WI0100012_Complete File - Historical_20220307

1'
LEGGETTE, BRASHEARS & GRAHAM, INC.
PROFESSIONAL GROUND-WATER AND
ENVIRONMENTAL ENGINEERING SERVICES M
TAYLOR STATION COMMERCE CENTER D O �'j
950 TAYLOR STATION ROAD,SUITE K D
GAHANNA.OH 43230
614-416-9100
FAX [phone] FEB - 4 2003
www.lbgweb.com
ASH OUNEO REGIONAL OFOF CE
February 3, 2003
W. Mark Pritzl
UIC Program
Groundwater Section
North Carolina DENR-DWQ
2728 Capital Blvd.
Raleigh,NC 27604
RE: Proposed Amendment to Injection Well Permit
BorgWarner Facility; Fletcher,North Carolina
Dear Mr. Pritzl:
In October 2002, Leggette, Brashears &Graham (LBG) submitted an injection
well permit application for a proposed remediation pilot test at the BorgWamer Cooling
Systems, Inc. facility in Fletcher, North Carolina. The proposed activities for the
remediation pilot test involve the injection of Hydrogen Release CompoundTm (HRC).
Following the application submittal,Mr. Qu Qi (the site coordinator with the
NCDENR) suggested that the three monitoring wells proposed in the permit application
be installed prior to final permit approval to verify conditions at the injection site. In
December 2002, LBG installed three monitoring wells (MW-12,MW-13 &MW-14) at
the proposed injection site, in accordance with the injection well permit, for the purpose
of monitoring ground-water quality prior to and following HRC injection. Following
installation, ground-water sampling was conducted to verify VOC concentrations in the
proposed pilot test area. The results of the monitoring well installation and subsequent
ground-water sampling were summarized in the January 22, 2003 letter report to Eaton
from LBG. A copy of the letter report is provided herein for your files.
As discussed in our January 13, 2003 telephone conversation,LBG wants to
amend the pending permit application to include more injection points in the proposed
pilot test area. In the current permit application, there are eight proposed borings drilled
at 10-foot spacings in two rows with four borings in each row. LBG would like to
increase the number to 21 borings drilled at 10-foot spacings in three rows with seven
borings in each row. The locations of the proposed injection borings relative to the pilot
test site are shown in Figure 1.
MISSOURI ILLINOIS SOUTH DAKOTA PENNSYLVANIA
FLORIDA NEW JERSEY MINNE.SOTA TEXAS ..
MASSACHUSETTS WISCONSIN NEW YORK CONNECPICUT

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If you have any questions or require additional clarification on the proposed
amendment to the injection well permit, please feel free to contact us.
Respectfully submitted,
LEGGE=, BRASHEARS &GRAHAM, INC.
Doug Hunter
Senior Ground-Water Hydrologist
cc: Steve Fesko, Eaton Corporation
Anastasia Hamel, BorgWarner, Inc.
Ray Raymond, BorgWamer Emissions/Thermal Systems
Qu Qi,NCDENR
LEGGETIEE, BRASHEARS & GRAHAM, INC.

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MEMORANDUM
Date: November 25,2002
To: Mark Pritzl
Underground Injection Control (UIC) Group
Groundwater Section, Central Office
Through: Landon Davidson, Regional Groundwater Supervisor
Asheville Regional Office
From: Qi Q u
Asheville Re ional Office
Subject: UIC Pre-Construction Inspection
Former Eaton Facility
Cane Creek Industrial Park, Fletcher
Henderson County
I have reviewed the subject UIC application and visited the site. The information in the
application package is accurate and the issuance of the permit is recommended. If you
have any questions about the site,please do not hesitate to call me at(828) 251-6208 ext.
228.

Page 1 of 2
North Carolina Department of Environment and Natural Resources
Division of Water Quality ;
Groundwater Section
PRECONSTRUCTION INJECTION FACILITY INSPECTION
REPORT-FORM A
INJECTION WELL PERMIT NO. WI DATE I// t Z o L-
NAME OF OWNER
ADDRESS OF OWNER 9'r,7C8tt Ce--6.er /7—y2
c' IeyeO _c( DN
(Screed road or lot and subdivision,county,town)
LOCATION OF PROPOSED INJECTION WELL (and source well(s), if applicable)
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Potential pollution source N"/Cn vL h, (—<ec Co,„,,, istance from well
Potential pollution source Distance from well
Potential pollution source Distance from well
Minimum distance of proposed well from property boundary e'v r
Quality of draina.ge at site c afe- Flooding potential of site
(good,a equate,poor) (high,moderate,low)
DRAW SKETCH OF SITE
(Show property boundaries,buildings, wells,potential pollution sources,roads,approximate scale, and north arrow.)
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GPS Data:
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DIVISION OF WATER QUALITY
GROUNDWATER SECTION
February 25, 2003
MEMORANDUM
To: Landon Davidson, L.G.,Regional Groundwater Supervisor
Groundwater Section
Asheville Regional Office
From: Mark Pritzl 14P [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 WI0100012 is for a pilot study to inject an HRC slurry to enhance reductive
dechlorination of the dissolved chlorinated solvent contamination at Cane Creek Industrial Park,
in the town of Fletcher. Please retain the application paper work and permit copy for the
ARO-UIC files. The UIC Program wishes to thank Qu Qi with the review and inspection tasks.
If you have any questions regarding this letter or the UIC program,please contact me at(919)
715-6166.
rASHEVILL
7 2003
cc: CO-UIC Files
Enclosures
TER SECTION
GIONAL OFFICE

t
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
February 19, 2003
MEMORANDUM
To: Debra Watts, Supervisor, Permits & Compliance Branch
Through: Evan Kane,Hydrogeologist, UIC Program Manager(
From: Mark Pritzl, Hydrogeological Technician,UIC Program (A JP 01
Re: Eaton Corporation's injection well application for a Pilot Study to inject HRC to enhance
reductive dehalogenation of the dissolved chlorinated solvent contamination.
• This site is located in Fletcher, North Carolina and is within the northeast-trending Brevard
fault zone, a narrow belt of steeply dipping low-grade metamorphic rocks. These rocks are
Cambrian Age prophyroclastic, mylonite and cataclastic schist. The consultant has identified
four lithologic zones beneath this site and generally the site geology consist of unconsolidated
fill, soil and alluvium, underlain by saprolite and fractured metamorphic rock. See map behind
summary. Average depth to the surficial water-table is approximately 8.5 feet at the pilot test
area. There is a significant water level(head) difference between deep wells and shallow wells
indicating that the surficial aquifer is recharging the semi-confined bedrock aquifer.
• cis-1,2-dichloroethene, trichloroethene and 1,1-dichloroethene are the main chlorinated solvent
contamination that exist in the surficial aquifer and are the contaminants of interest for this
pilot study.
• The injection wells used in the injection of HRC will be temporary, utilizing direct push
technology, or the GeoProbe, to a depth of 20 feet below ground surface (bls). Twenty one
borings will be installed in three rows at intervals of ten feet with seven borings in each row.
There has been three monitor wells installed at the proposed injection site, MW-12, MW-13
and MW-14 for the purpose of monitoring groundwater quality prior to and following HRC
injection. See map behind summary.
• Groundwater samples will be collected at monitor wells MW-12, MW-13 and MW-14 during
this pilot study and all three wells are screened from 10-15 feet bls. Prior to HRC injection
groundwater samples will be collected from the new monitoring wells. Following HRC
injection, the new monitoring wells will be sampled every two months for a period of six
months for VOCs and for the following biodegradation indicator parameters; dissolved iron,
manganese, sulfide, nitrate, sulfate, chloride, alkalinity, total organic carbon, lactic acid,
pyruvic acid, acetic acid, propionic acid and butyric acid. The following gases and other field
parameters will also be monitored; carbon dioxide, methane, ethane, ethane, dissolved oxygen,
ORP, pH, temperature and ferrous iron. After the first six months the sampling program will
be reevaluated to assess the need for continued monitoring.

• Groundwater samples will be collected using minimal drawdown sampling procedures that are
consistent with the Groundwater Section's policy Memo on Recommended Well Purge
..Volumes from Arthur Mouberry dated February 21, 2001.
The applicant has provided sampling results from biodegradation parameters which indicates
reductive dechlorination is present in the surficial aquifer. This information is promising and
indicates that HRC may increase natural attenuation or reductive dechlorination.
This UIC application proposes a simple pilot study utilizing HRC with one up-gradient
monitoring well, a monitoring well in the HRC injection grid and one monitoring well down-
gradient of the injection grid. At this time the UIC Program recommends that a permit be issued
to Eaton Corporation for a pilot study to inject HRC.

�OF VATF9v Michael F.Easley,Governor
William G.Ross Jr.,Secretary
�O G North Carolina Department of Environment and Natural Resources
�? r Alan W.Klimek,P.E.Director
> 1 Division of Water Quality
O -c
February 25, 2003
Steve Fesko
Eaton Corporation
Eaton Center
111 Superior-Avenue
Cleveland, OH 44114
Dear Mr. Fesko:
In accordance with the application received on October 29, 2002 we are forwarding Permit No.
WI0100012. This permit is for a pilot study to inject an HRC slurry to enhance reductive
dechlorination of the dissolved chlorinated solvent contamination at Cane Creek Industrial Park,in
Fletcher,North Carolina.
This permit shall be effective from the date of issuance until February 28,2006,and shall be subject
to the conditions and limitations stated therein, including the requirement to submit a final project
evaluation as stated in PART VE-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 injectant for the stated purpose,you should submit
an application to renew the permit three months prior to its expiration date.
If you have any questions regarding your permit please contact me at(919)715-6166 or Evan Kane
at(919) 715-6165.
Sincerely,
Mark Pritzl
Hydrogeological Technician
UIC Program
cc: MUM Files
ARO-UIC Files
Enclosures
M
Customer Service Division of Water Quality / Groundwater Section
1 800 623-7748 1636 Mail Service Center Raleigh,NC 27699-1636
Phone: [phone] Fax: [phone] Internet: hdp://gw.ehnr.state.nc.us

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH,NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and
other applicable Laws, Rules, and Regulations
- PERMISSION IS HEREBY GRANTED TO
Eaton Corporation
FOR THE CONSTRUCTION AND OPERATION OF A TYPE 5I INJECTION WELL, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to conduct a pilot study to
inject a HRCTM slurry for reductive dechlorination of the dissolved chlorinated solvent
contamination at this site. These injection wells will be located at Cane Creek Industrial Park,
Fletcher,North Carolina, and will be operated in accordance with the application received on
October 29, 2002 and in conformity with the specifications and supporting data received on
February 4, 2003, 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 February 28,
2006, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the a2C day of �f',G�_, 2003.
Ted L. Bush, Jr., Assistant Chief
Groundwater Section
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No.WI0100012 PAGE 1 OF 6
ver.3/01 GWiUIC-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 II- 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.
Permit No.WI0100012 PAGE 2 OF 6
ver.3/01 GW/UIC-5

• 0
3. -The issuance of this permit shall not relieve the Permittee of the responsibility of
complying with any and all statutes,rules, regulations, or ordinances which may be
imposed by other local, state, and federal agencies which have jurisdiction. Furthermore,
the issuance of this permit does not imply that all regulatory requirements have been met.
PART IV-PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there
is no contamination of groundwater which will render it unsatisfactory for normal use. In
the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions or failure of the injection zone to adequately assimilate the injected fluid, the
Permittee shall take immediate corrective"actions including those actions that may be
required-by the Division of Water Quality such as the repair, modification, or abandonment
of the injection facility.
2. The Permittee shall be required to comply with the terms and conditions of this permit
even if compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwater resulting from the operation of this facility.
PART V- OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the
Director of any planned 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. WI0100012 PAGE 3 OF 6
ver.3(01 GW/UIC-5

• e
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 in the UIC Permit Application received on October 29, 2002,
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 activity associated with your permit application. This document shall assess
the injection projects findings in a written summary. The final project evaluation shall also
contain: monitoring well sampling data, contaminant plume and 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 Woodfin 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.WI0100012 PAGE 4 OF 6
ver.3/01 GIMIC-5

