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HomeMy WebLinkAboutWI0700518_Permit (Issuance)_20211015RAMB LL Via Overnight Courier DWR - UIC Program 1636 Mail Service Center Raleigh, NC 27699-1636 (919)707-9000 Re: NOTIFICATION OF INTENT (NOI) TO CONSTRUCT OR OPERATE INJECTION WELLS FORMER EMPIRE BRUSH SITE 2400 N MEMORIAL DRIVE/205 STATON ROAD GREENVILLE, NORTH CAROLINA To whom it may concern: Ramboll US Corporation (Ramboll) has prepared the enclosed Notification of Intent to Construct or Operate Injection Wells for injection points at the property located at 2400 N Memorial Drive/205 Staton Road in Greenville, North Carolina. Should you have any questions regarding this request, please email or contact one of us using the contact information provided below. Sincerely, Ramboll US Corporation Beth Richter Managing Consultant D 312.288.3856 brichter@ramboll.com Enclosures NOI to Construct or Operate Injection Wells ENVIRONMENT & HEALTH Date October 4, 2021 Ramboll 333 W Wacker Drive, Suite 2700 Chicago, IL 60606 USA T +1 312 288 3800 www.ramboll.com 1/1 NC Department of Environmental Quality — Division of Water Resources (DWR) NOTIFICATION OF INTENT (NOI) TO CONSTRUCT OR OPERATE INJECTION WELLS The following are "permitted by rule" and do not require an individual permit when constructed in accordance with the rules of 15A NCAC 02C.0200 (NOTE: This form must be received at least 14 DAYS prior to injection) AQUIFER TEST WELLS (15A NCAC 02C .0220) These wells are used to inject uncontaminated fluid into an aquifer to determine aquifer hydraulic characteristics. IN SITU REMEDIATION (15A NCAC 02C .0225) or TRACER WELLS (15A NCAC 02C .0229): 1) Passive Injection Systems - In -well delivery systems to diffuse injectants into the subsurface. Examples include ORC socks, iSOC systems, and other gas infusion methods (Note: Injection Event Records (IER) do not need to be submitted for replacement of each sock used in ORC systems). 2) Small -Scale Injection Operations — Injection wells located within a land surface area not to exceed 10,000 square feet for the purpose of soil or groundwater remediation or tracer tests. An individual permit shall be required for test or treatment areas exceeding 10,000 square feet. 3) Pilot Tests - Preliminary studies conducted for the purpose of evaluating the technical feasibility of a remediation strategy in order to develop a full scale remediation plan for future implementation, and where the surface area of the injection zone wells is located within an area that does not exceed five percent of the land surface above the known extent of groundwater contamination. An individual permit shall be required to conduct more than one pilot test on any separate groundwater contaminant plume. 4) Air Injection Wells - Used to inject ambient air to enhance in -situ treatment of soil or groundwater. 5) In -Situ Thermal Wells (IST) — Used to `heat' contaminated groundwater to enhance remediation. Print Clearly or Type Information. Illegible Submittals Will Be Returned as Incomplete. DATE: October 4 20 21 PERMIT NO. (to be filled in by DWR) NOTE- If this NOI is being submitted as notification of a modification of a previously issued NOI for this site (e.g., different injection wells, plume, additives, etc.) and still meets the deemed permitted by rule criteria, provide the previously assigned permit tracking number and any needed relevant information to assess and approve injection: A. B. Permit No. WI Issued Date: WELL TYPE TO BE CONSTRUCTED OR OPERATED (1) Air Injection Well Complete sections B through F, J, M (2) Aquifer Test Well . Complete sections B through F, J, M (3) Passive Injection System Complete