DERR-2024-005557

January 2024 Microbe Injection Summary
Report

Brown Strauss Steel
VCP Site #052
800 South Chestnut Street
Salt Lake City, Utah

Prepared for:
Brown Strauss Steel
2495 Uravan Street
Aurora, CO

Prepared by:
Stantec Consulting Services Inc.
2890 East Cottonwood Parkway Suite 300
Salt Lake City UT 84121-7283

Project No.: 203723323

February 29, 2024

Sign-off Sheet and Signature of Environmental Professional
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept
This document was prepared by Stantec Consulting Services Inc. (“Stantec”) for Brown Strauss Steel
(the “Client”). The conclusions in this Report are Stantec’s professional opinion, as of the time of the
Report, and concerning the scope described in the Report. The opinions in the document are
based on conditions and information existing at the time the scope of work was conducted and do
not take into account any subsequent changes. The Report relates solely to the specific project for
which Stantec was retained and the stated purpose for which the Report was prepared. The Report
is not to be used or relied on for any variation or extension of the project, or for any other project or
purpose, and any unauthorized use or reliance is at the recipient’s own risk.
Stantec has assumed all information received from the Client and third parties in the preparation of
the Report to be correct. While Stantec has exercised a customary level of judgment or due
diligence in the use of such information, Stantec assumes no responsibility for the consequences of
any error or omission contained therein.
This Report is intended solely for use by the Client in accordance with Stantec’s contract with the
Client. While the Report may be provided by the Client to applicable authorities having jurisdiction
and to other third parties in connection with the project, Stantec disclaims any legal duty based
upon warranty, reliance or any other theory to any third party, and will not be liable to such third
party for any damages or losses of any kind that may result.

Prepared by
John G. Russell, III, CPG
Sr. Hydrogeologist, Environmental Risk Manager

Reviewed by
Cody Fauth
Geologist

JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept i
Table of Contents
1.0 EXECUTIVE SUMMARY .................................................................................................1.1
1.1 INTRODUCTION ........................................................................................................... 1.1
1.2 BACKGROUND............................................................................................................ 1.1
2.0 JANUARY 20, 2024 GROUNDWATER TREATMENT PROGRAM ....................................2.1
2.1 OVERVIEW OF REMEDIAL INJECTION PRODUCTS AND REMEDIAL INTENT ............... 2.1
2.2 JANUARY 20, 2024 MICROBIAL INJECTION LOCATIONS AND PROCESS ................. 2.2
2.2.1 Preparation in Advance of Injection Program ....................................... 2.2
2.2.2 JANUARY 20, 2024 MICROBIAL INJECTION LOCATIONS AND
PROCESS .................................................................................................... 2.2
3.0 PROPOSED GROUNDWATER QUALITY MONITORING PROGRAM IN PURSUIT OF VCP
SITE CLOSURE ...............................................................................................................3.1
LIST OF FIGURES
Figure 1 Project Location
Figure 2 Site Location
Figure 3 September 2022 Chlorinated VOC Detections above PRGs
LIST OF APPENDICES
APPENDIX A COPY OF REGENESIS' FEBRUARY 2024 APPLICATION SUMMARY REPORT FOR
BROWN STRAUSS STEEL
JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
EXECUTIVE SUMMARY
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept 1.1
1.0 EXECUTIVE SUMMARY
1.1 INTRODUCTION
On behalf of Brown Strauss Steel (BSS) of Aurora, Colorado, Stantec Consulting Services Inc.
(Stantec) has prepared this report to document groundwater treatment activities conducted on
January 20, 2024 at the BSS site located at 800 South Chestnut Street (approximately 2200 West)
in Salt Lake City, Utah. Reference Figures 1 and 2 for regional and site-specific location maps.
The remedial program was administered in accordance with protocol proposed within BSS’
September 2022 Groundwater Monitoring Summary Report, which included a Work Plan for
injection of REGENESIS® Remediation Services’ (REGENESIS) microbe products into the upper nine
feet of the uppermost aquifer at select borings located in inferred upgradient directions in
relation to groundwater monitoring well MW-3.
The injection activities proposed in the summary report were approved by the Utah Department
of Environmental Quality, Voluntary Cleanup Program (UDEQ, VCP) in an approval letter to BSS
dated April 5, 2023. As a result of delays associated with no drilling/injection firms having
availability to support the project during Summer and Fall of 2023, the groundwater treatment
program was not contracted and completed until January 2024. This report provides a summary
of the intended purpose of the groundwater treatment program, field activities associated with
the January 20, 2024 microbial injection program, and future-proposed groundwater monitoring
to investigate the success of the injections in pursuit of VCP site closure.
1.2 BACKGROUND
As agreed between BSS and the UDEQ and detailed in BSS’ May 2022 Site Management Plan
report, the UDEQ stipulated that the VCP site could be formally ‘closed’ by the UDEQ once all
chlorinated aliphatic hydrocarbon constituent concentrations (such as tetrachloroethylene [i.e.,
perchloroethylene, aka PCE], trichloroethylene [TCE], related dichloroethylene [DCE] isomers,
and vinyl chloride [VC], etc.) within groundwater in well MW-3 are below corollary UDEQ
Preliminary Remediation Goal (PRG; i.e., UDEQ Groundwater Quality Protection Standards)
concentrations – for a timeframe of three consecutive, annual groundwater sampling events.
Historical BSS/Stantec reports document soil excavation and off-site disposal actions that were
conducted at localized contaminated soil (source) areas in close proximity and in an inferred
upgradient (hydraulicly) direction (southwest) in relation to groundwater monitoring well MW-3.
Although the historical sources of localized contamination were removed during 2006, and
contaminant concentrations were below corollary PRGs during the July 2021 annual sampling of
well MW-3, the September 2022 sampling results indicated an increase in PCE and vinyl chloride
concentrations above the respective PRGs.

JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
EXECUTIVE SUMMARY
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept 1.2
As identified on Figure 3, the following constituents were quantified in groundwater at well MW-3
during the September 2022 annual sampling event:
− PCE at 10.8 micrograms per liter (i.e., ug/L, aka parts per billion-ppb) [with PRG: 5 ppb].

and

− Vinyl chloride at 12.7 ppb [with PRG: 2 ppb].

Historical monitoring of the site to date indicates that the uppermost aquifer beneath the site is
characterized by anaerobic conditions (i.e., low dissolved oxygen concentrations), which is
promoting natural, reductive dechlorination of chlorinated aliphatic hydrocarbon constituents.
Dechlorination of PCE involves the sequential replacement of a chlorine atom with a hydrogen
atom. This reaction provides energy for growth of bacteria and eventually reduces the
chlorinated compounds to naturally-occurring organic compounds such as ethene and ethane.
The schematic diagram below depicts the natural transformation of PCE to lesser chlorinated,
daughter by-products under typical oxygen-depleted groundwater and reductive
dechlorination processes:

Natural biological transformation (reductive dechlorination) of PCE typically observed in the environment

The intent of the January 2024 microbe injections was to attempt to enhance natural biological
degradation/reductive dechlorination of chlorinated aliphatic hydrocarbon constituents in
groundwater at well MW-3, in pursuit of VCP site closure. Historically, a similar groundwater
treatment program entailing injection of REGENESIS products was successful in reducing similar
contaminant concentrations below respective PRGs at different areas of the site (vicinities of
wells MW-7 and MW-9), as reported within BSS’ May 2012 Post-Microbial Injection and
Groundwater Monitoring Summary Report. The injection program reduced the total timeframe
during which all PRGs were satisfied at both wells, in comparison to the anticipated timeframe
that would have been expected if relying solely on natural degradative processes.
In consideration of historical groundwater quality data associated with well MW-3, and in hopes
of reducing the timeframe that might be required for natural attenuation processes to reduce
contaminant concentrations below corollary PRGs, BSS decided to implement a groundwater
treatment program in the vicinity of well MW-3, in similar fashion as conducted during August
2011 at wells MW-7 and MW-9. As detailed herein, the injection project was completed
upgradient of well MW-3 on January 20, 2024. BSS/Stantec anticipate that the January 2024
microbial injections should prove successful in reducing contaminant concentrations in
groundwater, as documented following the 2011 microbial injections at wells MW-7 and MW-9.

JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
EXECUTIVE SUMMARY
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept 1.3
Annual groundwater sampling at well MW-3 will be used to gauge the success of the recent
groundwater treatment program and progress toward VCP site closure. At this time, BSS
anticipates conducting the next annual groundwater sampling event at well MW-3 during early-
Fall 2024. All groundwater monitoring, sampling, and analytical protocol will be conducted in
accordance with measures, procedures, and protocol outlined with the UDEQ-approved, Site
Management Plan (specifically including report section 3.0 Proposed Work Plan for Annual
Groundwater Sampling of Monitoring Well MW-3).

JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
JANUARY 20, 2024 GROUNDWATER TREATMENT PROGRAM
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept 2.1
2.0 JANUARY 20, 2024 GROUNDWATER TREATMENT PROGRAM
2.1 OVERVIEW OF REMEDIAL INJECTION PRODUCTS AND REMEDIAL INTENT
Since REGENESIS’ injection products used at the site in 2011 proved successful, BSS/Stantec re-
engaged REGENESIS during 2023 to investigate what capabilities and resources REGENESIS might
offer to enhance ongoing natural, biodegradative processes to remediate the chlorinated
hydrocarbons in groundwater located upgradient of well MW-3. Recent and historical, site-
specific information regarding the VCP site hydrogeologic and ground water quality
characteristics were shared with REGENESIS for evaluation of site conditions.
REGENESIS proposed a new remedial program including in-situ injection application of three
proprietary products which are anticipated to work together to enhance natural degradative
breakdown of chlorinated hydrocarbon constituents in groundwater near and downgradient of
injection-points. REGENESIS recommended a combination of its 3-D, Microemulsion® (3DME),
Sulfidated-Micro Zero Valent Iron® (S-MZVI), and microbial Bio-Dechlor Inoculum Plus® (BDI Plus)
products for injection within the uppermost aquifer upgradient of well MW-3. REGENESIS
proposed injecting the products at eight boreholes located upgradient (generally southwest) of
well MW-3, as discussed in following report section 2.2 January 20, 2024 Microbial Injection
Locations and Process.
More specific details regarding each of these products and the January 20, 2024 injection
program are summarized in REGENESIS’ February 13, 2024 Application Summary Report for Brown
Strauss Steel, a copy of which is presented as Appendix A herein. In summary, the new product
formulation differs slightly from that injected at wells MW-7 and MW-9 during 2011, such that the
2024 remedial products are anticipated to affect an enhanced dechlorination degradative
process. The new formulation allows for the traditional reduction pathway to be augmented,
minimizing the formation of daughter species such as vinyl chloride, as generalized below:

Chlorinated ethene degradation pathways and products
The top pathway with single line arrows in the above schematic diagram represents the
traditional reductive dechlorination (hydrogenolysis), degradative pathway. The lower pathway
with downward facing double line arrows represents beta elimination pathways.
JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
JANUARY 20, 2024 GROUNDWATER TREATMENT PROGRAM
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept 2.2
2.2 JANUARY 20, 2024 MICROBIAL INJECTION LOCATIONS AND PROCESS
2.2.1 Preparation in Advance of Injection Program
In advance of the project, Stantec subcontracted GPRS, Inc., a nationally recognized Ground
Penetrating Radar (GPR) consulting firm, to conduct a local GPR buried utility-locate throughout
the proposed injection area southwest of well MW-3. Stantec also coordinated a formal Blue
Stakes of Utah Utility Locators’ utility-locate. Likewise, Stantec communicated with on-site BSS
staff regarding potential buried utilities in the general area. No buried utilities were identified
within the proposed injection area and none were encountered during the project.
All REGENESIS injection products were delivered to the BSS site a few days before January 20,
2024. Stantec, REGENESIS, and drilling team representatives completed a different injection
project at a different site located in Salt Lake City, Utah on January 19, 2024. The team mobilized
all drilling/injection equipment to the BSS site on the afternoon of September 19th and then
started the BSS injection project on the morning of Saturday January 20, 2024.
Site access, proposed project details, and health and safety related concerns were discussed
with on-site BSS representatives, with all field activities coordinated through BSS’ on-site
Operations Manager, Mr. Nicholas (Nick) Bustamante. Prior to starting the project, a jobsite
safety inspection was completed and documented, with introductory communications related
to on-site, potential hazards, directions to the closest hospital, and emergency contacts
discussed and documented.
2.2.2 January 20, 2024 Microbial Injection Locations and Process
On January 20, 2024, Stantec geologist, Mr. Cody Fauth, observed REGENESIS and its
subcontracted drilling firm, Interphase Drilling, inject microbial products at eight (8) different
injection-point boreholes. Each borehole was advanced by the direct-push boring process,
whereby products were then pressure-injected, utilizing downhole, steel rods, from the ground
surface into the upper nine feet of the aquifer (generally between 5 to 14 feet below grade; i.e.,
the water table was around five feet below grade). An on-site, BSS potable water source was
used for slurry-mixing REGENESIS products within a REGENESIS portable trailer located near the
MW-3 wellhead.
As depicted below, the portable trailer was equipped with two interior 350-gallon mixing tanks,
pumps, and delivery systems manifolded for direct connection to each of the injection-points.
Mixed REGENESIS products were pressure-slurried into each injection-point assembly, as was
photo-documented and is presented in the attached REGENESIS summary report. In summary,
the products were injected at an average injection rate approximating 2.62 gallons per minute
(gpm) and an average injection pressure of 11 pounds per square inch (psi). A total of 1,370
gallons of product were injected into the subsurface (approximately: 800 pounds of 3DME, 200
pounds of S-MZVI, and 18 liters of BDI Plus).
JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
JANUARY 20, 2024 GROUNDWATER TREATMENT PROGRAM
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept 2.3

