WI0100015_Complete File - Historical_20220307

V2 AR CA D 1 S ARCADIS G&M of North
Carolina,Inc.
Infrastructure, buildings, environment communications 801 Corporate Center Drive
Suite 300
Raleigh,
Mr. Evan Kane
North Carolina 27607-5073
LTIC Program Tel [phone]
Groundwater Section Fax [phone]
North Carolina DENR-DWQ w .arcaclis-us.conn
1636 Mail Service Center
Raleigh,NC 27699-1636
ENVIRONMENTAL
Subject
UIC Permit Application for Coats American Sylvan Facility,Rosman,North
Carolina,Incident Number 5337.
Date:
Dear Mr.Kane: 11 June 2003
ARCADIS is pleased to submit three copies of the underground injection permit Contact:
application for the above referenced site. This permit is for the injection of oxygen Alan Pinnix
release compound to address the presence of vinyl chloride in groundwater. Extension:
247
Should you have any questions,please contact the undersigned.
E-mall:
[e-mail]
Sincerely,
ARCADIS G&M of North Carolina,Inc. our ref:
)Alan
NC103013.0001
Pinnix, L.G.
Project Scientist
copies:
Mr. Mike Bell
Ms. Laura K. Dechant
p E C E o W E
JUN 16 2003
D
GROUNDWATER SECTION
ASHEVILLE REGIONAL OEfICE
Part of a bigger picture

l
UNDERGROUND INJECTION
CONTROL PERMIT
APPLICATION
Coats American Sylvan Plant
Rosman, North Carolina
Groundwater Incident No. 5337
JUN 16 2003 U
SECTION
E RFiiiOA'AL OFFICE
May 2003
VaARCADIS
Infrastructure, buildings, environment, communications
PREPARED FOR
Coats American, Inc.

ARCADIS
JUN 16 2003
GROUND—WATER SECTION
ASHEVILLE REGIONAL OFFiuE
UNDERGROUND INJECTION
CONTROL PERMIT
APPLICATION
Coats American Sylvan Facility
Rosman, North Carolina
Groundwater Incident No. 5337
Prepared for
Coats American,Inc.
Prepared by
ARCADIS Geraghty&Miller of
North Carolina,Inc.
801 Corporate Center Drive
Suite 300
North Carolina 27607
Tel [phone]
Fax 919 854-SW
Ow Ref.:
NC103013.0001
Dab:
May 2003
This document is intended only for the use of
the indWual or entity for which it was
prepared and may contain information that is
privileged,confidentOL and exempt from
disclosure under applxable law.Any
dissemination,distribution,or copying of this
document is strx*prohibited.

ARCADIS
GENERAL APPLICATION FOR PERMIT TO CONSTRUCT
AND/OR USE A WELL(S)FOR INJECTION
COATS AMERICAN SYLVAN PLANT
ROSMAN,NORTH CAROLINA
GROUNDWATER INCIDENT NO.5337
May 2003
Provided byARCADIS G&MofNorrh Carolina,Inc.
Michelle R. ,P.E.
Project ltoeer
�.•P�N CaRp rr.,,
��•o ,...,,,*%
J. Alan Pinnix,L.G. _ aL
1260
Project Scientist L
% �y
giemYn,b,menu^Winn OI,mWI[RmiMuk. g^_W9tlec

NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
TO: DIRECTOR,NORTH CAROLINA DIVISION OF WATER QUALITY
DATE: May 30,2003.
A. PERMIT APPLICANT
— Name: Mr.Mike Bell.Environmental and Safety Coordinator
Address: Coats North America
Post Office Box 670
City: Toccoa State: GA Zip Code: 30577
County: Stephens Telephone: [phone] Ext.2248
B. PROPERTY OWNER(same as applicant)
C. STATUS OF APPLICANT
Private: Commercial: X Federal: State:
County: Municipal: Native American Lands:
I ,
D. FACILITY(SITE) DATA
Name of Facility: Coats American Sylvan Plant
Address:Highway 178
City: Rosman Zip Code: 28772 County: Transylvania
Telephone: [phone] Ext. 17 Contact Person: Eddie Briscoe
E. INJECTION PROCEDURE
Provide a detailed description of all planned activities relating to the proposed injection facility
including but not limited to:
(1) Construction Plans and Materials: ARCADIS G&M of North Carolina,Inc. (ARCADIS)
will subcontract with Regional Probing Services,Inc. (Regional Probing)to inject
Oxygen Release Compound(ORC)into 9 temporary well points at the Coats Sylvan
Manufacturing Facility(the Site)shown on Figures 1, 2, and 3. The ORC material
V properties are described in the Material Safety Data Sheet(MSDS)provided as
Attachment 1. ARCADIS and Regional Probing will follow the procedures described by
L
GW-57 REM (Novembu 1999) Page 1 of 9

REGENESIS Bioremediation Products in Attachment 2: ORC® Slurry Installation
Instructions, Geoprobe®Injection into the Soil Matrix.
During the initial application,the 9 injection points in the source area will be treated
with a slurry solution of 60 pounds of ORC and 17 gallons of water per point for a total
of 540 pounds of ORC and 153 gallons of water. The calculations used to design the
injection program are included in Attachment 3.
-- (2) Operation Procedures: Refer to Attachment 2.
(3) Planned Iniection Schedule: The proposed scheduled is to complete the injection within
a two day period to commence within 4 weeks of UIC permit application approval in .
2003. The proposed injection of ORC will be used to reduce the concentrations of
contaminant constituents present in the surficial aquifer at the Site. A second,and
possibly a third injection of ORC may be required to achieve the desired contaminant
reduction. An injection schedule for the additional injections is unavailable at this time,
due to the length of time for monitoring the first injection. It is anticipated that the
additional injection events will be performed in less than two days. Additional injections
may not be necessary depending on the success of the initial ORC injection. Written
notification to NCDENR will be made at least thirty days prior to any subsequent
injections.
F. DESCRIPTION OF SITE
Provide a brief description of the contamination incident and the incident number assigned by
the Division of Water Quality staff in the Department's Regional Office:
The Coats American- Sylvan Facility is in a rural area of Transylvania County on State
Highway 64 near Rosman,North Carolina(Figure 1). The facility,which lies outside the
corporate limits of Rosman,is a spinning plant for textile threads used in industrial sewing. The
plant was constructed in the mid-1960's and was owned and operated by American Thread until
1991 when American Thread and Coats merged to form Coats American.The 50-acre plant
property is bounded on the north, south and east by pasture land. State Highway 64 borders the
plant on the western side. The land on the opposite side of Highway 64 is primarily pasture with
two parcels containing vacant houses.
Topographically,the site lies on the fluvial plain of the French Broad River.The site slopes
gently to the southeast, at a horizontal gradient of approximately 0.01 feet/foot,toward the
French Broad River,which is approximately 2,000 feet from the site. The surrounding area is
characterized by the hills and valleys of the southern Blue Ridge physiographic province.
Galloway Creek, a tributary of the French Broad,borders the facility on the west and south sides.
When the Sylvan plant began operations in the mid-1960's, floor scrubber and frame cleaning
water was placed into a storm-water drain which flowed into the French Broad River. In the
early 1970s a small(8 feet x 8 feet x 5 feet deep)pit was dug on the Company property for
deposition of the scrubber and frame cleaning water. In 1984 or 1985,the first pit was covered
by filling with soil and a second pit was dug. The second pit was used until January 1989 and
was covered/filled with soil in August 1989. The floor scrubber and washer water has since been
placed into the on-site wastewater treatment plant.
GW-57 REM (November 1999) Page 2 of 9

A written Notice of Violation(NOV)was issued April 12, 1990,based upon the results of a
groundwater sample collected from the disposal pit groundwater.A Phase I environmental site
assessment was performed in August and September 1990. A Phase H environmental site
assessment was performed in November and December 1990. Based on the investigations, a
Phase I soil/source removal was performed in May 1992.Approximately 500 tons of soil were
removed from the pits and transported off-site for disposal by thermal incineration.Phase II and
Phase III soil/source removal actions were performed in October 1992. During the Phase II
-- excavation event an additional 477 tons of soil were removed from the pits and sent for disposal.
Confirmatory samples indicated that one sample contained low concentrations of heavy oils.
Based upon the presence of heavy oils at the one location,a third excavation/sampling event was
performed and an additional 100 tons of soil were removed and treated off site.
On November 4, 1992,the NCDEHNR granted closure certification of the pit areas relative to
the source removal.In July 1993 groundwater recovery and treatment was initiated to remediate
a small plume containing low concentrations of VOCs and SVOCs. Quarterly monitoring from
1993 to 1995 showed a marked decrease in constituent concentrations. In December 1995, Coats
American submitted a Corrective Action Plan(CAP)under 15A NCAC 2L.0106(1). The CAP
demonstrated that natural attenuation and natural biodegradation of constituents would remediate
groundwater without impacting current or foreseeable receptors. On March 28, 1996,the
NCDENR approved the CAP and established a groundwater sampling frequency to monitor
degradation of constituents of concern. The approved CAP allowed a reduction of monitoring
frequency from quarterly to semiannually for the first year,followed by annual monitoring.
Semi-annual monitoring was conducted during the first year(1996). Sampling was then
converted to annual monitoring, and the first event was scheduled to be conducted in 1997.
However, the initial annual monitoring was not performed until October 1998. The fifth annual
sampling event was conducted in September 2002.
The following conclusions were based on the September 2002 sampling event:
Although eight VOCs were detected in the former recovery well GM-4 during the September
2002 sampling event, only one VOC(vinyl chloride,9.7 µg/L)was reported at a concentration
above the established state 2L groundwater standards (Table 1). No constituents were detected
in samples collected from wells GM-10,RW-1 and RW-2. Since groundwater monitoring began
at the site in the summer of 1993,recovery well GM-4 is the only well to have constituents
above regulatory limits. Based on historical data from numerous sampling events conducted
over 6 years, it is evident that the area of impacted groundwater at this facility is very small and
that only limited migration has occurred due to natural attenuation. The concentration of vinyl
chloride in well GM-4 is relatively similar to that observed over the last four sampling events.
The site incident number is 5337.
G. HYDROGEOLOGIC DESCRIPTION
j SECTION(G)MUST BE ORIGINALLY SEALED AND SIGNED BY A LICENSED
GEOLOGIST
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a
depth that included the known or projected depth of contamination. The number of borings shall
be sufficient to determine the following:
GW-57 REM (November 1999) Page 3 of 9

111111
10,
j CAFirp<� �.
`aO:�G6NSF •49 ":
(1) the regional geologic setting; SEAL o
(2) significant changes in lithology;
(3) the hydraulic conductivity of the saturated zone; �•n, 5
(4) the depth to the mean seasonal high water table; and ,�•'FQ.. .•�����`
(5) a determination of transmissivity and specific yield of the aquifer to l ,y � e n
(showing calculations). "s`Jill
Regional Geologic Setting
The area of Rosman,North Carolina is situated within the Blue Ridge Province. More
specifically,Rosman is located to the east of the Brevard Fault Zone within the Chauga Geologic
Belt.The entire area of Rosman is underlain by the Henderson Gneiss,which consists of biotite
gneiss(Horton and McConnell, 1991).
Lithology
The site is underlain by silts and clays interbedded with fine sands to a depth of approximately
90 ft bls where bedrock is present. Two lithologic cross sections were constructed using
information obtained from soil borings drilled during the Phase 11 investigation. Cross-section A
-A',illustrated in Figure 4,presents site lithology from upgradient of the pits at well GM-1
through the pits and downgradient to well GM-7 parallel to the general groundwater flow
direction. Cross-section B -B', illustrated in Figure 5,presents site lithology perpendicular to
the general groundwater flow direction. The cross-sections indicate that silts and clays are
i predominant in the upper portion of the lithologic section. These fine sediments generally
coarsen downward to a silty sand at variable depths. However, a clayey-silty sand is present in
the upper section of GM-5 and extends to the middle of section of boring BH-3 southwest of the
pits. These areas of sandy material illustrate the variable nature of the sediments in the area.
However,low permeable silts and clays are generally present in the upper 10 to 15 feet of the
lithologic section, especially near the pits where they are present to a depth of at least 10 ft bls.
Groundwater Flow and Direction
Historical groundwater elevation data were collected at various times prior to and following
remedial system operation. A comparison of historical water level data is presented on Table 2
for the June 15, 1993;August 28, 1996; October 20, 1998; October 18, 1999;November 16,
2000; August 2,2001 and September 18,2002 sampling events. All data were collected during
times when the recovery system was shutdown and are indicative of natural groundwater flow
direction. All water-level data indicate that the natural groundwater flow direction is generally
to the southeast and is consistent over time. Based upon the natural groundwater flow direction,
the monitoring well network is properly positioned to detect the potential migration of
constituents from the former source area near well GM-4. Depth to the mean seasonal high
water table is approximately 4.5 feet as measured in GM-4.
The hydraulic conductivity(K),which is the capacity of a medium to transmit water, was
determined from slug tests in on-site monitor wells. The calculated K values for the wells are
_ included in Table 3.
The site groundwater flow velocity was calculated using the K values derived from the slug tests,
a hydraulic gradient of 0.03 based upon the generated water-level contour maps and an effective
4
GW-57 REM (November 1999) Page 4 of 9

porosity of 0.010 based upon site lithologic data. Using the above assumptions, an average
groundwater flow rate of 59 feet per year(ft/yr)was calculated. It is important to note that.this
is an average velocity for the site. Using the K values from individual wells,the calculated
groundwater flow velocity ranged from a high of 184 ft/yr at well GM-9 to a low of 27 ft/yr at
well GM-4.
Transmissivity can be calculated from hydraulic conductivity and aquifer thickness. Using a
value of 0.2480 ft/day for K and aquifer thickness of 20 feet,the T would be 4.96 fl/day.For the
purpose of this calculation,the surficial aquifer is assumed to be present from 5 to 25 feet below
land surface in the vicinity of GM-4.
The specific yield for the sediments at this site can be obtained from a literature reference. In the
vicinity of GM-4,the lithology is predominantly silts and clays. The corresponding specific
yield would therefore be approximately 10 percent by volume(Heath, 1989).
H. MONITORING PROCEDURE
Provide plans for proposed location and construction details of groundwater monitoring well
network,including a schedule for sampling and analytical methods. Include any
modeling/testing performed to investigate injectant's potential or susceptibility to change
- (biological, chemical or physical)in the subsurface.
After the injection points are completed, existing site monitor wells GM-4, GM-10,RW-1,and
RW-2 will be used to assess the performance of the ORC(Figure 3). Three months after the
initial ORC application, a groundwater sampling event will be conducted to measure natural
attenuation-parameters and monitor the presence of vinyl chloride(the primary COC) and other
volatile organic compounds (VOCs). Geochemical parameters pH,redox,DO,turbidity,
temperature, and specific conductivity will be measured and recorded during well purging using
a flow through cell. Groundwater samples collected from the four wells will be submitted for
laboratory analysis of VOCs using USEPA Method 8260. If analytical results dictate,
subsequent ORC applications may be performed.
I. WELL USE Will the injection well(s) also be used as the supply well(s) for the following?
(1) The injection operation? YES NO X
(2) Personal consumption? YES NO X
J. CONSTRUCTION DATA(check one)
EXISTING WELL being proposed for use as an injection well. Provide the
data in(1)through(7)below to the best of your knowledge. Attach a copy
of Form GW-1 (Well Construction Record)if available.
X PROPOSED WELL to be constructed for use as an injection well. Provide
the data in(1)through(7)below as PROPOSED construction specifications.
{
Submit Form GW-1 after construction.
cw-57 REM (November 1999) Page 5 of 9

i
(1) Well Drilling Contractor's Name: Regional Probing Services, Inc.
NC Driller Registration number: 1625
(2) Date to be constructed: 2003 (to be determined based on UIC permit approval date.
Number of borings: 9
Approximate depth of each boring(feet): 25
(3) Well casing and screens: As described in Attachment 2,there are no screened intervals,
and the injection zone will be from approximately 25 feet below land surface(ft bls)to
approximately 5 ft bls.
(4) Grout type shall be Portland Cement Type I. The boreholes will be grouted to land
surface upon completion of the injection activities
(5) N.C. State Regulations (Title 15A NCAC 2C .0200)require the permittee to make
provisions for monitoring wellhead processes. A faucet on both influent(recovered
groundwater) and effluent(fluid being injected into the well) lines is generally
required.
This is not applicable due to the one time nature of the ORC application,and the fact that
there are no well casings or screened intervals for either injection or groundwater
extraction.
Will there be a faucet on the influent line? yes_no X .
Will there be a faucet on the effluent line? yes no X .
(6) SOURCE WELL CONSTRUCTION INFORMATION: Not Applicable.
NOTE: THE WELL DRILLING CONTRACTOR CAN SUPPLY THE DATA FOR
EITHER EXISTING OR PROPOSED WELLS IF THIS INFORMATION IS
— UNAVAILABLE BY OTHER MEANS.
K. OTHER WELL DATA
Provide a tabulation of data on all wells within '/<mile of the injection well(s), excepting water
supply wells serving a single-family residence,which penetrate the proposed injection zone.
_ Such data shall include a description of each well's type, depth,record of abandonment or
completion, and additional information the Director may require.
During the Corrective Action Plan phase of work,a potable well survey was conducted during
for properties within a 1,500-foot radius of the impacted monitor well (GM-4). Wells excepting
single-family residence wells include a water supply well on the NCDOT Maintenance Building
property,and three water supply wells,two groundwater recovery wells,and 11 groundwater
monitor wells present on the Coats American property. Water-supply wells in the area typically
pump water from the bedrock,which is present approximately 90 ft bls at the site. Well data are
{ tabulated below.
GW-57 REM (November 1999) Page 6 of 9
i

Relative Top
Well Date of Casing Screened Interval
Site Well ID Typ e Installed Elevation (Feet BLS
(NCDOT TRA-25- NA NA NA NA
Maintenance 2-21
Buildings)
_ Coats GM-1 8/6/90 184.84 11-21
American GM-2 8/7/90 181.32 4-14
Sylvan Facility GM-3 8/9/90 180.26 13-23
GM-4 8/7/90 179:53 5-15
GM-5 11/28/90 178.55 10-20
GM-6 11/29/90 177.13 9-19
GM-7 11/29/90 176.17 5-15
GM-8 11/27/90 178.16 10.5-20.5
GM-9 12/19/90 176.07 8-18
GM-10 9/16/91 178.29 65-75
GM-11 9/17/91 175.40 79-89
RW-1 6/5/92 177.03 5-50
RW-2 6/4/92 177.03 5-50
PW-1 NA NA 400 feet total depth
PW-2 NA NA 400 feet total depth
PW-3 NA I NA 1 212 feet total depth
L. PROPOSED OPERATING DATA
(1)- Injection rate: Average(daily) 1_6 gallons per minute(gpm)
(2) Injection volume: Average(daily) 76.5 gallons per day(gpd)
(3) Injection pressure: Average(daily) 100 pounds/square inch(psi)
(4) Injection temperature: Average(January) N/A°F,Average(July)N/A°F
(5) Hydraulic capacity of the well: Not Applicable
(6) Expected lifetime of the injection facility: 0.005 year
(7) Give a description of how the above data will be measured and controlled:
The injection rates/volume are monitored during the injection process by pre-measuring the amount of
ORC slurry to be injected per point as specified in the work plan. The entire volume is then injected for
that point, during which time the injection pressure is monitored with an in-line standard pressure gauge.
The temperature of the injected slurry will approximate the ambient atmospheric temperature at the time
of injection. The hydraulic capacity is not applicable because there is no well casing or screened interval
with this process. The expected lifetime of the injection process is one to two days per event.
M. INJECTION-RELATED EQUIPMENT
See Attachment 2.
N. LOCATION OF WELUSl
-- Attach a scaled, site-specific map(s) showing the location(s) of the following:
GW-57 REM (November 1999) Page 7 of 9

