WI0100091_Complete File - Historical_20220311

Moore, Andrew W
From: Moore,Andrew W
Sent: Wednesday, February 07,2018 9:53 AM
To: Shrestha, Shristi R
Cc: Davidson, Landon ([e-mail])
Subject: WI0100091 and WI0100126
Attachments: SF_F_NCD003166675_02-24-2015_SERB_CONTR.pdf, SF_F_NCD003166675_08-14-2013
_SERB_CONTR (2).pdf
Shristi,
I've had a chance to review BIMS,ARO's file,and DWM's online files related to the subject injection permits. Here is
what Ifound.
W10100091
Injection-related activities are summarized in the 7/28/2011 FINAL Redevelopment Areas Remedial Action Plan issued to
DWM,which I found in DWM's laserfiche files. I attempted to attach to this email, but it's too large.A review of ARO's
files indicates we did not receive a notification of initiation of injections, any monitoring data, or a final project '
evaluation for this permit.According the noted report, injection of ORC-Advanced occurred November 2010. A review of
BIMS indicates no injection event record was submitted. It's not clear whether the approved monitoring was conducted.
During the application review process, CO issued a request for additional information on 7/2/2010,which included a
request to install an additional downgradient monitoring well,the addition of arsenic to the monitoring plan; and
clarification on the frequency and duration of monitoring.The ARO does not have a copy of the response,which was
apparently received 7/23/2010 by CO.The response regarding monitoring was incorporated into the permit.A review of
the 8/14/2013 Quarterly Long-Term Monitoring Reports (attached), issued to DWM, indicates monitoring was
conducted in the injection vicinity in accordance with the original application.There is no indication that an additional
downgradient monitoring well was installed.Arsenic was analyzed in the baseline sample, but not in any of the post-
injection sampling.A review of the 8/14/2013 monitoring report indicates there were no analyzed constituents detected
>2L downgradient of the injection area (MW-37)following injections. Benzene and napathalene were detected>2L
following injections within the injection zone (MW-36), but were below pre-injection levels during the 6/2013
monitoring. Monitoring has continued in MW-36 through 2/2015,which is the last available monitoring report in
laserfiche (report attached). Benzene and naphthalene were still below pre-injection levels at that time.
WI0100126
Injection-related activities are summarized in the 7/28/2011 FINAL Redevelopment Areas Remedial Action Plan issued to
DWM.A review of ARO's files indicates we did not receive a notification of initiation of injections,any monitoring data,
or a final project evaluation for this permit.According to the noted report, injection of ABC occurred 3/2011.A review of
BIMS indicates no injection event record was submitted. Monitoring appears to have been conducted as proposed in the
application, including the construction of additional monitoring well MW-67. Constituents were all <2L as of 5/2012
monitoring. Monitoring data is summarized in the 8/14/2013 Quarterly Long-Term Monitoring Reports.
Feel free to contact me if you have any questions.
Andrew W. Moore, P.G.
Environmental Specialist—Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ— Division of Water Resources
1

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
August 31, 2010
John B. Henselman
Davidson River Village,LLC
36 Washington St., Suite 220
Wellesley,MA 02481
Ref: Issuance of Injection Permit WI0100091
Davidson River Village, LLC
Dear Mr. Bumb:
In accordance with the application received on April 26, 2010, and additional information received July 23, 2010, we are
forwarding permit number WI0100091. This permit is to inject ORC Advanced to remediate groundwater contaminated
with petroleum products in the vicinity of Building 27 at the Former Ecusta Paper Mill facility located 1 Ecusta Road,
Brevard, Transylvania County, NC 28712. This permit shall be effective from the date of issuance until July 31, 2012,
and shall be subject to the conditions and limitations stated therein, including the requirement to submit a final project
evaluation as stated in PART VII — MONITORING AND REPORTING REQUIREMENTS. Please read the entire
permit to ensure that you are aware of all compliance requirements of the permit.
Please note that the monitoring plan as originally presented in the application has been modified per the
Additional Information Letter dated July 21,2010,and received by the Division of Water Quality on July 23,2010.
You will need to notify this office and the Asheville Regional Office by telephone 48 hours prior to initiation of operation
of the facility. In order to continue uninterrupted legal use of the injection facility for the stated purpose,you must submit
an application to renew the permit 120 days prior to its expiration date. Please contact me at 919-715-6166 or
Michael.RogersCancdenr.sov if you have any questions about your permit.
Best Regards,
{
Michael Rogers,P.G. (NC &FL)
Environmental Specialist
Underground Injection Control Program
cc: Landon Davidson-Asheville Regional Office
Amar C.Bumb-Shaw Environmental,Inc.,3 Independence Pointe,Suite 107,Greenville, SC 29615
WI0100091 Permit File
James Bateson-Division of Waste Management.
Jennifer Wendell-US EPA Region 4
AQUIFER.PROTECTION SECTION
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
Location:2728 Capital Boulevard,Raleigh,North Carolina 27604 One
Phone:[phone] FAX 1:919-715-0588:FAX 2:919-715-60481 Customer Service:1-877-623-6748 NorthCarolina
Internet:wn.nonterouslitv.oro
Naturally
An Eouai Oownurvv Aff mahvs.Acran Emobver

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
Davidson River Village,LLC
FOR THE CONSTRUCTION AND/OR OPERATION OF 40 TYPE 5I INJECTION WELLS,
defined in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject ORC
Advanced, for the remediation of groundwater contaminated with petroleum products. These
injection wells/points will be located in the vicinity of Building 27 at the former Ecusta Paper Mill
Plant, 1 Ecusta Road,Brevard,Transylvania County,NC 28712,and will be operated in accordance
with the application submitted April 26, 2010, and in conformity with the specifications and
supporting data received July 23,2010, 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 Actor any other applicable Laws,Rules,or Regulations. Operation and use of an injection well
shall be in compliance with Title 15A North Carolina Administrative Code 2C.0100 and.0200,and
any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective,unless revoked,from the date of its issuance until July 31,2012, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 31`� day of August 2010.
Coleen H. Sullins,Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No.WI0100091 PAGE 1 OF 7
ver.Jan.2010 AP/UIC-6

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. This permit is valid only for construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Aquifer Protection Section.
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during construction
and use.
8. Each injection well shall have permanently affixed an identification plate.
9. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh,NC 27699-1636
PART II-WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight(48)hours prior to constructing each injection well,the Permittee shall notifythe
Aquifer Protection Section-Underground Injection Control (UIC) Central Office staff, telephone
number [phone] and the Asheville Regional Office Aquifer Protection Section Staff,
telephone number(828) 296-4500.
Permit No.WI0100091 PAGE 2 OF 7
ver.Jan.2010 AP/UIC-6

PART III- OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature,volume ofmaterials,rate of injection,and
number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to change
ownership,or there is aname change of the Permittee,aformal permit amendment request must
be submitted to the Director, including any supporting materials as maybe appropriate, at least
30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying with
any and all statutes,rules,regulations,or ordinances which maybe unposed 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
I
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 Aquifer Protection Section-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.
Permit No.WI0100091 PAGE 3 OF 7
ver.]an.2010 - APRIIC-6

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.
2. Department representatives shall have reasonable access forpurposes of inspection,observation,
and sampling associated with injection and any related facilities as provided for in N.C.G.S.87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application shall be followed except for the
following:
(A)The following field parameters will be analyzed-pH (field), conductivity, DO, and
ORP.
(B)Quarterly sampling will occur after each injection event until groundwater quality has
met standards according to 15A NCAC 2L .0200.
2. All sample results shall be submitted to the Aquifer Protection 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.
3. During each injection event, any spill or daylighting of the injectant shall be contained or
intercepted by the ditch,which discharges to the existing water treatment plant and settling basin.
4. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
5. The Permittee shall produce a final project evaluation within 9 months after completing all
injection-related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the injection
projects findings in a written summary. The final project evaluation shall also contain
monitoring well sampling data, contaminant plume maps and potentiometrie surface maps.
Permit No.W10100091 PAGE 4 OF 7
ver.Jan.2010 - APlUIC-6

6. The monitoring results and the final project evaluation shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh,NC 27699-1636
and to:
Aquifer Protection Section
DENR-DWQ Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
7. 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) 296-4500,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.
8. 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 anyreport to the Director,the
relevant and correct facts or information shall be promptly submitted to the Director by the
Permittee.
9. In the event that the permitted facility fails to perform satisfactorily,the Permittee shall take such
immediate action as may be required by the Director.
PART VHI-PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to'renew the permit 120 days prior to its expiration date.
PART IX- CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily,the Permittee must install a sanitary seal. If a
well is not to be used for any purpose that well must be permanently abandoned according to
15A NCAC 2C .0113,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:
Permit No.WI0100091 PAGE 5 OF 7
ver.Jan.2010 - AP/UIC-6

(A)All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B)The entire depth of each well shall be sounded before it is sealed to insure freedom from
obstructions that may interfere with sealing operations.
(C)The well shall be thoroughly disinfected,prior to sealing,if the Director determines that
failure to do so could lead to the contamination of an underground source of drinking
water.
(D)Drilled wells shall be completely filled with cement grout,or bentonite grout which shall
be introduced into the well through a pipe which extends to the bottom of the well and is
raised as the well is filled.
(E) hi the case of gravel-packed wells in which the casing and screens have not been
removed,neat-cement,or bentonite grout shall be injected into the well completely filling
it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has been
created, each well shall be abandoned in such a manner that will prevent the movement
of fluids into or between underground sources of drinking water and in accordance with
the terms and conditions of-the permit.
(G)The Permittee shall submit a Well Abandonment Record(Form GW-30) as specified in
15A NCAC 2C .0213(h)(1) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC 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.
Permit No.WI0100091 PAGE 6 OF 7
ver.Jan.2010 APIUIC-6

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.WI0100091 PAGE 7 OF 7
ver.Ian2010 APIUIC-6

HCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director RECEIVED Secretary
July 2, 2010 !I"L 0 7 26 iJ
Amar C. Bumb, Ph.D.. P.E. Ashe4;i:P flegional Office
Shaw Environmental & Infrastructure, Inc. Anr rifor ProtPr.ti99
3 Independence Point. Suite 107
Greenville, SC 29615
Re: Additional Information Request
Injection Well Permit Application WI0100091
Davidson River Village,LLC - Former Ecusta Paper Plant
Transylvania County
Dear Dr. Bumb:
While reviewing the referenced permit application our staff identified some items that need clarification and/or
additional information. Therefore,please address the following items:
• In the text part of the application (Section B.) the groundwater flow direction is `generally toward
the southeast'. However, the Potentiometric Surface Map (Figure 5) shows groundwater flow
direction to the northeast.
• If, according to Figure 5, the correct groundwater flow direction is to the northeast, there is no
monitoring well downgradient of the injection area and outside the cone of influence to evaluate the
injection effectiveness and potential plume displacement. Please install 1 additional monitoring well
northeast and downgradient of the injection area, and outside the zone of influence at a sufficient
distance that could monitor the injection effectiveness-possibly at a distance similar to MW-37.
This well would need to be sampled prior to injection activities for baseline data. Also, include the
new well construction.
• Please provide porosity or specific yield of the target aquifer and estimated groundwater flow
ratelvelocity along with the calculations used to determine these numbers.
• Please submit a modified sampling plan reflecting: (1) the additional monitoring well; (2)the
additional parameter of arsenic; and (3) a timeline showing when the post injection sampling starts
(i.e., 1 day after injection, 1 week after injection, etc.),the frequency, and the planned estimated
duration (i.e., 1 year, 2 years etc.).
AQUIFER PROTECTION SECTION
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
Location:2728 Capital Boulevard,Raleigh.North Carolina 27604 One
Phone:[phone] FAX 1:919-715-0588;FAX 2:919-715-60481 Customer Service:1-877-623-6748 NorthiCarolina
Internet:www.ncwatemuality.oro �VQturalllf
An Equal 0oportunny.'.Affirmaflve Action Employe!

Please submit your responses with any corrected text pages/figures for insertion into the previously submitted
UIC Application within 30 calendar days of receipt of this letter. If you have any questions regarding your
permit please call me at [phone] or email me at Michael.Rof'ers aincdenr.eov.
Thank you for your cooperation.
Best Regards,
Michael Ro erg P.G. &FL
g � )
Environmental Specialist
cc: Landon Davidson—Asheville Regional Office
Central Office File—W 10100091
James Bateson, Incident Manager—Division of Waste Management
John B. Hanselman - Davidson River Village, LLC
Page 2 of 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: June 18,2010 County: Transylvania
To: Aquifer Protection Central Office Permittee: NCDENR APS UIC
Central Office Reviewer: B. Laverty/J. Stepp Project Name: Davidson River Village
Regional Login No: Application No.: WI0100091
L GENERAL INFORMATION
1. This application is(check all that apply): ®New ❑Renewal
❑Minor Modification❑ Major Modification
❑ Surface Irrigation❑Reuse❑ Recycle ❑ High Rate Infiltration❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑Attachment B included ❑ 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed-loop Groundwater Remediation ® Other Injection Wells(including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or❑No.
a. Date of site visit: June 16,2010
b. Person contacted and contact information: Amar Bumb [phone]
c. Site visit conducted by:Brett Laverty and Jonathan Stepp
d. Inspection Report Attached: ®Yes or❑No.
2. Is the following information entered into the BIMS record for this application correct?
®Yes or❑No. If no,please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
e. Regulated Activities/Typ6 of Wastes(e.g., subdivision,food processing,municipal wastewater):
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s): Ecusta Road Brevard,NC
b. Driving Directions: U.S.280 to Brevard.Turn left on Ecusta Road just past the U.S.276 intersection
c. USGS Quadrangle Map name and number: Pisgah Forest/35082-C6-TF-024
d. Latitude-82/14/18.01 Longitude: 35016' 2.21"N 820 42' 8.84"W
Lf. NEWAND AfA.fOR 1110DIFICATIONAPPLICATIONS(this section not needed for renewals or minor
modifications,skip to nevt section)
Description Of Waste(S)And Facilities
1. Please attach completed rating sheet. Facility Classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system"
FORM: Davidson River Village.docx 1

AQUIFER PROTECTION REGIONAL STAFF REPORT
❑ Yes ❑ No ❑ N/A. if no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or ProfesslOnal Engineer'? ❑ Yes ❑No ❑ N/A. If no, please explain:
d. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑No ❑N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑No ❑
N/A. If no,please explain:
6. Are the proposed application rates for new sites(hydraulic or nutrient)acceptable?
❑ Yes❑No ❑N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-year tloodplain and please explain
and recommend any mitigative measures/special conditions in Part IV: !
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or❑No. if yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring.
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
i
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?) j
Ill. RENEWAL AND MODIFICATIONAPPLICATIONS(use previous section for new or major modification
syslems
I
Description Of Waste(S) And Facilities N/A
I. Are there appropriately certified ORCs for the facilities? ❑ Yes or❑No.
Operator in Charge: Certificate#:
Backup-Operator in Charge: Certificate#:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the,type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste?❑ Yes or❑ No. If no,please explain:
FORM: Davidson River Village.docx 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
'4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explainls the residuals management plan for the facility
adequate and/or acceptable to the Division?
❑ Yes or❑ No. if no,please explain:
5. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
6. is the existing groundwater monitoring program (number of wells, frequency of,monitoring; monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No. explain and recommend any changes to the
groundwater monitoring program:
7. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑N/A if yes, attach list of sites
with restrictions(CertificationB?)
8. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
9. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or❑No. If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
11. Has a review of all self-monitoring data been conducted (GW,NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
12. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC: ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
ansner/connments (such as NOV, NOD etc): Have all compliance dates/conditions in the existing permit,
(SOC, JOC, etc.) been complied with? ❑ Yes ❑ No ❑Not Determined ❑ N/A.. If no, please explain:
13. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or❑No❑N/A. If yes, please explain:
I
FORM: Davidson River Village.doex 3

AQUIFER PROTECTION REGIONAL STAFF REPORT
IV.. INJECTION WELL PERMIT APPLICATIONS(Complete these two sections for all systems that use injection
wells,including closed-loop groundwater remediation effluent injection wells,in situ remediation injection wells,and heat
pump injection wells.)
Description Of Well(S)And Facilities—New,Renewal,And Modification
1. Type of injection system:
❑ Heating/cooling water return flow(5A7)
❑ Closed-loop heat pump system (5QM/5QW)
N In situ remediation(51)
❑ Closed-loop groundwater remediation effluent injection(5LPNon-Discharge")
❑ Other(Specify: )
2. Does system use same well for water source and injection? ❑ Yes ®No
3. Are there any potential pollution sources that may affect injection? N Yes ❑No
• What is/are the pollution source(s)?Nearby caustic and mercury release sites
• What is the distance of the injection well(s)from the pollution source(s)?Approximately 1,000 feet
4. What is the minimum distance of proposed injection wells from the property boundary?250 ft.
5. Quality of drainage at site: ❑ Good N Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑Moderate N High (for injection site itself)
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring,monitoring parameters, etc.)adequate? N Yes ❑No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site(property lines,wells, surface drainage)? N Yes or❑No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings,wells,potential pollution
sources,roads, approximate scale, and north arrow.
Iniection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑No. If ves. explain:
2. For closed-loop beat pump systems,has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑No. if�,cs. explain:
3. For renewal or modification of groundwater remediation permits(of any type). will
continued/additionalhuodified injections have an adverse impact on misration of the plume or manaecment of
the contamination incident? ❑ Yes ❑No. If yes. explain:
FORM: Davidson River Village.docx 4

AQUIFER PROTECTION REGIONAL STAFF REPORT
4. Drilling contractor: Name:
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
FORM: Davidson River Village.docx 5

AQUIFER PROTECTION REGIONAL STAFF REPORT
V. EYALUATIONANDRECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: The site has been contoured to
promote positive drainage away from the Davidson River and towards a common ditch,which drains the
entire Ecusta site. The common ditch discharges to an existing water treatment plant and aeration
settling basin.Any spill or day lighting of injection fluid should be intercepted by the drainage ditch.
I am also aware from conversations with James Bateson(IHSB) that arsenic soil concentrations at the
former Ecusta site are high.Due to competition for sorption sites,arsenic solubility can be increased by
the presence of phosphate.From the MSDS sheets,it appears that the injection product(ORC)contains
appreciable amounts of phosphate. I would recommend adding arsenic to the post-injection monitoring
plan.
2. Attach Well Construction Data Sheet-if needed information is available:
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ®No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
Provide greater detail on post-injection Narrative only states that sampling will occur
monitoring plan timeline on a quarterly basis.
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
none
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
Add arsenic to post-injection monitoring Presence of phosphate in the injection fluid
plan
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny,please state reasons:
8. Signature of report preparer(s):�
Signature of APS regional supervisor: J (p Z Z of D
Date: 6/18/2010
FORM: Davidson River Village.docx 6

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April30,2010 RECEIVED
John B.Hanselman MAY 13 2�1�
Davidson River Village. LLC
36 Washington Street Suite 220
Wellesley.MA 02481 Asheville Regional Office
A uifer Protection
Subject: Acknowledgement of Application No.WI0100091
Former Ecusta Paper Mill-Building 27 Area
Injection In situ Groundwater Remediation Well(5I)
Transylvania
Dear Mr.Hanselman:
The Aquifer Protection Section of the Division of Water Quality(Division)acknowledges receipt of your permit application and
supporting materials on April 26,2010.This application package has been assigned the number listed above and will be reviewed by
Michael Rogers
The reviewer will perform a detailed review and contact you with a request for additional information if necessary.To ensure the
maximum efficiency in processing permit applications,the Division requests your assistance in providing a timely and complete
response to any additional information requests.
Please be aware that the Division's Regional Office,copied below,must provide recommendations prior to final action by the
Division.Please also note at this time,processing permit applications can take as long as 60-90 days after receipt of a complete
application.
If you have any questions,please contact Michael Rogers
at 919-715-6166,or via e-mail at michaelxcrgers@a ncdenngov. If the reviewer is unavailable,you may leave a message, and they
will respond promptly.Also note that the Division has reorganized. To review our new organizational chart,go to
http://h2o.enr.-,tate.nc.us/documents/dwq orachart.ridf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerely,
for Debra J.Watts
Supervisor
cc: Asheville Regional Office,Aquifer Protection Section
Amar C.Bumb,PH.D,PE(Shaw Environmental &Infrastructure,Inc.-3 Independence Pointe,Suite 107,Greenville,SC 29615)
Permit Application File W10100091
AQUIFER PROTECTION SECTION
1636 Mail Service Center,Raleigh,Nortn Carolina 27699-1636
Location:2728 Capital Boulevard.Raleigh,North Gamma 27604 One
Phone:[phone] t FAX 1:919-715'0588,FAX 2:919-715-6046\Customer Service:1-877-623-6748 North Carolina
internet.erww.ncerateroualay.oro
An Eoual Opponuaq Aifrtmawe fiction Employer Naturally