sections B through F, H-M (4) X Small -Scale Injection Operation Complete sections B through M (5) Pilot Test Complete sections B through M (6) Tracer Injection Well Complete sections B through M (7) In -Situ Thermal (IST) Well Complete sections B through M STATUS OF WELL OWNER: Choose an item. Deemed Permitted GW Remediation NOI Rev. 2-17-2020 Page 1 C. WELL OWNER(S) — State name of Business/Agency, and Name and Title of person delegated authority to sign on behalf of the business or agency: Name(s): Newell Brands Inc Mailing Address: City: Atlanta State: GA Zip Code: 30328 Day Tele No.: Cell No.: EMAIL Address: hgreen@patriotenviro.com Fax No.: D. PROPERTY OWNER(S) (if different than well owner/applicant) Name and Title: David Tsui Company Name Silver Empire LLC 6655 Peachtree Dunwoody Road 7120 Creek Wood Drive Mailing Address: City: Chapel Hill County: Fulton State: NC Zip Code: 27514 County: Orange Day Tele No.: Cell No.: EMAIL Address: avalonmed@gmail.com Fax No.: E. PROJECT CONTACT (Typically Environmental Consulting/Engineering Firm) Name and Title: Beth Richter Company Name Ramboll US Consulting Mailing Address: 333 W Wacker Drive, Suite 2700 City: Chicago State: IL Zip Code: 60606 County: Cook Day Tele No.: 312-288-3856 Cell No.: EMAIL Address: BRICHTER@RAMBOLL.COM Fax No.: F. PHYSICAL LOCATION OF WELL SITE (1) Facility Name & Address: Silver Empire/Former Empire Brush Property 2400 N Memorial Drive/205 Staton Road City: Greenville County: NC Zip Code: 27834 (2) Geographic Coordinates: Latitude**: " or °. Longitude**: " or 0. Reference Datum: Accuracy: Method of Collection: **FOR AIR INJECTION AND AQUIFER TEST WELLS ONLY: A FACILITY SITE MAP WITH PROPERTY BOUNDARIES MAY BE SUBMITTED IN LIEU OF GEOGRAPHIC COORDINATES. G. TREATMENT AREA Land surface area of contaminant plume: 8,000 square feet Land surface area of inj. well network: 8,000 square feet (< 10,000 ft2 for small-scale injections) Percent of contaminant plume area to be treated: 8,000 (must be < 5% of plume for pilot test injections) Deemed Permitted GW Remediation NOI Rev. 2-17-2020 Page 2 H. (1) See figures 1A, 1B, 1C, and 5. (2) See figures 2 &3. (3) See figure 4. I. J. INJECTION ZONE MAPS — Attach the following to the notification. (1) Contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the contaminant plume in soil and groundwater, existing and proposed monitoring wells, and existing and proposed injection wells; and (2) Cross-section(s) to the known or projected depth of contamination that show the horizontal and vertical extent of the contaminant plume in soil and groundwater, changes in lithology, existing and proposed monitoring wells, and existing and proposed injection wells. Potentiometric surface map(s) indicating the rate and direction of groundwater movement, plus existing and proposed wells. (3) DESCRIPTION OF PROPOSED INJECTION ACTIVITIES AT THE SITE — Provide a brief narrative regarding the cause of the contamination, and purpose, scope, goals of the proposed injection activity: Injection of a dilute solution using approximately 3.75% percent by weight potassium permanganate for the purpose of in -situ chemical oxidation treatment of chlorinated volatile organic compound -impacted soil. Injections will be performed using a Geoprobe® direct push drill rig for direct injection into the subsurface with no permanent or temporary well structures. WELL CONSTRUCTION DATA 50-100 (1) No. of injection wells: Proposed Existing (provide NC Well Construction Record (GW-1) for each well) (2) Appx. injection depths (BLS): 9 ft below ground surface (3) (a) Direct injection via Geoprobe/DPT (b) No casing, group, screen, or sand pack to be used or installed (c) Redox Tech LLC For Proposed wells or Existing wells not having GW-ls, provide well construction details for each injection well in a diagram or table format. A single diagram or line in a table can be used for multiple wells with the same construction details. Well construction details shall include the following (indicate if construction is proposed or as -built): (a) (b) (c) Well type as permanent, Geoprobe/DPT, or subsurface distribution infiltration gallery Depth below land surface of casing, each grout type and depth, screen, and sand pack Well contractor name and certification number K. INJECTION SUMMARY NOTE: Only injectants approved by the epidemiology section of the NC Division of Public Health, Department of Health and Human Services can be injected. Approved injectants can be found online at http://deq. nc. gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water- protection/ground-water-approved-injectants. All other substances must be reviewed by the DHHS prior to use. Contact the UIC Program for more info if you wish to get approval for a different additive. However, please note it may take 3 months or longer. If no injectants are to be used use N/A. Injectant: potassium permanganate Total Amt. to be injected (gal)/event: 8,360 Injectant: Total Amt. to be injected (gal)/event: Injectant: Total Amt. to be injected (gal)/event: Injectant: Total Amt. to be injected (gal)/event: Deemed Permitted GW Remediation NOI Rev. 2-17-2020 Page 3 Injectant: Total Amt. to be injected (gal)/event: Total Amt. to be injected (gal/event): No. of separate injection events: 1 Total Amt. to be injected (gal): 8,360 Source of Water (if applicable): site hydrant (coordinated through GUC) L. MONITORING PLAN — Describe below or in separate attachment a monitoring plan to be used to determine if violations of groundwater quality standards specified in Subchapter 02L result from the injection activity. Onsite monitoring during injection activities and follow up soil sampling and groundwater monitoring will occur appropriately one month after injection will be performed. M. SIGNATURE OF APPLICANT AND PROPERTY OWNER Well Owner/Applicant: `I hereby certify, under penalty of law, that I am familiar with the information submitted in this document and all attachments thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information, I believe that the information is true, accurate and complete. I am aware that there are significant penalties, including the possibility of fines and imprisonment, for submitting false information. I agree to construct, operate, maintain, repair, and if applicable, abandon the injection well and all related appurtenances in accordance with the 15A NCAC 02C 0200 Rules." F,L fp„ Elizabeth Richter, Managing Consultant Sign ture of Applicant �'"I Print or Type Full Name and Title Property Owner (if the property is not owned by the Well Owner/Applicant): "As owner of the property on which the injection well(s) are to be constructed and operated, I hereby consent to allow the applicant to construct each injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards (15A NCAC 02C .0200)." "Owner" means any person who holds the fee or other property rights in the well being constructed. A well is real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of contrary agreement in writing. See access agreement attached. Signature* of Property Owner (if different from applicant) Print or Type Full Name and Title *An access agreement between the applicant and property owner may be submitted in lieu of a signature on this form. Please send 1 (one) hard color copy of this NOI along with a copy on an attached CD or Flash Drive at