WQ0006992_Permit Rescission_20200929

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Water Resources
Environmental Quality
January 26, 2017
W. Scott Snow, P.E.
Environmental Engineer
Oracle Flexible Packing / LLFlex
220 Polo Road
Winston-Salem, NC 27105
Subject: Permit Rescission
Permit No. WQ0006992
Non -Discharge Groundwater Remediation Permit
Forsyth County
Dear Mr. Snow:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretarl-
S. JAY ZIMMERMAN
Director
Reference is made to your request for rescission of the subject permit located at 220 E. Polo Road, Winston-
Salem, North Carolina. Staff from the Winston-Salem Regional Office has agreed that a permit is no longer
required. Therefore, in accordance with your request, Non -Discharge Groundwater Remediation Permit
WQ0006992 is rescinded, effective immediately.
If in the future, you wish to operate a Non -Discharge Groundwater Remediation system, you must first
apply for and receive a new permit. Operating an injection system without a valid permit may result in the
assessment of civil penalties and/or the use of other enforcement mechanisms available to the state.
If it would be helpful to discuss this matter further. please do not hesitate to call Michael Rogers at
[phone].
Sincerely,
L6, J, l
4
Jay Zimmerman, P.G., Director
Division of Water Resources
cc: Winston-Salem Regional Office - WQROS
Central Files - Permit No. WQ0006992
Forsyth County Environmental Health Dept.
''`Nothing Compares::_,.
State of North Carolina I Environmental Quality I Division of Water Resources
Water Quality Regional operations Section
1636 Mail Service Center I Raleigh, North Carolina 27699-1636
919-707-9129

Non -Discharge Permit Rescission/Closure Report Checklist
Permittee/Facility Name: ('�]Lj..,jf- --
Permit No.: WQ Q UO (� Z
Reviewer- AL
Date:
1. PERMIT INFO
Permit issued date: o u ' Expiration date: i p_3 Zj
2. PERMIT RESCISSION REQUEST REC'D FROM PERMITTEE (tabbed w/ post-ito
Date Received /0
Letter or Email received from Permittee requesting permit rescission? (Yes or No).
Did Request include Reason for Closure? —� (Yes or No). v
Did Request include document from oversight agency authorizing closure of permit?
(Yes or No).
All Annual Fees Paid? v (Yes or No).
Did Request include a description of the proposed closure procedure? (Yes or No).
Comments:
3. PERMIT RESCISSI N ftEQUEST FORM SENT TO RO (tabbed w/ post-it�_�
Date Sent to RO a V1 /
Date Received Back fro RO // /S' 6
RO Approved Rescission Request (Yes or No). If no, explain:
Comments: .4- AAA
4. CLOSURE ACTIVIT ES PORT (tabbed w/ post -it)
Date Received: / o
Draft Permit Rescission APPROVAL LETTER Attached? � (Yes or No).
Injection Well(s)
Was injection well(s) properly abandoned per 15A NCAC 2C .0240?
(Yes/No/N/A). If abandoned, Date GW-30(s) received:
If ell(s) converted to other purposes, Date Injection Well Status Form Received:
Infiltration Gallery
Was infiltration Gallery closed such that the gallery was rendered permanently unusable
for the disposal or infiltration of treated effluent fluids and will not serve as a source or
channel of contamination? _)(Yes/No/N/A).
Record of disposal of contaminated soil/materials received? (Yes or No).
Evidence provided excavation has no residual contaminated soil? (Yes or
No).
* Non -Discharge Permit Closure Checklist (1-31-2017)

Dates provided for all closure activities? U (Yes or No).
Closure Report'complete, accurate, factual, and accurate per person signing report (i.e.,
sealed)? / (Yes or No).
Comments:
5. BIMS
Wells Tab reflect GW-1 s/GW-30s (if applicable) have been entered and/or well type and well
status modified:_ (Yes or No). If not received, then request from consultant and CC
Permittee. After receipt from these parties, enter as -built well construction into BIMS; and
well abandonment data or well type and well status, if applicable.
6. AFTER PERMIT RESCISSION APPROVAL LETTER is SIGNED BY SUPERVISOR
and PERMIT is OFFICIALLY RESCINDED
Date Completion Letter Sent to Permittee plus CCs:
Date Permit Rescinded in Events Tab in BIMS:
Date copies of all documents are put is permit folder in S Drive and submitted to be filed:
FINADpL COMMENTS, if any
/L2G aw-t- cjjo.4 L
Non-Discharge Permit Closure Checklist (1-31-2017)

Rogers, Michael
From: Kevin Slaughter <[e-mail]>
Sent: Monday, February 06, 2017 3:34 PM
To: Rogers, Michael
Cc: Matt Bramblett; Snow, William Scott
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Michael,
Thanks again for your assistance with this process
Kevin
From: Rogers, Michael [mailto:[e-mail]]
Sent: Monday, February 06, 2017 3:27 PM
To: Kevin Slaughter <[e-mail]>
Cc: Matt Bramblett <[e-mail]>; Snow, William Scott <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Please find attached the Permit Rescission Approval Letter.
Regards,
From: Kevin Slaughter [mailto:[e-mail]]
Sent: Tuesday, January 31, 2017 4:26 PM
To: Rogers, Michael <[e-mail]>
Cc: Matt Bramblett <[e-mail]>; Snow, William Scott <WiIlia [e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Thanks Michael!
From: Rogers, Michael [mailto:[e-mail]]
Sent: Tuesday, January 31, 2017 4:25 PM
To: Kevin Slaughter <[e-mail]>
Cc: Matt Bramblett <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
didn't notice that... it's been crazy here today. Disregard the form I sent. I'll change well type in BIMS w/out needing
the form.
From: Kevin Slaughter [mailto:[e-mail]]
Sent: Tuesday, January 31, 2017 3:59 PM
To: Rogers, Michael <[e-mail]>
Cc: Matt Bramblett <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Michael,
That's great news!

"Rogers, Michael
From: Wang, Shuying
Sent: Wednesday, January 25, 2017 9:50 AM
To: Rogers, Michael
Cc: Knight, Sherri; Wang, Shuying
Subject: RE: Termination of Non -Discharge Permit W00006992 - Oracle Flexible Packaging - Plant
604
HI Michael,
It will be your decision.
I agree with your point-- it is reasonable to assume they only removed 596 tons of contaminated infiltration soil/gravel
and piping. However, the report stated: "Once overburden soil above the HDPE liner was scraped to the side and
stockpiled, the gallery contents (gravel, distribution piping, liner material, and piezometers) were excavated." Based on
this statement, we can assume that at least 4024 cubic yards of washed gravel (based on the dimension/size of the
gallery) should have been excavated from the gallery. But why only 596 tons... If these 596 was contaminated, it will be
reasonable to ask them to document how did they determine the rest clean. In addition, we need to consider the
potential for the permeable fill portion (washed gravel) of the infiltration gallery would retain the ability to be used for
infiltration. Therefore, I think that the requirement of .1608(b)(2) can be met by excavating the subsurface permeable fill
materials or by covering them with uncontaminated low -permeability material. If the gravel was not removed or
backfilled to the pit, an uncontaminated low -permeable layer should apply on the top of permeable gravel. The report
only indicated that clean fill dirt was trucked in following removal of the former gallery contents, but did not document
what type of dirt was in term of permeability. Thus, I think it is reasonable to ask the additional information to
document the closure meeting the requirement.
If this is no clear, please let me know. Thank you!
Shuying Wang, P.G.
Hyd rogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
http://Portal.ncdenr.org/web/wq
�toihing, Compares,—_.,,
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.