PART VIII- 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 Permittee shall abandon that injection well in accordance with the procedures
specified in 15A NCAC 2C .0214, including but not limited to the following:
(A) All casing and 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 abandoned in such a manner
that will prevent the movement of fluids into or between underground
sources of drinking water and in accordance with the terms and conditions
of the permit.
(G) The Permittee shall submit a Well Abandonment Record(Form GW-30)
as specified in 15A NCAC 2C .0213(h)(1)within 30 days of completion of
abandonment.
Peanut No.WI0100012 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.
Permit No.WI0100012 PAGE 6 OF 6
ver.3/01 GW/UIC-5

t'
DIVISION OF WATER QUALITY D
GROUNDWATER SECTION NOY — 1 2002
October 31, 2002
GROUNDWATER SECTION
ASHEVILLE REGIONAL OFFICE
MEMORANDUM
To: Landon Davidson, L.G., Regional Groundwater Supervisor
Groundwater Section
Asheville Regional Office n
From: Mark Pritzl It'1�. [e-mail]
Hydrogeological Technician 11
Underground Injection Control (UIC) Group
Central Office(CO)
Re: Request for review of an injection well application, type 5I injection well (in-situ
remediation), submitted by Eaton Corporation,to construct and use injection wells for
the injection of an HRC' slung to enhance reductive dechlorination of the dissolved
chlorinated organic contamination at the Borg Warner Cooling Systems on Cane Creek
Industrial Park, in Fletcher,North Carolina.
1. Please review the application and submit comments to CO-UIC group. Retain the
application for your UIC file.
2. Please inspect the injection well site to verify that the location and construction plans
submitted in the application are accurate and that the NCAC Title 15A 2C.0200 standards
are being complied with, using the enclosed Preconstruction Injection Facility Inspection
Report(Form A) as appropriate.
3. You are requested to return The Review Comments and the completed Preconstruction
Injection Facility Inspection Report(Form A) to the CO-UIC by November 15, 2002.
If the inspection and review can not be accomplished by this date,please inform the CO-
UIC.
The UIC group greatly appreciates your assistance with this review. If you have any
questions regarding this review or the UIC program, please contact me at(919) 715-6166.
cc: CO-UIC Files
Enclosures

WAIF Michael F.Easley,Governor
IQ 9 William G.Ross Jr.,Secretary
[� Q North Carolina Department of Environment and Natural Resources
r ; Alan W.Klimek,P.E.Director
-i Division of Water Quality
O -c
October 31, 2002
Steve Fesko
Eaton Corporation
Eaton Center
111 Superior Avenue
Cleveland, OH 44114
Dear Mr. Fesko:
Your application for a permit to construct and/or use injection wells for injecting an HRC
slurry for reductive dechlorination of the dissolved chlorinated solvent contamination at Cane Creek
Industrial Park, in Fletcher,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,
p
Mark Pritzl
Hydrogeological Technician
UIC Program
cc: CO-UIC Files
ARO-UIC Files
AGA
WDENR
Customer Service Division of Water Quality / Groundwater Section
1 800 623-7748 1636 Mail Service Center Raleigh,NC 27699-1636
Phone: [phone] Fax: [phone] Internet: http://gw.ehnr.state.nc.us

NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FO z
INJECTION `
Class 5I Wells w
In Accordance with the provisions of NCAC Title 15A: 02C.0200
Complete application and mail to address on the back page. — <
C=)
TO: DIRECTOR,NORTH CAROLINA DIVISION OF WATER QUALITY ,
DATE: October 28 204� ,_
A. PERMIT APPLICANT
Name: Eaton Corporation
Address: Eaton Center - 1111 Superior Avenue
City: Cleveland State: OH 4 Zip Code:44114
County: Cuyahoga Telephone: (216) 523-5000
B. PROPERTY OWNER(if different from applicant)
Name: Borg Warner Cooling Systems, Inc.
Address: Cane Creek Industrial Park
City: Fletcher State: NC Zip Code: 28732
County: Henderson Telephone: (832) 684-3501
C. STATUS OF APPLICANT
Private: % Commercial: Federal: State:
County: Municipal: Native American Lands: _
D. FACILITY(SITE)DATA
(Fill out ONLY if the Status is Federal, State, County, Municipal or Commercial).
Name of Business or Facility:
Address:
City: Zip Code: County:
Telephone: Contact Person:
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; Provided in Attachment E
(2) operation procedures; and
(3) a planned injection schedule.
GW-57 REM (Jan,2000) Pagel of 5

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 NCDENR Incident Number is 21521 See Attachment F for
site description
J
G. HYDROGEOLOGIC DESCRIPTION Provided in Attachment G
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:
j (1) the regional geologic setting;
.. (2) significant changes in lithology;
(3) the hydraulic conductivity of the saturated zone;
(4) the depth to the mean seasonal high water table; and
(5) a determination of transmissivity and specific yield of the aquifer to be used for
injection(showing calculations).
— H. MONITORING PROCEDURE Provided in Attachment H
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.
I. WELL USE Will the injection well(s) also be used as the supply well(s) for the following?
y (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-I (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.
(1) Well Drilling Contractor's Name: Probe Technology Inc.
NC Contractor Certification number: 2724
I
(2) Date to be constructed: December 2002* Number of borings: 8
Approximate depth of each boring(feet): 20
J *Pending NCDENR approval
GW-57 REM (Jan,2000) Page 2 of 5

e
(3) Well casing: None
Type: Galvanized steel_Black steel_Plastic_Other(specify)
Casing depth: From to ft. (reference to land surface)
_ Casing extends above ground inches
(4) Grout:
Grout type: Cement_ Bentonite X Other(specify)
Grouted surface and grout depth(reference to land surface):
around closed loop piping; from to (feet).
around well casing; from to (feet).
(5) Screens None
Depth: From to feet below ground surface.
(6) 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.
Will there be a faucet on the influent line? yes no X
Will there be a faucet on the effluent line? yes nc X
(7) SOURCE WELL CONSTRUCTION INFORMATION (if different from injection
well). Attach a copy of Form GW-1 (Well Construction Record). If Form GW-1 is not
available, provide the data in part G of this application form to the best of your
knowledge.
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 Provided in Attachment K
Provide a tabulation of data on all wells within '/4 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.
L. PROPOSED OPERATING DATA
(1) Injection rate: Average (daily) NA eallons per minute(gpm)
(2) Injection volume: Average(daily) 43 gallons per day(gpd)
(3) Injection pressure: Average(daily) NA pounds/square inch(psi)
(4) Injection temperature:Average(January) 45 ° F, Average (July) 85 *F
(5) Hydraulic capacity of the well: NA (Temporary �eoprobe boring)
(6) Expected lifetime of the injection facilityless than lyears
(7) Give a description of how the above data will be measured and controlled:
A predetermined volume of HRC will be mixed in a hopper, then pumped
_ into each geoprobe boring.
GW-57 REM (Jan,2000) Page 3 of 5

! A
M. INJECTION-RELATED EQUIPMENT See Attachment M
J
Attach a diagram showing the detailed plans and specifications of the surface and subsurface
construction details of the system.
N. LOCATION OF WELLS) Provided in Attachment N
Attach a scaled, site-specific map(s) showing the location(s)of the following:
(1) the proposed injection well(s);
(2) all property boundaries;
(3) contour intervals not exceeding two feet;
(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);
(5) all buildings within the property boundary;
(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;
-' (7) potentiometric surface showing direction of groundwater movement;
(9) the horizontal and vertical extent of the contaminant plume (including
isoconcentration lines and plume cross sections);
(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; and
(10) all surface water bodies within 1000 feet of the injection well or well system.
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.
Depth:
Formation:
Rock/sediment unit:
(2) Provide the chemical, physical, biological and radiological characteristics of the fluid
to be injected. The Material Safety Data Sheets for the HRC compound
are provided in Attachment 0.
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 1
(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.
GW-57 REM (Jan,2000) Page 4 of 5

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Q. CERTIFICATION
"I hereby certify, under penalty of law, duet 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 tt=, 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."
Eaton Corporation
By: T (cam/_,
(Signature of Well Owner or Authorized Agent)
Vice President & Secretary
If authorized agent it 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 Constriction Standards (Title 15A NCAC 2C .0200)
i
f Property Owner If Differ en "rohn Applicant)
Please return two copies of the completed Application package to:
UIC Program
Groundwater Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
GW-57 REM (Jan,2000) Page 5 of 5

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ATTACHMENT E
INJECTION PROCEDURE
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E. INJECTION PROCEDURE
I
The proposed injection activities at the BorgWamer Cooling System, Inc. facility
in Fletcher, North Carolina involve the injection of Hydrogen Release Compound
(HRCT°') into the subsurface utilizing Geoprobe® direct-push methods. HRC is a
proprietary product developed and distributed by Regenesis, Inc., of San Clemente,
California. The purpose of the proposed injection is to evaluate the efficacy of using
HRC for the in-situ treatment of contaminated ground water at the site.
1) Construction Plans and Materials
A total of eight Geoprobe borings will be drilled in a 40 x 10 foot test treatment
area for the purpose of injecting HRC. The borings will be drilled at ten foot spacings in
two rows with four borings in each row. The borings will be installed within the
shallow ground-water zone at depths between 15 to 20 feet below grade. After reaching
the target depth, HRC will be injected directly through the Geoprobe rods into the
formation. Following injection, the Geoprobe rods will be pulled and the boring sealed
with bentonite grout. Consequently, no permanent/temporary injection wells will be
constructed.
HRC is a proprietary, food-grade polylactate ester specially formulated for slow
release of lactic acid upon hydration. The compound is a high viscosity, flowable liquid
with the consistency of viscous honey. Upon injection, HRC slowly dissolves and
degrades to lactic acid, which in turn is metabolized by indigenous anaerobic microbes to
produce hydrogen. The hydrogen is then used by reductive dechlorinating microbes to
degrade chlorinated solvents and their derivatives.
2) Operation Procedures
The Geoprobe rod assembly will be pushed to the desired depth and the
predetermined volume of HRC compound will be pressure injected through the rods into
the subsurface. Prior to injection, the HRC will be pre-heated, poured into a pump
hopper and mixed to a uniform consistency. During injection, the Geoprobe rods will be
slowly withdrawn to deliver the HRC across the treatment interval. HRC will be applied
to the boring at a rate of five (5) pounds per vertical foot of saturation. Following the
HRC injection, the Geoprobe rods will be pulled, and the boring filled with bentonite to
secure the HRC in place and to prevent contaminant migration from the surface.
3) Planned Injection Schedule
For the purposes of this pilot test, the schedule consists of a single HRC injection
I into each borehole. It is anticipated that the drilling/injection process will take one to two
days to complete.
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ATTACHMENT F
SITE DESCRIPTION
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F DESCRIPTION OF SITE
In the course of multiple assessment investigations at the Facility, impact to ground-
water (levels above State standards) was detected. The NCDENR incident number is
21521. The detailed results from the site investigations are documented in the July 2001
Comprehensive Site Assessment (CSA) Report and the August 2002 Addendum to the
CSA. The type, source and amount of ground-water impact are summarized below.
❑ Type of Contaminants: The type of impact consists of chlorinated volatile
organic compounds. Trichloroethylene, tetrachloroethylene, cis-1,2-
dichloroethene and vinyl chloride have been reported above State standards in
ground-water samples from the site.
❑ Source of the Release: After significant investigation, Eaton has been unable to
determine the historic source of ground-water impact. Chlorinated solvents are no
longer used or present at the Facility. The impact is not related to leaks from
above or below ground storage tanks, surface spills, or pipelines, etc. The impact
may be related to unknown historic activities at the site when the site was part of
the former airport. Historical aerial photographs, during the time of former
airport operations, show an area of surface disturbance in the current position of
the Facility building. The area of historical surface disturbance coincides with the
J area where ground-water impact was identified.
❑ Amount of Release: Because the exact source of the ground-water impact is not
known, the amount (volume) of VOCs in the ground water cannot be quantified.
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ATTACHMENT G
HYDROGEOLOGIC DESCRIPTION
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G HYDROGEOLOGIC DESCRIPTION
1) Regional Geologic Setting
Information regarding the geologic and hydrogeologic setting for the area in and
around the Facility is based on the Geologic Map and Mineral Resources Summary of the
Fruitland Quadrangle, North Carolina (Lemmon and Dunn, 1973) and the Mineral
Resources Summary of the Fruitland Quadrangle North Carolina (Lemmon, 1973). The
regional geology consists of four general stratigraphic units: unconsolidated alluvium,
residuum and saprolite and consolidated metamorphic bedrock. The alluvium consists of
clay, silt, sand, and gravel deposited by streams and rivers. The unit, where found, is
generally present at ground surface and ranges in thickness from a few feet to greater
than 50 feet. Where the alluvium is absent, residuum is usually encountered at ground
surface. Residuum is soil that has undergone sufficient weathering to destroy all relict
rock structure. This unit varies from thin (less than 10 feet) upwards to 30 feet in
thickness. Typically, the residuum grades into saprolite at depth. Saprolite is thoroughly
decomposed bedrock that retains relict rock structure. Thickness of this unit is highly
variable, from thin (less than 10 feet) up to 100 feet across the region. The region is
within the northeast-trending Brevard fault zone, a narrow belt of steeply dipping low-
grade metamorphic rocks. The rocks within the fault zone are generally Cambrian Age
porphyroclastic mylonite and cataclastic schist(Lemmon and Dunn, 1973).
2) Significant Changes in Lithology
The lithologic descriptions of the subsurface soils and geology at the Facility are
based on drilling results of the Geoprobe borings and monitoring wells. Generally, the
site geology consists of unconsolidated fill, soil and alluvium, underlain by saprolite and
fractured metamorphic rock. The units encountered at the Facility in order of increasing
depth are:
o Unconsolidated fill and soil
o Alluvium
o Saprolite
F o Bedrock
The relationship of these units is depicted on the geologic cross-sections on Figures G-1
and G-2. Cross-Section A—A' (Figure G-1) is oriented east-west along the southern
boundary of the Facility and Cross-Section B—B' (Figure G-2) is oriented north-south
along the eastern boundary of the Facility.
i