RECEIVED
AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FO MAY 13 2510
[_�!Aulfsreville Regional Office
Date: May 11, 2010 Protection
To: ® Landon Davidson,ARO-APS ❑ David May,WaRO-APS
❑ Art Barnhardt,FRO-APS ❑ Charlie Stehman,WiRO-APS
❑ Andrew Pitner,MRO-APS ❑ Sherri Knight,W-SRO-APS
❑ Jay Zimmerman,RRO-APS
From: Michael Rogers Groundwater Protection Unit
Telephone: [phone] Fag: [phone]
E-Mail: Michael.RogersAa ncmail.net
A. Permit Number: WI 0100091
B. Owner: Davidson River Village,LLC(Former Ecusta Paper Mill)
C. =Facility/Operation:
❑ Proposed ® Existing ❑ Facility ❑ Operation
D. Application:
1. Permit Type: ❑ Animal ❑ SFR-Surface Irrigation❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation(ND)
® UIC—5I Groundwater Remediation Well
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
1. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
NOTE:
Attached, you will find all information submitted in support of the above-referenced application for your
review,comment,and/or action. Within,please take the following actions:
® Return a Completed APSARR Form within 30 days. However, if laboratory analytical results are
needed in conjunction with the report, submit the report along with lab results whenever received.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO.*
* Remember that you will be responsible for coordinating site visits and reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office-Aquifer Protection Section contact person
listed above.
RO-APS Reviewer: Date:
FORM:APSARR 07/06 Page 1 of 1

State of North Carolina RECEIVED/DENR/DWQ
Department of Environment and Natural Resources Aquifer Protection Section
Division of Water Quality J APR 26 2010
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells—In Situ Groundwater Remediation /Type 5T Wells—Tracer Injection
• Do not use this form for remediation systems that extract contaminated groundwater,treat it,and reinject the treated groundwater.
• Submit TWO copies of the completed application and all attachments to the address on the last page of this fo .
• Any changes made to this form will result in the application package being returned. 9
Application Number(to be completed by DIV& D < M
m
mfD n
vm M
1. GENERAL INFORMATION: o o• ca <
CD : N
I. Applicant's Name (generally the responsible party): Davidson River Village, LLC C� M
2. Signing Official's Name: John B. Hanselman Title: Member 3
3. Mailing address of applicant:
36 Washington Street,Suite 220 CD
City:Wellesley State: MA Zip:02481
Telephone number:781-431-8101 ext 104 Fax number:781-431-8105
4. Property Owner's Name(if different from Applicant):John B. Hanselman
5. Property Owner's mailing address: Same as above
City: State: Zip:
6. Name and address of contact person who can answer questions about the proposed injection project:
Name:Amar C. Bumb, Ph.D., PE Title: Principal Engineer/Hydrogeologisi
Company:Shaw Environmental& Infrastructure, Inc.
Address:3 Independence Pointe, Suite 107
City:Greenville State:SC Zip:29615
Telephone number:864-289-8533 Fax number:864-254-9286
Email Address:[e-mail]
II. PERMIT INFORMATION:
1. Project is: X New Modification of existing permit Renewal of existing permit without modification
Renewal of existing permit with modification
2. If this application is being submitted for renewal or modification to an existing permit,provide:
existing permit number and the issuance date
For renewal without modifications,fill out sections I & II only, sign the certification on the last page of this
form,and obtain the property owner's signature to indicate consent(if the applicant is not the owner).
For all renewals,you must submit a status report including monitoring results of all injection activities to
date.
Revised 8/07 UIC-51/5T Page I of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
Type 5I Wells—In Situ Groundwater Remediation/Type 5T Wells—Tracer Injection
Ill. INCIDENT& FACILITY DATA
A. FACILITY INFORMATION
I. Facility name: Former Ecusta Paper Mill -- Building 27 Area
2. Complete physical address of the facility:
1 Ecusta Road
City:Brevard County: Transylvania State:NC Zip;28712
B. INCIDENT DESCRIPTION
I. Describe the source of the contamination:
Building 27 was a former transportation garage for vehicle refueling. Underground storage tanks(USTs)had
been previously removed with no contamination detected at the time of removal. On January 29, 2009 the
demolition contractor(DH Griffin)begin removal of the concrete footers and pits. As they dug down along side of
one of the pits they encountered a strong petroleum odor. Shaw collected a soil sample B27-CR-1 and analyzed
it for VOCs and SVOCs. The results of the sample indicated contamination was present.
2. List all contaminants present in soils or groundwater at the site(contaminants may be listed in groups, e.g.,
gasoline,diesel,jet fuel, fuel oil,chlorinated ethenes,chlorinated ethenes,metals, pesticides/herbicides,etc):
Gasoline with BTEX and naphthalene present
3. Has LNAPL or DNAPL ever been observed at the site(even if outside the injection zone)?
Yes If yes, list maximum measured separate phase thickness feet
X No If no, list maximum concentration of total VOCs observed at site: BTEX-5,431 ppb
4. Agency managing the contamination incident:
UST Section x Superfund Section(including REC Program and DSCA sites)
DWQ Aquifer Protection Section Solid Waste Section
Hazardous Waste Section x Other:US EPA Region 4. Jennifer Wendell, RPM
5. Incident managers name James Bateson and phone number 919-508-8449
6. Incident number or other site number assigned by the agency managing the contamination incident:
No incident number has been assigned
C. PERMITS
List all permits or construction approvals that have been issued for the facility or incident, including those not
directly related to the proposed injection operation:
1. Hazardous Waste Management program permits under RCRA: NCDO03166675
2. DWQ Non-Discharge or NPDES permits: NPDES 0000078
3. County or DEH subsurface wastewater disposal permits:
4. Other environmental permits required by state or federal law:
VIC 00 rni btIZO1_C90D72
Revised 8/07 UIC-51/5T Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells—In Situ Groundwater Remediation/Type 5T Wells—Tracer Injection
IV. INJECTION DATA
INJECTION FLUID DATA
I. List all proposed injectants.
NOTE:Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the
Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of
Health and Human Services. Review the list otapproved injectantsT or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by GEES.
Injectant:Oxygen Release Compound (ORC)Advanced
Concentration at point of injection:20 to 50 weight percent slurry
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
2. Source of fluids used to dilute or chase the injectants listed above:
None
x Municipal water supply
Groundwater from private well or any well within '/4 mile of injection site
Air
Other:
3. If any well within 'A mile of injection site, a private well,or surface water is to be used as the fluid source,supply
the following information:
a. Location/ID number of source: Not Applicable
b. Depth of source:
c. Formation:
d. Rock/Sedimenttype:
e. In Attachment C, provide a current, complete chemical analysis of the water from the source well, including
analyses for all contaminants suspected or historically recognized in soil or groundwater on the site.
NOTE:If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit
application form. You must apply for a closed-loop groundwater remediation permit using application form
GWRS.
Revised 8/07 UIC-51/5T Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells—In Situ Groundwater Remediation/Type 5T Wells—Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events:2
Expected duration of each injection event:30 days
Expected duration between events (if more than one event):6 to 12 months
2. Injection rate per well:5.0 gallons per minute(gpm)
3. Total Injection volume:200 (max per pt) gallons per day (gpd); 7,000 gallons per event(if separate events)
4. Injection pressure:20 pounds/square inch(psi)
5. Temperature at point of injection:70 OF
6. Briefiv describe how the above oarameters will be measured and controlled:
Flow meter and pressure gauge will be used.
7. Estimated hydraulic capacity of the well: 10 (short term) gpm
C. INJECTION WELL CONSTRUCTION DATA
1. Injection will be via:
❑ Existing well(s) proposed for use as an injection well. Provide the data in (2)through(6)below to the best of
your knowledge.
❑O Proposed well(s)to be constructed for use as an injection well. Provide the data in (2)through(6) below as
proposed construction specifications.
2. Well Drilling Contractor's Name: ESN Southeast
NC Well Contractor Certification number:Allen Merril - NC2004
3. Date to be constructed: June/July 2010 Number of borings: 40 (max)
Approximate depth of each boring(feet): 14
4. Screened interval/Injection interval of injection wells:
Depth: 5 to 15 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
5. Well casing(N/A if injection is through direct push rods):
Type: ❑ PVC ❑ Stainless steel X Other:Direct-push rods
Casing depth: to ft.
6. Grout(N/A if injection is through direct push rods):
Type: ❑ Cement ❑ Bentonite 9 Other:Direct-push Rods
Grout depth: to ft.
Revised 8/07 UIC-5I/5T Page 4 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells—In Situ Groundwater Remediation/Type 5T Wells—Tracer Injection
V. ATTACHMENTS
wide the following items as attachments with the given headings:
A. SITE HISTORY
Provide a brief description of the site history including:
(1) site usage historically and present,
(2) origin of the contamination,
(3) previous remedial action(s).
NOTE: G.S. 89E-I8 requires that any geologic plans, reports, or documents in which the performance is related to the
public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under his or her
direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work which shall have been
prepared or approved by a licensed geologist or a subordinate under his or her direction be signed and sealed by him or
her.
B. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic description,soils description,and cross section of the subsurface to a depth that includes the
known or projected depth of contamination. The hydrogeologic description shall include:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity,transmissivity, and specific yield of the aquifer to be used for injection, including a
description of the test(s)used to determine these parameters; and
(4) the depth to the mean seasonal high water table.
C. INJECTION FLUID COMPOSITION
Describe the chemical, physical,biological and radiological characteristics of each injectant. Attach the Material Safety
A Sheet(MSDS)for each injectant. If a private well or a well within '/a mile of the injection site is used as the source
II, include chemical analysis of source fluid here.
D. INJECTION RATIONALE
Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including:
(1) goals of the injection project;
(2) a description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection; and
(3) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change
(biological,chemical or physical) in the subsurface.
E. INJECTION PROCEDURE AND EQUIPMENT
Provide a detailed description of all planned activities related to the proposed injection including but not limited to:
(1) construction plans and materials;
(2) operation procedures;
(3) a detailed diagram of the surface and subsurface portions of the system; and
(4) a planned injection schedule.
F. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to be used;
(2) a list of monitoring parameters and analytical methods to be used; and
(3) a schedule for sampling to monitor the proposed injection.
NOTE: The selected monitoring wells must be located so as to detect any movement of injection,Jluids,process by-
ducts, or formation fluids outside the injection area or zone. The monitoring parameters should include the target
rtaminants as well as secondary or intermediate contaminants which may result from the injection and other
parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and
Revised 8/07 UIC-51/5T Page 5 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells—In Situ Groundwater Remediation/Type 5T Wells—Tracer Injection
other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated
reactions and rate of transport of the injectants and contaminants.
G. WELL DATA
Provide a tabulation of data on all existing or abandoned wells within '/< mile of the injection well(s)which penetrate the
proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells.
Such data shall include a description of each well's use(water supply, monitoring, etc),total depth, screened or open
borehole depth interval, and well construction or abandonment record, if available.
H. MAPS
Attach the following scaled, site-specific maps:
(1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and
showing the location of the proposed injection site.
(2) Site map including:
a. all property boundaries;
b. all buildings within the property boundary;
c. existing and proposed injection wells or well field(s)
d. any existing sources of potential or known groundwater contamination, including waste storage,
treatment or disposal systems within A mile of the injection well or well system;
e. all surface water bodies within '''A mile of the injection well or well system; and
f. all existing or abandoned wells within '''A mile of the injection well(s)which penetrate the proposed
injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection
wells.
(3) Potentiometric surface map(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(4) Contaminant plume map(s) including:
a. the horizontal extent of the contaminant plume, including isoconcentration lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(5) Cross-section(s)to the known or projected depth of contamination, including:
a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines
b. major changes in lithology
Revised 8/07 UIC-5I/5T Page 6 of 7

