WI0700012_Correspondence_20000918

DENR
DAMES-B. HUNT JR
*.;GOVERNOR
?BILL HOLMAN
...SECRETARY
Mr. Mario Kuhar
4 Hamilton Beach/Proctor-Silex, Incorporated
4421 Waterfront Drive
Glen Allen, VA 23060
r =t7
NORTH CAROLINA-DEPARTMENT-0F
ENVIRONMENT AND NATURAL. RESOURCES
September 18, 2000 DIVISION OF WATER QUALITY
Dear Mr. Kuhar:
In accordance with the application submitted on July 30, 1999 we are forwarding Permit
No. WI0700030. This permit is for the purpose of conducting a pilot study using the
CleanOX® Process at 234 Springs Road, Washington, North Carolina.
This permit, No. WI0700030, is a renumbering of Permit No. WI0700029, which
was issued on September 7, 2000, and shall be effective, unless revoked, from the
date of its issuance until September 30, 2005, and shall be subject to the conditions
and limitations specified in Parts I through VIII herein. This permit replaces and
shall also supersede Permit No. WI0700029.
This permit shall be effective from the date of issuance until September 30, 2005, and
shall be subject to the conditions and limitations stated therein, including the
requirement to submit a final project evaluation as stated in PART V -
MONITORING, REPORTING AND RECORD KEEPING REQUIREMENTS,
SECTION B: REPORTING. Three copies of the final project evaluation shall be
produced and submit one copy to the Undergroun njec ion ono rogram,
Groundwater Section, NC DENR-Division of Water Quality, 1636 Mail Service Center,
;. Raleigh, NC 27699-1636; the second copy submit to the Groundwater Section,
Washington Regional Office, 943 Washington Square Mall, Washington, NC 27889;
and the third copy submit to Kenneth Rudo, Ph. D. of the NC DHHS-Division of Public
Health, Occupational and Environmental Epidemiology Branch, 1912 Mail Service
Center, Raleigh, NC 27699-1912. You will also need to notify this office by telephone
48 hours prior to initiation of injection at this facility. If you have any questions
regarding your permit please contact me at [phone].
Sincerely,
mctitkp4
Mark Pritzl
Hydrogeological Technician II
Underground Injection Control Program
cc: CO-UIC Files
WARO-UIC Files
Enclosures
'F, ►Asr�
,„ AYGFt«A1
2 0 1 0
GROUNDWATER SECTION
1636 MAIL SERVICE CENTER, RALEIGH, NC 27699-1636 - 2725 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE SI9-733-3a/221 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 5096 RECYCLED/1O% POST -CONSUMER PAPER

ti
ICDENR
BILL'HOLMAN
.,SECRETARY
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
September 8, 2000
Mr. Mario Kuhar
Hamilton Beach/Proctor-Silex, Incorporated
4421 Waterfront Drive
Glen Allen, VA 23060
Dear Mr. Kuhar:
DIVISION OF WATER QUALITY
In accordance with the application submitted on July 30, 1999 we are forwarding Permit
No. WI0700029. This permit is. for the purpose of conducting a pilot study using the
CleanOX® Process at 234 Springs Road, Washington, North Carolina.
This permit shall be effective from the date of issuance until September 30, 2005, and
shall be subject to the conditions and limitations stated therein, including the
requirement to submit a final project evaluation as stated in PART V -
MONITORING, REPORTING AND RECORD KEEPING REQUIREMENTS,
SECTION B: REPORTING. Three copies of the final project evaluation shall be
produced and submit one copy to the Underground Injection Control Program,
Groundwater Section, NC DENR-Division of Water Quality, 1636 Mail Service Center,
Raleigh, NC 27699-1636; the second copy submit to the Groundwater Section,
Washington Regional Office, 943 Washington Square Mall, Washington, NC 27889;
and the -third copy submitIo%nne1kRudo Ph. D. of the NC DUBS -Division of Public
Health, Occupational and Environmental Epidemiology Branch, 1912 Mail Service
Center, Raleigh, NC 27699-1912. You will also need to notify this office by telephone
48 hours prior to initiation of injection at this facility. In order to continue uninterrupted
legal use of this injectant for the stated purpose, you should submit an application to
renew the permit three months prior to its expiration date.
If you have any questions regarding your permit please contact me [phone].
Sincerely,
Mati p.Z(
Mark Pritzl
Hydrogeological Technician II
Underground Injection Control Program
cc: CO-UIC Files
WARO-UIC Files
Radian Engineering Inc., James Narkunas, P.G.
Enclosures
4II,zs"T
+(Ne„cFlcs
1 0 1 0
GROUNDWATER SECTION
1636 MAIL SERVICE CENTER, RALEIGH, NC 27699-1636 - 2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE[phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

• NORTH CAROL.INA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
July 7, 2000
Mr. Mario Kuhar
Hamilton Beach/Proctor Silex
4421 Waterfront Drive
Glen Allen, VA 23060
Dear Mr. Kuhar:
DIVISION OF WATER QUALITY
The Groundwater Section attempted to complete the injection well application
process and CAP review by sending you a letter dated January 21, 2000 requesting
information and clarification of your submittals. Your enclosed responses are
unsatisfactory because they do not describe precautionary measures that are
sufficient to alleviate the stated concerns with the proposed Fenton's Reagent (FR)
technology. Specifically, the Groundwater Section has obtained EPA guidelines for
the use of FR technology. Basically, these guidelines call for a review of your site
as if it were an air sparging groundwater remediation system. This review process
will require the submission of detail plans for active measures to control potentially
explosive conditions, or more specifically to control excessive subsurface
temperature _pressure, oxygen and contaminant vapor migration. To date, your
application and response describes only passive measures for controlling these
processes, in spite of our efforts to describe and explain the necessity for active
measures in our January 21, 2000 correspondence to you.
Your responses to questions #1 & #2, under "Safety Review," and questions #3
& #5 under "Technical Review" in our January letter indicate that your passive vent
system has no provision to address many of the prevalent subsurface physical
conditions of this site. Our staff is particularly concerned that the subsurface is
known to be heterogeneous and anisotropic with numerous man-made preferential
pathways. Specifically, the precautions that you plan to implement to vent excessive
temperature, pressure, oxygen and contaminant vapors depend on the existence of a
homogeneous and isotropic subsurface. Since the subsurface exhibits neither of
these characteristics, your responses and proposed plans seem inapplicable to this
site. Therefore, our assertion would be that you have not demonstrated that you will
have control of the subsurface during the injection process.
epA'v LRsff CA �.r
N
2 0 1 0
GROUNDWATER SECTION
1636 MAIL SERVICE CENTER, RALEIGH, NC 27699-1636 - 2728 CAPITAL, BLVD., RALEIGH, NC 27604
PHONE [phone] FAX 919-71S-0588
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

rf
•
Before an injection well permit can be issued, the Groundwater Section will need you
to submit detailed plans to monitor and/or extract vapor. These plans will need to include, but
will not necessarily be limited to the following:
1. Identification of all nearby buildings, underground tanks, piping and utilities,
sewers, more permeable soil zones and any other anthropogenic or natural
features that could act as vapor migration pathways from treatment zones.
Information sources, such as local governments, utilities and "Before You Dig
Hotline" need to be contacted to determine the location of underground
features.
2. Development of a plan to monitor and control all potential vapor migration
pathways. The control plan will need to include a soil vapor extraction system
to prevent the migration of excessive subsurface temperature, pressure, oxygen
and contaminant vapors at each migration pathway.
If the requested information is not satisfactorily provided in writing within 45 days, all
permit application materials will be returned to your office. If you have any questions about
the requirements indicated in this letter, please contact Mark Pritzl at [phone] or Amy
Axon at [phone].
Sincerely,
Arthur Mouberry, P.E.
Chief, Groundwater Section
cc: James Narkunas, L.G., Radian Engineering
Willie Hardison, Washington Regional Supervisor, Groundwater Section

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HAMILfON BEACH m PROCTOR-SILEX, INC.
June 15, 2000
Mark Pritzl
North Carolina DENR-DWQ
Groundwater Section
Underground Injection Control Program
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
-- via facsimile --
Re: Additional Information
Response Submittal:
Review of Preliminary Corrective Action Plan, Addendum to Preliminary
Corrective Action Plan, and the Injection Well Permit Application for
C/eanOX Technology
Hamilton Beach/Proctor-Silex, Inc., Washington, North Carolina
Groundwater Incident No. 14338
Dear Mr. Pritzl:
I have enclosed for your review a copy of the following pages from the July 1998
on -site assessment report, which address the abandoned underground storage
tanks-(tiSTs).
1. Page S-3.
2. Pages 2-3 to 2-5.
3. Page 5-13.
4. Figure 2-3.
5. Table 2-1.
Also, I have enclosed the CleanOX case studies that were previously faxed to
you by Brett Berra, Radian International. Please note that more than one well is
used in the pilot tests.
If you have any further questions, please call me at 804/527-7222.
Sincerely,
Mario Kuhar
Sr. Environmental Engineer
Enclosures: As noted (12 pages).
Corporate Headquarters • 1-121 W i(uirnnt Drive • Glen Allcu. Virginia 23060 • It10-11lT;-II777