From: Rogers, Michael
Sent: Tuesday, January 24, 2017 2:29 PM
To: Wang, Shuying <[e-mail]>
Cc: Knight, Sherri <[e-mail]>
Subject: RE: Termination of Non -Discharge Permit WQ0006992 - Oracle Flexible Packaging - Plant 604
S-
I got the hard copy of the closure report and reviewed. I have the following comments to your email:
In regards to Item 1- It's reasonable to assume they only removed 596 tons of contaminated infiltration
soil/gravel and piping.
In regards to Item 2- The rule only states they need to close the gallery so it can't be used as an infiltration
gallery anymore and is not a channel for contamination. The have met the requirements by removing (or
plugging) all subsurface gravel and materials, and filling the gallery excavation with clean fill/soil and compacted
to grade.
Therefore, I think they complied per closure requirements per 2T .1608 (attached). Do you agree?
Thanks,
From: Wang, Shuying
Sent: Monday, January 09, 2017 10:00 AM
To: Rogers, Michael <[e-mail]>
Cc: Knight, Sherri <[e-mail]>
Subject: RE: Termination of Non -Discharge Permit WQ0006992 - Oracle Flexible Packaging - Plant 604
Good morning Michael!
Not sure what level of review do you need from me. A very brief reading indicates a couple of things we may
want to be clarified:
1. The report indicates that the abandoned infiltration gallery were approximately 106 ft long, 17 ft wide
and 9.5 ft deep. The report also indicates that the gallery consisted of approximately 7 ft of washed
gravel, which should be approximately 12614 cubic feet (106 ft x 17ft x 7 ft) or 4204 cubic yards.
However, only approximately 595.7 tons of material were removed from site and trucked to EVO's
facility for treatment and disposal. We would like to know why only such a small amount or volume was
excavated from the pit and were removed from the site for treatment. We understand if the material is
not contaminated, it does not have to be removed from the site for treatment.
2. The report also indicates that following removal of the former gallery contents, clean fill dirt was
trucked in, spread and compacted within the gallery excavation area to within approximately 1.5 ft of
land surface. I think that we need to ask for describing what type of material the clean fill dirt is in term
of clay, silt, sand, or mix and where the dirt they got from just for documenting purpose.
If you need me to review the report further, please let me know. Thank you!
Shuying Wang, P.G.
Nydrogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office

Phone: [phone]
`Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
http://Portal.ncdenr.org/web/wq
mr_"'"%4%thing, Compares,-«, -
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Kevin Slaughter [mailto:[e-mail]]
Sent: Friday, January 06, 2017 3:53 PM
To: Rogers, Michael <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Wang, Shuying <shuying.wangncdenr.gov>; Snow, William Scott
<[e-mail]>; Matt Bramblett <[e-mail]>
Subject: Termination of Non -Discharge Permit WQ0006992 - Oracle Flexible Packaging - Plant 604
Michael,
Please find the attached report for the above site in PDF format. A hard copy is also being sent to your attention
by mail. If you have any questions or comments, please let us know.
Thanks,
Kevin
J. Kevin Slaughter, Senior Environmental Scientist
Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4615 Mobile [phone] Main 704-586-0007
www.harthickman.com
hart hickman
s++.�MCX«wva�;w�.+��caxs svtut�ss

Permit Rescission Request Form
Information to be filled out by Central Office
CE'VED!NCDF0T
Permit No.: WQ0006992 NOV 1 5 2016
Permittee: Oracle Flexible, LLC 'later Quality Regions
Facility Name: Plant 604
Regional Office: Winston-Salem
County: Forsyth
Date Rescission Requested: 10/24/2016 via email attached
Received Original Request: ❑ Central Office = Regional Office
Form of Received Request: 0 Letter/Email = Signed Annual Fee Invoice = Other form
Annual Fees Paid to Date: Yes
Information to be filled out by Regional Office
Please Check Appropr' tely:
OrSite Visit Performed
Recommendations (check one block below):
❑ Rescind Pen -nit Immediately
Reason for Approval
❑ Groundwater Concerns Addressed
S Y�vi�
❑ Require Renewal with Suspended Actions
Recommended Actions to be Taken
❑ Do Not Rescind/Recommend Renewal
Reason for Denial

Signature of RO Certifier (WQROS Section):
Aq
Typed or Printed Name of RO Certifier: l�JLf a;;i
Date Certified:
Return Completed an Signed Form to the WQROS Section. Thanks.
Page 2 of 2

Rogers, Michael
From: Rogers, Michael
Sent: Thursday, November 10, 2016 1:07 PM
To: 'Kevin Slaughter'; Wang, Shuying
Cc: Knight, Sherri; Snow, William Scott; Matt Bramblett
Subject: RE: Oracle Non -Discharge Permit - W00006992
Your welcome sir, and happy holidays.
From: Kevin Slaughter [mailto:[e-mail]]
Sent: Thursday, November 10, 2016 12:49 PM
To: Wang, Shuying <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: Knight, Sherri <[e-mail]>; Snow, William Scott <[e-mail]>; Matt
Bramblett <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Shuying and Michael,
Thank you for your guidance on this project. Tentatively, the abandonment activities look like it will take place during
the first half of December. As requested, documentation of the gallery abandonment (including photographs) will be
provided following completion of field activities so the permit can be closed out.
Thanks again,
Kevin
From: Wang, Shuying [mailto:[e-mail]]
Sent: Thursday, November 10, 2016 11:49 AM
To: Kevin Slaughter <[e-mail]>
Cc: Rogers, Michael <[e-mail]>; Snow, William Scott <[e-mail]>; Matt
Bramblett <[e-mail]>; Knight, Sherri <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Hi Kevin,
Based on what you described, I do not think that any damages to the piping will result in a groundwater issue. So I do
not have any objection to what you proposed to do with it.
It may be only a facility safety concern. If it is a large diameter pipe and buried very shallow, once it is exposed to the
surface and damaged, something or someone may be hurt or damaged. Since we do not have clear guidance for closing
such piping, it will be your and the permittee's decision.
Thanks for answer my questions!
Shuying Wang, P.G.
Hydrogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]

Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
http://porta1.ncdenr.org/web/wq
Nothing Compares-,-,-,
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Kevin Slaughter[mailto:[e-mail]]
Sent: Thursday, November 10, 2016 11:24 AM
To: Wang, Shuying <[e-mail]>
Cc: Rogers, Michael <[e-mail]>; Snow, William Scott <[e-mail]>; Matt
Bramblett <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Hi Shuying,
Atthough there are several documents related to the proposed system construction, no "As -Built" drawings related to
piping installation have been located to date.
Water discharge lines from the recovery wells to the former pump and treat system appear to be approximately 1.5" in
diameter based on visual inspections inside recovery well vaults. Proposed system drawings indicate that the treated
water transfer line from the remediation system to the infiltration gallery is 2" PVC piping which terminates with 4"
perforated PVC piping within the infiltration galleries (which will be excavated and removed during abandonment
activities).
The transfer piping depth below land surface is unknown. Water discharge piping appears to exit vaults at
approximately 2' below land surface, but it is unknown if piping maintains this depth, or drops to a deeper
depth. System discharge piping depth to infiltration galleries is also unknown although it almost certainly deeper where
it passes underneath the railroad spur line.
I hope this helps,
Kevin
From: Wang, Shuying[mailto:[e-mail]]
Sent: Thursday, November 10, 2016 10:36 AM
To: Kevin Slaughter <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: Snow, William Scott <[e-mail]>; Matt Bramblett <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Hi Kevin,

Do you know what the diameter of the piping is and how deep it is from the surface?
Thank you!
Shuying Wang, P.G.
Hydrogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
http://porta1.ncdenr.org/web/wq
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Kevin Slaughter[mailto:[e-mail]
Sent: Thursday, November 10, 2016 10:25 AM
To: Rogers, Michael <[e-mail]>
Cc: Wang, Shuying <[e-mail]>; Snow, William Scott<[e-mail]>; Matt
Bramblett <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Michael,
As suggested, H&H originally considered pressure grouting the transfer piping from the recovery wells to the
remediation system, and from the remediation system to the infiltration galleries. However, due to the lack of impacts
in the system inlet and discharge water, the length of piping involved (estimated 2,000-3,000 ft), and the transfer line to
the infiltration galleries passing under a rail road spur (would most likely require a permit from railroad to inject
pressurized grout under rail line), H&H came to the conclusion that cutting off the transfer piping at both ends and
gluing a PVC cap over each end should be sufficient.
Based on your recommendations, H&H proposes that in addition to the originally proposed abandonment method, the
end of each transfer line be filled with a hydraulic cement plug (a minimum of 10 times the piping diameter) prior to the
PVC cap being glued on. The hydraulic cement plug will act as a second layer of protection if the PVC cap were to ever
fail or end of piping were broken off. As stated in the closure plan, H&H's contractors would remove and dispose of all
piping located within the infiltration galleries.
Please let me know if this is acceptable for the reasons given above.

Thanks, •
Kevin
From: Rogers, Michael [mailto:[e-mail]]
Sent: Wednesday, November 09, 2016 1:37 PM
To: Kevin Slaughter <[e-mail]>
Cc: Snow, William Scott <[e-mail]>; Matt Bramblett <[e-mail]>;
Wang, Shuying <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
You may proceed with closure. However, Ms. Wang recommends the treatment system piping below the grade be filled
with slurry if possible, instead of just capped. Please provide documentation/photographs of the closure. After receipt
we will close out the permit.
Thanks
From: Kevin Slaughter[mailto:[e-mail]]
Sent: Wednesday, November 09, 2016 10:10 AM
To: Rogers, Michael <[e-mail]>
Cc: Snow, William Scott <[e-mail]>; Matt Bramblett <[e-mail]>
Subject: RE: Oracle Non -Discharge Permit - WQ0006992
Michael,
I hope you have been doing well. I wanted to check on the approval process for closure of Non -Discharge Permit
WQ0006992. H&H would like to start closure work before winter sets in but is holding off contractor scheduling pending
final closure permit approval. If you have an estimated approval date, I would greatly appreciate it so I can begin the
scheduling process. Please let me know if you have any additional questions.
Thanks again,
Kevin
From: Rogers, Michael[maifto:[e-mail]]
Sent: Thursday, October 27, 2016 9:45 AM
To: Snow, William Scott <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Kevin Slaughter <[e-mail]>; Knight, Sherri
<[e-mail]>; Wang, Shuying <[e-mail]>; Matt Bramblett
<[e-mail]>
Subject: RE: Closure of Non -Discharge Permit - Oracle WQ0006992
OK, thanks.
From: Snow, William Scott [maifto:[e-mail]]
Sent: Monday, October 24, 2016 4:39 PM
To: Rogers, Michael <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Kevin Slaughter <[e-mail]>; Knight, Sherri
<[e-mail]>; Wang, Shuying <[e-mail]>; Matt Bramblett
<[e-mail]>
Subject: Closure of Non -Discharge Permit - Oracle WQ0006992
4

Michael,
Please accept this note as an official permit closure request for Oracle Flexible Packaging, 220 Polo Road, in
Winston-Salem, NC (Non -Discharge Permit WQ0006992). Oracle will implement the Work Plan submitted by
Hart & Hickman to permanently close the infiltration gallery and convert the existing pump and treat recovery
wells into monitoring wells. These wells, in conjunction with, the existing monitoring wells will be maintained
per Subchapter 2C until conditions warrant their permanent abandonment.
Also, please note that the current permit fee invoice is in the process of being paid and should be received by
your office on or before November 4cn
If you have any questions or need additional information pertaining to this request, please contact me at your
earliest convenience.
Best Regards,
W. Scott Snow, P.E.
Environmental Engineer
Oracle Flexible Packaging / LLFlex
220 Polo Road
Winston-Salem, NC 27105
[phone] (office)
[phone] (mobile)
From: Rogers, Michael [mailto:[e-mail]]
Sent: Thursday, October 20, 2016 10:06 AM
To: Matt Bramblett
Cc: Qi, Qu; Snow, William Scott; Kevin Slaughter; Knight, Sherri; Wang, Shuying
Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle WQ0006992
The plan looks good. However, We need the following additional 2 items addressed to move forward:
The annual fees of $1310 needs to be paid.
We need a letter or email from Oracle requesting the permit be rescinded.
Thanks
From: Matt Bramblett imailto:[e-mail]
Sent: Thursday, October 20, 2016 9:13 AM
To: Rogers, Michael <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Snow, William Scott<[e-mail]>; Kevin Slaughter
<[e-mail]>; Knight, Sherri <[e-mail]>; Wang, Shuying
<[e-mail]>
Subject: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle
Michael,
Please find the attached work plan for the above site for your review. With your approval, we will schedule the work
right away. If you have any questions, please let me know.