(1) the proposed injection well(s) (See Figure 3);
(2) all property boundaries (See Figure 2);
(3) contour intervals not exceeding two feet(See Figure 1);
(4) the direction and distance from the injection well or well system to two nearby,
permanent reference points (such as roads, streams, and highway intersections) (See
Figure 2);
(5) all buildings within the property boundary(See Figure 2);
(6) any other existing or abandoned wells, including water supply and monitoring wells,
within the area of review of the injection well or wells system(See Figure 8);
(7) potentiometric surface showing direction of groundwater movement(see Figure 6);
(8) the horizontal and vertical extent of the contaminant plume(including isoconcentration
lines and plume cross sections) (see Figure 7; due to limited extent of impact above
NCAC 2L standards,i.e.vinyl chloride in only one well, a plume cross section was
not developed);
(9) any existing sources of potential or known groundwater contamination,including waste
storage,treatment or disposal systems within the area of review of the injection well or
well system(None); and
(10) all surface water bodies within 1000 feet of the injection well or well system
(see Figures 1,2).
O. INJECTION FLUID DATA
(1) Fluid source,if underground, from what depth, formation and type of rock/sediment unit
will the fluid be drawn(e.g.,granite, limestone,sand,etc.).
Not Applicable-potable water will be used for ORC slurry.
(2) Provide the chemical,physical,biological and radiological characteristics of the fluid
to be injected.
See Attachment 2.
P. PERMIT LIST
Attach a list of all permits or construction approvals that are related to the site,including but not
limited to:
(1) Hazardous Waste Management program permits under RCRA
(2) NC Division of Water Quality Non-Discharge permits
(3) Sewage Treatment and Disposal Permits
4 (4) Other environmental permits required by state or federal law.
L
All permits and construction approvals relating to the site are on file with the Environmental Compliance
Division and are available upon request.
Q. CERTIFICATION
"I hereby certify,under penalty of law,that I have personally examined and am familiar with the
information submitted in this document and all attachments thereto and that,based on my
GW-57 REM (November 1999) Page 8 of 9

All permits and construction approvals relating to the site are on file with the Environmental Compliance
Division and are available upon request.
Q. CERTIFICATION
1 hereby certify, under penalty of law,that I have personally examined and am familiar with the
information submitted in this document and all attachments thereto and that, based on my inquiry
of those individuals immediately responsible for obtaining said information,I believe that the
information is true, accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to
construct, operate, maintain,repair, and if applicable,abandon the injection well and all related
appurtenances in accordance with the approved specifications and conditions of the Permit."
(Signature of Well Owner or Authorized Agent)
Ifauthorized agent is acting on behalf of the well owner,
please supply a letter signed by the owner
authorizing the above agent.
R. CONSENT OF PROPERTY OWNER
(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 rests ownership in the landowner
in the absence of contrary agreement in writing.)
If the property is owned by someone other than the applicant,the property owner hereby consents
to allow the applicant to construct each injection well as outlined in this application and that it
shall be the responsibility of the applicant to ensure that the injection well(s) conforms to the
Well Construction Standards (Title 15A NCAC 2C .0200)
(Signature Of Property Owner If Different From Applicant)
cw-57 Ram (November 1999) Page 10 of I 1
C ,

UIC Permit
Application
FIGURES

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SCALE 1:24000 N
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Rosman, NC Topographic Quadrangle.
PUTIX Dcae9 rr. FIGURE N0.
ARCADIS
P.Pfii„1N D T a..
w&wiN NCTOPO SITE
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A PINNI% K PAHR A. NORTON
NOTES: DRAWING
ARCADIS ChM of North Carolina, Inc. SITEI Cl
801 Corporate Center Drive, Suite 300
Raleigh, NC 27607 DATE-
Tel: [phone] Fax: [phone]
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SCALE IN FEET
0 250 500
R. NC103013.0001 FIGURE:
AMERICA — SYLVAN FACILITY SITE
OSMAN, NORTH CAROLINA LAYOUT 2

I \+ LEGEND
I \+ —•—•— FENCE
• MONITOR WELL
+ A RECOVERY WELL
IPROPOSED ORC
x N \+\ INJECTION POINT
I +\ SCALE IN FEET
i +\jPROPERTY o 30
BOUNDARY
i EXCAVATED +
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GM-4 •RW-2 \+\
I EXCAVATED •
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x
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+
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x
PRJT 1aNaGER- CHECKED BY. FIGURE.
A��/�A���+ a PIHmx H PAHR MONITOR WELL AND RECOVERY WELL LOCATIONS
J BRAVING,COATS-SITE-03D AND PROPOSED ORC INJECTION POINTS 3
ARCADIS GA:M of North CmoDRo, Inc. NC103013.0001
801 CoMo.ate Center DAre, Suite 300 PRJT ND COATS AMERICAN—SYLVAN FACILITY Role. h, NC 27607
rel: $19-854—IZ82 Fax: [phone] DVG DATE. DWYER. ROSMAN, NORTH CAROLINA
www.OrcaEie—ue.com 13MY03 A. NORTON

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105 GM-1 8H-1 GI GM-3 GM-4 GM-10 GM-7 185
180 I I I I 180 A1�
175 6. . . 4 k 175 I \•\, w-B
,. 1`YSllfy'ySandJ II uixx \\ x170
-P
170 -
T a �= elnc I cu-m A.
165 s"fA7 +. H t- ,y,, ..; • 165 I Du-a Ae oa-11
GM-6
160 �4'a 160
T I
c �
155 nr } 155
150 F' 5 � ' y- + x�"r� A pf A t _ Fiy fi ,.f{�3y,1 6r . 150
145 'Ati"'r� ,a�8 ' de"� '� .0 t¢ 145
�,,yytk rrt-t`.+s`1ft,R,,`s qr. ,i' &]fir �' tr'1 Y . 1i, + � T ,Y�•' '' h _ 3-'^'i .� ti'ur LEGEND
wo
140 , , , Organic Clays and Organic
Silty Clay
135 -r�, 1s „ I • 135 Inorganic Clays and Gravelly,
Sandy. or Silty Clay
130 130
T Sc Silty Sands, Poorly Graded
• .{125 3 r ,I!._ Sand-Silt Mixture
� �3 I I �i� jtx '` I ! s hu 1T,d+ 125
z • } `" �' "r ,,� '' Inorganic Silts, Fine or Silty
s g '
-$' r '-'r1 tl '''`. 120 Soils
d
® Inorganic Clays
115
115 Land Surface
110 w� { R ' ,`'`'',ret�y �� ,£'v Well Casing
vERncAL'SCAtE.IN FEET -..�.---- - - -
105
105 0 15 30
100 II' S Q�r .r`W`h 4 Id iillti 11: k3N 1 Y .' + rk 'rri>Fi'+ `J h4. g P't
7fi. 00
HORIZONTAL SCALE IN FEET
O 60 120 '
95
95
PRJT MANAGER. CHECKED BY, - FIGURE.U vING,%A-A N PANR
GENERALIZED SUBSURFACE CROSS-SECTION A-A'
ARCADIS MIJ RT N•Ah Caralina, Iac:2760) A
Rv
801 CerPemmal caer OAve. Suite 300 PRJT Na
a NC103013,0001 COATS AMERICAN SYLVAN FACILITY laigqh, NC
Tel: [phone]e2 Far. 919-854-5448 DWG DATE. DRArTM ROSMAN, NORTH CAROLINA
.orcaala—ue.c•m 16MAY03 A. NORTON

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175
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170 -ry'Y; i..:3tf
C} Clayey Silty Sand* R'` .4'. -tr 170 Clayey Silty Sand, Poorly
1
Graded Sand-Silt-Clayey Mixture
Ck �y. �3�Y 4'SGa x�l � 4 i '. � � •�'.
n T`i s. ° . Inorganic Clays and Gravelly,
165
.,�;€x�a'� .� 165 Sandy, or Silty Clay
-- ;17 Silty Sands, Poorly Graded
160 1fi0 Sand-Silt Mixture
�`.,� I .� �� ,
Inorganic Silts, Fine Sandy
'I' _' '� '+-P • 'i or Silty Soils
155 155 Inorganic Silts & Fine Sands,
® Silty or Clayey Fine Sand
° ® Inorganic Clays
150 150
Land- Surface
Well Casing
VERTICAL SCALE IN-FEET
0 10 20
HORIZONTAL SCALE IN FEET
0 40 RO
PRJT MANAGER- EMEE'HED BY• nOUflE:
ARCAD_ 1S A PINNI% M PAHR
BRAVING e_B GENERALIZED SUBSURFACE CROSS-SECTION B-B'
set C. c31u C M.r dC.. BC. Inc. NC103013.0001 5
e01 IS G&b f Mort OCar Carolina,
c. PRJT N6
Raleigh, NC 27607 COATS AMERICAN SYLVAN FACILITY '
TAR: B1B-es4-1282 FR.: 919-ee4-s44s DWG DATE. DRAFTER ROSMAN, NORTH CAROLINA
ww,orcadI.....com 16MAYD3 A. NORTON

00 w
�
GM-1
174.80 r\ PROPERTY
i BOUNDARY
r
+\ b
EXCAVATED \r
PIT AREA 2\O \
O
I \r �GM-8
GM-2 \, 172.17
ASSUME 184.0' ELEVATION i 174.48� \ /
AT LOADING DOCK ENTRANCE
GM-3 G •
172.72 GM-9
• RW-2 168.65
172*72
EEXPITCAVA PIT 1 GM-10 \r '
\«
/ BUILDING I� � � \r
j PAVED I • GM-5 RW-1• 168.39• \r\
170.46 • GM-11
/ II • GM-6
168.81
LEGEND
—•— FENCE NOTE 1: ALL ELEVATIONS ARE RELATIVE TO I
• MONITOR WELL THE LOADING DOCKENTRANCE. i
A RECOVERY WELL NOTE 2: GROUNDWATER ELEVATION DATA
172.72 WATER LEVEL ELEVATION (FT,MSL) FROM WELLS GM-10, GM-11, i
—170— POTENTIOMETRIC CONTOUR 2-FT RW-1 & RW-2 WERE NOT USED
( ) IN DETERMINING GROUNDWATER
3 GROUNDWATER FLOW DIRECTION CONTOURS DUE TO SCREENING SCALE IN FEET
DEPTHS BELOW SHALLOW AQUIFER. 0 60
PRJT PANI H. PAHR BY, GENERALIZED - FIGURE:
Va ARCADIS PINNIX H. PANR
9RAv1xd COATS-SITE-03 GROUNDWATER FLOW DIRECTION
801AD;S G&Meof Net o`Carolina,
Inc. PUT Nd SEPTEMBER 18, 2002 6
Raley", INC 2760T NC103013.0001
Tel: [phone] Pox. 919-854-5448 DvG COATS AMERICAN—SYLVAN FACILITY
ewr.a,caele-ae.com 13HAY03E A NCR;N ROSMAN, NORTH CAROLINA

GM-1
174.80
I r PROPERTY
i \ BOUNDARY
r\r 1`T
r\ _
r
EXCAVATED \+
PIT AREA 2\ \
GM-2 �• \+ NS
ASSUME 184.0' ELEVATION I UZI \r
AT LOADING DOCK ENTRANCE GM-3 *, GM-4 \+ •
...t.' • RW-2\
rW
EXCAVATED GM-10 <1.0 r\
PIT AREA 1 <1.0 +\
/ BUILDING I +\r
j PAVED RW_1 O NS \♦\•• G© <1.0
• GM—lL
NS
• GM-6
LEGEND I NS
—•— FENCE
• MONITOR WELL
RECOVERY WELL i
90. VINYL CHLORIDE CONCENTRATION (Ng/L)
FN_Sj NOT SAMPLED
APPROXIMATE HORIZONTAL EXTENT l OF GROUNDWATER IMPACT ABOVE SCALE IN iEEf
GGG....0 NC 2L STANDARDS o 60
PRJT MANAGER. CHECKER 9Y. VINYL CHLORIDE - ^°ORE:
ARCADIS A N PARR (N9/L)
DRAWING.
viNU COATS-SITE-03 CONCENTRATIONS
801 CI°rpomto Center ofna 7m a°ia0 PRJT NEB SEPTEMBER 18, 2002 7
Tel:91, NC 4-128 NC I03013.0001
Tel: 9 , NC 2-1382 Fat: 919-850-5449 COATS AMERICAN—SYLVAN FACILITY
'"•araa019—° °°m ISMAYOTE A. NORTON ROSMAN, NORTH CAROLINA

1
I 32 1 25E� 26
21A 97 _
21 6� 8
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12D - -_12A � 92D
-L 12C 1 12B `
� - ,12E
-�- L 12
12E\
SCALE IN FEET
0 400 800 - -�_L
A.PUT MANAGER CHECKED BY, DRAFTERS PROJECT
ARCADI L NOTES: M. PAHR DDRAWINGN ARCADIS C&M of North Carolina, Inc. TRANS-1
801 Corporate Center Drive, Suite 300
Raleigh, NC 27607 DATE,
Tel: [phone] Faz: 919-854-5448
www,arcadis—us.com l6MAY03
i

1 i
I 1 \ I
89 ` 92G
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MoU 91 \`
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LEGEND
1500-FT = PROPERTY LINE
RADIUS — 1500-FT RADIUS FROM SOURCE
/ INTERMITTENT STREAM
\ �I( WATER SUPPLY WELL
NOTE: SEE TABLE FOR ,PROPERTY DESCRIPTIONS..
ER' NC103013.0001 FlGURE:
f AMERICAN - SYLVAN FECILITY WATER-SUPPLY WELLS WITHIN 1,500=FEET
?OSMAN, NORTH CAROLINA OF THE SOURCE AREA 8
i

UIC Permit
Application
ARCADIS
TABLES

Table 1. Groundwater Quality Detection Summary,September 2002 Sampling Event,Coats American-Sylvan Plant,Rosman,North Carolina.
Constituent NC GWI/ GM4 DUP-1* GM-10 RW-1 RW-2
Date Sampled 9/18/2002 9/18/2002 9/18/2002 9/18/2002 9/18/2002
Pnrgeable Halnearbons
(USEPA Method 601)µg/L
1,1-Dichloroethane 700 8.1 9.0 <1.0 <1.0 <1.0
1,1-Dichloroethene 7 <5.0 <5.0 <1.0 <1.0 <1.0
1,1,1-Txichloroethane 200 5.0 <5.0 <1.0 <1.0 <1.0
Trichlorofluoromethane 2100 15 16 <1.0 <1.0 <1.0
Vinyl Chloride 0.015 9.7 9.2 <1.0 <1.0 <1.0
Pnrgeable Aromatics
(USEPA Method 602)µg/L
Toluene 1000 110 100 <I.0 <I.0 <1.0
Ethylbenzene 29 14 14 <1.0 <1.0 <1.0
Total xylenes 530 84 75 <2.0. <2.0 <2.0
Semi-Volatile Orga_ni .a
(USEPA Method 8270)µg/L - ND ND ND ND ND
Total TICsv 116.6 145.3 141 32 103.7
µg/L Micrograms per liter.
I/ North Carolina Subchapter 2L Groundwater Standards.
v Tentatively identified Compounds(TICS)(estimated concentrations).
J Sample data are qualified as estimated.
< Not detected above the quantitation limit.
* Blind field replicate of primary groundwater sample GM-4.
OConstituent concentration is above groundwater standard.
ND Compounds were not detected in sample.
GAEnv\CantsAmeri=\Sylvan 1`1=62002 S=pling\Tables\tablel.xls

Table 2. Groundwater Elevations, Coats American-Sylvan Plant,Rosman,North Carolina.
Pre-Pumping Non-Pumping Non-Pumping
Measuring 6/15/1993 8/28/1996 10/20/1998
Well Point Depth to Water-Level Depth to Water-Level Depth to Water-Level
Elevation* Water** Elevation Water** Elevation Water** Elevation
~ GM-1 184.84 11.72 173.12 9.22 175.62 11.10 173.74
GM-2 181.32 9.30 172.02 4.85 176.47 7.37 173.95
J GM-3 180.26 9.25 171.01 7.09 173.17 8.12 172.14
GM-4 179.53 8.80 170.73 4.50 175.03 5.38 174.15
GM-5 178.55 11.15 167.40 8.26 170.29 9.20 169.35
GM-6 177.13 14.32 162.81 8.77 168.36 11.09 166.04
GM-7 176.17 11.64 164.53 8.31 167.86 9.21 166.96
GM-8 178.76 8.46 170.30 7.92 170.84 7.21 171.55
GM-9 176.07 11.05 165.02 9.03 167.04 8.79 167.28
GM-10 178.29 11.78 166.51 8.67 169.62 9.55 168.74
GM-11 175.40 15.94 159.46 11.37 164.03 12.40 163.00
RW-1 177.03 13.75 163.28 9.89 167.14 9.81 167.22
RW-2 177.37 12.14 165.23 8.90 168.47 9.83 167.54
Non-Pumping Non-Pumping Non-Pumping
Measuring 11/16/2000 8/2/2001 9/18/2002
Well Point Depth to Water-Level Depthto Water-Level Depthto Water-Level
Elevation* Water** Elevation Water** Elevation Water** Elevation
GM-1 184.84 9.70 175.14 10.09 174.75 10.04 174.80
GM-2 181.32 6.00 175.32 4.95 176.37 6.84 174.48
GM-3 180.26 6.72 173.54 ND ND 7.54 172.72
GM-4 179.53 4.35 175.18 4.41 175.12 5.50 174.03
GM-5 178.55 6.79 171.76 7.77 170.78 8.09 170.46
GM-6 177.13 7.61 169.52 7.90 169.23 8.32 168.81
GM-7 176.17 6.83 169.34 7.36 168.81 7.78 168.39
GM-8 178.76 5.94 172.82 6.36 172.40 6.59 172.17
GM-9 176.07 6.57 169.50 7.09 168.98 7.42 168.65
GM-10 178.29 6.66 171.63 7.50 170.79 7.72 170.57
GM-11 175.40 5.56 169.84 7.15 168.25 7.58 167.82
" RW-1 177.03 7.92 169.11 8.13 168.90 8.44 168.59
RW-2 177.37 6.95 170.42 7.63 169.74 7.92 169.45
* Measuring point is the top of PVC casing;all elevations are relative.
** Depth below top of PVC casing.
ND No Data
G:\Env\Coats Amexi=\Sylvaa P1an62002 Annual Monitoring\Tables

