NC0088773_Regional Office Historical File Pre 2016

North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
February 27, 2015
Mr. Jake Fitzgerald
Greensboro Site Manager
Dow Corning Corporation
2914 Patterson Street
Greensboro, NC 27407
Donald van der Vaart
Secretary
SUBJECT: Compliance Evaluation Inspection
Dow Corning Groundwater Remediation System — Greensboro, NC
NPDES Permit No. NC0088773
Guilford County
Dear Mr. Fitzgerald:
On February 25, 2015, Mike Mickey of this office met with Ronica Edgerton and Rachael
Crowell to perform a Compliance Evaluation Inspection on the Dow Corning groundwater
remediation system (GWR). The treatment system was found to be compliant with the NPDES
permit. The inspection findings are detailed below and an inspection checklist is attached for your
records.
I. Permit
The NPDES permit expires on June 30, 2016. A renewal notice should be mailed to you
approximately 8 months prior to expiration.. Please note that at the next renewal the permit will
require that the monthly self -monitoring reports (DMRs) for Dow Corning be submitted
electronically per new EPA rules.
U. Records/Reports
The DMRs were reviewed for the period January 2014 through December 2014. The facility was
found to be compliant with the effluent limits for this period. In addition, all monitoring was
performed per the frequencies specified in the permit. Research & Analytical Laboratories is
contracted to conduct the effluent sampling. A comparison of the December DMR with the
certified laboratory data sheets from R&A Labs showed that the values were transcribed onto the
monitoring report properly.
III. Facilitv Site Review
The GWR system for treating volatile organic compounds consists of the following: extraction
wells, oil/water separator, two granular activated carbon canisters and air stripper. The facility was
competently operated and maintained. No problems or concerns were noted.
450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105
Phone: [phone] \ Internet: www.ncwaterguality.org
An Equal Opportunity\ Affirmative Action Employer —Made in part by recycled paper

I
Mr. Jake Fitzgerald
Page 2
February 27, 2015
IV. Flow Measurement
The permit requires continuous flow recording. Effluent flow is monitored with an in -line totalizer
that is connected to the electronic control panel.
Your efforts to comply with the permit are appreciated. Should you have any questions
concerning this letter, please contact Mike Mickey or me at [phone].
Sincerely,
Sherri V. Knight, PE
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
cc: Ronica Edgerton (via email: [e-mail])
Central Files

Permit: NC0088773 Owner -Facility.
Greensboro remediation site
Inspection Date: 02/25/2015 Inspection Type: compliance Evaluation
Permit
Yes No NA NE -
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
. ❑
M
❑
application?
Is the facility as described in the permit?
' 'M
❑
❑
❑
# Are there any special conditions for the'permit? ..
1:1
0
❑'
❑
Is access to the plant site restricted to the general public?
❑
❑
❑
Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment: The monthly self -monitoring reports for the Dow Corning groundwater remediation system
were reviewed for the period January 2014 through December 2014. The facility was found
to be compliant with the -effluent limits and monitoring requirements of the NDPES' permit
The permitted 1,000 GPD GWR system consists of the following:
*recovery wells
*oil/water separator
*two qranular activated carbon canisters
*air stripper
*flow totalizer
rNote: the system description found on the Supplement to Permit Cover Sheet notes "final
effluent percolation to constructed wetlands". It is our understanding
that the wetlands were
not constucted across Patterson Street.l
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑
❑
❑
Is flow meter calibrated annually?
❑ ❑
0
❑
Is the flow meter -operational?
N ❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
'❑ ❑
0
❑
Comment:. The permit requires continuous flow recording. Effluent flow is measured with an in -line
totalizer meter that is connected to the electronic control panel. The totalizer is read 1/week
and the value is divided by seven to discern a daily flow value to report on the DMR.
The average discharge volume from the system for calendar year 2014 was approximately
630 GPD.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
N
❑
Page# 3

Permit: NC0088773 Owner - Facility: Greensboro remediation site
Inspection Date: 02/25/2015 Inspection Type: Compliance Evaluation
Effluent Ph3e Yes No NA NE
Comment: The GWR system is located in building #3 and discharges via a rubber hose to a floor drain
Leading to the storm drain system along Patterson Avenue The exact location of where the
discharge surfaces outside of the facility is not known
The system has a sample value on the discharge line to allow collection of the effluent from
inside the building.

jam
k>�®
CDEH
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Regional Operations Section
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
January 24, 2014
Mr. Jake Fitzgerald
Greensboro Site Manager
Dow Corning Corporation
2914 Patterson Street
Greensboro, NC 27407
SUBJECT: Compliance Evaluation Inspection
Dow Corning Groundwater Remediation System — Greensboro, NC
NPDES Permit No. NCO088773
Guilford County
Dear Mr. Fitzgerald:
On January 23, 2014, Mike Mickey of this office met with Ronica Edgerton and Rachael Crowell to
perform a Compliance Evaluation Inspection on the groundwater remediation system (GWR) at the above
facility. The Dow Corning GWR system was found to be in compliance with the NPDES permit. The
inspection findings are detailed below and an inspection checklist is attached for your records.
1. Permit
The NPDES permit was reissued effective February 1, 2013. The system discharges into a tributary of
South Buffalo Creek, class "WS-V; NSW" waters of the Cape Fear River Basin.
2. Records/Reports
The monthly self -monitoring reports (DMR's) were reviewed for the period January 2013 through
December 2013. The facility was found to be compliant with the NPDES effluent limits for this period.
In addition, all monitoring was performed per the frequencies specified in the permit. Research &
Analytical Laboratories is contracted to conduct the effluent sampling. A comparison of the December
DMR with the certified laboratory data sheets from R&A Labs showed that all data was transcribed onto
the monitoring report properly.
3. Facility Site Review
The groundwater remediation system for treatment of the volatile organic compound groundwater
contamination consists of the following: extraction wells, oil/water separator, two granular activated
carbon canisters and air stripper. Effluent flow is monitored with a totalizer connected to the electronic
control panel. The facility appeared to be competently operated and maintained.
North Carolina Division of Water Resources, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
Internet: www.ncwaterquality.org
One
NofthCax®lina
An Equal Opportunity 1 Affirmative Action Employer

Mr. Jake Fitzgerald
Page 2
January 24, 2014
- Your efforts to comply with the permit are appreciated. Should you have any questions
concerning this letter, please contact Mike Mickey or me at [phone].
Sincerely,
Sherri V. Knight, PE
Assistant Regiondl Supervisor
Water Quality Regional Operations
Division of Water Resources
cc: Ronica Edgerton (via email: [e-mail])
Central Files
E"O'

Permit: NCO088773 Owner - Facility: Greensboro remediation site
Inspection Date: 01/23/2014 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ❑ ❑ ■ ❑
Is the facility as described in the permit? ■ ❑ ❑ ❑
# Are there any special conditions for the permit? ❑ ■ ❑ ❑
Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? ■ ❑ ❑ O
Comment: The Dow Corning groundwater remediation (GWR) system was found to be
compliant with the NPDES permit for the review period January 2013 through December
2013. The NPDES permit expires next on June 30, 2016.
The GWR system consists of the following components:
* recovery wells.
* oil/water separator.
* two granular activated carbon canisters.
* air stripper.
* flow totalizer.
The system appeared to be competently operated and maintained.
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? ■ ❑ . ❑ ❑
Is flow meter calibrated annually? (100,0
Is the flow meter operational? ■ ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ■ ❑
Comment: The permit specifies continuous flow recording. Effluent flow is measured
using an in -line totalizing meter that is connected to the electronic control panel.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? ❑ ❑ ❑ ■
Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ ■
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ■ ❑
Comment: The GWR system is located in Building #3 and discharges into a floor drain
that leads to a tributary of South Buffalo Creek, class "WS-V; NSW" waters in the Cape
Fear River Basin. The exact location that the effluent exits the storm drain system into
the side ditch along Patterson Street is not known.
Page # 3

Division, of Water Resources
August 6, 2014
MEMORANDUM
To: Corey Basinger
Water Quality Supervisor, WSRO
Through: Cindy A. Moore
Supervisor, Aquatic Toxicology Branch
From: Carol Hollenkamp C
Quality Assurance, Off, er, Aquatic Toxicology Branch
Subject: Whole effluent toxicity test results
Dow Corning Company
NPDES Permit # NC0088773/001
Guilford County
The aquatic toxicity test using grab samples of 'effluent discharged from Dow Corning Company has been
completed. Dow Corning Company has a permitted flow that is 0.001 .,pillion gallons per day ,(MGD)
discharging into an upper tributary to Buffalo Creek (7Q10 of N/A CFS). Whole effluent samples were
collected on July 8 by Jenifer Cater and facility representative Glenn Price and July i 0 by Jenifer Carter and
facility representative Neal McDuffe for use in a .chronic Ceriodaphnia dubia pass/fail toxicity test. The
test using these samples resulted in a pass. Toxicity information follows.
Test Type
Test Concentrations
Test Result
Control Survival
Control Mean Reproduction
Test Treatment Survival
Treatment Mean Reproduction
First Sample pH
First,Sample Conductivity
First Sample Total Residual Chlorine
Second Sample pH
Second Sample Conductivity
Second Sample Total Residual Chlorine
3-Brood Ceriodaphnia dubia pass/fail
90. %
Pass
92%
27.1
83%
25.5
7.61 SU
455 micromhos/cm
<0.10 mg/L
7.57 SU
459 micromhos/cm
<0.10 mg/L
Test results for the above samples indicate that the effluent would not be predicted to have water quality
impacts on receiving water. These samples were split and tested by Research and Analytical Laboratories.
The chronic Ceriodaphnia dubia pass/fail toxicity test run by Research and Analytical Laboratories also
resulted, in a pass. Please contact us if further effluent toxicity monitoring is desired. We may be reached at
(919) 743-840.1.
Basin: CPF02
cc: Central Files
Jenifer Carter, WSRO
Aquatic Toxicology Branch Uater Sciences Section

1V`L JWJ 1i'i Z0 - IYILV. vYa V V 4LICIF kQUjaULy i-s-egon
:+ 4XI[CITY SAWLIE COLLECTION FORM page I of ARO FRO IRO RRO WaRO WiRO WSAt
Facility/Water Body ��a� �jYM ;�
NPDES # NC 0 3
0m g Outfall # I
County ���� Basin/Sub-basin
Receiving Stream- (/�� sULC jPJAA l U �
� L'
— Collector(s) (print)' rf���/� �,f2c. f yti
Grab Sample Composite Sample ❑ Composite Type:
❑ Constant Time/Constant Volume: samples/hour for hours
❑ Flow Proportional
Sampling Equipment Used: ❑ DWQ Portable Sampler or ❑ Facility's Sampler 61'�o h
Date Began Time Began Date End Time End
121
Sampling Site
Description
Container: [914L (1 gal) PE cubitainer ❑Other (describe) # of containers_
Chlorinated: ❑ Yes O'io ollected on Ice or in Refrigerated Sampler: ❑ Yes ❑ NoN//l Shipped on Ice: 0� ❑ No
Method of Shipment: Courier 0 Bus ❑ Staff ❑ Other (explain):
DateAime oftransfer to shinner nr cnnrie.r hnx
Comments:
`S lit" sample, splitting lab name: 2 /"/ za/
Did DWQ staff perform the split? �C-5' 64) �r �i� Zp If 1�®, then did DWQ staff witness the split? .
Collectors)
Si ature: - - C�- Date _n
Additional s mnle h a(dler recnrrl.a- <
Relin uished by:
Received by:
Date:
Time:
Relinquished by:
Received by:
Date:
Time:
Relinquished by:
Received by:
Date:
Time:
Relinquished by:
Received b :
Date:
Time:
DWQ/Environmental Sciences Section
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699-1621
ESS Courier #: 520101
Use street address only if shipping FedEx or UPS
Street address: 4401 Reedy Creek Road
Raleigh, NC 27607
phone: [phone]

... .a..a.�.au- nsnve crn vv ca acpn �UHaA.Illt d�' jt_ euon
D2�7tCITY SAITLE COLLECTION FORM page I of A.RO FRO MRO RR® WaRR® WBRRO
Facility/Water Body
NPDES #
Outfall #7 . �.
CountyL&1,17ZV'66' Rasin/Sub-haSin -
Receiving Stream .I �� 7U Fx t /A lQ rre
—-Collector(s) (print) 1, �� �' f �. r z a/Q /4-( ne__
Grab Sample - El/"- Composite Sample ❑ Composite Type:
❑ Constant Time/Constant Volume: samples/hour for
❑ Flow Proportional
Sampling Equipment Used: ❑ DWQ Portable Sampler or ❑ Facility's Sampler
Date Began Time Beg �,'%�� sate End Time End
hours
Sampling Site 2(/
Description
Container: K]-,(L (1 gal) PE cubitainer FlOther (describe) nF nnn+a;n Are f
Chlorinated: L j Yes Lj to Collected on Ice. or in Refrigerated Sampler: ❑ Yes ❑ No Al* Shipped on Ice: No
Method of.Shipmeni: Courier 0-Bus ❑ Staff El Other (explain)-
Date/time of transfer to shipper, or courier box:.
CommenIU'ts: %�hate d a t 2)rq � f �� .SaAPI %rh Q46 7 /(! �4_
" Split" sample, splitting lab name:
Did DWQ did Q staff erfortn the split? �/i C Gr 5 If NO, then DWQ staff witness the
"1� _...,_ ;.� MAMR, ye.
Collector(s)::"
Si ature: \ Date:
Additional sdinnle ha tiler recnrrlc• /
it?
�
Relinquished by:
Received, by:
Date:
Time:
Relinquished by:
Received by:
Date:
Time:
Relinquish b :
Received by:
Date:
Time:
Relinquished by:
Received b :
Date:
fiime:
DWQ/Environmental Sciences Section
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699-1621
ESS Courier #: 520101
Use street address only if shipping FedEx or UPS
Street address: 4401 Reedy Creek Road
Raleigh, NC 27607
phone: [phone]

Mickey, Mike
From: Weaver, Charles
Sent: Wednesday, March 26, 2014 11:01 AM
To: Cranford, Chuck; Henson, Belinda; Parker, Michael; Smith, Danny; May, David; Gregson,
Jim; Basinger, Corey
Cc: Allocco, Marcia; Mickey, Mike; Brantley, Mark; Bullock, Robert; Hennessy, John; Bolich,
Rick
Subject: rescission requirements for groundwater remediation discharge sites
Importance: High
There are currently 102 remediation sites covered by NCG510000, the General Permit for discharges from petroleum -
contaminated groundwater remediation systems.
There are currently 41 remediation sites with individual NPDES permits (NC00).
Danny Smith & Rich Bolich let me know that there are specific rules for shutdown of such sites at 15A NCAC 2T.1608. As
you receive and evaluate rescission requests for remediation system permits, p.lease be certain that these steps have
been taken by the permittee / consultant:
15A NCAC 02T.1608 - REQUIREMENTS FOR CLOSURE
(a) 30 days prior to initiation of closure of a groundwater remediation system, the Permittee shall submit the following
documentation to the Division:
(1) the reason(s) for closure,
(2) a letter from the oversight agency authorizing closure of the system, and
(3) a description of the proposed closure procedure.
(b) The following closure procedures shall be followed:
(1) ' injection well closure procedures as specified in 15A NCAC 02C.0214, and
(2) 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.
(c) Within 30 days following upon completion of the closure of a groundwater remediation system, the Permittee shall
submit the following documentation to the Division:
(1) a description of the completed closure procedure;
(2) the dates of all actions taken relative to the procedure; and
(3) a written certification that the.closure has been accomplished, and that the information submitted is
complete, factual and accurate.
I realize that in some cases, the systems are abandoned and in disrepair; also, the personnel who installed them are long
gone. We'll have to deal with those on a case -by -case basis. If there is no need for the discharge and no discharge
occurring, we should rescind the permit / CoC.
For those of you [like me] who were unaware of the closure requirements, this message is FYI.
For those of you who knew and were already doing this, please accept my thanks.
Thanks also to Danny & Rich for educating me.
Let me know if you have questions, comments, etc.
CHW

N.C.Dept. ofENR
SEP 3 0 2013
V.,, Aston -Salem
September 23; 2013
Point. Source Branch,
Surface Water Protection Section
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Delegation of Signature Authority
Dow Corning — Greensboro GW-REIN
NPDIES No. NCO089773 : Physical/Chemical, Class i
To Whom It May Concern:
Recently, Jake Fit7,gerald has replaced Pamela Berry as Plant Manager of the Dow
Corning -Greensboro facility. By notice of this letter, I hereby delegate signatory
authority to each of the following individuals for all permit applications; discharge
monitoring reports, and other information relating to the operations at Dow Corning -
Greensboro as required by all applicablefederal, state, and local environmental agencies
specifically with the requirements for signatory authority as specified in 1 SA NCAC
2B.0506..
Walt Plekan, LG: Project Manager with URS Corporation
Stephanie Hempel, LG Project Geologist with URS Corporation
If you have any questions regarding this letter, please. feet free to contact me at (336)
547-7100.
SincerelPil-
Jake Fitzgerald
Plant. Manager
cc: W-ir sfon-SAlm vRegional fffice,_S.uriaca W-T-1Pratectiar-S:es:ti__.,c n�
Technical Assistance and Certification. Unit

Mickey, Mike
From: [e-mail]
Sent: Monday, February 25, 2013 8:54 AM
To: Mickey, Mike
Subject: RE: Dow Corning Permit Contacts
Hi Mike,
We can change Facility Contact Person to Pamela B. Solomon [phone].
For right now everything else can remain the same. When we make any changes, I will contact you. Thanks for your
help.
Permit: NCO088773 Version: 2.0 Status: ctive
Enti
*Mhtion T e
Name
Title
' - Phone Number
Facility
Contact Person
Clark, David
Facility
Contact Person
O'Connor, Joyce M.
[phone]
Owner
Owner
Solomon, Pamela B.
[phone]
Permit
Billing
Cross, Ronald E.
[phone]
From: Mickey, Mike [mailto:[e-mail]]
Sent: Friday, February 22, 2013 2:13 PM
To: EDGERTON, RONICA S. (RSEDGERT)
Subject: Dow Corning Permit Contacts
Ronica — Below is the contact information that is in our database. Permit correspondence goes to the "Owner" which is
Pamela Solomon ( is it Pamela Berry now?). The annual permit fee is sent to Ronald Cross. Let me know if anything is
outdated or needs to be changed. Thanks, Mike.
Permit: NCO088773 Version: 2.0 Status: ctive
--itntity
Type
Name
Title
Phone Number
Facility
Contact Person
Clark, David
Facility
Contact Person
O'Connor, Joyce M.
[phone]
Owner
Owner
Solomon, Pamela B.
[phone]
Permit
Billing
Cross, Ronald E.
[phone]
Mike Mickey
Mike.MickevPNCDENR.eov
NC Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North
1

Mickey, Mike
From: Corporon, Joe
Sent: Thursday, September 13, 2012 9:28 AM
To: Mickey, Mike
Subject:. RE: Permit Renewal - DRAFT DOW Corning Greensboro NCO088773
Attachments: image001.]pg; 88773 DOW Cover Letter 2012 FINAL.doc; 88773 DOW Permit & EFF 2012
FINAL.doc
Mr. Mike - thanks for your careful review. "1,2 Dichloromethane" has been corrected to "...ethane" [1,2 DCE]; PCE is
Tetrachloroethene, the P is "tetra" meaning "4" ...; alas, not in this permit, my bad. [O also not a chemist; studied
Hydrogeology].
Permit held due to problems with Public Notice. Good catch/good work on the missing discussion of removing permit
limits — I've added an explanation to the cover letter final (see attached). Drafting final for signature today — likely signed
next week. Hardcopy to follow.
Respectfully,
Joe R Corporon, L.G.
Environmental Specialist
Fc NPDES Program
NCDENR/Division of Water Quality (DWQ)
Surface Water Protection Section
919-807-6394; FAX [phone]
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: Mickey, Mike
Sent: Thursday, July 05, 2012 3:50 PM
To: Corporon, Joe
Cc: Basinger, Corey
Subject: RE: Permit Renewal - DRAFT DOW Corning Greensboro NCO088773
Joe —The parameters mentioned in the cover letter and fact sheet for relaxed monitoring do not exactly match. In
addition, neither the cover letter nor the fact sheet mention dropping any limits, however, the draft permit contains no
limits for 1,2—dichloroethane, 1,1,1,- trichloroethane and vinyl chloride. If limits are to be dropped, the cover letter and
fact sheet should specifically state that.
Specifics below:
1) Cover letter says monitoring for TCE (1,1,1—Trichloroethane) and PCE (what is this abbreviation for?) are relaxed
form monthly to quarterly. No problem with that. However, the cover letter does not mention dropping any permit
limits.
2) Fact sheet says monitoring relaxed for DCA (1,2 — Dichoromethane — this parameter was not mentioned in the old
permit. I assume it is synonymous with methylene chloride) and TCA (1,1,1,-Trichloroethane).

If I am missing something with the abbreviations, please set me straight. I'm a biologist, definitely not a chemist.
Thanks, Mike.
Mike Mickey
Mike.Mickey@ NCDENR.eov
NC Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
FAX: [phone]
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: Basinger, Corey
Sent: Tuesday, July 03, 2012 2:01 PM
To: Mickey, Mike
Subject: FW: Permit Renewal - DRAFT DOW Corning Greensboro NC0088773
For your review and comment.
W. Corey Basinger
Regional Supervisor
Surface Water Protection Section
Winston-Salem Regional Office
Division of Water Quality
Email: [e-mail]
Phone: [phone]
Fax [phone]
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: Corporon, Joe
Sent: Tuesday, July 03, 2012 1:39 PM
To: Basinger, Corey
Cc: Meadows, Susan; Pugh, James L.
Subject: Permit Renewal - DRAFT DOW Corning Greensboro NC0088773
Please review and comment as needed [note Fact Sheet as last page]
Respectfully,
Joe R. Corporon, L.G.
Environmental Specialist
, WA Ic
.;;-
NPDES Program
NCDENR/Division of Water Quality (DWQ)
Surface Water Protection Section

I
NODE
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
September 18, 2012
Ronald E. Cross, P.E., Project Engineer
Cardinal Resources LLC
1505 East Caron Street, Suite 200
Pittsburg, Pennsylvania 15203
Dee Freeman
Secretary
Subject: Issuance of NPDES Permit
NCO088773 — Class 1, Physical /Chemical
Dow Corning — Greensboro GW-REM
Guilford County
Dear Mr. Cross:
The Division of Water Quality (the Division or DWQ) hereby issues the attached NPDES permit for the
subject facility. We issue this permit pursuant to the requirements of North Carolina General Statute 143-
215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental
Protection Agency dated October 15, 2007, or as subsequently amended.
Changes to Your Previous Permit -- The Division understands that you have made no changes to your
wastewater treatment facility since last renewal. We have updated your facility description and site map,
and added parameter codes to Section A. (1.) for your convenience. While noting your sporadic
discharge, restarting operations in May of 2009, we have renewed this permit considering your monthly
discharge monitoring reports (DMRs), compliance history, and the effluent monitoring database. Because
the parameters TCE and PCE were not detected, the Division has relaxed their monitoring frequencies
from Monthly to Quarterly. Based on our review of discharge conditions and your compliance history
with both acute and chronic Whole Effluent Toxicity (WET) tests, you may discontinue Acute testing
and continue with Chronic WET testing only [Ceriodaphnia dubia, code TGP3B].
Lastly, we have removed the permit limits for the parameters 1,2 DCA, 1,1,1 TCA, and Vinyl Chloride
because data submitted do not show reasonable potential to exceed their respective water -quality
standards [see Section A. (1.)]. Monitoring of these parameters has likewise been reduced to Quarterly.
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty
(30) days after receiving this letter. Your request must take the form of a written petition conforming to
Chapter 150B of the North Carolina General Statutes, and you must file it with the office of
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 NortllCarolina
Phone: [phone] FAX: [phone]
Internet: www.ncwaterqualit .org atutrally
An Equal Opportunity 1 Affirmative Action Employer

Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a
demand is made, this permit shall be final and binding.
This permit is not transferable except after notifying the Division of Water Quality. The Division may
require permit modification, or revocation and re -issuance. Please note that this permit does not affect
your legal obligation to obtain other permits required by the Division of Water Quality, the Division of
Land Resources, the Coastal Area Management Act, or other federal or local governments.
If you have questions, or if we can assist you further, please contact Joe R. Corporon, L.G. at
[ioe.corporongncdenr.gov] or call [phone].
Respectfully,
Charles Wakild, P.E.
Enclosure: NPDES Permit NCO088773 (FINAL)
hc: Central Files
NPDES Program Files
WSRO/SWPS, Cory Basinger; Mike Mickey
ec: Aquatic Toxicity Unit, Attn: Susan Meadows
Cardinal Resources, Barbara Jones [bjones @cardinalres.com]
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 �s7On�e, t
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 1y of iCarol.ina
Phone: [phone] FAX: [phone]
Internet: www.ncwaterquality.org Naturallrf
An Equal Opportunity 1 Affirmative Action Employer

Permit NC0088773
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPa-
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Dow Corning Corporation
is hereby authorized to discharge wastewater from a facility located at the
Dow Corning - Greensboro GW-REM
2914 Patterson Street, Greensboro
Guilford County
to receiving waters designated as an unnamed tributary (UT) to South Buffalo Creek in the Cape Fear
River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, II, III, and IV hereof.
The permit shall become effective November 1, 2012.
This permit and the authorization to discharge shall expire at midnight on June 30, 2016.
Signed this day September 18, 2012.
Charles Wakild, P. E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0088773
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Dow Corning Corporation
is hereby authorized to:
1. continue to operate a 0.001 MGD groundwater-remediation system to remove volatile organic
compounds including chlorinated hydrocarbons utilizing
• equalization tank
• air stripper
• granulated activated carbon (GAC) filter
• discharge line
• final effluent percolation to constructed wetlands
located at the Dow Corning — Greensboro GW-REM facility, 2914 Patterson Street, Greensboro,
in Guilford County, and
2. discharge from said treatment works via Outfall 001, at a location specified on the attached map,
to an unnamed tributary to the South Buffalo Creek [Stream Segment 16-11-14-2], a waterbody
currently classified C-NSW within Subbasin 03-06-02 of the Cape Fear River Basin.