Thanks,
Matt
Matt Bramblett, PE, Principal
Hart & Hickman, PC 12923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4620 1 Mobile [phone] Main 704-586-0007
www.harthickman.com
hart hickman

Rogers, Michael w 61 �c e� . Sod 4v So &-Ae K L-,/
From: Kevin Slaughter <[e-mail]>
Sent: Wednesday, November 09, 2016 10:10 AM
To: Rogers, Michael
Cc: Snow, William Scott; Matt Bramblett
Subject: RE: Oracle Non -Discharge Permit - W00006992
Michael,
I hope you have been doing well. I wanted to check on the approval process for closure of Non -Discharge Permit
WQ0006992. H&H would like to start closure work before winter sets in but is holding off contractor scheduling pending
final closure permit approval. If you have an estimated approval date, I would greatly appreciate it so I can begin the
scheduling process. Please let me know if you have any additional questions.
Thanks again,
Kevin
From: Rogers, Michael [mailto:[e-mail]]
Sent: Thursday, October 27, 2016 9:45 AM
To: Snow, William Scott <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Kevin Slaughter <[e-mail]>; Knight, Sherri
<[e-mail]>; Wang, Shuying <[e-mail]>; Matt Bramblett
<[e-mail]>
Subject: RE: Closure of Non -Discharge Permit - Oracle WQ0006992
OK, thanks.
From: Snow, William Scott [mailto:[e-mail]]
Sent: Monday, October 24, 2016 4:39 PM
To: Rogers, Michael <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Kevin Slaughter<[e-mail]>; Knight, Sherri
<[e-mail]>; Wang, Shuying <[e-mail]>; Matt Bramblett
<MBra [e-mail]>
Subject: Closure of Non -Discharge Permit - Oracle WQ0006992
Michael,
Please accept this note as an official permit closure request for Oracle Flexible Packaging, 220 Polo Road, in
Winston-Salem, NC (Non -Discharge Permit WQ0006992). Oracle will implement the Work Plan submitted by
Hart & Hickman to permanently close the infiltration gallery and convert the existing pump and treat recovery
wells into monitoring wells. These wells, in conjunction with, the existing monitoring wells will be maintained
per Subchapter 2C until conditions warrant their permanent abandonment.
Also, please note that the current permit fee invoice is in the process of being paid and should be received by
your office on or before November 41n
If you have any questions or need additional information pertaining to this request, please contact me at your
earliest convenience.

Best Regards,
W. Scott Snow, P.E.
Environmental Engineer
Oracle Flexible Packaging / LLFIex
220 Polo Road
Winston-Salem, NC 27105
[phone] (office)
[phone] (mobile)
From: Rogers, Michael [mailto:[e-mail]]
Sent: Thursday, October 20, 2016 10:06 AM
To: Matt Bramblett
Cc: Qi, Qu; Snow, William Scott; Kevin Slaughter; Knight, Sherri; Wang, Shuying
Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle WQ0006992
The plan looks good. However, We need the following additional 2 items addressed to move forward:
The annual fees of $1310 needs to be paid.
We need a letter or email from Oracle requesting the permit be rescinded.
Thanks.
From: Matt Bramblett [mailto:[e-mail]]
Sent: Thursday, October 20, 2016 9:13 AM
To: Rogers, Michael <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Snow, William Scott<[e-mail]>; Kevin Slaughter
<[e-mail]>; Knight, Sherri <[e-mail]>; Wang, Shuying
<[e-mail]>
Subject: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle
Michael,
Please find the attached work plan for the above site for your review. With your approval, we will schedule the work
right away. If you have any questions, please let me know.
Thanks,
Matt
Matt Bramblett, PE, Principal
Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4620 Mobile [phone] Main 704-586-0007
www.harthickman.com
hart hickfT an
WAf'+�F x. v.','±s::stiEk€aa"A.:: SAt UTi"M'S

Rogers, Michael
From: Snow, William Scott <[e-mail]>
Sent: Monday, October 24, 2016 4:39 PM
To: Rogers, Michael
Cc: Qi, Qu; Kevin Slaughter; Knight, Sherri; Wang, Shuying; Matt Bramblett
Subject: Closure of Non -Discharge Permit - Oracle W00006992
Michael,
Please accept this note as an official permit closure request for Oracle Flexible Packaging, 220 Polo Road, in
Winston-Salem, NC (Non -Discharge Permit WQ0006992). Oracle will implement the Work Plan submitted by
Hart & Hickman to permanently close the infiltration gallery and convert the existing pump and treat recovery
wells into monitoring wells. These wells, in conjunction with, the existing monitoring wells will be maintained
per Subchapter 2C until conditions warrant their permanent abandonment.
Also, please note that the current permit fee invoice is in the process of being paid and should be received by
your office on or before November 0
If you have any questions or need additional information pertaining to this request, please contact me at your
earliest convenience.
Best Regards,
W. Scott Snow, P.E.
Environmental Engineer
Oracle Flexible Packaging / LLFlex
220 Polo Road
Winston-Salem, NC 27105
[phone] (office)
[phone] (mobile)
From: Rogers, Michael [mailto:[e-mail]]
Sent: Thursday, October 20, 2016 10:06 AM
To: Matt Bramblett
Cc: Qi, Qu; Snow, William Scott; Kevin Slaughter; Knight, Sherri; Wang, Shuying
Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle WQ0006992
The plan looks good. However, We need the following additional 2 items addressed to move forward:
The annual fees of $1310 needs to be paid.
We need a letter or email from Oracle requesting the permit be rescinded.
Thanks
From: Matt Bramblett [mailto:[e-mail]]
Sent: Thursday, October 20, 2016 9:13 AM
To: Rogers, Michael <[e-mail]>
Cc: Qi, Qu <qu.gi ncdenr.gov>; Snow, William Scott <[e-mail]>; Kevin Slaughter

<[e-mail]>; Knight, Sherri <[e-mail]>; Wang, Shuying
<[e-mail]>
Subject: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle
Michael,
Please find the attached work plan for the above site for your review. With your approval, we will schedule the work
right away. If you have any questions, please let me know.
Thanks,
Matt
Matt Bramblett, PE, Principal
Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4620 Mobile [phone] Main 704-586-0007
www.harthickman.com
hart 0 hlckman

Rogers, Michael
From: Wang, Shuying
Sent: Monday, January 30, 2017 4:32 PM
To: Rogers, Michael
Cc: Wang, Shuying; Knight, Sherri
Subject: FW: Oracle IHSB Site# NCD067441394
See below.
Shuying
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Caw and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Qi, Qu
Sent: Thursday, October 09, 2014 12:20 PM
To: Snow, William Scott <[e-mail]>
Cc: Wang, Shuying <[e-mail]>; Knight, Sherri <[e-mail]>; Slusser, Thomas
<[e-mail]>; Speer, David <[e-mail]>; Pierce, Gregory
<[e-mail]>; Ware, Bonnie <[e-mail]>; Day, Collin <[e-mail]>
Subject: RE: Oracle IHSB Site# NCD067441394
Mr. Snow:
A quick file review shows that the site was determined to be REC eligible and you were recommended to participate in
the REC program in 2008. Based on our records you did not choose to participate and therefore, your site's status is
"independent remediation without State's supervision". We have not received any documents or lab results and a
thorough review of the site is not possible. However, based on the information you provided in this e-mail, the Inactive
Hazardous Site Branch does not have any objections to rescind the Groundwater Remediation Permit
(WQ0006992). Contact me if you have any questions or want to discuss the status of your site further.
as PG
Inactive Hazardous Sites Branch
Superfund Section
Division of Waste Management
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records taw and may be disclosed
to third parties unless the content is exempt by statute or other regulation.
My phone/fax number is [phone]
Street address: Green Square Complex DENR Office Building 217 W Jones Street, Raleigh, NC 27603
Mailing address: 1646 Mail Service Center, Raleigh, NC 27699
From: Snow, William Scott [mailto:scottsnow(�i)oraclepkg.com]
Sent: Wednesday, October 08, 2014 4:14 PM
To: Ware, Bonnie
Cc: Qi, Qu; Wang, Shuying; Knight, Sherri; Slusser, Thomas; Speer, David; Pierce, Gregory
Subject: Oracle IHSB Site# NCD067441394
1