RECEIVED I UENK I UVVU
Aquifer Protection Section
APR 26 2010
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S)FOR INJECTION
Type 51 Wells—In Situ Groundwater Remediation/Type 5T Wells—Tracer Injection
VI. CERTIFICATION
I John B. Hanselman hereby certify under penalty of law that
I have personally examined and am familiar with the information submitted in this document and all attachments
thereto and that,based on my inquiry of those individuals immediately responsible for obtaining said information,
I believe that the information is true,accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment,for submitting false information. I agree to construct,
operate,maintain,repair,and if a icable,abandon the injection well(s)and all related appurtenances in
accordance with-the�pprov4 s cations and conditions of the Permit.
Signature: 4 -- Date: �� U
Title:Member
If authori agent is acting on behalf of the applicant,supply a letter signed by the applicant authorizing the
above agent.
vu. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant)
("Owner"means any person who holds the fee or other property rights in the well being constructed.A well is
real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement in writing.)
I John B. Hanselman as owner of the property on which the
injection well(s)are to be constructed and operated,hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection well(s)confo the Well Construction Standards(Title 15A NCAC 2C .0200)
Signature: ( Date: t
Title: Member.
Submit TWO copies of the completed application package,including all attachments,to:
UIC Program
Aquifer Protection Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh,NC 27699-1636
Telephone[phone]
Revised 8/07 UIC-51/5T Page 7 of 7

V. ATTACHMENTS
REFERENCES
North Carolina Department of Environment and Natural Resources,2007,Guidelinesfor Assessment
and Cleanup, Inactive Hazardous Sites Program, August.
Shaw Environmental Inc.,2007,Phase HEnvironmental Site Assessment,Ecusta Paper Mill,Pisgah
Forest,North Carolina. June 22.
Shaw Environmental Inc., 2008a, Field Sampling Plan, Ecusta Paper Mill, Pisgah Forest, North
Carolina. Rev 1, August.
Shaw Environmental Inc.,2008b,Quality Assurance Project Plan,Ecusta Paper Mill,Pisgah Forest,
North Carolina. Rev 1, August.
Shaw Environmental Inc., 2008c,Site-Specific Health and Safety Plan for Remediation Activities,
Former Ecusta Paper Mill, Pisgah Forest,North Carolina. May.
Shaw Environmental Inc.,2009e,Aquifer pump Test Work Plan,Former Ecusta Paper Mill,Pisgah
Forest,North Carolina. February.
A. SITE HISTORY
The property was first developed in 1938 as a paper manufacturing plant by Ecusta Paper Company
(Figure 1). In 1949, Olin Industries acquired the facility. Cigarette papers were the only products
manufactured at the facility until the mid-1950's when cellophane and rayon production was added
with the construction of the film plant. In 1958, printing and lightweight paper production
capabilities were added.A wastewater treatment plant was put into service in 1974,followed by the
installation of the sludge landfill and the ASB in 1976.In 1985,in conjunction with the purchase of
the property by a corporation of former Olin employees, cellophane and rayon production was
discontinued.In 1987,P.H.Glatfelter Company purchased the property which operated the business
until 2001 when PURICO(IOM)Limited purchased the facility,former RFS Ecusta.In 2002,RFS
Ecusta declared bankruptcy and all production ceased. In late 2003, The Ecusta Business
Development Corporation, LLC (EBDC) acquired the facility. Limited production of flax pulp
resumed on site while some of the buildings and warehouse facilities were leased for use by local
businesses. In January 2008, DRV purchased the property from EBDC and demolition activities
started in summer 2008.
UICAttachments-ECUSTA Bldg 27.doe 04/05/10 10:36AM

Building 27 was a former transportation garage used for vehicle refueling. Underground storage
tanks(USTs)had been previously removed with no contamination detected at the time of removal.
On January 29,2009 the demolition contractor(DH Griffin) begin removal of the concrete footers
and pit. As they dug down along side of a pit they encountered a strong petroleum odor. Shaw
collected a soil sample B27-CR-1, which was analyzed for VOCs and SVOCs.
On February 10, 2009, Shaw received the laboratory results indicating high levels of volatiles and
semi volatiles being present. TCRA removal request#6 was submitted to USEPA and NCDENR.
While excavating the maintenance pit on February 11, 2009, affected soil was noted at four feet
below land surface level based on visual observations and soil screening using a PID.Confirmation
soil samples were collected from the excavation walls and floor when PID results were less than 5
ppm. Shaw excavated approximately 280 cubic yards of soil. This soil was stored in Building 89
warehouse for disposal.
Shaw conducted a soil and groundwater investigation in May 2009 to delineate the horizontal and
vertical extent of petroleum hydrocarbons in the area of Building 27. A direct push rig installed 35
soil borings(SB-1 through SB-35)and three monitoring wells MW-35 through MW-37 on May 12-
14,2009. The excavation, direct push borings, and monitoring wells are shown on Figure 2. PID
readings for the borings and monitoring wells are in Table 1. The soil analytical results for the
borings and monitoring wells are presented in Table 2. Two additional monitoring wells(MW-38
and MW-39)were installed on September 16,2009 to help further delineate the groundwater plume
at Building 27.The groundwater analytical results for the monitoring wells are presented in Table 3.
B. HYDROGEOLOGIC DESCRIPTION
The subject site is located in the Blue Ridge geologic province adjacent to the Brevard fault zone.
The Brevard fault zone is a linear, southeast-dipping thrust fault that forms the boundary between
the Inner Piedmont geologic belt to the southeast and the Blue Ridge geologic belt to the northwest.
The geology in the vicinity of the site consists of moderate to high grade metamorphic rocks of
middle to late Proterozoic age. The rock units include meta-sedimentary and meta-igneous rocks,
including gneisses,amphibolites,metagabbros,and quartzite schist.According to the Geologic Map
of North Carolina (NCGS, 1985), the site is located within the Brevard fault zone which is
characterized by mylonitic and cataclastic rocks.
The general geologic stratigraphy, based on soil borings and monitoring wells that have been
completed at Building 27 area,is shown on Geologic Cross Section Location Map Figure 3 and the
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36AM

Cross Section in Figure 4. This cross section provides a general representation of the subsurface
conditions below the area of Building 27 which includes monitoring wells MW-35 through MW-39.
In general, a silty clay is present from ground surface to 3 feet bgs which is underlain by a sand
down to approximately 5 to 8 feet bgs. A gravelly sand is present from 8 feet bgs to 13 feet bgs. A
gray clay(saprolite)is present below the gravelly sand down to weathered rock at the bottom of the
borings. Boring and Well Construction logs from the Building 27 Area are presented in Appendix
A.
The area hydrogeologic setting consists of a vadose or unsaturated zone within the alluvium above
the groundwater table. The groundwater table lies within the alluvium and is recharged by
infiltrating precipitation. The groundwater in the shallow water table aquifer moves horizontally
until it discharges into surface waters. The surface of the water table is typically a subdued replica
of the topographic surface and is generally near the ground surface in streams/valleys (discharge
areas)and is somewhat deeper beneath ridges and hills(recharge areas). Specifically,at the mill it is
expected that shallow groundwater moves under relatively flat gradients with eventual discharge to
the Davidson River.
The occurrence and movement of groundwater in the Inner Piedmont and Blue Ridge provinces is
generally within two separate, but interconnected, water bearing zones. A shallow water-bearing
zone occurs within the saprolite zone, and a deeper zone occurs within the underlying bedrock.
Groundwater in the shallow saprolite zone occurs in the interstitial pore space of the saprolite. The
depth to groundwater in the saprolitic zone can range from 20 to more than 50 feet along ridges and
upland areas. In low lying stream valleys, the groundwater level will approach the local surface
water elevations in stream channels. Groundwater flow in this zone is typically governed by water
table conditions.This means that groundwater will flow under unconfined conditions and generally
mimic the surface topography as modified by highly permeable bedding for underground utilities.
Therefore, groundwater movement will be from upland areas (recharge zones) to nearby surface
streams (discharge zones).
The occurrence and movement of groundwater in the deeper water-bearing zone within crystalline
bedrock is controlled by secondary joints, fractures, and faults within the bedrock. Groundwater
within the bedrock zone may be under confined or unconfined conditions. The occurrence and
movement of groundwater is difficult to predict on a small scale due to the erratic nature of the
secondary openings that control groundwater flow in bedrock. Small surface water features generally
do not provide an accurate indication of the direction of groundwater movement in bedrock.
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36AM