Permit NC0088773
A. (1) EFFLUENT LIMITATIONS. AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to
discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
PARAMETER
[Parameter Codes] ..
EFFLUENT
-LIMITATIONS
MONITORING-
REQUIREMENTS
Monthly.
Average
Daily
Maximum
Measurement,
Frequency.
Sample
Type
Sample
Location
Flow
50050
0.001 MGD
Continuous
Recording
Effluent
Total Suspended Solids
C0530
30.0 mg/L
45.0 mg/L
Monthly
Grab
Effluent
Acetone
81552
Quarterly
Grab
Effluent
2-Butanone
78356
Quarterly
Grab
Effluent
Chloroethane
34311
Quarterly
Grab
Effluent
Chloroform
32106
Quarterly
Grab
Effluent
1,1 — Dichloroethane (1,1 DCA)
34496
Quarterly
Grab
Effluent
1,2 — Dichloroethane (1,2 (DCA)
32103
Quarterly
Grab
Effluent
1,2-Dichloropropane (1,2 DCP)
34541
Quarterly
Grab
Effluent
Methylene Chloride
34423
Quarterly
Grab
Effluent
1,1,1-Trichloroethane (1,1,1 TCA)
34506
Quarterly
Grab
Effluent
Trichlorofluoromethane
34488
Quarterly
Grab
Effluent
Vinyl Chloride
39175
Quarterly
Grab
Effluent
Total Xylenes
81551
Quarterly
Grab
Effluent
[WET Testing - Chronic Toxicity
TGP3B
Quarterly
Grab
Effluent
Footnotes:
1. Flow may be measured using a totalizing flow meter.
2. Whole Effluent Toxicity (WET) testing, limited; Chronic (Ceriodaphnia dubia) @ 90% effluent
concentration in January, April, July, and October [see Section A. (2)].
Conditions:
1. All Quarterly effluent samples shall be collected concurrently with chronic WET test sampling.
2. The Permittee shall discharge no floating solids or foam.

Permit NCO088773
A. (2) CHRONIC TOXICITY - LIMITED (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%. The permit holder shall perform at a minimum,
quarter lx monitoring using test procedures outlined in the "North it
Ceriodaphnia Chronic Effluent
Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of January, April, July and October. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then the Permittee shall perform multiple -concentration testing at a minimum, in each of the two
following months, as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP313 for
the pass/fail results and THP313 for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent
to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT Forms
submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

d ,
MCDENR
Borth Carolina Department of Environment and Natura
Division of Water Quality
Pat McCrory Charles Wakild, PE
Governor Director
February 25, 2013
Ms. Pamela B. Solomon
Greensboro Site Manager
Dow Corning Corporation
2914 Patterson Street
Greensboro, NC 27407
Resources
John E. Skvarla, III
Secretary
SUBJECT: Compliance Evaluation Inspection
Dow Corning Corporation Groundwater, Remediation System — Greensboro, NC
NPDES Permit No. N00088773
Guilford County
Dear Ms Berry:
On February 22, 2013, Mike Mickey of this office met with Ronica Edgerton and Rachael Crowell
to perform a Compliance Evaluation Inspection on the groundwater remediation system (GWR) at the
Dow Corning facility. This type_ of inspection consists of two basic parts: an in office file review and an
on -site inspection of the treatment system. The inspection found that Dow Corning was in compliance
with the NPDES permit. The inspection findings are detailed below and an inspection checklist is
attached for your records.
I. Permit
The NPDES permit was recently reissued with an effective date of February 1, 2013. The permit cover
letter noted the numerous changes in limits and monitoring frequencies.
Il. Self -Monitoring Program
The monthly self -monitoring reports (DMR's) were reviewed for the period January 2012 through
December 2012. The facility was found to be in complete compliance with final NPDES effluent limits for
the above period. In regards to the permit monitoring requirements, it was noted that all sampling was
performed per the frequencies specified in the permit, except for the acute and chronic toxicity tests
missed in January 2012. This monitoring omission was previously addressed by correspondence from
the Division dated March 28, 2012.
III. Flow Measurement
Effluent flow is monitored with a totalizer connected to the electronic control panel. Daily flow values are
reported on the DMR's as required.
IV. Sludge Handling and Disposal
No solids are generated that require disposal. The carbon canisters are changed out as needed.
V. Operations and Maintenance
The facility appeared to be competently operated and maintained. No concerns or problems were noted.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 One
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748 Noft Carolina.
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer

Ms. Pamela B. Solomon
Page 2
February 25, 2013
VI. Facility Site Review
The groundwater remediation system consists of recovery wells, an air/water separator, vapor phase
carbon canister, air stripper, two liquid phase carbon canisters, flow totalizer and effluent discharge line.
VII. Records/Reports
A review of the facility files showed that all records are being maintained according to the permit. A
comparison of the December DMR with the certified laboratory data sheets from R&A Labs showed .that
all data was transcribed properly.
VIII. Effluent/Receiving- Waters
The system discharges into a tributary of South Buffalo Creek, class "WS-V; NSW" waters of the Cape
Fear River Basin.
Should you have any questions concerning this report, please contact Mike Mickey or me at (336)
771-5000.
Sincerely,
W. Corey Basinger
Regional Water Quality Supervisor
Surface Water Protection Section
cc: Ronica Edgerton (via email: [e-mail])
Central Files

i
Permit: NCO088773 Owner - Facility: Greensboro remediation site
Inspection Date: 02/22/2012 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ❑ n ■
Is the facility as described in the permit? ■ Cl n n
# Are there any special conditions for the permit? n ■ n ❑
Is access to the plant site restricted to the general public? ■ n n n
Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑
Comment: The NPDES permit was reissued effective February 1, 2013. The permit
cover letter noted numerous changes in limits and monitoring frequencies. The
groundwater remediation system consists of the following: recovery wells, air/water
separator, vapor phase carbon canister, air stripper, two liquid phase carbon canisters,
flow totalizer and effluent discharge line.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
❑
n
11
Is all required information readily available, complete and current?
■
n
Cl
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
❑
n
n
Are analytical results consistent with data reported on DMRs?
■
n
Is the chain -of -custody complete?
■
1100
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
M
Are DMRs complete: do they include all permit parameters?
■
Q
n
Q
Has the facility submitted its annual compliance report to users and DWQ?
n
❑
■
n
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
❑
❑
■
Q
Is the ORC visitation log available and current?
❑
O
■
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
n
■
n
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
■
n
Is a copy of the current NPDES permit available on site?
■
n
n
n
Facility has copy of previous year's Annual Report on file for review?
n
Q
■
n
Page # 3

IN
Permit: NCO088773 Owner - Facility: Greensboro remediation site
Inspection Date: 02/22/2012 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Comment: The GWR system is classified as a PC-1. All records were thorough and
complete. A comparison of December 2012 self -monitoring report (DMR) with the
laboratory data results showed that all values were correctly transcribed onto the DMR.
The only monitoirng issue noted invovled the January 2012 toxicity monitoring that did
not occur. This omission was previously addressed by correspondence from the
Division.
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? ■ n n n
Is flow meter calibrated annually? n n n ■
Is the flow meter operational? ■ n n n
(If units are separated) Does the chart recorder match the flow meter? n n ■ n
Comment: The permit specifies continuous flow recording. Effluent flow is measured
using a in -line totalizer.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
n
❑
■
n
Is sample collected below all treatment units?
■
n
n
n
Is proper volume collected?
■
n
n
n
Is the tubing clean?
n
n
■
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
n
❑
■
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
n
n
n
Comment: The permit specifies grab sampling for all parameters. Effluent sampling is
performed by R&A Labs.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained? ■ n n n
Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ ■
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ■ n
Comment: The GWR treatment system discharges into a floor drain that leads to a
tributary of South Buffalo Creek, class "WS-V; NSW" waters in the Cape Fear River
Basin.
Page # 4

/ -I
AT.
41
HUD-ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Chuck Wakild, P.E.
Governor Director
July 3, 2012
Ronald E. Cross, P.E., Project Engineer
Cardinal Resources LLC
1505 East Caron Street, Suite 200
Pittsburg, Pennsylvania 15203
N.C.0apt, of ENR
AUG 0 2 2012
Winston-Salem
Ee IUAeI OfflCe
Dee Freeman
Secretary
Subject: NPDES Permit - DRAFT Review
NCO088773 —Class 1
Dow Corning — Greensboro GW-REM
Guilford County
Dear Mr. Cross:
In response to your request to renew the subject permit for DOW Corning, the Division of Water Quality (the
Division) hereby transmits this draft permit for your review and comment. Please read it carefully to assure your
understanding of the permit limits and monitoring conditions, and to correct errors, if any.
Concurrent with this notification, the Division will solicit public comment on this draft by publishing a notice in
newspapers having circulation in the general Guilford County area, as required by the NPDES Program. Please
provide your written comments, if any, to [e-mail]] or write to my attention at DENR / DWQ /
NPDES Program no later than August 3, 2012, approximately 30 days after receiving this document. We welcome
your comments on this draft, but they are not required.
Changes to Your Previous Permit -- The Division understands that you have made no changes to your wastewater
treatment facility since last renewal except to sporadically discharge, restarting operations in May of 2009. We
have renewed your permit considering monthly discharge monitoring reports (DMRs), compliance history, and the
effluent monitoring database. Because the parameters TCE and PCE were not detected, we have relaxed their
monitoring frequencies from Monthly to Quarterly. Based on our review of discharge conditions and your
compliance history with both acute and chronic Whole Effluent Toxicity (WET) tests, you may discontinue acute
WET testing. Please note that the quarterly chronic WET test is still required [using Ceriodaphnia dubia]. Finally,
we have updated your facility description and site map, and added parameter codes to Section A. (L) for your
convenience.
Following the mandatory 30-day public comment period, the Division will review all pertinent comments and
take appropriate action prior to issuing an NPDES permit final. If you have questions concerning this draft, please
e-mail me [e-mail]] or call_ my direct line (919)107-630
Enclosure: NPDES Permit NCO088773 (DFLUA) /
hc: NPDES Program Files [draft and Fact Shee
ec: WSR�/SRTPS, Atir_: Cory Basinger [dram an Fact Sheet]
Aquatic Toxicity Unit, Attn: Susan ivi�aaows [draft and Fact Sheet]
TACU, Attn: James Pugh [draft and Fact Sheet]
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: 9IM07-63001 FAX: 9IM07-6492 NofthCarolina
internet: www.ncwaterqualit .org Naturally
j4 �` yr�j��
An Equal Opportunity 1 Affirmative Action Employer N/ i L y

Permit NCO088773
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions of North Carolina General �tatuta`-T 15.1, other lawful standards
and regulations promulgated and adopted by the Nort Management
Commission and the Federal Water Po fo Control Adt`' s amended,
Dow Coming C`h or x1
is hereby authorized to discharg to ater fra „a facility located at he
Dow ' arning` re rnslio'� `REM
4 er `on Str Greensboro
'I-29i ti� "
to receiving waters design& d as anun,tiam butary (UT) to South Buffalo Creek in the Cape Fear
River Basin in accordance ? effluent1� ni to v , monitoring requirements, and other conditions set
forth in Parts I, II, III, andeigof. '
The permit shall become effective
92012.
This permit and the authorization to discharge shall expire at midnight on June ��, 2016.
Signed this day , 2012.
Charles Wakild, P. E., Director
Division Url 'VtVrder Quality
By Authority of the Environmental Management Commission

Approximate Property
Yk
Boundary
ftst
lip
/,7 Outfall 001
j,
'Ilk
7;
A
UT to South Buffalo Creek
(flows South)
�- J't �, 5�<'1, A i'�',' t� - -.'�.. •�M lttYY•"tii 4 't,i:
South Buffalo Creek
-7
7;
(flows le yes* lie n<
yr, eK-
IZ
i✓
ict, -k—
V
f.
-7 W
W]
US Hwy 1-40
High Point R
477112WM
.
2— A
1 7��k
DO Corning Corporation
Greensboro GW-REM
Receiving Stream: UT to South Buffalo Creek Stream Segment: 16-11-14-2
State Grid/Quad: C- I 9-SE / Greensboro, NC Sub -Basin: 03-06-02
Stream Class: WS-V; NSW HUC: 03050105
LAtitnde.- 16' V 14" N Permitted Flow: 0,001 MGrD
Longitude: 79' 5 1' 04" W Drainage Basin: Cape Fear River
Facility
Location
not to scale
NT
emnit NCO088773
o I I
rt�h NPDESP I Guilford County

Permit NCO088773
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to
discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EF<' N .
T
t, .
NMQITQMD G
a. l'AtAIVE'TETJIRElYIENT
_FLUE
RE S
Q'.
a dniet Co es 4P
f
�1VMo h k...
F 4•- '
E.S.'"' . yak:,
`'1V.[easuaein'ent;.
1
:Sam P;,iew�rt
-Avers' e.s
g_
:Da
a , ttna.
1VI xm
_ Ere uenc
qH..
-.>p.
r
..
.')Location
Flow'
50050
0.001 MGD
Continu9rs
Recording
Effluent
Total Suspended Solids
C0530
30.0 mg/L
45.0 mg/L
M riflily: l
Grab
Effluent
Acetone
81552
rly ��"
e
Grab
Effluent
2-Butanone
78356
/@uarterly
Grab
Effluent
Chloroethane
34311
`;
Quarterly
\� rab
Effluent
.
Chloroform
32106
Qu erl}�}r
Effluent
1,1 - Dichloroethane
34496
- u ' rly
Gra ,
Effluent
1,2 - Dichloroethane
32103
Q ` "; rly
Grab
Effluent
_
-
1,2-Dichloropropane
34541
u .`r�
Grab
Effluent
Methylene Chloride
34423
rl y
Grab
Effluent
1, 1, 1 -Trichloroethane
34506
_, i ; '(
Qua�&ly
Grab
Effluent
Trichlorofluoromethane
1'34
`
Quarterly
Grab
Effluent
f
_ - -
Vinyl Chloride
39175
Quarterly
Grab
Effluent
Total Xylenes
551..
V
Quarterly
Grab
Effluent
Chronic Toxicity2
T P�3
\
��
Quarterly
Grab
Effluent
Footnotes:
1. Flow may be measured using a totalizing flow meter.
2. Whole Effluent Toxicity (WET) testing limited; Chronic (Ceriodaphnia) @ 90% effluent concentration in
January, Ap.-il, July, and October [See Section A. (2.) j.
Conditions:
1. The Permittee shall discharge no floating solids or foam.

DENR / DWQ / NPDES
EXPIDITED FACT SKEET - NPDES PERMIT DEVELOPMENT
NPDES Permit NCO088773
y4.. ..
I
"GW-REM
'Applicant/Facl"tyNaine..,-,, ;-_
Dow Corning Corporation / Greensboro Facility
AplcanfAddress; ';
2914 Patterson Street, Greensboro, NC 27407
41, Facily Acldess , `,=:.
same
'.T'erri%tted1owF(MGI3T _;`' ;'" :
0.001
Groundwater contaminated with chlorinated hydrocarbons
Ph sical/Chemical
G.ouri `
Guilford
`la i ; Statusr'
Renewal
Re" `iona flce;;f
g:..
WSRO
,
Str Charactens 1 t
a
eeiviii¢treau--=- ��
UT to South�Straai
WS-V; NSW
Buffalo Creek;C:Iass`fieato;,
16-11-14-2
Drainage,ba++sii1':,;
CapeFear
. ".
e
0.0
ier;7Q1'.t}(cs}
0.0
IMPaired
"3 ?(cfsrYPs rt
0.0
343 d .Lsted :+;e a..++Y�+"
„""`"
Yes (biological impairment)
( g p )
:w>,°
0.0
r* .;.,.,
kr ;;: -
,,5,;y u,,,;,-
~�State;Gr��l.+k;;�x��W.`. �
C19SE
` TRYG (+10,) yF =
100
USGTt o Quad` ry- r
Greensboro
SUmmary — In January 2009 Dow Corning Corporation received authorization to construct and operate
a groundwater remediation (GW-REM) / wastewater treatment system to remove volatile organic
compounds including chlorinated hydrocarbons. The facility began operation in May 2009 (see Engineer's
Cert, 22May2009).
The system consists of an EQ tank and air stripper followed by a polish filter of granulated activated carbon
(GAC). Since start-up, treated effluent has averaged 0.00053 GPD with a maximum reported of 0.0012
MGD (n = 831 flow days reported). Flow via Outfall 001 discharges to a man-made treatment wetland
where it percolates slowly, eventually recharging to an unnamed tributary to South Buffalo Creek.
Renewal — DWQ updated facility description and Map; add parameter codes to Section A. (L). Based
on parameters "not detected" (database n = 11 to 33 sample events), DWQ relaxed Monthly monitoring to
Quarterly for DCA (1, 2 — Dichloromethane) and TCA (1, 1, 1 -Trichloroethane). No other changes to
parameter limits or monitoring.
WET Testing — Since start-up the permit has required both chronic and acute WET testing under zero -
flow receiving -stream conditions. Because test results are all reported as "PASS," and because the Aquatic
Toxicology Unit believes that acute testing is unjustifiably redundant, the Division will discontinue the
acute test; renew with chronic only, 7-day P/F using Ceriodaphnia dubia at 90% concentration [see email
RPA - Reasa{ile Potenti nalysis (RPA) - RPA was not conducted because all potential contaminates
of concern vverX repo -u aS "not ucteCt2u andJ2 uicli rc'.Sl3ectivC 1 "aCtlCa/ Vida77eliaeivil LEVPIS ll QLS�.
Joe R. CoiWn, L.G., NPDES Unit / 919-807-6394. 02July2012
Expedited Fact Sheet
Renewal 2012 -- NNAIS Permit NCONV73
Page 1

asin - Ca ,,e`F6arAiver,B­"`
xIieWumbe­
C a§sirlea ion,e ass-Dbte
3 , '
-:Deschtion
scr
—_.._
peca'Rn,_,,,S ,
Six Runs Creek
18-68-2-(0.3)
C;SW
04/01/59
.... . .. . . .......
to Quewiffle Swamp
. .
Six Runs Creek
18-68-2-(11.5)
C;Sw,ORW:+ 06/01/94
'From Quewiffle Swamp to Black River
115A NCAC 02B.0225 (e)(9)
Skipper,Hill Branch
18-66-6-2
C;Sw
04/01/59
,From source to Double Run
(------
Skunk Creek
17-40-1
C
03/01/77
;From source to Big Buffalo Creek
Slash Branch
18-23-16-6-1
WS-III
08/03/92
From source to Roundabout Branch
Smith Branch
18-20-31
WS_IV
08/03/92
Trorn-source to Upper Little River
..........
..... . ..... . . .. ........ . .....
. ......
....... . .... .... . .... ....
Smith Branch
16-11-11
WS-V;NSW
08/11/09
From source to Reedy Fork
... ..... ..... .. ___ — - - — ----------- - -- .......... . .... ... . . .. . .... ........ .......... . .... .. ... .... . . .................... . ........ ..... .
Smith Creek 18-74-63 C;SW 09/01/74
iFrom source to Northeast Cape Fear River
Smith Swamp (Jones Lake Drain) 18-46-7 C 09/01/74
'From Jones Lake to Turnbull Creek
. . . ........ ... . — -----
Smiths Creek 17-34 WS-IV 08/03/92
....... ...
:From source to Deep River
Smiths Mill Pond Run (Smiths Mill Pond) 18-68-12-14 C;SW 07/01/73
. .......... . . .. ... ...
:From source to South River
Smokehouse Creek 18-88-11 SC;HQW 08/01/90
From source to "ape FearRiver
............ .... . .... .
Snows Cut 18-87-31.5 SC 08/09/81
'From Carolina Beach Yacht Basin to Cape Fear River
Snows Marsh 18-88-2 SC 08/09/81
;Entire Marsh
South Buffalo Creek 16-11-14-2 WS-V;NSW 08/11/09
:From source to Buffalo Creek
South Fork Cane Creek
source to Cane Creek
16-28-5 WS-V;NSW 08/11/09
. ..... ..... ... . . ..... ...... ..... .
------ - — ------
Thursday, February 09, 2012 Based on Classifications as of 20120208 Page 81 of 98

Whole Effluent Toxicity Testing Self-Mo
itoring Summary
March 15, 201:
FACILITY REQUIREMEW
`
YEAR JAN
FEB
MAR APR
MAY
JUN JUL
AUG_
SEP
OCT
NOV
DEC
Domtar Paper Company, LLC chr lim: 6.
%
Ceri7dPF
y 2008 —
73.6
— —
>100
— —
73.8
—
—
>54.4.
—
NC0000680/001 Begina1/1/2011 Fraquency:Q
Feb May Aug Nov
+ NonComp:Single
2009 —
38.5
— —
>100
— —
>100
—
—
>100
—
County: Martin Region: WARO Subbasin: It
DA09
2010 —
73.8
— —
84.8
— —
>100
—
—
>100
—
PF: 55.0 Special
2011 —
1923
— —
>54.4
— —
>54.4
—
—
>54.4
—
7Q10: 1160 IWC(a/o)6.8 Order:
2012 —
Dow Coming Facility Chr lim: 9
% and Acu lim: 90 %
Ceri7dPF
2008 —
—
— —
—
— —
—
—
—
—
—
NC00813773/001 Begin 2/1/2009 Frequency: Q
Jan Apr Jul Oct
NonComp:
2009 —
—
— H
—
— Invalidt
—
Pass,Invalid
Pass,lnvalid
Pass
—
County. Guilford Region: `NSRO Subbasin:
PF02
2010 Invalid,Pass
—
— Pass,Pass
—
— Pass,Pass
—
—
Pass,Pass
—
—
PF: 0.001 Special
2011 Pass,Pass
—
— Pass,Paw
—
— Pass,Pass
—
—
H
Pass,Pass —
7Q10: IWC(°/a) Order:
2012 NR
H
Duke Pewer-Allen 002 chr lim: 2
%
Ceri7dPF
2008 Pass
—
— Pass
—
— Pass
—
—
Pass
—
—
NC0004979/002 Begin 3/1/2011 Frequency: Q
Jan Apr Jul Oct
+ NonComp:Single
2009 Pass
—
— Pass
—
— Pass
—
—
Pass
—
—
County: Gaston Region: MRO Subbasin: C
TB34
2010 Pass
—
— Pass
—
— Pass
—
—
Pass
—
—
PF: NA Special
2011 Pass
—
— Pass
—
— Pass
—
—
Pass
—
—
7Q10: 95.0 IWC(%) 24 Order:
2012 Pass
Duke Power-Eelews Creek/003 chr lim: 1
%
Ceri7dPF
2008 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
NCO024406/003 Begin12/1/2007 Fuequency:Q
Feb May Aug Nov
+ NonComp:Single
2009 --
Pass
— —
Pass
— —
Pass
—
—
Pass
—
County: Stokers Region: WSRO Subbasin: ROA01
2010 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
PF: NA Special
2011 —
Pass
— —
Pass
— —
Pass
—
—•
Pass
—
7QIO: 30.0 IWC(%) 19 Order:
2012 —
Duke Power-E,'uck Steam chr lim: 0.
%
Ceri7dPF
2008 —
—
Pass —
—
Pass —
—
Pass
—
—
Pass
NC0004774/602 Begin 1/1/2012 Fiequency:Q '
Mar Jun Sep Dec
+ NonComp:Single
2009 --
—
Pass —
—
Pass —
—
Pass
—
—
Pass
County: Rowan Region: MRO Subbasin:
AD06
2010 —
—
Pass —
—
Pass —
--
Pass
—
—
Pass
PF: NA Special
2011 _-
—
Pass —
—
Pass —
—
Pass
—
—
Pass
7Q10: 1030 IWC(%) 0.598 Order:
2012 —
Duke Power-Cliffside cbr lim: 7.
4%
Ceri7dPF
2008 —
—
Pass .—
—
Pass —
—
Pass
—
—
Pass
NC0005088/002 Begin 3/1/2011-Frequency:Q
Mar Jun Sep Dec
+ NonComp:Single
2009 —.
—
Pass —
—
Pass —
—
Pass
—
—
Pass
County: Rutherford Region: ARO Subbasin: I
IRD02
2010 —
—
Pass —
—
Pass —
—
Pass
—
—
Pass
PF: NA Special
2011 —
—
Pass —
—
Pass —
—
Pass
—
—
Pass
7Q10: 297 IWC(%) 7.14 Order
2012 —
Duke Pdwer-Dan River cbr lim: 1.
3%
Ceri7dPF
2008 —
—
Pass —
—
Pass —
—
Pass
—
—
Pass
NC00034681002 Begin:1/1/2010 Frequency-.Q
Mar Jun Sep Dec
+ NonComp: Single.
2009 —
—
Pass —
—
Pass —
—
Pass
—
—
Pass
County: Rockingham Region: WSRO Subbasin:
OA03
2010 —
—
Pass —
—
Pass —
—
Pass
—
—
Pass
PR 11.8 Special
-
2011 —
—
Pass —
—
Pass —
—
Pass
—
—
Pass
7Q10: 314.0 IWC(a/o) 1.65 Order:
2012 —
Duke Power -Lincoln Turbine chr lim: 2
%
Ceri7dPF
2008 —
65.1
— —
>92
— —
>92
—
—
—
>92
NC0080781/001 Begin:3/1/2010 Frequency: WQ
Jan Apr Jul Oct
+ NonComp:Single
2009 —
—
— >92
—
— —
—
>92
H
—
—
Courty: Lincoln Region: MRO Subbasin:
CTB33
2010 >92
—
— —
—
>92 —
—
H
—
—
H
PF: 0.4 Special
2011 —
—
H —
—
H —
—
H
—
—
H
7Q10: 2.1 IWC(a/o)23 Order:
2012 —
Duke Power -Marshall 002 chr lim: 1
%
Ceri7dPF
2006 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
NC0004987/002 Begin 3/l/2611 Frequency; Q
Feb May Aug Nov
+ NonComp: Single
2009 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
Count�•r. Catawba Region: MRO Subbasin:
CTB32
2010 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
PF: 5.:3 Special
2011 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
7Q10: 60.0 IWC(%) 12.0 Order:
2012 —
Duke Power•McGuire 001 24hr PH at:
lim: 90%
Ceri24PF
20D8 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
NCO024392/001 Begin:4/1/2010 Frequency: Q
Feb May Aug Nov
+ NonComp: Single
2009 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
County: Mecklenburg Region: MRO Subbasin:
TB32
2010 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
PF: iNA Special
2011 —
Pass
— —
Pass
— —
Pass
—
—
Pass
—
7Q1O: 80 IWC(%) 90 Order
2012 —
Duke Power -McGuire 002 48hr LCS
ac lim: 64%
Ceri48Ac
2008 —
>100
— —
>100
— - —
>100
--
—
>100
—
NC0024392/002 Begin:4/l/2010 Frequency:Q
Feb May Aug Nov
+ NonComp: Single
2009 —
>100
— —
>100
— —
>100
--
—
>100
—
County: Mecklenburg Region: MRO Subbasin:
TB33
2010 —
>100
— —
>100
— —
>100
—
—
>100
—
PF: 0.3315 Special
2011 —
>100
— —
>100
— —
>100
—
—
>100
—
7QI0: 80.0 IWC(%) 0.64 Order:
2012 —
Y Pre 2009 Data Available
LEGEND:
PERM = Permit Requirement LET — A cio inistmtive Le
er -Target Frequency = Monitoring frequency: Q- Quarterly; M- Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging; D- Diswntinued monitoring requirement
Bepin = Fint month required 7Q10 = Receiving stream Ic
w flow criterion (cfs)
+—quarterly monitoring increases to monthly upon failure
or NR Months that testing
must occur - ex Jan, Apr, Jul, Oct
NonComp = Current Compliance Requirement
PF = Permitted flow (MGD) IWC%= Jnstream waste co
eentration
P/F = Pass/Fail test
AC = Acute
CHR
= Chronic
Data Notation: f - Fathead Minnow, • - Ceriodaphnia sp.; n
y - Mysid shrimp; CW -
Chrmiic value; P - Mortality
of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation: --= Data not required; NR - Not repoi
led Facility Activity Status: I - inactive, N -Newly Issued(To construct);
H - Active
but not discharging; t-More
data available for month in question; = ORC signature needed
18

Mickey, Mike
From: Basinger, Corey
Sent: Tuesday, July 03, 2012 2:01 PM
To: Mickey, Mike
Subject: FW: Permit Renewal - DRAFT DOW Corning Greensboro NCO088773
Attachments: 88773 DOW Permit Renewal 2012 DRAFT.pdf
For your review and comment.
W. Corey Basinger
Regional Supervisor
Surface Water Protection Section
Winston-Salem Regional Office
Division of Water Quality
Email: [e-mail]
Phone: [phone]
Fax [phone]
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: Corporon, Joe
Sent: Tuesday, July 03, 2012 1:39 PM
To: Basinger, Corey
Cc: Meadows, Susan; Pugh, James L.
Subject: Permit Renewal - DRAFT DOW Corning Greensboro NCO088773
Please review and comment as needed [note Fact Sheet as last page]
Respectfully,
Joe R. Corporon, L. G.
Environmental Specialist
`' .. NPDES Program
NCDENR/Division of Water Quality (DWQ)
Surface Water Protection Section
919-807-6394; FAX [phone]
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.