1 I
The unconsolidated fill/soil consists of clay and silt with interbedded sand seams.
The material ranges in thickness from 3 to 17 feet and appears to thin to the east-
northeast at wells MW-3 and MW-4 to thicken to the southwest at wells MW-6D and
MW-10.
Below the surficial soil is the alluvium, a variable unit ranging from silty clay to
- sand and gravel. The total thickness of the alluvium ranges from 0 to 15 feet except in
the southwestern corner of the Facility at well MW-6D, where the thickness is almost 40
feet. The alluvium consists of interlayered silt, clay and sand except in the area near
where the surface ditch flows under Mills Gap Road. In this area (wells MW-8 and MW-
9, as shown on Drawing G-1), the alluvium is primarily coarser-grained sand and gravel.
At well MW-6D, the upper 10 feet is coarser-grained sand and gravel and the lower 30
feet is fine-grained silt and clay.
Below the alluvium is the saprolite unit, a clay, silt and sand that demonstrates
relict bedrock texture. This unit, which occurs at depths from 5 to 50 feet, ranges in
thickness from 14 to 20 feet, with the thickest area near well MW-5D (20 feet).
The bedrock beneath the facility is highly fractured metamorphic rock, ranging
from schist at MW-3D, MW-51), and MW-71) to quartzite and slate at MW-6D. The top
of the competent (unweathered) bedrock occurs at depths of 20 to 60 feet below grade.
3) Hydraulic Conductivity
Representative hydraulic conductivities for the shallow ground-water zone were
determined based on values reported in the September 1994 CSA Report for the
Wilsonart facility. The shallow ground-water zone evaluated at the Wilsonart facility is
stratigraphically equivalent to the proposed injection zone at the BorgWarner facility.
Based on slug tests, the hydraulic conductivity of the alluvium/saprolite ranged from 0.17
to 2.83 feet per day (ft/day), with an average of 1.16 ft/day.
4) Depth to Mean Seasonal High Water Table
Based on the available water level data for the shallow ground-water zone, the
depth to the seasonal high water table varies from 14.5 to 3.7 feet below grade across the
site. In the proposed area of the injection well pilot test, the depth to the seasonal high
water table is approximately 8.5 feet. Historical water-level data for the site is provided
in Table G-1.
5) Aquifer Transmissivity and Specific Yield
The transmissivity of the shallow ground-water zone in the area of the proposed
injection site was calculated based on the reported hydraulic conductivities from the 1994
Wilsonart pumping test and the estimated saturated aquifer thickness. Based on a depth

to water of 8.5 feet and total depth of 20 feet, the saturated thickness of the shallow
ground-water zone is approximately 11.5 feet. Assuming hydraulic conductivities
between 0.17 and 2.83 ft/day, the calculated transmissivity of the shallow ground-water
zone is between 2 and 33 ftZ/day. The best available specific yield estimates for the
shallow ground-water zone are those reported for the 1994 Wilsonart pumping test and
range between 0.001 and 0.007 (Rust, 1994).
North Carolina Licensed Geologist
d7' V M4S
Frank J. gtzchell

References
—' Lemmon, Robert E., 1973, Mineral Resources Summary of the Fruitland Quadrangle,
North Carolina, North Carolina Department of Natural and Economic Resources,
j Office of Earth Resources Report MRS 202-NW.
Lemmon, Robert E. and David E. Dunn, 1973, Geologic Map of the Fruitland
Quadrangle, North Carolina, North Carolina Department of Natural and
Economic Resources, Office of Earth Resources Map GM 202-NW.
RUST Environment &Infrastructure, September 1994, Comprehensive Site Assessment/
Corrective Action Plan, prepared for Ralph Wilson Plastics Company, Fletcher,
North Carolina.
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3000
2095 A MW-6D
WEST
2090 MW-10
2085 UNCONSOLIDATED FILL.
2080
(10) 2079,39
-
2075
2070
2065
2060
2055
2050
2045
-- - - - - - - - - - - - - -
2040
2035
2030
(10I)
2025
2020
2015
(lOD)
2010
2005

A'
EAST
MW-7D Q u0
MW-9 MW-8 ® CLAY
SILT
® SILT/CLAY
L ",r —,:' Q j 0 _' SAND
ALLUVIUM
, SAPROLTTE
71 ':=:= 207976 R e
T.,
CRYSTALLINE BEDROCK
+`< SLATE
�<<+ SCREENED
INTERVAL
c <
+ <
POTENTIOMETRIC SURFACE BEDROCK
I WATER TABLE
y POTENTIOMETRIC SURFACE INTERFACE
SAPROLITE /
GROUND WATER LEVEL ELEVATION
MEASUREMENTS TAKEN 8/8/01
s
r �
a . r
BEDROCK --
FORMER EATON CORPORATION
BORGWARNER COOLING SYSTEMS, INC.
FLETCHER, NORTH CAROLINA PLANT
o DATE:ocrOBER 2002 APPROVED BY: DWN BY:KwG
SCALE: As SHOWN
Vf5 CHKD. BV:off
VERTICAL: 1" = 10' SHEET 1 OF1
HORIZONTAL: 1" = 100' � GEOLOGIC CROSS SECTION DRAWING NUMBER
A—A' FIGURE G-1

B
NORTH
MW-3/3D MW-4 MW-5/5D
3000
2095
2090
2085 ALLUVIUM -
(3)
C5)
2080
2075
2070
SAPROLITE
2065
i 2060
w 2055 (5D)
w
w
2050 BEDROCK
a
J 2045 (3D)
w
2040
2035

LEGEND
B'
CLAY
SOUTH ®
M 7D
SILT
® SILT/CLAY
4r j1.
��- SAND
®47 2084.05 SAPROLITE
4
CRYSTALLINE BEDROCK
41 ® SLATE
SCREENED
INTERVAL
y POTENTIOMETRIC SURFACE BEDROCK
WATER TABLE
ALLUVIUM/SAPROUTE
GROUND WATER LEVEL ELEVATION
H MEASUREMENTS TAKEN 6/8/01
O
w VERTICAL: 1' = 10'
_. HORIZONTAL: 1" - 100'
'r FORMER EATON CORPORATION
as BORGWARNER COOLING SYSTEMS, INC.
FLETCHER, NORTH CAROLINA PLANT
DATE:OCTOBER 2002 APPROVED BY: DYM BY:awC
r r SCALE: AS SHOWN I 0I5 CHKD. BY:DH
SHEET 1 OF1
GEOLOGIC CROSS SECTION DRAWING NUMBER
RGURE G-2

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ATTACHMENT H
MONITORING PROCEDURE
J

_! H MONITORING PROCEDURE
Three monitoring wells, one upgradient, one inside the treatment area and one
downgradient of the injection site, will be installed in the shallow ground-water zone for
purposes of monitoring ground-water quality prior to and following HRC injection. The
proposed monitoring well locations are shown in Figure N-1 (Attachment N).
Monitoring wells will be drilled using 4 '/a inch ID hollow stem augers (HSA) by
advancing the augers to the completion depth and constructing the well within the augers.
Monitoring wells will be completed using 2-inch ID schedule-40 PVC casing and 0.010-
inch slot PVC screen. A washed silica sand filter pack will be placed in the annulus
around the screen to a depth of approximately 2 feet above the top of the screen. The filter
pack will secured with a 2-foot bentonite pellet seal and the remaining annular space will
backfilled with bentonite slurry to within approximately 3 feet below the ground surface.
Each monitoring well will be completed with a locking, steel protective casing set in a
sloping concrete pad. Following construction, the monitoring wells will be developed by
surging and pumping with a submersible pump. Each well will be developed until
_ approximately 10 well volumes were removed, the discharge water appeared clear, or the
well had been completely evacuated four times.
Following development and prior to HRC injection, ground-water samples from
the new monitoring wells will be submitted for analysis of VOCs and the following
biodegradation indicator parameters:
o Inorganic parameters consisting of dissolved iron and manganese, sulfide,
nitrate, sulfate, chloride, alkalinity, and total organic carbon.
o Metabolic acids consisting of lactic, pyruvic, acetic, propionic, and butyric.
o Dissolved gases consisting of carbon dioxide, methane, ethane, and ethene.
o Field parameters including dissolved oxygen, oxygen reduction potential, pH,
temperature, and ferrous iron.
The resultant data will be used to establish pre-treatment baseline conditions. Following
HRC injection, the new monitoring wells will be sampled every two months for a period
of six months for VOCs and the listed biodegradation indicator parameters. The resultant
data will be used to evaluate the efficacy of the HRC injection for reducing VOC
concentrations. After the initial six months, the sampling program will be reevaluated to
r assess the need for continued monitoring.
Ground-water samples will be collected using minimal drawdown sampling
procedures. In this approach, the wells will be purged with a peristaltic pump at a rate
that produces no net drawdown of the water-level surface within the well. The water
temperature, pH, specific conductance, dissolved oxygen, and oxidation reduction
potential will be monitored continuously throughout the purging process via a constant
J reading flow-through cell. The ground-water samples will be collected following
stabilization of the field parameters. Ground-water samples will be placed into approved

containers provided by the laboratory. Sample preservatives will be added to the sample
_ bottles prior to or immediately following sample collection. Following collection, the
sample bottles will be labeled and placed in a cooler with ice for delivery to Prism
Laboratories for analysis of VOCs and biodegradation indicator parameters.
On October 1, 2001, shallow zone monitoring wells MW-1, MW-2, MW-3, MW-
-� 4, MW-5, MW-8, and MW-9 were sampled for VOCs and to characterize the
concentrations of the biodegradation indicator parameters listed above. The laboratory
analytical results for the biodegradation indicator parameters in ground water from the
shallow zone monitoring wells are summarized in Table H-1. In general:
❑ Dissolved iron and sulfide were not detected in any of the shallow ground-
water samples.
❑ Dissolved manganese concentrations ranged from non-detect (MW-I) to 0.25
mg/L GvIW-2).
❑ Nitrate concentrations ranged from non-detect (MW-2, MW-4, and MW-9) to
0.26 mg/L(MW-1).
r ❑ Sulfate concentrations ranged from non-detect (MW-2 and MW-5) to 4.5
mg/L(MW-1).
❑ Chloride concentrations ranged from 1.1 (MW-5) to 8.7 mg/L (MW-9).
❑ Alkalinity concentrations ranged from 11 (MW-2) to 52 mg/L (MW-1).
I
j ❑ Total Organic Carbon was only detected in the ground-water sample from
MW-4 at a concentration of 4.7 mg/L.
Metabolic acids were not detected in any of the shallow ground-water samples and
the dissolved gas analytical results are listed below.
❑ Carbon Dioxide concentrations ranged from 79,000 (MW-5) to 140,000 µg/L
(MW-4).
❑ Methane concentrations ranged from 0.31 (MW-1) to 1,900 µg/1 (MW-4).
❑ Ethane concentrations ranged from 0.0076 (MW-1 and MW-3) to 0.052 µg/L
(MW-5).
❑ Ethene concentrations ranged from 0.026 (MW-4) to 0.14 µg/l (MW-5).
The laboratory analytical results for the biodegradation indicator parameters were
submitted along with the VOC data to Regenesis (San Juan Capistrano, California) to
evaluate the natural attenuation potential within the shallow ground-water zone. Based
on the available data, Regenesis concluded that the following conditions indicate that
natural attenuation is on-going at the Fletcher facility:

o Presence of dissolved manganese—indicates reducing conditions
o Low sulfate—indicates sulfate lowered by sulfate reducers
o Sulfides not detected—indicates reducing conditions
o Elevated carbon dioxide—indicates biologic activity in aquifer
i
o Presence of methane—indicates reducing conditions
o Presence of ethane—indicates naturally occurring reductive dechlorination
o Low to no TOC—low TOC associated with reductive dechlorination
o Low to no nitrate
Based on these results, it is concluded that conditions in the shallow ground-water zone
are favorable for enhanced/accelerated natural attenuation (biodegradation).
f