JUN 15 2000 01:37 FR HBPS DUALITY
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The hydrogeology of the site is characterized by a shallow groundwater reservoir
(Unit A), a surficial confining bed, a semi -confined aquifer (Unit B), and a lower (Yorktown)
confining bed. Groundwater in Unit A flows toward, and discharges into, the drainage ditch that
borders the active part of the kite on the east and south. Groundwater in Unit B flows, in the
opposite direction, toward the northwest. Vertical hydraulic gradients indicate that the site
overlies a groundwater recharge area, except at locations immediately adjacent to the drainage
ditch. The surficial confining bed that separates Unit A from Unit B appears continuous across
the site. However several monitoring wells previously installed near the source area have
penetrated this barrier. The Yorktown confining bed underlies Unit B and appears to be
continuous across the site.
Preliminary soil cleanup levels applicable to the site are the default values of
10 parts per million (ppm) for purgeable (gas) Total Petroleum Hydrocarbons (TPH), 40 ppm for
extractable (diesel) TPH, and 250 ppm for 0i1 and Grease. Chemical -specific "soil -to -
groundwater" target concentrations will also likely apply to the site. Preliminary cleanup goals
for Class GA (potentially potable) groundwater are the standards established under North
Carolina Administrative Code (NCAC) Title 15A, Subchapter 2t Si cfron . CStandards).
Soil in the source area exceeds established cleanup goals for TPH and for several
VOCs. Soil exhibiting elevated concentrations is primarily located adjacent to the former solvent
AST and encompasses an area approximately 60 feet by 60 feet in size. This area conceivably
extends beneath a portion of the plant building. Chemicals detected in soil outside this general
area are presumed to represent transport by groundwater and subsequent adsorption onto the soil.
Four abandoned underground storage tanks, formerly used to store gasoline, diesel fuel, and used
oil, appear to have had only an incidental effect, if any, on chemical distribution at the site.
Groundwater underlying the site exceeds the groundwater standards for certain,
predominantly, chlorinated volatile organic compounds. Groundwater also exceeds the standards
for certain semivolatile organic compounds; however, the extent of the semivolatile organics is
more limited. The volatile organic plume, originating at the source area, is present in both
aVnmiBmlartip rm (7l10198) It
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JUN 15 2000 01:38 FR HBPS QURLITY TO 9191971505B8 P.03/13
unpaved areas located farther south. Several smaller buildings and other structures are currently
located south of the plant building. They include a guard house, several storage sheds, and a
pump house associated with a 289,000 gallon water storage tank used for fire protection. Also
located here are electrical tranformers that service the facility, cooling towers, a solid waste
dumpster, two 550-gallon capacity ASTs containing gasoline and diesel fuel, a 1000-gallon
capacity AST containing Liquid Petroleum (LP) gas, and several closed USTs that are described
in Section 2.2.2.
A parcel of land located near the southwest corner of the plant building is used
exclusively by the City of Washington. This parcel of land is occupied by a 500,000-gallon
capacity, elevated water storage tank and a sewage lift station.
Solid waste generated by the facility consists of general production scraps, office
waste, floor sweepings, and packaging waste. The waste is placed in an on -site compacting
dumpster and removed regularly by a commercial waste hauler for proper disposal in a Subtitle 1)
landfill in Aulander, North Carolina. Metal and cardboard scrap are collected separately and sent
off site for recycling.
Wastewater, consisting of sanitary waste only, is discharged through the municipal
sewer system to the City of Washington Wastewater Treatment Plant (WWTP). The facility
does not generate process wastewater.
Stonnwater at the site is managed under the facility's stormwater permit. Runoff
at the facility is collected through a network of lined and unlined surface channels, drop inlets, and
subsurface pipes. It discharges into drainage ditches located along the north, east, and south sides
of the facility.
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2.2.1 Manufacturing Process
The facility is involved in the final assembly, packaging, and warehousing of small,
electric household appliances. Manufacturing processes include plastic injection molding and
building electronic subassemblies and electronic motors.
2.2.2 Chemical Use, Storage, and Handling
During the course of normal operations, various types of fuels, solvents, resins,
cleaning solutions, paints, thinners, adhesives, and sealers were used, and continue to be used, at
the facility. Also, some of the chemicals Used and the manner in which they were managed have
changed over time consistent with industry and regulatory standards. Current chemical use in . - -
terms of type and quantity is generally less than during other times in the facility's operating
• history. This section summarizes relevant information about present and past chemical usage and
management at the facility. The locations of all of the storage areas discussed below are
illustrated on Figure 2-3.
Diesel fuel and gasoline are currently stored in two 550-gallon ASTs located
within a partially covered, concrete, secondary containment area that adjoins the plant wall near
the building's southeast corner. Each AST rests on a metal cradle and is fitted with a metering
pump for dispensing the fuels. The two ASTs were installed in September 1986 to replace several
USTs that were abandoned. In the past, hydraulic oil and motor oil were also dispensed from 55-
gallon drums that were staged in the containment area next to the ASTs.
Prior to the installation of the two ASTs, gasoline was stored in one 1000-gallon
steel UST and diesel fuel was stored in two 4000-gallon steel USTs. The USTs, which were
registered to Waters Oil Company, are buried south of the plant building in the approximate
location shown on Figure 2-3. Several fuel dispensers were also reportedly located in this
immediate area. The diesel fuel tanks were installed in May 1973. The installation date of the
gasoline UST is unknown. In June 1979, a 1000-gallon used oil tank was installed in the general
area of the three fuel USTs and registered to Hamilton Beach. In January 1987, with the
a0emiaanhawptfin (7roro8) it
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concurrence of the Washington Regional Office (WaRO) of the North Carolina Department of
Environment, Health, and Natural Resources, Hamilton Beach abandoned the four USTs in -place
in general accordance with American Petroleum Institute Guidelines in effect at that time. The
USTs were triple rinsed with water after the product had been removed. The tops were then
removed and several holes drilled into each bottom. Each tank was then filled with washed sand.
All fill pipes were removed and vent pipes cut off and sealed. Subsequently, the top of the USTs
were covered with fill material and poured concrete. Table 2-1 summarizes the information
currently known about the four USTs.
Until 1984, an 8,000-gallon AST was located adjacent to the south wall of the
plant building. It was used to store No. 6 fuel oil for use in the plant boilers before the conversion
was made to natural gas. The tank rested on a cradle without secondary containment.
Although no longer used at the facility, 1,1, I-Trichloroethane (TCA) was
previously used to clean metal parts in the 1970s and 1980s. Most recently, the TCA was stored
in 500-gallon metal containers located next to the vapor degreaser. Prior to 1986, however, TCA
was stored in an AST located on a concrete pad adjacent to the south wall of the plant. A
concrete secondary containment dike was added to the pad sometime between the late 1970s and
early 1980s. TCA was delivered to the AST by tanker truck. A different degreasing solvent,
Trichloroethene (TCE), was reportedly used for parts cleaning and stored in the AST before the
conversion to TCA was made.
Isopropyl alcohol (IPA) and naptha were previously used in small amounts to also
clean parts and were stored in a dual -compartment AST that had a total capacity of approximately
2000 gallons. Until its removal in 1996, the tank was located within a covered, secondary
containment structure next to the hazardous materials storage shed.
Toluene was previously used during the period when motor cores were varnished
at the facility. Lacquer thinner was also used for cleanup in several processes. These chemicals,
together with varnish, which is still used at the facility, and miscellaneous other materials were
stored in drums in the hazardous materials storage shed. The shed consists of a roof over a
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5.4.5 Free Product
Free product was first detected in the source area in April 1997 when a layer of oil
more than three feet thick was measured in monitoring well MW-206. After a year of periodic
hand bailing followed by several rounds of AFVR, product thickness in May 1998 was measured
at about 0.01 foot. However, product accumulation may have been precluded by an elevated
water table at the time of measurement. Analysis of a product sample indicated that the oil
contains hydrocarbons in both the diesel and motor oil ranges and has a specific gravity of 0.9595
g/cm3 (Radian International, 1997).
Although oil has not been detected in any monitoring well other than MW-206, it
has been reported in a subsurface pipe that was part a former roof drain system for the plant - -
building. The drain pipe transects the source area and is located about 40 feet east of well MW-
206. CPT probing performed in the source area with a FFD did not detect levels of TPH in the
soil that would be indicative of free product. The FFD results were confirmed by soil sampling
and analysis that indicated a limited area of petroleum hydrocarbons at concentrations exceeding
CUGs, but-not_atlevelasuggesting-ihapresence-of free-product_Consequently,-the-extent-of free
product appears to be limited to an area between well MW-206 and the former drain pipe, and
located within 40 feet of the plant building's south wall. Therefore, the former USTs that are
buried approximately 40 feet to the west of MW-206 do not appear to be the source of the free
product.
5.5 Results of Surface Water Sample Analysis
This section presents the results of surface samples analyzed for the parameters
listed in Table 5-1. Each subsection addresses the results for a specific analytical group and is
supplemented by a table summarizing the qualified laboratory results. Data upon which
interpretations are made were evaluated based on USEPA Contract Laboratory Program National
Functional Guidelines for Organic Data Review (1994). Qualified analytical data and raw
analytical data are included in Appendices C and D, respectively.
c %amamntr ipl.do (7(9/98)1a
650138.0501 5-13

n
6\HBPS\SZ7C•00
7
Parking
Guard House
PLANT BUILDING
Former rue
(removed)
Former Solvent
(removed)
Petroleum ASTh (dik
Shed
' Hazardous ktoleriats
Storage Shed
Farmer IP
Naptha AS
AST
Employee
Parking
-Pump :louse
Hazardous Waste
Storage Shed
LPG AST
)1
Loedfurming Area
LEGEND
Q Building
rL Road and/or Parking Area
v
—'— Property Line
"--•- Fenceline
Ditch
Qn Water Tank
Cooling Tower
m Transformers
AST Aboveground Storage Tent
UST Underground Storage Tank
200 0
nweemli
SCALE IN FEET
ID
AS SIUiI
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JUN 15 2000 01:39 FR HBPS
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JUN 15 2000 01:39 FR HBPS QUALITY
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Table 2-1
Summary Table of Underground Storage Tanks
Hamilton BeachOProctor-Silez, Washington, North Carolina
0-00294a
Waters Oil Company
4,000
Diesel Fuel
3/73
1187
0-002948
Waters Oil Company
4.000
Diesel Fuel
3/73
1/87
0-002855
Waters Oil Company
1,000
Gasoline
NA
0-023693
Hamilton Beach
1,000
Used Oil
6/79
1/87
No evidence of product release was documented in the available records.
NA = Not Available.
Y C:WM9L1VMWSIOIGTMSA .RP13PWA LTABLHSTABLa7.1