M K
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Chuck Wakild, P.E.
Governor Director
July 3, 2012
Ronald E. Cross, P.E., Project Engineer
Cardinal Resources LLC
1505 East Caron Street, Suite 200
Pittsburg, Pennsylvania 15203
Dee Freeman
Secretary
Subject: NPDES Permit - DRAFT Review
NCO088773 —Class 1
Dow Corning — Greensboro GW-REM
Guilford County
Dear Mr. Cross:
In response to your request to renew the subject permit for DOW Corning, the Division of Water Quality (the
Division) hereby transmits this draft permit for your review and comment. Please read it carefully to assure your
understanding of the permit limits and monitoring conditions, and to correct errors, if any.
Concurrent with this notification, the Division will solicit public comment on this draft by publishing a notice in
newspapers having circulation in the general Guilford County area, as required by the NPDES Program. Please
provide your written comments, if any, to [e-mail]] or write to my attention at DENR / DWQ /
NPDES Program no later than August 3, 2012, approximately 30 days after receiving this document. We welcome
your comments on this draft, but they are not required.
Changes to Your Previous Permit -- The Division understands that you have made no changes to your wastewater
treatment facility since last renewal except to sporadically discharge, restarting operations in May of 2009. We
have renewed your permit considering monthly discharge monitoring reports (DMRs), compliance history, and the
effluent monitoring database. Because the parameter,.s CE1—b P,.CEJ were not detected, we have relaxed their
monitoring frequencies from Monthly to Quarterly. Based on our review of discharge conditions and your
compliance history with both acute and chronic Whole Effluent Toxicity (WET) tests, you may discontinue acute
WET testing. Please note that the quarterly chronic WET test is still required [using Ceriodaphnia duhia]. Finally,
we have updated your facility description and site map, and added parameter codes to Section A. (1.) for your
convenience.
Following the mandatory 30-day public comment period, the Division will review all pertinent comments and
take appropriate action prior to issuing an NPDES permit final. If you have questions concerning this draft, please
e-mail me [e-mail]] or call my direct line [phone].
Respectfully,
Joe R. Corporon, L.G.
NPDES Program
Enclosure: NPDES Permit NC0088773 (DRAFT)
hc: NPDES Program Files [draft and Fact Sheet]
ec: WSRO/SWPS, Attn: Cory Basinger [draft and Fact Sheet]
Aquatic Toxicity Unit, Attn: Susan Meadows [draft and Fact Sheet]
TACU, Attn: James Pugh [draft and Fact Sheet]
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604N-
Phone: [phone] FAX: [phone].a-ll ►'�.�lirb;�
Internet: www.ncwaterquality.orge
An Equal Opportunity \ Affirmative Action Employer � k

Approximate Property
f ,Park Boundary
862 FOSI
AWN it
Outfall 001 S
b
7
4
J UT to South Buffalo Creek
X (flows South)
0%
7., lot
IL
Ve
Z�xIx
South Buffalo Creek N
(flows east)
d
sum
J
r
Is
s
Go*
v oil se m GG
od
US Hwy 1-40
High Point Road
r
DOW Corning Corporation
Greensboro GW-REM
Facility
Location
Receiving Stream: UT to South Buffalo Creek Stream Segment: 16-11-14-2
not to scale
State Grid/Quad: C-1 9-SE / Greensboro, NC Sub -Basin: 03-06-02
Stream Class: WS-V; NSW HUC: 03050105
Latitude: 3613' 14" N Permitted Flow: 0.001 MGD
Longitude: 790 5 P 04" W Drainage Basin: Cape Fear River
Nh
ort
NPDES Permit NCO088773
Guilford County

Permit NCO088773
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions of North Carolina General
and regulations promulgated and adopted by the North(
Commission, and the Federal Water Pollur
Dow Corning Corp
is hereby authorized to discharge\wastewater fr
Dow Corning`.)'Gr(
2914 P\ttersbn S
Guilforc
to receiving waters designated as an unnamed tribut
River Basin in accordance ith effluen�limitations,
forth in Parts I, II, III, and IV\kergof. 1
The permit shall become effective
Gre
1`43-215.1, other lawful standards
Environmental Management
I Ac6s amended,
facility located at
=REM
boro
ary (UT) to South Buffalo Creek in the Cape Fear
monitoring requirements, and other conditions set
, 2012.
This permit and the authorization to discharge shall expire at midnight on June 30, 2016.
Signed this day , 2012.
Charles Wakild, P. E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0088773
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Dow Corning Corporation
is hereby authorized to:
1. continue to operate a 0.001 MGD group
compounds including chlorinated hydro
• equalization tank
• air stripper
• granulated activated
• discharge line
• final effluent oerc`ol
located at the
in Guilford C
to
remove volatile organic
W-REM facility, 2914 Patterson Street, Greensboro,
2. discharge from said tredtnient works via Outfall 001, at a location specified on the attached map,
to an unnamed tributary to4e'South Buffalo Creek [Stream Segment 16-11-14-2], a waterbody
currently classified C-NSW within Subbasin 03-06-02 of the Cape Fear River Basin.

Permit NCO088773
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to
discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT
MONITORING
PARAMETER
LIMITATIONS
REQUIREMENTS
[Parameter Codes]
Monthly
Daily
Measurement
Sample
Sample
Average
Maximum
Frequency
Type
Location
Flow'
50050
0.001 MGD
Continuous'
Recording
Effluent
Total Suspended Solids
C0530
30.0 mg/L
45.0 mg/L
Mon{hly
Grab
Effluent
Acetone
81552
/Qaarrerly\\
Grab
Effluent
2-Butanone
78356
louarterly
�� Grab
Effluent
Chloroethane
34311
��
Quarterly
\Grab
Effluent
Chloroform
32106
\Quarterly
Grab
Effluent '
1,1 - Dichloroethane
34496
\Quarterly
Grab)
Effluent
���
1,2 - Dichloroethane
32103\�
\ Quarterly
Grab
Effluent
1,2-Dichloropropane
34541
��
�->'�-Quarterly,
Grab
Effluent
Methylene Chloride
34423
'✓
j Quarterly} J
Grab
Effluent
1,1,1-Trichloroethane
34506
\ /
)
Quarterly
Grab
Effluent
Trichlorofluoromethane
Z4988`
✓
���
` Quarterly
Grab
Effluent
Vinyl Chloride
�39175
Quarterly
Grab
Effluent
Total Xylenes
\81\551
Quarterly
Grab
Effluent
Chronic Toxicity2
7GP3B
Quarterly
Grab
Effluent
v
Footnotes:
1. Flow may be measured using a totalizing flow meter.
2. Whole Effluent Toxicity (WET) testing limited; Chronic (Ceriodaphnia) @ 90% effluent concentration in
January, April, July, and October [see Section A. (2.)].
Conditions:
1. The Permittee shall discharge no floating solids or foam.
2. All Quarterly effluent samples shall coincide with the chronic toxicity test.

Permit NC0088773
A. (2) CHRONIC TOXICITY - LINIITED (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%. The permit holder shall perform at a minimum,
quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent
Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of January, April, July and October. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then the Permittee shall perform multiple -concentration testing at a minimum, in each of the two
following months, as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival a4the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment;" collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised-February\1998) or subsequent�ersions.
All toxicity testing results required as part of this I
Monitoring Form (MR-1) for the months in which
the pass/fail results and THP3B for the Chronic V
to the following address:
162
Completed Aquatic Toxicity Test -Forms sh-,
days after the end of the\ep rting period`fo
\ \��� \.
Test data shall be complete; accurate, incluc
concentration/response data, aod•be certifies
Total residual chlorine of the effluent toxici
disinfection of the waste stream. \\
iition will,lie entered on the`Effluent Discharge
performed„using the parameter code TGP3B for
itional)y„ DWQ Form AT-3 (original) is to be sent
Sciences Section
la, North`Caxolina 21699-1621
ed with the Environmental Sciences Section no later than 30
th re epg�made.
pporting chemical/physical measurements and all
oratory supervisor and ORC or approved designate signature.
le must be measured and reported if chlorine is employed for
Should there be no discharge of flow'from the facility during a, month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT Forms
submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

DENR / DWQ / NPDES
EXPIDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit NCO088773
Facility Information
Applicant/Facility Name
Dow Corning Corporation / Greensboro Facility GW-REM
Applicant Address
2914 Patterson Street, Greensboro, NC 27407
Facility Address
same
Permitted Flow (MGD)
0.001
Type of Waste
Groundwater contaminated with chlorinated hydrocarbons
Facility Class
Physical/Chemical
County
I Guilford
Facility Status
Renewal
Regional Office
I WSRO
Stream Characteristics
Receiving Stream
UT to South
Buffalo Creek
Stream
Classification
WS-V; NSW
Stream Segment
16-11-14-2
Drainage basin
Cape Fear
Summer 7Q10 (cfs)
0.0
Subbasin
03-06-02
Winter 7Q10 (cfs)
0.0
Use Support
impaired
30Q2 (cfs)
0.0
303(d) Listed
Yes (biological impairment)
Average Flow (cfs)
0.0
State Grid
C19SE
IWC (%)
100
USGS Topo Quad
Greensboro
SUMMM — In January 2009 Dow Corning Corporation received authorization to construct and operate
a groundwater remediation (GW-REM) / wastewater treatment system to remove volatile organic
compounds including chlorinated hydrocarbons. The facility began operation in May 2009 (see Engineer's
Cert, 22May2009).
The system consists of an EQ tank and air stripper followed by a polish filter of granulated activated carbon
(GAC). Since start-up, treated effluent has averaged 0.00053 GPD with a maximum reported of 0.0012
MGD (n = 831 flow days reported). Flow via Outfall 001 discharges to a man-made treatment wetland
where it percolates slowly, eventually recharging to an unnamed tributary to South Buffalo Creek.
Renewal — DWQ updated facility description and Map; add parameter codes to Section A. (L). Based
on parameters "not detected" (database n = 11 to 33 sample events), DWQ relaxed Monthly monitoring to
Quarterly forlD_ CA�(1, 2 — Dichloromethane) and TCA (1,1,1-Trichloroethane). No other changes to
parameter limits or monitoring.
WET Testing — Since start-up the permit has required both chronic and acute WET testing under zero -
flow receiving -stream conditions. Because test results are all reported as "PASS," and because the Aquatic
Toxicology Unit believes that acute testing is unjustifiably redundant, the Division will discontinue the
acute test; renew with chronic only, 7-day P/F using Ceriodaphnia dubia at 90% concentration [see email
between Sergei Chemikov (NPDES) and Susan Meadows (ATU), 22Jan2009].
RPA - Reasonable Potential Analysis (RPA) - RPA was not conducted because all potential contaminates
of concern were reported as "not detected" above their respective Practical Quantitation Levels (PQLs).
Joe R. Corporon, L.G., NPDES Unit / 919-807-6394. 02July2012
Expedited Fact Sheet
Renewal 2012 -- NPDES Permit NCO088773
Page 1

Beverly Eaves Perdue
Governor
AGI IPA
®
NCDENR
North Carolina Department of Environment and Natural Resou
:Division of Water Quality
Charles Wakild; P.E.
Director
March 28, 2012
CERTIFIED MAIL
RETURN RECEIPT REQUESTED: 7007 1490 0004 5533 6318
Mr. David Clark
Dow Corning Corporation
2914 Patterson St.
Greensboro, NC 27407
Subject: NOTICE OF VIOLATION: NR NOV-2012-SP-0003
Effluent Toxicity Testing
NPDES Permit No. NCO088773
Greensboro Remediation Site
Guilford County
Dear Mr. Clark:
N.C.DePt. of ENR
APR 0.12 2012
Winston-Salem
Dee Freeman
Secretary
This is to inform you that the Environmental Sciences Section has not received your quarterly toxicity self -
monitoring report form for the month of January 2012. This is in violation of Title 15A of the North Carolina
Administrative Code, Chapter 2, Subchapter 213, Section .0506 (a)(1)(A) which states that "monthly monitoring
reports shall be filed no later than 30 days after the end of the reporting period for which the report was made."
Please remember that reporting of toxicity self -monitoring data is a dual requirement. Toxicity test results must be entered
on your Discharge Monitoring Report and the Toxicity Reporting Form (AT Report Form). The AT report form must be
submitted to: DWQ/ESS, 1621 Mail Service Center, Raleigh NC 27699-1621 within the required time frame.
Your NPDES permit requires you to submit an Aquatic Toxicity Self -Monitoring Form to this office during a month in which
toxicity testing is required, regardless of whether a discharge occurs from the facility. Please ensure that AT test forms
labeled "No Flow" are sent to this office during months when no discharge occurs and the facility is required to perform
toxicity testing.
Additional reporting and/or monitoring violations within a twelve (12) month period subiects the facility to the
enforcement authority of the Division.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service:1-877-621-6741
Internet: htlp:1/h2o.enr.state.nc.us1esb/
An Equal Opportunity 1 Affirmative Action Employer
One NhCarohna
Xitu ally

Attached to this Notice, you will find a summary of important toxicity monitoring and reporting requirements. Please read
this summary. If you have any questions concerning this Notice, please contact Mr. John Giorgino with the Aquatic
Toxicology Unit at [phone].
Sincerely,
4
Cindy Moore
Supervisor, Aquatic Toxicology Unit
ME
cc: arey Basinger- Winston-Salem Regional Office
Jenifer Carter- Winston-Salem Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
Nne
orthCarolina
An Equal Opportunity 1 Affirmative Action Employer
AA

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information. The items below dfi not address or include all the' toxicity testing and reporting
requirements contained in .your NPDES permit. If you should have any questions about your toxicity testing requirement, please contact Mr.
John Giorgino with the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the appropriate
parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period
(eg, January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of any
single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit, then at least two multiple
concentration toxicity tests (one per month) will be conducted over the following two months. As many analyses as can be completed will be
accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you
may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement
initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring
requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and December, then toxicity testing must
be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30, then you must provide
written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months of the calendar
year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the Environmental Sciences
Section at [phone]. and provide written documentation indicating why the test was invalidated and the date when follow-up testing will
occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the information block
located at the top of the AT form indicating the facility name, permit number, pipe number, county and the month/year of the subject report.
You should also write "No Flow" on the AT form, sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the, facility's Operator in Responsible Charge (ORC) except for facilities which have not
received a facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT form must also be
signed by. the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water. Quality, you may consider submitting your toxicity test
results certified mail, return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 NorthCarolina
Phone: [phone] VFAX: 919-743-85171 Customer Service:1-877-623-6748
\\ Internet http:llh2o.enr.state.nc.uslesbl Naturally
/ An Equal Opportunity 1 Affirmative Action Employer

Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
NorthCarolina
;VW11d"'i lly
AA
An Equal Opportunity 1 Affirmative Action Employer

Christine Freeman
Shamrock Environmental Corp.
6106 Corporate Park Dr
Browns Summit, NC 27214
PC II Cert # 992007
Monday, April 16, 2012
WPCSOCC
1618 Mail .Service Center
Raleigh, NC 27699-1618
Dear Sir or Madam:
Effective today, Monday, April 16, 2012, I am submitting my 14-day notice to the
WPCSOCC and to the Winston Salem, NC DWQ office that I am relinquishing my ORC
duties at Dow Corning Facility Remediation Site (NPDES Permit NC0088773, Shamrock
Environmental has been contracted through Cardinal Resources of Pittsburgh,
Pennsylvania to provide ORC services to Dow Corning of Greensboro, NC. Shamrock
Environmental will no longer provide any ORC services to Dow Corning through
Cardinal Resources. This notice also serves as the 14-day notice of relinquishment for
backup ORCs Michael Fankhauser (PC II cent# 992150) and Stephen Davis (PCII cert#
28215). The last day of ORC duties for Shamrock Environmental is April 30, 2012.
Sincerely,
Christine Freeman
PCII 992007
le4..F.�hael Fankhauser
PCII 992150
Steph Davis
PCII.28215

Mickey, Mike
From:. Hudson, Gary
Sent: Wednesday, April 18, 2012 10:16 AM
To: Mickey, Mike
Subject: FW: ORC
Attachments: 20120416170305802. pdf
fyi
-----Original Message -----
From: Chris Freeman [mailto:[e-mail]]
Sent: Wednesday, April 18, 2012 8:20 AM
To: Hudson, Gary
Subject: Fw: ORC
I sent this to you Monday, but it got returned as undeliverable. I used the wrong email
address
----- Original Message -----
From: Chris Freeman
Sent: Monday, April 16, 2012 05:10 PM
To: '[e-mail]' <[e-mail]>
Subject: ORC
Hi Gary. I believe I left you a voice mail this morning about relinquishing my duties as ORC
at Dow Corning. I have faxed the attached letter to Raleigh and am sending a hard copy in the
mail. Do I need to do anything else?
Thanks, Chris Freeman
Original Message -----
From: [e-mail] [mailto:[e-mail]]
Sent: Monday, April 16, 2012 05:03 PM
To: Chris Freeman
Subject:
This E-mail was sent from "Ricoh3045" (Aficio 3045).
Scan Date: 04.16.2012 17:03:05 (-0400)
Queries to: ricoh2035(@shamrockenviro.com
1

MONITORING REPORT(MR) VIOLATIONS for:
ReportDate: 11/16/11
Page: 4 of 5
un
PB�� N���� ��|0�
�Q���
REGION:
�����
:o:C�i—n-ffild7fati on
wownnn/me ouTe^L/
vmuAT/ou
UNIT OF
CALCULATED
nsponr pp/ LOCATION
pAaAMsrsn o^Ts pnsuusmov
MeAauas LIMIT
VALUE % OVER LIMIT
VIOLATION TYPE
VIOLATION ACTION
nr ao11 001 emvont
Flow, inconduit »'mm 07/01/11 Continuous
treatment plant
mou
Frequency Violation
None
KS
07'2011 001 emvom
Flow, i»conduit mmm 07w7n1 Continuous
meu
Frequency Violation
m ��mentp|om
'
07'2011 001 Effluent
Flow, i»conduit »rmm 07/12/11 Continuous
mou
Frequency Violation
monotreatment
plant
PERMIT: NCo032191 FACILITY: Hebron Colony Ministries Inc ' Hebron Colony & Grace
COUNTY: Watauga
REGION:
Winston-Salem
nomevxvv/r
Monitoring Violation
MONITORING OUTFALL/
VIOLATION
UNIT OF
_�C�TED
REPORT PPI LOCATION
PARAMETER DATE FREQUENCY
MEASURE NffT�
VALUE % OVER LIMIT
VIOLATION TYPE
VIOLATION ACTION
07-2011 001 Effluent
Temperature, Water Deg. 07/02/ x
deg c
Frequency Violation
None
Centigrade
07'2011 001 Effluent
Temperature, Water Deg. 07n6/11 oXweek
deg
Frequency Violation
None
Centigrade
07'2011 001 Effluent
Temperature, Water Deg. 07m3/11 nxweek
deg
pmquonvyviv|at|on
wvno
Centigrade
07'2011 001 Effluent
Temperature, Water Deg. 07m0/11 5x=oe:
deg
Frequency Violation
None

MONITORING REPORT(MR) VIOLATIONS for: ReportDate: 11/16/11 Page: 5 of 5
W
Q�. _ _ Violation :Cate o ^ f a o"rain Cat ,o
_.,. .
Permit. MRs Between 11 .and b,'1 - Reglor FAr€stoil Solent- : ,:: 9 N I knEtcartilg i?]otatiin Pr. ;g,. e9, �'
:_
;',.. :.
Faclli ,Na0 None
me. �Para a Caen ," ,. r•>:
^y
�i
Ma
L or M nor. � 3
PERMIT: NCO088773 FACILITY: Dow Corning Corporation - Greensboro remediation site COUNTY G—O fords REGION: Winston-Salem
and oringRViolatian
MONITORING
OUTFALL/
REPORT
PPI
LOCATION
PARAMETER
06 -2011
001
Effluent
Flow, in conduit or thru
treatment plant
06 -2011
001
Effluent
Flow, in conduit or thru
treatment plant
06 -2011
001
Effluent
Flow, in conduit or thru
treatment plant
VIOLATION
UNIT OF
DATE FREQUENCY
MEASURE
06/24/11 Continuous
mgd
06/25/11 Continuous mgd
06/26/11 Continuous mgd
CALCULATED
LIMIT VALUE % OVER LIMIT
VIOLATION TYPE VIOLATION ACTION
Frequency Violation None
Frequency Violation None
Frequency Violation None
PERMIT: NCO028614
FACILITY: NC DOT - Environmental Operations -1-77 Rest Area COUNTY: Yadkin
Yadkin County
REGION:
Winston-Salem
, oTil�ning �7iolation
MONITORING OUTFALL /
VIOLATION
UNIT 01="'^�-- CALCULATED
REPORT PPI
LOCATION PARAME�TRE
DAT FREQUENCY
MEASURE LIMNT__-1VALUE % OVER LIMIT
VIOLATION TYPE
VIOLATION ACTION
06 -2011 001
EfflueAt�—CMV Say CHR
06/30/11 Quarterly
percent
Fre uency Violation
None
Cerodaphnia
06 -2011 001
Effluent P/F STATRE May Chr
06/30/11 Quarterly
pass/fail
Frequency Violation
None
Ceriodaphnia
\)_-a:5 \l

RECEIVED
1 Aft
:N.C. Deptof ENR
l MAY 18 2009
NCDENR Winston-Salem
North Carolina Department of Environment and Natural Resour Regional Office
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
May 13, 2009
Mr. David Clark
Dow Corning Corporation
2914 Patterson Street
Greensboro, North Carolina 27407
SUBJECT: Authorization to Construct
A to C No. 088773A01
Dow Corning
Dow Corning Facility - Greensboro
Guilford County
Dear Mr. Clark:
A letter of request for an Authorization to Construct was received March 10, 2009, by the
Division of Water Quality (Division), and final plans and specifications for the subject project
have been reviewed and found to be satisfactory. Authorization is hereby granted for the
construction and operation of the 0.001 MGD Dow Corning Remediation Site treatment system,
with discharge of treated wastewater into Buffalo Creek in the Cape Fear River Basin.
This authorization results in no increase in design or permitted capacity and is awarded
for the construction of the following specific modifications:
A skid mounted dual phase extraction system consisting of. a vacuum blower, an
oil/water separator, an air stripper, and a liquid phase granular activated carbon
treatment unit with a vapor capacity of 180 CFM and a liquid capacity of 0.7-15 gpm,
in conformity with the project plans, specifications, and other supporting data
subsequently filed and approved by the Department of Environment and Natural
Resources.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of
NPDES Permit No. NCO088773 issued January 8, 2009, and shall be subject to revocation unless
the wastewater treatment facilities are constructed in accordance with the conditions and
limitations specified in Permit No. NC0088773.
The sludge generated from these treatment. facilities must be disposed of in accordance
with G.S. 143-215.1 and in a manner approved by the Division.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 NorthCarolina
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org l,�aturLlLL �/
An Equal Opportunity 1 Affirmative Action Employer f� �/

Mr. David Clark
May 13, 2009
Page 2
In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as may
be required by the Division, such as the construction of additional or replacement wastewater
treatment or disposal facilities.
The Winston-Salem Regional Office, telephone number [phone], shall be notified
at least forty-eight (48) hours in advance of operation of the installed facilities so that an on site
inspection can be made. Such notification to the regional supervisor shall be made during the
normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays.
Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted facility
has been installed in accordance with the NPDES Permit, this Authorization to Construct and the
approved plans and specifications. Mail the Certification to: Construction Grants & Loans,
DWQ/DENR, 1633 Mail Service Center, Raleigh, NC 27699-1633.
Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of the
wastewater treatment facilities. The operator must hold a certificate of the type and grade at
least equivalent to or greater than the classification assigned to the wastewater treatment
facilities by the Certification Commission.
The Permittee must also employ a certified back-up operator of the appropriate type and
grade to comply with the conditions of T15A:8G.0202. The ORC of the facility must visit each
Class I facility at least weekly and each Class II, III and IV facility at least daily, excluding
weekends and holidays, must properly manage the facility, must document daily operation and
maintenance of the facility, and must comply with all other conditions of T I 5A: 8G.0202.
A copy of the approved plans and specifications shall be maintained on file by -the
Permittee for the life of the facility.
During the construction of the proposed additions/modifications, the permittee shall
continue to properly maintain and operate the existing wastewater treatment facilities at all times,
and in such a manner, as necessary to comply with the effluent limits specified in the NPDES
Permit.
You are reminded that it is mandatory for the project to be constructed in accordance
with the North Carolina Sedimentation Pollution Control Act, and when applicable, the North
Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's
responsibilities shall be in complying with these Acts.