General schematic of portable trailer, as discussed in greater detail in attached REGENESIS summary report
The inferred, historical groundwater flow direction since monitoring began in 2007 has been
consistently from the southwest toward the northeast beneath the VCP site. As generalized in the
below schematic diagram, the injection-point locations were proposed by REGENESIS to provide
an anticipated, optimal injection-pattern in relation to well MW-3 and former source areas
located southwest of the well. Reference Figure 2 in REGENESIS’ Application Summary Report for
Brown Strauss Steel presented as Appendix A herein for an aerial figure identifying the locations
of the eight injection-points, as superimposed atop Stantec Figure 3 herein.

Injection-points

JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
PROPOSED GROUNDWATER QUALITY MONITORING PROGRAM IN PURSUIT OF VCP SITE CLOSURE
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept 3.1
3.0 PROPOSED GROUNDWATER QUALITY MONITORING PROGRAM IN
PURSUIT OF VCP SITE CLOSURE
Currently and for the foreseeable future (continued industrial land use), the site poses little to no
risk to human health and the environment, as detailed within numerous preceding reports
including BSS’ May 2022 Site Management Plan. As agreed between BSS and the UDEQ, BSS will
conduct annual sampling of well MW-3 following the January 2024 injections. All groundwater
monitoring, sampling, and analytical protocol associated with well MW-3 will be conducted in
accordance with procedures outlined with the UDEQ-approved, Site Management Plan
(specifically including Section 3.0 Proposed Work Plan for Annual Groundwater Sampling of
Monitoring Well MW-3).
It is proposed that the annual sampling event be conducted during early-Fall. The annual
qualitative observations and quantitative analytical results, including a copy of the laboratory
result report, will be documented in a Summary Report that will be submitted to the UDEQ within
a few weeks following receipt of each respective laboratory report, each year.
Once all chlorinated aliphatic hydrocarbon constituent concentrations in well MW-3 are below
respective PRGs for three consecutive annual sampling events, BSS proposes that the VCP site
be closed at that time, as deemed acceptable to the UDEQ. If future monitoring results indicate
that satisfying PRGs at well MW-3 will not be achieved within the next few years, and/or if BSS
prefers to attempt to close the VCP site in a different manner, BSS will consult with the UDEQ to
discuss other options for pursuing VCP site closure, at that time.
If PRGs are satisfied at well MW-3, proposed site closure activities would include abandoning of
all groundwater monitoring wells by a Utah-certified, well drilling firm, as well as addition of a site-
specific Environmental Covenant to the property deed, as already discussed with the UDEQ. The
Environmental Covenant would document that site land use would remain industrial and shallow
groundwater beneath the site will not be used for irrigation, potable, or other usage.

JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
FIGURES
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept
Figure 1 Project Location
Project Location
Client/Project
Figure No.
Title
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VCP Site C052
Brown Strauss Steel
Notes
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203706019
T11N, R12E, S05
Salt Lake County, Utah
Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data.
Prepared by NF on 2014-09-15
Technical Review by ABC on 2014-01-16
Independent Review by ABC on 2014-01-16
Coordinate System: NAD 1983 UTM Zone 12N
Service Layer Credits: Sources: Esri, HERE, DeLorme, USGS, Intermap,
increment P Corp., NRCAN, Esri Japan, METI, Esri China (Hong
Kong), Esri (Thailand), TomTom, MapmyIndia, © OpenStreetMap
ProjectLocation
JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
FIGURES
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept
Figure 2 Site Location

Project Location
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Brown Strauss Steel
Notes
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203706019
T11N, R12E, S05
Salt Lake County, Utah
Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data.
Prepared by NF on 2014-09-15
Technical Review by ABC on 2014-01-16
Independent Review by ABC on 2014-01-16
Coordinate System: NAD 1983 UTM Zone 12N
Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, i-cubed,
USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and
the GIS User Community
ProjectLocation
JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
FIGURES
February 29, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept
Figure 3 September 2022 Chlorinated VOC Detections above PRGs
Project Location
Client/Project
Figure No.
Title
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September 2022 Chlorinated VOC Detections above PRGs
3
VCP Site C052
Brown Strauss Steel
Notes1.
2.
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203706019
T11N, R12E, S05
Salt Lake County, Utah
Disclaimer: Stantec assumes no responsibility for data supplied in electronic format. The recipient accepts full responsibility for verifying the accuracy and completeness of the data. The recipient releases Stantec, its officers, employees, consultants and agents, from any and all claims arising in any way from the content or provision of the data.
Prepared by NF on 2015-11-19
Technical Review by TH on 2015-11-19
Independent Review by JR on 2015-11-19
Coordinate System: NAD 1983 UTM Zone 12N
Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar
Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping,
Aerogrid, IGN, IGP, swisstopo, and the GIS User Community
ProjectLocation
All results in ug/l; PPB
ND - Not Detected
NS - Not Sampled
Preliminary Remediation Goal - PRG
PCE - Tetrachloroethene 5
5
none
70
100
2
TCE - Trichloroethylene
DCA - Dichloroethane
DCE - Dichloroethene
cis-1,2-DCE:
trans-1,2-DCE
VC - Vinyl Chloride
JANUARY 2024 MICROBE INJECTION SUMMARY REPORT
Appendix A Copy of REGENSIS’ February 2024 Application Summary Report for Brown Strauss Steel
March 5, 2024
Project No.: 203723323/05-Reports/2024/Microbial Injection SumRept
Appendix A Copy of REGENSIS’ February 2024 Application Summary
Report for Brown Strauss Steel

Global Headquarters
1011 Calle Sombra
San Clemente, CA 92673
Ph: [phone]
Fax: [phone]

Sincerely,

Will Mohan Isaac Gregg
Will Mohan Isaac Gregg
Senior Project Supervisor West Region Project Manager
REGENESIS Remediation Services REGENESIS Remediation Services

2/13/2024 REGENESIS Proposal No. BRG65686
John Russell
Stantec
2890 East Cottonwood Parkway, Suite 300
Salt Lake City, Utah, 84121
SUBJECT: Application Summary Report for Brown Strauss Steel
John,
REGENESIS Remediation Services (RRS) has recently completed an in-situ injection application of 3-D
Microemulsion (3DME), S-MicroZVI (S-MZVI), and Bio-Dechlor Inoculum Plus (BDI Plus) at Brown Strauss
Steel, 800 Chestnut St, Salt Lake City, UT 84104. The goal of this application was to install an upgradient
grid to treat the chlorinated volatile organic compounds (VOC) found onsite.
RRS mobilized a support pickup truck, injection trailer, and personnel to the site to begin work over one
(1) day. On-site injection operations began on 1/20/2024 and finished on 1/20/2024. RRS staffed this
project with experienced project personnel who ensured a safe and successful injection application.
RRS applied the combined above mentioned remediation technologies to eight (8) direct push technology
(DPT) injection points over the event duration. The target treatment zone for the contaminants ranges
from 5 to 14 feet below ground surface (ft. bgs).
Please review the attached application summary page, map, injection log, and photo log for more details
on the application.
RRS appreciates the opportunity to work onsite with Stantec. RRS will be available to interpret the field
data as it is collected or answer any questions. If you need additional information regarding the
application process or attached field notes, please contact Isaac Gregg ([e-mail]) or Will
Mohan ([e-mail]).