JUN 15 2000 01:39 FR HHPS QUALITY
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klanT001 Environmental Corporation CleanO.X6 Qualifications
CLEANOX® CASE STUDY
CHLORINATED SOLVENTS IN BEDROCK
CIRCUIT BOARD MANUFACTURER, MASSACHUSETTS
ManTech Environmental Corporation (ManTech) conducted a pilot study to determine the •
destruction potential of the CleansX® Process in romediating chlorinated solvents in the
saturated glacial till and bedrock aquifer below a circuit board manufacturing plant north of
Boston. Chlorinated solvents, primarilytrichloreethane (TCA) were detected in the groundwater
perched above and residing within the glacial till and bedrock aquifer at the site. Hydraulic
conductivity was estimated to range from 104 to 10's ernlsec.
ManTech assisted the primary consultant during the second phase of the site investigation
project in specifying and locating dual-purpose monitoring wells. One purpose of the additional a
well installation was to further delineate the TCA source area below the plant's water treatment 4
area. By constructing steel wells and by placing the screened interval appropriately, the
additional wells could be used for pilot testing the Cleano)(® Process, for continued monitoring
of groundwater conditions at the site, and for soil vapor extraction.
Following well installation and data review, Msntech also assisted in preparing the pilot testing 1
Work Plan for review and approval by the State regulators. ManTech then mobilized equipment, i
personnel, land Materials to the site and completed several cycles of treatment to four of ten i
wells. Wells that were not used for treatment served as off -ant monitoring points and as vapor I
extraction points to monitor and control process vapor migration, If necessary. During the
course of the pilot test application, ManTech measured various groundwater parameters such
as pH. temperature, dissolved oxygen, specific conductance, and oxidation-reduction potential i
to gauge the radial influence of CleanOxe reagents. These data, combined with an evaluation
of pre- end post -treatment volatile organic compound (VOC) data, were used as the basis for 1
determining the effectiveness of the treatment, estimating thew -attics ofinfluence Ofthe treatment 4
wells, and designing the full-scale treatment of the source area atthe site.
Post -treatment contaminantconcentrations remained above regulatory standards, and the pilot
test was successful in significantly degrading contaminants In the source area end in obtaining*
the design parameters needed for full-scale source removal. Thefull-scaletreatmentto achieve
90% contaminant destruction over the approximately 5,000 square feet source area is planned tl
for implementation In the first quarter of 2000. A summary of the pilot teat reoutts is presented i
below:
4
• •
-Pre-PllotTCA (Debt '•
Post -Pilot TCA (peb)
• ^ %'Reduction. •
Avg. application Well
Concentration
347,500
,
64,30D
81 %
Avg. Off -Set Well
Concentration (-15 ft)
570,000
205,000
_
84%
Avg. Off -Set Welt
Concentration
(20-3O ft)
414,51)0
252,500
40%
4
i
4
i
'a
4
1
1
28
i
1
JUN 14 2000 07!11
9194611371 PAGE.02

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ManTech Environmental Carportatien
CfeanoX° Oualilicafians
CLEANOX0 CASE STUDY
CHLORINATED VOLATILE ORGANIC COMPOUNDS AT AN ACTIVE INDUSTRIAL FACILITY
CLIFTDN, New JEnaWzr
Ol'eanOXe In -alto ohemlcal oxidation was applied using application wells inside an operating
feeillty Where an underground storage tank (UST) had 0 solvent retinae of approximately 600
gallons over five years or more. The most heavily impacted portion of the groundwater plume
was located below the building with the average total volatile organic compounds (VOCS)
detected at 44,000 ug/I; and 1,1,1-trichloroethane was detected at 101,000 ug/I in One
monitoring well. An existing groundwater pump and treat system wag located outside the
building and had operated for a five year period with moderate reduction in contaminant
concentrations. Due to high iron metabolizing bacteria at the alto, the pump and treat system
was plagued with frequent operations and maintenance (O&M) problems.
The CleaniaXsin-seuchemlcal oxidation application was complicated by the heterogamous and
highly stratified aquifer lithology and by naturally occurring interferences such as high organic
carbon concentrations in groundwater. Aquifer permeability wee estimated ati millidarcy and
conductivity was estimated at 10d cm/s. Site soils having low permeability and conductivity
necessitated muwple application points to cover the proposed 100,000 square foottreatment
area. Interferences such as naturally occurring organic carbon were factarad in determining
the appropriate application dosage rate because organic carbon will partially consume the
applied oxidants.
After confirming reactivity of the contaminants and the site geochemistry during a bench test,
a limited field application was conducted in the field using an existing well. Analysis of the
groundwater sample from the glasnost determined that 1,1.dichloroetmene was red ucedfrom
14,000 ug/I to 710 ug/1 and 1,1,1-trichloroethane decreased from 79,000 ugll to 1,300 uge
Forthe full-scale application, twelve, four -inch diameter, PVC wells were installed Into fractured
bedrock overa i 00,000 square footarea underneath the facility building. The application wells
were screened 10 to 30 feet below grade. Chemical additions were applied over a three weak
period resulting in Iewaring total volatile organic compound concentration from an average of
44,000 ugll down to 15,000 ugll and 1,1,1-triohleroethane concentration in the most
contaminated well from 101,000 ug/I to 2,000.ugll.
' ..•
: 1 1,'1 Trlchloro ane ConCeffrallon u'WL)', •; `'- •.:
f ILQT-SdALE ...
- :;'i; FULL'rSCAllE r..":, ',' .;.
...' INITIAL ;,.:.: ,,,
'.r' .„FINAL .,::1..
4:7::aNTAL';:_
'.. ..:• ; FINAL :' „r ..
Average
NA
NA
44,000 ,
• 15,000
Highest
Concentration
Well
70,000
1,300 '
101,000
2,000
A second full-sca e application of the CleanOX0 process ig required to further reduce the
chlorinated solvents to achieve MCI-.
13
JUN 14 2000 07:11
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MenTeeh Envlrenmental Corporation
Ckwnot ousrilkaticns
CLEANOXS CABE brunt
LIGHT Nos-AQUEous-PRASE LIQUIDS AT AN ABANDQNen INCUSTRIAL FACRn
BOSTON, MASSACHUSETTS
The Cleaner in -situ chemical oxidation process was applied at an abandoned facility for
remediation of light, non -aqueous -phase liquids (LNAPL) detected et the site. The former
industrialfaollkywes undergoing redevelopment by a propertydeveloper, end LNAPL removal
was required to keep the redevelopmentecheduleon-traok. ManTech was contracted by the
developer to address the LNAPL as an interim remedial measure. Only four months were -
�, required to complete the project, from the time ManTeoh was first contacted through the
completion of the field application of the CleanOX° Process.
LNAPL was encaunlnedduringremovaloftheundergroundstoragetank(UST)usedtostore
No. 2 fuel oil. The UST was located outside the boiler room wall and subvaqucnt assessment
activities showed that the LNAPL had migrated under the building foundation. The LNAPL
plume was eotimatedatapproximately 2,000aqua refeet. LNAPL thicknesswas highest atthe
formertank bed (well WC-5) at 1.5 feet and was measured at 2 to 4 inches over the rest of tha
impacted area. The geology underlying the site was characterized asins-grained sand with
lenses of silty. tine sand and silt, and trace clay. The hydraulic conductivity of subsurface soil
was estimated using slug tests at3.6 x 104cm/sec. Regionally, bedrock exists at en estimated
depth cf 80 to 100 feet below ground surface (bgs). The depth to groundwater at the site wes
measured at approximately 20 feet bgs. Further, the basement of the on -site building was
approximately 15 feet below grade, making the depth to groundwater under the building
(where LNAPL had migrated) five feet.
LNAPLmeasurementswere made over atwo-week stabilization period. Moatwellswere found
to have a slight sheen of LNAPL, and the tankbed welLhadiess-than- one -foot of-LNAPL. A
second cycle of CleanOX®treatment was implemented focusing more on the tank bed area
where LNAPL thickness was the greatest. Monitoring that was performed following the
second application cycle indicated that no measurable product was detected in any of the site
wells. Groundwater sampling and analysis waS then conducted for use in risk analysis.
Cased on the risk analysis results, a Massachussetts Licensed Site .Professional has
determined that no further actions are needed et the site, Urpundwateranalytical results for
two key compliance wells are summarized below:
3
0
:Afro r- .
MM yr-
LNAP.
thickness
C9413
Apwet:oe
t 10.Cae
AlipMbs
911-crt
a rnalieA
,wv;
?r. -/1Afoglr:PgQ
+' hY+�6trnilY10C4
sso.aon
46,000
Nano
240
None
140
230 415
UAW 0.76 Fcet
170.000 60,000
54000 1t,000
.44.000 14,000
Norco
15,000
4.=OO
5.600
• 11
JUN 14 2000 07:12
9194611371 PRGE.04