Mr. David Clark
May 13, 2009
Page 3
Prior to entering into any contract(s) for construction, the recipient must have obtained all
applicable permits from the State.
Failure to abide by the requirements contained in this Authorization to Construct may
subject the Permittee to an enforcement action by the Division in accordance with North
Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from
complying with any and all statutes, rules, regulations, or ordinances which may be imposed by
other government agencies (local, state, and federal) which have jurisdiction.
One (1) set of approved plans and specifications is being forwarded to you. If you have
any questions or need additional information, please contact Seth Robertson, P.E. at telephone
number [phone].
Sincerely,
�. 'd P" i
r
Coleen H. Sullins
MM: sr
cc: Ronald E. Cross, P.E., Cardinal Resources, 1505 East Carson St., Suite 200, Pittsburg,
Pennsylvania 15203
Guilford County Health Department
DWQ.;Winston-Salem Regional"Office;-.Surface Watq p otectiori '
Technical Assistance and Certification Unit
Point Source Branch, NPDES Program
Michelle McKay, E.I.
ATC

Dow Corning Corporation
A To C No. 088773AOI
Issued May 13, 2009
Engineer's Certification
I, , as a duly registered Professional Engineer in
the State of North Carolina, having been authorized to observe (periodically/weekly/full time)
the construction of the modifications and improvements to the Dow Corning Remediation Site
treatment system, located on Patterson Street in Guilford County for the Dow Corning
Corporation, hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the following construction:
A skid mounted dual phase extraction system consisting of. a vacuum blower, an
oil/water separator, an air stripper, and a liquid phase granular activated carbon
treatment unit with a vapor capacity of 180 CFM and a liquid capacity of 0.7-15 gpm,
in conformity with the project plans, specifications, and other supporting data
subsequently filed and approved by the Department of Environment and Natural
Resources.
I certify that the construction of the above referenced project was observed to be built within
substantial compliance and intent of the approved plans and specifications.
Signature
Date
Registration No.
Send to: Construction Grants & Loans
DENR/DWQ
1633 Mail Service Center
Raleigh, NC 27699-1633

1 • i RECEIVED
r
N.C. Dent. or ENR
NCDENR DEC 10 2010
North Carolina Department of Environment and Natural Resources Rzglcnal-� e e
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
December 2, 2010
Ms. Jane Waldorn
Dow Corning Corporation
2914 Patterson St
Greensboro, NC 27407
Subject: Renewal Notice
NPDES Permit NCO088773
Greensboro remediation site
Guilford County
Dear Permittee:
Your NPDES permit expires on June 30, 2011. Federal (40 CFR 122.41) and North Carolina (15A
NCAC 2H.0105 (e)) regulations state that permit renewal applications must be filed at least 180 days prior
to expiration of the current permit. If you have already mailed your renewal application, you may
disregard this notice.
Your renewal package must be sent to the Division postmarked no later than January 1, 2011.
Failure to request renewal by this date may result in a civil penalty assessment. Larger penalties may be
assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after June 30, 2011, the current permit must be renewed.
Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1;
unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact
me at the telephone number or address listed below.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you
must submit with the permit renewal application. If you have any questions, please contact me at the .
telephone number or e-mail address listed below.
Sincerely,
l
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
Winston-Salem Regional Office, Surface Water Protection
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 No
512 North Salisbury Street, Raleigh, North Carolina 27604 1� Oaro a
Phone: [phone] / FAX [phone] / [e-mail] Xatt(rallff

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A A
� A. '
HCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
24 September 2010
Ms. Kelle Beatty, Environmental Engineer
Dow Corning
2914 Patterson Street
Greensboro, North Carolina 27407
SUBJECT: Compliance Evaluation Inspection
Dow Corning
NPDES Permit No. NCS000077 &Vi F WIL
Guilford County
Dear Ms. Beatty:
Dee Freeman
Secretary
A Compliance Evaluation Inspection was performed on the Dow Corning groundwater remediation system and stormwater
facilities on September 21, 2010 by Corey Basinger of the Winston-Salem Regional Office. You were present for the
inspection. The inspection consisted of two parts: an on -site inspection of the stormwater facilities and an in -office file
review. The following are the findings from the subject inspection.
L Permit
The NPDES permit for groundwater remediation discharge (NC0088773) became effective on February 1, 2009 and
expires on June 30, 2011. The NPDES permit for stormwater discharge (NCS000077) became effective on April 27,2007
and expires on April 26, 2012.
II. Records/Reports
A review of the Stormwater Pollution Prevention Plan (SPP. Plan) revealed that -all areas of concern had been. addressed.
The SPP Plan was very comprehensive and well organized.
A review of the records associated with NCO0887733 revealed that the facility was in compliance with permit
requirements.
III. Facilitv Site Review
All outfalls noted in the SPP Plan were inspected and found to be satisfactory. The facility requested representative outfall
status for Outfall 002 in a letter dated March 29, 2007 and was approved on April 24, 2007. Since that time, the site has
been modified and the topography of the site has changed slightly. You indicated that facility staff was having a difficult
time collecting a stormwater sample at several of the outfalls due to the fact that very little stormwater was present in the
storm sewer pipes. It may be helpful to wait until later in the representative storm event to collect the sample in order to
allow the stormwater to enter the storm sewer system. If you continue to have difficulties with collecting a stormwater
sample, please contact this office and we will assist you in determining a viable solution.
The groundwater remediation system discharges across Patterson Street into an unnamed tributary to South Buffalo Creek.
Please remember to maintain access to the discharge point at all times.
IV. _Effluent & Receiving Waters
Dow Coming discharges treated groundwater and stormwater to an unnamed tributary to South Buffalo Creek in the Cape
Fear River Basin.
V. Self -Monitoring Program
All monitoring requirements required by NPDES Permit NC0088773 have been met.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughlown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An -qual Oppo,iunity 1 A.fl.rinalive Aclion employer
One
NorthCarolina
Naturullff

The qualitative monitoring required by NPDES Permit NCS000077 has been conducted. The facility has had difficulty
collecting analytical samples required by NPDES Permit NCS000077 due to insufficient stormwater in the storm sewer
collection system. Please refer to Section III above for further detail.
Overall, the facility was deemed to be in compliance with NCS000077 and NC0088773. The Division greatly appreciates
your continued efforts to maintain compliance with the subject permits and solicits any input you may have regarding this
inspection report. If you should have any questions or concerns regarding this report, please contact this Office at (336)
771-5000.
Sincerely,
Steve W. Tedder
Water Quality Supervisor
Cc: Central Files, WSRO

Form Approved
OMB No.2040.0057
s"°"�•
Approval Expires
8-31-98
United States Environmental Protection Agency,Washington, D.C., 20460
Section A: National Data System Coding
Transaction Code NPDES No. Yr/Mo/Day Inspection Type Inspector FacilityType
N 5 NCS000077 10-09-21 C S 2
Facility Evaluation Rating BI QA ..........Reserved...........
4 N N
Section B: Facility Data
Name and Location of Facility Inspected:
Entry Time:
Permit Effective
1000 hrs.
Date: April 27, 2007
Dow Corning Facility — Greensboro
Located at 2900 Randolph Avenue, Greensboro, NC
Exit Time:
Permit Expiration
1100 hrs.
Date: Aril 26, 2012
Name(s) of On -Site Representative(s): Phone No(s):
Ms. Kelle Beatty 336-547-7126
Name, Address of Responsible Official:
Plant Manager
Mr. David Clark
2914 Patterson Street
Phone No.
Contacted? N
Greensboro, NC '27407
336-547-7183
Section C: Areas Evaluated During Inspection (check only those areas evaluated)
X Permit NA Flow Measurement NA Operations/Maintenance NA Sewer Overflow
X Records/Reports X Self -Monitoring Program NA Sludge Handling/Disposal NA Pollution Prevention
X Facility Site Review NA Compliance Schedules NA Pretreatment
NA Effluent/Receivin Waters NA Laboratory X Stormwater
Section D: Summary of Findings/Comments
See attached letter for further details regarding the subject inspection.
Name(s) and Signature(s) of Inspectors:
Agency/Office/Telephone:
Date:
Talk
DWQ / WSRO / [phone]
Signature of Rev' er:
Agency/Office:
Date:
DWQ / WSRO / [phone]
jr- ,Z �e

Permit: NCS000077 Owner -Facility: Dow Corning Corporation
Inspection Date: 09/21/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■
n
n n
# Does the Plan include a General Location (USGS) map?
■
❑
n n
# Does the Plan include a "Narrative Description of Practices"?
■
❑
n n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n
n n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑
Q
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑ n
# Does the facility provide all necessary secondary containment?
■
n
n n
# Does the Plan include a BMP summary?
■
n
n ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n n
# Does the facility provide and document Employee Training?
■
❑
n Cl
# Does the Plan include a list of Responsible Party(s)?
■
n
n n
# Is the Plan reviewed and updated annually?
■
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
0
n n
Has the Stormwater Pollution Prpvention Plan been implemented?
■
n
n n
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Yes No NA NE
■nnn
Comment:
Analytical Monitoring Yes No. NA NE
Has the facility conducted its Analytical monitoring? ■ ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n Cl ■ n
Comment: Facility has recently completed a site modification project.
Once a storm event occurs the facility will be better able to determine how the site
changes have afftected the stormwater outfalls. At present, the facility staff are having a
difficult time obtaining a sample as very little water is flowing through the storm sewer
pipes.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ n ❑ ❑
# Were all outfalls observed during the inspection? ■ ❑ n In
# If the facility has representative outfall status, is it properly documented by the Division? ■ n n ❑
Page: 3

Permit: NCS000077 Owner - Facility: Dow Corning Corporation
Inspection Date: 09121/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment:
■nn❑
Page: 4

Form Approved
OMB No.2040.0057
n ,4
Approval Expires
8-31-98
United States Environmental Protection Agency,Washington, D.C. 20460
Section A: National Data System Coding
Transaction Code NPDES No. Yr/Mo/Day Inspection Type Inspector FacilityType
N 5 NCO088773 10-09-21 C S 2
Facility Evaluation Rating BI QA ..........Reserved...........
4 N N
Section B: Facility Data
Name and Location of Facility Inspected:
Entry Time:
Permit Effective
1000 hrs.
Date: Feb 1, 2009
Dow Corning Facility - Greensboro
Exit Time:
Permit Expiration
Located at 2914 Patterson Street, Greensboro, NC
1100 hrs. I
Date: June 30, 2011
Name(s) of On -Site Representative(s): Phone No(s):
Ms. Kelle Beatty 336-547-7126
Name, Address of Responsible Official:
Plant Manager
Mr. David Clark
Phone No.
Contacted? N
2914 Patterson Street
336-547-7183
Greensboro, NC 27407
Section C: Areas Evaluated During Inspection (check only those areas evaluated)
X Permit NA Flow Measurement NA Operations/Maintenance NA Sewer Overflow
X Records/Reports X Self -Monitoring Program NA Sludge Handling/Disposal NA Pollution Prevention
X Facility Site Review NA Compliance Schedules NA Pretreatment
NA Effluent/Receiving Waters NA Laboratory X Stormwater
Section D: Summary of Findings/Comments
See attached letter for further details regarding the subject inspection.
Name(s) and Signature(s) of Inspectors:
Agency/Office/Telephone:
Date:
:g v
DWQ / WSRO / [phone]
Signature of Review :
Agency/Office:
Date:
DWQ / WSRO / [phone]

Permit: NCO088773
Inspection Date: 09/21/2010
Owner - Facility: Dow Corning Facility - Greensboro
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge n n ■ ❑
Judge, and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ■ ❑ ❑ ❑
Is the facility as described in the permit? ■ n ❑ n
# Are there any special conditions for the permit? ❑ ❑ ® ❑
Is access to the plant site restricted to the general public? ■ ❑ n ❑
Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑
Comment:
Record Keeping
Yes
No NA NE
Are records kept and maintained as required by the permit?
■
❑ ❑ ❑
Is all required information readily available, complete and current?
■
❑ n ❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
0 ❑ ❑
Are analytical results consistent with data reported on DMRs?
■
❑ n n
Is the chain -of -custody complete?
®
n n n
Dates, times and location of sampling
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
Name of person performing analyses
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
❑ ❑ ❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑ ■ ❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
❑
❑ ■ ❑
Is the ORC visitation log available and current?
❑
n n ■
Is the ORC certified at grade equal to or higher than the facility classification?
❑
n n
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑ ❑ ■
Is a copy of the current NPDES permit available on site?
■
n n ❑
Page # 3

Permit: NC0088773 Owner - Facility: Dow Corning Facility - Greensboro
Inspection Date: 09/21/2010 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA NE
Facility has copy of previous year's Annual Report on file for review?
❑
❑
■ ❑
Comment:
Effluent Pipe
Yes
No
NA NE
Is right of way to the outfall properly maintained?
n
■
n n
Are the receiving water free of foam other than trace amounts and other debris?
■
n
❑ ❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
■ ❑
Comment: Access to outfall should be maintained all year round.
Flow Measurement- Effluent
Yes
No
NA NE
# Is flow meter used for reporting?
❑
❑
❑
Is flow meter calibrated annually?
n
n
n
Is the flow meter operational?
n
n
n ■
(If units are separated) Does the chart recorder match the flow meter?
n
❑
n
Comment:
Effluent Sampling
Yes
No
NA NE
Is composite sampling flow proportional?
❑
n
■ n
Is sample collected below all treatment units?
■
n
n ❑
Is proper volume collected?
■
n
n n
Is the tubing clean?
n
n
■ ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑ ❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
❑
n ❑
Comment:
Page # 4

RECEIVE®
N.C. Deot of ENR
ALTT4 1.9 XA
SEP 3 0 2009
...r...,..
Winston-Salem
NCDENR
Regional Office
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Coleen H. Sullins
Dee Freeman
Governor
Director
Secretary
September 25, 2009
CERTIFIED MAIL: 7006 2760 0001 9282 0266
RETURN RECEIPT REQUESTED
Mr. David Clark
Plant Manager
Dow Corning Corporation
2914 Patterson St.
Greensboro, NC 27407
Subject:
Whole Effluent Toxicity Reporting Requirements
Effluent Toxicity Testing
NPDES Permit No. NCO088773
Dow corning Facility- Greensboro
Guilford County
Mr. Clark:
Our office has received the Greensboro Dow Corning Facility's 7/20/09 chronic toxicity test and the
7/22/09 acute test reports for plant effluent. Upon review of these AT-1 forms, we noted that the hardness was
out of range for both tests. Our office has recorded these tests as "invalid" as submitted.
Ms. Susan Meadows of our office has contacted Ms. Barb Jones on 9/17/09 and informed her of the error.
Ms. Meadows suggested that two more tests be run before the end of September.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting
requirements. Please review this summary and direct any questions concerning the summary or this Notice to me
at 919-743-8442 or Mr. John Giorgino at 919-743-8441.
Sj*p.perely,
Cindy Moore, Supervisor
Aquatic Toxicology Unit
cc: Steve Tedder- Winston-Salem Regional Office
Jenifer: Carte"r- Winston Salem Regional Office
Susan meadows- Aquatic Toxicology Unit
Environmental Science Corporation
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 North Carohna
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/ N%turallY
An Equal Opportunity 1 Affirmative Action Employer

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information. The items below do not address or include all the toxicity testing and reporting
requirements contained in your NPDES permit. If you should have any questions about your toxicity -testing requirement, please contact Mr. Kevin
Bowden with the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement All toxicity test results must be entered (with the appropriate parameter
code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period (eg,
January test result is due by the end ofFebruary).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of any single
quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit, then at least two multiple concentration
toxicity tests (one per month) will be conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct
either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives effective July 1,
1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing morths are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring requirements (eg, if
the testing months specified in your NPDES permit are March, .tune, September, and December, then toxicity testing must be conducted during these
months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until
such time that a single test is passed. Upon passing this monthly test requirement, the permittee will revert to the quarterly months specified in the
permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30, then you must provide
written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months of the calendar year,
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the Environmental Sciences Section
at [phone] and provide written documentation indicating why the test was invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the information block located
at the top of the AT form indicating the facility name, permit number, pipe number, county and the month/year of the subject report. You should also
write "No Flow" on the AT form, sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for facilities whidi have not received a
facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT form must also be signed by the
performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality, you may consider submitting, your toxicity test results
certified mail, return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http:/ih2o.enr.state.nc.uslesb/
One
NorthCarol.ina
atimally
An Equal Opportunity 1 Affirmative Action Employer

a w a
$.
North Carolina Department of Environment and N.atura
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
September 25, 2009
CERTIFIED MAIL: 7006 2760 0001 9282 0266
RETURN RECEIPT REQUESTED
Mr. David Clark
Plant Manager
Dow Corning Corporation
2914 Patterson St.
Greensboro, NC 27407
Subject: Whole Effluent Toxicity Reporting Requirements
Effluent Toxicity Testing
NPDES Permit No. NCO088773
Dow corning Facility- Greensboro
Guilford County
Mr. Clark:
RECEIVED
N.C. DeOL of ENR
SEP 3 0 2009
Resou ces rt'g cnai Cffi e
Dee Freeman
Secretary
Our office has received the Greensboro Dow Corning Facility's 7/20/09 chronic toxicity test and the
7/22/09 acute test reports for plant effluent. Upon review of these AT-1 forms, we noted that the hardness was
out of range for both tests. Our office has recorded these tests as "invalid" as submitted.
Ms. Susan Meadows of our office has contacted Ms. Barb Jones on 9/17/09 and informed her of the error.
Ms. Meadows suggested that two more tests be run before the end of September.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting
requirements. Please review this summary and direct any questions concerning the summary or this Notice to me
at 919-743-8442 or. Mr. John Giorgino at 919-743-8441.
Si erely,
Cindy Moore, Supervisor
Aquatic Toxicology Unit
cc: cSteve Tedder- Winston-Salem Regional Office
Jenifer Carter- Winston Salem Regional Office
Susan meadows- Aquatic Toxicology Unit
Environmental Science Corporation
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
NorthCar.Ol.ina
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
�'�8dr� llif
����//// `/
An Equal Opportunity 1 Affirmative Action Employer

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information. The items below do not address or include all the toxicity testing and reporting
requirements contained in your NPDES permit. If you should have any questions about your toxicity -testing requirement, please contact Mr. Kevin
Bowden with the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the appropriate parameter
code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period (eg,
January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of any single
quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit, then at least two multiple concentration
toxicity tests (one per month) will be conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct
either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives effective July 1,
1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing monhs are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring requirements (eg, if
the testing months specified in your NPDES permit are March, .June, September, and December, then toxicity testing must be conducted during these
months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until
such time that a single test is passed. Upon passing this monthly test requirement, the permittee will revert to the quarterly months specified in the
permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January I -June 30, then you must provide
written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the Environmental Sciences Section
at [phone] and provide written documentation indicating why the test was invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the information block located
at the top of the AT form indicating the facility name, permit number, pipe number, county and the month/year of the subject report. You should also
write "No Flow" on the AT form, sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for facilities which have not received a
facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT form must also be signed by the
performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality, you may consider submitting your toxicity test results. .y;...
certified mail return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
One
NorthCarohna
Nattirally
An Equal Opportunity 1 Affirmative Action Employer

PA I
A41
NC®EN
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
June 25, 2009
Mr. David Clark
Dow Corning Corporation
2914 Patterson Street
Greensboro, North Carolina 27407
(A)"� f2EcEIVEb
N.C. DeDt of ENR
JUL 01 12009
win; on.salem
Resour es Regional Office
Dee Freeman
Secretary
SUBJECT: Dow Corning Corporation
Permit No. 088773AOI
Transmittal of Approved Plans and Specifications
Dear Mr. Clark:
Enclosed is a copy of the plans and specifications, which were approved on
May 13, 2009. The subject documents have been stamped "approved" for your records. A copy
is also being forwarded to the Winston-Salem Regional Office. The Permittee should retain
these documents for the life of the facility.
Should you have questions regarding this matter, call me at [phone].
Sincerely,
Seth Robertson, P.E., Supervisor
Design Management Unit
MM: sr
Enclosures
cc: Ronald E. Cross, P.E., Cardinal Resources, 1505 East Carson St., Suite 200, Pittsburg,
Pennsylvania 15203
W Winston-Salem-Regioni�C�f ace
Michelle McKay, E.I.
ATC File
1633 Mail Service Center, Raleigh, North Carolina 27699-1633 ATtthOne 1 1
Location: 2728 Capital Blvd. Raleigh, North Carolina 27604 1�16 CarO1111a
Phone: [phone] \ FAX: [phone] \ Customer Service:1-877-623-6748
Internet: www.ncwaterquality.org �%$��`�
An Equal Opportunity \ Affirmative Action Employer

RECEIVED
N.C. Deot. of ENR
MCM MR
JAN 0 3 2011
North Carolina Department of Environment and Natural Resources
Winston-Salem j
Division of Water Quality
Regional Office
Beverly Eaves Perdue Coleen H. Sullins
Dee Freeman
Governor Director
Secretary
December 28, 2010
PAMELA BERRY
PLANT MANAGER
DOW CORNING CORPORATION
2914 PATTERSON STREET
GREENSBORO NC 27407
Subject: Receipt of permit renewal application
NPDES Permit NCO088773
Dow Corning Corporation - Greensboro
Guilford County
Dear Ms. Berry:
The NPDES Unit received your permit renewal application on December 28, 2010. A member of the
NPDES Unit will review your application. They will contact you if additional information is required to complete
your permit renewal. You should expect to receive a draft permit approximately 30-45 days before your existing
permit expires.
If you have any additional questions concerning renewal of the subject permit, please contact Jeff Poupart at
[phone].
Sincerely,
Dina Sprinkle
Point Source Branch
cc: CENTRAL FILES
Q►ViinRtQ Sin egioMffice/Surface Water Protection
NPDES Unit
Ronald E. Cross, P.E., Project Engineer, Cardinal Resources, 1500 East Carson Street, Suite 200,
Pittsburgh, PA 15203
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748 North Carolina
Internet: ww+,v.ncwaterquality.org
An Equal Opportunity \ Affirmative Action Employer �/

RECEIVED
N:C. Dept. of ENR
L JAN 0 3 201 1�,
Winston-Salem
Regional Office
December 17, 2010
Project No. 104-0011-0950
Mrs. Dina Sprinkle
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Permit Renewal Request
NPDES Permit Number NCO088773
Dear Mrs. Sprinkle:
The Dow Corning Corporation facility located in Greensboro, North Carolina requests renewal of
the NPDES permit referenced above. Please find enclosed the following documents required for
permit renewal.
f Completed NPDES permit application form with required attachments
Authorization letter from Dow Corning, allowing Cardinal Resources to apply for the
permit renewal on their behalf
• Letter describing sludge management
If you have any questions or need more information to complete the permit renewal, please contact
Joyce O'Connor or me at 412.374.0989.
Sincerely,
CARDINAL RESOURCES LLC
Ronald E. Cross, P.E.
Project Engineer
REC/wdi
Enclosures
Clean Water *Clean Environment *Worldwide
1505 East Carson Street, Suite 200, Pittsburgh, Pennsylvania 15203
412.374.0989 - 888.374.0989 - Fax: [phone]
Web://www.cardinalres.com

1 NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
RECEIVED
Mail the complete application to: N.C. Deot. of ER
N. C. DENR / Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617 JAN 0 3 200111
Winston-Salem
NPDES Permit Number INCO088773 Regional Once
If you are completing this form in computer use the TAB key or the up — down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name Dow Corning Corporation
Facility Name Dow Corning Facility - Greensboro
Mailing Address 2914 Patterson Street
City Greensboro
State / Zip Code NC 27407
Telephone Number [phone]
Fax Number [phone]
e-mail Address
2. Location of facility producing discharge:
Check here if same as above
Street Address or State Road
City
State / Zip Code
County
Guilford
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name Cardinal Resources LLC
Mailing Address 1505 E. Carson Street _ F�
q
City Pittsburgh ��) � �a�i�w."s 'aim L
Gft 4z_
State / Zip Code PA 15203 Fn F c6, i 1
Telephone Number 412-374-0989
Fax Number 412-374-0959
4. Ownership Status:
Federal ❑ State ❑ Private ® Public ❑
Pagel of3 C-GW 05/08

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ® Other
6. Number of separate discharge points: 1 Outfall Identification number(s) 001
Water will be discharged through one outfall to a treatment wetland on site. This water will
then slowly infiltrate to groundwater with eventual discharge to an unnamed tributary of
South Buffalo Creek.
7. Frequency of discharge: Continuous ® Intermittent ❑
If intermittent:
Days per week discharge occurs: Duration:
8. Treatment System Design flow 0.001 MGD
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Unnamed tributary to South Buffalo Creek
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
No additives will be used during treatment.
11. Is this facility located on Indian country? (check one)
Yes ❑ No
12. Additional Information See attached for additional information
All applicants (including renewals):
➢ A USGS topographical map (or copy of the relevant portion) which shows all outfalls
➢ A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
➢ Engineering Alternative Analysis
➢ Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
➢ If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
➢ A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
➢ For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
Page 2 of 3 C-GW 05/08

NPDES PERMIT APPLICATION - SHORT FORM C: - GW
For discharges associated with groundwater treatment facilities.
> For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Printed name of Person Signing
Signature of Applicant
itle
Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or
certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of
the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any
recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or
imprisonment not more than 5 years, or both, for a similar offense.)
Page 3 of 3 C-GW 05108

Source: U.S.G.S. 7.5 Minute Series Quadrangle
"Greensboro, North Carolina" dated 1997
Dow Corning Corporation
Greensboro, Guilford County,
North Carolina
104-0011
Scale: 1:24000
Figure 1
Site Location Map
0 INITIAL ISSUE I I I CADD FILE 1 107-0122-0010 DATE 11/19/2007
NO DRWN DATE REVISION CHKDl DATE JAPPVDI DATE IDRAWINGNO.1 107-0122-1 1 SCALE:
C RA DINAL

Job Number: 680-62318-1
Job Description: Dow Corning Irondale
For:
Cardinal Resources
1505 E Carson Street
Suite #200
Pittsburgh, PA 15203
Attention: Barbara Jones
r '`f Approved for release.
��.+ <-,✓_, +� Sheila Hoffman
R f
�� 1 �•L �� 1(.y�.�ti"':—; `'�,�.,�..—....._...... Project Manager I
w.
10128/201011:24 AM
Sheila Hoffman
Project Manager I
[e-mail]
10/29/2010
cc: Mrs. Joyce M O'Connor, P.G.
The test results in this report meet NELAP requirements for parameters for which accreditation is required or available.
Any exceptions to the NELAP requirements are noted. Results pertain only to samples listed in this report. This report
may not be reproduced, except in full, without the written approval of the laboratory. Questions should be directed to the
person who signed this report.
Savannah Certifications and ID #s: A2LA: 0399.01; AL: 41450; ARDEQ: 88-0692; ARDOH; CA: 03217CA; CO; CT:
PH0161; DE; FL: E87052; GA: 803; Guam; HI; IL: 200022; IN; IA: 353; KS: E-10322; KY EPPC: 90084; KY UST; LA
DEQ: 30690; LA DHH: LA080008; ME: 2008022; MD: 250; MA: M-GA006; MI: 9925; MS; NFESC: 249; NV: GA00006;
NJ: GA769; NM; NY: 10842; NC DWQ: 269; NC DHHS: 13701; PA: 68-00474; PR: GA00006; RI: LA000244; SC:
98001001; TN: TN0296; TX: T104704185; USEPA: GA00006; VT: VT-87052; VA: 00302; WA; WV DEP: 094; WV
DHHR: 9950 C; WI DNR: 999819810; WY/EPAR8: 8TMS-Q
TestAmerica Laboratories, Inc.
TestAmerica Savannah 5102 LaRoche Avenue, Savannah, GA 31404
Tel [phone] Fax [phone] www.testamericainc.com
Page 1 of 10
10/29/2010