Table 3. Hydraulic Conductivity Values from Slug Tests, Coats American Sylvan Plant,
Rosman,North Carolina.
Well Hydraulic Conductivity(K) cm/sec
GM-1 2.68 x 10-4
GM-3 1.10 x 10-4
GM-4 8.75 x 10"5
GM-5 1.17 x 10-4
GM-6 1.22 x 104
GM-7 7.47 x 10-5
GM-8 1.63 x 104
GM-9 5.93 x 10-4
cm/sec Centimeters per second.
g:lmWeoan�ai�\%➢han plmtWic pemitUable 3.d«\

UIC Permit
Application
ARCADIS
ATTACHMENT t
ORC MATERIAL SAFETY
DATA SHEET

L-.
OXYGEN RELEASE COMPOUND (ORC®)
MATERIAL SAFETY DATA SHEET (MSDS)
Lr
Last Revised:March 27,2003
L~
SECTION 1 -MATERIAL IDENTIFICATION
*####k########***************kk##******#k########*#k#####************######**#
SUPPLIER:
REGENESIS
1011 Calle Sombra
San Clemente, CA 92673
949-366-8000 phone
949-366-8090 fax
[e-mail] e-mail
CHEMICAL DESCRIPTION:
A mixture of Magnesium Peroxide [M902],Magnesium Oxide [MgO], and Magnesium
Hydroxide [Mg(OH)2]
CHEMICAL FAMILY:
Inorganic Chemicals
r , PRODUCT NAME:
j Oxygen Release Compound(ORC"')
PRODUCT USE:
Used for environmental remediation of contaminated soil and groundwater
SECTION 2-CHEMICAL IDENTIFICATION
CHEMICAL CHARACTERIZATION
Magnesium Peroxide [MgO2]: CAS Reg.No. 14452-57-4
Magnesium Oxide [MgO]: CAS Reg.No. 1309484
Magnesium Hydroxide((Mg(OH)2): CAS Reg.No. 1309-42-8
` FORM : powder
- COLOR:white
ODOR: odorless
j I ASSAY:25 -35%Magnesium Peroxide(MgO2)

******************************************************************************
SECTION 3 -PHYSICAL AND TECHNICAL SAFETY DATA
******************************************************************************
MELTING POINT:Not Determined
BOILING POINT:Not Determined
DENSITY: 0.6-0.8 g/cc
BULK DENSITY: ---
VAPOR PRESSURE: Data not available
VISCOSITY: --
SOLUBILITY: Reacts with water. Soluble in acid
pH VALUE: Approx. 10 in saturated solution
FLASH POINT:Not applicable
SELF-IGNITION TEMPERATURE:Not applicable
EXPLOSION LIMITS %BY VOLUME: —
THERMAL DECOMPOSITION: Spontaneous decomposition possible about 150' C
` HAZARDOUS DECOMPOSITION PRODUCTS:Not known
HAZARDOUS REACTIONS: Hazardous polymerization will not occur
FURTHER INFORMATION:Non-combustible,but will support combustion
SECTION 4-REACTIVITY DATA
STABILITY: Product is stable unless heated above 150°C.Magnesium Peroxide reacts with
water to slowly release oxygen.React by product is magnesium hydroxide
1 CONDITIONS TO AVOID: Heat above 150°C. Open flames
INCOMPATIBILITY: Strong Acids. Strong chemical agents
HAZARDOUS POLYMERIZATION:None known
I
1

##############################################################################
SECTION 5-REGULATIONS
##############################################################################
PERMISSIBLE EXPOSURE LIMITS IN AIR:Not established. Should be treated as a nuisance
dust.
SECTION 6-PROTECTIVE MEASURES,STORAGE,AND HANDLING
TECHNICAL PROTECTIVE MEASURES
STORAGE: Keep container tightly closed.Keep away from combustible material
HANDLING: Use only in well-ventilated areas
PERSONAL PROTECTIVE EQUIPMENT
_ RESPIRATORY PROTECTION: Recommended(HEPA Filters)
HAND PROTECTION: Wear suitable gloves
EYE PROTECTION: Use chemical safety goggles
OTHER: ---
INDUSTRIAL HYGIENE: Avoid contact with skin and eyes
PROTECTION AGAINST FIRE AND EXPLOSION: ---
DISPOSAL: Dispose via sanitary landfill per state/local authority
f
_ FURTHER INFORMATION:Not flammable,but may intensify fire
##############################################################################
SECTION 7-MEASURES IN CASE OF ACCIDENTS AND FIRE
AFTER SPILLAGE/LEAKAGE/GAS LEAKAGE: Collect in suitable containers.Wash
remainder with copious quantities of water.
J EXTINGUISHING MEDIA
it
SUITABLE: Carbon dioxide, dry chemicals, foam
I� NOT TO BE USED: ---
FURTHER INFORMATION: Self contained breathing apparatus or approved gas mask should
f I be wom due to small particle size. Use extinguishing media appropriate for surrounding fire.
1

FIRST AID:After contact with skin,wash immediately with plenty of water and soap. In case of
contact with eyes,rinse immediately with plenty of water and seek medical attention.
FURTHER INFORMATION: ---
**MMMMMMMMMMM#MMMM***MM*MM###*##*MMMM#**MMMMM#######**#*##########**#*MM##****
SECTION 8-INFORMATION ON TOXICOLOGY
*MMMM##*#########M#M##MM###****MM###**MMM##**#***#*****MM**MM*MMMMMM###***MMM#
TOXICITY DATA:Data not available
*****MMMMMMMM*M*#***MM#*MMMMM###**MM#****MMMM##*#***************#*MMMMM###****
SECTION 9-INFORMATION ON ECOLOGY
WATER POLLUTION HAZARD RATING(WGK): 0
****MM#MMM#MMMMMMM#MMM#MMMM###**MMMM#*#**MMM#########**####*######**#*#MMM####
SECTION 10-FURTHER INFORMATION
After the reaction of magnesium peroxide to form oxygen the resulting material,magnesium
hydroxide is mildly basic. The amounts of magnesium oxide (magnesia) and magnesium
hydroxide in the initial product have an effect similar to lime,but with lower alkalinity.
The information contained in this document is the best available to the supplier at the time of
writing,but is provided without warranty of any kind. Some possible hazards have been
determined by analogy to similar classes of material. The items in this document are subject to
change and clarification as more information becomes available.
C
l
I
� I
i �L

UIC Permit
Application
ARCADIS
ATTACHMENT 2
ORC SLURRY
INSTALLATION
INSTRUCTIONS
I
I
I
1

z'
REGENESIS
Oxygen Release Compound (ORC(5)
Installation Instructions
(Direct-Injection Slurry Application)
SAFETY:
Pure ORC is shipped to you as a fine powder rated at-325 mesh (passes through a 44
micron screen). It is considered to be a mild oxidizer and as such should be handled
with care while in the field. Field personnel should take precautions while applying the
pure ORC. Typically, the operator should work upwind of the product as well as use
appropriate safety equipment. These would include eye and respiratory protection,
and gloves as deemed appropriate by exposure duration and field conditions.
Personnel operating the field equipment utilized during the installation process should
have appropriate training, supervision and experience.
GENERAL GUIDELINES:
_! ORC may be installed in the contaminated saturated zone in the ground utilizing hand
augered holes, Geoprobe°type hydraulic punch equipment, or hollow stem augers.
This set of instructions is specific for Geoprobe equipment. Alternate instructions may
be obtained from the Regenesis Technical Support Department.
For optimum results the ORC slurry installation should span the entire vertical
contaminated saturated thickness, including the capillary fringe and "smear zone".
f Two general installation approaches are available. The first is to backfill only the
probe hole with slurry. This is a simple approach, in that it is easy, straightforward,
and the location of the ORC slurry is-precisely known after installation. However, this
method requires significantly more probe holes than the alternative, and may take
more time for the completion of the remediation process. A separate set of
instructions for this method utilizing Geoprobe equipment is available from Regenesis.
The second method is to inject the slurry through the probe holes into the
contaminated saturated zone. This method requires fewer probe holes, is less
disruptive to the site, and aids the spread of oxygen by spreading the ORC source
material. However, it may be difficult to know the exact, final disposition of the ORC
installed with this method. This is the method described in these instructions.
Note: It is important that the installation method and specific ORC slurry point location
— be established prior to field installation. It is also important that the ORC slurry volume
and solids content for each drive point be predetermined. The Regenesis Technical
h Service Department is available to discuss these issues, and Helpful Hints at the end
of these instructions offers relevant information. Regenesis also has available
Technical Bulletins covering source treatments with ORC.
1
J

I` SPECIFIC INSTALLATION PROCEDURES
1. Identify the location of all underground structures, including utilities, tanks,
distribution piping, sewers, drains, and landscape irrigation systems.
2. Identify surface and aerial impediments.
3. Adjust planned installation locations for all impediments and obstacles.
4. Pre-mark the installation grid point locations, noting any that have special depth
requirements.
5. Set up the Geoprobe unit over each specific'point, following manufacturer
recommended procedures. Care should be taken to assure approximate
vertical probe holes.
6. Penetrate surface pavement, if necessary, following standard Geoprobe
procedures.
7. Drive the 1 112" (one-and-one-half inch) pre-probe (part#AT-148B) with the
expendable tip (part#AT142B) to the desired maximum depth. Standard 1"
(one.inch) drive rods (part AT104B) should be used, after the pre-probe, (Hint:
-- Pre-counted drive rods should be positioned prior to the installation driving
procedure to assure the desired depth is reached.)
8. Disconnect the drive rods from the expendable tip, following standard Geoprobe
procedures.
9. Mix the appropriate quantity of ORC slurry for the current drive point. (See
separate "Directions for ORe Slurry Mixing" and Helpful Hints). Note: Do not
_ mix more slurry than will be used within a 30 minute period.
10.Set up and operate an appropriate slurry pump according to manufacturer's
directions. Based on our experience, a Geoprobe model GS-1000 pump is
recommended. Connect the pump to the probe grout pull cap (GS-1054) via a
1 inch diameter delivery hose. The hose is then attached to the 1" drive rod
with its quick connector fitting. Upon confirmation of all connections add the
ORC slurry to the pump hopper/tank.
11.Withdraw the pre-probe and drive stem 4' (four feet). (Also note Helpful Hints -
Operations at end of instructions.)
12.Optional pretreatment step. (See Helpful Hints - Operations at end of
instructions). Pump one to two gallons of tap water into the aquifer to enhance
dispersion pathways from the probe hole.
13.Pump the predetermined quantity of ORC slurry for the depth interval being
injected. Observe pump pressure levels for indications of slurry dispersion or
refusal into the aquifer. (Increasing pressure indicates reduced acceptance of
material by the aquifer).
14.Remove one 4' section of the 1" drive rod. The drive rod will contain slurry.
This slurry should be returned to the ORC bucket for reuse.
15.Repeat steps 11, 13, and 14 until treatment of the entire affected thickness has
been achieved. It is generally recommended that the procedure extend to the
top of the capillary fringe/smear zone.
16.Install an appropriate seal, such as bentonite, above the ORC slurry through the
-- entire vadose zone. This helps assure that the slurry stays in place and
prevents contaminant migration from the surface. Depending on soil conditions
and local regulations, a•bentonite seal can be pumped through the slurry pump
or added via chips or pellets after probe removal.
17.Remove and decontaminate the drive rods and pre-probe.
2

18.Finish the probe hole at surface as appropriate (concrete or asphalt cap, if
necessary).
is. Move to the next probe point, repeating steps 5 through 18.
HELPFUL HINTS:
A. Physical characteristics
Al. Slurry
The ORC slurry is made using the dry ORC powder(rated at-325 mesh). It makes a
smooth slurry, with a consistency that depends on the amount of water used.
A thick, but pumpable, slurry that approaches a paste can be made by using 65-67%
solids. This material would normally be used for back-filling a bore or probe hole. It is
especially useful where maximum density is desired such as where ground water is
present in the hole or there are heaving sands.
Thinner slurries can be made by using more water. Typical solids for the thinner
slurries content will range from 35% to 62%. Such slurries are useful for injecting
through a probe or bore hole into.the saturated aquifer.
As a rule, it is best to mix the first batch of slurry at the maximum solids content one
would expect to use. It can then be thinned by adding additional water in small
increments. By monitoring this process, the appropriate quantities of water for
subsequent batches can be determined.
The slurry should be mixed at about the time it is expected to be used. It is best to not
hold it for more than 30 minutes. Thinner slurries, especially, can experience a
separation upon standing. All ORC slurries have a tendency to form cements when
left standing. If a slurry begins to thicken too much, it should be mixed again and
additional water added if necessary.
Care should be taken with slurry that may be left standing in a grout pump or hose.
_ Problems can generally be avoided by periodically re-circulating the slurry through the
pump and hose back into the pump's mixing or holding tank.
A2. Equipment
Most geotechnical grout pumping equipment has a holding tank with a capacity
sufficient for injection.
When applying measured volumes of ORC slurry to probe holes, it is sometimes useful
to know the volumes and content of the delivery system lines. The following
information may be useful in this regard.
Geoprobe pump: At the end of a pump stroke virtually no deliverable slurry remains in
the pump.
5/8" O.D. connecting hose(10 feet long): 0.2 gallons (26 fluid ounces).
Four foot(4')length of 1"drive rod: .04 gallons(5 fluid ounces).
Three foot(3') length of 1 1/2"pre-probe: .03 gallons(4 fluid ounces).
3

Cleaning and maintenance:
Pumping equipment and drive rods can be lightly cleaned by circulating clear water
through them. Further cleaning and decontamination (if necessary due to subsurface
conditions) should be performed according to the equipment supplier's standard
procedures and local regulatory requirements.
B. Operating characteristics
131. Operations - General
Judgment will be needed in the field when injecting ORC slurries. In general, it is
relatively easy to inject ORC slurries into sandy soils, and this can usually be
accomplished at very moderate pressures. Silts and clays require more pressure, and
may accept less slurry.
Careful observation of pressure during slurry pumping is the best indication of the
effectiveness of the slurry injection. To test the soil's ability to accept the slurry and to
"precondition" the injection point for the slurry, it is sometimes useful to inject a small
volume of plain water prior to the slurry. Normally, one-half(0.5) gallons to two (2)
gallons would be appropriate.
During injection, increasing pressure and decreasing flow rate are signs of refusal by
the soil matrix to accept the slurry. The site geologist should determine whether to
increase pressure, and possibly fracture ("frac') the soil matrix to achieve ORC slurry
installation in a tight site that has refused the slurry at lower pressures.
B2. Fill Volumes
Probe hole back-filling
Probe hole capacities:
Per 10'(Ten Foot)Length
Theoretical Operating Volume
(Gallons/Fluid Ounces/Cubic Inches) (Gallons/Fluid Ounces)
Sand, Silts&Clay Sand Silts &Clay
1" Diameter .41 gal/52 fl. oz./94.2 cu. in. 11.61 gal/78 fl. oz. 51 gal/65 fl.oz.
1 1/2" Diameter .92 gal/117 fl. oz./212.0 cu. in. 111.38 gal/176 fl. oz. 1.15 gal/146 fl. oz.
T Diameter 11.63 gal/209 fl.oz./376.8 cu. in. 112.44 gaU313 fl. oz. 2.04 gal/261 fl.oz.
2 1/4" Diameter 2.06 gaU264 fl. oz./476.9 cu. in 113.09 gal/396 fl. oz. 2.57 gaU330 fl. oz.
Note that the operating volumes include a 50% excess above the theoretical volume in
sands and 25% in clays and silts. This is important to successful treatment. The
additional material allows for a small degree of infiltration of the slurry into the
surrounding soil and fractures, as well as hole diameter variability. It is important to
assure that the entire contaminated saturated zone is treated (including the capillary
fringe), since this is often the area of highest pollution concentration. Failure to treat
this area due to improper installation can undermine an otherwise successful
remediation effort.
4

For direct assistance or answers to any questions you may have regarding
these instructions, contact Regenesis Technical Services at 949-366-8000.
REGENESIS, 2002
- www.regenesis.com
5

UIC Permit
Application
ARCADIS
ATTACHMENT 3
DESIGN CALCULATIONS

_ -ORC Design Software for Grid Applications Using Slurry Injection ` USverdon 3.1
Re9ales5 Teihnial Support:USA(949)3668000,xwu2Eegaless.min - t _ I
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I JUN 19 2003
D
UNDERGROUND INJECTION
GROUNDWATER SECTION
CONTROL PERMIT ASHEVILLE REGIONAL OFFICE
APPLICATION
Coats American Sylvan Plant
Rosman, North Carolina
Groundwater Incident No. 5337
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May 2003
0ARCADIS
Infrastructure, buildings, environment, communications
PREPARED FOR
Coats American, Inc.

ARCADIS
UNDERGROUND INJECTION
CONTROL PERMIT
APPLICATION
Coats American Sylvan Facility
Rosman, North Carolina
Groundwater Incident No. 5337
Prepared for
Coats American,Inc.
Prepared by
ARCADIS Geraghty&Miller of
North Carolina,Inc
801 Corporate Center Drive
Suite 300
North Carolina 27607
Tel [phone]
Fax [phone]
Our Ref.:
NC103013.0001
Dab:
May 2003
This document is intended only for the use of
the individual or entity for which it was
prepared and may contain information that is
privileged,confidential,and exempt from
disclosure under applicable law.Any
d&eminatxln,dstdbution,or copying of the
document B strictly prohibited.