JUN 15 2000 01:42 FR HERS QUALITY
TO 919197150508
P.12/13
SUPPLEMENTAL DETAILS TO CLEANOX® CASE STUDIES
Circuit Boar&Manufaeturer, Massachusetts
• Point of Contact: Joe Fiacco, P.G. (ERM), 617-646-7840.
• Pilot test was completed in the fall of 1999. Four application wells were treated over
three separate 1-week periods.
• Fullscale application was completed in April 2000. Nine wells were treated over three
separate 2-week periods (final data due in June 2000)
• Depth to groundwater ranges from approximately 3 to 20 feet below, ground surface.
Geology consists of tan, medium grained sand fill material below the buildings concrete slab to a
depth of about 10 feet bgs. The fill material is underlain by glacial till material consisting of
olive -brown. fine-grained sand from approximately 10 to 20 feet bgs. The till grades very
quickly to a moderately fractured Gneiss bedrock at about 20 feet bgs. Bedrock integrity
generally increases while the degree of weathering decreases with depth.
Groundwater flow at the site is primarily driven by the infiltration of recharge onto the hilltop
where the site is located. The amount of direct recharge is limited by the presence of buildings
and paved parking lots. Limited perched zones may exist in the areas between the two buildings,
as recharge infiltrates through the fill and becomes perched on top of the glacial till or bedrock.
Saturated zones in the till are locally perched over competent bedrock and appear to be restricted
to areas where the depth to bedrock is greatest. Groundwater flows to the north-northeast at the
site. Drawdown tests provided hydraulic conductivity estimates of 0.03 tt/day minimum and 3
ft/day maximum.
Site investigations identified the presence of chlorinated volatile organic compounds including
TCA and-DCE in groundwater and both saturated and unsaturated soils within the lower portion
of the glacial till unit and within the upper, fractured portion of the underlying gneiss. The
highest concentrations of TCA and DCE appear to be isolated to an area beneath Building A, just
west of a wastewater treatment room.
The shallow bedrock aquifer at the site is of very low yield. Groundwater within the defined
area of impact is present at depths of 18 to 20 feet bgs.
Xndustrial Facility, Clifton, New Jersey
• Point of Contact: Ken Cottrell, P.G. (TetraTech NUS), 301-258-8557
• Project completed as CleanOX Environmental Services (prior to ManTech's acquisition
of the C1ean0Xv technology).
• Depth to groundwater approximately 15 feet.
• Application completed both inside and immediately outside building.
The uppermost unconsolidated materials at the site generally consist of fill material (1 to 5 feet)
and glacial till composed of sands and gravels with some silts and clays. Depth to the weathered
JUN 14 2000 07:12
9194611071 PRGE.05

JUN 15 2000 01:42 FR HBPS QUALITY
TO P19197150568 P.13/13
and fractured shale and sandstone vary across the site from approximately 3 to 20 feet below
grade.
Abandoned Industrial Facility, Boston. Massachusetts
• Point of Contact: Rob McGrath (Woodard & Curran), 781-251-0200
• Applications wells and passive vent points were installed both inside and outside the
building. Inside wells were drilled and installed from the first floor and cased through the
basement,
• Four to Six application wells were treated for two 2-week periods
• The site was closed by a Licensed Site Professional within 2 months of C1eanOX4'
treatment.
• Application covered an area of was approximately 3,000 square feet.
The geology at the site consists of fill materials overlying sand and glacial till. Approximately
three to five feet of sandy fill overlie a gray and brown medium to fine sand. Glacial till,
consisting of dense silt, sand, and gravel, is present approximately 16 feet below ground surface
(bgs). Groundwater occurs approximately 19 bgs. The basement of the building extends to a
depth of approximately 15 feet bgs. Groundwater occurs approximately 3 to 5 feet below the
basement floor,
JUN 14 2000 07112
9194611371 PAGE.05
** TOTAL PAGE.13 **

JAMESB. HUNT JR,-
GOVERNOR
BILL"HOLMAN
':SECRETARY
--
KERR',T.-STEVENS"
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Jan 21, 2000
(CERTIFIED MAIL
RETURN RECEIPT REQUESTED)
%Mr. Mario Kuhar
Hamilton Beach Proctor Silex
4421 Waterfront Drive
Glen Allen, Virginia 23060
DIVISION OF WATER QUALITY
RE:' Review of Preliminary Corrective Action Plan, Addendum to Preliminary
Corrective Action Plan and the Injection Well Permit Application for
C1eanOX® Technology
Hamilton BeachcProctor Silex Incorporated Facility
Washington, Beaufort County, North Carolina
Groundwater Incident No. 10433
Dear Mr. Kuhar:
After having reviewed your Injection Well Permit application for CleanOX®
Technology dated July 30, 1999, the Preliminary Corrective Action Plan dated July
28, 1999 and the Addendum tojhe Preliminary Cnrrerrive Arrion Plan -dated October
25, 1999, the Groundwater Section has determined that the application and the plans
are incomplete. The following additional information must be received in writing
before the Groundwater Section can review both documents and make a final decision.
j Your written response to these concerns can take the form of a single document which
can then be included in both the application and the Corrective Action Plan proposal.
SUMMARY
The Groundwater Section's main concern about the proposed injection of
hydrogen peroxide into an area containing both chlorinated and petroleum
hydrocarbon contamination is that the resulting oxidation reaction will produce an
explosive mixture of subsurface heat, pressure and oxygen. Additionally, the process
yields an undesirable increase in carbon dioxide, chloride ions and acids; and the
permit application does not adequately characterize the contamination plume. The
Groundwater Section has organized its concerns into the two categories of safety and
technical review.
rAEPT
2 0 n 0
GROU.HDWATER SECTION
1636 MAIL SERVICE CENTER, RALEIGH, NC 27699-1638 -2728 CAPITAL, BLVD., RALCIOH, NC Z76O4
PHoNE[phone] FAX 919-71S-9583
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - 5O% RCCVCLCO/I O% POST-CONSUMCR PAPER

SAFETY REVIEW
The Groundwater Section is concerned about the safety of using in -situ chemical
oxidation in an area of relatively complex geology where geologic and manmade
preferential pathways exist under extensive asphalt and concrete surfaces. The proposed
injection of hydrogen peroxide to oxidize the organic hydrocarbon contamination will
produce an increase in subsurface temperature, pore pressure, and concentrations of
oxygen, carbon dioxide, chloride ions and acids.
1. Explain how you will control the development of subsurface by-products so as to
prevent an explosion.
2. Explain how you will control or vent excessive subsurface temperature and gases
under areas extensively covered by asphalt and concrete. The Groundwater Section is
concemed that the proposed passive vent points may be inefficient at venting excessive
pressure, since most of the subsurface is very heterogeneous and anisotropic. Specific
construction and/or placement details for the passive vent points should be included
along with your explanation.
1.
TECHNICAL REVIEW
You propose injecting into the unsaturated zone to oxidize the organic
hydrocarbon contamination that exists in the source area soils. The use of CleanOX'�
technology to oxidize or destroy the organic hydrocarbon contamination requires the
addition of hydrochloric acid to bring the injected soil -matrix to a pH of less than 4, and
the addition of ferrous ions to catalyze hydroxyl radical formation. How will you insure
the occurrence of mixingin-the-unsaturated-zouc tu piomote full oxidation -of the
hydrocarbon contamination by the hydroxyl radicals?
2. The Injection Well Permit application has incomplete or insufficient plume
characterization of the chlorinated and petroleum hydrocarbons that exist in the
subsurface at this site. Specifically, your Injection Well Permit application does not
show horizontal and vertical delineation with isoconcentration lines as required by
NCAC 15A 2C .0211(d)(3)(B) (iv). The Groundwater Section requires pre -injection
delineation for comparison with post -injection data in its assessment of the effectiveness
of your proposed in -situ chemical oxidation degradation technology.
3. During the injection process, what specific measures or hydraulic controls will be
used to prevent migration of both the hydrocarbon contamination and oxidation by-
products into areas where groundwater is not contaminated? What hydraulic controls
will be used to prevent hydrocarbon contamination or injection by-products from
reaching nearby water supply wells?"
4 Present a detailed proposed monitoring schedule and develop contaminant
reduction goals which will monitor the success of the in -situ chemical oxidation
technology.

5. The proposed injection area is directly under the Plant Building's foundation.
What actions will be taken to ensure that the formation of increased subsurface
temperature, pressure, oxygen, carbon dioxide, chloride ions, acids and other by-
products will not impact the integrity of the Plant Building's foundation and underlying
soil matrix?
6. You have submitted two Injection Well Permit applications that make use of in -
situ chemical degradation technologies. However, one submitted Injection Well Permit
application makes use of chemical oxidation technology, (CleanOX®,) and the other
makes use of chemical reduction technology, (Zero Valence Iron.) Since both of your
proposed injection systems are in close proximity of each other, how will these systems
be hydraulically controlled so as not to physically or chemically interact? If these two
systems do interact, how will this affect both in -situ chemical degradation technologies?
Please respond in writing to the items above within 45 days of receipt of this
letter. The Groundwater Section is prepared to meet with you to discuss these safety and
technical concerns. In the meantime, please direct questions to Keith Starner at (252)
946-6481 regarding the CAP, or Mark Pritzl for matters regarding the Injection Well
Permits and associated pilot tests, at [phone].
Sincerely,
Arthur Mouberry, P.E.
Chief, Groundwater Section
cc: Radian Engineering
WaRO

N :DENR
JAMES B. HUNT JR:
GOVERNOR
BILLHOLMAN
SECRETARY
KERRIT.. STEVEN9
DIRECTOR
1¢
iJ
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL. RESOURCES
Jan 21, 2000
(CERTIFIED MAIL
RETURN RECEIPT REQUESTED)
Mr. Mario Kuhar
Hamilton Beach Proctor Silex
4421 Waterfront Drive
Glen Allen, Virginia 23060
DIVISION OF WATER QUALITY
RE: Review of Preliminary Corrective Action Plan, Addendum to Preliminary
Corrective Action Plan and the Injection Well Permit Application for
CleanOX® Technology
Hamilton BeachOProctor Silex Incorporated Facility
Washington, Beaufort County, North Carolina
Groundwater Incident No. 10433
Dear Mr. Kuhar:
After having reviewed your Injection Well Permit application for CleanOX®
Technology dated July 30, 1999, the Preliminary Corrective Action Plan dated July
28, 1-999 and-the-Addendum-to-the-Preliminary-Coneutixe-Action_Elan-dated October
25, 1999, the Groundwater Section has determined that the application and the plans
are incomplete. The following additional information must be received in writing
before the Groundwater Section can review both documents and make a final decision.
Your written response to these concerns can take the form of a single document which
can then be included in both the application and the Corrective Action Plan proposal.
SUMMARY
The Groundwater Section's main concern about the proposed injection of
hydrogen peroxide into an area containing both chlorinated and petroleum
hydrocarbon contamination is that the resulting oxidation reaction will produce an
explosive mixture of subsurface heat, pressure and oxygen. Additionally, the process
<.. yields an undesirable increase in carbon dioxide, chloride ions and acids; and the
l permit application does not adequately characterize the contamination plume. The
Groundwater Section has organized its concerns into the two categories of safety and
technical review.
FfRSr
•/Y IYCt 1:A n
2 A I O
GROUNDWATC$ SECTION
1636 MAIL SERVICE CENTER, RALEIOH, NC 27699-1836 - 2728 CAPITAL, ULVO-, RALEIOH, ,NC 27604
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10 YOOT- onsuw.ER HPER