METHOD / ANALYST SUMMARY
Client: Cardinal Resources
Job Number: 680-62318-1
Method Analyst Analyst ID
40CFR136A 624
MCAWW 160.2
TestAmerica Savannah
Cowart, Judson
WJC
Robinson, Tiffany TR
Page 2 of 10
10/29/2010

SAMPLE SUMMARY
Client: Cardinal Resources
Job Number: 680-62318-1
Date/Time
Date/Time
Lab Sample ID
Client Sample ID
Client Matrix
Sampled
Received
680-62318-1
AWS EFFL
Water
10/18/2010 0912
10/19/2010 1020
680-62318-2
System EFFL
Water
10/18/2010 0914
10/19/2010 1020
680-62318-3
TSS System EFFL
Water
10/18/2010 0915
10/19/2010 1020
TestAmerica Savannah
Page 3 of 10 10/29/2010

Client: Cardinal Resources
Client Sample ID: AWS EFFL
Analytical Data
Job Number: 680-62318-1
Lab Sample ID: 680-62318-1
Client Matrix: Water
Date Sampled: 10/18/2010 0912
Date Received: 10/19/2010 1020
624 Volatile Organic Compounds (GC/MS)
Method: 624
Analysis Batch: 680-184175
Instrument ID: MSB
Preparation: N/A
Lab File ID: b005.d
Dilution: 1.0
Initial Weight/Volume: 5 mL
Date Analyzed: 10/26/2010 2028
Final Weight/Volume: 5 mL
Date Prepared:
Analyte
Result (ug/L)
Qualifier RL
1,2-Dichloroethane
<1.0
1.0
1,1,1-Trichooroethane
<1.0
1.0
Xylenes, Total
<2.0
2.0
1,2-Dichloroethene, Total
<2.0
2.0
1, 1 -Dichloroethane
<1.0
1.0
1,2-Dichloropropane
<1.0
1.0
Acetone
<25
25
Methylene Chloride
<5.0
5.0
Chloroethane
<1.0
1.0
2-Butanone (MEK)
<10
10
Trichlorofluoromethane
<1.0
1.0
Chloroform
<1.0
1.0
Vinyl chloride
<1.0
1.0
Surrogate
%Rec
Qualifier Acceptance Limits
Dibromofluoromethane
101
77 - 129
Toluene-d8 (Surr)
95
79 - 119
4-Bromofluorobenzene
99
71 - 121
TestAmerica Savannah Page 4 of 10 10/29/2010

Client: Cardinal Resources
Client Sample ID: System EFFL
Analytical Data
Job Number: 680-62318-1
Lab Sample ID: 680-62318-2
Client Matrix: Water
Date Sampled: 10/18/2010 0914
Date Received: 10119/2010 1020
624 Volatile Organic Compounds (GC/MS)
Method: 624
Analysis Batch: 680-184175
Instrument ID: MSB
Preparation: N/A
Lab File ID: b006.d
Dilution: 1.0
Initial Weight/Volume: 5 mL
Date Analyzed: 10/26/2010 2054
Final Weight/Volume: 5 mL
Date Prepared:
Analyte
Result (ug/L)
Qualifier RL
1,2-6ichloroethane
<1.0
1.0
1,1,1-Trichloroethane
<1.0
1.0
Xylenes, Total
<2.0
2.0
1,2-Dichloroethene, Total
<2.0
2.0
1,1-Dichloroethane
<1.0
1.0
1,2-Dichloropropane
<1.0
1.0
Acetone
<25
25
Methylene Chloride
<5.0
5.0
Chloroethane
<1.0
1.0
2-Butanone (MEK)
<10
10
Trichlorofluoromethane
<1.0
1.0
Chloroform
<1.0
1.0
Vinyl chloride
<1.0
1.0
Surrogate
_._f... ..n, ..e
%Rec
Qualifier Acceptance Limits
Dibromoluor. _.. _.omethan,
99. _.. .._.,.,... ,.,._.....,_..........
. ...................... _...._,.. „ ,_..77....1 -,"29...___..._.....__..., ....,....... ..... , ..
-
Toluene-d8 (Surr)
96
79 - 119
4-Bromofluorobenzene
100
71 - 121
TestAmerica Savannah Page 5 of 10 10/29/2010

Client: Cardinal Resources
General Chemistry
Client Sample ID: TSS System EFFL
Lab Sample ID: 680-62318-3
Client Matrix: Water
Analytical Data
Job Number: 680-62318-1
Date Sampled: 10/18/2010 0915
Date Received: 10/19/2010 1020
Analyte Result Qua] Units RL Dil Method
Total Suspended Solids 6.5 mg/L 5.0 _ 1.0 160.2
Analysis Batch: 680-183440 Date Analyzed: 10/19/2010 1726
TestAmerica Savannah Page 6 of 10 10/29/2010

Client: Cardinal Resources
Method Blank - Batch: 680-184175
Lab Sample ID:
MB 680-184175/8
Client Matrix:
Water
Dilution:
1.0
Date Analyzed:
10/26/2010 1818
Date Prepared:
N/A
Analyte
1,2-Dichloroethane
1,1,1-Trcchloroethane
Xylenes, Total
1,2-Dichloroethene, Total
1,1-Dichloroethane
1,2-Dichloropropane
Acetone
Methylene Chloride
Chloroethane
2-Butanone (MEK)
Trichlorofluoromethane
Chloroform
Vinyl chloride
Surrogate
Dibromofluoromethane
Toluene-d8 (Surr)
4-Bromofl uorobenzene
Quality Control Results
Job Number: 680-62318-1
Method: 624
Preparation: N/A
Analysis Batch: 680-184175 Instrument ID: MSB
Prep Batch: N/A Lab File ID: bg375.d
Units: ug/L Initial Weight/Volume: 5 mL
Final Weight/Volume: 5 mL
Result
Qua]
RL
<1.0
_
1.0
<1.0
1.0
<2.0
2.0
<2.0
2.0
<1.0
1.0
<1.0
1.0
<25
25
<5.0
5.0
<1.0
1.0
<10
10
<1.0
1.0
<1.0
1.0
<1.0
1.0
% Rec
Acceptance Limits
99
77 - 129
97
79 - 119
100
71 - 121
TestAmerica Savannah Page 7 of 10 10/29/2010

Client: Cardinal Resources
Lab Control Sample/
Lab Control Sample Duplicate Recovery Report - Batch: 680-184175
Quality Control Results
Job Number: 680-62318-1
Method: 624
Preparation: N/A
LCS Lab Sample ID:
LCS 680-184175/6
Analysis Batch:
680-184175
Instrument ID: MSB
Client Matrix:
Water
Prep Batch: N/A
Lab File ID: bg372.d
Dilution:
1.0 .
Units: ug/L
Initial Weight/Volume: 5 mL
Date Analyzed:
10/26/2010 1700
Final Weight/Volume: 5 mL
Date Prepared:
N/A
LCSD Lab Sample ID:
LCSD 680-184175/7
Analysis Batch:
680-184175
Instrument ID: MSB
Client Matrix:
Water
Prep Batch: N/A
Lab File ID: bg373.d
Dilution:
1.0
Units: ug/L
Initial Weight/Volume: 5 mL
Date Analyzed:
10/26/2010 1726
Final Weight/Volume: 5 mL
Date Prepared:
N/A
% Rec.
Analyte
LCS LCSD
Limit
RPD
RPD Limit LCS Qua[ LCSD Qua[
1,2-Dichloroethane
103 97
49 - 155
5
30
1,1,1-Trichloroethane
108 105
52-162
3
30
Xylenes, Total
102 103
78 - 119
1
30
1,2-Dichloroethene, Total
104 106
60 - 131
2
30
1,1-Dichloroethane
103 107
59 - 155
4
30
1,2-Dichloropropane
101 100
1 -210
0
30
Methylene Chloride
104 105
1 - 221
1
30
Chloroethane
96 94
14 - 230
2
50
Trichlorofluoromethane
114 111
17 - 181
2
30
Chloroform
101 104
51 - 138
3
30
Vinyl chloride
118 119
1 - 251
0
50
Surrogate
LCS % Rec
LCSD % Rec
Acceptance Limits
Dibromofluoromethane
102
102
77 - 129
Toluene-d8 (Surr)
100
97
79 - 119
4-Bromofluorobenzene
100
98
71 - 121
TestAmerica Savannah Page 8 of 10 10/29/2010

Client: Cardinal Resources
Method Blank -Batch: 680-183440
Lab Sample ID:
MB 680-183440/1
Client Matrix:
Water
Dilution:
1.0
Date Analyzed:
10/19/2010 1726
Date Prepared:
N/A
Analysis Batch: 680-183440
Prep Batch: N/A
Units: mg/L
Quality Control Results
Job Number: 680-62318-1
Method: 160.2
Preparation: N/A
Instrument ID: No Equipment Assigned
Lab File ID: N/A
Initial Weight/Volume: 200 mL
Final Weight/Volume: 200 mL
Analyte Result Qua[ RL
Total Suspended Solids <5.0 5.0
Lab Control Sample/ Method: 160.2
Lab Control Sample Duplicate Recovery Report - Batch: 680-183440 Preparation: N/A
LCS Lab Sample ID: LCS 680-183440/2 Analysis Batch: 680-183440 Instrument ID: No Equipment Assigned
Client Matrix: Water Prep Batch: N/A Lab File ID: N/A
Dilution: 1.0 Units: mg/L Initial Weight/Volume: 200 mL
Date Analyzed: 10/19/2010 1726 Final Weight/Volume: 200 mL
Date Prepared: N/A
LCSD Lab Sample ID: LCSD 680-183440/3 Analysis Batch: 680-183440 Instrument ID: No Equipment Assigned
Client Matrix: Water Prep Batch: N/A Lab File ID: N/A
Dilution: 1.0 Units: mg/L Initial Weight/Volume: 200. mL
Date Analyzed: 10/19/2010 1726 Final Weight/Volume: 200 mL
Date Prepared: N/A
% Rec.
Analyte LCS LCSD Limit RPD RPD Limit LCS Qua] LCSD Qual
Total Suspended Solids 107 104 80 - 120 2 25
TestAmerica Savannah Page 9 of 10 10/29/2010

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Ms. Pamela Berry
Plant Manager
DOW CORNING CORPORATION
2914 Patterson Street
Greensboro, North Carolina 27407
Authorization to Sign NPDES Renewal Application
Dow Corning Greensboro Facilitv
Dear Ms. Berry:
December 16, 2010
Project No. 104-0011
Cardinal Resources LLC (Cardinal Resources) has prepared a National Pollutant Discharge
Elimination System (NPDES) permit renewal application for your facility located at 2914 Patterson
Street in Greensboro, North Carolina. The purpose of the permit is to allow discharge of treated
groundwater to an unnamed tributary of South Buffalo Creek. The treated groundwater meets all
of the North Carolina standards prior to discharge. This permit was issued on February 1, 2009
and expires on June 30, 2011. The State of North Carolina requires that the renewal application
be submitted to their office 180 days prior to expiration.
Cardinal Resources is requesting authorization from you to sign the NPDES application form. The
North Carolina Division of Water Quality permits the consultant to sign the permit application as
long as the authorization is properly documented.
If you agree to allow Cardinal Resources to sign the permit application, please acknowledge this
by signing below. Please feel free to contact us with any questions on the permitting process.
Sincerely,
CARDINAL RESOURCES LLC
0.
J ce M. O'Connor
enior Project Manager
JMOlwdi
Cardinal Resources LLC is authorized to sign the NPDES Permit Application on behalf of
Dow Corning Corporation for the 2914 Patterson Street facility, Greensboro, North Carolina.
f
Authorized by: 4JU2 Date: I,Z Loh U
Diw onling Cor ora . n
Clean Water `Clean Environment *Worldwide
1505 East Carson Street, Suite 200, Pittsburgh, Pennsylvania 15203
412.374.0989 - 888.374.0989 - Fast: 412.374.0959
Web://www.cardinalres.com

Mrs. Dina Sprinkle
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Sludge Management Plan
NPDES Permit Number NC0088773
Dear Mrs. Sprinkle:
December 17, 2010
Project No. 104-0011-0950
A sludge management plan has not been prepared for solid waste generated from the dual -phase
extraction system installed at the Dow Corning Corporation facility in Greensboro, North Carolina.
This dual -phase extraction system generates wastewater that is treated and discharged under the
NPDES permit referenced above. The method of treatment for collected groundwater prior to
discharge includes air/water separation, oil/water separation, air stripping, filtration, and adsorption.
The filtration system consists of a bag filter, which that was installed as a precautionary measure,
to prevent sediment from fouling the granular -activated carbon adsorbers.
The mass of sediment collected in the bag filter is very low, requiring only two bag filter changeouts
in the past year; and the analytical report, included with the permit renewal application, confirms
that untreated, sediment -laden water taken from the air/water separator contains no detectable
concentrations of volatile organic compounds. Spent bag filters currently are combined with plant
process trash for off -site disposal.
If you have any questions related to solid waste generation and disposal from this dual -phase
extraction system, please contact Barbara Jones or me at 412.374.0989.
Sincerely,
CARDINAL RESOURCES LLC
/9-1 &,.*/
Ronald E. Cross, P.E.
Project Engineer
R EC/wd i
Clean Water *Clean Environment *Worldwide
1505 East Carson Street, Suite 200, Pittsburgh, Pennsylvania 15203
412.374.0989 - 888.374.0989 - Fax: [phone]
Web://www.cardinalres.com

Dow Corning Corporation
A To C No. 088773AOI
Issued May 13, 2009
Engineer's Certification
i 3 �_
I, lV90I`9ah , as a duly registered Professional Engineer in
the State of North Carolina, having been authorized to observe (periodically/weekly/full time)
the construction of the modifications and improvements to the Dow Corning Remediation Site
treatment system, located on Patterson Street in Guilford County for the Dow Corning
Corporation, hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the following construction:
A skid mounted dual phase extraction system consisting of: a vacuum blower, an
oil/water separator, an air stripper, and a liquid phase granular activated carbon
treatment unit with a vapor capacity of 180 CFM and a liquid capacity of 0.7-15 gpm,
in conformity with the project plans, specifications, and other supporting data
subsequently filed and approved by the Department of Environment and Natural
Resources.
I certify that the construction of the above referenced project was observed to be built within
substantial compliance and intent of the approved plans and specifications.
Signature ri' Y / t Gil Registration No. _� m 7��
Date �Irrr pd e 00 r
Send to: Construction Grants & Loans
DENR/DWQ 1
1633 Mail Service Center
Raleigh, NC 27699-1633 \
RECEIVED
N,C, Dept of ENR
JUL 0 1.2009
Winston-Salem
Regional Office

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5 Dow Corning Corporation
a Authorization to Construct
s 2914 Patterson Street Item 14 - Site Cross Section C eReD I N A L
2 Greensboro, North Carolina
I
0 INITIAL ISSUE DATE 2-10-2009 FILE 104-0010 DWG NO. 104-0011-1 REVISION 0
NO DRWN DATE REVISION CHKD DATE APPVD DATE

REFERENCE: DAVIS— MARTIN —POWELL & ASSOCIATES, INC., SITE DRAINAGE MAP,
PROPERTY OF DOW CORNING, DRAWING D-340, SEPTEMBER, 1991;
REVISED APRIL 21, 1998.
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SURFACE WATER SAMPLE LOCATION
J
OplWEq�T
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/ PROFESSIONAL M DOW CORNING CORPORATION
Ronald Eric Cross 2914 PATTERSON STREET
00"010 GREENSBORO, NORTH CAROLINA
SW—W ,.,1�' ENGINEER
NO
PE•056 94•E �P AUTHORIZATION TO CONSTRUCT
ITEM 6 - MONITORING WELL LOCATIONS AND PROPERTY BOUNDARY
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GUILFORD COUNTY NORTH CAROLINA
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OF SOUTH BUFFALO CREEK 03 jogboog Job No.: 104-0011-0300-01
CARDINAL
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DPE SYSTEM
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AUTHORIZATION TO CONSTRUCT
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Ronald Eric Cross
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C RDINAL
REVISION 0

ATvA.
NCDN
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 3, 2009
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. David Clark
Dow Corning Corporation
2914 Patterson Street
Greensboro, North Carolina 27407
Dear Mr. Clark:
Dee Freeman
Secretary
RECEIVED
N.C. Deot. or Fl"Q
MAR 0 6 2009
Winston•$al:::-;
Regio,napcc
SUBJECT: Return of ATC Application
NPDES Permit No. NCO088773
Dow Corning
Dow Corning Facility - Greensboro
Guilford County
This letter is in reference to your Authorization to Construct permit application, received
on February 10, 2009, for the construction and operation of the subject wastewater treatment
facilities. After review of the application it has been determined that all information required for
a complete ATC application has not been received. Therefore, the Division of Water Quality
must return your application as incomplete in accordance with 15A NCAC 02T .0107
Information on the requirements for a complete Authorization to Construct application
can be found on our web site at: littp://www.nccpl.net/Engineeritig/plans.html. Please read the
Plans and Specifications Submittal Guidance and complete the ATC Application.
Please be advised that construction and/or operation of wastewater collection, treatment,
and/or disposal facilities without a valid permit is a violation of North Carolina General Statute
§ 143-215.1 and may subject the owner/operator to appropriate enforcement actions in
accordance with North Carolina General Statute § 143-215.6A-6C. Civil penalties of up to
$25,000 per day per violation may be assessed for failure to secure a permit required by North
Carolina General Statute § 143-215.1.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One 1 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 NOI�h�ar011lla
Phone: [phone] \ FAX: [phone] \ Customer Service:1-877-623-6748
Internet www.ncwaterquality.org %, atlnall .
An Equal Opportunity \ Affirmative Action Employer •

Mr. David Clark
March 3, 2009
Page 2
When you have obtained the information for a complete application, you may submit a
new application package and the appropriate permit processing fee for review. If you have any
questions or comments concerning this matter, please contact Seth Robertson, P.E. at
[phone].
Sincerely,
(&
Coleen H. ullins
bsr/dr
Enclosures
cc: Ronald E. Cross, P.E., Cardinal Resources, 1505 East Carson Street, Suite 200, Pittsburgh,
Pennsylvania 15203
I�W(�?ixston-Salem Regional (Mice; Surface Water Protection Section
ATC File

Re: NCO088773 Dow Corning
Subject: Re: NCO088773 Dow Corning
From: Sergei Chernikov <[e-mail]>
Date: Wed, 05 Nov 2008 09:34:35 -0500
To: Corey Basinger <[e-mail]>
Corey,
Thank you for comments!
1) They are proposing discharge, but think that infiltration might be significant
enough during extended periods, which will result in no direct discharge.
2) I think it is attributed mostly to infiltration, but evaporation will also have
an impact.
3) I agree with you.
4) The will have a limit and should install some device to measure flow.
5) I did not inquire about it. I think that constructed wetland is a nice gesture,
it is going above and beyond our requirements.
Sergei
Corey Basinger wrote:
Sergei,
I've reviewed the application for the subject site (NC0088773 Dow Corning).
Overall, I have no problems with issuance of this permit.
However, below are several items I feel need attention:
1) In Section 2.2, the third (3rd) bullet states "...allow for slow
infiltration...". This is misleading language. Are they proposing infiltration
or direct discharge from the wetland?
2) In Section 4.0, bottom 1/2 of the page, second (2nd) bullet, _Land.
Application_ states "...During periods of low rainfall, there will be no
discharge to the stream...". Is this attributed to evaporation or infiltration
into the groundwater?
3) In Section 2.0, the end of the first (1st) paragraph states "...receiving
stream near the site is an unnamed and unclassified stream...". Again,
misleading language. While it is correct to state that the receiving stream is
unnamed, it is not 100% correct to state that it is unclassified. All streams
not specifically classified are assigned the same classification as the nearest
classified downstream water. In this case, the UT to South Buffalo Creek would
be carry the Class C, NSW classification.
4) How do they plan to measure actual discharge flow? Will they have a 1000
gal/day limit?
5) What wetland plants are going to be used? Is there a plan to provide
proper/adequate maintenance of the wetland (and wetland plants) during the course
of the permit?
Contact me with any questions or comments.
Corey
Corey Basinger
[e-mail]
NC DENR Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
[phone]
Fax [phone]
Sergei Chernikov, Ph.D.
Environmental Engineer II
NPDES-West
Phone: [phone], fax [phone]
1617 Mail Service Center
1 of 2 11/13/2008 2:22 PM

NCO088773 Dow Corning draft
Subject: NCO088773 Dow Corning draft
From: Corey Basinger <[e-mail]>
Date: Wed, 12 Nov 2008 08:42:31 -0500
To: Sergei Chernikov <[e-mail]>
Sergei,
I've reviewed the subject draft document and found the information accurate with the exception of the
stream name on the Fact Sheet in the "Stream Characteristics" box.
The receiving stream is listed as UT to Country Line Creek and it should be UT to South Buffalo
Creek. The classification is correct.
Thanks.
Corey
Corey Basinger
[e-mail]
NC DENR Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
[phone]
Fax [phone]
Corey Basinger <Corey.BasingerPNCmail.net>
WSRO
NC DENR

� _ t
DENR / DWQ / NPDES
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NCO088773
Facility Information
Applicant/Facility Name
Dow Corning Corporation/Dow Corning Facility
Applicant Address
2914 Patterson Street, Greensboro, NC 27407
Facility Address"
same
Permitted Flow (MGD)
0.001
Type of,Waste `
Groundwater
Facility 'Class : '
NR
County '`
Guilford
Facility :Status
New
Regional Office :`
WSRO
Stream ''Characteristics" -
Receiving, Stream.
UT to.,Country
Line Creek
Stream,"; .; ,; .::
Classification
•C-NSW
Drainage. Area (sq. mi.)
Drainage basin
Cape Fear "
Summer 7Q 10 (cfs)
0
Subbasiri
03-06-02
Winter 7Q'10 •(cfs)
NA
Use. Support:
impaired
30Q2-(cfs) _".
NA
303(d) Listed
Yes (biological
impairment)
Average Flow (cfs)
NA
State "Grid
IWC (%) . "
100
USGS Topo Quad
C19SE
Summary
Dow Corning Corporation applied for a groundwater remediation permit at their
Greensboro facility to remove numerous volatile organic compounds that have been
found in the groundwater.
Dual -phase extraction system will consist of air stripper with a final GAC
(granulated 'activated carbon) polish. Approximately 1,000 gallons per day will be
discharged through the outfall to the treatment wetland. The water will slowly
percolate into the wetland and eventually discharge with groundwater .into
unnamed tributary to South Buffalo Creek.
Whole Effluent Toxicity (WET) Test
WET requirement is a Quarterly Chronic and• Acute Toxicity Pass/Fail using
Ceriodaphnia at 90%.
Reasonable Potential Analysis (RPA)
RPA analysis. (please see attached) was based on the assumption that system will
operate with 95% removal efficiency. Consultant estimates that removal efficiency
will be 100% are not realistic. Maximum predicted effluent concentrations were
determined based on a coefficient of variation of 0.6 and multiplier of 13.2 (as
outlined in NC's RPA procedure based on EPA's Technical Support Document, n =
1).
Fact Sheet
Renewal -- NPDES Permit NCO088692
Pagel

Proposed Schedule of Issuance
Draft Permit to Public Notice: November 5, 2008 (est.)
Permit Scheduled to Issue: December 29, 2008 (est.)
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached
permit, please contact Sergei Chernikov at [phone] ext. 594.
REGIONAL OFFICE COMMENTS:
RC-L�l Jinll�' STXEA.� 611&14" 7b S /3dFFfiw �2E6rL /J d I
vI- To coa16 rR'( -=zer,--- -gFR6er-( cre,��Ci
Name • Date: 2 J'V 2,00
Fact Sheet
Renewal -- NPDES NCO088692
Page 2

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r
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n
or EPA
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efficienryiis
cnterta "
Acetone
39
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no
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340
17
224
550
no
Chloroform
1.4
0.07
0.92
170
no
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18
0.9
11.9
20,000
no
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5.5
0.28
3.6
0.38
yes
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Ae - i
C-04e r
of wA rF9
r NCDENR
o �
David Clark, Plant Manager
Dow Corning Corporation"
2914 Patterson Street
Greensboro, NC 27407
Dear Mr. Clark:
Michael:F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
November 5, 2008
Coleen H. Sullins, Director
Division of Water Quality
Winston-Salem
Regional Office
--
Subject: Draft NPDES Permit
Permit NCO088773
Dow Corning Facility
Remediation Site
Guilford County
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very carefully
to ensure thorough understanding of the conditions and requirements it contains.
Please submit any comments to me no later than thirty days following your receipt of the draft. Comments
should be sent to the address listed at the bottom of this page. If no adverse comments are received from
the public or from you, this permit will likely be issued in late December, with an effective date of February
1, 2009.
If you have any questions or comments concerning this draft permit, contact me at the telephone
number: 919-807-6393, or e-mail address: sergei.chernikov@ncm-,til.net.
Sincerely,
Sergei Chernikov, Ph.D.
Environmental Engineer II
NPDES-West
cc: NPDES Permit File
Aquatic Toxicology Unit_
Wine St011 Salem Regional Office_ / Surface Water Protection
Joyce M. O'Connor
Cardinal Resources LLC, 1505 E. Carson Street, Pittsburgh, PA 15203
N. C. Division of Water Quality / NPDES Unit. Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center: 1 800 623-7748

Permit NCO088773
-STATE OF NORTH CAROLINA
DEPARTMENT. OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Draft PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGrE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Dow Corning Corporation
is hereby authorized to discharge wastewater from a facility located at the
Dow Corning Facility
2914 Patterson Street
Greensboro
Guilford County
to receiving waters designated as an unnamed tributary to Unnamed Tributary to South
Buffalo Creek in the Cape Fear River Basin in accordance with effluent limitations,
monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof.
The permit shall become effective
This permit and the authorization to discharge shall expire at midnight on June 30, 2011.
Signed this day
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

v
Permit NCO088773
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Dow Corning Corporation is hereby authorized to:
Upon receiving an Authorization to Construct from the Division of Water Quality,
construct a 0.001 MGD groundwater treatment plant located at Dow Corning Facility,
2914 Patterson Street, Greensboro, Guilford County.
2. After submitting an Engineer's Certification, discharge from said treatment works at
the location specified on the attached map into unnamed tributary to the South
Buffalo Creek, a class C-NSW water in the Cape Fear River Basin.

