WI0400345_Permit (Completion)_20220725

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHAR) E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
July 25, 2022
Kate Dugan, General Counsel and Corp. Secretary
Energizer Holdings, Inc.
419 Art Bryan Drive
Asheboro, NC 27203
Re: Injection Permit WI0400345
Energizer Battery Facility
419 Art Bryan Drive
Asheboro, Randolph County, NC 27203
Sent electronically and via U.S. Postal Service
Dear Ms. Dugan:
In accordance with your permit modification application received May 19, 2022, and additional
information received July 11, 2022, we are forwarding this permit to construct and operate in -situ
groundwater remediation injection wells located at the above referenced facility. This permit shall be
effective, unless revoked, from the date of issuance until August 30, 2024 (expiration date of original
permit), and shall be subject to the conditions and limitations stated therein, including the requirement to
submit a Final Project Evaluation (FPE) as stated in PART VI — MONITORING AND REPORTING
REQUIREMENTS. Please read the entire permit to ensure that you are aware of all compliance
requirements of the permit.
Please note the following:
Per permit conditions Part VI.3 &4, and IX.2(G), within 30 days after each injection event, if
applicable, please provide the well construction (if not previously submitted) and injection
information on the applicable forms listed below. Note: if well construction/abandonment
information is essentially the same (e.g., direct push points or geo-probes), then only one GW-1
or GW-30 form is needed. Just indicate in the comments section on the form the total number of
well points. These forms are available on the Division of Water Resources' website at
https://deq.nc. gov/about/divisions/water-resources/groundwater-resources/underground-inj ection-
control-wells-uic-program
➢ Injection Event Record (IER)
➢ Well Construction Record (GW-1), if applicable
➢ Well Abandonment Record (GW-30), if applicable
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an
application to renew the permit 120 days prior to its expiration date. As indicated in the permit, this
permit is not transferable to any person without prior notice to, and approval by, the Director of the
Division of Water Resources (DWR). If you have any questions regarding your permit or the
Underground Injection Control Program, please call me at [phone].
North Carolina Department of Environmental Quality - Division of Water Resources
Mailing address: 1636 MSC, Raleigh NC 27699-1636
NORTH OAROLJNA Physical address: 512 North Salisbury Street, Raleigh NC 27604
UeparlmeM of E AkonmenW OeWN_00�
919.707.9000

Best Regards,
2{ "ice
Michael Rogers, P.G.- NC & FL (inactive)
Underground Injection Control (UIC) Program Manager
Division of Water Resources
Groundwater Resources Section
cc: Winston-Salem Regional Office, WQROS (sent electronically)
Alan Martin, ERM NC, Inc. (sent electronically)
North Carolina Department of Environmental Quality - Division of Water Resources
�J/j� Mailing address: 1636 MSC, Raleigh NC 27699-1636
NORTH cnaou NnD � v Physical address: 512 North Salisbury Street, Raleigh NC 27604
I)Wanmem of Envlmnmenml Oual�
919.707.9000

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY (DEQ)
RALEIGH, NORTH CAROLINA
PERMIT FOR THE USE 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
Energizer Holdings, Inc.
Randolph County
WI0400345
FOR THE CONSTRUCTION AND/OR OPERATION OF 16 (SIXTEEN) NEW AND 10 (TEN)
EXISTING IN SITU GROUNDWATER REMEDIATION, INJECTION WELL(S) defined in
Title 15A North Carolina Administrative Code 2C .0209(5)(b)(viii), to inject sodium
permanganate for the remediation of groundwater contaminated with volatile organic compounds
(VOCs). Further, permission is granted to initiate pneumatic fracturing in the 16 proposed new
injection wells. These injection wells/points will be located at the Energizer Battery Facility, 419
Art Bryan Drive, Asheboro, NC 27203, and will be operated in accordance with the permit
modification application received May 19, 2022, and in conformity with the specifications and
supporting data submitted July 11, 2022, all of which are filed with the Department of
Environmental Quality and are considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the Water
Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an injection
well shall be in compliance with Title 15A North Carolina Administrative Code 02C .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 issuance until August 30, 2024
(expiration date of original permit).
Permit issued the 251h day of July 2022
Docu Signed by:
F-4EC sm .
for Richard Rogers, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0400345 PAGE 1 OF 8
ver. 9-1-2020 UIC-GW Remediation