least two (2) weeks prior to injection to: DWR — UIC Program 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone: (919) 707-9000 Deemed Permitted GW Remediation NOI Rev. 2-17-2020 Page 4 L:1Loop Project Files/_CAD11690010395_Newell Brands_Pre-RAP Soil Activities 1-008103A_cis-1,2-DCE Results.dwp DESIGNER: ELS/CKL PROJECT: 1690010395-008 DATED: 7/12/2021 fit .ar MW-16 (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 325 Staton Rd. MW-16 (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 130 93.5 64.4 63.4 52.6 270/270 MW-16D (pg/L) JUN2017 1.000 OCT 2018 1.00 U FEB 2019 1.00 U MAY 2019 1.00 U AUG 2019 1.00 U OCT 2020 0.41 U JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW-21 OMW i f� Atlantic Coastline Railroad MW-18 1r MW-18 (pg/L) JUN 2017 192 OCT 2018 49.0 FEB 2019 60.7 MAY 2019 79.2 AUG 2019 119.0 OCT 2020 230/230 Mohawk Carpet C< 311 Staton Rd. MW-181 MW-17 (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW-18 (pg/L) JUN 2017 665 OCT 2018 74.5 FEB 2019 136 MAY 2019 230 AUG 2019 200 OCT 2020 52 1.80 1.00 U 0.58 J 1.40 1.30 1.0 MW-14 MW-16b 9 MW-17 MW-12 (pg/L) AUG 2020 OCT 2020 MW-16 /1W-161 IIIIIIIIIIIIIIIIIIII H-IIIII 13 22 MW-12 6 aee JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 0.950 J 1.00 U 1.00 U 1.00 U 0.41 U MW-23 (pg/L) JUN 2017 2.80 OCT 2018 1.90 FEB2019 1.30 MAY 2019 2.70 AUG 2019 1.00 U OCT 2020 0.41 U MW-15 200 Staton Rd. City of Greenville 100 Staton Rd. Old Mill Properties LLC 112 Staton Rd. Frank Hart Trust /allabll IW_23 ties MW-231 MW-24 MW-24 (pg/L) JUN 2017 34.3 OCT2018 1.60 FEB 2019 0.880 J MAY 2019 1.00 U AUG 2019 3.20 OCT 2020 6.4 JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIFFFFFFFFH IIIIIIIIIIIIIIIIIIII Source: Aerial Imagery: Google EarthT", image dated January 2013 MEMORIAL DRIVE , 0.980 J 1.00 U 1.00 U 1.00 U 1.00 U 0.41 U NIIIIIIIIIIIIIIIIIIIIIII 150 Feet PROPERTY BOUNDARY (APPROXIMATE) MNA MONITORING WELL NETWORK SHALLOW MONITORING WELL INTERMEDIATE MONITORING WELL (BASE OF UPPER AQUIFER) DEEP MONITORING WELL OTHER SITE WELLS AND BORINGS 45 SHALLOW MONITORING WELL INTERMEDIATE MONITORING WELL (BASE OF UPPER AQUIFER) DEEP MONITORING WELL Notes 1. The 15A NCAC 2L Groundwater Standard for cis-1,2-DCE=70pg/L. 2. June 2017 data represents a baseline condition prior to implementation of the 2018 Remedial Action Plan for Groundwater. Sampling event occurred June 28-30, 2017. 3. Monitored natural attenuation sampling events occurred on October 17-18, 2018; February 11-12, 2019; May 21-22, 2019; August 27-28, 2019; October 29-30, 2020. cis-1,2-DICHLOROETHENE GROUNDWATER RESULTS FORMER EMPIRE BRUSH FACILITY 105 STATON ROAD GREENVILLE, NORTH CAROLINA FIGURE 1A RAMBOLL US CONSULTING, INC. A RAMBOLL COMPANY RAMB LL L:1Loop Project Files\_CAD11690010395_Newell Brands_Pre-RAP Soil Activities\-008\03B_PCE Results.dw9 DESIGNER: ELS/CKL PROJECT: 1690010395-008 DATED: 7/12/2021 JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 4.10 2.60 1.80 1.70 1.60 21 MW-16I (pg/L) JUN 2017 3.50 OCT 2018 2.00 FEB 2019 1.90 MAY2019 1.70 AUG 2019 1.20 OCT 2020 4.1/4.5 MW-16D (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW-19 (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW-221 MW-21 MW-19 Atlantic Coastline Railroad JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW-18 25.6 10.0 9.80 13.8 16.6 22/21 Mohawk Carpet C 311 Staton Rd. MW-18I 1 MW-17 (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW-18 (pg/L) JUN 2017 26.5 OCT 2018 1.80 FEB 2019 1.70 MAY 2019 2.00 U AUG 2019 7.20 OCT 2020 2.10 0.740 J 1.00 U 0.77 J 1.90 1.00 U 1.1 MW-14 I MW-17 MW-12 (pg/L) AUG 2020 OCT 2020 MW-16 MW-161 2.9 4.4 MW-12 41, 6 JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U 