ARCADIS
GENERAL APPLICATION FOR PERMIT TO CONSTRUCT
AND/OR USE A WELL(S)FOR INJECTION
COATS AMERICAN SYLVAN PLANT
ROSMAN,NORTH CAROLINA
GROUNDWATER INCIDENT NO.5337
May 2003
Provided byARCADIS G&MofNorth Carolina,Inc.
Michelle R.yq,P.E.
Project eer
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NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
TO: DIRECTOR,NORTH CAROLINA DIVISION OF WATER QUALITY
DATE: May 30,2003.
A. PERMIT APPLICANT
` Name: Mr.Mike Bell. Environmental and Safety Coordinator
Address: Coats North America
Post Office Box 670
City: Toccoa State: GA Zip Code: 30577
County: Stephens Telephone: [phone] Ext.2248
B. PROPERTY OWNER(same as applicant)
C. STATUS OF APPLICANT
Private: Commercial: X Federal: State:
County: Municipal: Native American Lands:
D. FACILITY(SITE)DATA
Name of Facility: Coats American Sylvan Plant
Address:Highway 178
City: Rosman Zip Code: 28772 County: Transylvania
Telephone: [phone] Ext. 17 Contact Person: Eddie Briscoe
E. INJECTION PROCEDURE
Provide a detailed description of all planned activities relating to the proposed injection facility
including but not limited to:
(1) Construction Plans and Materials: ARCADIS G&M of North Carolina,Inc. (ARCADIS)
will subcontract with Regional Probing Services,Inc. (Regional Probing)to inject
Oxygen Release Compound(ORC)into 9 temporary well points at the Coats Sylvan
Manufacturing Facility(the Site)shown on Figures 1,2,and 3. The ORC material
properties are described in the Material Safety Data Sheet(MSDS)provided as
Attachment 1. ARCADIS and Regional Probing will follow the procedures described by
OW-57 REM (November 1999) Page 1 of 9

REGENESIS Bioremediation Products in Attachment 2: ORC®Slurry Installation
Instructions, Geoprobe®Injection into the Soil Matrix.
During the initial application,the 9 injection points in the source area will be treated
with a slurry solution of 60 pounds of ORC and 17 gallons of water per point for a total
of 540 pounds of ORC and 153 gallons of water. The calculations used to design the
injection program are included in Attachment 3.
- (2) Operation Procedures:Refer to Attachment 2.
(3) Planned Injection Schedule: The proposed scheduled is to complete the injection within
a two day period to commence within 4 weeks of UIC permit application approval in
2003.The proposed injection of ORC will be used to reduce the concentrations of
contaminant constituents present in the surficial aquifer at the Site. A second,and
possibly a third injection of ORC may be required to achieve the desired contaminant
reduction. An injection schedule for the additional injections is unavailable at this time,
due to the length of time for monitoring the first injection. It is anticipated that the
additional injection events will be performed in less than two days. Additional injections
may not be necessary depending on the success of the initial ORC injection. Written
notification to NCDENR will be made at least thirty days prior to any subsequent
injections.
F. DESCRIPTION OF SITE
Provide a brief description of the contamination incident and the incident number assigned by
the Division of Water Quality staff in the Department's Regional Office:
The Coats American- Sylvan Facility is in a rural area of Transylvania County on State
Highway 64 near Rosman,North Carolina(Figure 1). The facility,which lies outside the
corporate limits of Rosman, is a spinning plant for textile threads used in industrial sewing. The
plant was constructed in the mid-1960's and was owned and operated by American Thread until
1991 when American Thread and Coats merged to form Coats American.The 50-acre plant
property is bounded on the north,south and east by pasture land. State Highway 64 borders the
plant on the western side. The land on the opposite side of Highway 64 is primarily pasture with
two parcels containing vacant houses.
Topographically,the site lies on the fluvial plain of the French Broad River.The site slopes
gently to the southeast, at a horizontal gradient of approximately 0.01 feet/foot,toward the
French Broad River,which is approximately 2,000 feet from the site. The surrounding area is
characterized by the hills and valleys of the southern Blue Ridge physiographjc province.
Galloway Creek, a tributary of the French Broad,borders the facility on the west and south sides.
When the Sylvan plant began operations in the mid-1960's, floor scrubber and frame cleaning
water was placed into a storm-water drain which flowed into the French Broad River. In the
early 1970s a small(8 feet x 8 feet x 5 feet deep)pit was dug on the Company property for
deposition of the scrubber and frame cleaning water. In 1984 or 1985,the first pit was covered
by filling with soil and a second pit was dug: The second pit was used until January 1989 and
was covered/filled with soil in August 1989. The floor scrubber and washer water has since been
placed into the on-site wastewater treatment plant.
GW-57 REM (November 1999) Page 2 of 9

A written Notice of Violation(NOV)was issued April 12, 1990,based upon the results of a
groundwater sample collected from the disposal pit groundwater.A Phase I environmental site
assessment was performed in August and September 1990. A Phase II environmental site
assessment was performed in November and December 1990. Based on the investigations, a
Phase I soil/source removal was performed in May 1992.Approximately 500 tons of soil were
removed from the pits and transported off-site for disposal by thermal incineration.Phase II and
Phase III soil/source removal actions were performed in October 1992. During the Phase II
excavation event an additional 477 tons of soil were removed from the pits and sent for disposal.
Confirmatory samples indicated that one sample contained low concentrations of heavy oils.
Based upon the presence of heavy oils at the one location, a third excavation/sampling event was
performed and an additional 100 tons of soil were removed and treated off site.
On November 4, 1992,the NCDEHNR granted closure certification of the pit areas relative to
the source removal.In July 1993 groundwater recovery and treatment was initiated to remediate
a small plume containing low concentrations of VOCs and SVOCs. Quarterly monitoring from
1993 to 1995 showed a marked decrease in constituent concentrations. In December 1995, Coats
American submitted a Corrective Action Plan(CAP)under 15A NCAC 2L.0106(1). The CAP
demonstrated that natural attenuation and natural biodegradation of constituents would remediate
groundwater without impacting current or foreseeable receptors. On March 28, 1996,the
NCDENR approved the CAP and established a groundwater sampling frequency to monitor
degradation of constituents of concern. The approved CAP allowed a reduction of monitoring
frequency from quarterly to semiannually for the first year, followed by annual monitoring.
Semi-annual monitoring was conducted during the first year(1996). Sampling was then
converted to annual monitoring, and the first event was scheduled to be conducted in 1997.
However,the initial annual monitoring was not performed until October 1998. The fifth annual
sampling event was conducted in September 2002.
The following conclusions were based on the September 2002 sampling event:
Although eight VOCs were detected in the former recovery well GM-4 during the September
2002 sampling event,only one VOC (vinyl chloride, 9.7 µg/L) was reported at a concentration
above the established state 2L groundwater standards (Table 1). No constituents were detected
in samples collected from wells GM-10,RW-1 and RW-2. Since groundwater monitoring began
at the site in the summer of 1993,recovery well GM-4 is the only well to have constituents
above regulatory limits. Based on historical data from numerous sampling events conducted
over 6 years, it is evident that the area of impacted groundwater at this facility is very small and
that only limited migration has occurred due to natural attenuation. The concentration of vinyl
chloride in well GM4 is relatively similar to that observed over the last four sampling events.
The site incident number is 5337.
G. HYDROGEOLOGIC DESCRIPTION
SECTION(G)MUST BE ORIGINALLY SEALED AND SIGNED BY A LICENSED
GEOLOGIST
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a
depth that included the known or projected depth of contamination. The number of borings shall
be sufficient to determine the following:
- - GW-57 REM (Novmnba 1999) Page 3 of 9

Opp 111111Jfff#I
%,�` ;CR �'.
A
y?Z:
(1) the regional geologic setting; SEAL
(2) significant changes in lithology; 12�
(3) the hydraulic conductivity of the saturated zone; '
(4) the depth to the mean seasonal high water table; and '•�� '�QLO��•��.���`
(5) a determination of transmissivity and specific yield of the aquifer to 152, �kdl FI)fh���1�on
(showing calculations). '*fit 11111%
Regional Geologic Setting
The area of Rosman,North Carolina is situated within the Blue Ridge Province. More
specifically,Rosman is located to the east of the Brevard Fault Zone within the Chauga Geologic
-- Belt.The entire area of Rosman is underlain by the Henderson Gneiss,which consists of biotite
gneiss (Horton and McConnell, 1991). .
Lithology
The site is underlain by silts and clays interbedded with fine sands to a depth of approximately
90 ft bls where bedrock is present. Two lithologic cross sections were constructed using
information obtained from soil borings drilled during the Phase H investigation. Cross-section A
A',illustrated in Figure 4,presents site lithology from upgradient of the pits at well GM-1
through the pits and downgradient to well GM-7 parallel to the general groundwater flow
direction. Cross-section B -B', illustrated in Figure 5,presents site lithology perpendicular to
the general groundwater flow direction. The cross-sections indicate that silts and clays are
predominant in the upper portion of the lithologic section. These fine sediments generally
coarsen downward to a silty sand at variable depths. However, a clayey-silty sand is present in
the upper section of GM-5 and extends to the middle of section of boring BH-3 southwest of the
pits. These areas of sandy material illustrate the variable nature of the sediments in the area.
However,low permeable silts and clays are generally present in the upper 10 to 15 feet of the
lithologic section,especially near the pits where they are present to a depth of at least 10 ft bls.
Groundwater Flow and Direction
Historical groundwater elevation data were collected at various times prior to and following
remedial system operation. A comparison of historical water level data is presented on Table 2
for the June 15, 1993; August 28, 1996; October 20, 1998; October 18, 1999;November 16,
2000; August 2,2001 and September 18,2002 sampling events. All data were collected during
times when the recovery system was shut down and are indicative of natural groundwater flow
direction. All water-level data indicate that the natural groundwater flow direction is generally
to the southeast and is consistent over time. Based upon the natural groundwater flow direction,
the monitoring well network is properly positioned to detect the potential migration of
constituents from the former source area near well GM-4. Depth to the mean seasonal high
water table is approximately 4.5 feet as measured in GM-4.
The hydraulic conductivity(K),which is the capacity of a medium to transmit water,was
determined from slug tests in on-site monitor wells. The calculated K values for the wells are
included in Table 3.
The site groundwater flow velocity was calculated using the K values derived from the slug tests,
a hydraulic gradient of 0.03 based upon the generated water-level contour maps and an effective
GW-57 REM (November 1999) Page 4 of 9

porosity of 0.010 based upon site lithologic data. Using the above assumptions,an average
groundwater flow rate of 59 feet per year(ft/yr)was calculated It is important to note that.this
is an average velocity for the site. Using the K values from individual wells,the calculated
groundwater flow velocity ranged from a high of 184 ft/yr at well GM-9 to a low of 27 ft/yr at
well GM-4.
Transmissivity can be calculated from hydraulic conductivity and aquifer thickness. Using a
value of 0.2480 ft/day for K and aquifer thickness of 20 feet,the T would be 4.96 ft/day.For the
purpose of this calculation, the surficial aquifer is assumed to be present from 5 to 25 feet below
land surface in the vicinity of GM4.
The specific yield for the sediments at this site can be obtained from a literature reference. In the
vicinity of GM-4,the lithology is predominantly silts and clays. The corresponding specific
yield would therefore be approximately 10 percent by volume(Heath, 1989).
H. MONITORING PROCEDURE
Provide plans for proposed location and construction details of groundwater monitoring well
network,including a schedule for sampling and analytical methods. Include any
modeling/testing performed to investigate injectant's potential or susceptibility to change
(biological, chemical or physical)in the subsurface.
After the injection points are completed, existing site monitor wells GM-4,GM-10,RW-1,and
RW-2 will be used to assess the performance of the ORC(Figure 3). Three months after the
initial ORC application, a groundwater sampling event will be conducted to measure natural
attenuation parameters and monitor the presence of vinyl chloride(the primary COC) and other
volatile organic compounds(VOCs). Geochemical parameters pH, redox,DO,turbidity,
temperature, and specific conductivity will be measured and recorded during well purging using
a flow through cell. Groundwater samples collected from the four wells will be submitted for
laboratory analysis of VOCs using USEPA Method 8260. If analytical results dictate,
subsequent ORC applications may be performed.
I. WELL USE Will the injection well(s)also be used as the supply well(s) for the following?
(1) The injection operation? YES NO X
(2) Personal consumption? YES NO X
J. CONSTRUCTION DATA(check one)
EXISTING WELL being proposed for use as an injection well. Provide the
data in(1)through(7)below to the best of your knowledge. Attach a copy
of Form GW-1 (Well Construction Record) if available.
X PROPOSED WELL to be constructed for use as an injection well. Provide
the data in(1)through(7)below as PROPOSED construction specifications.
Submit Form GW-1 after construction.
Gw-57 REM (November 1999) Page 5 of 9

(1) Well Drilling Contractor's Name: Regional Probing Services, Inc.
NC Driller Registration number: 1625
(2) Date to be constructed: 2003 (to be determined based on UIC permit approval date.
Number of borings: 9
Approximate depth of each boring(feet): 25
(3) Well casing and screens: As described in Attachment 2, there are no screened intervals,
and the injection zone will be from approximately 25 feet below land surface (ft bls)to
approximately 5 ft bls.
—' (4) Grout type shall be Portland Cement Type I. The boreholes will be grouted to land
surface upon completion of the injection activities
(5) N.C. State Regulations(Title 15A NCAC 2C .0200)require the permittee to make
provisions for monitoring wellhead processes. A faucet on both influent(recovered
groundwater) and effluent(fluid being injected into the well)lines is generally
required.
This is not applicable due to the one time nature of the ORC application, and the fact that
there are no well casings or screened intervals for either injection or groundwater
extraction.
Will there be a faucet on the influent line? yes_no X
Will there be a faucet on the effluent line? yes no X
_ (6) SOURCE WELL CONSTRUCTION INFORMATION: Not Applicable.
NOTE: THE WELL DRILLING CONTRACTOR CAN SUPPLY THE DATA FOR
EITHER EXISTING OR PROPOSED WELLS IF THIS INFORMATION IS
UNAVAILABLE BY OTHER MEANS.
K. OTHER WELL DATA
Provide a tabulation of data on all wells within '/< mile of the injection well(s), excepting water
supply wells serving a single-family residence, which penetrate the proposed injection zone.
Such data shall include a description of each well's type, depth,record of abandonment or
completion,and additional information the Director may require.
During the Corrective Action Plan phase of work, a potable well survey was conducted during
for properties within a 1,500-foot radius of the impacted monitor well(GM-4). Wells excepting
single-family residence wells include a water supply well on the NCDOT Maintenance Building
property,and three water supply wells,two groundwater recovery wells,and 11 groundwater
monitor wells present on the Coats American property. Water-supply wells in the area typically
pump water from the bedrock,which is present approximately 90 ft bls at the site. Well data are
tabulated below.
GW-57 REM (November 1999) Page 6 of 9

Relative Top
Well Date of Casing Screened Interval
Site Well ID Type Installed Elevation (Feet BLS
(NCDOT TRA-25- NA NA NA NA
Maintenance 2-21
Buildings)
Coats GM-1 8/6/90 184.84 11-21
American GM-2 8/7/90 181.32 4-14
Sylvan Facility GM-3 8/9/90 180.26 13-23
GM-4 8/7/90 179.53 5-15
GM-5 11/28/90 178.55 10-20
GM-6 11/29/90 177.13 9-19
GM-7 11/29/90 176.17 5-15
GM-8 11/27/90 178.16 10.5-20.5
GM-9 12/19/90 176.07 8-18
GM-10 9/16/91 178.29 65-75
GM-11 9/17/91 175.40 79-89
RW-1 6/5/92 177.03 5-50
RW-2 6/4/92 177.03 5-50
PW-1 NA NA 400 feet total depth
PW-2 NA NA 400 feet total depth
PW-3 NA NA 1 212 feet total depth
L. PROPOSED OPERATING DATA
(1) Injection rate: Average(daily) 1_6 gallons per minute(gpm)
(2) Injection volume: Average(daily)76.5 gallons per day(gpd)
(3) Injection pressure: Average(daily) 100 pounds/square inch(psi)
(4) Injection temperature: Average(January) N/A°F,Average (July)N/A°F
(5) Hydraulic capacity of the well: Not Applicable
(6) Expected lifetime of the injection facility: 0.005 vear
(7) Give a description of how the above data will be measured and controlled:
The injection rates/volume are monitored during the injection process by pre-measuring the amount of
ORC slurry to be injected per point as specified in the work plan. The entire volume is then injected for
that point, during which time the injection pressure is monitored with an in-line standard pressure gauge.
The temperature of the injected slurry will approximate the ambient atmospheric temperature at the time
of injection. The hydraulic capacity is not applicable because there is no well casing or screened interval
with this process. The expected lifetime of the injection process is one to two days per event.
M. INJECTION-RELATED EQUIPMENT
See Attachment 2.
N. LOCATION OF WELUSl
Attach a scaled, site-specific map(s) showing the location(s)of the following:
GW-57 REM (November 1999) Page 7 of 9

(1) the proposed injection well(s) (See Figure 3);
(2) all property boundaries (See Figure 2);
(3) contour intervals not exceeding two feet(See Figure 1);
(4) the direction and distance from the injection well or well system to two nearby,
permanent reference points (such as roads, streams, and highway intersections) (See
Figure 2);
(5) all buildings within the property boundary(See Figure 2);
(6) any other existing or abandoned wells, including water supply and monitoring wells,
- within the area of review of the injection well or wells system(See Figure 8);
(7) potentiometric surface showing direction of groundwater movement(see Figure 6);
(8) the horizontal and vertical extent of the contaminant plume (including isoconcentration
lines and plume cross sections) (see Figure 7; due to limited extent of impact above
NCAC 2L standards,i.e.vinyl chloride in only one well, a plume cross section was
not developed);
(9) any existing sources of potential or known groundwater contamination, including waste
storage,treatment or disposal systems within the area of review of the injection well or
well system (None); and
(10) all surface water bodies within 1000 feet of the injection well or well system
(see Figures 1,2).
O. INJECTION FLUID DATA
(1) Fluid source,if underground,from what depth,formation and type of rock/sediment unit
will the fluid be drawn(e.g.,granite,limestone,sand, etc.).
Not Applicable-potable water will be used for ORC slurry.
(2) Provide the chemical,physical,biological and radiological characteristics of the fluid
to be injected.
See Attachment 2. -
P. PERMIT LIST
Attach a list of all permits or construction approvals that are related to the site,including but not
limited to:
(1) Hazardous Waste Management program permits under RCRA
(2) NC Division of Water Quality Non-Discharge permits
(3) Sewage Treatment and Disposal Permits
(4) Other environmental permits required by state or federal law.
All permits and construction approvals relating to the site are on file with the Environmental Compliance
Division and are available upon request.
Q. CERTIFICATION
"I hereby certify,under penalty of law,that I.have personally examined and am familiar with the
information submitted in this document and all attachments thereto and that,based on my
_ _ cw-57 REM (November 1999) Page 8 of 9

All permits and construction approvals relating to the site are on file with the Environmental Compliance
Division and are available upon request.
Q. CERTIFICATION
"I hereby certify, under penalty of law,that I have personally examined and am familiar with the
information submitted in this document and all attachments thereto and that, based on my inquiry
of those individuals immediately responsible for obtaining said information, I believe that the
information is true,accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to
construct, operate, maintain,repair, and if applicable, abandon the injection well and all related
appurtenances in accordance with the approved specifications and conditions of the Permit."
(Signature of Well Owner or Authorized Agent)
If authorized agent is acting on behalf of the well owner,
please supply a letter signed by the owner
authorizing the above agent.
R. CONSENT OF PROPERTY OWNER
(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 rests ownership in the landowner
in the absence of contrary agreement in writing.)
If the property is owned by someone other than the applicant,the property owner hereby consents
to allow the applicant to construct each injection well as outlined in this application and that it
shall be the responsibility of the applicant to ensure that the injection well(s)conforms to the
Well Construction Standards (Title 15A NCAC 2C .0200)
— (Signature Of Property Owner If Different From Applicant)
- GW-57 REM (November 1999) Page 10 of 11