PART I — PERMIT GENERAL CONDITIONS
The Permittee shall 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).
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 [ 15A
NCAC 02C .0211(k)].
3. This permit is valid only for construction or operation 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 Division of Water Resources (DWR) [15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. In the event there is a desire
for the facility to change ownership, or there is a name change of the Permittee, a formal permit
amendment request and any supporting materials must be submitted at least 30 days prior to
the date of the change [ 15A NCAC 02C .0211(o)] .
5. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other local,
state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit does
not imply that all regulatory requirements have been met [15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(b)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(h)(17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(h)(4)].
4. Bentonite grout shall not be used to seal any water -bearing zone with a chloride concentration
equal to or greater than 1,500 milligrams per liter. In areas where elevated chloride levels are
known to exist or are probable, such as coastal areas, chloride levels shall be verified in the
field to determine existing conditions. [15A NCAC .0225(h)(8)].
5. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well shall be secured with a locking cap as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(h)(23)].
Permit No. WI0400345 PAGE 2 OF 8
ver. 9-1-2020 UIC-GW Remediation

6. Each injection well shall be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .02250)(3)].
7. Each permanent injection well shall have a permanently affixed identification plate [15A
NCAC .0225(h)(20)].
8. If not previously submitted, a copy of the completed Well Construction Record (Form GW-1)
shall be submitted as described in Part VI.3 of this permit (the original document goes to the
address indicated on the form).
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing or operating any injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-707-9000, and the Winston-Salem Regional Office staff, telephone number 336-
776-9800.
PART IV - OPERATION AND USE CONDITIONS
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 [I 5A NCAC 02C
.0211(i)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [ 15A NCAC 02C
.0206].
3. The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted activity [ 15A NCAC 02C
.0211(i)] .
4. In the event that the facility fails to perform satisfactorily resulting in the creation of nuisance
conditions, failure of the injection zone to adequately assimilate the injected fluid, or
daylighting, the Permittee shall take immediate corrective actions including, but not limited
to, repairs, modifications, or abandonment of the injection facility. The Permitee shall report
non-compliance according to Part VI.7 of this permit [15A NCAC 02C .0206].
5. Fracturing process shall not result in the fracturing of any confining units or otherwise cause
or contribute to the migration of contamination into uncontaminated areas, or otherwise
cause damage to buildings, wells, septic systems, underground storage tanks, and
underground utilities
Permit No. WI0400345 PAGE 3 OF 8
ver. 9-1-2020 UIC-GW Remediation

PART V -INSPECTIONS [15A NCAC 02C .02110)]
Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) 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. DWR representatives shall have reasonable access for purposes of inspection, observation, and
sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VI - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan revised per Additional Information received July 11, 2022, shall
be followed (Attachment A). Any additional monitoring, including groundwater, surface
water, or soil sampling, deemed necessary to ensure surface water and groundwater protection
may be established and an acceptable sampling reporting schedule shall be followed [15A
NCAC 02C .0225(k)].
2. An Annual Report with all historical monitoring results shall be submitted in bound hard copy
format with attached CD or flash drive to the UIC Program Central Office, and Winston-Salem
Regional Office starting within one year of the first injection event. Monitoring reports shall
include, a summary of injection activities and monitoring results, analytical data presented in
a spreadsheet distinguishing between pre -injection and post injection data, and an update on
the status and location of monitoring and injection wells. Well locations may be given in a
table with the name and geographic coordinates or shown on an updated version of the site
map [15A NCAC 02C .0225(1)].
3. Records of well construction (GW-1), repair, or abandonment (GW-30) shall be submitted
within 30 days of completion of such activities [15A NCAC 02C .0225(1)].
4. An Injection Event Record (IER) shall be submitted within 30 days of each individual injection
event [15A NCAC 02C .0225(1)].
5. The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps. PLEASE NOTE: Injectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02L .0202, whichever is greater, in order for this permit to be closed. Otherwise, corrective
action as described in Part VII ma., b�quired [15A NCAC 02C .0225(1)].
Permit No. WI0400345 PAGE 4 OF 8
ver. 9-1-2020 UIC-GW Remediation