� .; — t ! ` •. ..��' , f(. - , 'tl'IF.':�`9P.. ; ? ',y � /` .�•,�. e w f 4' . �-���-� � -�fi `.rL,'+�.
`�'l _ _- �- �. . �• ', � �� .'aunt iCar a ,� !�. �' .�
�, � �•4'��` '", } . '•� -I it i ,� .,� o .,
-r!.%:
j � `Y',..t3 �—'1` •/I � �vI i,• _�_ ter- }, '0. yam, �rN� - �J :�.�� �� `i
Ae
IN
rr,_..t R `ggo
'
III n'? f' t
f'. OUTFdLL 001 LOCATION
1� atom
---_
ZZ+ c
tiJ .•r• ''' J :�`;;': }'�,'=r.y ri �' _' +r
Latitude: 36°3' 18"
Longitude: 79°50' 59"
Receiving Stream: UT South
Buffalo Creek
Stream Class:'C-NSW
Subbasin: 030602
Dow Corning
Corporation
NC008,8773
Guilford County
Facility''
Location "4-3k1;;rj`
ky

Permit NCO088773
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized
to discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
r��3r��EFFLiTENT
°�
��bAMONITORINGREQUIREMEIVTS
Monthly
,
Daily
. e
Measurment
Sample T y pe z
,x ��
Sample
CHARACTERISTICS
Aveta a
Malnmum
Locattori � �%
z
W4,
Flow'
0.001 MGD
Continuous
Recording
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Monthly
Grab
Effluent
Acetone
Quarterly
Grab
Effluent
2-Butanone
Quarterly
Grab
Effluent
Chloroethane
Quarterly
Grab
Effluent
Chloroform
Quarterly
Grab
Effluent
1,1 - Dichloroethane
Quarterly
Grab
Effluent
1,2 - Dichloroethane
0.38 pg/L
Monthly .
Grab
Effluent
1,2-Dichloropropane
Quarterly
Grab
Effluent
Methylene Chloride
Quarterly
Grab
Effluent
1, 1, 1 -Trichloroethane
4.4 ug/L'
Monthly
Grab
Effluent
Trichlorofluoromethane
Quarterly
Grab
Effluent
Vinyl Chloride
2.4 Vg/L
Quarterly
Grab
Effluent
Total Xylenes
Quarterly
Grab
Effluent
Chronic and Acute
Quarterly
Grab
Effluent
Toxicity2
Notes:
1. Flow may be measured using a totalizing flow meter.
2. Chronic Toxicity (Ceriodaphnia) limit at 90% with testing in January, April, July and October (see
A. (2) and A. (3)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Quarterly samples for monitored parameters shall coincide with the chronic toxicity test.

Permit NCO088773
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or
significant mortality to Ceriodaphnia dubia at an effluent concentration of 90%.-
The.permit holder shall perform at a minimum, quarterly monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of January, April, July and October. Effluent sampling for
this testing shall be performed at the NPDES permitted final effluent discharge below all
treatment processes.
If the test procedure performed as the first test of any single quarter results in a
failure or ChV below the permit limit, then multiple -concentration testing shall be
performed at a minimum, in each of the two following months as described in "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February
1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric
mean of the highest concentration having no detectable impairment of reproduction or
survival and the lowest concentration that does have a detectable impairment of
reproduction or survival. The definition of "detectable impairment," collection methods,
exposure regimes, and further statistical methods are specified in the "North Carolina Phase
II Chronic Whole Effluent Toxicity Test Procedure" (Revised_February 1998) or subsequent
versions.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed,
using the parameter code TGP3B for
the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3
(original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences
Section no later than 30 days after the end of the reporting period for which the report is
made.
Test data shall be complete, accurate, include all supporting chemical/physical
measurements and all concentration/response data, and be certified by laboratory
supervisor and ORC or approved designate signature. Total residual chlorine of the effluent
toxicity sample must be measured and reported if chlorine is employed for disinfection of the
waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the
aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number,
county, and the month/year of the report with the notation of "No Flow" inthe comment
area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.

Permit NC0088773
A. (3) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (Quarterly) continued.
Should ' there be no 'discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the
aquatic. toxicity (AT) test form indicating the facility name, permit number, pipe number,
county, and the month/year of the report with the notation of "No Flow" in the comment
area of the form. The report shall be submitted to the Environmental Sciences Branch at the
address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, , then
monthly monitoring will begin immediately until such time that a single test is passed. Upon
passing, this monthly test requirement will revert to quarterly in the -months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
then monthly monitoring will begin immediately until such time that a single test is passed.
Upon passing, this monthly test requirement will revert to quarterly in the months specified
above.
Should any test data from either these monitoring requirements or tests performed by the
North Carolina Division of Water Quality indicate potential impacts to the receiving stream,
this permit may be re -opened and modified to include alternate monitoring requirements or
limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the
results of such monitoring shall be included in the calculation & reporting of the data
submitted on the DMR & all AT Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival and appropriate environmental controls, shall constitute
an invalid test and will require immediate follow-up testing to becompleted no later than the
last day of the month following the month of the initial monitoring.

Permit NCO088773
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) continued.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirements or
limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the
results of such monitoring shall be included in the calculation & reporting of the data
submitted on the DMR & all AT Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival, minimum control organism reproduction, and
appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
A. (3) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (Quarterly)
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined
in the North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining
Acute Toxicity In A Single Effluent Concentration" (Revised -July, 1992 or subsequent
versions) . The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24
hour static test. The effluent concentration at which there may be at no time signif cant
acute mortality is 90% (defined as treatment two in the procedure document). Effluent
samples for self -monitoring purposes must be obtained during representative effluent
discharge below all waste treatment. The tests will be performed during the months of
January, April, July and October.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using
the parameter code TGE6C. Additionally, DWQ Form AT-2 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences
Branch no later than 30 days after the end of the reporting period for which the report is
made.
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed tin association with the toxicity tests, as well as all dose/response
data. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection oft -he waste stream.

NC00.88773 Dow Corning
Subject: NCO088773 Dow Corning
From: Corey Basinger <[e-mail]>
Date: Wed, 05 Nov 2008 09:31:44 -0500
To: Sergei Chernikov <[e-mail]>
CC: Steve Tedder <[e-mail]>
Sergei,
I've reviewed the application for the subject site (NC0088773 Dow Corning). Overall, I have no -
problems with issuance of this permit.
However, below are several items I feel need attention:
1),In Section 2.2, the third (3rd) bullet states "...allow for slow infiltration...". This is misleading
language. Are they proposing infiltration or direct discharge from the wetland?
2) In Section 4.0, bottom 1/2 of the page, second (2nd) bullet, Land Application states "...During
periods of low rainfall, there will be no discharge to the stream...". Is this attributed to evaporation or
infiltration into the groundwater?
3) In Section 2.0, the end of the first (1 st) paragraph states "...receiving stream near the site is an
unnamed and unclassified stream...". Again, misleading language. While it is correct to state that the
receiving stream is unnamed, it is not 100% correct to state that it is unclassified. All streams not
specifically classified are assigned the same classification as the nearest classified downstream water.
In this case, the UT to South Buffalo Creek would be carry the Class C, NSW classification.
4) How do they plan to measure actual discharge flow? Will they have a 1000 gal/day limit?
5) What wetland plants are going to be used? Is there a plan to provide proper/adequate maintenance
of the wetland (and wetland plants) during the course of the permit?
Contact me with any questions or comments.
Corey
Corey Basinger.
[e-mail]
NC DENR Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
[phone]
Fax [phone]
j Corey Basinger <Corey.Basinger(c),NCmail.net>
WSRO
NC DENR
:.

a I s
y North Carolina Deparhne
f
October 27, 2008 C041-C &'I
0
To: Steve Tedder
WQ Regional Supervisor
Winston-Salem Regional Office
a
From: Sergei Chernikov, Ph.D. Regional or rme
Environmental Engineer II
NPDES-West
Re: Dow Corning Corporation
Guilford County
Permit NCO088773
The NPDES-West has received EAA (please see attached) for a new groundwater remediation
NPDES permit for the above referenced project. Please let me know if you have any questions,
objections or concerns.
cc: Permit File
N. C, Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Phone: [phone]
fax: [phone]
DENR Customer Service Center: 1 800 623-7748

Re: NCO088773 Dow Corning
Subject: Re: NCO088773 Dow Corning
From: Sergei Chernikov <[e-mail]>
Date: Wed, 05 Nov 2008 09:34:35 -0500
To: Corey Basinger <[e-mail]>
Corey,
Thank you for comments!
1) They are proposing discharge, but think that infiltration might be significant
enough during extended periods, which will result in no direct discharge.
2) I think it is attributed mostly to infiltration, but evaporation will also have
an impact.
3) I agree with you.
4) The will have a limit and should install some device to measure flow.
5) I did not inquire about it. I think that constructed wetland is a nice gesture,
it is going above and beyond our requirements.
Sergei
Corey Basinger wrote:
Sergei,
I've reviewed the application for the subject site (NC0088773 Dow Corning).
Overall, I have no problems with issuance of this permit.
However, below are several items I feel need attention:
1) In Section 2.2, the third (3rd) bullet states "...allow for slow
infiltration...". This is misleading language. Are they proposing
infiltration or direct discharge from the wetland?
2) In Section 4.0, bottom 1/2 of the page, second (2nd) bullet, _Land
Application_ states "...During periods of low rainfall, there will be no
discharge to the stream...". Is this attributed to evaporation or infiltration
into the groundwater?
3) In Section 2.0, the end of the first (1st) paragraph states "...receiving
stream near the site is an unnamed and unclassified stream...". Again,
misleading language. While it is correct to state that the receiving stream is
unnamed, it is not 100% correct to state that it is unclassified. All streams
not specifically classified are assigned the same classification as the nearest
classified downstream water. In this case, the UT to South Buffalo Creek would
be carry the Class C, NSW classification.
4) How do they plan to measure actual discharge flow? Will they have a 1000
gal/day limit?
5) What wetland plants are going to be used? Is there a plan to provide
proper/adequate maintenance of the wetland (and wetland plants) during the
course of the permit?
Contact me with any questions or comments.
Corey
Corey Basinger
[e-mail]
NC DENR Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
[phone]
Fax [phone]
Sergei Chernikov, Ph.D.
Environmental Engineer II
NPDES-West
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
1 of 2 11/5/2008 9:50 AM

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CXARD INA L
RESOURCES
National Pollutant Discharge Elimination System (NPDES)
Permit Application Package,
Dow Corning Corporation
2914 Patterson Street
Greensboro, North Carolina 27407
Prepared for eRu
North Carolina Division of Wat ECEIVED
NPDES Unit
0a 21
Prepared by.- DEM. WM'OUAM
p01W SOURCE BRANCH
Cardinal Resources LLC
1505 East Carson Street
Pittsburgh, Pennsylvania 15203
Project No. 104-0011-1000
Y
DENR QiALIT
po!,
r%I-T
i
October 2008
Clean Water *Clean Environment *Worldwide
1505-East Carson Street, Suite 200, Pittsburgh, Pennsylvania 15203
412.374.0989 - 888.374.0989 - Fax: [phone]
Web://www.cardinalres.com

Table of Contents
NPDES Permit Application Short Form C-GW
Engineering Alternatives Analysis
1.0
Introduction and Background........................................................................................1
1.1 Introduction............................................................................................................1
1.2 . _Remediation System.............................................................................................1
1.3 South Buffalo Creek..............................................................................................2
2.0
Step 1 - Determine if the Proposed Discharge Will be Allowed..................................3
2.1 Non -Municipal Applicants ......................................................................................4
2.2 Description of the Proposed Project......................................................................4
2.3 Applicant Information.............................................................................................5
2.4 EAA Preparer Information.....................................................................................5
3.0
Step 2 - Non -Municipal Flow Projections......................................................................6
4.0
Step 3 - Evaluate Technologically Feasible Alternatives............................................8
4.1 Alternative A - Connection to an Existing Wastewater Treatment System ............
9
4.2 Alternative B - Land Application............................................................................
9
4.3 Alternative C - Wastewater Reuse......................................................................10
4.4 Alternative D - Direct Discharge to Surface Waters............................................10
4.5 Alternative E - Combination of Alternatives.........................................................10
5.0
Step 4 - Evaluate Economic Feasibility of Alternatives.............................................11
6.0
Local Government Review Form.................................................................:...............14
List of Tables
Table 1 Groundwater Analytical Results - May 2008 .
Table 2 Pilot Test Recovery Well Analyses
List of Figures
Figure 1 Site Location Map
Figure 2 Remediation System and Discharge Location
Figure 3 Process Flow Diagram
Figure 4 Treatment Wetland Schematic
List of Attachments
Attachment 1 7Q10 and 30Q2 Data
Attachment 2 QED Modeling Results
Attachment 3 Denial of Request to POTW
Attachment 4 Local Government Review Form
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina i Cardinal Resources LLC

NPDES Permit Application Short Form C-GW

NPDES PERMIT APPLICATION - SHORT FORM C - GHAT
For discharges associated with groundwater treatment facilities. .
Mail the complete application to:
N. C. DENR / Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number INC001 g 77
If you are completing this form in computer use the TAB key or the up - down arrows to moue from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Dow Corning Corporation
Dow Corning Facility - Greensboro
2914 Patterson Street
Greensboro
NC 27407
[phone]
[phone]
2. Location of facility producing discharge:
Check here if same as above
Street Address or State Road
City
State / Zip Code
County Guilford
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name Cardinal Resources LLC
Mailing Address 1505 E. Carson Street
City . Pittsburgh
State / Zip Code PA 15203
Telephone Number 412-374-0989
Fax Number 412-374-0959
4. Ownership Status:
Federal ❑ State ❑ Private ® Public ❑
Page 1 of 3 C-GW 05/08

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ® Other
6. Number of separate discharge points: 1 Outfall Identification number(s) 001
Water will be discharged through one outfall to a treatment wetland on site. This water will
then slowly infiltrate to groundwater with eventual discharge to an unnamed tributary of
South Buffalo Creek.
7. Frequency of discharge: Continuous ® Intermittent ❑
If intermittent:
Days per week discharge occurs: Duration:
8. Treatment System Design flow 0.001 MGD
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Unnamed tributary to South Buffalo Creek
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
No additives will be used during treatment
11. Is this facility located on Indian country? (check one)
Yes ❑ No
12. Additional Information See attached for additional information
All applicants (including renewals):
➢ A USGS topographical map (or copy of the relevant portion) which shows all outfalls
➢ A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
➢ Engineering Alternative Analysis
➢ Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
➢ If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
➢ A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
➢ For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed. -
Page 2 of 3 C-GW 05/08

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Printed name of Person Signing Title
of Applicant
Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or
certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of
the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any
recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or
imprisonment not more than 5 years, or both, for a similar offense.)
Page 3 of 3 C-GW 05/08

Engineering Alternatives Analysis

1.0 Introduction and Backaround
1.1 Introduction
Cardinal Resources LLC (Cardinal Resources) has prepared this Engineering
Alternatives Analysis (EAA) on behalf of Dow Corning Corporation (Dow Corning) for
their facility located at 2914 Patterson Street, Greensboro, North Carolina.
Cardinal Resources proposes to install a dual phase extraction system at the site to
extract and treat soil vapors and groundwater. Treated groundwater will be piped to a
treatment wetland that will be constructed on site. A small portion of groundwater from
the treatment wetland will eventually discharge to an unnamed tributary of South Buffalo
Creek.
Further information regarding the proposed discharge is provided in the following
sections.
1.2 Remediation System
Volatile organic compounds (VOCs) have been discovered in groundwater at Dow
Corning's facility located in Greensboro, North Carolina (Figure 1). To ameliorate
impacts to groundwater, Dow Corning proposes to treat the source by installing a dual
phase extraction system at the source area. Both soil vapors and groundwater will be
extracted in the area near Building No. 3 (Figure 2). The water will be pumped through
an air stripper to volatilize the VOCs and will then be pumped through granular -
activated carbon (GAC) to remove any residual constituents. It is expected that treated
water will be below detectable limits and will meet North Carolina standards prior to
discharge from the outfall.
Approximately 1,000 gallons per day (gal/day) will be discharged through the outfall to
a treatment wetlands constructed in a low-lying area on site. The water will slowly
percolate into the treatment wetland and eventually discharge with groundwater into
the unnamed tributary to South Buffalo Creek. Based on this plan, the groundwater
discharging to the unnamed tributary will be well below all North Carolina water -quality
standards.
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 1 Cardinal Resources LLC

1.3 South Buffalo Creek
The discharge from the remediation system will eventually discharge to an unnamed
tributary of South Buffalo Creek. Because it is an unnamed tributary, the stream
classification numbers and restrictions for South Buffalo Creek will be used for
evaluating the effects of the discharge on North Carolina waters.
South Buffalo Creek is part of the Cape Fear River Subbasin 03-06-02. South Buffalo
Creek is a Class C, nutrient sensitive water (NSW). Class C surface water is protected
for secondary recreation, fishing, wildlife, fish consumption, aquatic life, and agriculture.
South Buffalo Creek flows eastward from its starting point along Big Tree Way. It flows
east, approximately parallel to Route 40. The unnamed tributary to South Buffalo Creek
enters the steam near the intersection of S. Holden Road and Route 40. South Buffalo
Creek continues to flow generally parallel to Route 40 in an east/southeast direction.
The South Buffalo Creek gaging station (United States Geological Survey [USGS]
02094770 South Buffalo Creek at US 220 station) is approximately 0.2 mile north of
Route 40 at Randelman road. South Buffalo Creek eventually joins North Buffalo Creek
in the northeast portion of the county.
South Buffalo Creek is not a zero -flow stream. USGS data collected at the gauging
station shows both the 7Q1O and 3OQ2 flows are above zero. Attachment 1 provides
details of these data.
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 2 Cardinal Resources LLC

2.0 Step 1 - Determine if the Proposed Discharge
will be Allowed
Cardinal Resources and Dow Corning have reviewed the items used to determine if the
proposed discharge will be allowed. Based on this review, there is nothing precluding
the discharge from being approved. As noted previously, the treated water will dis-
charge to an unnamed tributary of South Buffalo Creek. Based on instructions from the
North Carolina Division of Water Quality NPDES Unit (August, 2008) because the
receiving stream near the site is an unnamed and unclassified stream, information on
South Buffalo Creek has been reviewed:
Zero Flow Stream Restrictions - South Buffalo Creek is a severely degraded
stream below the Town of Greensboro. For that reason, the 1996 Basinwide
Water Quality Plan recommended no further wastewater discharges to the
stream. The 2005 Plan notes that the stream habitat is still degraded. Although
it does not specifically state that no discharges be approved, it can be assumed
that further degradation from wastewater discharges will not be permitted.
However, as the discharge from the Dow Corning site will not further degrade the
stream, it is expected that this discharge will be permitted. The 7Q10 and 30Q2
stream flows are above zero. Additionally, neither basic oxygen demand (BOD)
nor ammonia (NH3) will be added to the stream from the new discharge.
Receiving Stream Classification Restrictions - South Buffalo Creek is classified
as a Class C, NSW. Based on a review of the wastewater discharge restrictions,
nutrients are considered the main problem along this stream. These stream
classifications do not preclude approval of this discharge.
Basinwide Water Quality Plans - As noted above, South Buffalo Creek is a
severely degraded stream, and wastewater discharges that will further degrade
the stream will not be approved. As the main impacts to the stream are from
fecal coliform and NH3, discharges that will contribute additional BOD and NH3
will not be allowed. As the discharge from the site will not contribute to further
degradation of the stream, and may slightly improve water quality, there is no
reason for this discharge to conflict with the plan for South Buffalo Creek.
• Impaired Waters and Total Maximum Daily Loads (TMDLs) - South Buffalo Creek
is on the 303(d) list. However, the discharge from the remediation system will
not adversely impact the stream. It will be treated groundwater, and all
chemicals of interest will be removed prior to discharge.
resence of Endangered Species - No endangered species are present at the
proposed discharge locations.
National Pollutant Discharge Elimination System
Dow Corning Corporation
Greensboro, North Carolina
M
October 2008
Cardinal Resources LLC

2.1 Non -Municipal Applicants
After reviewing the water -quality factors for South Buffalo Creek, Cardinal Resources
believes that discharge to the treatment wetland with subsequent discharge to the
unnamed tributary of South Buffalo Creek and ultimate discharge to South Buffalo
Creek will not cause further degradation of the stream. In fact, it may be beneficial to
the creek in that the water to be discharged will be low turbidity water with no con-
taminants. According to Chapter 2 of the North Carolina Basinwide Planning Program
(October 2005 Cape Fear River Basinwide Water Quality Plan), South Buffalo Creek
below Greensboro has some of the worse water -quality problems in the state and the
worst water quality in the river basin. This appears to be mainly caused by nonpoint
source discharges as well as flow from the Greensboro wastewater treatment plant.
Fecal coliform and NH3 are the major causes of habitat degradation in this area.
The discharge proposed from the site will be treated through an air stripper and GAC
and discharged to a treatment wetland. This water will not be directly discharged to the
unnamed tributary to South Buffalo Creek, but will instead flow with groundwater into
the stream. In this way, additional solids will not be discharged to the stream. The
water will have been treated for VOCs before discharge to the treatment wetland, and
VOC levels will be below the North Carolina standards prior to discharge. Although the
flow will be low (1,000 gal/day), this treated water will be beneficial to the stream rather
than causing further degradation.
As required, the 7Q10 and 30Q2 flow statistics are attached to this application. Addi-
tionally, a copy of the Local Government Review Form completed by Greensboro has
been attached.
2.2 Description of the Proposed Project
The proposed project for this site calls for the following:
• Removal of soil vapor and impacted groundwater from four recovery wells.
Installation of a dual -phase extraction (DPE) system to remove and treat soil
vapors and impacted groundwater. Groundwater will be pumped through an air
stripper with a final GAC polish.
• Construction of a treatment wetland to further treat groundwater and allow for
slow infiltration of water to the unnamed tributary to South Buffalo Creek.
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 4 Cardinal Resources LLC

After construction is completed, treated groundwater will be discharged to the treatment
wetland from the DPE system. Estimated flow is 1,000 gal/day. This water will then
percolate through groundwater and eventually discharge to the unnamed tributary to
South Buffalo Creek.
2.3 Applicant Information
Applicant Name:
Dow Corning Corporation
Mailing Address:
2914 Patterson Street, Greensboro, NC 27407
Telephone No.:
336.547.7100
Contact Person:
David Clark, Plant Manager
Facility Name:
Dow Corning Corporation - Greensboro
Facility Address:
2914 Patterson Street, Greensboro, NC 27407
County:
Guilford
Telephone No.:
336.547.7100
Contact Person:
David Clark, Plant Manager
2.4 EAA Preparer Information
EAA Preparer's Name: Cardinal Resources LLC
Mailing Address: 1505 East Carson Street, Pittsburgh, PA 15203
Telephone No.: 412.374.0989
Contact Person: Joyce M. O'Connor
National Pollutant Discharge Elimination System
Dow Corning Corporation
Greensboro, North Carolina
5
October 2008
Cardinal Resources LLC

3.0 Step 2 - Non -Municipal Flow Projections
As stated previously, the flow from the site will be groundwater treated through an air
stripper and discharged to a treatment wetland. A copy of the process flow diagram is
attached to this application.
There will be four recovery wells installed at the site. These_ wells will pump ground-
water at 1 to 11 gallons per minute (gal/min), depending upon the location of the well.
The wells will not be pumping continually. Based on the geology at the site, and a pilot
test that was performed, it is estimated that total continuous flow from the wells will be
on the order of 1,000 gal/day. The unconsolidated material above bedrock is a thin
layer that will be dewatered near the recovery wells. After initial dewatering, ground-
water will be pumped intermittently from each well.
After groundwater is treated by the remediation system, it will be discharged to the
treatment wetland. The water will be combined with groundwater in the area and will
eventually discharge to the unnamed tributary of South Buffalo Creek. It is likely that
less than 1,000 gal/day will actually reach the unnamed tributary, and that the actual
additional flow into the stream will be minimal.
Levels of contaminants near the source area on site are being monitored at monitoring
well MW-15. The most recent data are provided in Table 1. Additionally, groundwater
data collected during the pilot test are included as Table 2. It should be noted that the
elevated levels of 2-butanone measured during the pilot test are due to the use of the
flexible tubing and tape for attaching hoses during the test. Additionally, both acetone
and 2-butanone are known laboratory contaminants. They have never been used
during the manufacturing process at this plant.
The contaminants of concern at the site are 1,1-dichloroethane (1,1-DCA), 1,1-
dichloroethene (1,1-DCE), 1,1,1-trichloroethene (1,1,1-TCA), cis- 1,2-dichloroethene
(cis-1,2-DCE), tetrachloroethene (PCE), and trichloroethene (TCE). Other chlorinated
VOCs have also been sporadically detected at the site at low levels. The remediation
system has been designed to provide 100 percent (%) removal of the constituents of
concern.
To verify the removal efficiency of the remediation system, QED Environmental
Systems' (QED) Air Stripper Model was used. Attached to this submittal are results
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 6 Cardinal Resources LLC

from the model runs. For the contaminants of concern, there is 100% removal
efficiency at the levels of constituents measured within the past year. Additionally, there
is still 100% removal efficiency when the levels of these constituents are theoretically
increased well above the recent levels. There is less than 100% removal efficiency for
both acetone and 2-butanone because of their high water solubility. Removal rates are
closer to 80% for those two constituents.
Although both acetone and 2-butanone are believed to be laboratory and field artifacts
and not actually present in the groundwater, Cardinal Resources plans to place GAC as
the final step in treatment from the remedial system (Figure 3). This will remove any
remaining amounts acetone and 2-butanone, if present, and will also provide an extra
level of. insurance that the constituents of concern will be removed prior to discharge to
the treatment wetland.
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 7 Cardinal Resources LLC

4.0 Step 3 - Evaluate Technologically Feasible
Alternatives
Cardinal Resources has evaluated the following alternatives for the discharge:
• Discharge to the Town of Greensboro Publicly Owned Treatment Works (POTW)
- The Town of Greensboro has denied our request to discharge to the POTW.
They have stated that they no longer have a program to oversee groundwater
remediation discharges to the POTW and therefore cannot approve the dis-
charge. A copy of the POTW denial is attached to this application.
• Land Application Alternatives - The proposed approach is partially a land
application alternative in that the treated groundwater will be discharged to a
treatment wetland. This is a technologically feasible alternative if an NPDES
discharge is permitted.
• Wastewater Reuse - Wastewater reuse is not a viable alternative for the manu-
facturing plant because the water is from a groundwater remediation system.
However, the water will be reused as part of the treatment wetland.
• Surface Water Discharge through the NPDES Program - This is a technologically
feasible alternative.
• Combinations of the Above - Cardinal Resources is proposing a combination of
land application, water reuse, and NPDES discharge.
Additionally, based on the EAA requirements, the following alternatives were evaluated
because it will be a groundwater remediation discharge:
Discharge to Town of Greensboro POTW - As noted above, the Town of
Greensboro has rejected our request to discharge to the POTW.
Land Application - As noted above, the proposed remediation system will be a
combination of land application to a treatment wetland as well as an NPDES
discharge. The NPDES discharge is required for this alternative because zero
discharge to the stream cannot be guaranteed throughout the entire year using
the planned remedial approach. During periods of low rainfall, there will be no
discharge to the stream. However, during periods of high rainfall, it is possible
that some of the water discharged to the treatment wetland could ultimately flow
to the stream.
Infiltration Galleries - This is not technically feasible due -to space limitations at
the site.
• In -Situ Groundwater Remediation Wells - This option has been reviewed in
detail for the site. However, this alternative is not technologically feasible in this
instance. Both soil and groundwater have been impacted at the site, and
therefore, soil vapors need to be removed to assist with remediation of soil.
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 8 Cardinal Resources LLC