SAFETY REVIEW
The Groundwater Section is concerned about the safety of using in -situ chemical
oxidation in an area of relatively complex geology where geologic and manmade
preferential pathways exist under extensive asphalt and concrete surfaces. The proposed
injection of hydrogen peroxide to oxidize the organic hydrocarbon contamination will
produce an increase in subsurface temperature, pore pressure, and concentrations of
oxygen, carbon dioxide, chloride ions and acids.
1. Explain how you will control the development of subsurface by-products so as to
prevent an explosion.
2. Explain how you will control or vent excessive subsurface temperature and gases
under areas extensively covered by asphalt and concrete. The Groundwater Section is
concerned that the proposed passive vent points may be inefficient at venting excessive
pressure, since most of the subsurface is very heterogeneous and anisotropic. Specific
construction and/or placement details for the passive vent points should be included
along with your explanation.
TECHNICAL REVIEW
1. You propose injecting into the unsaturated zone to oxidize the organic
hydrocarbon contamination that exists in the source area soils. The use of C1eanOX°
technology to oxidize or destroy the organic hydrocarbon contamination requires the
addition of hydrochloric acid to bring the injected soil -matrix to a pH of less than 4, and
the addition -of -ferrous -ions -to -catalyze -hydroxyl -radical -formation. How will you insure
the occurrence of mixing in the unsaturated zone to promote full oxidation of the
hydrocarbon contamination by the hydroxyl radicals?
2. The Injection Well Permit application has incomplete or insufficient plume
characterization of the chlorinated and petroleum hydrocarbons that exist in the
subsurface at this site. Specifically, your Injection Well Permit application does not
show horizontal and vertical delineation with isoconcentration lines as required by
NCAC 15A 2C .0211(d)(3)(B) (iv). The Groundwater Section requires pre -injection
delineation for comparison with post -injection data in its assessment of the effectiveness
of your proposed in -situ chemical oxidation degradation technology.
3. During the injection process, what specific measures or hydraulic controls will be
used to prevent migration of both the hydrocarbon contamination and oxidation by-
products into areas where groundwater is not contaminated? What hydraulic controls
will be used to prevent hydrocarbon contamination or injection by-products from
reaching nearby water supply wells?"
4. Present a detailed proposed monitoring schedule and develop contaminant
reduction goals which will monitor the success of the in -situ chemical oxidation
technology.

5. The proposed injection area is directly under the Plant Building's foundation.
What actions will be taken to ensure that the formation of increased subsurface
temperature, pressure, oxygen, carbon dioxide, chloride ions, acids and other by-
products will not impact the integrity of the Plant Building's foundation and underlying
soil matrix?
6. You have submitted two Injection Well Permit applications that make use of in -
situ chemical degradation technologies. However, one submitted Injection Well Permit
application makes use of chemical oxidation technology, (CleanOX®,) and the other
makes use of chemical reduction technology, (Zero Valence Iron.) Since both of your
proposed injection systems are in close proximity of each other; how will these systems
be hydraulically controlled so as not to physically or chemically interact? If these two
systems do interact, how will this affect both in -situ chemical degradation technologies?
Please respond in writing to the items above within 45 days of receipt of this
letter. The Groundwater Section is prepared to meet with you to discuss these safety and
technical concerns. In the meantime, please direct questions to Keith Starner at (252)
946-6481 regarding the CAP, or Mark Pritzl for matters regarding the Injection Well
Permits and associated pilot tests, at [phone].
Sincerely,
Arthur Mouberry, P.E.
Chief, Groundwater Section
cc: Radian Engineering
WaRO

NCDENR
JAMES,B. HUNT
GOVERNOR ;W��s:S (CERTIFIED MAIL
RETURN RECEIPT REQUESTED)
BILCHOLMAN
SECRETARY
KERRT.:STEVENS-
":
DIRECTOR %aY:�jy} RE:
tlyei
Mr. Mario Kuhar
Hamilton Beach Proctor Silex
4421 Waterfront Drive
Glen Allen, Virginia 23060
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL. RESOURCES
DIVISION OF WATER QUALITY
Jan 21, 2000
Review of Preliminary Corrective Action Plan, Addendum to Preliminary
Corrective Action Plan and the Injection Well Permit Application for
CleanOX® Technology
Hamilton BeachOProctor Silex Incorporated Facility
Washington, Beaufort County, North Carolina
Groundwater Incident No. 10433
Dear Mr. Kuhar:
After having reviewed your Injection Well Permit application for CleanOX®
.J Technology dated July 30, 1999, the Preliminary Corrective Action Plan dated July
28—}999-and-the-Addendum-to-fhc Preliminary-Correetive Action -Plan dated Oc-tober
25, 1999, the Groundwater Section has determined that the application and the plans
.-'�'eare incomplete. The following additional information must be received in writing
:
3j.1 before the Groundwater Section can review both documents and make a final decision.
� ,�� Your written response to these concerns can take the form of a single document which
can then be included in both the application and the Corrective Action Plan proposal.
SUMMARY
4
The Groundwater Section's main concern about the proposed injection of
3 hydrogen peroxide into an area containing both chlorinated and petroleum
=i hydrocarbon contamination is that the resulting oxidation reaction will produce an
;�_.�
. ,
�explosive mixture of subsurface heat, pressure and oxygen. Additionally, the process
t yields an undesirable increase in carbon dioxide, chloride ions and acids; and the
:,:sYj permit application does not adequately characterize the contamination plume. The
Groundwater Section has organized its concerns into the two categories of safety and
sz
` technical review.
asa
•FIRST
/.! AMLLICA
2 0 1 0
GROONDWATCR SECTION
1636 MAIL SERVICE CENTER, RALEIGH, NC 2769E-1636 - 2728 CAPITAL, BLVD., RALEIGH/ NC 27804
PHONE [phone] FAX 9 t 9.715-0588
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYCR - 50% RECYCLED/1O% POST-CONSLMCN PAPER

SAFETY REVIEW
The Groundwater Section is concerned about the safety of using in -situ chemical
oxidation in an area of relatively complex geology where geologic and manmade
preferential pathways exist under extensive asphalt and concrete surfaces. The proposed
injection of hydrogen peroxide to oxidize the organic hydrocarbon contamination will
produce an increase in subsurface temperature, pore pressure, and concentrations of
oxygen, carbon dioxide, chloride ions and acids.
1. Explain how you will control the development of subsurface by-products so as to
prevent an explosion.
2. Explain how you will control or vent excessive subsurface temperature and gases
under areas extensively covered by asphalt and concrete. The Groundwater Section is
concerned that the proposed passive vent points may be inefficient at venting excessive
pressure, since most of the subsurface is very heterogeneous and anisotropic. Specific
construction and/or placement details for the passive vent points should be included
along with your explanation.
1.
TECHNICAL REVIEW
You propose injecting into the unsaturated zone to oxidize the organic
hydrocarbon contamination that exists in the source area soils. The use of CleanOX®
technology to oxidize or destroy the organic hydrocarbon contamination requires the
addition of hydrochloric acid to bring the injected soil -matrix to a pH of less than 4, and
the addition -of -ferrous -ions -to -catalyze -hydroxyl radical -formation How -will you insure
the occurrence of mixing in the unsaturated zone to promote full oxidation of the
hydrocarbon contamination by the hydroxyl radicals?
2. The Injection Well Permit application has incomplete or insufficient plume
characterization of the chlorinated and petroleum hydrocarbons that exist in the
subsurface at this site. Specifically, your Injection Well Permit application does not
show horizontal and vertical delineation with isoconcentration lines as required by
NCAC 15A 2C .0211(d)(3)(B) (iv). The Groundwater Section requires pre -injection
delineation for comparison with post -injection data in its assessment of the effectiveness
of your proposed in -situ chemical oxidation degradation technology.
3. During the injection process, what specific measures or hydraulic controls will be
used to prevent migration of both the hydrocarbon contamination and oxidation by-
products into areas where groundwater is not contaminated? What hydraulic controls
will be used to prevent hydrocarbon contamination or injection by-products from
reaching nearby water supply wells?"
4. Present a detailed proposed monitoring schedule and develop contaminant
reduction goals which will monitor the success of the in -situ chemical oxidation
technology.

5. The proposed injection area is directly under the Plant Building's foundation.
What actions will be taken to ensure that the formation of increased subsurface
temperature, pressure, oxygen, carbon dioxide, chloride ions, acids and other by-
products will not impact the integrity of the Plant Building's foundation and underlying
soil matrix?
6. You have submitted two Injection Well Permit applications that make use of in -
situ chemical degradation technologies. However, one submitted Injection Well Permit
application makes use of chemical oxidation technology, (CleanOX®,) and the other
makes use of chemical reduction technology, (Zero Valence Iron.) Since both of your
proposed injection systems are in close proximity of each other; how will these systems
be hydraulically controlled so as not to physically or chemically interact? If these two
systems do interact, how will this affect both in -situ chemical degradation technologies?
Please respond in writing to the items above within 45 days of receipt of this
letter. The Groundwater Section is prepared to meet with you to discuss these safety and
technical concerns. In the meantime, please direct questions to Keith Stamer at (252)
946-6481 regarding the CAP, or Mark Pritzl for matters regarding the Injection Well
Permits and associated pilot tests, at [phone].
Sincerely,
Arthur Mouberry, P.E.
Chief, Groundwater Section
cc: Radian Engineering
WaRO