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it
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ATTACHMENT K
OTHER WELL DATA
J
J
J

K OTHER WELL DATA
The available information on all wells within '/a mile of the proposed injection
well site that penetrate the shallow ground-water zone (excepting water supply wells
i serving single-family residences) is provided in Table K-1. A total of 29 wells were
identified:
❑ Seven monitoring wells and one site production well are reported at the Wilsonart
facility;
❑ Four monitoring wells are reported at the Steelcase facility;
❑ Fifteen monitoring wells are at the BorgWarner facility (former Eaton); and
❑ One monitoring well is reported at the ABF facility.
I
I
J
J
i
J
J

TABLE K-1
WATER WELL SEARCH
Former Eaton Facility-Fletcher,North Carolina
Number Well Casing Screened
Current OwnerNser Name of Total Depth Depth(feet Interval
Address Wells Well Type (feet bgs) bgs) (feet bgs) Comments
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 17 7 7-17 MW-1
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 17 7 7-17 MW-2
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 16 6 6-16 MW-3
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 55 45 45-55 MW-3D
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 14 4 4-14 MW-4
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 16 6 6-16 MW-5
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 26 21 21-26 MW-51
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 42 32 32-42 MW-513
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 75 65 65-75 MW-61D
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 35 25 25-35 MW-713
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 14 9 9.14 MW-8
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 19 9 9-19 MW-9
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 15 5 5-15 MW-10
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
- Park 1 Monitoring 65 60 60-65 MW-101
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 85 75 75-85 MW-10D
BKT Enterprises 7 Monitoring 20 5 15 ABF Transportation
Ralph Wilson Plastics Co. Industrial
1469 Cane Creek 1 Supply 401 41 NA RWP Production well
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring 23 13 13-23
Leggette,Brashears&Graham,Inc. October 2002
Columbus,Ohio 1 of 2 Injection Well Permit Application

TABLE K-1
WATER WELL SEARCH
-- Former Eaton Facility-Fletcher,North Carolina
Number Well Casing Screened i
Current Owner/User Name of Total Depth Depth(feet Interval
Address Wells Well Type (feet bgs) bgs) (feet bgs) i Comments
Ralph Wilson Plastics Co.
_ 1469 Cane Creek 1 Monitoring 29 19 19-29
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co. -
1469 Cane Creek 1 Monitoring unk
I Ralph Wilson Plastics Co.
—' 1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring unk
_ Steelcase,Inc
Hoopers Creek Rd.
04-694.2241 1 Monitoring unk
Steelcass, Inc
Hoopers Creek Rd.
04-6a4-2241 1 Monitoring unk (1)
Steelcase,Inc
Hoopers Creek Rd.
04-684-2241 2 Monitoring unk (1)
J
Leggette,Brashears&Graham,Inc. October 2002
Columbus,Ohio 2 of 2 Injection Well Permit Application

ATTACHMENT M
INJECTION-RELATED EQUIPMENT
J
I
J
J
J
J
J
i
i

M INJECTION-RELATED EQUIPMENT
The HRC will be pressure injected into the target formation through Geoprobe®
drilling rods. Prior to injection, the HRC will be pre-heated, poured into a pump hopper
and mixed to a uniform consistency. Following injection, the Geoprobe®rods will be
pulled and the boring will be sealed with bentonite. Because there will be no permanent
injection wells or injection equipment at the facility, equipment plans or specifications
will not be prepared.

i
f
l
ATTACHMENT N
- LOCATION OF WELL(S)

-J
_ I _
�G G G 6 G1
,�G G
G Y Y a . 1
1994 997
¢ it 1994 1987
a
E APLOYEE I�
ARKING a
a� ORIGINAL ADC
BUILDING 11
a 1976
a
rn
a OFFICES � � a
1978
PROPOSE[
a a INJECTION
ISITOR
ARKING
I \ a
eow,�
���8�—
W wv
I

REVISION RECORD
DAIS DESGDPIIDN
RE.Vf iflEVf_DESC
RE RE DEM
REMI VJ RE/iDESC
REVa 1 REVa_DESD
REM I RM-DM
�s LEGEND
STORM SEWER
BURIED ELECTRIC
-�- BURIED GAS
\ -n- FIRE PROTECTION
-.- WATER
n \ BURIED SANITARY
PROPERTY BOUNDARY
-0 SECURITY LIGHT
-n1 M FIRE HYDRANT
MONITORING WELL
1994 III PROPOSED MONITORING WELL
J • INJECTION WELL
v
a
a
a
aII
`VAS St`ei R IN FEET
5�
—'wv /°r FORMER EATON CORPORATION
COOLING
BORGWARNER COOLING SYSTEMS, INC.
' FLEfCHER, NORTH CAROLINA PLANT
DA1E:oCTORI7t zaD2 APPROVED BY: OWN BY:I<MAC
SCALE: AS SHOWN J1S CHKD. BY:DH
SHEET 1 OF1
0 SITE PLAN DRAWING NUMBER
FIGURE N-1

BOMR WA NER
SITE LOCATION MAP
FLETCHER., NORTH CAROUNA

6 6
3 1997
� ..,.' 1994
II 1994 19,
a
EMPLOYEE
PARKING
a� IGINAL ADDI
ev n—,7 ^v n-Rr-^-Vn-no- B DING 19
i—:—. �-- 19 6
a
a
a a
p-n-R
O9713 ES
a a
a a
VISITOR
PARKING
a
M`N
201 9I-LES GAP — ROAD
g2
�1
MO 9 56 6w wv M 0ea o

REVISION RECORD
AM I DESCRIPTION
REVt 1REY1_OE9C
Rm REVZDESC
REV] IREVS_DESC
M4 1 REV4_1E
REVS REVS_OESC
4ADDITION \
1997
LEGEND
dog MONITORING WELL
1994 II A FORPORARY STREAMBENCH ELEVATION MARK,
MEASUREMENT
—'— BURIED ELECTRIC
a- —'— BURIED GAS
FIRE PROTECTION
a
— — WATER
a —•— SANITARY
�MW,A MONITORING WELL & STREAM
ELEVATIONS MEASURED 9/21/00
Ia
- -n—nJ —2090— EQUIPOTENTIAL CONTOUR
GROUND WATER FLOW DIRECTION
GRADIENT: A—A'a 2090 —680 2080 p 0.015
-'1' 2p85 9
D n Im
j5 37
—' ^w /°N FORMER EATON CORPORATION
COOLING
BORGWARNER COOLING SYSTEMS, INC.
FLETCHER, NORTH CAROLINA PLANT
OilDATE.F 08EE 2002 APPROVED BY: DM BY:KMAC
SCALE: As sHowN As CHKD. BY:DH
SHALLOW ZONE SHEET 1 OF1
o POTENTIOMETRIC SURFACE MAP DRAWNG NUMBER
(1/22/02) FIGURE N-3

N
25� Kg 22 8 21
250•
Gp' �s
6 6
f 6 • � f
f—i —L
Kg
i 1997 Ke 9
1994
al 1994 1987 •
0 4
EMPLOYEE I" K9' KB'2
PARKING a
I
KB • " ORIGINAL
a ADDI
BUILDING 19
1976
1 �
yl '2 a K
_• / /�D Oaf SC�'V✓/� J '�#a Gnp_" V'
�1 1 M,N�1p0 �22/G
P o ® OFFICES / ((;; 19 a GP�20 1
h O l 1978 / � Op ® 28 i
KGP-18 �v'
NO Gp, � 15
�4 GP'1'1
O- GP NQ VISITOR
a PARKING O/
,�O
Z 55 6 �Q
/ NO
Gp�Q P'229 GP 2� , / Gp'NG i GP23 Gp,a Gpbc
7

REVISION RECORD
DALE DESWPTfRI
Roil
IW REYt_06C
EV2 PEV20ESC
REV] I REVJ_D
REVt 1 REVt_DESC
REPS I REV5_DEX
t\
nADDLEGEND
• OCTOBER 1999 GEOPROBE
BORING, BY KERAMIDA
APRIL 2000, CEC GEOPROBE
SAMPLE POINT
1994 • K I I MONITORING WELL
TEMPORARY BENCH MARK,
AL FOR STREAM ELEVATION
MEASUREMENT
—�— BURIED ELECTRIC
o1 2�, LKg 1�0
p5 —.— BURIED GAS
J a
• I —w— FIRE PROTECTION
�Cg' /• h a
BURIED SANITARY
BURIED WATER
3 • p2 �' 28 TOTAL VOC CONCENTRATION (ug/Q
55, I
1 MW,2
GP O '
i
IN FEkf
I/50 O'D
l
FORMER EATON CORPORATION
BORGWARNER COOLING SYSTEMS, INC.
y FLETCHER, NORTH CAROLINA PLANT
S DATE:OCTOBER 20112 APPROVED BY: OWN BY:KMAC
SCALE: AS SHOWN .Rs CHKO. BY:DH
M•N' SHALLOW ZONE SHEET 1 OF 1
TOTAL VOCs ISOCONCENTRATION DRAWNG NUMBER
MAP (09/1) FIGURE N-4

1
r
ATTACHMENT O
INJECTION FLUID DATA
J '
l
1�

HRC MSDS ; Page 1 of 6
REGENIESIS
r 4mma� MATERIAL SAFETY DATA SHEET
tit�.v
Last Revised: March 1, 2001
-_ �d�ill6ssf't_c�tJne=ylS.,� .
ai±sr, 'fm2r1
�., Section 1 -Material Identification
Supplier: Regenesis Bioremediation Products
Yam' 1011 Calle Sombra
San Clemente, CA 92673
Telephone: [phone]
�;t ' Facsimile: [phone]
Chemical Name: Propanoic acid, 2-[2-[2-(2-hydroxy-l-oxopropoxy)-1-oxopropoxy]
-1-oxopropoxy]-1,2,3-propanetriyl ester
Chemical Family: Organic Chemical
i
Trade Name: Glycerol tripolylactate r
Product Name: Hydrogen Release Compound (HRCO)
Section 2-Hazardous Ingredients
i
j
CAS #: 201167-72-8
One should anticipate the potential for eye irritation and skin 'irritation with large
scale exposure or in sensitive individuals. i
i
Section 3 -Physical Data
http://www.regenesis.com/HRC/hrcrosds.htm 8/22/2002

HRC MSDS Page 2 of 6
Melting Point: NA
Boiling Point: ND
Flash Point: ND
Density: 1.347
Solubility: Acetone and DMSO
Appearance: Amber semi-solid
Odor: Not detectable
Vapor Pressure: None
Section 4-Fire and Explosion Hazard Data
Extinguishing Media: Carbon Dioxide,Dry Chemical Powder or Appropriate Foam.
Water may be used to keep exposed containers cool.
For large quantities involved in a fire, one should wear full protective clothing and a
NIOSH approved self contained breathing apparatus with full face piece operated in
the pressure demand or positive pressure mode as for a situation where lack of
oxygen and excess heat are present.
Section 5 -Toxicological Information
Acute Effects: May be harmful by inhalation, ingestion, or skin absorption.
May cause irritation. To the best of our knowledge, the chemical, physical, and
toxicological properties of the glycerol tripolylactate have not been investigated.
Listed below are the toxicological information for glycerol and lactic acid.
RTECS#: NIA8050000
http://www.regenesis.com/BRC/hrcrosds.htm 8/22/2002