Additionally, in order to prevent impacted groundwater from leaving the site, the
hydraulic gradient must be modified. Therefore, a DPE remediation system was
selected as the best approach. In -situ groundwater remediation wells are not
technologically feasible.
Close -Loop Groundwater Remediation Wells - Because the shallow nature of the
unconsolidated aquifer and the low permeability of the subsurface material, it
would not be possible to reinject groundwater into the shallow aquifer. The
possibility of reinjecting groundwater into the bedrock aquifer was also examined.
However, the possibility of contaminating the bedrock aquifer, while very low, is
still not zero. Therefore, it is not technologically feasible to establish close -loop
groundwater remediation wells.
Further details of the above alternatives are discussed in the remainder of this section.
4.1 Alternative.. - Connection to an Existing
Wastewater Treatment System
In August 2008, Cardinal Resources contacted Ms. Sharon Miller, the Pretreatment
Coordinator for the Town of Greensboro, to obtain information on discharge to the
Greensboro POTW. At that time, Ms. Miller explained that the Town of Greensboro no
longer accepts discharge water from remediation systems. She added that, in the past,
the POTW had a staff tasked with overseeing these types of discharges. However,
Ms. Miller stated that the POTW no longer has such a staff and cannot provide over-
sight on discharges from remediation systems.
As follow-up to this discussion with Ms. Miller, Cardinal Resources submitted a written
request to the City of Greensboro Water Resources Department on August 26, 2008.
This letter requested the conditions under which the POTW would accept water from the
remediation system. This letter was returned to Cardinal Resources with a note that the
request was denied because the POTW does not have the staff to oversee such a
discharge. A copy of this rejection is attached to the application.
4.2 Alternative B - Land Application,
There is not sufficient property on the site to allow for drip irrigation or spray irrigation;
therefore, this alternative is not technologically feasible. However, there is sufficient
open space to construct a treatment wetland on the site. This treatment wetlands will
be in a naturally occurring low spot on the property (Figure 2), and treated groundwater
from the remediation system will be discharged to the wetland with subsequent
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 9 Cardinal Resources LLC

discharge of a small percentage of the groundwater to the unnamed tributary of South
Buffalo Creek.
4.3 Alternative C - Wastewater Reuse
Because the wastewater is from a remediation system, it cannot be used by the plant
for the manufacturing process. However, as noted under Alternative B, Land Applica-
tion, the discharge water will be reused as part of the treatment wetlands. The water
from the remediation system will be combined with storm water runoff to support the
treatment wetlands.
4.4 Alternative D - Direct Discharge to Surface Waters
The 7Q10 and 30Q2 stream flows are above zero for South Buffalo Creek immediately
downstream of the site (Attachment 1). Additionally, the groundwater eventually
discharged to the unnamed tributary to South Buffalo Creek through the treatment
wetland will not be oxygen -consuming waste. Therefore, direct discharge is not
precluded for the site.
Neither BOD nor NH3 will be elevated for this discharge. The incoming groundwater will
not have elevated levels, nor will the discharge from the remediation system. Addition-
ally, the water will be further treated through discharge to the treatment wetland.
The diagram of the treatment system and a schematic of the outfall location are
attached to this submittal as Figures 3 and 4.
4.5 Alternative E - Combination of Alternatives
Cardinal Resources proposes to use a combination of wastewater reuse, land
application, and direct discharge to surface waters. In this way, the wastewater will
have a beneficial reuse, and only a minimum amount of water will actually be
discharged to the unnamed tributary of South Buffalo Creek.
National Pollutant Discharge Elimination System
Dow Corning Corporation
Greensboro, North Carolina
in
October 2008
Cardinal Resources LLC

5.0 Step 4 - Evaluate Economic Feasibility of
Alternatives
As discussed previously, Cardinal Resources is proposing a combination of alternatives,
including reuse of wastewater by discharge of the treated groundwater to a treatment
wetland with subsequent discharged to the unnamed tributary of South Buffalo Creek.
Direct discharge of treated groundwater to the unnamed tributary of South Buffalo
Creek without the intermediate treatment wetland is also a viable alternative. The other
alternatives, including connection to an existing wastewater treatment system and drip
or spray irrigation, are not technologically feasible. Additionally, reuse of wastewater
and land application are only viable alternatives when combined with the surface water
discharge. They would not be technologically feasible as standalone options.
The following estimated costs show a comparison between direct discharge without the
intermediate treatment wetland and the combination of three alternatives (wastewater
reuse, land application, and direct discharge to surface water).
Capital Costs
Land Acquisition Costs
Direct Discharge to Stream
Discharge to Stream
without Treatment Wetland
with Treatment Wetland
Land Acquisition Costs
Not Applicable
Not Applicable
Installation:
- Equipment costs
$100,000
$195,000
- Labor costs
$ 30,000
$ 65,000
- Expense costs
$ 20,000
$ 30,000
Subtotal
$150,000
$290,000
Design costs
$ 25,000
$ 55,000
Total
$175,000
$345,000
Recurring Costs
$63,000
$72,000
Operation and maintenance
($3,500/mo for 18 mo)
($250/mo additional
for 36 mo)
Laboratory costs, operation
$18,000
$18,000
and support staff costs
($1,000/mo for 18 mo)
Residual disposal costs
$10,000
$10,000
Connection fees and users
NA
NA
fee
Utility costs
$ 9,000
($500/mo for 18 mo)
$ 9,000
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 11 Cardinal Resources LLC

The estimated costs for both alternatives were obtained through a combination of
subcontractor quotes and historic costs from other sites. The following provides further
details:
• Equipment Costs - Quotes were obtained for the DPE system (Chemviron
Midwest), for construction of the treatment wetland (Tiger Technologies), and for
purchase of the plants to be placed in the wetland (Brady Landscaping).
• Labor Costs - Labor costs were estimated based upon similar projects performed
including design and installation of the remedial option.
• Expenses - Expenses include travel costs, Vehicle costs, and other expenses to
be incurred during installation. These items were estimated based upon work
performed on similar sites.
Lost Opportunity
There are no lost opportunity costs associated with this site.
Present Value Calculations
The present value (PV) costs are calculated as follows:
where:
PV = C + C (1 + r)n -1)
o r(1 + r)n
Co = costs incurred in the present year
Ct = costs incurred in time t
t = time period after present year
n = ending year of the life of the facility
r = current U.S. EPA discount rate = 4.875% (provided by Jennifer Haynie,
North Carolina Construction Grants and Loans, October 2008)
For a direct discharge to the unnamed tributary without the intermediate treatment
wetland, the PV costs are calculated:
PV = 175,000 + [(100,000) x ( (1 + 0.04875)1.5 -1)
(0.04875 (1 + 0.04875)1.5
= 175,000 + (100,000) x l7 0.0
= 175,000 + 140,000
PV = $315,000
National Pollutant Discharge Elimination System
Dow Corning Corporation October 2008
Greensboro, North Carolina 12 Cardinal Resources LLC

For a direct discharge to the unnamed tributary, without the intermediate treatment
wetland, the PV costs are calculated:
PV = 345,000 + [109,000 x 1.4]
= 345,000 + 152,600
= $497,600
National Pollutant Discharge Elimination System
Dow Corning Corporation
Greensboro, North Carolina
FBI
October 2008
Cardinal Resources LLC

6.0 Local Government Review Form
The Guilford County and Town of Greensboro governments were contacted regarding
zoning and subdivision ordinances. Copies of their review forms are attached to this
submittal (Attachment 4).
National Pollutant Discharge Elimination System
Dow Corning Corporation
Greensboro, North Carolina
14
October 2008
Cardinal Resources LLC

Tables

Table 1
Groundwater Analytical Results
May 2008
Detected Volatile Organic Compounds (ug/L)
Dow Corning Corporation
Greensboro Facility
Constituents
MAC
MW-4
MW-6
MW-7
MW-7a
MW-13
MW-15
MW-17
MW-17
DUP
MW-18
MW-19
MW-20
MW-21
Acetone
700
39 J,B
22 J,B
1.3 J,B
4.0 J
4.8 J
2.2 J,B
3.9 J
4.4 J
ND
ND
10 J,B
1.6 J,B
2-Butanone
4,200
ND
ND
ND
ND
7.6 J
ND
ND
ND
0.64 J
ND
ND
ND
Carbon Disulfide
700
ND
ND
0.31 J
ND
ND
ND
ND
ND
ND
ND
ND
ND
Chloroethane
4800.
ND
340
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Chloroform
70
ND
ND
ND
ND
ND
0.31 J
1.4 J
1.3 J
ND
ND
ND
ND
1,1-Dichloroethane
70
710
470 °
ND
10
4.0
4.4
1.6 J
1.5 J
1.2
1.1
18
ND
1,2-Dichloroethane
0.38.
5.5J
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1,1-Dichloroethene
7
660.
110
1.9
67
46
0.81 J
10
8.9.
2.7
1.3
170
ND
cis-1,2-Dichloroethene
70
ND
ND
ND
ND
6.5
25
22
20
2.4
1.2
17
0.24 J
trans-1,2-Dichloroethene
100
ND
ND
ND
ND
ND
0.20 J
ND
ND
ND
ND
1.4 J
ND
1,2-Dichloropropane
0.51
ND
ND
ND
ND
2.1. J
ND
4.2
-3.9
ND
ND
1.3 J
ND
Methylene Chloride
4.6
12 J,B
6.4 J,B
ND
1.7 J,B
1.7 J,B
ND
2.5 J,B
2.6 J,B
ND
ND
2.7 J,B
ND
Tetrachloroethene
0.7.
ND
ND
ND
ND
0.90 J .
3'
7.2.
6.5
0.97 J
1.1
170.
ND
1,1,1-Trichloroethane
200
34
74
ND
ND
7.1
ND
1.2 J
1.0 J
ND
1.2
19
ND
Trichloroethene
2.8
ND
ND
ND
ND
12
41
1.10
1`00
0.98 J
1.1
43
ND
Trichlorofluoromethane
2,100
42
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Vinyl Chloride
0.015
ND
16
1 ND
ND
-NLL
ND
ND
ND
ND
ND
ND
Xylenes (total)
530.
ND
10J,B
ND
2.1 J,B2.1-J,B
ND
ND
ND
0.84 J,B
0.84 J,B
N+0.83
J,B
Notes:
MAC - Maximum Allowable Concentration
J = Estimated concentration less than the reporting limit.
B = Detected in method blank.
ND = Analyte not detected at the reporting limit.
Red = Reported concentration exceeds MAC.

Table 2
Pilot Test Recovery Well Groundwater Analyses
Detected VOCs
Results in Micrograms per Liter (ug/L)
Dual -Phase Extraction Pilot Study
Dow Corning Corporation
Greensboro, North Carolina
06/11/08
06/26/08
06/27/08
Acetone
ND
F06/25/08
J, B
17 J, B
14 J, B
2-Butanone
1,900..
71
14 J
6.1 J
1,1-Dichloroethane
20J
19
15
11
1,1-Dichloroethene
ND
6.1
4.6
3.4
cis-1,2-Dichloroethene
19 J
15
12
9.1
Methylene chloride
111
ND
ND
ND
Tetrachoroethene
140
110
91
68
Toluene
61
5.7
5.1
4.2
1,1,1-Trichloroethane
ND
4.6
3.7
2.1
Trichloroethene
25 J
18
10
Total VOCs*
276
1784
E14
108
Notes:
J - Estimated concentration below reporting limit
B - Constituent detected in blank
ND = Not detected
Blue font = Detected constituent
*Excludes acetone and 2-butanone, which are potentially laboratory artifacts or airborne contaminants.
C:Projects/104-0011/DPE/Table 5 - Pilot Test VOCs 1 of 1 10/17/2008

Figures

Source: U.S.G.S. 7.5 Minute Series Quadrangle
"Greensboro, North Carolina" dated 1997
Dow Corning Corporation
Greensboro, Guilford County,
North Carolina
104-0011
Scale: 1:24000
Figure 1
Site Location Map CARDINAL
0 INITIAL ISSUE CADD FILE 107-0122-0010 DATE 11/19/2007
NO DRWN DATE REVISION CHO DATE APPVD DATE DRAWING N,
. 107-0122-1 SCALE:

WETLAND PLANTS
LOW PERMEABILITY SOIL
FIGURE 4
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01/24/2008 IFILE1 104-0011 DWGNO.1104-0011-Cl SCALE I NTS
CARDINAL
REVISION

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Attachment 1
7Q10 and 30Q2 Data

Attachment 1
7Q10 and 30Q2 Information
Dr. Sergei Chernikov, of the National Pollutant Discharge Elimination System (NPDES)
Unit, indicated that if no stream data were available regarding the unnamed tributary to
South Buffalo Creek, then stream data on South Buffalo Creek should be used.
Cardinal Resources LLC (Cardinal Resources) made inquiries of the United States
Geologic Survey (USGS) regarding the low -flow characteristics of both the unnamed
tributary and South Buffalo Creek. Mr. Curtis Weaver of the USGS provided as much
up-to-date information as is available regarding flow characteristics of this portion of
South Buffalo Creek. Additionally, 7Q10 and 30Q2 data were obtained from the Low -
Flow Characteristics and Discharge Profiles for Selected Streams in the Cape Fear
Basin, North Carolina, through 1998 (Weaver and Pope, 2001).
There are four USGS gauging stations in the area of the unnamed tributary. One sta-
tion is approximately 2,500 feet upstream of the confluence of the unnamed tributary
and South Buffalo Creek. The three remaining stations are located further downstream.
Of the three downstream locations, site 02095000 is the only one considered to be a
continuous record gauging station. Sites 02094772 and 02094980 are partial record
measuring sites. Site 02094772 is the closest downstream site to the unnamed tribu-
tary; the site had a 7Q10 of 0.5 cubic feet per second (cfs) and a 30Q2 of 1.5 cfs. Site
02094980 is the next downstream site and had a 7Q10 of 0.8 cfs and a 30Q2 of 2.6 cfs.
The continuous gauging station (02095000) is the farthest downstream, and it had a
7Q10 of 1.7 cfs and a 30Q2 of 5.3 cfs (Weaver and Pope, 2001). Sites further down-
stream were not included due to lack of information or because they would include flow
from the wastewater treatment plant.
According to the same report, the 7Q10 low -flow yield for this reach of South Buffalo
Creek is 0.03 cubic feet of flow per square mile of drainage area (cfsm). However, it
was noted by C. Weaver (2008) that the data for the report is based on a period of
record ending in 1998. Since the report was published, the area has experienced
overall drought conditions and the low -flow yield has dropped. Due to a lack of his-
torical data at the upstream station 02094659, a formal low -flow analysis could not -be
completed. A preliminary low -flow analysis for this station indicates a 7Q10 yield of
0.014 cfsm or 0.103 cfs (Weaver, 2008). Current data provided by the USGS indicated
a low -flow yield of 0.017 cfsm for this reach (Weaver, 2008). This figure is the average
yield of the two closest sites. When this yield is applied to the drainage area of site
02094659 (7.3 square miles), the 7Q10 for this reach of South Buffalo Creek is 0.12 cfs.
-9-

Based on the available information, the 7Q10 and 30Q2 for this area of South Buffalo
Creek is greater than zero even under drought conditions.
References:
Weaver, J.C. and B.F. Pope, 2001, Low -Flow Characteristics and Discharge Profiles for
Selected Streams in the Cape Fear Basin, North Carolina, through 1998, Division
of Water Quality of the North Carolina Department of Environmental and Natural
Resources, Raleigh, North Carolina, 146 pp.
Weaver, C., 2008, Email regarding South Buffalo Creek.
-2=

From: John C Weaver [e-mail]]
Sent: Friday, September 26, 2008 4:24 PM
To: Mark Cokain; Joyce O'Connor
Cc: Jeanne C Robbins; Ramona J Traynor; [e-mail]; John C Weaver
Subject: Low -flow characteristics for South Buffalo Creek at Greensboro... RE: South
Buffalo Creek
Mr. Cokain and Ms. O'Connor:
In response to your inquiry about the low -flow characteristics (7Q10) for South Buffalo Creek at South
Holden Road in Greensboro in Guilford County, the following information is provided:
A check of the low -flow files here at the USGS North Carolina Water Science Center does not indicate a
previous determination of low -flow characteristics for your point of interest. Nor are there any known
USGS records of discharge for your specific point of interest on South Buffalo Creek. In the absence of
data sufficient for a low -flow analysis, a determination of low -flow characteristics is based on assessment
of low -flow yields (expressed as flow per square mile drainage area, or cfsm) at nearby locations where
such statistics have previously been determined.
Several pieces of information to consider...
(1) The most recent low -flow information published for streams in Greensboro is in a basinwide low -flow
report completed in 2001. It is USGS Water -Resources Investigations Report 01-4094, "Low -flow
characteristics and discharge profiles for selected streams in the Cape Fear River Basin, North Carolina,
through 1998 " (Weaver and Pope, 2001). An online version of the report is available through
http://nc.water.usgs.gov/reports/wriO14094/. The report provides the low -flow characteristics (based on
data through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear
basin. The report also provides low -flow discharge profiles (7QI0, 30Q2, winter 7Q10, and 7Q2) for the
Cape Fear River and selected tributaries within the basin.
(2) Low -flow discharge profiles (figure 9B, page 49) for South Buffalo Creek and a corresponding
discussion (pages 27-28) about these profiles are presented in the report.
(3) In Table 8 of this report, there are 2 downstream partial -record sites on South Buffalo Creek at South
Elm Street ( station id 02094772, drainage area 15.8 sgmi) and Willow Road (station id 02094980, drainage
area 29.9 sgmi) for which 7Q10 discharge estimates are provided and could be considered useful for
assessing the low -flow characteristics. Expressing these estimates as 7QI0 low -flow yields (flow per
square mile of drainage area, or cfsm) provides some indication of the yield range that could potentially be
applicable to your location. The 7Q10 low -flow yield range is from about 0.027 to 0.032 cfsm (average
about 0.029 cfsm).
(4) As both of you have noted, there are active continuous -record gaging stations currently in operation on
South Buffalo Creek, two of which are located upstream and downstream of your point of interest. The
upstream gaging station (id 02094659, drainage area 7.33 sgmi) is the closest, located 300 feet upstream
from Merritt Road (or about 2,500 feet upstream from your point of interest). The downstream gaging
station (id 02094770, drainage area 15.4 sgmi) is located at U.S. Highway 220 (also known as Randleman
Road at this location). The period of record (POR) at these sites began after the ending year of record
(1998) used Cape Fear low -flow report. Available records of discharge are not sufficient for completing a
formal low -flow analysis. However, a preliminary low -flow analysis completed for each gaging station
indicates the 7QI0 yields are 0.014 and 0.019 cfsm, respectively, which are well below the range of 7Q10
low -flow yields cited in the above report.
(5) No drainage area is listed in our files for your point of interest. Once you determine a drainage area for
South Buffalo Creek at South Holden Road, you apply it to the low -flow yield value to obtain a 7Q10

estimate in units of cfs.
(6) In making use of this estimate, please consider the following: One cause of uncertainty in low -flow
estimates is the effect of urbanization on low -flow characteristics. The USGS has not conducted any
formal studies in North Carolina that document the effects of urbanization / developed basins on low flows.
However speculation among the hydrologic community is that low -flow characteristics decrease as a result
of development. Low flow (or base flow) is sustained by discharge from the surficial aquifers into streams
during extended dry periods, thus the magnitude of low flows are dependent on the storage of water in the
surficial aquifer. And because the presence of impervious areas in a developed basin reduce the
opportunity of infiltration into the surficial aquifers, then it's possible low -flow characteristics may also
decrease.
(7) As you consider the above information, please be aware of the following note. The above data in the
Cape Fear low -flow report are based on periods of record ending in the 1998 water year, in advance of the
drought conditions that have occurred since publication of the report. In some North Carolina basins, the
low -flow conditions observed during the 1998-2002 and current (2007-08) droughts have resulted in lower
low -flow statistics. No formal statewide investigation has been completed to document the changes in low -
flow statistics since the drought. However, where updated analyses have been completed for selected
stations, the changes in pre -drought versus updated 7Q10 discharges have shown varying percentage
changes of decline.
Putting together the above pieces of information...
As published in the Cape Fear low -flow report, the 7Q101ow-flow yield for this reach of South Buffalo
Creek is about 0.03 cfsm. The 7Q10 low -flow yields for the two nearby active gaging station based on
short periods of record are less than 0.02 cfsm.
It is my judgment that perhaps the most appropriate low -flow yield to currently use for your point of
interest on South Buffalo Creek is the average of the yields at the two nearby gaging stations (0.017 cfsm)
with the understanding that the short POR record reflects overall drought conditions. As additional data is
collected at these sites, it is possible the 7Q10 statistic at these gaging stations may increase.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Telephone: [phone] // Fax: [phone]
E-mail address -- [e-mail]
Internet address -- http://ne.water.usgs.gov/

Low -Flow Characteristics and Discharge
Profiles for Selected Streams in the
Cape Fear River Basin, North Carolina,
through 1998
By J. Curtis Weaver and Benjamin F. Pope
U.S. GEOLOGICAL SURVEY
Water -Resources Investigations Report 01-4094
Prepared in cooperation with the
Division of Water Quality of the
North Carolina Department of Environment
and Natural Resources
Raleigh, North Carolina
2001

Table 6. Summary of continuous -record gaging stations and partial -record measuring sites in the Cape Fear River Basin in North Carolina where records of gage
height and streamflow were collected —Continued
[miz, square mile; SR, secondary road; N/A, not applicable; SEO, sewage effluent outfall; Ind, drainage area is undetermined and(or) may be indeterminate. Gray shading indicates sites for which low -flow
characteristics have been developed. Period of record for continuous -record sites (site type 1) is shown in months and years; period of record for partial -record sites (site type 2) is shown in water years in
which discharge measurements were made]
Number of
a
measure-
d USGS
USGS
Drainage
Hydrologic
CO
ments for
=
x downstream
Station name
Latitude
Longitude
County
topographic
area
Tributary
unit
w
Period of record
partial -record
order number
quadrangle
2
(mi)
to
code
;
sites
G
.d
y
Flow
Zero
flow
32, .0209391880
Horsepen Creek at SR 2136 near Guilford
36°07'02"
79°53`31"
Guilford
Suinmerficld
7.52
Reedy Fork
03030002
2
1974-75, 1986
13
0
College
33 02093919
Horsepen Creek near Guilford College
36°0720"
79°53'02"
Guilford
Guilford
9.1'
Reedy Fork
03030002
2
1954-55, 1966, 1970
6
0
34 '02093959
Horsepen Creek tributary,near Guilford
36°07'08"
. 79°52'10"
Guilford
Greensboro
104
Horsepen
03030002
2
1954-55, 1986
16
0,
College
Creek
35 02093992
Horsepen Creek at U.S. Hwy 220 near
36°08'12"
79°5140"
Guilford
Lake Brandt
15.9
Reedy Fork
03030002
2
1960, 1962, 1974-75,
14
0
Greensboro
1986
36 02094000
Horsepen Creek at Battle Ground
3600834" .
79°51 40"
Guilford
Lake Brandt
16.4
Reedy Fork
03030002 •
la
Oct 1925 -Sept 1931,
N/A
N/A
Apr 1934 = Sept 1959
;
37 02094232
Squirrel Creek near Greensboro
360I1 42"
79045'16"
Guilford
Lake Brandt
5.42
Reedy Fork
03030002
2
1962
1
0
38 02094377
Reedy Fork,near Monticello
36°10'55"'
79°4027"
Guilford
Browns
'119
Haw River
03030002
2
1969-71,1973
8
0
Summit
39 02094379
Smith Branch near Monticello
360I120"
79°4033"
Guilford
Browns
2.51
Reedy Fork
03030002
2
1962, 1966
3
0
Summit
40 02094500
Reedy Fork near Gibsonville.
16°1031"
79°37'01"
Guilford
Ossipee
"131
Haw River
03030002
1
Sept1928 - Sept 1998
N/A
N/A
41 02094659
South Buffalo Creek near Pomona
36°02'59"
79°5122"
Guilford
Greensboro
7.30
Buffalo
03030002
2
1954
3
0
Creek
42 '02094172
South Buffalo Creek at South Elm Street
36°02'02!'
79°4730" .
Guilford
Greensboro
15.8
Buffalo
03030002
2
1969-70, 1973, '
6
0
-at Greensboro
Creek
`
43 0209478755
South Buffalo Creek tributary at SR 3303
36°00'58"
79°4722"
Guilford
Greensboro
2.5'
South
03030002
2
1974-75
5
0
at Greensboro
n ff 1
44 02094819 South Buffalo Creek at U.S. Hwy421 at 36°0237" 79°4627" Guilford
Greensboro
45 ` 02094980 'South Buffalo Creek at Willow Road at 36°02 43" 79°45 43" Guilford
y
Greensboro
W
W
u ao
Creek
Greensboro 27.8 Buffalo 03030002 2 1969-71,1973-74 10 0
Creek
Greensboro:, ' 29:9 Buffalo 03030002 2 - .1954, 1956, 1958, 64,_ 27 0
Creek . 1966 ..