However,on a regional scale,the direction of groundwater movement will generally be from upland
areas(North)to major surface streams downgradient(South).
Shaw personnel gauged Building 27 area shallow monitoring wells MW-35 through MW-39 on
March 15,2010 for groundwater elevations(Table 4). The groundwater potentiometric surface on
March 15,2010 is illustrated on Figure 5. The groundwater potentiometric surface map indicated
that groundwater flowed generally toward the southeast at an average hydraulic gradient of 0.013
feet per foot(ft/ft) between monitoring wells MW-35 and MW-37.
Aquifer Tests
Aquifer tests (slug tests) were conducted at the former Ecusta Mill site from February 24, 2009
through March 6, 2009 in the Caustic Area(approximately 1,000 ft from the former Building 27).
Monitoring wells MW-1 through MW-4,MW-16/S/l/D, and PZ-30AB/C through PZ-34AB/C in
the caustic area near former Building 70 were selected for slug testing to determine general
hydraulic conductivity distribution at the site. Rising and falling head slug tests were performed by
placing a LevelTrollTm 700 pressure transducer/datalogger in the monitoring well and recording
background water levels until the water level in the well stabilized. Slug test data(both falling head
and rising head tests)were analyzed to determine hydraulic conductivity values. Slug test analysis
results are summarized in Table 5. The data analysis was performed with the aid of AQTESOLVTM
software using the the Hyder et al.(1994)solution,also known as the KGS Model for slug tests in a
partially penetrating well in an unconfined aquifer. The hydraulic conductivity for the gravelly
clayey sand (above the first clay layer—zone of interest at Building 27) ranged from 1.05 x 10'
centimeters per second(cm/sec)(0.30 feet per day (ft/day])to 1.78 x 10-3 cm/sec(5.05 ft/day)with
an geometric mean value of 8.77 x 10-4 cm/sec(2.49 ft/day). The geometric mean value of hydraulic
conductivity for the clay layer was 1.28 x 10-6 cm/sec (3.63 x 10-3 ft/day). The geometric mean
value of hydraulic conductivity for the sandy/gravelly zones within the clay layer was 1.11 x 10-5
cm/sec (3.15 x 10-2 ft/day).
C. INJECTION FLUID COMPOSITION
ORC Advanced will be used for injection. The Material Safety Data Sheet (MSDS) for the ORC
Advanced is included in Appendix B.
UIC Att bo ts-ECUSTA Bldg 27Am 04/05/10 10:36 AM

D. INJECTION RATIONALE
The purpose of this corrective action is for the completion of the project remediation activities and
meet the requirements as described in the 5A NCAC 02L regulations, commonly known as the
Groundwater 2L Standards,which require groundwater BTEX concentrations to be at 1.0 µg/L for
benzene, 550 µg/L for ethylbenzene, 530 µg/L for xylenes, and 21 g/L for naphthalene. All other
petroleum hydrocarbon constituents are currently below the Groundwater 2L Standards.
The benzene, toluene, ethylbenzene, and total xylenes (BTEX) groundwater contamination are
shown on Figure 6 surrounding Building 27 area. The objective of this remediation of Building 27
area groundwater is to supply controlled release of molecular oxygen to the subsurface environment
where it will accelerate the rate of naturally occurring aerobic biodegradation of petroleum
hydrocarbons in groundwater and saturated soils for periods of up to 12 months (on a single
application). ORC Advanced TM is one such commercially available product to provide controlled
release of oxygen. After the reaction of magnesium oxides in ORC Advanced with water to form
oxygen,the resulting material,magnesium hydroxide,is mildly basic. The amounts of magnesium
oxide and magnesium hydroxide in the initial product have an effect similar to lime,but with lower
alkalinity.
The amount of ORC Advanced needed is a function of groundwater BTEX concentrations and
amount of residual BTEX in soil. The maximum concentrations observed were 101 µg/L for
benzene, 1120 µg/L for ethylbenzene, 3,952 µg/L for xylenes, and 221 µg/L for naphthalene. For
relatively low level of contamination observed at Building 27 and 15-foot injection spacing and
approximately 7 feet of saturated zone, a dosage rate of 46 Ibs/liner ft of saturated zone was
calculated(see attached calculation). Therefore,501bs of ORC Advanced will be used per injection
point.
ORC AdvancedTM is a product of Regenesis and is a NCDENR approved chemical oxidation
compound for concentration reduction of petroleum hydrocarbon constituents in groundwater.
E. INJECTION PROCEDURE AND EQUIPMENT
ORC Advanced is typically applied using direct injection techniques. This process requires ORC
Advanced to be mixed with water to form injectable slurry which is then pressure injected using a
pump to the zone of contamination. Once in the aquifer, tiny ORC Advanced particles can sorb to
and/or reside in the soil matrix and produce a controlled release of oxygen for periods up to 12
months.
UIC Machments-ECUSTA Bldg 27.doc 04/05/10 1036AM

Grid Injection Layout
The groundwater in the area of Building 27 where the BTEX and naphthalene in groundwater are
higher than the Groundwater 2L Standards will be treated by means of injecting 50 lbs of ORC
Advanced in approximately 200 gallons of water in each of the injection points into the
groundwater. The radius of influence for injection is estimated to be approximately 10 to 15 feet
based on the average hydraulic conductivity of shallow gravelly clayey sand zone is 8.77 x 104
cm/sec(2.49 ft/day). Therefore, l5-foot spacing for injection points will be used. Approximately 31
injection points will advance to 14 ft-bgs to the top of the clay for injections. Figure 7 shows the
injection points for groundwater remediation.
Injection
ORC Advanced slurry will be injected using DPT. Injection points with 5-foot screens will be
advanced to the top of the clay and retrieved back one foot before injection to start. Within the
source zone,temporary injection points will be used to facilitate injection. A manifold system will
be used and the ORC Advanced slurry will be pumped into groundwater using a day tank and a
pump. The amount of slurry needed for the next 30-minute will be prepared in the day tank using
portable water and ORC Advanced in powder form. Injection rate will be monitored and adjusted to
ensure that temporary mound at injection points does not result in surface runoff of the ORC
Advanced slurry. Injections will start from the edge of the plume and progress inwards. This will
ensure that as groundwater is displaced,it will pass through the treatment zone and groundwater will
be reduced to less than the Groundwater 2L Standards for the BTEX constituents.
Potential Rebound and Additional Treatment
Chemical oxidation is a very slow reaction and requires contact between the reagent and impacted
soil/groundwater. Contact with groundwater in the dead-end pores or in low permeability clayey
soils is limited by slow diffusion processes. Therefore,there is a possibility,especially in the source
areas, groundwater BTEX concentrations might increase 6 to 12 months after the injection of the
ORC Advanced slurry. Should groundwater BTEX concentrations increase to greater than the
Groundwater 21, Standards for the BTEX constituents, a second treatment may be required. If
second treatment is required, the ORC Advanced slurry will be reinjected in the affected areas.
UIC Attachments-ECUSTA Bldg 27.doc 04105110 10:36 AM

F. MONITORING PLAN
Accurate delineation of impacted BTEX affected groundwater, an understanding of subsurface
conditions and characteristics, and identification of impacted groundwater migration rates and
direction are critical for evaluating the occurrence of natural attenuation, for designing reagent
application to reduce the BTEX values, and for establishing regulatory support for its use at a site.
These data are available. Therefore, no new monitoring wells are required. Existing monitoring
wells at the Site will be utilized for monitoring the progress of in-situ remediation.
Baseline Sampling
Monitoring wells in Building 27 area were sampled in March 2010. The results of March 2010
groundwater sampling will be considered as the baseline sampling event.
Groundwater Monitoring Frequency
Groundwater BTEX and naphthalene sampling will be performed on a quarterly basis. In addition to
groundwater BTEX and naphthalene laboratory analysis, water levels will be recorded for all
monitoring wells on a quarterly basis.
Closure Plan
After the remediation BTEX and naphthalene goals have been confirmed for two consecutive
quarters,a final groundwater remediation closure report will be prepared. Upon approval of the final
report by the USEPA and NCDENR, existing monitoring wells will be abandoned.
G. WELL DATA
All wells within ''/4-mile of the caustic area are monitoring wells. See Figure 1 and Table 1 for
the requested information.
H. MAPS
Please see attached Figures 1 through 7.
UIC AOachments-ECUSTA Bldg 27.doe 04/05/10 10:36 AM

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Figures
UIC AOnnWnenw-ECUSTA Bldg 27.dm 03/26/10 8:42 AM

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Tables
UIC Attachments-ECUSTA Bldg 27.doc 0326/10 8:42AM

Table 1
PID Data for DPT Borings
Ecusta Building 27 Area
Boren Date Hi hest PID Depth
of Submitted for
g B P
Reading(PPM) Measurement VOC&Lead
(ft-bgs) Analysis
SB-1 05/12/09 0.0 10.0
SB-2 05/12/09 0.7 7.5
SB-3 05/12/09 0.4 10.0
SB-4 05/12/09 100 10.0
SB-5 05/12/09 177 10.0
SB-6 05/12/09 1.6 10.0
SB-7 05/12/09 110 10.0
SB-8 05/12/09 0.8 5.0
SB-9 05/12/09 5.3 10.0
SB-10 05/12/09 29.7 2.5
SB-11 05/12/09 1.7 10.0
SB-12 05/12/09 2.2 2.5
SB-13 05/12/09 0.2 10.0
SB-14 05/12/09 0.6 2.5
SB-15 05/12/09 0.7 10.0
SB-16 05/12/09 1.2 7.5
SB-17 05/12/09 1.6 5.0
SB-18 05/12/09 1.6 7.5
SB-19 05/13/09 0.8 10.0
SB-20 05/13/09 0.7 5.0
SB-21 05/13/09 0.8 10.0
SB-22 05/13/09 10.6 5.0
SB-23 05/13/09 4.6 5.6
SB-24 05/13/09 4.6 5.0
SB-25 05/13/09 8.4 10.0
SB-26 05/13/09 5.6 7.5
SB-27 05/13/09 5.5 10.0
SB-28 05/13/09 2.8 5.0
SB-29 05/13/09 1609 10.0
SB-30 05/13/09 1681 7.5
SB-31 05/13/09 15.7 7.5
SB-32 05/13/09 10.5 7.5
SB-33 05/13/09 352 10.0
SB-34 05/13/09 47.3 7.5
SB-35 05/13/09 33.5 10.0
MW-35 05/14/09 7.9 10.0
MW-36 05/14/09 1655 10.0
MW-37 05/14/09 4.4 10.0
Note: ft-bgs=feet below ground surface
Page 1 of 1