05/19/1999 10:34 2529468961 GROUNDWATER PAGE 01
Ara
NCDENR
NCRm Guouxa DORMS/AMC Or
ENVIRONMENT ..O NATURAL RESOURCES
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WASHINGTON REGIONAL OFFICE
DIVISION OF WATER QUALITY
Groundwater Section
943 WASIi1NGTON SQUARE MALL
WASHINGTON NC 27889
PHONE [phone] FAX [phone]
TO: AMY AXON
FAX NUMBER:
FROM: IL E ITI4 5T A RN
DATE: 51IG �49
NO. PAGES (including-cover-pagc)
COMMENTS: AM'(: PLEASE MAKE COMMFTITS
RECTA 2nwi& THE "CARFR1L&'( 12,E'S_ 1 QLHt118
tJ rMNOCarru S lz.E5 erlarnIcEn IN THIS
OUR FAX 4i is (164 �`i % g4 (p 1
s Hi Iq9
Lj i It ke—. W ri ' T1)L 4 at rrr_
oi
71
ic, CA1 (11 k al i 9
rush', n 1CY

FQ5/19/1999 10:34 2529400gf1
GROUNDWATER
PAGE 02
0-
RADIAN INTERNATIONAL
April 30, 1999
Mr. Keith Starner
NCDENR
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
SUBJECT: Corrective Action Plan (CAP) Schedule
Hamilton Beach0Proctor-Silex Facility
Washington, Beaufort County, North Carolina
Groundwater Incident No. 14335
Dear Mr. Starner:
- 3 1999
WASHINGTON REGIONAL OFFICE
owa
Radian International, on behalf of Hamilton Beacb Proctor-Si1ex, Inc., is requesting an
extension for submitting the referenced CAP consistent with the attached schedule. Justification
for the request is provided below.
Radian International (Radian) has carefully researched the options for remediating soil and
groundwater in hydrogeologic units A and B at the Hamilton Beach -Proctor Silex facility in
Washington, NC. The alternatives have been narrowed down to several in -situ treatment
technologies. The vadose zone contamination in the -source -area -will --be addressed through the
application of chemical oxidation (Fenton's reaction via the CleanOX process) or through soil
washing using a biodegradable surfactant. Chemical oxidation and/or zero -valence iron and
molasses injection will be utilized to attack the saturated zone contamination in the source area.
Following source reduction, there are several available options for treatment of the dissolved
plume in hydrogeologic units A and B. A combination of Hydrogen Release Compound (HRC)
and Oxygen Release Compound (ORC) or zero -valence iron with molasses will be injected to
address all dissolved contaminants outside of the source area. Successful full-scale
implementation of any of these in -situ applications requires bench and pilot scale testing to
optimize design parameters. The following paragraphs describe the general approach for bench
and pilot scale testing for any of the proposed technologies.
Bench scale testing will consist of sampling soil and groundwater from the two affected
hydrogeologic units on -site and applying the treatment technology(s) in a laboratory setting.
After recording measured parameters and observations, the samples will be analyzed and a report
of the results will be prepared,
Based on the results of the bench scale test, a Work Plan and Health and Safety Plan for
conducting a pilot test will be developed. A pilot test will consist of the application of the
proposed technology(s) through injection points/wells in both hydrogeologic units. A
combination of existing wells and newly installed piezometers will be used to measure the
1

95/19/1999 10:34 2529468961 GROUNDWATER PAGE 03
effectiveness of the treatment during the pilot application. Baseline soil and groundwater
samples will be collected and analyzed prior to applying the pilot test treatment technology.
Appropriate parameters will be measured during the application process, and post -treatment
samples will be collected for laboratory analysis. Finally, a technical report will be prepared that
describes the results of the bench and pilot tests. Information regarding the radius of influence
from the application points/wells and the reactivity of site media to the applied reagents will be
presented. The post -treatment results will also be compared with the baseline monitoring results
to illustrate the effectiveness of the applied technology. Assuming successful bench and pilot
scale testing results, Radian will be able to complete a full-scale design for implementing site
remediation.
Bench scale testing is estimated to require approximately 10 weeks to complete. In preparing for
pilot scale testing, all of the proposed remediation alternatives will require an injection well
permit from the North Carolina Department of Environment and Natural Resources Underground
Injection Control Program. Because of the UIC permit application requirements, the application
can not be submitted until bench scale testing and pilot scale work plans are completed. The
permit application(s) would require only a few days to complete. However, after speaking with a
representative of the UIC program, it is our understanding that the proposed injection(s) may
need to be reviewed by the NC Department of Health and Human Services Occupational &
Environmental Epidemiology Section. This may further extend the review period and the
approval of a UIC permit application. We estimate that this process may require 8 to 12 weeks
for completion. Once a UIC permit is granted, pilot scale testing is estimated to require 4 to 5
months to complete. We estimate that bench scale testing, UIC permitting, and pilot scale testing
would be completed in approximately 10 months. The attached schedule details the approximate
dates associated with each of the individual tasks.
It is inadvisable to complete the Corrective Action Plan (CAP) until the proposed technologies
are properly evaluated through bench and pilot scale testing. Therefore, additional time is
necessary to perform the requisite testing and to ensure submittal of a CAP that adequately
describes the proposed remediation technology.
If you have any questions regarding this request, please contact Mario Kuhar at [phone].
Sincerely,
RADIAN INTERNATIONAL
Senior Staff Scientist
Enclosure
cc: Mario Kuhar, Hamilton BeachOProctor-Silex, Inc.
Brett Berra, Radian International

HAMILTON
WASHINGTON,
BENCH SCALE, PILOT
BEACH/PROCTOR-SILEX,
INC.
NORTH CAROLINA
AND CAP PREPARATION SCHEDULE
SCALE
ID
Task Name
Duration
Start
Finish
1999
Apr l May f Jun Jul
Aug
Sep
Oct Nov
Dec
Jan
Feb
Mar
Apr
May
1
Bench and Pilot Scale Testing
220d
5110199
3/10/00
`�
�
,.
4114
-
"1
•
•.
.. ,�
.:.,
j
1
..
•,„
,.,.
2
Preparation Activities
3w
5/10/99
5/28/99
3
Bench Scale Test
10w
5131/99
8/6/99'
4
Work Plan and HASP for Picot Test
3w
819/99
8/27/99
5
UIC Permitting Process
10w
8/30/99
11/5/99
6
Pilot Test
18w
1118/99
3/10100•
7
CAP
25d
3/13/00
4414/00
8
CAP Preparation
5w
3/13/00
4/14100,,`
9
Submit CAP
Od
4/14/00
4/14/00
a
Date: 4/28/99
Task
Summary
; _,` Milestone.
Page 1
Ic:OT 6661/61/S9
T96890E293
a31VMQNN0a9

•
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr„ RE., Director
January 27, 1997
CleanOX Environmental Services, Inc.
1723 Verrazzano Drive
Wilmington, North Carolina 28405
Subject: Letter of Response to CleanOX Letter dated 11-29-96
McGirt Site
Incident #12061
Maxton, North Carolina
Dear. Mr. Vigneri:
AnNiA
HNR
The following letter is in response to your letter dated November 29, 1996, concerning the results of the
bench test and pilot test conducted at the former McGirt Store site in Maxton, North Carolina. After review
of your letter and the information in our file, I am withholding payment to Law Engineering &
Environmental Services Inc. (Law) for both the cost of the bench test and pilot test ($99 215-9,00) for reasons
outlined in this letter.
Based on my interpretation of the data, a 30% reduction"of the plume was not accomplished, nor could the
effective influence of the CleanOX application be determined at this site (i.e., lateral influence in off -set
wells). Their was a substantial decrease in concentration from injection well (IW) IW-1 and a moderate
decrease in IW-2, although benzene in IW-2 (610 ug/L pretest) increased (816 ug/L post-test).
Questionable concentration decreases were observed in the targeted well MW-8 (located 15 to 20 feet from
the injection wells). The post -injection sampling analysis indicated an overall decrease of compounds in
MW-8 by approximately 14%. However, I feel this is directly related to normal aquifer contaminant
fluctuations and not as a result of the CleanOX process. Some compounds were higher in concentration (i.e.
xylene) and new compounds not previously detected were also found (i.e. isopropyl benzene, styrene, etc.).
In fact, the BTEX data observed in January of 1996 were actually lower than the October 1996 results.
Groundwater Section, Voice 919-733-3221 FAX [phone]
P.O. Box 29578, Raleigh, North Carolina 27626-0578 Nifr,214,
IMF An Equal Opportun y/Affirmative Action Employer
2728 Capital Blvd., Raleigh, North Carolina 27604 gets Reuse Recycle 50°/a recycles/10% post -consumer paper

•
Page 2
CleanOX Test - McGirt Site
Characterization of the site was performed adequately. CleanOX was given every opportunity to ask for
additional information, if needed. To question the characterization of the site is untimely and unreasonable.
Law provided to you the data they had collected, plus information gathered by Aquaterra (previous
consultants). Law stated that they would stand behind the data they provided to you (e.g. geology, water
elevations, etc.). With the exception of Aquaterra's data, I am confident Law can reasonably reproduce the
data provided to CleanOX, if necessary. Again, the hydraulic conductivity characteristics have been
adequately defined, using conventional techniques (i.e., slug testing). Slug tests conducted at the site
indicated an average hydraulic conductivity of 0.34 feet per day for the surficial aquifer. A pumping test was
not requested by CleanOX and therefore the term heterogeneous permeability for the site is based on
CleanOX's observations and not Law's interpretation. This data was provided to CleanOX and at the time
was satisfactory. If more extensive testing were required, it should have been stated prior to the bench test.
I can only assume streak permeability is a CleanOX term used to describe preferential flow patterns in an
aquifer (e.g. preferred flow characteristics in a fractured rock aquifer). The site boring logs provided to
CleanOX indicated a fine to medium sands with some varying amounts of clay and silt are present in the
surficial aquifer. Some coarse amounts of sand was also sporadically observed. A potentially confining clay
layer was observed in well MW-6D (deep well), however additional data would be required to assess how
continuous this layer is at the site. Groundwater flow rates could change where more permeable layers occur.
The data and conditions observed are typical of the coastal plain geology in the Maxton, North Carolina area.
Soil boring-log-data-(split=spoon-blow-counts)-indieates-very-dense-subsur-iaee-soils are present -within -the —
upper ten feet of materials. As shown on the logs this data also indicates less dense soils at the groundwater
interface where the injection was targeted. Therefore, permeability in the unsaturated zone is irrelevant.
CleanOX specifically requested a grout seal above the well screens of the injection wells. I fail to understand
why unsaturated soil is a concern. CleanOX has contended all along that this technology treats only the
saturated zone (i.e., groundwater).
In April 1995, Law supervised the collection of soil and groundwater samples at the study area using
geoprobe technologies. Specific areas at the site, including the former UST area and the former pump island,
were targeted to assess the extent of soil and groundwater contamination. The results of analyses indicated
the presence of TPH compounds at 6.5 ppm (below the 10 ppm action level) near the former UST
excavation. TPH was not detected in remaining soil samples. This data was provided in Law's report dated
April, 28, 1995. On the basis of existing data, I believe the majority of contaminated soil was removed by
the previous consultant during the tank closure.
I concur, an oval shaped concrete structure is observable near the NCDOT Right-of-way, which could have
been the old pump island. Well MW-8 is also positioned in this approximate area. Again, soil analysis from
this area was found to be below the action levels.