UIC Permit
Application
ARCADIS
FIGURES

.y
• ii
GrAveyard
v Y i• Hill.
SITE
LOCATION
000
Rosniali
brnr On
Mile
215
1 1/2 0 1 MILE
1000 0 1000 2000 0000 •000 s000 1 700o
SCALE 1:24000 (v
County Contour Interval 40—ft Datum is Mean Sea Level
Location U.S.C.S. 7.5 Minute Series
Rosman, NC Topographic Quadrangle.
PRJT N IGM aEC120 BY, FIGURE N0.
ARCADIS AAWi ' aT
p„nvINO NCTOPO SITE
�s�M a Na Carolina, Inc. LOCATION
801 Corporate Center Dry ,suite 700 PRJT Ne NC101043.0001
Rdei9h, NC 21C0) COATS AMERICAN — SYLVAN FACILITY
Tal: IF..: 918-es4-sua III wTE, 1a 1Ew 12DCT01 A N TIW ROSMAN, NORTH CARODNA
rw.arcaaia-ua.wm

ggg COATS ANERKAN
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EXCAVATED '11111 X GM-1
PIT AREA No.1 rGM-6
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EXCAVATED-y GAF
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— REFERENCED DRAWINGS —
or mo oExOnwx
Ho.
A-1 LOCKWOOD GREEN SITE m_ s
A-2 LOCKWOOD GREEN GRADE
63108 1 PROPERTY PLAT
SY-124 1 SYLVAN PLANT
ARC
A. PI MANAGER+ KPAHCHECKED BY. GRAFTER PROJECT
A P1NMAN PAHR A.DRAFTER-
DRAWING,
ARCADIS G&N of North Carolina, Inc. SITEI C
801 Corporate Center Drive, Suite 300 -
Raleigh, NC 27607 - DATE-
Tel: [phone] Fax: [phone] 14NAY03
wwx,.orccdi.—us.ccm

Za
n
15' WIDE EASEMENT
+ ACCESS ROAD TO m
PASTURE PUMP STATION mQ
BROAD RIVER 1,907-ft.
FRENCH
SHORTEST D
(STAKE TD ZRF�S
VJ-2 19 GPM 0212'
1 pW_1 ..\
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� �`\ PROPERTY�LINE J
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00
SEWAGE DISPOSAL
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GRASS
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s �a
1, a4ZIOP'AY REEK • — FENCE LINE
PROPERTY LINE
GRASS -� PAVEMENT
---
- GRASS
STATE HIGHWAY #64 • MONITOR WELLS
• RECOVERY WELLS
■ PRODUCTION WELLS
SG IN FEET
0 250 500
.R NC103013.0001 FIGURE:
i AMERICA — SYLVAN FACILITY SITE
'OSMAN. NORTH CAROLINA LAYOUT 2

LEGEND
I — FENCE
+\ • MONITOR WELL
x +\ A RECOVERY WELL
I PROPOSED ORC
x N +\ INJECTION POINT
+\ SCALE IN FEET
PROPERTY o 30
BOUNDARY G�
+\
i EXCAVATED +
PIT AREA 2 \
x \ •
+\ GM-8
GM-2• +\
iGM-3 • �+
GM-9
•
x GM 4 • RW-2 +
EXCAVATED GM-10
PIT AREA 1 +\
x
+
I \+
+
• GM-5 \
I GM-11
x
I
PUT NANAGEM CNEIX D 9Y,
ARCADIS a PINNIX K PANR MONITOR WELL AND RECOVERY WELL LOCATIONS FlGUflE
DRAWING,COATS—SITE-030 AND PROPOSED ORC INJECTION POINTS
ARCMIS GAM of North Corou... Inc.
801 Co,orute Camar orm,, S.R. 300 PRAT rm,NCI030I3.0001
R.I.tgh, NC 2760] COATS AMERICAN—SYLVAN FACILITY
Tel: [phone] FRA: 919-854-5448 DVG DATE, DRAFTER, ROSMAN, NORTH CAROLINA
nwe.arcoEie-ua.com 13NAY93 A. NDRTON

185 GM-1 BH-1 GM-2 GM-3 GM-4 GM-10 GM-7 185
180 I A \
1eo
175 5dra:6' S &
170 -Yi 9 x $!(fy Send i ,"" 4My-3
170
v?}
155 d , 155
r''=1;� .��. I r.
150 ems} ��;' i ar<-J � �«��,�. 150
145 - I e� 1 r tas
LEGEND
140 — 1 k 5 140 Organic Clays and Organic
r t � t III Silty Clay
135 °Y i k ` �t", < $ u r<+y e t } s °
135 ® Inorganic Clays and Gravelly.
730 � "5'� + � � e`�;t � ,�( "'' ' Slily Send - Sandy, or Silty Clay
"`. � t� of ' 1*'�T �xa Tx �c,F^a '�''r`. ' � 130
Silty Sands, Poorly Graded
125 d, ,,�`� 3 d h5 , ' ` ' � 41 125 Sand—Silt Mixture
Inorganic Silts, Fine or Silty
r", Y ,r s k a ' -' lI�F
120 G�{a d # c1'zr .1. :,1rz4J k ?' , '� 120 Soils
Inorganic Clays
115C'1 i 115
Land Surface
.,;'
110 -€^ " '�.ws �&�' k �3't no Well Casing
{kI
105 vmnm sail!IM FEEr - �--—-
ir'.7 TJ J �` 5 rl 4 v e r r..+[[ry Y x,,, �r ,�yy"" • 4,C,' 105 0 1s 30
k'wY9G � .qM,IN iY Yv'9 11:.. "' G. 1',,✓ 1 ' !Sy Y�a�'`y 'l.J. "+' p,T'
arr, rA.,
100 Jr,'trn�'d' � � P. . i$`-�r.IPltil
, f rite ' .fie E l: 4 S c'+ '�,� \ cA' '2� `,5."X Ila >
F P "N `"'S 11 l a r kv ,p v 100 HORIZONTAL SCALE W FEET
�1 r .� t a :a",a'+^I'� o 60 1zo
95 I LLr. „Nfi a�,^' i .tt u"f
95
PRJT HAHADERI CHECKED BY-
A. - -HR FlCIIRE:
ARCADISVIN&A A PA8
GENERALIZED SUBSURFACE.CROSS-SECTION A-A'
ARCADIS ChM RI Nar aaralina, Ina. 4
801 caraorala Canter Drive, Suite 300 PRJT N NC103013.0001
RalaigA, H0 27607 COATS AMERICAN SYLVAN FACILITY
Tel: [phone] Fax: [phone] Ova DATE, DRUTER� ROSMAN, NORTH CAROLINA
www.arcadia-ue.cam 16MAY03 A. MORT6M

wl_1 T.
B I \\ Be
B• I a cu-e
I EW25 _2 W 0
BIDO I W-4 W-10
W-7-
GM-5 BH-3 GM-4 GM-8 I W2,
I c'M-a
180 180 I
i marnm.
o m
175 175
LEGEND
170
170 Clayey Silty Sand, Poorly
,<4 Graded Sand—Silt—Clayey Mixture
�
165 ;?"-i1 r ® Inorganic Clays and Gravelly,
165 Sandy, or Silly Clay
Silty Sands, Poorly Graded
,1 ,� I� Sand—Silt Mixture
160
Inorganic Silts, Fine Sandy
Or Silty Soils
155 155 ® Inorganic Silts & Fine Sands,
Silty or Clayey Fine Sand
® Inorganic Clays
t5o 15a
Land Surface
Well Casing
VERTICAL SCALE IN FEET _
0 r0 20
HORIZONTAL SCALE IN fEEr
a Q ea
PRJT HANA6ER- CHECKED BY. RGORE:
ARCADIS PINNI% L PA HI;!
W2
DRAWING. e_B GENERALIZED SUBSURFACE CROSS-SECTION B-B'
ARCADIS G&M of North Cwoll'na. Inc.
801 Comomle Center Drive. Suite 0DO PR.1T xa NC103013.0001
Raleigh, NO 27607 COATS AMERICAN SYLVAN FACILITY
Tel: [phone] Fax: 919-85e-5448 Bvo DATE, ORAFTER� ROSMAN, NORTH CAROLINA
w^.arcoriie-ua.com I6NATU3 A. NORTON

GM-1
174.80
�r\ PROPERTY
r
r\r� jp N
k,
r
EXCAVATED \r
/ I PIT AREA 2\O
� ^o
GM-2 \r\r ~172.17
ASSUME 184.0' ELEVATION i 174.48�
AT LOADING DOCK ENTRANCE
GM-3 G r � •
172.72 vo • �r GM-9
• Rtd-2 168.65
EXCAVA GM-10 r\
PIT 1 *�
/ BUILDING I r\r
j PAVEDGM 7
• GM-5 RW-1 • 168.39• r\
170.46 • GM—Il
/ I • GM-6
168.81
LEGEND
—•— FENCE NOTE 1: ALL ELEVATIONS ARE RELATIVE TO
• MONITOR WELL - THE LOADING DOCK ENTRANCE. i
A RECOVERY WELL NOTE 2: GROUNDWATER ELEVATION DATA
172.72 WATER LEVEL ELEVATION (FT,MSL) FROM WELLS GM-10, GM-11, i
—170— POTENTIOMETRIC CONTOUR 2—FT RW-1 & RW-2 WERE NOT USED
( ) IN DETERMINING GROUNDWATER
GROUNDWATER FLOW DIRECTION CONTOURS DUE TO SCREENING SCALE IN FEET
DEPTHS BELOW SHALLOW AQUIFER. 0 60
PRJT MANAGER- CHECKED BY, GENERALIZED
BRAVING,
FIGURE
ARCADIS H. PAMR
vI"G'COATS—SITE-03 GROUNDWATER FLOW DIRECTION
ARCADIS G&M of North Carolina, Inc. SEPTEMBER 18 6
eat Corporate Center Dave, suite 300 PRJT NO'NCI03013.0001 ' 2��2
Raleigh. NC PRD) COATS AMERICAN-SYLVAN FACILITY
Tel:
919-664-1362 To.; 91R-65<-3448 3vG OATEN DRAFTER.
^w.arcaale—ae.aam 13MAY03 A. NORTON ROSMAN, NORTH CAROLINA

GM-1
174.00
PROPERTY/ BOUNDARY
r
\r N
I r\
r\
EXCAVATED r\r
PIT AREA 2 r \
r
\r �GM-8
ASSUME 184.0' ELEVATION
AT LOADING DOCK ENTRANCE GM-3r 9.7 \r\ GM-9
® %1 • •RW 2\r
EXCAVATED GM-10 Kill \
PIT AREA 1 <1.0 r\
/ BUILDING I r\r
j PAVED I RW-I •i G©
Offs]
• \r\• G <1.D N
• GM-]I
/ II • GM-6
LEGEND I ®S
—•— FENCE
• MONITOR WELL
A RECOVERY WELL i
EZI VINYL CHLORIDE CONCENTRATION (Hg/L)
NS NOT SAMPLED
APPROXIMATE HORIZONTAL EXTENT OF GROUNDWATER IMPACT ABOVE SCALE IN FEET
L=1•=•=I NC 2L STANDARDS 0 60
PUT 14WAGER, CNECKEB 9Y, VINYL CHLORIDE FIGURE:
ARCADIS VIN.PINI H PANR \r9
oRAwuc'COATS—SITE-03 CONCENTRATIONS /L
ARCAUIS G&M NPAN C 1Ae. SEPTEMBER 18 7
em como.°t. ce°mr 0d.°. SeRe 300 PRJT N0,NC103013.0001 ' 2��2
R°lelgh, NC Z)BW COATS AMERICAN—SYLVAN FACILITY
Tel: [phone] Fe.: 919-854-5445 9VG SATE- ER
AFI"
"••°�°°a"—° °°'^ 151AYo3 A. 10R6 ROSMAN, NORTH CAROLINA

I. 32 25E,� 26
5
I
'21A 1 I 97
21 .6� —88
y
1
18
92B
20
I 1 •.
/ FORMER
1 PITS
ICOATS AMERICAI
16
I. 93
15\
_ '13 13H 1 1
--- �
13A 13B I,
/�-/' 13\\F\
13J-� 14
12D 12A __ 92D
12c--- 12B 2
-�- 12 ,12F
.SCALE IN FEET — / 12E�
0 400 am _L
PUT MANAGER, CHECKED BY, DRAFTER, PROJECT
ARCAD I S NOTES:A. NNIX N. PAHR A. NORTO DRAW NGN
ARCADIS G&M of North Carolina. Inc. TRANS-1 C
801 Corporate Center Drive. Suite 300
Raleigh, NC 27507 DATE-
Tel: [phone] Fax: [phone] 16MAY03
www.arcadis—us.conn
I

r
r �
i
r
90
M 0 u ! 91
N \ `
Tq \
2
0
9 ,
�v
92
1
/ LEGEND
1500-FT =- = PROPERTY LINE
RADIUS - 1 500-FT RADIUS FROM SOURCE
/ INTERMITTENT STREAM
3}F WATER SUPPLY WELL
NOTE: SEE TABLE FOR PROPERTY DESCRIPTIONS.
.R NC103013.0001 FIGURE:
AMERICAN - SYLVAN FECILITY WATER-SUPPLY WELLS WITHIN 1,500-FEET
!OSMAN, NORTH CAROLINA OF THE SOURCE AREA 8

UIC Permit
Application
ARCADIS
TABLES

Table 1. Groundwater Quality Detection Summary,September 2002 Sampling Event,Coats American-Sylvan Plant,Rosman,North Carolina.
Constituent NCGWI/ GM4 DUP-1* GM-10 RW-1 RW-2
Date Sampled 9/18/2002 9/18/2002 9/18/2002 9/18/2002 9/18/2002
Pnrgeable Halocarbons
(USEPA Method 601)µg/L
1,1-Dichloroethane 700 8.1 9.0 <1.0 <I.0 <1.0
1,1-Dichloroethene 7 <5.0 <5.0 <1.0 <1.0 <1.0
1,1,1-Trichloroethane 200 5.0 <5.0 <1.0 <I.0 <1.0
Trichlorofluoromethane 2100 15 16 <I.0 <1.0 <1.0
Vinyl Chloride 0.015 9.7 9.2 . <1.0 <1.0 <1.0
Purgeable Aromati c
(USEPA Method 602)µg/L
Toluene 1000 110 100 <1.0 <1.0 <1.0
Ethylbenzene 29 14 14 <1.0 <1.0 <1.0
Total xylenes 530 84 75 <2.0 <2.0 <2.0
Semi-Volatile Organics
(USEPA Method 8270)µg/L - ND ND ND ND ND
TotalTICsv 116.6 145.3 141 32 103.7
µg/L Micrograms per liter.
1/ North Carolina Subchapter 2L Groundwater Standards,
v Tentatively identified Compounds(TICS)(estimated concentrations).
J Sample data are qualified as estimated.
< Not detected above the quantitation limit.
* Blind field replicate of primary groundwater sample GM4.
OConstituent concentration is above groundwater standard.
ND Compounds were not detected in sample.
(3AFm%CualsAmericantSylvan Plantt2002 SamplinglTablesttabIcI.xls

Table 2. Groundwater Elevations, Coats American-Sylvan Plant, Rosman,North Carolina.
Pre-Pumping Non-Pumping Non-Pumping
Measuring 6/15/1993 8/28/1996 10/20/1998
- Well Point Depth to Water-Level Depth to Water-Level Depth to Water-Level
Elevation* Water** Elevation Water** Elevation Water** Elevation
Y GM-1 184.84 11.72 173.12 9.22 175.62 11.10 173.74
GM-2 181.32 9.30 172.02 4.85 176.47 7.37 173.95
GM-3 180.26 9.25 171.01 7.09 173.17 8.12 172.14
GM-4 179.53 8.80 170.73 4.50 175.03 5.38 174.15
GM-5 178.55 11.15 167.40 8.26 170.29 9.20 169.35
GM-6 .177.13 14.32 162.81 8.77 168.36 11.09 166.04
GM-7 176.17 11.64 164.53 8.31 167.86 9.21 166.96
GM-8 178.76 8.46 170.30 7.92 170.84 7.21 171.55
GM-9 176.07 11.05 165.02 9.03 167.04 8.79 167.28
GM-10 178.29 11.78 166.51 8.67 169.62 9.55 168.74
GM-11 175.40 15.94 159.46 11.37 164.03 12.40 163.00
RW-1 177.03 13.75 163.28 9.89 167.14 9.81 167.22
RW-2 177.37 12.14 165.23 8.90 168.47 9.83 167.54
Non-Pumping Non-Pumping Non-Pumping
Measuring 11/16/2000 8/2/2001 9/18/2002
Well Point Depth to Water-Level Depth to Water-Level Depth to Water-Level
Elevation* Water** Elevation Water** Elevation Water** Elevation
GM-1 184.84 9.70 175.14 10.09 174.75 10.04 174.80
GM-2 181.32 6.00 175.32 4.95 176.37 6.84 174.48
GM-3 180.26 6.72 173.54 ND ND 7.54 172.72
GM-4 179.53 4.35 175.18 4.41 175.12 5.50 174.03
GM-5 178.55 6.79 171.76 7.77 170.78 8.09 170.46
GM-6 177.13 7.61 169.52 7.90 169.23 8.32 168.81
GM-7 176.17 6.83 169.34 7.36 168.81 7.78 168.39
GM-8 178.76 5.94 172.82 6.36 172.40 6.59 172.17
GM-9 176.07 6.57 169.50 7.09 168.98 7.42 168.65
GM-10 178.29 6.66 171.63 7.50 170.79 7.72 170.57
GM-11 175.40 5.56 169.84 7.15 168.25 7.58 167.82
RW-1 177.03 7.92 169.11 8.13 168.90 8.44 168.59
RW-2 177.37 6.95 170.42 7.63 169.74 7.92 169.45
* Measuring point is the top of PVC casing;all elevations are relative.
** Depth below top of PVC casing.
ND No Data
Q:\Env\Coats American\Sylvan Plant\2002 Annual Monitoring\Tables

Table 3. Hydraulic Conductivity Values from Slug Tests, Coats American Sylvan Plant,
Rosman, North Carolina.
Well Hydraulic Conductivity (K) cm/sec
GM-1 2.68 x 104
GM-3 1.10 x 104
GM-4 8.75 x 10-5
GM-5 1.17 x 104
GM-6 1.22 x 10-4
GM-7 7.47 x 10-'
GM-8 1.63 x 104
GM-9 5.93 x 104
cm/sec Centimeters per second.
g.'mnvk en==i=%yly pl=6wc p=iNable Mod