Global Headquarters
1011 Calle Sombra
San Clemente, CA 92673
Ph: [phone]
Fax: [phone]

Table of Contents
1. Overview ............................................................................................................................................... 3
2. Treatment Technology.......................................................................................................................... 3
3. Design.................................................................................................................................................... 4
A. Injection Area.................................................................................................................................... 4
4. Application ............................................................................................................................................ 6
A. Job Site Inspection ............................................................................................................................ 6
B. Injection Sequence............................................................................................................................ 7
5. On-Site Work Summary ........................................................................................................................ 8
A. Injection Area.................................................................................................................................... 8
Appendix A: Injection Log ............................................................................................................................. 9
Appendix B: Photo Log................................................................................................................................ 11
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1.Overview
Client: Stantec
Project Name: Brown Strauss Steel
Client Project Manager: John Russell Site Address: 800 Chestnut St, Salt Lake City, UT 84104
RRS Project Manager: Isaac Gregg Project Dates: 1/20/2024 - 1/20/2024
RRS Project Supervisor: Will Mohan
2.Treatment Technology
RRS applied 3-D Microemulsion (3DME), S-MicroZVI (S-MZVI), and Bio-Dechlor Inoculum Plus (BDI Plus) to
remediate the treatment area.
3-D Microemulsion®
3-D Microemulsion (3DME ® ) is comprised of a patented molecular structure containing oleic acids (i.e.,
oil component) and lactates/polylactates, which are molecularly bound to one another (figure 1). The
3DME molecule contains both a soluble (hydrophilic) and insoluble (lipophilic) region. These two regions
of the molecule are designed to be balanced in size and relative strength. The balanced
hydrophilic/lipophilic regions of 3DME result in an electron donor with physical properties allowing it to
initially adsorb to the aquifer material in the area of application, then slowly redistribute via very small
3DME “bundles” called micelles. These 3DME micelles spontaneously form within sections of the aquifer
where concentrations of 3DME reach several hundred parts per million. The micelles’ small size and
mobility allow it to move with groundwater flow through the aquifer matrix, passing easily through the
pore throats in between soil grains resulting in the further redistribution of 3DME within the aquifer. This
allows for advective distribution of the oleic acids which are otherwise insoluble and unable to distribute
in this manner, allowing for increased persistence of the lactate/polylactates component due to their
initial attachment to the oleic acids.
Due to its patented molecular structure, 3DME offers far greater transport when compared to blended
emulsified vegetable oil (EVO) products, which fail to distribute beyond the limits of pumping. 3DME also
provides greater persistence when compared to soluble substrates such as lactates or simple sugars. The
3DME molecular structures capitalize on the best features of the two electron-donor types while at the
same time minimizing their limitations. 3DME is delivered to the site as a ready-to-apply emulsion that is
simply diluted with water to generate a large volume of a 3DME colloidal suspension.
Application Summary
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Sulfidated-Micro Zero Valent Iron®
S-MZVI is a concentrated aqueous suspension of sulfidated, colloidal zero valent iron formulated for
compatibility with PlumeStop. When applied to the subsurface it imparts an ISCR mechanism that allows
for the destruction of chlorinated ethenes (i.e., TCE) via abiotic degradation pathways. This unique
mechanism allows for the traditional reduction pathway to be circumvented, minimizing the
formation of daughter species such as vinyl chloride (Figure 1). Sulfidation blocks the effects of water on
the ZVI particles, allowing the reagent to be effectively focused on the chemical reduction of chlorinated
ethenes.
Figure 1: Chlorinated ethene degradation pathways and products. The top pathway with single line
arrows represent the reductive dechlorination (hydrogenolysis) pathway. The lower pathway with
downward facing double line arrows represent the beta elimination pathway.
Bio-Dechlor INOCULUM Plus®
Bio-Dechlor INOCULUM Plus (BDI PLUS®) is an enriched natural consortium containing species of
Dehalococcoides sp. (DHC). BDI PLUS has been shown to simulate the rapid and complete dechlorination
of chlorinated solvents such as tetrachloroethene (PCE), trichloroethene (TCE), dichloroethene (DCE)
and vinyl chloride (VC) to non-toxic end products, ethene, carbon dioxide and water.
The culture also contains microbes capable of dehalogenating halomethanes (e.g., carbon tetrachloride
and chloroform) and haloethanes (e.g., 1,1,1-TCA and 1,1-DCA) as well as mixtures of these
contaminants.
Additional information about these products can be found at regenesis.com.
3.Design
A.Injection Area
As seen on the injection map (Figure 2), the injection area is located upgradient of MW-3 and consists of
8 injections points in a grid.
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The grid is approximately 600 square feet and has a vertical treatment interval of 9 feet (5 ft. to 14 ft. bgs).
The grid design required 800 pounds of 3DME, 200 pounds of S-MZVI, and 18 liters of BDI Plus. The
products were mixed with water in the same batch tanks and injected at the same time. The BDI Plus was
slip-streamed into each injection line around the midway point of the injection interval. Additional design
specifications are provided in Table 1.
Figure 2: Map of Brown Strauss Steel Injection Area.
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Table 1: 3DME, S-MZVI, BDI Plus Design Summary.
4.Application
A.Job Site Inspection
REGENESIS Remediation Services (RRS) arrived on-site on 1/20/2024. A health and safety tailgate meeting
was performed with all field staff present. RRS performed site reconnaissance to become familiar with the
project site, water source, traffic pattern adjustments, hospital locations, and potential hazards. A jobsite
safety inspection was completed and documented. Other hazards discussed included slips, trips, and falls
resulting from several injection hoses lying on the ground, ice and snow, and large stacks of metal found
onsite. Once completed, the injection trailer was staged and prepared for product transfer and mixing.