Page 3
CleanOX Test - McGirt Site
The sediment sample described by CleanOX was collected (according to CleanOX) from a soil pile on the
NCDOT Right-of-way beside the site, which was reportedly spoils from a water line installation. The water
line installation was reportedly conducted by the Robeson County Water Department. The soils were likely
collected at depths no greater than five feet below land surface (Ns) and thus the TOC concentration would
not be indicative of concentrations within the aquifer 10 to 20 feet bls. Furthermore without documentation,
the exact origin of these soils is unknown.
Are we to understand that off -gassing has a direct relationship to TOC content (e.g., the more TOC, the more
off -gassing)? TOC analysis of soils and or groundwater was never requested by CleanOX. Additionally,
CleanOX performed TOC analysis at a previous test site, but made the decision not to run this analysis for
the McGirt Site, due to lack of off -gassing observed during the bench test. If TOC has a negative effect on
the chemical reaction, TOC analysis should have been measured by CleanOX.
The groundwater parameters for pH, specific conductance, and dissolved oxygen were field analyzed by
Law personnel. These data were available to CleanOX prior to the pilot test but were requested only after
the injection process had been completed. Variability in the data could have been discussed prior to the
injection process. The accuracy of the data should also be relied on as field data and not laboratory quality
controlled data.
Six sets of water level readings have been obtained between January and October 1996 at the site. In general,
two-anomalies-in-the-data_araobserved_Between January 4, 1996_and August 1, 1996, the data with some
seasonal fluctuations, appears to be consistent. Note the August 1, 1996 reading was the day of the injection
process. The groundwater configuration indicated,a depressed zone in the vicinity of MW-4 on each of the
four water level gauging events. On August 13, 1996, the groundwater configuration was essentially flat,
indicating a water level rise had occurred in the vicinity of MW-4 and MW-8, and IW-1 and IW-2. The
flattening of the water table may have been caused by the injection of the chemicals to the aquifer and
possibly the volume expansion of the reaction process itself, as described by CleanOX. No other internal or
external factors have been observed at the site during this time. The October 31, 1996 gauging event
indicated essentially the same depressed configuration observed in the first four events, however, the water
levels were significantly higher than previously observed. The increase in water levels on the October event
was likely caused by precipitation produced from Hurricane Fran, which occurred on September 5, 1996.
Law has conducted sample analyses in accordance with the injection well permit for the site as required by
the State Underground Injection Control (UIC) group. Under this permit, a volatile organic analysis by EPA
Method 6210D (an 8260 equivalent) has been conducted on each of the samples collected. CleanOX has
collected their own samples, which were analyzed by EPA Methods 625 (BN's only) and 624 plus 15 TICs
(volatiles). The compound Lists of the analyses differ by 31 compounds The analytical procedures are
similar analyses, however, the 624 analysis has a lower detection limit. The results should indicate
essentially similar results with the possible exception for elevated constituent samples where dilution of the
sample is required. In this case, up to 10% variation in the results could be observed. The differing TIC
results, as suggested by CleanOX, may be explained by these reasons.

Page 4
CleanOX Test - McGirt Site
In retrospect, I do not understand why the TIC identification is so important? This data was identified by
CleanOX prior to the bench test (CleanOX analyzed MW-8 by EPA 624 + 15 TICs). The bench test
removed all identified TIC compounds as stated by CleanOX prior to the pilot test. I do not understand why
the TICs would change in the aquifer and why wouldn't they be effected as they were in the bench test? Is it
possible the geochemistry of the soil has a profound effect on the chemical reaction? Maybe CleanOX
should consider using a soil column/water combination in their bench test, before field application is
considered. Performing the bench test with the soil column (taken from the saturated zone) would be more
indicative of field conditions and would likely save money by not performing the pilot test if the bench test
were to yield limited results.
It should be noted that Law collected each of the samples for volatile analyses in laboratory prepared 40 ml
VOA vials (no headspace) containers in accordance with EPA required standard sample collection and
handling procedures. CleanOX samples were collected in wide mouth 500 ml containers (and were likely
un-preserved), as observed by Law personnel and recorded on a All -Test laboratory report dated October 11,
1996.
Sample collection in the manner conducted by CleanOX will likely reduce the reported concentrations of
volatiles by allowing headspace in the containers. In addition, the lab I authorized, LENL, has been
conducting laboratory analytical work for the industry for over 10 years. Their QA/QC standard procedures
are defensible and reproducible. QA/QC laboratory data for this site can be provided at your request.
CleanOX indicated to Law, after the injection process, that dosing from the acetic acid was at a pH of 2.5.
Field analysis of pH from the well 1W-1 samples have been as low as 2.0. In summary, Law provided
available data which CleanOX requested. Law is of the opinion the data provided to CleanOX is accurate.
Collapsing of the well screen in IW-2 can only be contributed to the CleanOX process. CleanOX stated this
has not happened before. However, this well was developed and sampled and remained intact for
approximately one month prior to the injection process. Law maintains that the well was installed properly
and was functioning correctly' until the injection process was applied. As you have stated, heat and steam is
generated when the final reactant (35% hydrogen peroxide) is injected into the well. Therefore, it is my
belief that the heat generated by the chemical reaction caused the well screen to soften and subsequently
collapse.
It appears that CleanOX, based on their working knowledge of their own injection process, should have
foreseen site -specific difficulties using the data provided. This site was not problematic until after the
sampling results (post injection) were available. As a matter of fact, I was under the impression that the
injection went better than expected and as a result, CleanOX finished injecting ahead of schedule. At the
time you agreed to do the McGirt site, I do not recall anything in our conversation that lead me to believe
that this was a difficult site to treat. In addition, any data lacking should have been requested prior to the start
of the bench test. Many of the items discussed by CleanOX might have been resolved prior to the injection
process if some appropriate testing was conducted. Furthermore, CleanOX could have refused to treat this
site had there been any reservations about the site's so-called difficulties.

Page 5
CleanOX Test - McGirt Site
Since we were unable to determine a radius of influence from the injection wells how can we possibly design
for full remediation using the data available? All that we can confirm is that some reductions were noticed
within the confines of the injection wells. For your final remediation proposal, what is the basis for the
change of chemical concentration and how did you determine a 10 foot radius of influence? Are these
assumptions? If so, will this lead to more accusations and excuses, if projected knockdown is not achieved?
In response to using existing monitoring wells for injection, we cannot effectively evaluate any remedial
technology without adequate monitoring points. This is a statewide practice • that has proven to be an
effective tool to measure and evaluate cleanup progress. If other States choose to blindly accept data from
injecting into monitoring wells, it will surely lead to later problems if fragments of the plume are left behind.
If additional wells (for injection purposes) are not installed separately from monitoring points, how can we
possibly measure remedial performance laterally throughout the plume? By injecting into existing
monitoring wells, the ability to monitor the effect of the process is lost. Little if any quantifiable data of the
process would be obtained without monitoring data from these wells. Our goal is to cleanup the plume not
the monitoring wells.
Excluding your recent invoice for the amount of $22,269.00 (bench test and pilot test costs), I have
authorized payment to Law for approximately $27,800.00, which included preparation of the injection well
permit, costs for installing the two injection wells, cost to perform rising head slug tests in on -site wells,
Law's cost to oversee injection and sampling, plus all laboratory costs. By assuming better than half the
costsfor performing_this_test, T feelw_eltave 1Zeen more than generous to this point and find further payment
of these costs neither reasonable or necessary. For the tremendous amount of time and energy spent on this
project, very little, if any information was gained. Certainly a reduction of 30% over the entire plume was
not recognized, nor can we definitively say that the plume can be cleaned up economically with this
technology. Other pilot tests usually cost no more than $3,600.00 to $4,600.00 for typical soil vapor
extraction tests and air sparging tests, respectively (excluding costs for installing wells). Based on the high
costs of this technology and the inability to measure lateral influence, I cannot recommend full remediation
using the CteanOX technology at the McGirt site.
In summary, it would appear many site -specific parameters can have a potentially negative effect on the
chemical reaction (some of which are not well understood by CleanOX). Therefore, rather than placing the
burden of selecting a third site on the State, I strongly recommend CleanOX select the site that best fits the
"Sand Aquifer" profile as you have outlined in your letter. Based on potentially similar results, I am
rescinding my previous decision to test the CleanOX technology at the "Fletcher Site" (Elm City). When you
find a third test site, I recommend that you notify the Innovative Technology Committee and the UIC Group
for proper evaluation and permitting. At this time, all costs associated with any subsequent application or
testing of this technology will be at the expense of CleanOX and not eligible for reimbursement from the
State Trust Fund.