0.37 U MW-23 (pg/L) JUN2017 1.000 OCT 2018 1.00 U FEB 2019 1.00 MW-15 200 Staton Rd. City of Greenville 100 Staton Rd. Old Mill Properties LLC �allabll IW_23 ties MW-231 U OU OU I E 112 Staton Rd. Frank Hart Trust MW-24 MW-24 (pg JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII Source: Aerial Imagery: Google Earth'", image dated January 2013 MEMORIAL DRIVE , 0.930 J 1.00 U 1.00 U 1.00 U 1.00 U 0.37 U 13.8 2.90 9.10 5.00 3.70 15 150 I Feet PROPERTY BOUNDARY (APPROXIMATE) MNA MONITORING WELL NETWORK SHALLOW MONITORING WELL INTERMEDIATE MONITORING WELL (BASE OF UPPER AQUIFER) DEEP MONITORING WELL OTHER SITE WELLS AND BORINGS 45 SHALLOW MONITORING WELL INTERMEDIATE MONITORING WELL (BASE OF UPPER AQUIFER) DEEP MONITORING WELL Notes 1. The 15A NCAC 2L Groundwater Standard for PCE=0.7pg/L. 2. June 2017 data represents a baseline condition prior to implementation of the 2018 Remedial Action Plan for Groundwater. Sampling event occurred June 28-30, 2017. 3. Monitored natural attenuation sampling events occurred on October 17-18, 2018; February 11-12, 2019; May 21-22, 2019; August 27-28, 2019; October 29-30, 2020. TETRACHLOROETHENE GROUNDWATER RESULTS FORMER EMPIRE BRUSH FACILITY 105 STATON ROAD GREENVILLE, NORTH CAROLINA FIGURE 1 B RAMBOLL US CONSULTING, INC. A RAMBOLL COMPANY RAMB LL L:1Loop Project Files\_CAD11690010395_Newell Brands_Pre-RAP Soil Activities\-008\03C_TCE Results.dw9 DESIGNER: ELS/CKL PROJECT: 1690010395-008 DATED: 7/12/2021 JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW'16 (pg/L) 10.0 MW-16I (pg/L) JUN 2017 31.7 OCT 2018 34.6 FEB 2019 26.5 MAY2019 21.9 AUG 2019 14.1 OCT 2020 48/50 MW-16D (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW-19 (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 1.00 U 1.00 U 1.00 U 1.00 0 1.00 U 0.16 U MW-221 MW-21 MW-19 ft Atlantic Coastline Railroad MW-18 MW-18 (pg/L) JUN 2017 41.8 OCT 2018 9.60 FEB 2019 10.2 MAY 2019 14.9 AUG 2019 21.8 OCT 2020 31/28 Mohawk Carpet C 311 Staton Rd. MW-18I 1 MW-17 (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 MW-18 (pg/L) JUN 2017 111 OCT 2018 7.40 FEB 2019 6.90 MAY 2019 10.00 AUG 2019 25.2 OCT 2020 10 1.80 1.00 U 0.77 J 1.90 1.00 U 1.4 MW-16b ort IIIIII� IIIII MW-161 MW-12 (pg/L) AUG 2020 OCT 2020 JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U 0.16 U MW-23 (pg/L) JUN2017 1.000 OCT 2018 1.00 U FEB2019 1.000 MAY2019 1.000 AUG2019 1.000 OCT 2020 0.16 U 200 Staton Rd. City of Greenville 100 Staton Rd. Old Mill Properties LLC Source: Aerial Imagery: Google EarthT", image dated January 2013 MEMORIAL DRIVE , et 112 Staton Rd. Frank Hart Trust dallabll IW_23 ties MW-231 MW-24 (pg/L) JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 JUN 2017 OCT 2018 FEB 2019 MAY 2019 AUG 2019 OCT 2020 • 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U 0.31 J 0.710 J 1.00 U 1.00 U 1.00 U 1.00 U 0.44 J II-HII H IIIIIIIIIIIIII IIIIIIIIIIIIIIIIIIIIIII 150 Feet PROPERTY BOUNDARY (APPROXIMATE) MNA MONITORING WELL NETWORK SHALLOW MONITORING WELL INTERMEDIATE MONITORING WELL (BASE OF UPPER AQUIFER) DEEP MONITORING WELL OTHER SITE WELLS AND BORINGS 45 SHALLOW MONITORING WELL INTERMEDIATE MONITORING WELL (BASE OF UPPER AQUIFER) DEEP MONITORING WELL Notes 1. The 15A NCAC 2L Groundwater Standard for cis-1,2-DCE=70pg/L. 2. June 2017 data represents a baseline condition prior to implementation of the 2018 Remedial Action Plan for Groundwater. Sampling event occurred June 28-30, 2017. 