Table 2: Summary of Soil Analytical Results
Building 27 Area
Sample Sample Date B T E X
ID depth Sampled Benzene Toluene Ethylbenzene Xylenes Naphthalene
(ft.bgs) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg)
Residential Soil Cleanup Levels 18 3200 1560 3129 313
B27-SB4 7.5-10 5/12/2009 ND ND ND ND 0.503
B27-SB5 7.5-10 5/12/2009 ND ND ND ND 18.80
B27-SB-22 2.5-5 5/13/2009 ND ND ND ND ND
B27-SB-24 7.5-10 5/13/2009 ND ND ND ND ND
B27-SB-29 2.5-5 5/13/2009 ND ND 0.469 4.022 0.482
B27-SB-30 5-7.5 5/12/2009 ND ND 23.80 10.63 191.5
B27-SB-31 5-7.5 5/13/2009 ND ND ND ND ND
B27-MW-35 7.5-10 5/13/2009 ND ND ND ND ND
B27-MW-37 7.5-10 5/13/2009 ND ND ND ND 0.048
Notes:
ft bgs=feet below ground surface
mg/kg=milligrams per kilogram
ND=not detected

Table 3: Summary of Groundwater Analytical Results
Building 27 Area
Sample Date B T E X
Location Sampled Benzene Toluene Ethylbenzene Xylenes Naphthalene
u /L u L u u u
NCDENR 21,Standards 1 1000 550 530 21
6/19/2009 ND ND ND ND ND
MW-11 10/20/2009 ND ND ND ND ND
3/10/2010 ND ND 1.2 2.9 ND
6/19/2009 ND ND ND ND ND
MW-35 10/20/2009 ND ND ND ND ND
3/9/2010 ND ND ND ND ND
6/19/2009 101 258 1120 3952 179
MW-36 10/21/2009 39.5 110 961 1899 221
3/9/2010 54.2 129 649 1994 155
6/19/2009 ND ND ND ND ND
MW-37 10/21/2009 ND ND 1.3 2.1 ND
3/11/2010 ND ND 1.6 4.1 7.0
10/21/2009 6.8 ND 1.4 5.7 7.8
MW-38
3/10/2010 1.9 ND 2.1 5.2 6.1
10/21/2009 ND ND ND 2.5 37.7
MW-39
3/10/2010 ND ND L5 3.6 12.8
Notes:
L Exceeds NCDENR 21,Standards
ug/L =micrograms per liter
NCDENR =Norht Carolina Department of Environment and Natural Resources
ND =not detected

Table 4: Potentiometric Elevations
Building 27 Area
Well Date TOC Depth to Water Depth to Product
Location Gauged Elevation Water Elevation Product Elevation
(ft) (ft) (ft) (ft) (ft)
MW-11 3/10/2010 2120.98 8.40 2112.58 ND N/A
MW-35 3/10/2010 2120.71 7.66 2113.05 ND N/A
MW-36 3/10/2010 2121.36 9.40 2111.96 ND N/A
MW-37 3/10/2010 2120.05 9.33 2110.72 ND N/A
MW-38 3/10/2010 2121.20 10.20 2111.00 ND N/A
MW-39 3/10/2010 2121.45 10.38 2111.07 ND N/A
Notes:
TOC= Top of casing: elevations relative to a set datum
ft=feet
ND =Not Detected
N/A =Not Applicable

Table 5
Summary of Slug Test Results
Ecusta Caustic Spill Area
Brevard,North Carolina
Fleight of Hydraulic Conductivity(emis)
Depth of o epih(o Lithclogy'
Monitoring Water Groundwater
Screen Top of Clay Across Screened Geometric
Well (ft bgs) Column in (feet) Interval Falling Head Test Rising Head Test Mean Flow Rate
Well (feet) (ttlyear)
Wells Screened above the first Clay Layer(Sa rolite
MW-1 9.8'-19.8' 13.49 NM Sand/clay 1.32E-03 1.28E-03 1.30E-03
Sand/gravel/
MW-2 T-17' 10.32 NM sandy silt 4.12E-04 3.68E.04 3.89E-04
MW-3 T-17' 12.31 NM Sand Too Much Scatter 7.04E-01 7.04E-01
MW-4 3'-13' 8.08 13+ Silt 1.78E-04 2.49E-04 2.09E-04
MW-16s 3'-13' 4.00 14.5 Silt/Sand/Gravel 5.25E-03 6.02E-04 1.78E-03
PZ-30A 10'-11, 5.81 15.0 Sand 6.63E-04 1.20E-03 8.92E-04
PZ.31A 7'-8' 4.04 11 Sand .1.17E.03 3.77E-04 6.65E-04
Clay(?)(Based
PZ.31B IT-14' i 8.21 (7 on CGW-19 2.93E-04 3.79E-05 1.05E-04
PZ-32A 10'-11, 5.34 15 7 Sand Too Much Scatter 1.48E-04 1.46E-04
PZ-33A 10'-ll' 5.02 14.0 Sand 4.66E-04 1.06E-04 2.22E.04
AVERAGE 8.77E-04 36 to 91
Wells Screened in the First Clay Layer(Saprolite)
Incomplete Failing
PZ-30B 16-17' 11.60 1 15 1 clay 7.47E-07 Head Test 7.47E-07
Incomplete Falling
PZ-329 Ifi'-17' 10.66 15 77 sand/clay6.72E-07 Head Test 6.72E-07
PZ.33B 16-17' 1.79 14.5 elay Incomplete Test 2.92E-06 2.92E-06
PZ-34A 10'-l1' 2.35 13.0 Sand(?) Incomplete Test 1.81E-06 1.81E-06
AVERAGE I 1.28E-96 <1.0
Wells Screened in the Set irolite Sandy/Gravelly Zane
Incomplete Falling
PZ-30C 22-23' 17.44 15 Sand/Clay 8.72E-06 Head Test I 8.72E-06
PZ-32C 22'-23' 15.92 IS sand 7 4.03E-04 5.57E-04 4.74E-04
PZ-33C 22'-23' 9.52 14.5 cla Incom lete Test 3.57E-06 3.57E-06
PZ-34C 22'-23' IL89 13 clay 2.65E-07 4.08E-06 I 1.04E-06
AVERAGE 1.11E-05 0.S to 1.2
Dee er Wells
MW-16I 1 30-35' 1 24.02 14.5 clay 1.46E-04 1.24E-N 1.34E-04
MW-16D 82'-87' 76.38 14.5 rock 7.04E-04 1.20E-04 1.12E.04
=top of rasing,NM=no

Appendix A
Boring and Well Construction Logs
UIC AtlachmmtsECUSTA Bldg 27.doc 0326110 8:42 AM

Cal
A
Shaw
WELL CONSTRUCTION LOG
Project Name: Former Ecusta Paper Mill Project No.: 131497
Client: Renoval DRV Boring No.: MW-35
Location: Brevard,North Carolina Date: 14-May-09
Drilling Company: Landprobe logged by: Jim Wilson
Dril Rig Hollow Stem Auger weather: sunny
e ons met Description Depth I 'Samples I urilling-OFs-e-Nali—ons
(feel) L9TrTy­p-eT-EFo-ws77 Recov. PID SPT boring
Light to dark brown silty clay,
- 4.25"Diameter Borehole 0.00 dry,no odor
4 bentonite
'.`� 3.0 Brown sand,dry,no odor
Top of screen at 9bls 0.00
5 Gray gravelly sand,dry
Depth to Water 7'bls 6.0 0.40
Sand Filter Pack 7.90
9.0
10 0.30 Gray to white clay,moist,
_- 2.0"Sch 40 PVC no odor
_ 12.0 0.00
Bottom of screen 15'bls
_ 0.00
15 15.0
0.00
Bottom of Boring 16'bls"
18.0 0.00
20 0.00
21.0
0.00
23.0
0.00
25
LhQhND
note:elevation data not bona Pack = e o o-icniza ion
available 1—Well Screen detector
Benionile Seal
Concrete Seal bls=Below Land Surface

l
g
I I
S h�aaw
1
WELL CONSTRUCTION.LOG
Project Name: Former Ecusta Paper Mill Project No.: 131497 1
Client: RenovafDRV Boring No.: MW-36
Location: Brevard,North Carolina Date: 14-May-09
Drilling Company: Landprobe logged by. Jim Wilson
Dril Rig Hollow Stem Auger weather. sunny
IWeil uonstruct - OR ion Depthamp esows n mg servaions
.(feet) o. ype ecov. onng
Light to dark brown silly clay, j
s; 4.25"Diameter Borehole 0.00 dry,no odor
bentonile 3.0 Brown sand,dry,.no odor
Top of screen at 5'his 5.30
5 Gray gravelly sand,dry, i
Depth to Water T bls 6.0 10.50 slight odor l
Sand Filler Pack 1655 strong petroleum odor
— 9.0
10 334 Gray to while clay,moist,
2.0"Sch 40 PVC slight odor
12.0 8.10
Bottom of screen 15'bls f
0.00
15 _ 15.0 i
0.00
Bottom of Boring 16'bls 1
18.0 0.00
20 0.00
21.0
0.00
23.0
0.00
25
LEGEND
note:elevation data not Sand Pack Pill=IU.beV Photo-ionization
Lavailable Well Screen detector
Bentonile Seal
_-"a,Concrete Seal bls=Below Land Surface
r 1
I
I

Sh e
WELL CONSTRUCTION LOG
Project Name: Former Ecusta Paper Mill Project No.: 131497
Client: Renova/DRV Boring No.: MW-37
Location: Brevard,North Carolina Date: 14-May-09
Drilling Company. Landprobe logged by: Jim Wilson
Dril Rig Hollow Stem Auger weather: sunny
e onstruc escnpuon ep amp es Drilling Observations
(feel) o. ype o ecov. boring
t`. = Light to dark brown silty clay,
4.25"Diameter Borehole 0.00 dry,no odor
bentonite 3.0
Top of screen at 5'bls 0.10
5 Gray gravelly sand,dry
—= Depth to Water 7'bls 6.0 1.60
Sand Filler Pack 1.10 Gray to white clay,moist;
9.0 no odor
10 0.40
2.0"Sch 40 PVC
12.0 0.00
Bottom of screen 15'bls
0.00
15 15.0
0.00
Bottom of Boring 16'bls
18.0 0.00
20 0.00
21.0
0.00
23.0
0.00
25
note:elevation data not an ac = e o o-ioniza ion
available RE.HWell Screen detector
Bentonite Seal
F Concrete Seal bls=Below Land Surface