Oracle Flexible Packaging (OFP)
220 Polo Road
Winston-Salem, NC 27105
IHSB Site# NCD067441394
DWR Groundwater Permit WQ0006992
Hi Bonnie,
OFP is exploring a permit closure request to the NC Division of Water Resources (DWR) for a pump and treat Air Stripper
GW remediation system (GW Permit WQ0006992) at our Polo Road site in Winston-Salem. One qualification for this
request is to obtain a letter from the oversight agency (DWM - IHSB) authorizing shutdown of the remediation
system. Therefore, the purpose of this email is to provide background information and discussion of OFP's
intent. Please keep in mind, this is not a request for site closure or a NFA letter, only to rescind the GW system permit.
I refer you to Section III of the attached DWR permit (GW Permit — Polo Rd 2016.pdf) which contains quarterly GW
system monitoring requirements. Quarterly and annual monitoring well sampling requirements are outlined in a
separate DWR letter (DENR Monitoring Letter 1997.pdf). Note the site map (GW Map — Polo Road IHSB) included for
reference.
Also attached is the temporary GW system shutdown notification letter from June 2010 (Shutdown Notice 22Jun10.pdf)
which describes the lack of target organic detection in monitoring wells and system influent for several years prior to
shutdown. Since July 2010, OFP has continued to conduct this monitoring in order to eliminate the concern of bounce
back. The attached spreadsheet (MW's 604 IHSB.xlsx) shows that no target compounds have been measured above 2L
standards or vapor intrusion groundwater screening levels (GWSL). Acetone, detected in MW-14 in April 2011 and 2012,
was at a level 250 times below the 2L standard and several orders of magnitude lower than GWSL.
Since over four years has passed since temporary shutdown, OFP respectfully requests a letter or email authorizing
permanent GW remediation system shutdown. It is my understanding that permit rescission would relieve all DWR-
mandated monitoring requirements, however, OFP is willing to continue monitoring if so requested by DWM. In
addition, should future remediation of the site be required, OFP anticipates that an alternative method of treatment
would be utilized.
Please let me know if you have questions or need additional information, or if you would like to meet at the site to
discuss this request.
I sincerely appreciate your time and consideration of this matter and look forward to hearing from you.
Regards,
W. Scott Snow, P.E.
Environmental Engineer
Oracle Flexible Packaging / LLFIex
220 Polo Road
Winston-Salem, NC 27105
[phone] (office)
[phone] (mobile)

hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
Via Email
October 20, 2016
NC DEQ
DWR Water Quality Regional Operation Section (WQRPS),
Groundwater Protection Branch — UIC Program Manager
1636 Mail Service Center,
Raleigh, NC 27699
Attention: Mr. Michael Rogers
Re: Termination of Non -Discharge Permit WQ0006992
Oracle Flexible Packaging / LLFIex, Plant #604
220 E. Polo Rd. Winston-Salem, NC 27105
IHSB Site #NCD067441394
H&H Job No. ORA-013
Dear Mr. Rogers:
On behalf of Oracle Flexible Packaging / LLFIex (Oracle), Hart & Hickman, PC (H&H) is
providing this Work Plan to terminate Non -Discharge Permit WQ0006992. The non -discharge
permit is associated with a groundwater pump and treat system located at 220 E. Polo Rd. in
Winston-Salem, Forsyth County, North Carolina. A site location map and a site plan are
included as Figures 1 and 2, respectively.
As outlined in 15A NCAC 02T .1608 of the Division of Water Quality North Carolina
Administrative Code, Oracle is seeking to terminate Non -Discharge Permit WQ0006992 which
will expire on October 31, 2016. The former pump and treat system consisted of eleven
groundwater recovery wells, an air stripping treatment system, and an infiltration gallery for on -
site injection of treated groundwater.
2923 South Tryon Street, Suite 100 I 3334 Hillsborough Street
Charlotte, NC28203 Raleigh, NC 27607 www.harthickman.corn
704.586.0007 main 919.847.4241 main

Mr. Michael Rodgers
October 20, 2016
Page 2
Operation of the pump and treat system started in the late 1980s. The system was shut down in
July 2010 following several years of no measurable impacts in the treatment system influent and
low to non -detect groundwater concentrations in the system treatment area. During the last six
years of monitoring, there has been no significant rebound of groundwater constituents in site
monitoring wells being sampled. For this reason, Oracle has made the decision not to renew its
non -discharge permit. As required by the administrative code, attached is an email from Mr. Qu
Qi with the Inactive Hazardous Sites Branch (IHSB) stating that IHSB has no objection with
rescinding groundwater remediation permit WQ0006992.
Oracle intends on converting the former recovery wells into groundwater monitoring wells. This
will be accomplished by removing the submersible pumps, electric cables, and discharge piping
from each recovery well. In addition, electric lines and groundwater recovery piping will be cut
off and capped within each vault. Following removal of the recovery well pumps and down well
piping, each monitoring well will be sealed with a lockable expansion plug and the 2-ft x 2-ft
steel vault lid will be re -secured with bolts.
Groundwater recovery piping entering the above ground air stripping treatment system and the
treated water discharge line to the infiltration gallery area will be cut off and capped at the
former treatment system location. In addition, power to the system will be permanently
disconnected by a licensed electrician.
For closure of the infiltration gallery trenches, Oracle will subcontract for the excavation of the
infiltration gallery gravel materials. An impermeable liner currently separates l to 2 ft of
overburden soil from the gravel located within the gallery trenches. This overburden soil will be
scrapped off and stockpiled for reuse. Infiltration gallery gravel and PVC distribution piping
located within the trenches will then be excavated for off -site disposal at a facility permitted to
accept such materials. Treatment system discharge piping and electrical level sensor wiring will
be cut off where it enters the galleries, and the treatment system piping will be permanently
capped below grade.
S-\AAA-Masser Prujpcts\0rac1e\0RA-013 Polo Road In6ltrawn CmIlery Closur6Work Plm.doc
hart hiekman
WARTFF. AlSOLUT)ONS

Mr. Michael Rodgers
October 20, 2016
Page 3
Once the former gallery material has been removed, clean fill will be imported from off -site,
placed in the trenches, and compacted in lifts. The upper 1 to 2 feet of gallery fill material will
be composed of overburden soil previously stockpiled. The trenches will be filled slightly above
land surface to avoid stormwater accumulation. Disturbed areas will be covered with grass seed
and straw.
On Oracles behalf, within 30 day of system closure, H&H will submit a letter report describing
the completed closure procedures. The report will include a certification that the closure was
accomplished in accordance with this work plan and that the information submitted is complete,
factual and accurate.
We look forward to your review and approval of this work plan. If you have any questions,
please do not hesitate to contact us.
Sincerely,
Hart & Hickman, PC
J. Kevin Slaughter
Senior Environmental Scientist
MVB/vmg
Enclosures
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Matt Bramblett
Principal and Project Manager
cc: Scott Snow, Oracle (PDF by Email and Hard Copy by Mail)
Sherri Knight, Division of Water Resources (PDF by Email)
Qu Qi, Inactive Hazardous Sites Branch (PDF by Email)
S::AAA-Master Projead'vOnclehORA-013 Polo Road lnfihntio . Gallen Ciosim%Wcttk Plan doc
hart � hickman
SMARTER ENVIMONMEN?AL SOLUTIONS