3. Monitored natural attenuation sampling events occurred on October 17-18, 2018; February 11-12, 2019; May 21-22, 2019; August 27-28, 2019; October 29-30, 2020. cis-1,2-DICHLOROETHENE GROUNDWATER RESULTS FORMER EMPIRE BRUSH FACILITY 105 STATON ROAD GREENVILLE, NORTH CAROLINA FIGURE 1C RAMBOLL US CONSULTING, INC. A RAMBOLL COMPANY RAMB LL L:\Loop Project Files\CAD\1690010395_Newell Brands_Pre-RAP Soil Activities\ 007\3-1_Cross Section A-A'.dwg NORTH CROSS SECTION A -A' SOUTH -------...... Warehouse Finished Floor ,- --�\` Sand Sand 1 Sand Silty Sand 70 37.9 113U 634 88.4 Silty Sand Silty Sand 22.7 /71\- — — Sand Sand Sand -25 25 -0+40 -0+20 0+00 0+20 0+40 0+60 0+80 1+00 1+20 1+40 1+60 1+80 2+00 2+20 2+40 2+60 2+80 3+00 3+20 3+40 3+60 3+80 Station SITE OVERVIEW LEGEND SOIL BORING PCE CONCENTRATION (pg/kg) STRATA CONTACT - STRATA CONTACT INFERRED — — — WATER LEVEL (AUGUST 2019) SILTY SAND SAND HORIZONTAL SCALE VERTICAL SCALE VERTICAL EXAGGERATION = 10 CROSS SECTION A -A' FORMER EMPIRE BRUSH FACILITY 105 STANTON ROAD GREENVILLE, NORTH CAROLINA RAMB LL DRAFTED BY: ELS I DATE: 8/27/20 FIGURE 2 1690010395 L:\Loop Project Files\CAD\1690010395_Newell Brands_Pre-RAP Soil Activities \RAP\3-3_Extent of Soil Impact_D.2.1.1.1&D.2.1.2(1).dwg S T Wooten Corporation 325 Staton Rd. Depth 4-5 cis-1,2-DCE 4 U PCE 4.2 U TCE 4.2 U f ,f+ 4.5 5.3 Depth cis-1,2-DCE 8-9 4.6 U 4.6 U 4.6 U SB-26 Depth 4-5 cis-1,2-DCE 0.8 U PCE 1.4 U TCE 1.1 U Depth cis-1,2-DCE TCE 3.1 J SB-8 SB-25 SB-24 SB-10 4.4U 95.9 ® O 1 9.3 22.7 ,B-16 () TSB-13 SB-23 4.4 U 41.7 Depth cis-1,2-DCE PCE TCE SB-9 24.5 96.6 SB-7 8-9 4.7 U 4.7 U 4.7 U 12.6 48.2 Depth cis-1,2-DCE PCE TCE 410 634 620 27.4 7.6 6.2 SB-8 Depth cis-1,2-DCE PCE TCE Depth cis-1,2-DCE Depth cis-1,2-DCE SB-23 Depth 4-5 cis-1,2-DCE 8.3 PCE 37.9 TCE 20.9 Depth cis-1,2-DCE Depth cis-1,2-DCE Depth cis-1,2-DCE 8-9 0.7 J 1.0 U 0.8 U 8-9 1.0 J 13.9 2.9 J 8 1.6 J 0.88 U 0.77 U SB-RI-3 SB2t( SB-1 SB-RI-4 Depth cis-1,2-DCE PCE TCE SB-25 Depth 4-5 cis-1,2-DCE 19.6 U PCE 35.7 U TCE 29.3 U 3.5-4.0 11 19 23 8-9 28.5 14.0 11.5 Depth cis-1,2-DCE PCE TCE Depth cis-1,2-DCE PCE TCE 8.5-9.0 12 1.8 J 2.9 J SB-1 4 5.9 0.92 U 0.8 U Depth cis-1,2-DCE SB-19 SB-22 SB-21 8 4.3 J 1U 0.88 U Depth 4-5 8-9 cis-1,2-DCE 3.9 U 7.1 PCE 3.9 U 3.9 U TCE 3.9 U 3.9 U SB-18 SB-20 SB-17 t■ T SB-RI-4 Depth cis-1,2-DCE PCE TCE 8.0-8.5 3.6 J 5U 1.8 J Depth cis-1,2-DCE Depth cis-1,2-DCE Depth 3.7 1 1.0 J 5.9 1 1.0 U 9.3 1 0.8 U cis-1,2-DCE 47.8 PCE 2.7 J 0.99 U TCE 4.8 Depth 4 cis-1,2-DCE 0.8 U PCE 0.93 U TCE 0.8 U 0.83 U Depth cis-1,2-DCE PCE 1 0.98 U TCE 0.82 U a 1 AERIAL PHOTOGRAPH OBTAINED FROM GOOGLE EARTH PRO. PHOTO TAKEN JANUARY 2013. LEGEND APPROXIMATE PROPERTY BOUNDARY INTERIOR WALL FOCUSED REMEDIAL AREA SOIL BORINGS WITH VOC RESULTS GREATER THAN SOIL PSRGs SOIL BORINGS WITH VOC RESULTS LESS THAN SOIL PSRGs 2017 SOIL BORING (See Note 7) Notes: 1. PSRG = North Carolina Preliminary Soil Remediation Goal (October 2017). 2. Units = Micrograms per kilograms (pg/kg) 3. NS = Not Sampled 4. SB-RI-1 through SB-RI-4 were collected in March 2012. Source: Environmental Resource Management (ERM), Remedial Investigation Report, March. 5. SB-1 through SB-10 were collected in January 2013. Source: Environmental Resource Management (ERM), Remedial Investigation Report, March. 6. SB-11 through SB-16 were collected in April 2014. 7. SB-17 through SB-22 were collected in June 2017. 8. SB-23 through SB-28 were collected in November 2019. 