HRC MSDS Page 3 of 6
Glycerol
Irritation data: SKN-RBT 500 MG/24H MLD 85JCAE-,207,1986
EYE-RBT 126 MG MLD BIOFX* 9-4/1970
EYE-RBT 500 MG/24H MLD 85JCAE-,207,1986
Toxicity data: ORL-MUS LD50:4090 MG/KG FRZKAP (6),56,1977
SCU-RBT LD50:100 MG/KG NIIRDN 6,215,1982
ORL-RAT LD50:12600 MG/KG FEPRA7 4,142,1945
H-M-RAT LC50: >570 MG/M3/1H BIOFX* 9-4/1970
IPR-RAT LD50: 4420 MG/KG RCOCB8 56,125,1987
IVN-RAT LD50:5566 MG/KG ARZNAD 26,1581,1976
IPR-NMS I.D50: 8700 MG/KG ARZNAD 26,1579,1978
SCU-MUS LD50:91 MG/KG N=N 6,215,1982
IVN-MUS LD50: 4250 MG/KG JAPMA8 39,583,1950
ORL-RBT LD50: 27 GM/KG DMDJAP 31,276,1959
SKN-RBT LD50:>10GM/KG BIOFX* 9-4/1970
IVN-RBT LD50: 53 GM/KG N=N 6,215,1982
ORL-GPG LD50: 7750 MG/KG JIHTAB 23,259,1941
Target Organ data: Behavioral (headache), gastrointestinal (nausea or vomiting),
Paternal effects (spermatogenesis, testes, epididymis, sperm duct), effects of fertility
(male fertility index,post-implantation mortality).
RTECS#: OD2800000
Lactic acid
Irritation data: SKN-RBT 5MG/24H SEV 85JCAE-,656,86
EYE-RBT 750 UG SEV AJOPAA 29,1363,46
Toxicity data: ORL-RAT LD50:3543 MG/KG FMCHA2-,C252,91
SKN-RBT LD50:>2 GM/KG FMCHA2-,C252,91
http://www.regenesis.com/HRC/hrcrosds.htm 8/22/2002

IMC MSDS Page 4 of 6
ORL-MUS I.D50: 4875 MG/KG FAONAU 40,144,67
ORL-GPG LD50: 1810 MG/KG=AB 23,259,41
ORL-QAL LD50: >2250 MG/KG FMCHA2-,C252,91
-. Only selected registry of toxic effects of chemical substances anECS) data is
presented here. See actual entry in RTECS for complete information on lactic acid
and glycerol.
Section 6 - Health Hazard Data
Handling: Avoid continued contact with skin.
Avoid contact with eyes.
In any case of any exposure which elicits a response, a physician should be consulted
immediately.
_- First Aid Procedures:
Inhalation: Remove to fresh air. If not breathing give artificial respiration. In case of
labored breathing give oxygen. Call a physician.
Ingestion: No effects expected.Do not give anything to an unconscious person. Call i
physician immediately.
Skin Contact: Flush with plenty of water. Contaminated clothing may be washed or
dry cleaned normally.
Eye contact: Wash eyes with plenty of water for at least 15 minutes lifting both uppe
and lower lids. Call a physician.
Section 7 -Reactivity Data
http://www.regenesis.com/ERC/hrcrosds.htm 8/22/2002

iKu M.ND6 rage:) or o
Conditions to Avoid: Strong oxidizing agents, bases and acids
Hazardous Polymerization: None known
_ Further Information: Hydrolyses in water to form Lactic Acid and Glycerol.
Section 8 - Spill, Leak or Accident Procedures
After Spillage or Leakage: Neutralization is not required.This combustible material
may be burned in a chemical incinerator equipped with an afterburner and scrubber.
Disposal: Laws and regulations for disposal vary widely by locality. Observe all
- applicable regulations and laws. This material, may be disposed of in solid waste.
Material is readily degradable and hydrolyses in several hours.
No requirement for a reportable quantity (CERCLA) of a spill is known.
Section 9 - Special Protection or Handling
Should be stored in plastic lined steel, plastic, glass, aluminum, stainless steel, or
reinforced fiberglass containers.
Protective Gloves: Vinyl or Rubber
Eyes: Splash Goggles or Full Face Shield
Area should have approved means of washing
eyes.
Ventilation: General exhaust.
Storage: Store in cool, dry, ventilated area.
Protect from imcompatible materials.
*****************************************************************
http://www.regenesis.com/HRC/hrcrosds.htm 8/22/2002

*HRC MSDS Page 6 of 6
Section 10 - Other Information
This material will degrade in the environment by hydrolysis to lactic acid and
glycerol.
Materials containing reactive chemicals should be used only by personnel with
appropriate chemical training.
The information contained in this document is the best available to the supplier as of
the time of writing. Some possible hazards have been determined by analogy to
similar classes of material. No separate tests have been performed on the toxicity of
this material.The items in this document are subject to change and clarification as
more information becomes available.
[Hnnm][tip
]
Copyright©Regenesis Bioremediation Products. 1996-2002.All Rights Reserved.
O Registered Trademark of Regenesis Bioremediation Products, Inc.
http://www.regenesis.com/HRCthrcrosds.htin 8/22/2002

D WE
LEGGETTE BRASBEARS & GRAHAM OCi 3 0 2002 D
PROFESSIONAL GROUND-WATER AND
ENVIRONMENTAL ENGINEERING SERVICES GROUNDWATER SECTION
ASHBILLE REGIONAL OFFICE
TAYLOR STATION COMMERCE CENTER
950 TAYLOR STATION ROAD.SUITE K
GAHANNA,OH 43230
614416-9100
PAX 614416-9101
www.Ibgweb.e
October 28, 2002
Mr. Evan Kane
UIC Program Manager
UIC Program
Groundwater Section
North Carolina DENR-DWQ
2728 Capital Blvd.
Raleigh,NC 27604
RE: Injection Well Permit Application
BorgWamer Facility; Fletcher, North Carolina
Dear Mr. Kane:
Enclosed please find two signed injection well permit applications for the
proposed remediation pilot test at the BorgWamer Cooling Systems, Inc. facility in
Fletcher, North Carolina. The proposed activities for the remediation pilot test involve
the injection of Hydrogen Release Compound (HRCTm) into the subsurface utilizing
Geoprobe® direct-push methods. HRC is a proprietary product developed and
distributed by Regenesis, Inc., of San Clemente, California. The purpose of the proposed
injection is to evaluate the efficacy of using HRC for the in-situ treatment of
contaminated ground water at the site.
If you have any questions or concerns regarding the permit application, please
feel free to contact us at [phone]. Thank you for your assistance in this matter.
Very truly yours,
LEGGETTE, B HEARS & GRAHAM, INC.
90tA
Doug unter
Senior Ground-Water Hydrologist
DRH/drh
cc: Steve Fesko, Eaton
Anastasia Hamel, Borg-Warner
Ray Raymond, Borg-Warner
MISSOURI ILLINOIS SOUTH DAKOTA PENNSYLVANIA
FLORIDA NEW JERSEY MINNESOTA TEXAS
MASSACHUSETTS WISCONSIN NEW YORK CONNECTICUT

NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR
INJECTION
Class 51 Wells
In Accordance with the provisions of NCAC Title I SA: 02C.0200
Complete application and mail to address on the back page.
TO: DIRECTOR,NORTH CAROLINA DIVISION OF WATER QUALITY
DATE: October 28 20 02
A. PERMIT APPLICANT
Name: Eaton Corporation
Address: Eaton Center - 1111 Superior Avenue
City: Cleveland State: OH ' Zip Code:44114
County: Cuyahoga Telephone: (216) 523-5000
B. PROPERTY OWNER(if different from applicant)
Name: Borg Warner Cooling Systems, Inc.
Address: Cane Creek Industrial Park
City: Fletcher State: NC Zip Code: 28732
County: Henderson Telephone: (832) 684-3501
C. STATUS OF APPLICANT
Private: % Commercial: Federal: State:
County: Municipal: Native American Lands:_
D. FACIL=(SITE)DATA
(Fill out ONLY if the Status is Federal, State, County,Municipal or Commercial).
Name of Business or Facility:
Address:
City: Zip Code: County:
Telephone: Contact Person:
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; Provided in Attachment E
(2) operation procedures; and ki
(ra pp f�
(3) a planned injection schedule. l� U LS D
OC�S 3 0 2002
OW-57 REM (Jan,2000>
GROUNDWATER SECTION
ASHEVILLE REGIONAL OFFICE
i'A

1
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 NCDENR Incident Number is 21521, See Attachment F for
site description
G. HYDROGEOLOGIC DESCRIPTION Provided in Attachment G
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:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity of the saturated zone;
(4) the depth to the mean seasonal high water table; and
(5) a determination of trarismissivity and specific yield of the aquifer to be used for
injection(showing calculations).
H. MONITORING PROCEDURE Provided in Attachment H
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.
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.
- (1) Well Drilling Contractor's Name: Probe Technology Inc.
NC Contractor Certification number: 2724
_r (2) Date to be constructed: December 2002* Number of borings: 8
Approximate depth of each boring(feet): 20
*Pending NCDENR approval
_ Page 2 of-5 REM (Jan,2000)

4
{ (3) Well casing: None
J Type: Galvanized steel—Black steel—Plastic—Other(specify)
Casing depth: From to ft. (reference to land surface)
Casing extends above ground inches
(4) Grout:
Grout type: Cement— Bentonite X Other(specify)
Grouted surface and grout depth(reference to land surface):
_ —around closed loop piping; from to (feet).
i
around well casing; from to (feet).
(5) Screens None
Depth: From to feet below ground surface.
(6) 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.
Will there be a faucet on the influent line? yes no X
Will there be a faucet on the effluent line? yes ncL X
(7) SOURCE WELL CONSTRUCTION INFORMATION (if different from injection
well). Attach a copy of Form GW-1 (Well Construction Record). If Form GW-1 is not
available, provide the data in part G of this application form to the best of your
knowledge.
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 Provided in Attachment K
Provide a tabulation of data on all wells within I/4 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.
L. PROPOSED OPERATING DATA
(1) Injection rate: Average(daily) NA gallons per minute(gpm)
(2) Injection volume: Average(daily) 43 gallons per day (gpd)
I (3) Injection pressure: Average (daily) NA pounds/square inch(psi)
(4) Injection temperature:Average(January) 45 °F, Average (July) 85 ° F
(5) Hydraulic capacity of the well: NA (Temporary geoprobe boring)
(6) Expected lifetime of the injection facilityless than lyears
(7) Give a description of how the above data will be measured andicontrolled:
-I A predetermined volume of HRC will be mixed in a ,hovner. then numved
into each geoprobe boring.
GW-57 REM (Jan,2000)
! Page 3 of 5

YJ
M. INJECTION-RELATED EOUIPMENT See Attachment M
-� Attach a diagram showing the detailed plans and specifications of the surface and subsurface
construction details of the system.
N. LOCATION OF WELLS) Provided in Attachment N
Attach a scaled, site-specific map(s) showing the location(s) of the following:
(1) the proposed injection well(s);
(2) all property boundaries;
J (3) contour intervals not exceeding two feet;
(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);
(5) all buildings within the property boundary;
(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;
(7) potentiometric surface showing direction of groundwater movement;
(8) the horizontal and vertical extent of the contaminant plume (including
isoconcentration lines and plume cross sections);
(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; and
(10) all surface water bodies within 1000 feet of the injection well or well system.
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.
Depth:
_ Formation:
Rock/sediment unit:
-JI (2) Provide the chemical, physical, biological and radiological characteristics of the fluid
to be,injected. The Material Safety Data Sheets for the HRC compound
are provided in Attachment 0.
P. PERMIT LIST
Attach a list of all permits or construction approvals that are related to the site, including but
J not limited to:
(1) Hazardous Waste Management program permits under RCRA
J (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.
JGW-57 REM.(Jan,2000) Page 4 of 5