From: Qi, Qu <[e-mail]>
Sent: Thursday, October 09, 2014 12:20 PM
To: Snow, William Scott
Cc: Wang, Shuying; Knight, Sherri; Slusser, Thomas; Speer, David; Pierce, Gregory; Ware,
Bonnie; Day, Collin
Subject: RE: Oracle IHSB Site# NCD067441394
Mr. Snow:
A quick file review shows that the site was determined to be REC eligible and you were recommended to participate in
the REC program in 2008. Based on our records you did not choose to participate and therefore, your site's status is
"independent remediation without State's supervision". We have not received any documents or lab results and a
thorough review of the site is not possible. However, based on the information you provided in this e-mail, the Inactive
Hazardous Site Branch does not have any objections to rescind the Groundwater Remediation Permit
(WQ0006992). Contact me if you have any questions or want to discuss the status of your site further.
Qu Qi, PG
Inactive Hazardous Sites Branch
Superfund Section
Division of Waste Management
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statute or other regulation.
My phone/fax number is [phone]
Street address: Green Square Complex DENR Office Building 217 W Jones Street, Raleigh, NC 27603
Mailing address: 1646 Mail Service Center, Raleigh, NC 27699
From: Snow, William Scott[mailto:[e-mail]]
Sent: Wednesday, October 08, 2014 4:14 PM
To: Ware, Bonnie
Cc: Qi, Qu; Wang, Shuying; Knight, Sherri; Slusser, Thomas; Speer, David; Pierce, Gregory
Subject: Oracle IHSB Site# NCD067441394
Oracle Flexible Packaging (OFP)
220 Polo Road
Winston-Salem, NC 27105
IHSB Site# NCD067441394
DWR Groundwater Permit WQ0006992
Hi Bonnie,
OFP is exploring a permit closure request to the NC Division of Water Resources (DWR) for a pump and treat Air Stripper
GW rerr►ediation system (GW Permit WQ0006992) at our Polo Road site in Winston-Salem. One qualification for this
request is to obtain a letter from the oversight agency (DWM - IHSB) authorizing shutdown of the remediation

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Rogers, Michael
From: Matt Bramblett <[e-mail]>
Sent: Thursday, October 20, 2016 3:38 PM
To: Rogers, Michael
Cc: Qi, Qu; Snow, William Scott; Kevin Slaughter; Knight, Sherri; Wang, Shuying
Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle
W00006992
Michael,
Per your voice message question regarding monitoring wells, Oracle is planning to keep and maintain the existing
monitoring well network and the recover well conversions for future groundwater monitoring purposes. Therefore, we
are not planning to abandon any wells as part of this phase of work.
If you have any further questions, please let me know.
Thanks,
Matt
From: Rogers, Michael [mailto:[e-mail]]
Sent: Thursday, October 20, 2016 10:06 AM
To: Matt Bramblett <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Snow, William Scott <[e-mail]>; Kevin Slaughter
<[e-mail]>; Knight, Sherri <[e-mail]>; Wang, Shuying
<[e-mail]>
Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle WQ0006992
The plan looks good. However, We need the following additional 2 items addressed to move forward:
The annual fees of $1310 needs to be paid.
We need a letter or email from Oracle requesting the permit be rescinded.
Thanks
From: Matt Bramblett [ma ilto:MBra [e-mail]]
Sent: Thursday, October 20, 2016 9:13 AM
To: Rogers, Michael <[e-mail]>
Cc: Qi, Qu <[e-mail]>; Snow, William Scott <[e-mail]>; Kevin Slaughter
<[e-mail]>; Knight, Sherri <[e-mail]>; Wang, Shuying
<[e-mail]>
Subject: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle
Michael,
Please find the attached work plan for the above site for your review. With your approval, we will schedule the work
right away. If you have any questions, please let me know.
Thanks,
Matt

Matt Bramblett, PE, Principal
Hart & Hickman, PC 12923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4620 1 Mobile [phone] Main 704-586-0007
www.harthickman.com
14
hart hickman

Rogers, Michael
From: Rogers, Michael
Sent: Tuesday, October 18, 2016 10:05 AM
To: Wang, Shuying; Kevin Slaughter
Cc: Knight, Sherri
Subject: RE: Termination of Non -Discharge Permit W00006992 (Oracle)
I was looking at our BIMS database and there is an annual fee of $1310 due on November 6. This will need to be paid
before closing out the permit. Our Budget office contact person contact info is below.
Teresa. Revis(@ncdenr. cov
NCDENR/DWR Budget Office
6`1 Floor
1617 Mail Service Center
Raleigh NC 27699-1617
919 807 6316 (TEL)
919 807 6490 (FAX)
From: Wang, Shuying
Sent: Tuesday, October 18, 2016 9:15 AM
To: Kevin Slaughter <[e-mail]>
Cc: Knight, Sherri <[e-mail]>; Rogers, Michael <[e-mail]>
Subject: RE: Termination of Non -Discharge Permit WQ0006992 (Oracle)
Hi Kevin,
It sounds about right. Sorry for late response!
Shuying Wang, P.G.
Hydrogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
http://portal.ncdenr.org/web/wq
'--`Nothing Compares --�.

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Knight, Sherri
Sent: Wednesday, October 12, 2016 5:00 PM
To: Wang, Shuying <[e-mail]>
Subject: Fwd: Termination of Non -Discharge Permit WQ0006992 (Oracle)
Sent from my iPhone
Begin forwarded message:
From: Kevin Slaughter <[e-mail]>
Date: October 12, 2016 at 10:34:42 AM EDT
To: "Knight, Sherri" <[e-mail]>
Subject: Termination of Non -Discharge Permit WQ0006992 (Oracle)
Sherri,
I hope you have been doing well. H&H is preparing a work plan to terminate the Non -Discharge Permit
above (for 220 Polo Rd) and I want to make sure everyone relevant gets copied. Original is going to
Mike Rodgers, and plan on copying yourself, and Qu Qi. Is this sufficient, or am I leaving anyone out?
Thanks for your assistance!
Kevin
J. Kevin Slaughter, Senior Environmental Scientist
Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4615 Mobile [phone] Main 704-586-0007
www.harthickman.com
Id
hart hiCkman