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B. Injection Sequence
RRS applied the Regenesis technologies by mixing the products in the RRS injection trailer and injecting
through 1.5-inch DPT injection tool string fitted for 0.75‐inch diameter injection hosing, as shown on
Figure 3. The injection trailer is fully enclosed and contains mixing tanks, pumps, and delivery system
equipped for direct connection to the injection wells. The application pump is a multiple diaphragm
positive displacement pump designed to prevent pulsation of the remediation products while being
applied. The application pump can deliver the remediation products at up to 250 pounds per square inch
(PSI) and 20 gallons per minute (GPM).
Safety bypass mechanisms are installed to release back pressure buildup in the event injection pressures
exceed commonly accepted application ranges. RRS delivered the remediation products at up to four (4)
separate delivery lines simultaneously, each having the capability of monitoring injection pressures and
injection flowrates/totals at any given time. Each delivery line can reach beyond the injection trailer at
least 100 linear feet, limiting the need to move the injection trailer from point to point or in this case
limiting the need to move the trailer several times each day. Additional line extensions were utilized when
necessary to increase the trailer range without being moved.
The remedial solution was prepared in two (2) 350‐gallon conical tanks that are configured with chemically
resistant materials. Mixing water was provided by an on-site property water connection and fitted for a
standard garden hose that output as a direct source to the RRS injection trailer. Once water was filled to
the appropriate volume per the design concentration, each product was transferred from their respective
container via an air‐driven diaphragm pump. Product containers were measured and marked to track
volumetric batch amounts to ensure accurate product dosing.

Figure 3: RRS Trailer Schematic - DPT injection.

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5. On-Site Work Summary
A. Injection Area
Table 2: Total Amount Applied.

A total of 1,370 gallons of 3DME, S-MZVI, and BDI Plus was applied in the treatment area (Tables 2 &
3).
Application Method: Direct Push Technology using 3-foot retractable screen
Injection Depth: 5 - 14 feet below ground surface
Number of Injection Points: 8
Average Injection Rate: 2.62 GPM; Average Injection Pressure: 11 PSI

For a detailed injection log of the remediation application, please see Appendix A; Table 3 for details.