I
I
aw
WELL CONSTRUCTION LOG
Project Name: Former Ecusta Paper Mill Project No.: 131497
Client: Renova/DRV Boring No.: MW-38
Location: Brevard,North Carolina Date: 16-Sep-09
Drilling Company. Landprobe logged by Jim Wilson
DO Rig Hollow Stem Auger weather, cloudy
lWell GonsTw­ct escnpbonDepth amp es rl mg Observations
(feet) o. ype o ecov. onng
.rn Light to dark brown silty clay,
4.25"Diameter Borehole 0.00 dry,no odor
bentonite 3.0
Top of screen at 5'bls 0.00
5 Brown sand,dry,slight odor
6.0 0.80
Depth to Water 8'bls 30.10 Gray gravelly sand,wet
9.0 strong petroleum odor I
10 55.00
2.0"Sch 40 PVC
12.0 65.00
Gray to white clay,moist,
� 13.10 no odor
15 15.0
2.80 Light brown weathered rock;
wet,no odor
18.0 0.00
i
20 0.00
21.0
Sand Filter Pack 0.00
23.0
Bottom of screen 25'bls 0.00 j
25 =
Bottom of Boring 25'bls
I
I
I
note:elevation data not an ac = e. o o-lomza Ion
avallable h Well Screen detector
LLM Bentonite Seal
Concrete Seal bls=Below Land Surface j

t
S6J 0
WELL CONSTRUCTION LOG
Project Name: Former Ecusta Paper Mill Project No.: 131497
Client: Renoval DRV Boring No.: M W-39
Location: Brevard,North Carolina Date: 16-Sep-09
Drilling Company: Landprobe logged by: Jim Wilson
Dill Rig Hollow Stem Auger weather: cloudy
Well Construct Discription Depthampes Drilling Observations
(feet) o. ype o ecov. boring
`r Light to dark hrown silly clay,
4.25"Diameter Borehole 0.00 dry,no odor
bentonite
3.0
Top of screen at 5'bls 0.20
5
6.0 3.40 Brown sand,dry,slight odor
Depth to Water V his 8.90 Gray gravelly sand,wet
9.0 petroleum odor
10 4.60
2.0"Sch 40 PVC
12.0 2.80
2.50 Gray to white clay,moist,
15 __ 15.0 slight odor
1.90 Gray gravelly sand,wet
= no odor
18.0 0.00 Light brown weathered rack,
_ wet,no odor
20 — 0.00
21.0
Sand Filter Pack 0,00
23.0
_ Bottom of screen 25'bls 0.00
25 __
Bottom of Boring 25'bls
LEGhND
note:elevation data not Sand Pack = e o o-wmza ion
available Well Screen detector
rBentonite Seal
ill Concrete Seal his=Below Land Surface

1
PAGE 1 OF 1
12- 0
PROJECT: 3 LOCATION: d
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY': I,an BORING: - $
DRILLER: �; pmr
DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: �c MWrk_
D S B PID U
E A N L / S
T P M w PID S GEOLOGIC DESCRIPTION I COMMENTS
(ft E ER
/6" (PPm) (vm)
s s6•i o s;ley 'Clsy - Rlq�h
7Yz' 5V 0 S���y Clfy - 614o1+
lot 56 b s: I+y Clsy gl,?th

I
PAGE 1 OF 1
PROJECT: LOCATION: I 7
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: _ b BORING: W- -7.
DRILLER: ;A DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST:
E A N L P/ID S
T L B S FID S GEOLOGIC DESCRIPTION I COMMENTS
R �6„ DPP )eft) E (SYM)
2'h . se z o Sa��y srlf — GrctyA brown
S;
7X' s.8 2 0.1 s:)�y 5q,7J - CMyh , brow„
1�` Sol D GrvNe�I y S�r9 - Gray�'sh brown

PR07ECT: PAGE 1 OF 1
s
13 � LOCATION:
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: L i BORING: 2? - B-
DRILLER: Mh DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST; t
E A N L PID S
P M U 0 FID C
T P M W 3 GEOLOGIC DESCRIPTION/ COMMENTS
(ft E ER /6" (PAm) (SYM)
59.3 p 57r14y 504r - gown
s` 58,3 o S Icy Braon
-9�k SS-3 0 3 Gcw•el ly Se47� - Grown
ID` 58-3 6.q Gfavell�s4-j) - grown

I
PAGE 1 OF I
PROJECT: 131 LOCATION: - 2)
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: c BORING: gZq - $B Ll
-
DRILLER: e✓A s DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: &4p
D S B PID U
E A N L ! S
P M U 0 FID C
T P M W S GEOLOGIC DESCRIPTION/COMMENTS
(fr II R /6" (PPm) ( )
-Zh 56-4 '(3,1 G�-,y.`si, brawn
s' So-4 11.3 S:ify sand . GAj,l bmdn
—7h 58-4 N3.4 S,�fy send Gr4y�h brown
lot lay Sr�fy Sa,d G�oyl�l� Noun
57MpW 7 A 7D . �� ' I�fretor2 r y02 J4!

i
PAGE I OF I
5-12-Oq
PROTECT: 131Yq) LOCATION: 1 Z
DATE INSTALLED: ELEVATION. TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: Lq i BORING:YZ7- -S-
DRILLER: Wo IhomesDEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: rr—_
D S B PID U
E A N L / S
P M U O PID C
T L B S m S GEOLOGIC DESCRIPTION/COMMENTS
(e) E R /6d (PP ) ( )
2yi $B.y b•7 S;41 Jane 9r6uxj%4k
s' s63 �.a S;Icy 50„a Bls�h
13S St) Sw)`� glgoh
lo' 58-5 177 Grgy
I

i
PAGE 1 OF 1
-12•D
PROJECT: 13f y9 LOCATION: 9041
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: BORING: Q -$9-6
DRILLER: er? o DEPTH TO WATER FROMTOC:
SAMPLER TYPE: GEOLOGIST: e
D S B PID U
E A N L / S
P M U O m C
T P M W s GEOLOGIC DESCRIPTION/COMMENTS
($) E R /6" (PPm) ( )
'2h 56-6 D•'{ Gro�Clly S4r� gravqul7 9rty
S' S8-6 D•z Sandy clay �I�cl,
- V/ 5B 6 b.`� $� Icy Sang groLMA 6�4ch
lo` SB 6 / b ��a�c�l� S4nr� grown�hWach

PAGE I OF I
- 2-D
PROJECT:T35TI 7 LOCATION: 8 Z
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: t BORING: .2 • S -
DRILLI 4 DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST:
D S D PID u
E A N L / S
T P M W FID S GEOLOGIC DESCRIPTION/ COMMENTS
(h E E /6" (PPm) (SYm) ^^ T
R M d �D I
'c
—7Yz Its 51 Sand grcwn;l
We-h bfCQvsr, J R"J� fwd,j
on P,rs� Z IA' , Movtd 4x)12

i
PAGE 1 OF 1
PROTECT: y LOCATION: a z
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: (cq BORING: 8 z7
DRILLER: ftk; T-hDft.S THTO WATER FROM TOG:
SAMPLER TYPE: GEOLOGIST:
D S B P]D U
E A N L / s
T P M W FID s GEOLOGICNDESCRIPTION/COMMENTS
(ft & EE W (PPm) (Sym)
-2h, sa•� y,z. 5c Q,00;s1, b kc&
-7'h 5,Q 7 /0,� S:I�y Sa4 grOW4:.c�
Io �6-7 AID lly fated prownisL 5%y
Mbv `d well 2 ' �6 eca�

------------
i
PAGE 1 OF 1
•12•b9
PROJECT: LOCATION: 91j,
.Z
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: 6` BORING: 27-
DRILLER: /( of DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: je# Mgt_
D S B PIDU
E A N L / S
P M U O FID C
T P M W S GEOLOGIC DESCRIPTION/COMMENTS
(ft E ER
16" (PPm) (UM)
-zh 5B 8 b.f Cry„fIly si4 onwn�A
s' S&V cl.gy Bls�h
- 7%L 56 $ b.b Sg4aj Clay Q��i1t
ID SB 8 0 J Sand Cloy Gr4 b

i
n
PAGE 1 OF 1
- z•o
PROJECT: I (y LOCATION: Z�
DATE INSTALLED: ELEVATION: TOC:
DRI LLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: BORING: z7
DRILLER: r1 j� DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: �c
D S B PID U
E A N L / S
P M U 0 FID C
T P M W S GEOLOGIC DESCRIPTION/COMMENTS
(ft E R 161 (PPm) ( )
SNy SQ - grow4 a� $/f4h
s' SB•4 I•z .k��y clFy . 8!«h
3.6 5Wy clay - B/96A
o� SB q S.3 Clgy _ Blsc)t

i
i
PAGE 1 OF 1
Z•0
PROJECT: 131 y47 LOCATION: 2)
DATE INSTALLED; ELEVATION: V TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: Lan BORING: ? _ - p
DRILLER; y; eM DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: j e
D S B PID U
E A N L / S
P M U 0 FID C
T P M w S GEOLOGIC DESCRIPTION/COMMENTS
(fi) E E� /6" (PPm) (�)
-2`h 5B JO ZQ.� Grsvelly Scud - ?ra 4-A jf4 y
sl4y C'Igy Blcck���, q.o y
-9' SB ro No fecDpery
Jo' S6 !0 1.3 S;Icy Clgy Groy-A brown

i
u
PAGE 1 OF 1
2•a9
PROJECT: 131 y ) LOCATION:
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: Lynd BORING: -27 - so I
DRILLER: DEPTH TO WATER FROM TOC:
SAINTLER TYPE: GEOLOGIST:
D S B PID U
E A N L / S
P M U 0 FID C
H L D S m S GEOLOGIC DESCRIPTION/COMMENTS
/6" (pP ) (mo)
-2h' 59•11 &A &Puelly Jc4 grown:Jb �raY
S' 59-11 6.6 5; },� SGnB Brown
-7yL 5>; II 1.Z Clay (�rownit� 9r4y1
)bi Cloy C
ery

i
PAGE 1 OF 1
5- 2-
PROJECT: 131y97 LOCATION: 91j, Z
DATE I NSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: LFga bt BORING: - $ - 12
DRILLER: Ctu' hon DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST:
n s A161'
rID u
E A 'N I s
P M u FID C
T P M s GEOLOGIC DESCRIPTION/COMMENTS
(ft E ER
(PPm) (sym)
-Z S8 IZ 2.2 5.l fy
4' S8 12 0.3 GAvel)y •fen a Qrouw,,'A g.cy
Ufl4�f( To 1, pgl7 `/ ` Ron M to zy'% ,
�1ec;d�a � Moues �a ne�f /octi�`o•n .