9. BOLD -ITALICIZED results are greater than soil protection of GW PSRGs [D.2.1.2 (1)]. Ref: NC REC (2015) D.2.1.1.1 North Carolina Residential Health Based Soil PSRGs (pg/kg) North Carolina Industrial/ Commercial Health Based PSRG (pg/kg) North Carolina Soil PSRG Protection of Groundwater (pg/kg) cis-1,2-Dichloroethene 470,000 31,000 410 Tetrachloroethene 17,000 82,000 6.3 Trichloroethene 870 4,000 21 0 100 SCALE IN FEET EXTENT OF SOIL IMPACT FORMER EMPIRE BRUSH FACILITY 105 STATON ROAD GREENVILLE, NORTH CAROLINA FIGURE 3 DRAFTED BY: ELS/APR DATE: 10/23/20 1690010395 L:1Loop Project Files/_CAD11690010395_Newell Brands_Pre-RAP Soil Activities\-008102E_GW Contour Map (Oct 2020).dwg DESIGNER: ELS/CKL PROJECT: 1690010395-008 DATED: 7/12/2021 MW-21 20.9 MW-19 DP-GW-1 • Atlantic Coastline Railroad Source: Aerial Imagery: Google EarthT", image dated January 2013 Mohawk Carpet Corporation 311 Staton Rd. MW-18 20.8 20.7 MW-181 • DP-GW-4 II II MW-10Gt 1KlJ_I I I lIJ.i I.I LF+-kl 111111 111111111 I-H+i 111 I,I 1111111111 MEMORIAL DRIVE (Addre Gree CI JB & GB Properties 310 ;taton Rd. P3 s Unavailable ville Utilities mrnission 210 Staton R. Cit of Greenvi le MW-24 18.0 112 ' taton Rd. Frank art Trust 100 Staton Rd. Old Mill Properties LLC -- PROPERTY BOUNDARY (APPROXIMATE) —18.0— UNCONFINED AQUIFER GROUNDWATER CONTOUR (FT AMSL) 20.7 GROUNDWATER ELEVATION (FT AMSL) (OCTOBER 2020) MNA MONITORING WELL NETWORK cb SHALLOW MONITORING WELL INTERMEDIATE MONITORING WELL (BASE OF UPPER AQUIFER) DEEP MONITORING WELL OTHER SITE WELLS AND BORINGS 1 SHALLOW MONITORING WELL INTERMEDIATE MONITORING WELL (BASE OF UPPER AQUIFER) DEEP MONITORING WELL DIRECT -PUSH GROUNDWATER SAMPLE UNCONFINED AQUIFER GROUNDWATER CONTOUR MAP OCTOBER 2020 FORMER EMPIRE BRUSH FACILITY 105 STATON ROAD GREENVILLE, NORTH CAROLINA FIGURE 4 RAMBOLL US CONSULTING, INC. A RAMBOLL COMPANY RAMB LL L:\Loop Project Files\CAD\1690010395_Newell Brands_Pre-RAP Soil Activities\RAP\4-3_Proposed Remedial Design.dwg TSB-26 OSB-9 I I 4 1 QSB-8 RA-1 OSB-' 3 AERIAL PHOTOGRAPH OBTAINED FROM GOOGLE EARTH PRO. PHOTO TAKEN JANUARY 2013. OSB OSB-3 RA-4 _-' I- r SB-1 I-3 QQ OSB-27 —�-i i' IRA-2 nSB-7 I OSB-25 1 OSB-24 OSB-10 O S B-6 OSB-2 SB-1® OSB-RI-4 O S B-5 _j tr OSB-14 LEGEND APPROXIMATE PROPERTY BOUNDARY = INTERIOR WALL [-] PROPOSED INJECTION AREAS O SOIL BORINGS WITH VOC RESULTS GREATER THAN SOIL PSRGs O SOIL BORINGS WITH VOC RESULTS LESS THAN SOIL PSRGs O 2017 SOIL BORING s Construction Details: Well type: Direct injection via temporary Geoprobe/DPT Depth: 9 ft BLS Casing/Grout/Sand Pack Materials: NONE; no wells to be installed Contractor: Redox Tech LLC ( 0 50 SCALE IN FEET PROPOSED AREAS OF INJECTION FORMER EMPIRE BRUSH FACILITY 105 STATON ROAD GREENVILLE, NORTH CAROLINA DRAFTED BY: ELS/APR FIGURE 5 DATE: 10/26/20 1690010395 RIGHT OF ACCESS AGREEMENT This Agreement entered on this YO • day of ApFil-May 2021 by and between Silver Empire, in the County of Orange, State of North Carolina with principal offices at 7120 Creek Wood Drive (hereinafter "SITE OWNER") and Newell Brands Inc. or one of its subsidiaries, located at 6655 Peachtree Dunwoody Road, Atlanta, Georgia 30328 (hereinafter "CLIENT"); and WHEREAS, SITE OWNER owns the Property located at 2400 North Memorial Drive, Greenville, North Carolina, (hereinafter "the Property"); and WHEREAS, CLIENT is involved in remedial action and monitoring activities at the Property owned by PROPERTY OWNER at 2400 North Memorial Drive, Greenville, North Carolina, and WHEREAS, Ramboll US Consulting, Inc., f/k/a Ramboll US Corporation, a Virginia corporation with an office located at 333 West Wacker Drive, Suite 2700, Chicago, Illinois 60606 (hereinafter "Ramboll") is CLIENT'S environmental consultant for the project; and - WHEREAS, CLIENT has requested Ramboll to implement a Remedial Action Plan which may include injection of potassium permanganate, along with soil, ground water, and/or other media sampling at the Property; and WHEREAS, SITE OWNER is willing to permit such sampling provided it receives assurance.that CLIENT will indemnify and hold SITE OWNER harmless from Ramboll's activities at the Property. NOW THEREFORE, the parties agree as follows: 1. SITE OWNER agrees to grant, or cause to be granted, to Ramboll access to the Property to be remediated under this Agreement. 