UIC Permit
Application
ARCADIS
ATTACHMENT 1
ORC MATERIAL SAFETY
DATA SHEET

OXYGEN RELEASE COMPOUND (ORC®)
MATERIAL SAFETY DATA SHEET(MSDS)
Last Revised: March 27,2003
SECTION 1-MATERIAL IDENTIFICATION
******************************************************************************
SUPPLIER:
REGENESIS
1011 Calle Sombra
San Clemente, CA 92673
_ 949-366-8000 phbne
949-366-8090 fax
[e-mail] e-mail
CHEMICAL DESCRIPTION:
A mixture of Magnesium Peroxide [MgO2],Magnesium Oxide [MgO], and Magnesium
Hydroxide [Mg(OH)2]
CHEMICAL FAMILY:
Inorganic Chemicals
PRODUCT NAME:
Oxygen Release Compound (ORe)
PRODUCT USE:
Used for environmental remediation of contaminated soil and groundwater
SECTION 2-CHEMICAL IDENTIFICATION
CHEMICAL CHARACTERIZATION
Magnesium Peroxide [M902]: CAS Reg.No. 14452-57-4
Magnesium Oxide [MgO]: CAS Reg.No. 1309-48-4
Magnesium Hydroxide((Mg(OH)2): CAS Reg.No. 1309-42-8
FORM : powder
COLOR:white
ODOR: odorless
ASSAY: 25 -35%Magnesium Peroxide(MgO2)

SECTION 3 -PHYSICAL AND TECHNICAL SAFETY DATA
MELTING POINT:Not Determined
BOILING POINT:Not Determined
DENSITY: 0.6-0.8 g/cc
BULK DENSITY: --
VAPOR PRESSURE: Data not available
VISCOSITY: ---
SOLUBILITY: Reacts with water. Soluble in acid
pH VALUE: Approx. 10 in saturated solution
FLASH POINT:Not applicable
SELF-IGNITION TEMPERATURE:Not applicable
EXPLOSION LIMITS %BY VOLUME: ---
THERMAL DECOMPOSITION: Spontaneous decomposition possible about 150' C
HAZARDOUS DECOMPOSITION PRODUCTS:Not known
HAZARDOUS REACTIONS: Hazardous polymerization will not occur
FURTHER INFORMATION:Non-combustible,but will support combustion
******************************************************************************
SECTION 4-REACTIVITY DATA
******************************************************************************
STABILITY:Product is stable unless heated above 150°C. Magnesium Peroxide reacts with
water to slowly release oxygen. React by product is magnesium hydroxide
CONDITIONS TO AVOID: Heat above 150°C. Open flames
INCOMPATIBILITY: Strong Acids. Strong chemical agents
HAZARDOUS POLYMERIZATION:None known

SECTION 5-REGULATIONS
PERMISSIBLE EXPOSURE LIMITS IN AIR:Not established. Should be treated as a nuisance
dust.
SECTION 6-PROTECTIVE MEASURES, STORAGE,AND HANDLING
TECHNICAL PROTECTIVE MEASURES
STORAGE: Keep container tightly closed. Keep away from combustible material
HANDLING: Use only in well-ventilated areas
PERSONAL PROTECTIVE EQUIPMENT
RESPIRATORY PROTECTION: Recommended(HEPA Filters)
HAND PROTECTION: Wear suitable gloves
EYE PROTECTION:Use chemical safety goggles
OTHER: ---
INDUSTRIAL HYGIENE: Avoid contact with skin and eyes
PROTECTION AGAINST FIRE AND EXPLOSION: ---
DISPOSAL: Dispose via sanitary landfill per state/local authority
FURTHER INFORMATION:Not flammable,but may intensify fire
******************************************************************************
SECTION 7-MEASURES IN CASE OF ACCIDENTS AND FIRE
******************************************************************************
AFTER SPILLAGE/LEAKAGE/GAS LEAKAGE: Collect in suitable containers.Wash
remainder with copious quantities of water.
EXTINGUISHING MEDIA
SUITABLE: Carbon dioxide, dry chemicals, foam
NOT TO BE USED: ---
FURTHER INFORMATION: Self contained breathing apparatus or approved gas mask should
be worn due to small particle size. Use extinguishing media appropriate for surrounding fire.

FIRST AID: After contact with skin, wash immediately with plenty of water and soap. In case of
contact with eyes,rinse immediately with plenty of water and seek medical attention.
FURTHER INFORMATION: ---
SECTION 8 -INFORMATION ON TOXICOLOGY
TOXICITY DATA:Data not available
******************************************************************************
SECTION 9-INFORMATION ON ECOLOGY
WATER POLLUTION HAZARD RATING(WGK): 0
SECTION 10-FURTHER INFORMATION
******************************************************************************
- After the reaction of magnesium peroxide to form oxygen the resulting material,magnesium
hydroxide is mildly basic. The amounts of magnesium oxide (magnesia) and magnesium
hydroxide in the initial product have an effect similar to lime,but with lower alkalinity.
The information contained in this document is the best available to the supplier at the time of
writing,but is provided without warranty of any kind. Some possible hazards have been
determined by analogy to similar classes of material. The items in this document are subject to
change and clarification as more information becomes available.

UIC Permit
Application
ARCADIS
ATTACHMENT 2
ORC SLURRY
INSTALLATION
INSTRUCTIONS

REGENESIS
Oxygen Release Compound (ORC°)
Installation Instructions
(Direct-Injection Slurry Application)
SAFETY:
Pure ORC is shipped to you as a fine powder rated at-325 mesh (passes through a 44
micron screen). It is considered to be a mild oxidizer and as such should be handled
with care while in the field. Field personnel should take precautions while applying the
pure ORC. Typically, the operator should work upwind of the product as well as use
appropriate safety equipment. These would include,eye and respiratory protection,
and gloves as deemed appropriate by exposure duration and field conditions.
Personnel operating the field equipment utilized during the installation process should
have appropriate training, supervision and experience.
GENERAL GUIDELINES:
ORC may be installed in the contaminated saturated zone in the ground utilizing hand
augered holes, Geoprobe®type hydraulic punch equipment, or hollow stem augers.
This set of instructions is'specific for Geoprobe equipment. Alternate instructions may-
be obtained from the Regenesis Technical Support Department.
For optimum results the ORC slurry installation should span the entire vertical
contaminated saturated thickness, including the capillary fringe and "smear zone".
Two general installation approaches are available. The first is to backfill only the
probe hole with slurry. This is a simple approach, in that it is easy, straightforward,
and the location of the ORC slurry is precisely known after installation. However, this
method requires significantly more probe holes than the alternative, and may take
more time for the completion of the remediation process. A separate set of
instructions for this method utilizing Geoprobe equipment is available from Regenesis.
The second method is to inject the slurry through the probe holes into the
- contaminated saturated zone. This method requires fewer probe holes, is less
disruptive to the site, and aids the spread of oxygen by spreading the ORC source
material. However, it may,be difficult to know the exact, final disposition of the ORC
installed with this method. This is the method described in these instructions.
Note: It is important that the installation method and specific ORC slurry point location
be established prior to field installation. It is also important that the ORC slurry volume
and solids content for each drive point be predetermined. The Regenesis Technical
Service Department is available to discuss these issues, and Helpful Hints at the end.
of these instructions offers relevant information. Regenesis also has available
Technical Bulletins covering source treatments with ORC.

S
SPECIFIC INSTALLATION PROCEDURES
1. Identify the location of all underground structures, including utilities, tanks,
distribution piping, sewers, drains, and landscape irrigation systems.
2. Identify surface and aerial impediments.
3. Adjust planned installation locations for all impediments and obstacles.
_ 4. Pre-mark the installation grid point locations, noting any that have special depth
requirements.
,- 5. Set up the Geoprobe unit over each specific point, following manufacturer
recommended procedures. Care should be taken to assure approximate
vertical probe holes.
6. Penetrate surface pavement, if necessary, following standard Geoprobe
procedures.
7. Drive the 1 1/2 (one-and-one-half inch) pre-probe (part#AT-148B) with the
expendable tip (part#AT142B) to the desired maximum depth. Standard 1"
(one inch) drive rods (part AT104B) should be used, after the pre-probe. (Hint:
Pre-counted drive rods should be positioned prior to the installation driving
procedure to assure the desired depth is reached.)
8. Disconnect the drive rods from the expendable tip, following standard Geoprobe
procedures.
9. Mix the appropriate quantity of ORC slurry for the current drive point. (See
separate "Directions for OR&Slurry Mixing" and Helpful Hints). Note: Do not
mix more,slurry than will be used within a 30 minute period.
10.Set up and operate an appropriate slurry pump according to manufacturer's
directions. Based on our experience, a Geoprobe model GS-1000 pump is
recommended. Connect the pump to the probe grout pull cap (GS-1054)via a
1 inch diameter delivery hose. The hose is then attached to the 1" drive rod
with its quick connector fitting. Upon confirmation of all connections add the
ORC slurry to the pump hopper/tank.
11.Withdraw the pre-probe and drive stem 4' (four feet). (Also note Helpful Hints -
Operations at end of instructions.)
12.Optional pretreatment step. (See Helpful Hints - Operations at end of
instructions). Pump one to two gallons of tap water into the aquifer to enhance
dispersion pathways from the probe hole.
13.Pump the predetermined quantity of ORC slurry for the depth interval being
injected. Observe pump pressure levels for indications of slurry;dispersion or
refusal into the aquifer. (Increasing pressure indicates reduced acceptance of
material by the aquifer).
14.Remove one 4' section of the 1" drive rod. The drive rod will contain slurry.
This slurry should be returned to the ORC bucket for reuse.
15.Repeat steps 11, 13, and 14 until treatment of the entire affected thickness has
been achieved. It is generally recommended that the procedure extend to the
top of the capillary fringe/smear zone.
16.Install an appropriate seal, such as bentonite, above the ORC slurry through the
- entire'vadose zone. This helps assure that the slurry stays in place and
prevents contaminant migration from the surface. Depending on soil conditions
and local regulations, a bentonite seal can be pumped through the slurry pump
or added via chips or pellets after probe removal.
17.Remove and decontaminate the drive rods and pre-probe.
2 i
_ I
t

18.Finish the probe hole at surface as appropriate (concrete or asphalt cap, if
necessary).
19. Move to the next probe point, repeating steps 5 through 18.
HELPFUL HINTS:
A. Physical characteristics
Al. Slurry
The ORC slurry is made using the dry ORC powder (rated at-325 mesh). It makes a
smooth slurry, with a consistency that depends on the amount of water used.
A thick, but pumpable, slurry that approaches a paste can be made by using 65-67%
solids. This material would normally be used for back-filling a bore or probe hole. It is
especially useful where maximum density is desired such as where ground water is
present in the hole or there are heaving sands.
Thinner slurries can be made by using more water. Typical solids for the thinner
slurries content will range from 35% to 62%. Such slurries are useful for injecting
_ through a probe or bore hole into the saturated aquifer.
As a rule, it is best to mix the first batch of slurry at the maximum solids content one
would expect to.use. It can then be thinned by adding additional water in small
increments. By monitoring this process, the appropriate quantities of water for
subsequent batches can be determined.
The slurry should be mixed at about the time it is expected to be used. It is best to not
hold it for more than 30 minutes. Thinner slurries, especially, can experience a
separation upon standing. All ORC slurries have a tendency to form cements when
- left standing. If a slurry begins to thicken too much, it should be mixed again and
additional water added if necessary.
Care should be taken with slurry that may be left standing in a grout pump or hose.
Problems can generally be avoided by periodically re-circulating the slurry through the
pump and hose back into the pump's mixing or holding tank.
A2. Equipment
Most geotechnical grout pumping equipment has a holding tank with a capacity
sufficient for injection.
When applying measured volumes of ORC slurry to probe holes, it is sometimes useful
to know the volumes and content of the delivery system lines. The following
information may be useful in this regard.
Geoprobe pump: At the end of a pump stroke virtually no deliverable slurry remains in
the pump.
5/8" O.D. connecting hose(10 feet long): 0.2 gallons (26 fluid ounces).
Four foot(4')length of 1"drive rod: .04 gallons (5 fluid ounces).
Three foot(3') length of 1 1/2"pre-probe: 11 .03 gallons (4 fluid ounces).
3

Cleaning and maintenance:
Pumping equipment and drive rods can be lightly cleaned by circulating clear water
through them. Further cleaning and decontamination (if necessary due to subsurface
conditions) should be performed according to the equipment supplier's standard
procedures and local regulatory requirements.
B. Operating characteristics
' 131. Operations- General
Judgment will be needed in the field when injecting ORC slurries. In general, it is
relatively easy to inject ORC slurries into sandy soils, and this can usually be
accomplished at very moderate pressures. Silts and clays require more pressure, and
- may accept less slurry.
Careful_observation of pressure during slurry pumping is the best indication of the
effectiveness of the slurry injection. To test the soil's ability to accept the slurry and to
"precondition" the injection point for the slurry, it is sometimes useful to inject a small
volume of plain water prior to the slurry. Normally, one-half(0.5) gallons to two (2)
T gallons would be appropriate.
During injection, increasing pressure and decreasing flow rate are signs of refusal by
the soil matrix to accept the slurry. The site geologist should determine whether to
increase pressure, and possibly fracture ("frac") the soil matrix to achieve ORC slurry
installation in a tight site that has refused the slurry at lower pressures.
B2. Fill Volumes
Probe hole back-filling
Probe hole capacities:
Per 10'(Ten Foot) Length
Theoretical Operating Volume
(Gallons/Fluid Ounces/Cubic Inches) (Gallons/Fluid Ounces)
Sand,Silts &Clay Sand ISilts &Clay
1"Diameter .41 gal/52 fl: oz./94.2 cu. in. 61 gal/78 fl.oz. 51 gal/65 fl.oz.
1 1/2" Diameter 1.92 gal/117 fl. oz./212.0 cu. in. 1.38 gal/176 fl. oz. 1.15 gaV146 fl. oz.
2" Diameter 11.63 gal/209 fl.oz./376.8 cu. in. 112.44 gal/313 fl. oz. 2.04 gal/261 fl. oz.
- 2 1/4" Diameter 2.06 gal/264 fl, oz./476.9 cu. in 3.09 gal/396 fl. oz. 2.57 gal/330 fl, oz.
Note that the operating volumes include a 50% excess above the theoretical volume in
sands and 25% in clays and silts. This is important to successful treatment. The
additional material allows for a small degree of infiltration of the slurry into the
surrounding soil and fractures, as well as hole diameter variability. It is important to
assure that the entire contaminated saturated zone is treated (including the capillary
fringe), since this is often the area of highest pollution concentration. Failure to treat
this area due to improper installation can undermine an otherwise successful
remediation effort.
4

_ r
For direct assistance or answers to any questions you may have regarding
these instructions, contact Regenesis Technical Services at 949-366-8000.
f
REGENESIS, 2002
— www.regenesis.com
5

UIC Permit
Application
ARCADIS
ATTACH ME NT 3
DESIGN CALCULATIONS

ORC Design:Software for- rid Applications Using Slurry Injection 1•usVerson Bl
Regenes67edlniml Sup G
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Chumlad Os,,oh Demand(COD) ,_. Use a muNple M dlswlead phen 1.00 y - 0.0 1 0
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.5mmery of EatknatadoRCReRI ad'- �"' Pnaae lha 'Phase ha 11otOx"e paid Cella FedorS 1000 -
InaNbual Species,Total 811 MTBE 4 - 23 5 - 135 $ 1150 F
Total P¢hob mra NYdlbonal •y• 2 .. $ li i
i6l.kglral OryOen Dunned(SOD) -. -, -r 2 - E •,. ':
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Required ORC per feet - '" Mnmum Dow WeRdN 30toaby¢ ", Simple ORO Backspin,thin halo ale.fw R]%slurry -2R t4 "
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Total install Loel rot including wnwlUnl.lad.etc $ 9,ell -„Total Pooled Cost $ 9.Ob '- _�

RECEIVED
MAPS 1 G "��Qfi
DIVISION OF WATER QUALITY II Asheville Regional Office
AQUIFER PROTECTION SECTION I A uiter Protection
March 14, 2006
MEMORANDUM
To: Landon Davidson
Asheville Regional Office
From: Jesse Wiseman J ln1
Central Office UIC Program
Re: Notice of Expiration
UIC Permit No. WI0100015
Coats North America
Transylvania County
UIC Permit No. WI0100015 (Injection hi situ Groundwater Remediation Well(51)) issued to
Coats North America is due to expire on July 31, 2006. A Notice of Expiration regarding this
permit was sent by this office to Mike Bell of Coats North America on March 14, 2006. This
letter is attached for your records.
Attachment
cc: CO-UIC Files

� t�oifiiU le; '
rtoi�ss�d �U:�u��+r;,,l�
__. `Iili ld t_�1

f WATF
f ��� 9pG Michael F.Easley,Governor O
Cl) y William G.Ross Jr.,Secretary
t— North Carolina Department of Environment and Natural Resources
O Y Alan W.Klimek,P.E.Director
Division of Water Quality
March 14, 2006
Mike Bell
Coats North America
P.O. Box 670
Toccoa, GA 30577
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7002 2410 0003 0273 3853
Subject: Notice of Expiration
North Carolina Well Construction Standards
Applicable to Injection Wells - Subchapter 2C
UIC Permit No. WI0100015 Issued to Coats North America
Transylvania County
Dear Mr. Bell: _
The Underground Injection Control (UIC) Program of the North Carolina Division of Water
Quality is responsible for regulating injection well construction and operation activities within
the state. Our records show that the injection well permit referenced above will expire on July
31, 2006. This permit was issued for the injection system located at Highway 178 in Rosman,
North Carolina.
Please submit the enclosed form;STATUS OFINJECTION WELL SYSTEM(form GW/UIC-68)to
indicate the current status of your injection well system within 30 calendar days of the receipt of
this letter. If you intend to conduct additional injections or pursue any injection-related activities
that are beyond the scope of the permit referenced above,you must submit a letter requesting a
renewal and/or amendment of the permit that describes in detail the procedure, locations,
volume, and frequency of injected material, and any other pertinent information regarding the
proposed activity.
In addition, our records indicate that a final project evaluation is due within 9 months after
completion of the injection operation. To date we have not received this report. If the injection
project has been completed,please submit the required final project evaluation as indicated in
your permit in PART VII—MONITORING AND REPORTING REQUIREMENTS.
If any injection well is no longer being used for any purpose, it must be permanently abandoned
according to the regulatory requirements specified in the North Carolina Administrative Code
Npow�t}tCarolina
- ,/VllfuCQ�l�
Aquifer Protection Section 1636 Mail Service Center Raleigh,NC 27699-1636 Telephone: [phone]
Internet:vnnv.ncwaterauality ore Location: 2728 Capital Boulevard Raleigh,NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal Opportunily/Affirmative Action Employer—50%Recycled110%Post Consumer Paper Customer Service: [phone]

Mike Bell
March 14,2006
Page 2 of 2
Title 15A Subchapter 2C Section .0214. If any injection well is to be permanently abandoned,
well abandonment records must be submitted to our office to ensure proper abandonment.
Please contact Thomas Slusser at(919) 715-6166 or Evan Kane at(919) 715-6182 if you have
any questions regarding this correspondence,your permit, or injection well rules and regulations.
Sincerely,
Jesse Wiseman
Processing Assistant
UIC Program
Enclosure
cc: J.Alan Pinnix,L.G.-ARCADIS
APS Asheville Regional Office w/o enclosure
CO-UIC Files w/o enclosure