Page 6
CleanOX Test - McGirt Site
If you have any further questions concerning the contents of this letter, please feel free to call on me at your
earliest convenience [phone].
Sincerely,
J.I. Barker, Environmental Engineer II
State Trust Fund Group
cc: Burrie Boshoff
George Matthis
Innovative Technology Committee
Mark Milligan
Bob Cheek
Regional Office Groundwater Supervisors
Walker Jones, Law Engineering Inc., 5710 Oleander Drive Suite 110, Wilmington, NC 28403
Bob Witsell, S&ME Inc., 3100 Spring Forest Road, Raleigh, NC 27604
Tor Vatne, CleanOX World Headquarters, 16801 Greenspoint Park Drive Suite 360, Houston, TX 77060

es, Inc.
V range from pretreatment measured levels on the order
s long a continuing reaction time before (over 90 days).
'Identifies some of the low level acid forms present, and
lated to the CleanOX Process. The high TOC and low
to present. The groundwater levels, X/E ratios and pH
fie site characteristics. I would welcome the opportunity to
with the Innovative Technology Committee and you.
plied almost every working day in other states. It is
,zdged in NC because of two pilot test applications on
hs. These applications were accepted as difficult to treat,
/X, were worth trying (as they were the only sites
num for evaluation of the CleanOX Process, and have
downs. We now have a methodology for the site that we
old like to complete the remediation of the McGirt site to
I with the technology, and we would like to obtain
firmed. We are still seeking a coastal sand saturated matrix
'project in Elm City, for which the permit application was
iinantly one well hot spot contained in a sandy-clay/clayey
eterized), the water from the MW-5 Bench Test sample
:Bench Test was successful, and the Pilot should have
ms-obtained in the -other -injection -wells -treated -in -the NC
iing log and other info didn't make this an attractive job for
:ability was demonstrated to be higher than the other two
Tut "holding" the injection permit for Elm City right after
'r of factors. From what we Teamed on the Maxton and
:dified our chemical recipe (particularly the oxidizer
is on this site. We anticipated establishing our clay
in the performing of this project. The significant efforts that
lysis and testing relative to the two other NC jobs has led to
Inew algorithms, one for clay matrix applications, another
one for the combination. These items can be discussed in
tion. We are still interested in obtaining an application in a
o complete what was to have been a three job evaluation.
contract work on such NC sites. I am available at your
6ion or information.
Sincerely,

.
CleanOX Environment, _ Aervices, Inc.
1723 Verrazzano Drive
Wilmington, NC 28405
910-256-2920 Ph
910-256-2973 Fax
Ron Vigneri, Sr VP/R&D, Ops
CleanOX Environmental Services, Inc.

CleanOX Environment,
1723 Verrazzano Drive
Wilmington, NC 28405
910-256-2920 Ph
910-256-2973 Fax
November 29, 1996
ervices, Inc.
Mr. J.D. Barker
NC DEHNR, Groundwater Section
P.O.Box 29578
Raleigh, NC 27626-0578
RE: McGirt Site, Maxton, NC
Dear J.D:
t-o
01
0
rn
C)
w
•
The enclosed material represents the latest interpretation by CleanOX of the results of the
McGirt Pilot Test completed over portions of two days ending 8/1/96. The Maxton site
was remediated below the 30% threshold for payment that was informally agreed between
us (with the condition that the site characterization be accurate and complete). Whether
the site characterization is accurate and complete is debatable, and CleanOX cannot
explain some of the observations detailed in the enclosed data. The site variances are
listed, but does not include the pH data from the Law testing of 10/31/96. The TOC level
in our design was 1 ppm for the water, but due to streak permeability we contacted the
TOC in the matrix which measured 328 ppm which introduced some loss of oxidizer
efficiency. CleanOX has a very high regard for Walker Jones and Dan Shields of Law
Engineering and has raised these points previously.
Whether you use the Law data or the All -Test data, there is a substantial decrease in
contamination levels without any harmful effects from the CleanOX Process application.
In fact, the site can be fully remediated by CleanOX with a change in chemical
concentration along with direct injection into MW-4,8 and IW-1,2. The design to inject
directly into monitoring wells is required to assure that there is contact with the
contaminated groundwater.
CleanOX injects directly into monitoring wells in 8 of the 9 states we are presently active
in, the lone exception is North Carolina. The Maxton site hydrodynamics are not fully
understood by CleanOX, and the permeability linkage from the new injection wells to the
offset monitoring wells was very low level. The 1.25 inch string which CleanOX installed
into IW-2 can be utilized for injection. A proposal is attached for the full remediation of
the site.
During our telecon of 10/23/96, I requested to test MW-4 at Maxton because CleanOX
questioned the Law data presented. CleanOX proceeded to test MW-4 and make other
field measurements on 10/25/96. The latest Law sampling was done on 10/31/96. The
MW-4 data between Law's lab and the All -Test lab is now similar on MW-4, but different
on MW-8 TIC content. This has occurred with almost all the split samples for this job,

CleanOX Environmei_Services, Inc.
1723 Verrazzano Drive
Wilmington, NC 28405
910-256-2920 Ph
910-256-2973 Fax
especially around the identification of the "acetone" that was a focus of attention. Note
now that no acetone or acetic acid compounds are present in either lab's data, as CleanOX
stated would be the case. At present, the two labs' numerical differences for BTEX data
are not large, but there are differences ih TIC compound identifications.
The CleanOX Pilot Test on this site presented problems in injection wells (IW-2 well
screen collapse), horizontal areal extent of CleanOX effectiveness (chemical effects were
slow to reach the 20 foot radius points), site hydrodynamics (6 foot water rise),
groundwater parameters (water pH, DO, Conductance commonality, X/E ratios), and lab
analysis (varied with the lab used). CleanOX depends upon third party data and
characterizations. As we discussed many times, the CleanOX Bench Test proves the
chemical recipe, the Pilot Test proves the site characterization. We always proceed
through the steps of Bench/Pilot/Full Remediation because of uncertainties in the site
characterization parameters. The CleanOX Process is good, but we'd have to be Devine to
fully remediate this site with only a Pilot Test, which seems to have been the expectation.
A Pilot Test is a Pilot Test is a Pilot Test. It delivers results indicative of the realities of
the site characteristics with some level of knockdown, all of which are evaluated as to the
practicality of a design for a full remediation.
The full remediation bid is enclosed with a Job Input Parameters sheet presenting the
design for a full remediation based upon a 10 foot radius of influence and low
concentration injection directly into two monitoring and two injection wells (all existing).
We still don't know if contaminants were fully remediated in the vadose zone prior to the
Pilot Test, or the extent or location of the excavation of soils. Our sampling of the soils
stopped at a depth of 6 feet because the silty soil was so very hard. From a local resident
and our observation, it appears that some old pump island curbing is still present on the
site. But on the basis of the Pilot Test, we think the groundwater can be remediated
economically and over a short period of time. We feel the method to offer many
advantages over air sparging as mentioned by Law. This can be discussed in detail.
The Pilot Test delivered contaminant level knockdowns in the injection and the related
offset wells despite high TOC content, streak permeability, low pH effects and higher
temperature levels. No harmful intermediates were produced, knockdowns were obtained,
no plume spreading occurred, and the process application was demonstrated. We suggest
that the water level, pH, groundwater temperature parameters indicate that a significant
groundwater influence in the area (local discharge to groundwater or large capacity supply
well) is present. The lack of quick offset well response and any surface water emissions
during injection indicates to CleanOX that we had a downward direction to our chemical
volume expansion. The present groundwater temperature is high enough to utilize the
groundwater as a hydronic heating system source. The extremely low pH effect has been
to greatly lengthen the CleanOX chemical reaction period with continuing knockdown
effects proceeding that are chemical, not dilutional. We never experienced operating in the
2-3 s.u. pH range before, and did not dose to below 3.5 in our design. The ORP levels in

CleanOX Environment_ ,iervices, Inc.
1723 Verrazzano Drive
Wilmington, NC 28405
910-256-2920 Ph
910-256-2973 Fax
these wells are still in the -150 mV range from pretreatment measured levels on the order
of +15 mV. We've never seen this long a continuing reaction time before (over 90 days).
The SVOC TICs scan of MW-4 identifies some of the low level acid forms present, and
these are clearly not chemically related to the CleanOX Process. The high TOC and low
pH would indicate humic acids are present. The groundwater levels, X/E ratios and pH
tables are attached to illustrate the site characteristics. I would welcome the opportunity to
review the CleanOX application with the Innovative Technology Committee and you.
The CleanOX Process is being applied almost every working day in other states. It is
unfortunate that we may be misjudged in NC because of two pilot test applications on
sites with problematical conditions. These applications were accepted as difficult to treat,
were new formations for CleanOX, were worth trying (as they were the only sites
offered), definitely weren't optimum for evaluation of the CleanOX Process, and have
yielded contaminant level knockdowns. We now have a methodology for the site that we
believe will work. CleanOX would like to complete the remediation of the McGirt site to
show what can be accomplished with the technology, and we would like to obtain
payment for the Pilot Test performed. We are still seeking a coastal sand saturated matrix
application.
On another topic, the proposed project in Elm City, for which the permit application was
withdrawn, you have a predominantly one well hot spot contained in a sandy-clay/clayey
sand saturated matrix (as characterized), the water from the MW-5 Bench Test sample
was moderate in TOC level, the Bench Test was successful, and the Pilot should have
ex�ubite�C a east the knockdowns obtained in the other mlecfion wells treated int IWNC
jobs. Review of the MW-5 drilling log and other info didn't make this an attractive job for
CleanOX either, but the permeability was demonstrated to be higher than the other two
sites. Mark Milligan talked about "holding" the injection permit for Elm City right after
the second job due to a number of factors. From what we learned on the Maxton and
Apex sites, we would have modified our chemical recipe (particularly the oxidizer
concentration) for the injections on this site. We anticipated establishing our clay
formulation and methodology in the performing of this project. The significant efforts that
CleanOX has expended in analysis and testing relative to the two other NC jobs has led to
successful bench tests of three new algorithms, one for clay matrix applications, another
for high TOC applications, and one for the combination. These items can be discussed in
detail.
Thank you for your consideration. We are still interested in obtaining an application in a
sand aquifer for our process to complete what was to have been a three job evaluation.
We have been bidding private contract work on such NC sites. I am available at your
convenience for further discussion or information.
Sincerely,