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Q. CERTIFICATION
"I hereby certify, ender 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
infoffiation. 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"
Eaton Corporation
(Signature ofWell Owner or Authorized Agent)
I Vice President & Secretary
JIf authorized agent is acting on behalf of the well owner,
please supply a letter signed by the owner
authorizing the above agent.
I
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)
f Property Owner If Di$eren rom Applicant)
f Please return two copies of the completed Application package to:
UIC Program
_ Groundwater Section
North Carolina DFNR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
J GW-57 REM (Jan,2000) Page 5 of 5

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ATTACHMENT E
i INJECTION PROCEDURE
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E. INJECTION PROCEDURE
The proposed injection activities at the BorgWamer Cooling System, Inc. facility
in Fletcher, North Carolina involve the injection of Hydrogen Release Compound
(HRCm) into the subsurface utilizing Geoprobe® direct-push methods. HRC is a
proprietary product developed and distributed by Regenesis, Inc., of San Clemente,
California. The purpose of the proposed injection is to evaluate the efficacy of using
HRC for the in-situ treatment of contaminated ground water at the site.
1) Construction Plans and Materials
A total of eight Geoprobe borings will be drilled in a 40 x 10 foot test treatment
area for the purpose of injecting HRC. The borings will be drilled at ten foot spacings in
two rows with four borings in each row. The borings will be installed within the
shallow ground-water zone at depths between 15 to 20 feet below grade. After reaching
the target depth, HRC will be injected directly through the Geoprobe rods into the
formation. Following injection, the Geoprobe rods will be pulled and the boring sealed
with bentonite grout. Consequently, no permanent/temporary injection wells will be
constructed.
HRC is a proprietary, food-grade polylactate ester specially formulated for slow
release of lactic acid upon hydration. The compound is a high viscosity, flowable liquid
with the consistency-of viscous honey. Upon injection, HRC slowly dissolves and
degrades to lactic acid, which in turn is metabolized by indigenous anaerobic microbes to
produce hydrogen. The hydrogen is then used by reductive dechlorinating microbes to
degrade chlorinated solvents and their derivatives.
2) Operation Procedures
The Geoprobe rod assembly will be pushed to the desired depth and the
predetermined volume of HRC compound will be pressure injected through the rods into
the subsurface. Prior to injection, the HRC will be pre-heated, poured into a pump
hopper and mixed to a uniform consistency. During injection, the Geoprobe rods will be
slowly withdrawn to deliver the HRC across the treatment interval. HRC will be applied
to the boring at a rate of five (5) pounds per vertical foot of saturation. Following the
HRC injection, the Geoprobe rods will be pulled, and the boring filled with bentonite to
secure the HRC in place and to prevent contaminant migration from the surface.
3) Planned Injection Schedule
For the purposes of this pilot test, the schedule consists of a single HRC injection
into each borehole. It is anticipated that the drillinglinjection process will take one to two
days to complete.

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ATTACHMENT F
i SITE DESCRIPTION

F DESCRIPTION OF SITE
In the course of multiple assessment investigations at the Facility, impact to ground-
water (levels above State standards) was detected. The NCDENR incident number is
21521. The detailed results from the site investigations are documented in the July 2001
Comprehensive Site Assessment (CSA) Report and the August 2002 Addendum to the
J CSA. The type, source and amount of ground-water impact are summarized below.
❑ Tvpe of Contaminants: The type .of impact consists of chlorinated volatile
organic compounds. Trichloroethylene, tetrachloroethylene, cis-1,2-
dichloroethene and vinyl chloride have been reported above State standards in
ground-water samples from the site.
❑ Source of the Release: After significant investigation, Eaton has been unable to
determine the historic source of ground-water impact. Chlorinated solvents are no
longer used or present at the Facility. The impact is not related to leaks from
above or below ground storage tanks, surface spills, or pipelines, etc. The impact
may be related to unknown historic activities at the site when the site was part of
the former airport. Historical aerial photographs, during the time of former
airport operations, show an area of surface disturbance in the current position of
the Facility building. The area of historical surface disturbance coincides with the
area where ground-water impact was identified.
❑ Amount of Release: Because the exact source of the ground-water impact is not
known, the amount (volume) of VOCs in the ground water cannot be quantified.
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ATTACHMENT G
HYDROGEOLOGIC DESCRIPTION

G EIYDROGEOLOGIC DESCRIPTION
1) Regional Geologic Setting
Information regarding the geologic and hydrogeologic setting for the area in and
around the Facility is based on the Geologic Map and Mineral Resources Summary of the
Fruitland Quadrangle, North Carolina (L.emmon and Dunn, 1973) and the Mineral
Resources Summary of the Fruitland Quadrangle North Carolina (L.emmon, 1973). The
regional geology consists of four general stratigraphic units: unconsolidated alluvium,
residuum and saprolite-and consolidated metamorphic bedrock. The alluvium consists of
clay, silt, sand, and gravel deposited by streams and rivers. The unit, where found, is
generally present at ground surface and ranges in thickness from a few feet to greater
than 50 feet. Where the alluvium is absent, residuum is usually encountered at ground
surface. Residuum is soil that has undergone,sufficient weathering to destroy all relict
rock structure. This unit varies from thin (less than 10 feet) upwards to 30 feet in
thickness. Typically, the residuum grades into saprolite at depth. Saprolite is thoroughly
decomposed bedrock that retains relict rock structure. Thickness of this unit is highly
variable, from thin (less than 10 feet) up to 100 feet across the region. The region is
within the northeast-trending Brevard fault zone, a narrow belt of steeply dipping low-
grade metamorphic rocks. The rocks within the fault zone are generally Cambrian Age
porphyroclastic mylonite and cataclastic schist (Lemmon and Dunn, 1973).
2) Significant Changes in Lithology
The lithologic descriptions of the subsurface soils and geology at the Facility are
based on drilling results of the Geoprobe borings and monitoring wells. Generally, the
site geology consists of unconsolidated fill, soil and alluvium, underlain by saprolite and
fractured metamorphic rock. The units encountered at the Facility in order of increasing
depth are:
o Unconsolidated fill and soil
o Alluvium
o Saprolite
o Bedrock
The relationship of these units is depicted on the geologic cross-sections on Figures G-1
and G-2. Cross-Section A—A' (Figure G-1) is oriented east-west along the southern
boundary of the Facility and Cross-Section B—B' (Figure G-2) is oriented north-south
along the eastern boundary of the Facility.
I

The unconsolidated fill/soil consists of clay and silt with interbedded sand seams.The material ranges in thickness from 3 to 17 feet and appears to thin to the east-
northeast at wells MW-3 and MW-4 to thicken to the southwest at wells NM-6D and
MW-10.
Below the surficial soil is the alluvium, a variable unit ranging from silty clay to
sand and gravel. The total thickness of the alluvium ranges from 0 to 15 feet except in
the southwestern corner of the Facility at well MW-6D, where the thickness is almost 40
feet. The alluvium consists of interlayered silt, clay and sand except in the area near
where the surface ditch-flows under Mills Gap Road. In this area (wells MW-8 and MW-
9, as shown on Drawing G-1), the alluvium is primarily coarser-grained sand and gravel.
At well MW-6D, the upper 10 feet is coarser-grained sand and gravel and the lower 30
feet is fine-grained silt and clay.
Below the alluvium is the saprolite unit, a clay, silt and sand that demonstrates
relict bedrock texture. This unit, which occurs at depths from 5 to 50 feet, ranges in
thickness from 14 to 20 feet, with the thickest area near well MW-5D (20 feet).
The bedrock beneath the facility is highly fractured metamorphic rock, ranging
from schist at MW-3D, MW-5D, and MW-7D to quartzite and slate at MW-6D. The top
of the competent(unweathered) bedrock occurs at depths of 20 to 60 feet below grade.
3) Hydraulic Conductivity
Representative hydraulic conductivities for the shallow ground-water zone were
determined based on values reported in the September 1994 CSA Report for the
_ Wilsonart facility. The shallow ground-water zone evaluated at the Wilsonart facility is
stratigraphically equivalent to the proposed injection zone at the BorgWamer facility.
Based on slug tests, the hydraulic conductivity of the alluvium/saprolite ranged from 0.17
to 2.83 feet per day (ft/day), with an average of 1.16 ft/day.
4) Depth to Mean Seasonal High Water Table
Based on the available water level data for the shallow ground-water zone, the
depth to the seasonal high water table varies from 14.5 to 3.7 feet below grade across the
site. In the proposed area of the injection well pilot test, the depth to the seasonal high
water table is approximately 8.5 feet. Historical water-level data for the site is provided in Table G-1.
5) Aquifer Transmissivity and Specific Yield
The transmissivity of the shallow ground-water zone in the area of the proposed
injection site was calculated based on the reported hydraulic conductivities from the 1994
Wilsonart pumping test and the estimated saturated aquifer thickness. Based on a depth

to water of 8.5 feet and total depth of 20 feet, the saturated thickness of the shallow
ground-water zone is approximately 11.5 feet. Assuming hydraulic conductivities
between 0.17 and 2.83 ft/day, the calculated transmissivity of the shallow ground-water
zone is between 2 and 33 ft2/day. The best available specific yield estimates for the
shallow ground-water zone are those reported for the 1994 Wilsonart pumping test and
range between 0.001 and 0.007 (Rust, 1994).
North Carolina Licensed Geologist
2
J Frank J. tchell
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References
Lemmon, Robert E., 1973, Mineral Resources Summary of the Fruitland Quadrangle,
- North Carolina, North Carolina Department of Natural and Economic Resources,
Office of Earth Resources Report MRS 202-NW.
Lemmon, Robert E. and David E. Dunn, 1973, Geologic Map of the Fruitland
Quadrangle, North Carolina, North Carolina Department of Natural and
I' Economic Resources, Office of Earth Resources Map GM 202-NW.
RUST Environment&Infrastructure, September 1994, Comprehensive Site Assessment/
j Corrective Action Plan, prepared for Ralph Wilson Plastics Company, Fletcher,
North Carolina.
1
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(10) 207939
2080
2075
2070
2065
2060
2055
2050
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2040
2035
2030
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2015
(10D)
2010
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A'
EAST
MW-7D LEGEND
MW-9 MW1-8 ® CLAY
SILT
y ® SILT/CLAY
IIL 2084.057 SAND
ALLUVIUM
SAPROLRE
27 2079,76
CRYSTALLINE BEDROCK
SLATE
SCREENED
INTERVAL
y POTENTIOMETRIC SURFACE BEDROCK
S WATER TABLE
/ 7 POTENTIOMETRIC SURFACE INTERFACE
SAPROLITE
GROUND WATER LEVEL ELEVATION
MEASUREMENTS TAKEN 6/6/01
v
Y
BEDROCK - -
FORMER EATON CORPORATION
BORGWARNER COOLING SYSTEMS, INC.
FLETCHER, NORTH CAROLINA PLANT
DATE:70BM 2002 APPROVED BY: DWN BY:KMAC
SCALE: AS SHOWN its CHKD. BY:D1
VERTICAL 1" = 10' SHEET 1 OFT
HORIZONTAL: 1' = 100' o GEOLOGIC CROSS SECTION DRAWING NUMBER
A-A' FIGURE G-1

B
NORTH
MW-3/3D MW-4 MW-5/5D
3000 l
1
2095
2090 �0�3E3,( - •
2085 ALLUVIUM
(3) = `<
r:
(5)
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2075
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2065 [7SAPR
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w 2055 (5D)
w
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a
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2035

LEGEND
B'
SOUTH ® CLAY
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41 SAND
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-
CRYSTALLINE BEDROCK
® SLATE
/ SCREENED
INTERVAL
q POTENTIOMETRIC SURFACE BEDROCK
WATER TABLE
ALLUVIUM/SAPROLITE
GROUND WATER LEVEL ELEVATION
N MEASUREMENTS TAKEN 6/8/01
O
VERTICAL: 1" = 10'
HORIZONTAL: 1" 100'
cr :, / FORMER EATON CORPORATION
= BORGWARNER COOLING SYSTEMS, INC.
A '� / FLETCHER, NORTH CAROLINA PLANT
-- B
DATE:OCTW 2002 APPROVED BY: DM BY:KMAC
r r SCALE: AS sgw11 iTs CHKD. BY:oH
SHEET 1 OF1
GEOLOGIC CROSS SECTION DRAWING NUMBER
RGURE G-2