Rogers, Michael
From: Kevin Slaughter <[e-mail]>
Sent: Friday, October 07, 2016 9:58 AM
To: Rogers, Michael ©fl- G
Cc: Matt Bramblett
Subject: RE: Infiltration Gallery Abandonment Requirements WO0006992
Thanks Michael,
Have a great weekend!
From: Rogers, Michael [mailto:[e-mail]]
Sent: Friday, October 07, 2016 9:47 AM
To: Kevin Slaughter <[e-mail]>
Subject: RE: Infiltration Gallery Abandonment Requirements WQ0006992
Yes, this will suffice.
From: Kevin Slaughter [mailto:[e-mail]]
Sent: Thursday, October 06, 2016 4:45 PM
To: Rogers, Michael <[e-mail]>
Subject: RE: Infiltration Gallery Abandonment Requirements WQ0006992
Michael,
I hope you have been doing well. Oracle / has given H&H approval to produce a closure plan for the non -discharge
permit referenced above and attached email. I know that 15A NCAC 02T .1608 requests that "a letter be included from
the oversight agency authorizing closure of the system". Attached is an email regarding closure of this permit by Mr. Qu
Qi with the Inactive Hazardous Sites Branch. Would this suffice for the letter portion of the closure plan, or would I need
an actual letter from Mr. Qi?
Thanks,
Kevin
From: Rogers, Michael [mailto:[e-mail]]
Sent: Monday, June 06, 2016 12:39 PM
To: Wang, Shuying <[e-mail]>; Kevin Slaughter <[e-mail]>
Cc: William Scott Snow ([e-mail]) <[e-mail]>; Matt Bramblett
<[e-mail]>; Watts, Debra <debra. [e-mail]>; Knight, Sherri
<[e-mail]>; Gonsiewski, James J <[e-mail]>
Subject: RE: Infiltration Gallery Abandonment Requirements WQ0006992
Attached is the closure requirements from 2T. As Shuying mentioned below, provide the closure plan to both the CO
and RO. IF you are requesting the permit be rescinded, include that request in the package.
Also, please include the permit number of the system you are proposing to close in the subject line of any emails.
Thanks.

From: Wang, Shuying
Sent: Monday, June 06, 2016 11:22 AM
To: Kevin Slaughter <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: William Scott Snow ([e-mail]) <[e-mail]>; Matt Bramblett
<[e-mail]>; Watts, Debra <[e-mail]>; Knight, Sherri
<[e-mail]>; Gonsiewski, James J <[e-mail]>
Subject: RE: Infiltration Gallery Abandonment Requirements
Hi Kevin,
Once you determine how the infiltration gallery is to be closed, please submit a revised closure plan to Michael Rogers,
DWR Water Quality Regional Operation Section (WARPS), Groundwater Protection Branch and send a copy here (DWR
WQROS WSRO). I am not aware of any soil sampling requirements for infiltration gallery closure. Michael may have
something different. In your future correspondence regarding this issue, please do not forget to copy Michael Rogers,
the Central Office contact person. Thank you!
Michael, could you please give Kevin a further reply regarding the soil sampling concern for the closure? Thank you!
Shuying Wang, P.G.
Hydrogeologist
Division of Water Resources
NC Department of Environmental Quality
Winston-Salem Regional Office
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
http://portal.ncdenr.orp,/web/wq
f,
c . j "-Nothing Compares. --,...-
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Kevin Slaughter[mailto:[e-mail]]
Sent: Monday, June 06, 2016 10:12 AM
To: Gonsiewski, James J <[e-mail]>
Cc: Wang, Shuying <[e-mail]>; William Scott Snow ([e-mail])
<[e-mail]>; Matt Bramblett <[e-mail]>
Subject: Infiltration Gallery Abandonment Requirements
Jim,

I hope you are doing well. H&H is assisting Mr. W. Scott Snow with Oracle Flexible Packaging / LLFIex (Oracle) to obtain
permanent closure of the infiltration gallery at the Oracle facility located at 220 Polo Rd, Winston-Salem, NC. The
current Non -Discharge Permit #WQ0006992 will expire on October 31, 2016.
Although pressure grouting the diffuser piping and capping the infiltration gallery area with an impervious liner is
currently being considered as an option (previously suggested by Thomas Slusser in email below), Oracle may decide for
future land use purposes to completely remove the gallery piping and gravel material. Once excavated, the gallery
material will be properly disposed of and any gallery excavations will be refilled with clean compacted fill dirt.
Am I correct that you would be the contact person when H&H submits documentation prior to initiation of gallery
closure procedures to receive oversight agency authorization for closure of the system as detailed in 15A NCAC 02T
.1608 (a)(2)? It also appears from prior emails regarding closure of the subject gallery and reviewing 15A NCAC 02T
.1608 "Requirements For Closure", that there are no sampling requirements required for permanent gallery
closure. H&H would like to confirm that soil sampling is not a requirement for infiltration gallery closure if Oracle
decides to choose the gallery excavation option.
If you have any comments or can offer additional guidance, I would greatly appreciate it_
Thanks again,
Kevin
J. Kevin Slaughter, Senior Environmental Scientist
Hart & Hickman; PC ( 2923 South Tryon Street; Suite 100 1 Charlotte, NC 28203
Direct 704-887-4615 Mobile [phone] ( Main 704-586-0007
www.harthickman.com
haft tiGkCT an
From: Slusser, Thomas[mailto:thomas.slusser@)ncdenr.gov]
Sent: Tuesday, November 25, 2014 2:32 PM
To: Wang, Shuying <[e-mail]>; Snow, William Scott <scottsnow(d)oraclepkg.com>
Cc -.-Knight, Sherri <sherri.knight@)ncdenr.gov>; Basinger, Corey <corev. basinger(cDncdenr.gov>
Subject: RE: Permit and Infiltration Gallery Closure - Oracle WQ0006992
Greetings Scott,
The closure plan described below adequately addresses the piping , but what of the permeable material in the remainder
of the infiltration gallery? I do not have the infiltration gallery design specifications in front of me, but we need to
consider the potential for the permeable fill portion of the infiltration gallery would retain the ability to be used for
infiltration.
15A NCAC 02T .1602(3) defines "infiltration gallery" as a subsurface ground absorption system expressly designed for
the introduction of wastewater into the subsurface environment. Normally the piping is placed in permeable material in
an excavation cut into the subsurface in order to facilitate infiltration of the wastewater.
15A NCAC 02T .1608(b)(2) requires that "infiltration galleries shall be closed such that the infiltration gallery will be
rendered permanently unusable for the disposal or infiltration of fluids and will not serve as a source or channel of
contamination."
Permeable material surrounding the piping could still be used for infiltration and serve as a source of contamination to
the extent that contaminants remain present in the permeable material or surrounding soil. The requirements of
.1608(b)(2) can be met by excavating subsurface materials or by covering them with uncontaminated low -permeability
material. I can provide additional information if you are interested in some options.