2. SITE OWNER shall indicate to Ramboll the boundary lines of the Property and agrees to be responsible for the accuracy of such lines. 3. SITE OWNER shall indicate to Rambo!' the location of any underground water, telephone, electric, sewer, gas and other u-til.ity lines and other apparatus underground and shall be responsible for the accuracy of such information. 4. SITE OWNER shall indicate to Ramboll the location of any underground tanks and the contents of such tanks and shall be responsible for the accuracy of such information. 5. SITE OWNER agrees to make available, or cause to be made available, to Ramboll all information within its control necessary to allow Ramboll to perform its services under this Agreement and agrees to comply with all reasonable requests by Ramboll for and to clarify such information and shall be responsible for the accuracy of such information. 6. Ramboll/CLIENT shall be liable to the SITE OWNER for direct damages that result from Ramboll's negligence or willful misconduct in the performance of its services. UNDER NO CIRCUMSTANCES SHALL RAMBOLL BE LIABLE FOR INDIRECT, CONSEQUENTIAL, SPECIAL, OR EXEMPLARY DAMAGES, OR FOR DAMAGES CAUSED BY THE CLIENT'S OR SITE OWNER'S FAILURE TO PERFORM ITS OBLIGATIONS. 1/3 Agv 7. Ramboll, its employees, contractors and subcontractors shall not use the Property in any manner that would interfere with or cause harm to the Property, its operations or any other lawful activity being undertaken by SITE OWNER on the Property. 8. Nothing contained within this Agreement shall be construed or interpreted as requiring Ramboll to assume the status of a generator, storer, treater or disposal facility as those terms appear within the Resource Conservation and Recovery Act, 42 USCA, Section 6901, et seq., as amended, (hereinafter "RCRA") or within any state statute governing the treatment, storage and disposal of waste. 9. SITE OWNER shall assume the responsibility for compliance with the provisions of RCRA and any state statute governing the treatment, storage and disposal of waste generated during the remedial action implementation. 10. Ramboll shall carry at its expense, during the term of this Agreement, the minimum insurance coverages set forth below: Coverage Limits (1) Worker's Compensation Statutory (2) Employer's Liability $1,000,000 each occurrence (3) General.:Liability $2,000,000 aggregate (Bodily Injury & Property Damage) (4) Excess Liability (Bodily Injury & Property Damage) (5) Automobile Liability (Bodily Injury & Property Damage) (6) Professional Liability Insurance $5,000,000 aggregate $1,000,000 combined single limit $2,000,000 aggregate 11. Ramboll agrees to use its best professional judgment in the performance of its services under this Agreement and to use the degree of care and skill ordinarily exercised, under similar circumstances, by reputable consultants performing comparable services. The standard of care shall exclusively be judged as of the time the services are rendered and not according to later standards. Ramboll and CLIENT agree that no other warranty or representation, either expressed or implied, is included or intended under this Agreement. 12. Ramboll agrees to comply with appropriate local, state and federal health and safety procedures during site activities. 13. This agreement shall be construed according to the laws of the State of North Carolina. ENTERED the date and year written above: Newell Brands Inc. Silver Empire, LLC By: By: 2/3 Ramboll US Consulting, Inc. By: David Holdout, Principal 3/3.