6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Water Quality Regional Operations
NC Division of Water Resources and WQROS Winston-Salem Regional Office
1636 Mail Service Center 450 W. Haines Mill Road
Raleigh, NC 27699-1636 Winston-Salem, NC 27105
7. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule
15A NCAC 02C .0211(p), noncompliance notification shall be as follows:
(A) Oral notification shall be given within 24 hours of the occurrence, or first knowledge
of the occurrence, to the Winston-Salem Regional Office, telephone number 336-
776-9800.
(B) Written notification shall be made within five days of the occurrence and submitted
to the addresses in Item #6 above.
(C) The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
PART VII - CORRECTIVE ACTION [I 5A NCAC 02C .0206]
Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of injectants or reaction
byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
(B) Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206, depending
on the type, concentration, and distribution of the groundwater quality standards being
exceeded.
PART VIII - PERMIT RENEWAL [15A NCAC 02C .0211(h)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
Permit No. WI0400345 PAGE 5 OF 8
ver. 9-1-2020 UIC-GW Remediation

PART IX - CHANGE OF WELL STATUS [15A NCAC 02C .0240]
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 .0240, 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 .0240, including but not limited to the following:
(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 WQROS staff 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) In 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 .0225(1) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2)(G) shall be submitted to:
UIC Program
DEQ-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Permit No. WI0400345 PAGE 6 OF 8
ver. 9-1-2020 UIC-GW Remediation

PART X — WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0225(a)]
1. Some effects reported to be associated with the product proposed to be used are as follows:
eye, skin, nose, throat, and lung irritation. If the product is released into the environment in a
way that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, and
protective clothing. Face and body protection should be used for anticipated splashes or
sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0400345 PAGE 7 OF 8
ver. 9-1-2020 UIC-GW Remediation

ID
f'
Grou.dwaw
Fuld
Ekrw won
Parannerb ra'
A*02
x
x
W-19C1
x
x
lmwzz
x
x
gwv-23
x
x
A %L24
x
x
AV-25
x
x
M-29b
x
x
]&01
x
x
}&02
x
x
]&03
x
x
7B-04,4
x
x
7B-04H
x
x
]6-05'
x
x
78-06-
x
74
DE47'
x
x
784W
x
x
)&-o9-
x
x
pro•
x
x
ATTACHMENT A
ANALYSES
VOCa
f3wxsrie
(EPA S260
SIFAI
x
x
x
x
x
x
x
x
x
x
x
x
x
X
x
x
x
iAanganege
;EPA200 7p
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
A
TOTAL
PERFDRMA14CE MONFFORING SCHEDULE
DAsaiNE
3-
6•
12-
PAONTH
MDHTH
MONTH
T
#
1K
•
■
v
#
■
v
v
!
•
T
T
•
•
y
r
•
v
T
!
T
T
T
T
T
T
#
T
T
1
T
T
1
T I
v
v
•
T
T
�
•
►
T
1
T
T
T
T
T
v
10
19
is
�$
N07ES
a -Field params�qm mcW&alW aosd W&Vy. dated, pH, oomipt". h r,"ratw+w. dissoFred mywn. and rr b pchr3 a;.
2 - (A.WC- F". per swoM for VOCa pf a VUG hv bknw WX be wxdudBd breads Q_Qt owusinfog voc sample -a
Permit No. WI0400345 PAGE 8 OF 8
ver. 9-1-2020 UIC-GW Remediation