Please submit a revised closure plan when you are able.
Have a nice Thanksgiving,
Thomas Slusser, L.G.
Program Manager
Underground Injection Control Program
ph# 919-807-6412
http://portal.ncdenr.org/web/­wq/­aps/qwpro
DWR - Groundwater Protection Branch
1636 Mail Service Center
Raleigh, NC 27699-1636
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Wang, Shuying
Sent: Tuesday, November 18, 2014 4:29 PM
To: Snow, William Scott
Cc: Knight, Sherri; Slusser, Thomas; Basinger, Corey
Subject: RE: Permit and Infiltration Gallery Closure - Oracle WQ0006992
Hi Scott,
Oracle Flexible Packaging / LLFlex has met the closure requirement 15A NCAC 02T .1608 (a), and you should pursue the
proposed closure procedures to meet 2T Closure Requirements .1608 (b) and (c).
Thomas, if I missed anything, please let Scott know directly, but copy me.
Thank both of you!
Effective October 22 at 5:00 pm, my new telephone number is 336-776-9702
Shuying Wang, P.G.
Hydrogeologist
NC DENR Winston-Salem Regional Office
Water Quality Regional Operations Section
Division of Water Resources
Email: [e-mail]
Phone:[phone]
Fax: [phone]
http://portal.ncdenr.org/web/wq/ps/gwp
Please be advised: Beginning October 23, 2014, the Winston Salem Regional Office
(WSRO) of the NC Department of Environment and Natural Resources (NCDENR) will
begin moving to a new location. Starting October 22, 2014 at 5:00 pm, our new main
telephone number will change to 336-776-9800. If you contact staff at their previous
telephone number, you will be directed to their new direct telephone number. All
regional office services, including file review, will continue and all appointments need to

be prescheduled with WSRO staff during this transition. If you have any questions or
concerns, please contact the main number provided above during our normal hours of
operation, 8:00 am to 5:00 pm.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties
From: Snow, William Scott [ma iIto: scottsnow(a)oraclepkg.com]
Sent: Tuesday, November 18, 2014 2:40 PM
To: Wang, Shuying; Slusser, Thomas
Cc: Knight, Sherri
Subject: RE: Permit and Infiltration Gallery Closure - Oracle WQ0006992
Hello Folks,
Oracle continues to pursue the possibility of permit closure for the above referenced site. If I interpret the permit
language and associated regulations concerning system closure correctly, Oracle is required to provide the following:
1) The reason for closure — The remediation system has been inactive since July 2010 with no apparent bounce
back in site contamination. In addition, no measurable contaminants were detected in groundwater for several
years prior to system deactivation. Therefore, Oracle believes there is no reason to continue permit -sponsored
operations.
2) Letter of permission from the oversight agency — Please recall the email dated October 9, 2014, from Qu Qi
stating that DWM has no issue with rescinding the permit.
3) Description of proposed closure procedure — Oracle proposes hiring a well contractor to cut the infiltration
gallery supply line pipe at the point of discharge from the groundwater remediation system. The pipe will be cut
below grade and filled with grout prior to installing a cap and re-covering the disturbed area. A similar
procedure is proposed at the four infiltration gallery stick ups. Cut pipe below grade, fill will grout, cap, and re-
cover the disturbed area.
I hope this email fulfills all requirements to proceed with system closure. However, if not, please let me know of any
additional information needed or other procedures you might recommend.
Sincerely,
W. Scott Snow, P.E.
Environmental Engineer
Oracle Flexible Packaging / LLFIex
220 Polo Road
Winston-Salem, NC 27105
[phone] (office)
[phone] (mobile)
From: Wang, Shuying [mailto:shuying.wang(cbncdenr.gov)
Sent: Friday, October 03, 2014 11:53 AM
To: Snow, William Scott
Cc: Slusser, Thomas; Knight, Sherri
Subject: RE: Permit and Infiltration Gallery Closure - Oracle WQ0006992
Hi Scott,

I am glad to hear that you are looking into the matter. To get the permit reclosed, please follow 2T .1608 Requiremelits
for Closure on the last second page of the attached 15A NCAC 02T. You may also want to check with the current permit.
Thanks for emailing me.
Shuying Wang, P.G.
Hydrogeologist
NC DENR Winston-Salem Regional Office
Division of Water Resources, Water Quality Regional Operations Section
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
shuying.wang(d)ncdenr.gov
http://porta1.ncdenr.org/web/wq/ps/gwp
From: Snow, William Scott[mailto:scottsnow(cboraclepkkq.com]
Sent: Friday, October 03, 2014 10:56 AM
To: Wang, Shuying
Subject: Permit and Infiltration Gallery Closure - Oracle WQ0006992
Hi Shuying,
I hope you are doing well. Oracle is looking at the possibility of permit closure for our Polo Road facility in Winston-
Salem (Permit WQ0006992). (This is NOT the Cunningham Ave site where the wells were closed due to the NCDOT road
project).
I am looking for the specific NCDENR Rules or Guidelines to follow in order to rescind the Operating Permit and close the
infiltration gallery. Any assistance you can provide, including documents, links, or referrals, will be greatly appreciated.
Thank you,
W. Scott Snow, P.E.
Environmental Engineer
Oracle Flexible Packaging / LLFlex
220 Polo Road
Winston-Salem, NC 27105
[phone] (office)
[phone] (mobile)
<DWQ 2003 Memorandum.pdf>
J. Kevin Slaughter, Senior Environmental Scientist
Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4615 Mobile [phone] I Main 704-586-0007
www.harthickman.com
hart hickman
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Rogers, Michael
From: Snow, William Scott <[e-mail]>
Sent: Wednesday, August 17, 2016 4:44 PM
To: Rogers, Michael
Cc: Wang, Shuying
Subject: RE: W00006992 Oracle
Hi Michael,
Oracle is still planning to close the permit. We are currently reviewing proposals to accomplish this and I
expect to have decision soon so that we can move forward with completing this process by the permit
expiration in October.
Best Regards,
W. Scott Snow, P.E.
Environmental Engineer
Oracle Flexible Packaging / LLFlex
220 Polo Road
Winston-Salem, NC 27105
[phone] (office)
[phone] (mobile)
From: Rogers, Michael[mailto:[e-mail]]
Sent: Tuesday, August 16, 2016 5:08 PM
To: Snow, William Scott; Kevin Slaughter; Matt Bramblett ([e-mail])
Cc: Wang, Shuying
Subject: RE: WQ0006992 Oracle
Disregard the email below if you are planning to close the GW remediation system. I ran a report on permits about to
expire and sent the email without checking my Outlook for other emails in regard to this permit. I see where there has
been some communication about closing the permit. Where are you at in this process?
Thanks
From: Rogers, Michael
Sent: Tuesday, August 16, 2016 4:54 PM
To: Snow, William Scott ([e-mail]) <[e-mail]>
Subject: WQ0006992 Oracle
Greetings -
The permit above will expire 10/13/2016. If you want to renew, we need a renewal application, which can be found at
link below.
Michael Rogers, P.G. (NC & FL)
Underground Injection Control (UIC) Program Manager - Hydrogeologist
NCDEQ- DWR
Water Quality Regional Operations Section
1636 Mail Service Center

Raleigh, NC 27699
Direct No. 919-807-6412
http://deg.nc.gov/`about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water-
protection/ground-water-applications
NOTE: Per Executive Order No. 150, all e-mails sent to and from this account are subject to the North Carolina Public
Records Law and may be disclosed to third parties.