RECEIVED
DIVISION OF WATER QUALM APR 2 0 2906
AQUIFER PROTECTION SECTION Asheville Regional Office
April 18, 2006 A uifer Protection
MEMORANDUM
To: Landon Davidson
Asheville Regional Office
From: Jesse Wiseman J vJ
Central Office LTIC Program
Re: Notice of Regulatory Requirement
UIC Permit No. WI0100015
Coats North America
Transylvania County
UIC Permit No. WI0100015 (Injection In situ Groundwater Remediation Well (51))issued to
Coats North America is due to expire on July 31, 2006. A Notice of Regulatory Requirement
regarding this permit was sent by this office to Mike Bell of Coats North America on April 18,
2006. This letter is attached for your records.
Attachment
cc: CO-UIC Files

�. F WAIF
Michael F.Easley,Governor
0 y William G.Ross Jr.,Secretary
CO> [ North Carolina Department of Environment and Natural Resources
1
0 Y Alan W.Klimek,P.E.Director
Division of Water Quality
t
April 18, 2006
Mike Bell
Coats North America
P.O. Box 670
Toccoa, GA 30577
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7002 2410 0003 0273 4249
Subject: Notice of Regulatory Requirement
North Carolina Well Construction Standards
Applicable to Injection Wells - Subchapter 2C
UIC Permit No. WI0100015 Issued to Coats North America
Transylvania County
Dear Mr. Bell:
The Underground Injection Control (UIC) Program of the North Carolina Division of Water
Quality is responsible for regulating injection well construction and operation activities within
the state. Our records show that the injection well permit referenced above will expire on July
31, 2006. This permit was issued on July 30, 2003 for the injection system located off of
Highway 178 in Rosman,North Carolina.
This office attempted to bring your injection well system into compliance by sending you a
Notice of Expiration and an injection well status form on March 14, 2006. To date the UIC
Program has not received the requested status form. The pumose of this letter is to inform Coats
North America of its responsibilities pertaining to injection well rules
Please submit the enclosed form, STATUS OFINJECTION WELL SYSTEM(form GW/UIC-68) to
indicate the current status of your injection well system within 15 calendar days of hie,] of
this letter. If you intend to conduct additional injections or pursue any inj ection-related activities
that are beyond the scope of the permit referenced above, you must submit a letter requesting
renewal and/or amendment of the permit that describes in detail the procedure; locations,
volume, and frequency of injected material, and any other pertinent information regarding the
proposed activity.
In addition, our records indicate that a final project evaluation is due within 9 months after
completion of the injection operation. To date we have not received this report. If the injection
N°rthCaoulina
J�atura/!7
Aquifer Protection Section 1636 Mail Service Center Raleigh,NC 27699-1636 Telephone: [phone]
Internet:w v.ncvvaterqualitv.ore Location: 2728 Capital Boulevard Raleigh,NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal OpportunitylAfSrmaliveAclion Employer—50%Recycled/10%Post Consumer Paper Customer Service: [phone]

Mike Bell
✓ .April 18,2006
Page 2 of 2
project has been completed,please submit the required final project evaluation as indicated in
your permit in PART VH—MONITORING AND REPORTING REQUIREMENTS.
If any injection well is no longer being used for any purpose,it must be permanently abandoned
according to the regulatory requirements specified in the North Carolina Administrative Code
Title 15A Subchapter 2C Section .0214. If any injection well is to be permanently abandoned,
well abandonment records must be submitted to our office to ensure proper abandonment.
Again, we have provided you with the appropriate information to update your UIC permit. You
must respond within 15 calendar days of the receipt of this letter, or a Notice of Violation will be
issued to you, which carries the possibility for an assessment of fines or cessation of operation of
the injection well system. Please call Mike Ranck at [phone] or email him at
Michael.Ranck(a)ncmail.net if you have any questions about this correspondence, the UIC
Program, or the enclosed form.
Sincerely,
9. J,
Debra J. Watts, Supervisor
Groundwater Protection Unit
Enclosure
cc: J.Alan Pira ix, L.G. -ARCADIS
APS Asheville Regional Office w/o enclosure
CO-UIC Files w/o enclosure

01/26/2004 15:42 919-71- 58 , „ NCDE&N /WATER C''-' PAGE 01
L► R CA
�/� Post-Ir Fax Note 7677 Date �� pa°pes�
/ To From ARCADIS C&M of North
infrastructtuu 11 re, buildinc ColDept co w -CZ L, igre, Carolina,Inc.
Phorlee Phone 4/p ,� / !� 801 Corporate Center Drive
0 1G suite 300
Mr.Mark Fritz] Raleigh,
LUC,Program North Carolina 27607-5073
Tel 919 8S4 1282
Groundwater Section Fax 919 854 S448
North Carolina DENR-DWQ w .arcadis-umom
1636 Mail Service Center
Raleigh,NC 27699-1636
ENVIRONMENTAL
Subject:
UIC Permit Application,Coats American Svlvan Plant,Rosman,North Carolina,
Groundwater Incident#5337.
Date;
Dear Mr.laritzl: July 25,2003
Contact
As per our telephone conversation on July 24,2003 we are pleased to follow up with J.Alan Pinnix L.G.
clarification on the monitoring frequency for the proposed injection of oxygen
release compound(ORC)at the above referenced site. This letter is to confirm that Extension;
the planned monitoring will be on a quarterly basis for a period of one year. As 247
outlined in the permit application,the first event will be approximately 3 months
after ORC injection. EmaB:
apmnixda arcadis-
Thank you for your assistance in reviewing this permit application and should you us.com
have additional questions,please do not hesitate to contact the undersigned,
our ref:
NC103015.0001
Sincerely,
ARCADIS G&M of North Carolina,Inc.
PAlan Pinnix, L.G.
Project Scientist
Covias
Mr.Mike Bell c
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Part of a bigger picture

R
E C E o y E
AUG 4 2003
D
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
GROUNDWATER SECTION ASHEVILLE REGIONAL OFFICE
July 31, 2003
MEMORANDUM
To: Landon Davidson, L.G.,Regional Groundwater Supervisor
Groundwater Section
Asheville Regional Office
From: Mark Pritzl [e-mail]
Hydrogeological Technician II
UIC Group
Groundwater Section
Raleigh Central Office
Re: Issuance of injection well permit type 5I (in-situ Groundwater Remediation Well)
Permit Number WIOI 00015 for the injection of an ORC to enhance aerobic biodegradation of the
dissolved vinyl chloride contamination at the Coats America Sylvan Plant, in Rosman,North
Carolina. The UIC group greatly appreciates Kay Dechant's assistance with this review.
Please retain the application paper work and permit copy for the ARO-UIC files. If you have any
questions regarding this Memo or the UIC program, please contact me at [phone].
cc: CO-UIC Files
Enclosures

GROUNDWATER SECTION
July 29, 2003
MEMORANDUM
To: Debra Watts, Supervisor,Permits &Compliance Branch
Through: Evan Kane, Hydrogeologist,UIC Program Manager 7/�_
From: Mark Pritzl, Hydrogeological Technician,UIC Program 4
Re: Coats' injection well application for the injection of an Oxygen Releasing Compound
(ORC) slurry to enhance aerobic biodegradation of the dissolved vinyl chloride
contamination in groundwater at this site.
• This site is located within the Blue Ridge physiographic province of North Carolina and is
located just east of the Brevard Fault in the Chauga Geologic Belt. The site is underlain by
silts and clays inter-bedded with fine sands to a depth of 90 feet below land surface (bls),
where bedrock begins. These fine sediments generally coarsen downward to a silty sand just
before encountering bedrock. Bedrock under the site has been identified as the Henderson
Gneiss which consists of a biotite gneiss.
• Shallow local groundwater movement at the entire site generally moves toward the south-cast
and depth to groundwater is less than 5 feet(bls) around the injection area. Head data from
GM-4 and GM-10 indicate that the shallow sediments are recharging the deeper sediments, or
that the injection area is in a recharging zone. (See X-sections in application)
• Chlorinated solvent contamination exists in the surficial aquifer with vinyl chloride as the
main dissolved contaminant of concern for this remedial activity. Groundwater contamination
is the result of depositing floor scrubber and frame cleaning water into two pits that existed
from the early 1970s to 1989. Since 1990, the site has been the subject of a great number of
remedial activities such as the excavation of over 1,000 tons of soil from both pits in 1992.
The proposed injection process is to address the last or residual contamination around GM-4.) p
Within the proposed injection process, the injection of an ORC slurry is proposed to enhance
the aerobic bacteria breakdown of vinyl chloride to heat, CO2, H2O and Cl-. I have provided a r
technical written summary illustrating this direct substrate biodegradation process, in which f,
the author also explains that aerobic co-metabolic processes may also occur to break down the
dissolved vinyl chloride contamination.
• Nine injection points are proposed that will utilize the GeoProbe or push rod technology. The
nine injection points will be placed in three rows with 8 feet between each row, and three
injection points will be placed in each row with 8 feet between each injection point. Each
injection point will deliver 3 lbs/vertical foot of ORC or 60 lbs per hole, and the injection
interval is from 5 feet bls to 25 feet bls. The entire injection grid is located hydraulically up
gradient of GM-4 or inside the"Excavated Pit Area L" As mentioned before, this area is the
only area identified by the consultant where groundwater is contaminated above the 2L
standards. A second and possibly a third injection event of ORC may be required to
achieve the desired contaminant reduction.

• All groundwater samples will be analyzed for VOCs, DO, ORP,pH, turbidity, temperature
and specific conductivity. Groundwater samples will be collected from GM-4, GM-10, RW-
1, RW-2, and MW-4D. A pre-injection sampling event will take place, and post-injection
sampling from the monitoring wells mentioned above will begin three months after injection
and continue every three months for one year.
• The main limiting factor for ORC injection at this site is the existence of significant dissolved
iron(ferrous) in shallow groundwater,which could scavenge the delivered oxygen, making it
unavailable for bacterial utilization. This limited availability of delivered oxygen could, in
turn, limit the radius of influence of the injected oxygen so as not to be effective.
• At this time, I recommend that a permit be issued to Coats for the injection of an ORC slurry
to enhance aerobic biodegradation of vinyl chloride dissolved in groundwater at this site.

'17 .8G4.8
' 0 '
PROPERTY
\ BOUNDARY
r
r\r N
\r
r
II AR
EA EXCAVATED \r\
\`O r
\r �GM-8
/ I GM-2 1 \r\ NS
ASSUME 184.0' ELEVATION ® r
AT LOADING DOCK ENTRANCE I GM-3 ,F GM-4 \r •
9.7 • \r GM-9
' • RW-2\
EXCAVATED GM-10
PIT AREA i <1.0 r\
r
BUILDING I \r
PAVED I RW—i • GM-7 • \r\
j • GM-5 <1.0 NS •
NS GM-11
NS
• GM-6
LEGEND I 0
—•— FENCE
• MONITOR WELL
RECOVERY WELL i
179-71 VINYL CHLORIDE CONCENTRATION (Vg/L)
NS NOT SAMPLED
a APPROXIMATE HORIZONTAL EXTENT
a"3"1'"' OF GROUNDWATER IMPACT ABOVE o ScnLE IN FEET OF
NC.2L STANDARDS 6
PRJT MANAGER, CHECKED BYE VINYL CHLORIDE AGURE:
A. PINNIX N PANR
ARCADIS BRAVING COATS—SITE-03 CONCENTRATIONS (dig/L)
AflCAD1S Na"" Cara° "a' NclD3D13.0001 SEPTEMBER 18 2002 7
.. 801 Carycrata Cantor ogre. Salta 3W PRJT Na r
' Raleigh, INC 27607 COATS AMERICAN—SYLVAN FACILITY,
Tel: [phone] Fax: [phone] 8VG BATE. A.nR-TERM ROSMAN, NORTH CAROLINA
.w.arcoaia—ua.<am
15MAY02 NURTUN

17 .8G4.8
0
r PROPERTY
i \ / BOUNDARY
r
EXCAVATED
PIT AREA 2/ \O II GM-2 \+\r �172.17
ASSUME 184.0' ELEVATION 174.48� \
AT LOADING DOCK ENTRANCE GM-3 c3m
/ 172,72 k • \+ GM-9
• RW-2 168.65
EXCAVA GM-10
PIT 1 \+\
/ BUILDING I +\r
j PAVED I • GM-5 RW-1 • 168.39• \+\
170.46 • GM-11
. I / / • GM-6
LEGEND
I 168.81
—•— FENCE NOTE 1: ALL ELEVATIONS ARE RELATIVE TO I
• MONITOR WELL THE LOADING DOCK ENTRANCE. i
A RECOVERY WELL NOTE 2: GROUNDWATER ELEVATION DATA
172.72 WATER LEVEL ELEVATION (FT,MSL) FROM WELLS GM-10, GM-11, i
—170— POTENTIOMETRIC CONTOUR 2—FT RW-1 & RW-2 WERE NOT USED
( ) IN DETERMINING GROUNDWATER
�D GROUNDWATER FLOW DIRECTION CONTOURS DUE TO SCREENING SCALE IN FEET
DEPTHS BELOW SHALLOW AQUIFER. 0 60
PRJT HANAGERJ CHECKED BY. GENERALIZED FIGURE:
ARCADIS PINNI% H PAHR
Danvwu CDA7S—SITE-03 GROUNDWATER FLOW DIRECTION
ARCADES C&M a1 NartN caraaaa, Ioa. SEPTEMBER 18 6
NC103013.0001 2��2
eDt Coryo.ote Cuter Drive. 5uaa 300 PRJT N0' r
. Rolel9n. NC 99507 COATS AMERICAN—SYLVAN FACILITY
Tel: [phone] For: 919-85e-5448 DVG DATE, DRAFTER.
a,e.orcaaro—ue.core 13HAY03 A. NORTON ROSMAN, .NORTH CAROLINA

I \+ LEGEND
I —•—•— FENCE
+ • MONITOR WELL
eC \+ A RECOVERY WELL
I N +\ PROPOSED ORC
INJECTION POINT
x
PROPERTY a
I +\ SCALE IN FEET 30
x +\ BOUNDARY
x EXCAVATED +
PIT AREA 2
x \ • '
+ GM-8
GM-2• \T\
+\
x GM-3 • � +
I w
+\ GM*
-9
•
x RW-2 \+\
EXCAVATED CM-4 •
PIT AREA 1 GM-10 +\
x +
I �+
x \
I +
x RW-1 • GM-7 • \+
I • GM-5 \
x •GM-11
I
x
1
A. P NAIX CN PMR 9T MONITOR WELL AND.RECOVERY WELL LOCATIONS f1CURE
ARCADIS Vi N1% N PANR
R9Av1NG COATS-SITE-030 AND PROPOSED ORC INJECTION POINTS . 3
01CaryamIS �e Caaler Dr of North ..,.. S.R.�300 PRAT �NC103013.0001
Raleigh, INC 27607 COATS AMERICAN—SYLVAN FACILITY
Tel: [phone]]62 Fax: [phone] Rvc RATc, RR'NTCRI ROSMAN• *NORTH CAROLINA
• nnn.arcoCi.-4. Co. 13NAY03 0. OR TON

tb2223 r``h Page 1 of 3
{
Remediation of Vinyl Chloride
Vinyl Chloride and ORC
Vinyl chloride(VC)is a common groundwater contaminant usually associated with higher order chlorinated aliphatic
hydrocarbons(CAHs)such as perchloroethylede(PCE),tichloroethylene(TCE),and dichloroethylene(DCE). The presence
of oxygen stimulates the degradation of vinyl chloride and is the basis upon which ORC has been shown to effectively treat
this contaminant.
Aerobic M tahnlicm of Vinyl Chloride
The metabolism of vinyl chloride in the presence of oxygen may proceed via two possible mechanisms.In one pathway,VC
serves as a primary substrate for oxygen-dependent microbial growth and is degraded completely to carbon dioxide and water
(Davis and Carpenter,1990).This process occurs intracellularly and unlike co-metabolic(aerobic)remediation,no
oxygenase-inducing compounds,such as methane are required for VC metabolism in this oxidative pathway.The use of ORC
can thus stimulate vinyl chloride degradation without any additional treatment amendments or technologies.
The direct,intracellular metabolism of vinyl chloride proceeds via oxidation to an intermediate compound(chlorooxirane)
which ultimately degrades to carbon dioxide and water(Harhnans and DeBont, 1992).The chlorooxirane,an unstable
epoxide intermediate,degrades further into various fragments(such as formic acid and oxyglycolic acid)which,in tutu,are
transformed to CO2 and H2O.This results in a net energy benefit to the microbe.The proposed.mechanism of intracellular
aerobic metabolism of VC is illustrated in Figure 1:
H C1 02 H2O H O C1
) C = C C ........0 —I — ► various intermediates
(HCOOH,HOCCOOH)
NADH NAD' H H
02 incorporated
into cell mass
Energy+ CO2+H2O+ Cl
,Figure 16 VC intracell"lar degradation pathway Net energy benefit to degrading organism.
Others have suggested a,second possible pathway that involves methanotrophs capable of destroying vinyl chloride
extracellularly through co-metabolism(McCarty, 1994).In co-metabolism,the formation of the chlorooxirane intermediate
requires an enzyme-inducing substrate(in this case methane)that is apparently not required in intracellular aerobic VC
metabolism.When co-metabolic VC degradation occurs,methanotrophs produce oxygenases,for example methane
monooxygenase(MMO),that leak out of the cell and fortuitously degrade VC extracellularly with no net energetic benefit to
the microbe.This co-metabolic degradation pathway may proceed according to the reactions shown in Figure 2:
http://w�vw.regenesis.com/ORCtech/Tb2223.htm 3/21/2003