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r. ATTACHMENT H
MONITORING PROCEDURE
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` H MONITORING PROCEDURE
Three monitoring wells, one upgradient, one inside the treatment area and one
downgradient of the injection site, will be installed in the shallow ground-water zone for
purposes of monitoring ground-water quality prior to and following HRC injection. The
proposed monitoring well locations are shown in Figure N-1 (Attachment N).
Monitoring wells will be drilled using 4 1/4 inch ID hollow stem augers (HSA) 'by
advancing the augers to the completion depth and constructing the well within the augers.
Monitoring wells will be completed using 2-inch ID schedule-40 PVC casing and 0.010-
inch slot PVC screen.- A washed silica sand filter pack will be placed in the annulus
around the screen to a depth of approximately 2 feet above the top of the screen. The filter
pack will secured with a 2-foot bentonite pellet seal and the remaining annular space will
backfilled with bentonite slurry to within approximately 3 feet below the ground surface.
Each monitoring well will be completed with a locking, steel protective casing set in a
sloping concrete pad. Following construction, the monitoring wells will be developed by
surging and pumping with a submersible pump. Each well will be developed until
approximately 10 well volumes were removed, the discharge water appeared clear, or the
well had been completely evacuated four times.
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Following development and prior to HRC injection, ground-water samples from
the new monitoring wells will be submitted for analysis of VOCs and the following
biodegradation indicator parameters:
- o Inorganic parameters consisting of dissolved iron and manganese, sulfide,
nitrate, sulfate, chloride, alkalinity, and total organic carbon.
o Metabolic acids consisting of lactic, pyruvic, acetic, propionic, and butyric.
1 o Dissolved gases consisting of carbon dioxide, methane, ethane, and ethene.
' o Field parameters including dissolved oxygen, oxygen reduction potential, pH,
— temperature, and ferrous iron.
The resultant data will be used to establish pre-treatmentfbaseline conditions. Following
HRC injection, the new monitoring wells will be sampled every two months for a period
of six months for VOCs and the listed biodegradation indicator parameters. The resultant
data will be used to evaluate the efficacy of the HRC injection for'reducing VOC
concentrations. After the initial six months, the sampling program will be reevaluated to
assess the need for continued monitoring.
Ground-water samples will be collected using minimal drawdown sampling
procedures. In this approach, the wells will be purged with a peristaltic pump at a rate
that produces no net drawdown of the water-level surface within the well. The water
temperature, pH, specific conductance, dissolved oxygen, and oxidation reduction
potential will be monitored continuously throughout the purging process via a constant
reading flow-through cell. The ground-water 'samples will be collected following
stabilization of the field parameters. Ground-water samples will be placed into approved
J

containers provided by the laboratory. Sample preservatives will be added to the sample
bottles prior to or immediately following sample collection. Following collection, the
sample bottles will be labeled and placed in a cooler with ice for delivery to Prism
Laboratories for analysis of VOCs and biodegradation indicator parameters.
On October 1, 2001, shallow zone monitoring wells MW-1, MW-2, MW-3, MW-
4, MW-5, MW-8, and MW-9 were sampled for VOCs and to characterize the
concentrations of the biodegradation indicator parameters listed above.' The laboratory
analytical results for the biodegradation indicator parameters in ground water from the
shallow zone monitoring wells are summarized in Table H-1. In general:.
❑ Dissolved iron and sulfide were not detected in any of the shallow ground-
water samples.
❑ Dissolved manganese concentrations ranged from non-detect (MW-1) to 0.25
mg/L (MW-2).
- ❑ Nitrate concentrations ranged from non-detect (MW-2, MW-4, and MW-9) to
0.26 mg/L(MW-1).
❑ . Sulfate concentrations ranged from non-detect (NW-2 and MW-5) to 4.5
mg/L.(MW-1).
❑ Chloride concentrations ranged from 1.1 (MW-5) to 8.7 mg/L (MW-9).
❑ Alkalinity concentrations ranged from 11 (MW-2) to 52 mg/L (MW-1).
❑ Total Organic Carbon was only detected in the ground-water sample from
MW-4 at a concentration of 4.7 mg/L.
Metabolic acids were not detected in any of the shallow ground-water samples and
the dissolved gas analytical results are listed below.
❑ Carbon Dioxide concentrations ranged from 79,000 (MW-5) to 140,000 µg/L
(MW-4).
❑ Methane concentrations ranged from 0.31 (MW-1) to 1,900 µg/1 (MW-4).
❑ Ethane concentrations ranged from 0.0076 (MW-1 and MW-3) to 0.052 µg/L
(MW-5).
❑ Ethene concentrations ranged from 0.026 (MW-4) to 0.14 µg/l (MW-5).
The laboratory analytical results for the biodegradation indicator parameters were
submitted along with the VOC data to Regenesis (San Juan Capistrano, California) to
evaluate the natural attenuation potential within the shallow ground-water zone. Based
on the available data, Regenesis concluded that the following conditions indicate that
natural attenuation is on-going at the Fletcher facility:
1

o Presence of dissolved manganese—indicates reducing conditions
o Low sulfate—indicates sulfate lowered by sulfate reducers
o Sulfides not detected—indicates reducing conditions
o Elevated carbon dioxide—indicates biologic activity in aquifer
o Presence of methane—indicates reducing conditions
o Presence of ethane—indicates naturally occurring reductive dechlorination
o Low to no TOC—low TOC associated with reductive dechlorination
o Low to no nitrate
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Based on these results, it is concluded that conditions in the shallow ground-water zone
are favorable for enhanced/accelerated natural attenuation (biodegradation).
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TABLE H-1
NATURAL ATTENUATION PARAMETERS
Former Eaton Facility,Fletcher,North Carolina
Detection
{ Limit MW-1 MW-2 MW-3 MW-4 MW-5 MW-8 MW-9
Field Parameters
Dissolved Oxygen (g/L) 0.87 4.41 5.54 0 1.31 n/a n/a
ORP n/a n/a n/a n/a n/a n/a n/a
pH 6.08 5.10 5.45 5.31 5.66 5.59 5.16
temperature (C) 18.0 14.3 19.0 18.9 15.4 17.9 17.2
ferrous iron (mg/L) 0 0 0 0.2 0 0 0.2
Inorganic Parameters(mg/L)
dissolved iron 0.5 ND ND ND ND ND NO ND
dissolved manganese 0.01 ND 0.25 0.017 1.6 0.034 0.049 0.018
sulfide 0.5 ND ND ND ND ND ND ND
nitrate 0.1 0.26 ND 0.12 ND 0.16 0.11 ND
sulfate 1 4.5 ND 3.1 2.8 ND 3.6 2.0
chloride 1 2.4 1.3 1.7 6.1 1.1 4.1 8.7
alkalinity 5 52 11 15 19 28 33 48
TOC 1 ND ND ND 4.7 ND ND ND
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Metabolic Acids(mg/L)
lactic acid 25 ND ND ND ND ND ND ND
pyruvic acid 10 ND ND ND ND ND ND ND
acetic acid 1 ND ND ND ND ND ND ND
propjonic acid 1 ND ND ND ND ND NO ND
butyric acid 1 ND ND ND ND ND ND ND
Dissolved Gases(ug/L)
_1
carbon dioxide 600 110,000 81,000 100,000 140,000 79,000 120,000 110,000
methane 0.02 0.31 1.8 0.35 1,900 0.59 0.73 0.78
ethane 0.01 0.0076 0.013 0.0076 0.0077 0.052 0.026 0.011
ethene 0.01 0.033 0.039 0.13 0.026 0.14 0.074 0.031
n/a field instrument malfunctioned
ND parameter concentration below the method detection limit
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Leggette,Brashears&Graham,Inc. October 2002
Columbus,Ohio t of 1 Injection Well Permit Application

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ATTACHMENT K
I OTHER WELL DATA
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K OTHER WELL DATA
The available information on all wells within 114 mile of the proposed injection
well site that penetrate the shallow ground-water zone (excepting water supply wells
serving single-family residences) is provided in Table K-1. A total of 29 wells were
identified:
❑ Seven monitoring wells and one site production well are reported at the Wilsonart
facility;
❑ Four monitoring wells are reported at the Steelcase facility;
❑ Fifteen monitoring wells are at the BorgWarner facility(former Eaton); and
❑ One monitoring well is reported at the ABF facility.
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TABLE K-1
WATER WELL SEARCH
Former Eaton Facility-Fletcher,North Carolina
Number Well Casing Screened
Current Owner/User Name of Total Depth Depth(feet Interval
Address Wells Well Type I (feet bgs) bgs) (feet bgs) . Comments
1 BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 17 7 7-17 MW-1
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 17 7 7-17 MW-2
_ BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 16 6 6-16 MW-3
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 55 45 45-55 MW3D
-' BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 14 4 4-.14 MW-4
( BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 16 6 6-16 MW-5
BorgWamer Cooling Systems,
J Inc. Cane Creek Industrial
Park 1 Monitoring 26 21 21-26 MW-51
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 42 32 32-42 MW-5D
_ BorgWamer Cooling Systems,
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Inc. Cane Creek Industrial
Park 1 Monitoring 75 65 65-75 MW613
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 35 25 25-35 MW-7D
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
-� Park 1 Monitoring 14 9 9.14 MW-8
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 19 9 9-19 MW-9
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 15 5 1 5-15 MW-10
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 65 60 60-65 MW-101
BorgWamer Cooling Systems,
Inc. Cane Creek Industrial
Park 1 Monitoring 85 75 75-85 MW-10D
BKT Enterprises 1 Monitoring 20 5 15 ABF Transportation
Ralph Wilson Plastics Co. Industrial
1469 Cane Creek 1 Supply 401 41 NA RW P Production well
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring 23 13 13-23
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Leggette,Brashears&Graham,Inc. October 2002
Columbus,Ohio 1 of 2 Injection Well Permit Application

TABLE K-1
WATER WELL SEARCH
Former Eaton Facility-Fletcher,North Carolina
Number Well Casing Screened
-- Current Owner/User Name of Total Depth Depth(feet Interval
Address Wells Well Type (feet bgs) bgs) (feet bgs) Comments
J� Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring 29 19 19-29
Ralph Wilson Plastics Co. ,
1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co.
_ 1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co.
1469 Cane Creek 1 Monitoring unk
Ralph Wilson Plastics Co.
-- 1469 Cane Creek 1 Monitoring unk
_ Steelcase,Inc
! Hoopers Creek Rd.
i 04-684-2241 1 1 Monitoring unk (1)
Steelcase,Inc
Hoopers Creek Rd.
{ 04-684-2241 1 Monitoring unk (1)
Steelcase,Inc
Hoopers Creek Rd.
04-684-2241 2 Monitoring unk (1)
t
I
i
Leggette,Brashears&Graham,Inc. October 2002
iColumbus,Ohio 2 of 2 Injection Well Permit Application

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ATTACHMENT M
INJECTION-RELATED EQUIPMENT
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VI
J .
J
i

M INJECTION-RELATED EQUIPMENT
The HRC will be pressure injected into the target formation through Geoprobe®
drilling rods. Prior to injection, the HRC will be pre-heated, poured into a pump hopper
i
and mixed to a uniform consistency. Following injection, the Geoprobe® rods will be
pulled and the boring will be sealed with bentonite. Because there will be no permanent
injection wells or injection equipment at the facility, equipment plans or specifications
_J will not be prepared.
G
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-r
J

ATTACHMENT N
LOCATION OF WELL(S)

6
G f�
a w 1997
J � 1994
¢ II 1994 1987
a
E PLOYEE
ARKING a
a� ORIGINAL AE
BUILDING
a 1976
i a
M � 0 00 a rn as
OFFICES a
1978
a PROPOSE
a a INJECTIO
RKING
a
MW,6aMW'�
MW�S
RM - - --
RIV
MW-g MW
sa wv