i
� PAGE I OF I
PROJECT: y LOCATION: 27
DATE INSTALLED: ELEVATION: _ TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: Laq� of„ BOILING: Z - Sg-/
DRILLER: Kev.k6DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST:
D 5 B PID TUCSGEOLOGIC
O FIDW DESCRIPTION/ COMMENTS
S (ppm)161
-2VE YO-13 p Crovell y s'wJ gro"
4v jr4b ph,wn
-�'A S043 0
lo' 1i CIQy (Brown
p.z : C(ay Gniy
bore`I)9w� a�o}

PAGE I OF 1
S• •o
PROJECT: �LOCATION: gldj Z)
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: tonbory6c. BORING: 0 Z7 -SQ•/N
DRILLER: vn ThDmo-% DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: JJEL
D S B PID U
E A N L / S
T P M w FID S GEOLOGIC DESCRIPTION/COMMENTS
(ft E B 16" (PPm) (sym)
Gravelly Jana 810
s' 5641 b.0 Grnuell y 'Swsa 6re9-'),'A bkrr
-7'/z SG•/y D.S Clay Qrown
10, SB•ly b•y clay

- 2•D
L� PAGE I OF 1
PROJECT: 3 LOCATION: gja, Z
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: Lq4 {, BORING: ? -SE-a-
DRILLER: v: DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST:
D S B PID U
E A N L 1 S
T P M w PID S GEOLOGIC DESCRIPTIONICOMMENTS
(h) E E /61,� (PPm) ( )
Brown
S' SPY 6.q Scgdy Gy y grown IS6 04FA
7 y 58-1S 04 Iq Y Brown
!o• 5B-1S 60 clay erq
Y
MDud so,! bor>n9 .1,4 rLDI 2 '

i
PAGE 1 OF 1
S!2-D
PROJECT: 131 97 LOCATION: (a
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLINGCOMPANY: (4 BORING: Z) - B-
bRILLER: f, Uomq'i DEPTH TO WATER FROMTOC:
SAMPLER TYPE: GEOLOGIST: t
D S B PID U
P M U 0 FID C
T P M w s GEOLOGIC DESCRIPTION/COMMENTS
(ft) B R �6" (PPm) (sym)
-1y: SB/to U,S S: Ify - S&4— Qown
S` 58-1 . 0•� G�ovtlly =Sa,r�— Brown
Clyy- B14ch
ID` 5B !to b.7 Cley - 814

i
�I
e.
PAGE I OF 1
- Z-D
PROJECT: I31'I9 LOCATION: I
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILING COMPANY: „ BORING: Z) •S -1)
DRILLER: Kwr DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: t
D S B MID U
E A N L / S
P M U 0 FID C
T P M W S GEOLOGIC DESCRIPTION/COMMENTS
(ft) E ER /6° (PPm) (SYM)
s ss•)7 1.6 s"4y SCAB — 8117d9
-7V-1 S6.17 I, I CI°y — 81sch
)o, S6-17 b.`� Sandy Clay

PAGE 1 OF 1
- 2-D
PROTECT: I I LOCATION: r
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: LFn� BORING: �.$Ulk
DRILLER: t(tv"n AvAgsDEPTH TO WATERFROM TOC:
SAMPLER TYPE: GEOLOGIST: 1�y
D S B PID U
P M U 0 FID C
T P M W S GEOLOGIC DESCRIPTION/COMMENTS
(ft E E 16.
R (PPm) ( )
-M s61y
s� se ►� r, � s,ray sad - 614�k
-? g r� r. 6 v4y s nb - 6kch
to 5818 !.D Gmvcrl y

- 13-p
L� PAGE 1 OF 1
PROJECT: 1LOCATION: g Z
DATE INSTALLED; ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: L Qr,J BORING: )- Ss-
DRILLER: Kw` DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: J
D S B PID U
E A N L I S
P M U 0 FID C
T P M W S GEOLOGIC DESCRIPTION/COMMENTS
(ft) B R 161. (PPm) ( )
—M 59-19 6.0 S;�fy Sanr� Brown,sl,
S` SB-1q 0,y .S:I fy SNP` B�ow��sR
—7'h sQ-19 p.� S;I+y ����9 (�rown•`sl,
W SR-19 b4 S,)4 arowq,A

PAGE 1 OF 1
-D
PROJECT: f 9 LOCATION: f 2)
DATE INSTALLED: ELEVATION: TOC:
DRILLINGMETHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: Lean BORING: z) -S 9-2p
DRILLER: DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: 3cq !`'DuA-,
D S B PID U
E A N L I S
P M U 0 FID C
T P M W S GEOLOGIC DESCR2TION!COMMENTS
(ft) E EF 16" �Pm) (SM)
-2h.' SB-2� D.y Sandy Clay _/}�own`s�
S' SQ-21) D.7 CI4y 4,
—9h SQ 20 D•t 5,4v San - Brown;l�
lo` S6-2o b, I GrgvCll� SU,J- Brown'ati

i
PAGE I OF I
-0
PROJECT: S� LOCATION: Z
DATE INSTALLED: ELEVATION: TOC:
DRILLING METHOD: TOTAL DEPTH OF WELL:
DRILLING COMPANY: (� BORING: Z? -2
DRILLER: ! o21j, DEPTH TO WATER FROM TOC:
SAMPLER TYPE: GEOLOGIST: L o
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Appendix B
Material Safety Data Sheet (MSDS) for the ORC Advanced
UIC AltachmenlsECUSTA Bldg 27.doc 03/26/10 8:42AM

Oxygen Release Compound (ORC11)
MATERIAL SAFETY DATA SHEET(MSDS)
Last Revised: October 18,2005
Section 1 -Material Identification
Supplier:
lay
REGENESIS
1011 Calle Sombra
San Clemente, CA 92673
Phone: [phone]
Fax: [phone]
E-mail: infona.regenesis.com
Chemical Description: A mixture of Magnesium Peroxide (MgOZ), Magnesium
Oxide(MgO),and Magnesium Hydroxide [Mg(OH)2]
Chemical Family: Inorganic Chemical
Trade Name: Oxygen Release Compound (ORCI)
Product Use: Used to remediate contaminated soil and groundwater
(environmental applications)
Section 2—Chemical Identification
CAS# Chemical
14452-57-4 Magnesium Peroxide (MgO2)
1309-48-4 Magnesium Oxide(MgO)
1309-42-8 Magnesium Hydroxide [Mg(OH)21
7758-11-4 Dipotassium Phosphate OW2O4P)
7778-77-0 Monopotassium Phosphate(H2KO4P)
Assay: 25-35% Magnesium Peroxide(MgO2)
J:\Operations\MSDS\ORC Page 1

Regenesis—ORC MSDS
Section 3 -Physical Data
Melting Point: Not Determined (ND)
Boiling Point: ND
Flash Point: Not Applicable(NA)
Self-Ignition Temperature: NA
Thermal Decomposition: Spontaneous Combustion possible at 150°C
Density: 0.6—0.8 glee
Solubility: Reacts with Water
pH: Approximately 10 in saturated solution
Appearance: White Powder
Odor: None
Vapor Pressure: None
Hazardous Decomposition Not Known
Products:
Hazardous Reactions: Hazardous Polymerization will not occur
Further Information: Non-combustible, but will support combustion
Section 4—Reactivity Data
Product is stable unless heated above 150 °C. Magnesium
Stability: Peroxide reacts with water to slowly release oxygen.
Reaction by product is Magnesium Hydroxide
Conditions to Avoid: Heat above 150°C. Open Flames.
Incompatibility: Strong Acids. Strong Chemical Agents.
Hazardous Polymerization: None known.
7:\0perations\MSDS\HRC MSDS Page 2

Regenesis—ORC MSDS
c.
Section 5 -Regulations
Permissible Exposure Not Established. Should be treated as a nuisance dust.
Limits in Air
Section 6—Protective Measures,Storage and Handling
Technical Protective Measures
Storage: Keep in tightly closed container. Keep away from
combustible material.
Handling: Use only in well ventilated areas.
Personal Protective Equipment(PPE)
Respiratory Protection: Recommended (HE PA Filters)
Hand Protection: Wear suitable gloves.
Eye Protection: Use chemical safety goggles.
Other: NA
Industrial Hygiene: Avoid contact with skin and eyes
Protection Against Fire & NA
Explosion:
Disposal: Dispose via sanitary landfill per stateflocal authority
Further Information: Not flammable, but may intensify a fire
After Spillage/Leakage/Gas Collect in suitable containers. Wash remainder with copious
Leakage: quantities of water.
Extinguishing Media: NA
Suitable: Carbon Dioxide, dry chemicals,foam
Self contained breathing apparatus or approved gas mask
Further Information: should be worn due to small particle size. Use extinguishing
media appropriate for surrounding fire.
After contact with skin, wash immediately with plenty. of
First Aid: water and soap. In case of contact with eyes, rinse
immediately with plenty of water and seek medical attention.
Section 7—Information on Toxicology
J:10perationslMSDS\HRC MSDS Page 3

Regenesis—ORC MSDS
Toxicity Data: Not Available
Section 8—Information on Ecology
Water Pollution Hazard 11
Raging(WGK-):
Section 9—Further Information
After the reaction of magnesium peroxide with water to form oxygen, the resulting
material, magnesium hydroxide, is mildly basic. The amounts of magnesium oxide
(magnesia) and magnesium hydroxide in the initial product have an effect similar to lime,
but with lower alkalinity.
The information contained in this document is the best available to the supplier at the time
of writing, but is provided without warranty of any kind. Some possible hazards have been
determined by analogy to similar classes of material. The items in this document are
subject to change and clarification as more information become available.
J:\Operations\MSDS\HRC MSDS Page 4