tb2223 Page 2 of 3
intracellular
various intermediates
,
CH, CH30H incorporated -L+ CO2 +H=O
into cell mass
NADH, OZ NAD+ ,',
extracellular'; O
H 0 M H :' CI various intermediates
C=C """"'C� incorporated by non-
H H ' I N . H/ �H.�D+ methanonophs and/or
NADH, OZ mineralized to CO,Cl ,H=O
Figure 2: VC extracellular.co-metabolic dMradatlon pathway: No net energy benefit to
MMO producing methanotroph.
Both of the proposed mechanisms of VC biodegradation are oxygen-demanding processes that will benefit from ORC
treatment. In addition to the requirements of aerobic respiration,oxygen plays an integral role in both intracellular and
extracellular enzymatic reactions.The application of ORC can thus aid in the sustenance of the relevant microbial
populations and enhance the rate of aerobic dechlorination of vinyl chloride.
ORC Treatment of Yin idt
Results from controlled laboratory studies and field applications support the ability of OKC to effectively enhance the
biodegradation of vinyl chloride.
1.In a recent study conducted on groundwater and soils from an industrial site,VC was shown to degrade very rapidly(Tin
=5 days)with ORC addition as the only applied treatment technology(Bell,P.et.al, 1997).
2.In another field demonstration of ORC conducted on a New York State Superfund site,ORC treatment resulted in
significant degradation of vinyl chloride(Martinovich and Putscher, 1997;see also TB 3.1.1).Concurrent laboratory studies
corroborated the field results using materials from the site.
3.At an industrial site in Massachusetts,project engineers sought to remediate chlorinated compound contamination in the
property's groundwater.Treatment options were confined to the following limitations:the treatment was to be non-invasive
and operate within limited available space;facility operations were to remain undisturbed; all possible air and water(both
surface and subsurface)health hazards were to be considered and monitored for exposure to contamination.The particular
remediation objectives of this site prompted project engineers to design an inventive dual phase strategy to remediate
chlorinated compounds in sites The strategy is engineered as follows:
6 A groundwater recirculation system extracts water from three wells and re-injects the water into three injection wells
upgradient
A Phase one: addition of organic acids stimulates anaerobic conditions in the recirculation system,allowing microbial
dechlorination of highly chlorinated compounds,(PCE,TCE,DCE).
6 Phase two:ORC socks are placed in an injection well to generate aerobic conditions and bacteria begin to degrade
the vinyl chloride that accumulates in phase one.
6 Preliminary results indicate that vinyl chloride concentrations decreased as dissolved oxygen levels increased.
6 During the aerobic phase,the co-metabolic substrate methane was also introduced into the system.Addition of
methane further accelerated degradation of vinyl chloride.
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tb2223 �` ``t Page 3 of 3
These results suggest that both of the possible metabolic processes for aerobic vinyl chloride degradation may be occurring
simultaneously within this system.
As of early 1997,ORC has been applied to degrade VC at several sites across the U.S.This passive approach to remediation
of chlorinated compounds presents a cost-effective method of treating both leachate contaminated landfills and industrial
solvent contaminated sites.Investigations to further establish the role of ORC in vinyl chloride biodegradation are currently
underway.
ORC Installation Design Parameters
The theoretical mass ratio of oxygen to vinyl chloride required for the aerobic metabolism of VC is relatively low at 1.3:1.
Thus,for every pound of vinyl chloride to be degraded,at least 1.3 pounds of oxygen are required.
The sorption coefficient(Koc)for vinyl chloride is 57(mUg),indicating that its tendency to sorb to the aquifer matrix is
approximately equal to that of benzene(Koc=83 mUg).Therefore,in ORC application designs,when using dissolved vinyl
chloride data from groundwater samples one can use additional demand factors usually associated with BTEX remediation
projects as an acceptable approximation.
References
Bell, P.,K Casper and P.McIntire. 1997.Treatability Evaluation of In-Situ Biodegradation of
Chlorinated Solvents in Groundwater. Proceedings from Air&Waste Management Association 90ffi
Annual Meeting &Exhibition. Toronto, Canada.
Davis,J. and C. L. Carpenter. 1990. Aerobic Biodegradation of Vinyl Chloride in Groundwater
Samples.Appl. Environ.Microbiol. 56: 3878-3880.
Hartmans, S. and J. A. M.DeBont. 1992. Aerobic Vinyl Chloride Metabolism in Mycobacterium aurum
Ll. Appl. Environ. Microbiol. 58:1220-1226.
Martinovich,B. and A. Putscher. 1997. Aerobic Biodegradation of Vinyl Chloride in Groundwater. In
Situ and On-Site Bioremediation (5): 469.Alleman and Leeson eds. Battelle Press, Columbus, Ohio.
McCarty,P. and L. Semprini. 1994. Groundwater Treatment for Chlorinated Solvents. Handbook of
Bioremediation, Chapter 5. Matthews, T.E. ed. Lewis Publishers,Boca Raton,Florida. 257 pp.
Technical Bulletin Indexl ftgenesis Home Page
http://www.regenesis.com/ORCtech/Tb2223.htm 3/21/2003

�0�WAf��0 / Michael F.Easley,Governor
William G.Ross Jr.,Secretary
0 (� North Carolina Department of Environment and Natural Resources
0 r Alan W.Klimek P.E.Director
—i I Division of Water Quality
O Y Coleen H.Sullins,Deputy Director
Division of Water Quality
July 31, 2003
Mr. Mike Bell, Environmental Safety Coordinator
Coats North America
Post Office Box 670
Toccoa, GA 30577
Dear Mr. Bell:
In accordance with the application received on June 16, 2003, we are forwarding Permit Number
WI0100015 for the injection of an ORC slurry to enhance aerobic biodegradation of the dissolved
vinyl chloride contamination at the Coats America Sylvan Plant, in Rosman,North Carolina.
This permit shall be effective from the date of issuance until July 31, 2006, and shall be subject to
the conditions and limitations stated therein, including the requirement to submit a final project
evaluation as stated in PART VII-MONITORING AND REPORTING REQUIREMENTS. 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 inj ectant for the stated purpose,you should submit
an application to renew the permit three months prior to its expiration date.'
If you have any questions regarding your permit please contact me at(919)715-6166 or Evan Kane
at(919) 715-6165.
Sincerely,
0j,
Mark Pritzl
Hydrogeological Technician
UIC Program
cc: J.Alan Pinnix,ARCAD IS,fax copy
CO-UIC Files
ARO-UIC Files
Enclosures
AMA
NLDENR
N.C.Division of Water Quality /Groundwater Section
1636 Mail Service Center,Raleigh,N.C. 27699-1636 ,Customer Service
Phone: [phone] Fax: [phone] Internet: httpl/gw.ehncstate.nc.us I-877-623'6748

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH,NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and
other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Coats North America
FOR THE CONSTRUCTION AND OPERATION OF A TYPE 5I INJECTION WELL, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), for the injection of an ORC
slurry to augment biodegradation of vinyl chloride dissolved in groundwater at this site. These
injection wells will be located at Highway 178, in Rosman,North Carolina, and will be operated
in accordance with the application received on June 16, 2003, and in conformity with the
specifications and supporting data submitted, all of which are filed with the Department of
Environment and Natural Resources and are considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the
Water Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an
injection well shall be in compliance with Title 15A North Carolina Administrative Code 2C
.0100 and .0200, and any other Laws,Rules, and Regulations pertaining to well construction and
use.
This permit shall be effective, unless revoked, from the date of its issuance until July 31, 2006,
and shall be subject to the specified conditions and limitations set forth in Parts I through X
hereof.
Permit issued this the 36 day of 2003.
Ted L. Bush, Jr., Assistant Chief
Groundwater Section
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No.WI0100015 PAGE 1 OF 6
ver.3101 GW/UIC-5

PART I-WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and
criteria specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C
.0200). Any noncompliance with conditions of this permit constitutes a violation of the
North Carolina Well Construction Act and is grounds for enforcement action as provided
for in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. Each injection well shall not hydraulically connect separate aquifers.
4. Each injection well shall be constructed in such a manner that water from land surface
cannot migrate into the gravel pack or well screen.
5. Each injection well shall be secured to reasonably insure against unauthorized access and
use. Each well shall be permanently labeled with a warning that it is for injection purposes
and the entrance to each well must be secured with a locking cap.
6. Each injection well shall be afforded reasonable protection against damage during
construction and use.
7. Each injection well shall have permanently affixed an identification plate.
8. A completed Well Construction Record(Form GW-1) must be submitted for each injection
well to, DENR-Division of Water Quality, Groundwater Section UIC-Staff, 1636 Mail
Service Center,Raleigh,NC 27699-1636,within 30 days of completion of well
construction.
PART H-WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight(48) hours prior to constructing each injection well, the Permittee shall
notify the Groundwater Section-Underground Injection Control (UIC), Central Office
staff, telephone number(919) 715-6166.
PART III- OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials and rate of
injection, as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to
change ownership, or there is a name change of the Permittee, a formal permit amendment
request must be submitted to the Director, including any supporting:materials as may be
appropriate, at least 30 days prior to the date of the change.
i
Permit No.WI0100015 PAGE 2 OF 6
ver.3/01 GW/UIC-5

3. The issuance of this permit shall not relieve the Permittee of the responsibility of
complying with any and all statutes,rules, regulations, or ordinances which may be
imposed by other local, state, and federal agencies which have jurisdiction. Furthermore,
the issuance of this peimit does not imply that all regulatory requirements have been met.
PART IV-PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there
is no contamination of groundwater which will render it unsatisfactory for normal use. In
the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone to adequately assimilate the injected fluid,the
Permittee shall take immediate corrective actions including those actions that may be
required by the Division of Water Quality such as the repair, modification, or
abandonment of the injection facility.
2. The Permittee shall be required to comply with the terms and conditions of this permit
even if compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwater resulting from the operation of this facility.
PART V- OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the
Director of any planned physical alterations or additions in the permitted facility or activity
not specifically authorized by the permit.
3. At least forty-eight(48) hours prior to the initiation of the operation of the facility for
injection, the Permittee must notify by telephone the Groundwater Section-Underground
Injection Control (UIC), Central Office staff, telephone number(919) 715-6166.
Notification is required so.that Division staff can inspect or otherwise review the injection
facility and determine if it is in compliance with permit conditions.
PART VI-INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality
may,upon presentation of credentials, enter and inspect any property, premises, or place
on or related to the injection facility at any reasonable time for the purpose of determining
compliance with this permit, may inspect or copy any records that must be maintained
under the terms and conditions of this permit, and may obtain samples of groundwater,
surface water, or injection fluids.
Permit No.WI0100015 PAGE 3 OF 6
ver.3/01 GW/UIC-5

2. Department representatives shall have reasonable access for purposes of inspection,
observation, and sampling associated with injection and any related facilities as provided
for in N.C.G.S. 87-90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated
with the injection facility activities.
PART VII -MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitor plan included in the application received on June 16, 2003, and
amended letter received on July 28, 2003, shall be followed and all sample results shall be
submitted to the Groundwater Section's Asheville Regional Office and the Raleigh Central
Office. Any monitoring(including groundwater, surface water, or soil sampling) deemed
necessary by the Division of Water Quality to insure surface and ground water protection,
will be established and an acceptable sampling reporting schedule shall be followed.
2. The Permittee shall produce a final project evaluation within 9 months after completing
all injection-related activities associated with the permit application. This document shall
assess the injection projects findings in a written summary. The final project evaluation
shall also include all monitoring well sampling data, the contaminant plume maps and the
potentiometric surface maps.
3. The final project evaluation shall be submitted to the Underground Injection Control
Program, Groundwater Section,NC DENR-Division of Water Quality, 1636 Mail Service
Center, Raleigh,NC 27699-1636 and to the Groundwater Section, Asheville Regional
Office, Interchange Building, 59 Woodfrn Place, Asheville,NC 28801.
4. The Permittee shall report by telephone, within 48 hours of the occurrence or first
knowledge of the occurrence,to the Asheville Regional Office, telephone number(828)
251-6208, any of the following:
(A) Any occurrence at the injection facility which results in any unusual
operating circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility
incapable of proper injection operations, such as mechanical or electrical
failures.
5. Where the Permittee becomes aware of an omission of any relevant facts in a permit
application, or of any incorrect information submitted in said application or in any report
to the Director,the relevant and correct facts or information shall be promptly submitted to
the Director by the Permittee.
6. In the event that the permitted facility fails to perform satisfactorily,the Permittee shall
take such immediate action as may be required by the Director.
Permit No.WI0100015 PAGE 4 OF 6
vec3/01 GW/UIC-5

PART VIH-PERMIT RENEWAL
The Permittee shall, at least three (3) months prior to the expiration of this permit,
request an extension.'
PART IX- CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of
an injection well. Such a change would include the discontinued use of a well for
injection. If a well is taken completely out of service temporarily, the Permittee must
install a sanitary seal. If a well is not to be used for any purpose that well must be
permanently abandoned according to 15A NCAC 2C .0213(h)(1), Well Construction
Standards.
2. When operations have ceased at the facility and a well will no longer be used for any
purpose, the Permittec shall abandon that injection well in accordance with the procedures
specified in 15A NCAC 2C .0214, including but not limited to the following:
(A) All casing and materials may be removed prior to initiation of
abandonment procedures if the Director finds such removal will not be
responsible for, or contribute to, the contamination of an underground
source of drinking water.
(B) The entire depth of each well shall be sounded before it is sealed to insure
freedom from obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected,prior to sealing, if the Director
determines that failure to do so could lead to the contamination of an
underground source of drinking water.
(D) Drilled wells shall be completely filled with cement grout,which shall be
introduced into the well through a pipe which extends to the bottom of the
well and is raised as the well is filled.
(E) In the case of gravel-packed wells in which the casing and screens have
not been removed,neat-cement shall be injected into the well completely
filling it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface
cavity has been created, each well shall be abandoried in such a manner
that will prevent the movement of fluids into or between underground
sources of drinking water and in accordance with the terms and conditions
of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30)
as specified in 15A NCAC 2C .0213(h)(1) within j0 days of completion
of abandonment.
Permit No.WI0100015 PAGE 5 OF 6
ver.3/01 GW/UIC-5

3. The written documentation required in Part IX(1) and(2) (G) shall be submitted to:
Groundwater Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh,NC 27699-1636
PART X—WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows:
eye, skin,nose, throat and lung irritation. If the product is released into the environment in
a way that could result in a suspension of fine solid or liquid particles (e.g., grinding,
blending, vigorous shaking or mixing), then proper personal protective equipment should
be used. The application process should be reviewed by an industrial hygienist to ensure
that the most appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are.working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
i
{
I
Permit No.WI0100015 PAGE 6 OF 6
ver.3101 GW/UIC-5

FILE COTY
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
ASHEVILLE REGIONAL OFFICE
MEMORANDUM:
TO: Mark Pritzl
Central Office
THROUGH: Landon David
FROM: Kay Dechant 1�e
SUBJECT: UIC Pre-Construction Inspection
Coats American Sylvan Plant
Groundwater Incident 5537
DATE: July 15, 2003
This office has reviewed the subject UIC permit application and completed the Preconstruction
Injection Facility Inspection. Attached is Report Form-A. Issuance of the permit is
recommended. If you have any comments or questions, please contact me at(828) 251-6208.

— t Page I of 2
North Caruhiiia Department of Environment anti iY`utural Resources
Division of Water Quality !
Groundwater Section
I
c
PRECONSTRUCTION INJECTION FACILITY INSPECTION
REPORT-FORM A
INJECTION WELL PERMIT NO. WI DATE
NAME OF OWNER /yl,�� p�/�• (_dq/S 1604
ADDRESS OF O-vN-.NER A /o,< 4M
Teccam Gfit 30 ,�
(Streed road or lot and subdivision,county,town)
LOCATION OF PROPOSED INJECTION WELL (and source well(s), if applicable)
tffe a 6 �
(Streed road or 16t and subdivision, county,town, iirdierent than owner's address,plus description ojlocation on site)
Potential pollution source / Distance from well V'4
Potential pollution source Distance from-well Al-4-
Potential pollution source Distance from well
Minimum distance of proposed well from property boundary %S
Quality of drainage at site, f� Flooding potential of site
Igood.u, yuate.po"p (bigh.macerate.lowt
s
DRAW SKETCH OF SITE
(Shaw property boundaries. buildings. .,ells.po%ential poifaior sources. reads,approrinla:e sce/r. and norfh arrow.)
^ /tntli= Wr
sit-€
/ cn \
UN al661�
a 0 RU \
I
V
Ver.3/01 G W-'UIC-1

Page 2 of 2
PRECONSTRUCTION INJECTION FACILITY
INSPECTION REPORT - FORM A (cont.)
GPS Data:
Latitude: 33 (z��,� � , r! Longitude: sj,26 4e 42j�1rR/�
COMMENTS
INSPECTOR
Office
WITNESS
Address
WITNESS ✓ tom
Address
I
Ver.J!O I GWr2IIC-I

i
DIVISION OF WATER QUALITY ,
GROUNDWATER SECTION
ASHEVILLE REGIONAL OFFICE
MEMORANDUM:
TO: Mark Pritzl
Central Office
THROUGH: Landon Davidson
FROM: Kay Dechant
SUBJECT: UIC Pre-Construction Inspection
Coats American Sylvan Plant
Groundwater Incident 5537
DATE: July 15, 2003
This office has reviewed the subject UIC permit application and completed the Preconstruction
Injection Facility Inspection. Attached is Report Form-A. Issuance of the permit is
recommended. If you have any comments or questions,please contact me at [phone].
i
I
.- I

/ Page 1 of 2
— t
North Carolina Department of Environment and Natural Resources.
Division of Water Quality i
Groundwater Section
PRECONSTRUCTION INJECTION FACILITY INSPECTION
REPORT-FORM A
INJECTION WELL PER-MIT
G/ NO. Wl DATE /
NA.-*IE OF OWNER /yJ,ri� Al ts /(/w, L,do Ar,6C4
ADDRESS OF OWNER & Add �D
Toccoa. , 6 ,3oS,�7
(Street/road or lot and subdivision, county, town)
LOCATION,,cOF PROPOSED INJECTION WELL (and source well(s), if applicable)
laf�SiH�w
tSireeri road o r, t and subdivision , county, tmtw,iifdifj-erent than owner's address,plus description of location on site)
°clential poih:cion scn- _ Z d Distance moo^ T'
potential r)oliu or. Q/ Q � D15m^.Ce Ir0': rf off
Potential pollution source Distance from %cell
i
Minimum distance of proposed well from property boundary /S
Quality of drainage ai site Flooding potential of site
DRAW SKETCH OF SITE
• e
A"-y a
- ,Mav
i
i
e.._ . . G1d' 1:i i
i
3r'1'n 4

Page 2 of 2
a ,
PRECONSTRUCTION INJECTION FACILITY
INSPECTION REPORT -' FORM A (conL)
GPS Data:
6
Latitude:_ Longitude: 6 /r
COi UMENTS
INSPECTOR
Office
WITNESS
:address
WIT\-ESS
kddr s; — U
GV L iC
i

�OF W ATF90 _ I Michael F.Easley,Governor
William G.Ross Jr.,Secretary
\� G North Carolina Department of Environment and Natural Resources
rAlan W.Klimek,P.E.Director
-� Division of Water Quality
O C Coleen H.Sullins,Deputy Director
Division of Water Quality
I
June 17, 2003
Mr. Mike Bell, Environmental Safety Coordinator
Coats North America
Post Office Box 670
Toccoa, GA 30577
Dear Mr. Bell:
Your application for a permit to construct and/or use injection wells for the injection of an
ORC slurry to enhance aerobic biodegradation of the dissolved vinyl chloride contamination in
groundwater at Coats American Sylvan Plant, on.Highway 178 in Rosman,North Carolina has been
received and is currently under review. A member of the Groundwater Section's Asheville
Regional Office staff will be contacting you to arrange an inspection of the injection site as part of
the review.
If you have any questions regarding the permit or injection well rules please contact me at
[phone].
Sincerely,
Mark Pritzl
Hydrogeological Technician
UIC Program
cc: CO-UIC Files
ARO-UIC Files
E,4
N.C.Division of Water Quality /Groundwater Section 1
1636 Mail Service Center Raleigh,N.C. 27699.1636 FIU58'77-623-6748
omer Service
Phone: [phone] Fax: [phone] Internet: hupl/gw.ehncstate.nc.us