REN9DN RECORD
DATE IDE541tIPaDN
REV, REVI.�ESC
REYt REVLDESC
RE`/3 Hf/3_DFSf.
REVI PEV�..DFSC
uvs RFvs_oEsc
`w,3o LEGEND
STORM SEWER
— BURIED ELECTRIC
—E— BURIED GAS
\ —n— FIRE PROTECTION
WATER
ADDITION \ BURIED SANITARY
1997 PROPERTY BOUNDARY
+ SECURITY LIGHT
m FIRE HYDRANT
MONITORING WELL
1994 I I PROPOSED MONITORING WELL
_ V • INJECTION WELL
a
V
a
�0*'A
T� a
C MN�2
E .
4,5D
vog
FORMER, EATON CORPORATION
COOLING
BORGWARNER COOLING SYSTEMS, INC.
FLETCHER, NORTH CAROLINA PLANT
gDATE:OCTOBER 2002 APPROVED BY: DWN BY:KNAc
SCALE: AS SHOWN ars CHKD. BY:DH
m SHEET 1 OF1
0 SITE PLAN DRAWING NUMBER
FIGURE N-1

1111011111
F I
drA
Brashears Grohom,
GAHANNA. CHO
FORMER EATON CORPORATION
BORGWARNER COOLING SYSTEMS, INC.
SITE LOCATION MAP
FLETCHER., NORTH CAROLINA

N
a4
--i
6`
_ `u
II. 1997
1994
a"
¢ ¢ I 1994 1987
¢ ¢ a
EMPLOYEE
PARKING I toe
s
a� IGINAL XADS
B DING
1
a
a
m
Qo I OFFICES a
1978
a a
VISITOR
PARKING
a
Mw� �
2��9 62
_
6AP ROAD
�1
Mo 9 56 m wv M o$o o

REVISION RECORD
DALE I DESCdSR1
REV1 i
Eli
REV2 RlV1_OESC
REY.I REV]_DESC
REV{ RF/{_pE%
REVS I REVS_DESC
ADDITION \
1997
LEGEND
�090 —R-T ip MONITORING WELL
TEM
1994 I ♦ FOR REAM ELEVATION
BENCH
O MARK,OR
MEASUREMENT
—�— BURIED ELECTRIC
—E— BURIED GAS
—�— FIRE PROTECTION
—•— WATER
' — — SANITARY
�Mw A MONITORING WELL & STREAM
ELEVATIONS MEASURED 9/21/00
J —2090— EQUIPOTENTIAL CONTOUR
GROUND WATER FLOW DIRECTION
GRADIENT: A-A'r-- 2090 -680 2080 a 0.015
vb 99
�N
15 32 i
a�
FORMER EATON CORPORATION
COOLING
BORGWARNER COOLING SYSTEMS, INC.
' FLETCHER, NORTH CAROLINA PLANT
DATE:OCTORER 2002 APPROVED BY: DYNJ BY:KEWC
§� SCALE: AS SHOWN JTS CHKO. BY:DN
SHALLOW ZONE SHEET 1 OFI
POTENTIOMEMIC SURFACE MAP DRANANG NUMBER
(1/22/02) FIGURE N-3

2ge Kg 22 B 21
ram`
r
r`
• I r
GP,260
i i i � � y •
•K8,10 KB 'I
' 1997
1994 9
a^
¢ 1994 1987 •
EMPLOYEE I^ KgN`, K8�2 �KB13
PARKING a
Kg • a^ ORIGINAL I
ry—n—pn—n�- BUILDING ADD
—,—a—{-.� 19
1976
a
K1 �
K 2 a
I , ,
• � � °a\ s G3 � � � i a wP 4n d
Gpd� p0 od ® \ OFFICES Gp!�y19 i Gp�2 a®
\1978Y.
(4 pCS o
10• p , i P�15
a ,2A GP50 P-
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J N° VISITOR I n G
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5q$ 1�
7 50°
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Wa-
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o Gp�1° P�27-9 Gp ,' GP�N° Gp2 Gp 5� GI?g(
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G9

REASON RECORD
DATEOESCICPllp1
REVt REVt_DESC
REY] WEVZOESC
IffVJ ,RVJ_DESC
REVS REVI_DESC
REVS REYS_DESC
ADDITION
1997 \ LEGEND
. OCTOBER 1999 GEOPROBE
BORING, BY KERAMIDA
"'-1 •p APRIL 2000, CEC GEOPROBE
y�g i�3 SAMPLE POINT
Nn a
MONITORING WELL
1994
2D I � TEMPORARY BENCH MARK,
FOR STREAM ELEVATION
I MEASUREMENT
BURIED ELECTRIC
d O I•Y15
S� D5 a BURIED GAS
FIRE PROTECTION
BURIED SANITARY
BURIED WATER
• a
5® p2 1 TOTAL VOC CONCENTRATION (ug/1)
OF 0 E NO
/ OO Gp�23 VS
,5D
FORMER EATON CORPORATION
BORGWARNER COOLING SYSTEMS, INC.
FLETCHER, NORTH CAROLINA PLANT
Nx DATE:OCTOBER 2002 APPROVED BY: DWN BY:KWC
-ID SCALE: AS SHOWN ,RS CHKD. BY:DH
5 SHALLOW ZONE SHEET 1 OF 1
TOTAL VOCa ISOCONCENTRATION DRAWING NUMBER
MAP ("9/1) FIGURE N-4

i
-I
ATTACHMENT O
. INJECTION FLUID DATA
_l

HRC MSDS Page 1 of 6
FOR
w
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REGENESIS
MATERIAL SAFETY DATA SHEET
Mom' Last Revised: March 1, 2001
Section 1 -Material Identification
' beiifJncmramnnRp.ie'�ri- .
f— Supplier. Regenesis Bioremediation Products
1011 Calle Sombra
_ = San Clemente, CA 92673
Telephone: [phone]
m ��9 Facsimile: [phone]
Chemical Name: Propanoic acid, 2-[2-[2-(2-hydroxy-l-oxopropoxy)-l-oxopropoxy]
-1-oxopropoxy]-1,2,3-propanetdyi ester
Chemical Family: Organic Chemical
Trade Name: Glycerol tripolylactate
I
Product Name: Hydrogen Release Compound® (HRC®)
Section 2 -Hazardous Ingredients
I
CAS #: 201167-72-8
One should anticipate the potential for eye irritation and skin irritation with large
scale exposure or in sensitive individuals.
l
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Section 3 -Physical Data
http://www.regenesis.conifBRC/hrcrosds:htm 8/22/2002

HRC MSDS Page 2 of 6
Melting Point: NA
Boiling Point: ND
Flash Point: ND
Density: 1.347
Solubility: Acetone and DMSO
Appearance: Amber semi-solid
Odor.Not detectable
Vapor Pressure:None
_I
Section 4-Fire and Explosion Hazard Data
Extinguishing Media: Carbon Dioxide, Dry Chemical Powder or Appropriate Foam.
Water may be used to keep exposed containers cool.
- For large quantities involved in a fire, one should wear full protective clothing and a
NIOSH approved self contained breathing apparatus with full face piece operated in
the pressure demand or positive pressure mode as for a situation where lack of
oxygen and excess heat are present.
i
1
Section 5 -Toxicological Information
Acute Effects: May be harmful by inhalation, ingestion, or skin absorption.
May cause irritation. To the best of our knowledge, the chemical,physical, and
toxicological properties of the glycerol tripolylactate have not been investigated.
Listed below are the toxicological information for glycerol and lactic acid.
RTECS#: NIA8050000
http://www.regenesis.com/HRC/hrcrosds.htm 8/22/2002

HRC MSDS Page 3 of 6
Glycerol
Irritation data: SKN-RBT 500 MG/24H MLD 85JCAE-,207,1986
EYE-RBT 126 MG MLD BIOFX* 9-4/1970
EYE-RBT 500 MG/24H MLD 85JCAE-,207,1986
Toxicity data: ORL-MUS LD50:4090 MG/KG FRZKAP (6),56,1977
SCU-RBT-LD50:100 MG/KG NMZDN 6,215,1982
ORL-RAT LD50:12600 MG/KG FEPRA7 4,142,1945
1EM-RAT LC50: >570 MG/M3/1H BIOFX* 9-4/1970
IPR-RAT LD50: 4420 MG/KG RCOCB8 56,125,1987
IVN-RAT LD50:5566 MG/KG ARZNAD 26,1581,1976
IPR-MUS LD50: 8700 MG/KG ARZNAD 26,1579,1978
SCU-MUS LD50:91 MG/KG N=N 6,215,1982
IVN-MUS I-D50: 4250 MG/KG JAPMA8 39,583,1950
ORL-RBT LD50: 27 GM/KG DMDJAP 31,276,1959
SKN-RBT LD50:>10GM/KG BIOFX* 9-4/1970
IVN-RBT LD50: 53 GM/KG NIIRDN 6,215,1982
I
ORL-GPG LD50: 7750 MG/KG=AB 23,259,1941
Target Organ data: Behavioral (headache), gastrointestinal (nausea or vomiting),
Paternal effects (spermatogenesis, testes, epididymis, sperm duct), effects of fertility
(male fertility index,post-implantation mortality).
RTECS#: OD2800000
Lactic acid
Irritation data: SKN-RBT 5MG/24H SEV 85JCAE-,656,86
EYE-RBT 750 UG SEV AJOPAA 29,1363,46
Toxicity data: ORL-RAT LD50:3543 MG/KG FMCHA2-,C252,91
SKN-RBT LD50:>2 GM/KG FMCHA2-,C252,91
http://www.regenesis.com/ERC/hrcrosds.htin 8/22/2002

HRC MSDS Page 4 of 6
ORL-MUS LD50: 4875 MG/KG FAONAU 40,144,67 .
ORL-GPG LD50: 1810 MG/KG=AB 23,259,41
ORL-QAL LD50: >2250 MG/KG FMCHA2-,C252,91
Only selected registry of toxic effects of chemical substances.(RTECS) data is
presented here. See actual entry in RTECS for complete information on lactic acid
and glycerol.
Section 6 -Health Hazard Data
Handling: Avoid continued contact with skin.
Avoid contact with eyes.
In any case of any exposure which elicits a response, a physician should be consulted
immediately.
I
First Aid Procedures:
Inhalation: Remove to fresh air. If not breathing give artificial respiration. In case of
labored breathing give oxygen. Call a physician.
Ingestion: No effects expected. Do not give anything to an unconscious person. Call
physician immediately.
J
Skin Contact: Flush with plenty of water. Contaminated clothing may be washed or
dry cleaned normally.
Eye contact: Wash eyes with plenty of water for at least 15 minutes lifting both uppej
and lower lids. Call a physician.
Section 7 -Reactivity Data
http://www.regenesis.conVBRC/hrcrosds.htm 8/22/2002

y1L\l.lY1VLJ L 4dV J V1 v
<• s
Conditions to Avoid: Strong oxidizing agents, bases and acids
Hazardous Polymerization: None known
Further Information: Hydrolyses in water to form Lactic Acid and Glycerol.
Section 8 - Spill, Leak or Accident Procedures
After Spillage or Leakage: Neutralization is not required. This combustible material
may be burned in a chemical incinerator equipped with an afterburner and scrubber.
J
Disposal: Laws and regulations for disposal vary widely by locality. Observe all
applicable regulations and laws. This material, may be disposed of in solid waste.
Material is readily degradable and hydrolyses in several hours.
No requirement for a reportable quantity (CERCLA) of a spill is known.
Section 9 - Special Protection or Handling
Should be stored in plastic lined steel, plastic, glass, aluminum, stainless steel, or
reinforced fiberglass containers.
Protective Gloves: Vinyl or Rubber
Eyes: Splash Goggles or Full Face Shield
Area should have approved means of washing
eyes.
Ventilation: General exhaust.
Storage: Store in cool, dry, ventilated area.
Protect from imcompatible materials.
http://www.regenesis.com/HPC/hrcrosds.htm 8/22/2002

HRC MSDS Page 6 of 6
Section 10- Other Information ;
This material will degrade in the environment by hydrolysis to lactic acid and
- glycerol.
Materials containing reactive chemicals should be used only by personnel with
-J appropriate chemical training.
The information contained in this document is the best available to the supplier as of
— the time of writing. Some possible hazards have been determined by analogy to
similar classes of material.No separate tests have been performed on the toxicity of
this material. The items in this document are subject to change and clarification as
more information becomes available.
Hninc][UP
Copyright©Regenesis Bioremediation Products. I996-2002.All Rights Reserved
I
®Registered Trademark ofRegenests Bioremediation Products, Inc.
J�
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http://www.regenesis.com/BRC/hmmsds.htm 8/22/2002