3DME 800 pounds
S-MZVI 200 pounds
BDI Plus 18 liters

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Appendix A: Injection Log

Beginning Flow
Meter (gal)
Ending Flow
Meter (gal)
Gallons Injected
Per Interval
1/20/2024 11:34 11-14 12 2.70 0.0 57 57.0 33.3 8.3 0.75
1/20/2024 11:55 8-11 11 2.80 57.0 114 57.0 33.3 8.3 0.75
1/20/2024 12:04 5-8 10 2.50 114.0 171 57.3 33.4 8.4 0.75
1/20/2024 11:35 11-14 12 2.70 0.0 57.0 57.0 33.3 8.3 0.75
1/20/2024 11:55 8-11 12 2.80 57.0 114.0 57.0 33.3 8.3 0.75
1/20/2024 12:04 5-8 9 2.50 114.0 171.3 57.3 33.4 8.4 0.75
1/20/2024 9:52 11-14 11 2.40 0.0 57 57.0 33.3 8.3 0.75
1/20/2024 10:30 8-11 10 2.50 57.0 114 57.0 33.3 8.3 0.75
1/20/2024 10:54 5-8 8 2.80 114.0 171 57.3 33.4 8.4 0.75
1/20/2024 11:36 11-14 13 2.80 0.0 57.0 57.0 33.3 8.3 0.75
1/20/2024 11:55 8-11 12 2.70 57.0 114.0 57.0 33.3 8.3 0.75
1/20/2024 12:04 5-8 10 2.50 114.0 171.3 57.3 33.4 8.4 0.75
1/20/2024 11:38 11-14 12 2.70 0.0 57 57.0 33.3 8.3 0.75
1/20/2024 11:55 8-11 11 2.60 57.0 114 57.0 33.3 8.3 0.75
1/20/2024 12:04 5-8 10 2.50 114.0 171 57.3 33.4 8.4 0.75
1/20/2024 9:52 11-14 12 2.50 0.0 57.0 57.0 33.3 8.3 0.75
1/20/2024 10:30 8-11 10 2.60 57.0 114.0 57.0 33.3 8.3 0.75
1/20/2024 10:54 5-8 11 2.80 114.0 171.3 57.3 33.4 8.4 0.75
1/20/2024 9:52 11-14 11 2.50 0.0 57 57.0 33.3 8.3 0.75
1/20/2024 10:30 8-11 11 2.60 57.0 114 57.0 33.3 8.3 0.75
1/20/2024 10:54 5-8 11 2.80 114.0 171 57.3 33.4 8.4 0.75
1/20/2024 9:52 11-14 13 2.50 0.0 57.0 57.0 33.3 8.3 0.75
1/20/2024 10:30 8-11 10 2.60 57.0 114.0 57.0 33.3 8.3 0.75
1/20/2024 10:54 5-8 10 2.80 114.0 171.3 57.3 33.4 8.4 0.75
1370.0 800.0 200.0 18.00
Volume of Solution Injected
Pounds of
3DME per
Interval
Pounds of
MicroZVI per
Interval
Injection Point Date Time
Injection Depth
(feet)
Injection
Pressure (psi)
Flow Rate
(gpm)
7
8
1
2
3
4
5
6
171.3
171.3
171.3
171.3
171.3
171.3
Total Gallons
Per Location
171.3
171.3
Total
Gallons:
Pounds of
3DME Per
Location
100 25
100 25
100 25
100 25
100 25
100 25
Liters of BDI
Per Interval
Total Liters
of BDI
Total Lbs. of
3DME
Total Lbs. of
S-Micro ZVI
100 25
100 25
3-Foot Screen
3-Foot Screen
3-Foot Screen
3-Foot Screen
3-Foot Screen
Stantec-Brown Strauss Steel
Injection Summary Log
MW-3 Treatment Area
Table 3
Pounds of S-
Micro ZVI Per
Location
3-Foot Screen
3-Foot Screen
3-Foot Screen
Comments Injection Tooling

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Appendix B: Photo Log

Photo 1: ↑ On-site view of Brown Strauss Steel injection area. ↑
Photo 2: ↓ On-site water source to fill RRS mixing tanks. ↓

Photo 3: ↑ RRS trailer on-site getting prepared to perform injections. ↑

Photo 4: ↓ Injections being performed by RRS and the drill crew. ↓