A Table 6. Summary of continuous -record gaging stations and partial -record measuring sites in the Cape Fear River Basin in North Carolina where records of gage
height and streamflow were collected —Continued
o [miZ, square mile; SR, secondary road; N/A, not applicable; SEC, sewage effluent outfall; Ind, drainage area is undetermined and(or) may be indeterminate. Gray shading indicates sites for which low -flow
F characteristics have been developed. Period of record for continuous -record sites (site type 1) is shown in months and years; period of record for partial -record sites (site type 2) is shown in water years in
T which discharge measurements were made]
0
S
Number of
o
measure-
USGS
USGS
Drainage
Hydrologic o
ments for
x downstream Station name
Latitude Longitude County topographic
area
Tributary unit
Period of record partial -record
corder number
quadrangle
(miZ)
fO code y
sites
in
in
Flow
flow
46
02094996
South Buffalo Creek at Pear Street at
36°03'09"
79°44'19"
Guilford
McLeansville
31.3
Buffalo
03030002
2 1969-70, 1973-74
7
0
Greensboro
Creek
47 ` -
ON095000
South Buffalo Creek near Greensboro
36°03'36.".
:79°43 33"
. Guilford. -
McLeansville : -
.34.0: :
"Buffalo
03030002
1 Aug 1928.z Sept 1958
N/A
N/A"
Creek. -
-
�
-
;2".�.1969,�L973-74.
�6 ,
�0
48
02095046
South Buffalo Creek 'ncar• Bcssemer, .
36°05.22"
..79P41.19" '
Guilford
McLeansville '"
.' 39.3 ;
Buffalo
03030002
2 " 1969-70;"197344' ,,1986
'`14
0
. _
Creek
"
49
02095091'
South,Buffalo Creek at SR 2821 at
36°0645" .,-
79°40'1,9''_,,
Guilford
.; McLxansville",
= 43;5,
Buffalo -
03030002 -
.l 'Mar- I986;-Sept 1987"
�N/A"
N/A".
McLeahsville..
Creek
.
...
"
2 �1969-70,;1973;, 976=81,
62
0 "
0,8345,1991-98 '.
50
02095181
North Buffalo Creek at Westover Terrace
36°04 45"
79°48 48"
Guilford
Greensboro
9.55
Haw River
03030002 .
2 1962
2
0
at Greensboro
51
02095228
North Buffalo Creek at Greensboro
36°04'53"
79°48'09"
Guilford
Greensboro
11.7
Buffalo
03030002
2 1969-71, 1973
6
0
52
02095271
North Buffalo Creek at Church Street at
36°05'52"
79°4658"
Guilford
Greensboro
Greensboro
53,"
'02095273,
North Buffalo Creek at"Yanceyville Street
36°66'05"'
79°4624"
Guilford'
=Greensboro .
near Greensboro-._
54
02095316
North Buffalo Creek at Summit Avenue at
36°06'18"
79°4553"
Guilford
Greensboro
Greensboro
55
02095317
North Buffalo Creek at U.S. Hwy 29 at
36°0617"
79°4543"
Guilford
Greensboro
Greensboro
56
02095406
Muddy Creek at Greensboro
36°06'35"
79°44'30"
Guilford
McLeansville
57
02095475
North Buffalo Creek tributary at SR 2835
36°08'01"
79°4329"
Guilford
Browns
at Greensboro
Summit
Creek
14.2
Buffalo
03030002
2
1986
4 0
Creek
15.3"
-"Buffalo
03030002 ,
2•
:1974-75;""L989 .
1.0 0'
".Creek'
.. -
21.7
Buffalo
03030002
2
1986
4 0
Creek
22.0
Buffalo
03030002
2
1969-71, 1973
7 0
Creek
3.85
North
03030002
2
1954, 1962
2 0
Buffalo
Creek
1.19
North
03030002
2
1974-75
5 0
Buffalo
Creek

Table 7. Magnitude and frequency of annual low -flow characteristics at selected continuous -record gaging stations in the
Cape Fear River Basin, North Carolina
[mP, square mile; climatic years, the annual period from April 1 to March 31 and identified by the year in which the period begins; (ft3/s)/mi2, cubic foot per
second per square mile; ft3/s, cubic foot per second; 7Q10, 7-day, 10-year low flow; 30Q2, 30-day, 2-year low flow; W7Q10, winter 7-day, 10-year low flow;
7Q2, 7-day, 2-year low flow; Flow regulation: U, unregulated flow; R, regulated flow; Method of analysis: C, estimates based on correlation techniques; LP,
estimates based on log -Pearson frequency distribution; G, estimates based on best -fit curves developed graphically from the log -Pearson analyses; PR,
gaging station having less than 10 years record of daily mean discharge, treated as a partial -record site where low -flow characteristics were developed by
using correlation techniques; <, less than; SR, secondary road; N/A, not available; NPDES, National Pollutant Discharge Elimination System. For each
continuous -record site using the period of analysis (usually the available period of record), the number of daily discharges equal to zero or less than or equal
to the indicated 7Q10 discharge are provided for informational purposes]
_
G
v
r_
E
C j
o c
'p
rn o
j0
Station name
W w
m '�
C `-'
❑
Mn
l6 T
c 2
10
o f
d v
Number of
observed
days of flow
O
3 0
C
m o
W N N 3
J Q
07
E r
C y
y ,�
m 3
;
Q
Low -flow characteristics
tfta/s)
O
( d CJ
t07 r
3
o
LL
5
b
c
-O
t
9
0209330990
Brooks Lake tributary near
0.06
PR
0a
0
0.9
0
< 0.05
< 0.05
0
U
C
Browns Summit
12
0209331325
Candy Creek at SR 2700 near
1.10
PR
0
23
0.9
< 0.05
0.2
0.2
0.1
U
C
Monticello
20
02093500
Haw River near Benaja
168
1929-70
0
68
0.9
7.8
34.0
31.0
23.0
U
LP
27
02093800
Reedy Fork near Oak Ridge
20.6
1956-97
0
94
1.2
3.4
7.2
7.4
5.7
Rb
LP
36
02094000
Horsepen Creek at Battle
16.4
1926-30,
0
72
0.9
1.4
3.3
3.0
2.5
U
LP
Ground'
1934-58
40
02094500
Reedy Fork near Gibsonville
131
1970-97
0
76
0.8
2.5
7.3
5.5
5.3
Ra
LP
47
02095000
South Buffalo Creek near
34.0
1929-57
0
97
1.1
1.7
5.3
3.5
4.0
Re
LP
Greensboro`
49
02095091
South Buffalo Creek at SR 2821
43.5
PR
0
34
1.5
17.7
23
22
20
Re
C
at McLeansville
58
02095500
North Buffalo Creek near
37.1
1938-89f
0
299
1.6
11.5
22.4
15.0
18.9
Re
LP
Greensboro
60
0209555450
Buffalo Creek at SR 2719 near
97.4
PR
0
23
1.5
37
49
49
45
Re
C
Osceola
61
02095608
Reedy Fork at NC 61 near
243
PR
0
30
1.5
43
60
58
55
Re
C
Osceola
75
02096000
Stony Creek near Burlington'
45.2
PR
29
29
0.9
0
1.0
0.6
0.4
U
C
81
02096500
Haw River at Haw River
606
1973-97
0
60
1.1
68.6
126
116
101
Rb
LP
109
02096700
Big Alamance Creek near Elon
116
1958-80
0
28
1.0
1.3
9.6
7.5
5.4
U
LP
College`
135
02096842
Cane Creek 0.1 mile above SR
0.64
PR
74
74
1.0
0
0
0
0
U
C
1126 near Buckhom
136
02096846
Cane Creek near Orange Grove
7.54
1989-97
53
53
1.0
0
0.09
.07
< 0.05
U
G
139
02096850
Cane Creek near Teere
33.4
1960-72
0
5
0.9
0.1
1.9
1.6
1.1
U
LP
152
02096960
Haw River near Bynurn
1,275
1974-97
0
94
1.0
75.9
164
152
132
Rb
LP
156
02097000
Haw River near Pittsborog
1,303
1929-72
0
270
0.9
40.0
160
103
102
Rb
LP
191
02097243
Third Fork Creek at Durham
1.67
PR
0a
0
1.0
0
0.2
0.1
0.1
U
C
197
02097314
New Hope Creek near Blands
75.9
1983-97
0
25
1.4
6.1
12.7
6.9
9.1
Re
LP
130 , Low -Flow Characteristics and Discharge Profiles for Selected Streams in the Cape Fear River Basin, N.C., through 1998

Table 7. Magnitude and frequency of annual low -flow characteristics at selected continuous -record gaging stations in the
Cape Fear River Basin, North Carolina -Continued
[miz, square mile; climatic years, the annual period from April 1 to March 31 and identified by the year in which the period begins; (ft3/s)/mi2, cubic foot per
second per square mile; ft3/s, cubic foot per second; 7Q10, 7-day, 10-year low flow; 30Q2, 30-day, 2-year low flow; W7Q10, winter 7-day, 10-year low flow;
7Q2, 7-day, 2-year low flow; Flow regulation: U, unregulated flow; R, regulated flow; Method of analysis: C, estimates based on correlation techniques; LP,
estimates based on log -Pearson frequency distribution; G, estimates based on best -fit curves developed graphically from the log -Pearson analyses; PR,
gaging station having less than 10 years record of daily mean discharge, treated as a partial -record site where low -flow characteristics were developed by
using correlation techniques; <, less than; SR, secondary road; N/A, not available; NPDES, National Pollutant Discharge Elimination System. For each
continuous -record site using the period of analysis (usually the available period of record), the number of daily discharges equal to zero or less than or equal
to the indicated 7Q10 discharge are provided for informational purposes]
Number of
Low -flow characteristics
U)a
An
observed
2
(fta/s)
d a
ro
days of flow
E
°
c
x
v
3 c'
o
Station name
m E
ro y
o'
`o
a
m
rn
o
c
rn
o f
3
o�-
mtf0.
3
O
o
°
m
o
m
frJ
Ci
LL
r
v
fn
rrn
a
W N
m
J =
>.2
Q
v
203
0209736050
Battle Branch near Chapel Hill
0.42
PR'
531
531
1.0
0
0.05 < 0.05
< 0.05
U
C
223
0209741955
Northeast Creek at SR 1100 near
21.1
1983-92,
0
32
1.5
1.8
4.6
2.4
3.0
Re
LP
Genlee
1996-97
229
02097464
Morgan Creek near White Cross
8.35
1989-97
0
12
1.0
< 0.05
0.4
0.5
0.2
U
G
236
02097500
Morgan Creek near Chapel Hill'
30.0
1923-31
0
10
1.1
0.6
4.2
2.2
2.7
R3
G
240
02097517
Morgan Creek (below
41.0
1983-97
0
38
1.1
6.4
12.2
6.5
10.5
Ri
LP
University Lake Dam) near
Chapel Hill
245
0209782150
New Hope River tributary at SR
2.05
PR
516
516
1.1
0
0
0
0
U
C
1716 near Farrington
247
02098000
New Hope River near Pittsborog
288
1949-72
0
67
1.0
4.5
16.4
10.7
10.8
Rb
LP
255
02098198
Haw River below B. Everett
1,689
PR
0
18
1.0
50.0
203
130
128
Rb
C
Jordan Dam near Moncure
1982-91
0
36
1.0
183
382
176
251
R'
LP
264
02098500
West Fork Dee River near
32.5
1929-57
0
57
1.0
2.1
5.7
5.3
4.0
Rb
LP
High Pointe
266
02099000
East Fork Deep River near High
14.8
1929-93
0
210
1.1
2.0
3.8
3.3
3.1
Rb
LP
Pointer
285
02099500
Deep River near Randleman'
125
1929-94
0
403
1.0
7.7
18.1
12.5
13.6
Rb
LP
287
02100000
Muddy Creek near Archdale'
16.5
PR
45
48
1.0
< 0.05
0.6
0.3
0.2
U
C
317
02100500
Deep River at Ramseur'
349
1923-94
0
384
1.0
12.0
45.6
25.1
29.5
Rb
LP
356
02101000
Bear Creek at Robbins'
137
1940-70
36
82
1.1
0.4
11.9
7.4
6.2
U
LP
367
0210108450
Suck Creek tributary near Zion
0.67
PR
49
49
1.0
0
< 0.05
< 0.05
0
U
C
Grove'
399
0210166029
Rocky River near Crutchfield
7.42
1989-97
4
101
1.1
0.2
0.5
0.3
0.3
U
G
Crossroads'
409
02101800
Tick Creek near Mount Vernon
15.5
1959-80,
304
304
0.9
0
0.3
0.08
0.06
U
LP
Springs`,l
1994
417
02102000
Deep River at Moncure'
1,434
1931-94
0
178
1.0
24.0
113
45.7
71.3
Rb
LP
431
02102192
Buckhorn Creek near Corinth
76.3
1981-97
0
54
0.7
0.2
0.9
0.4
0.4
Rm
LP
438
02102500
Cape Fear River at Lillington
3,464
1924-71
0
190
1.0
75.1
342
177
212
Rb
LP
1982-97
0
108
1.0
530
623
522
590
Rk
LP
Tables 131

Attachment 2
(QED Modeling Results

Table 2
Dowrigradient Area Groundwater Results
December 2007 through August 2008
Detected Volatile Organic Compounds (ug/L)
Dow Corning Corporation
Greensboro Facility
Constituents I MAC I D c 07 I Jan 08 I Mar 08 I May 08 I Jun 08 I Aug-08
Yellow 1/2 Report Limit
Est < Reporting limit (J)
(J,B)
Max Max Average Report limit Report limit Report limit Report limit Report limit Report limit
Actual Estimated+ Estimated+ now n7 Ian nQ RA-, no RA- no I.- no A.. nn
Acetone
700
75
50
5
45.5
40
2.2
75
36.28
150
100
10
10
91
80
2-Butanone
4,200;`
:9:2`i
50
5
5
45.5
40
9.2
50
25.78
150
100
10
10
91
80
Chloroform
70
7.5
5
,..fi_35`;N''=
Ot3 , `
4.55
A
0.35
7.5
3.62
15
10
1
1
9.1
8
Chloromethane
2.6
7.5
5
0.5
- 0.5
4.55,
4,
ND
7.5
3.68
15
10
1
1
9.1
8
Cyclohexane
1.e3i5e
5 _
0.5
0.5
4.55
4
3.5
5
3.01
15
10
1
1
9.1
$
1,1-Dichloroethane
70
51
35
2.4
4.4
34
29
51
51
25.97
15
10
1
1
9.1
8
1,1-Dichloroethene
7
54
x
28
54
54
23.68
15
10
1
1
9.1
8
cis-1,2-Dichloroethene
70
110
85
12
25
65
52
110
110
58.17
15
10
1
1
9.1
8
trans 1,2-Dichloroethene
100
7.5
5
0.5
0:$
4.55
4
0.2
7.5
3.63
15
10
1
1
9.1
8
1,2-Dichloropropane
0.51
7.5
5
0.5
0:5
4.55
4
ND
7.5
3.68
15
10
1
1
9.1
$
Methylene Chloride
4.6
7.5-
5'
0.5
0.5
4.55
4
ND
7.5
3.68
15
10
1
1
9.1
$
Tetrachloroethene
0.7
510
350
1_4
3
260
150
510
510
212.40
15
10
1
1
9.1
8
Toluene
1,000
. 7.5,
5 ' '
; `�°0;38; `;
. 0.5
4.55
4
0.38
7.5
3.66
15
10
1
1
9.1
8
1,1,1-Trichloroethane
200
7.5
5
0.5
0.5
:4.55
4-
ND
7.5
3.68
15
10
1
1
9.1
8
Trichloroethene
2.8
150
110
3=5
4_7
92
61
150
150
70.20
15
10
1
1
9.1
8
Vinyl Chloride
0.015
.7.5
5
'0.5
-0.5
4.55
4
ND
7.5
3.68
15
10
1
1
9.1
8
xylenes (total)
530
15.5
10
1
1
9
8.
ND
15.5
7.42
31
20
2
2
18
16
Total Chlorinated'VOCs
Concern of I 875 I 611 I 19.9 I 38.4 I 479 I 320
Notes:
(')Summation of tetrachloroethene, trichloroethene, 1, 1 -dichloroethene, 1,2-dichloroethene (total), i
MAC - North Carolina Maximum Allowable Concentration for Class GA groundwater.
J = Estimated concentration less than the reporting limit.
ND = Analyte not detected at the reporting limit.
Red underlined = Reported concentration exceeds MAC.
Stripper simulation run using the maximum actual ata, estimate ata
;blue and green) and)/2 reporting limit data for analytes not detected (yellow)
Nhichever was the greatest.
C:Projects/104-0011/SWI/Aug08/Table 2 - DGArea-Dec07-Aug08 1 of 1 9/22/2008

QED Stripper Model
Page 1 of 3
QED Air Stripper Model ver. c1.10 9/22/2008
Site Data
Name: Mark Allan Cokain e-mail: [e-mail]
Project: Greensboro. Max of actual, estimated and 1/2 rpt limits.
Units: English Altitude: 0 ft
Air Temp: 55 F Flow: 1 gpm
Water Temp: 55 F
Stripper: EZ-Stacker 2.xp - Click for details Stripper Air Flow: 140 cfm
Stripper Max Flow: 25 gpm
Water Results
Contaminant
Influent
Target
4-Tray
4-Tray
6-Tray
6-Tray
(ppb)
(ppb)
Results
%
Results
(ppb)
Removal
(ppb)
Removal
lacetone 1175 0� 15.4 79.467 9.6 87.200
1,1,1-trichloroethane 7.5 01 < 1 100.000 < 1 100.000
1,1-dichloroethane 51 0� < 1 100.000 < 1 100.000
1,1-dichloroethylene 54 0� < 1 61. < 1 100.000
1,2-dichloropropane 7.5 0� < 1 100.000 < 1 100.000
c-1,2-dichloroethylene 110 < 1 100.000 1100.0001
chloroform (trichloromethane) I7.5 0� < 1IT, 00.000 < 1 100.000
cyclohexane F-7 < 1 F _00-- _00 OTI 1100.000
m-xylene 15.5 0� < 1 100.000 < 1 Flo 0.000
methyl chloride 7.5 0� < 1 100.000 < 1 100.000
methyl ethyl ketone (MEK) 50 0� 5.8 88.400 2.5 95.000
methylene chloride 7000 .5 l0 < 1 100.< 1 100.006
o-xylene 15.5
0�
< 1
100.000
< 1 100.000
p-xylene 15.5
0�
< 1
100.000
< 1 100.000
It-1,2-dichloroethylene 117.5 10 < 1 100.000 < 1 100.000I
tetrachloroethylene (PERC,PCE)
IT,00.000
toluene
7.5
< 1
100.000
< 1
100.000
trichloroethylene (TCE) I150 10 < 1 100.000 < 1 1100.000
vinyl chloride (chloroethylene) 7.5 �� < 1 100.000 IF 1 100.000
Air Results
Contaminant
-Tray ]14-Tray
V4ppmv)
(ib/hr)
6-Tray
(ppmv)
6-Tray
(lb/hr)
acetone 110.0230
O.00003
0.0252
O.00003
1,1,1-trichloroethane 0.0013 J10.00000 110.0013 J10.00000
1,1-dichloroethane 10.0115
O . 00 0
10.0115
0.00003
1,1-dichloroethylene i10.0125
O.00003 110.0125
O.00003
1,2-dichloropropane 110.0015 JJO.00000 0.0015
O.00000
c-1,2-dichloroethylene 0.0254
O.00006 0.0254
0.00006
chloroform (trichloromethane)
10.0014
0.00000 110.0014 110.00000
cyclohexane
0.0013
0.00000
0.0013
O.00000
m-xylene 110.0033 O.00001
0.0033 J10.00001
II II II II --]1 11
http://64.9.214.199/egi-bin/cmod_run.pl 9/22/2008

QED Stripper Model
Page 2 of 3
Imethyl chloride II0.0033 110.00000 I10.0033 110.00000
methyl• ethyl ketone (MEK) 110.0138 110.00002 110.0148 O.00002
methylene chloride 0.0020 O.00000 110.0020 O.00000
o-xylene
0.0033
0.00001
0.0033
O.00001
p-xylene 110.0033
O.00001 110.0033
O.00001
t-1,2-dichloroethylen 10.0017 O.00000 0.0017 110.00000
tetrachloroethylene (PERC,PCE). 0.0689 O.00026 1 10.0689 110.00026
toluene
0.0018
0.00000
0.0018
0.00000
trichloroethylene (TCE)
0.0256
0.00008
0.0256
0.00008
otes
Copyright -- QED Treatment Equipment, PO Box 3726, Ann Arbor, MI 48106. 11
H-> 1-800-624-2026 or 1-734-995-2547 FX-> 1-734-995-1170. E-mail-
[e-mail]. WEB->www.pedenv.com.
QED modeler estimates unit performance for the listed contaminants. Results
mo -
1. dissolved -phase contaminant within a water matrix
2. clean stripper air
3. no surfactants, oil, grease or other immiscible phase(s) in the influent
4. unit operated within the given parameters and as instructed in the O&M
manual
Stripper performance shall meet or exceed either the required effluent
concentrations) or effluent estimates, whichever is greater, for the
conditions supplied and assumes the influent concentrations of each contaminant
are less than 25�1 solubility in water. QED makes no claim of the model's
accuracy beyond the 25t solubility in water limit.
Contact Us
Fill out your contact and project information and click Send to have a QED Treatment application
specialist contact you.
Name - IMark Allan Cokain
Company,
Comp
any
Phone - Phone Fax - Fax
e-mail - [e-mail] Project Greensboro. Max of actual, estimated and 1
Application Notes
Send Reset
Save Data
http://64.9.214.199/cgi-bin/cmod_run.pl 9/22/2008

QED Stripper Model
Page 3 of 3
Use the following URL to reconstruct your data form for future remodeling with
changes. This URL can be saved in any text file for record keeping and later
retrieval. This run's URL:
http://64.9.214.199/cgi-bin/remodel.pl?
u=e&tw=55&ta=55&f=1&a=0&s=2.xp&n=Mark+&e=[e-mail]&p=Gr
een&c=160,75;50,7.5;65,51;70,54;105,7.5;200,110;235,7.5;242,5;300,15.
5;310,7.5;315,50;330,7.5;340,15.5;20,15.5;405,7.5;40,510;10,7.5;35,15
http://64.9.214.199/egi-bin/emod_run.pl 9/22/2008

Table 2
Downgradient Area Groundwater Results
December 2007 through August 2008
Detected Volatile Organic Compounds (ug/L)
Dow Corning Corporation
Greensboro Facility
Constituents MAC I
MW-15 MW-15 MW-15 MW-15 MW-15 MW-15
Dec 07 Jan 08 Mar 08 May 08 Jun 08 Aug-08
Yellow., , . 1/2 Report Limit
fi•,,.fBtue:ar"` x:: <Est < Reporting limit (J)
Max Max Average Report limit Report limit Report limit Report limit Report limit Report limit
Actual Estimated+ Estimated+ nor n7 Ann nR hA.r t)Q hA-, no I- no A,.. no
Acetone
700
75...
50
45.5: ;
40
2.2
75
36.28
150
100
10
10
91
80
2-Butanone
4,200
>'> .9 2 r='`.
50
s `°
' - 51.
45.5;
40'•
9.2
50
25.78
150
100
10
10
91
80
Chloroform
70
715
5" -
=',t735; ;t
,='0'�1.'i:
' 4;55
4, .
0.35
7.5
3.62
15
10
1
1
9.1
8
Chloromethane
2.6
7.5
5
05
0 5 .
`. 4.55
:4
ND
7.5
3.68
15
10
1
1
9.1
8
Cyclohexane5.:,"=.
0.5`:.,
✓` 0.5'::
4:5b:,
`, 4:
3.5
5
3.01
15
10
1
1
9.1
8
1,1-Dichloroethane
70
51
35
2.4
4.4
34
29
51
51
25.97
15
10
1
1
9.1
8
1 J -Dichloroethene
7
54
31
;.:
:z,Pxa>-hF
28
28
54
54
23.68
15
10
1
1
9.1
8
cis-1,2-Dichloroethene
70
110
85
12
25
65
52
110
110
58.17
15
10
1
1
9.1
8
trans-1,2-Dichloroethene
100
7.5':..-
015,,
0.2
7.5
3.63
15
10
1
1
9.1
8
1,2-Dichloropropane
0.51
`= ` 7-,.,5'.
5...
- 0.5 ':
0:5 ' :
=.- 4.55 "_
4�'� -;,
ND
7.5
3.68
15
10
1
1
9.1
8
Methylene Chloride
4.6
0:5:; .
.`'6:5 -:
�,'4s55
.; � 4< '`
ND
7.5
3.68
15
10
1
1
9.1
8
Tetrachloroethene
0.7
510
350
1_4
3
260
150
510
510
212.40
15
10
1
1
9.1
8
Toluene
1,000
.'75
5
_a 38 "
0 5 "
"_ a 55_ ;
,: "a : `
0.38
7.5
3.66
15
10
1
1
9.1
8
1,1,1-Trichloroethane
200
7:5
::: :5�-:",
_ ` 0:5 `; =
`�; 0.5;
' . 4,55,
ND
7.5
3.68
15
10
1
1
9.1
8
Trichloroethene
2.8
150
110
3_5
4_7
92
61
150
150
70.20
15
10
1
1
9.1
8
Vinyl Chloride
0.015
7:5 _. `
. ':' 5 _
0.5 ':
_ `- 0:5 .`
4t55 ',
.'' .4:
ND
7.5
3.68
15
10
1
1
9.1
8
Xylenes (total)
530
15.5;
�. 10 ;;,.
1
1
9
8
ND
15.5
7.42
31
20
2
2
18
16
Total Chlorinated VOCs of Concern I 875 I 611 I 19.9 I 38.4 I 479 I 320
Notes:
1'ISummation of tetrachloroethene, trichloroethene, 1,1-dichloroethene, 1,2-dichloroethene (total),
MAC - North Carolina Maximum Allowable Concentration for Class GA groundwater.
J = Estimated concentration less than the reporting limit.
ND = Analyte not detected at the reporting limit.
Red underlined = Reported concentration exceeds MAC.
Stripper simulation run using the average of actual data, estimatedata
'blue and green) ands/2 reporting limit data for analytes not detected (yellow)
,ombined.
C:Projects/104-0011/SWI/Aug08rrable 2 - DGArea-Dec07-AugO8 1 of 1 9/22/2008

QED Stripper Model
Page 1 of 3
QED Air Stripper Model ver. c1.10 9/22/2008
Site Data
Name: Mark Allan Cokain e-mail: mark [e-mail]
Project: Greensboro. Average of actual, estimated and 1/2 rpt limits.
Units: English Altitude: 0 ft
Air Tamp: 55 F Flow: 1 gpm
Water Temp: 55 F
Stripper: EZ-Stacker 2.xp - Click for details Stripper Air Flow: 140 cfm
Stripper Max Flow: 25 gpm
ater Results
Contaminant
Influent
Target
4-Tray
4-Tray
6-Tray
6-Tray
(ppb)
(ppb)
Results
%
Results
(ppb)
Removal
(ppb)
Removal
P
cetone 136.28 lO 117.4 79.603 4.6 87.321
,1,1-trichloroethane 3.68 �� < 1 100.000 < 1 100.000
1,1-dichloroethane
125.97
0�
< 1
100.000
< 1
100.000
1,1-dichloroethylene
23.68
0�
< 1
100.000
< 1
100.000
1, 2-dichloropropane 3 . 68 110 l�< 1 11100. 0001k 1 11100. 00011
c-1,2-dichloroethylene 1158.17
10�
< 1
100.000
< 1
100.000
chloroform (trichloromethane)
3.62
100.000
< 1
100.000
lcyclohexane 13.01 10 < 1 100.000 < 1 1100.000
m-xylene 7.42 Fo I < 1 100.000 < 1 100.000
methyl chloride
3.68
< 1
100.000
< 1
100.000
methyl ethyl ketone (MEK)
25.78
�3.0
88.363 111.3
94.957
methylene chloride 13.68
10
< 1
100.000
< 1
100.000
o-xylene
7.42
0�
< 1
100.000
< 1
100.000
p-xylene
7.42
0�
< 1
F-6-6 -- -76EI
1100.0001
t-1,2-dichloroethylene 3.63
0�
< 1
100.000
< 1
100.000
tetrachloroethylene (PERC,PCE)
212.4
0�
< 1
100.000
< 1
100.000
toluene
3.66
0�
< 1
100.000
< 1
100.000
trichloroethylene (TCE)
70.20
0�
< 1
100.000
< 1
100.000
vinyl chloride (chloroethylene) 3.68
IV I
< 1 100.000
< 1
100.000
Air Results
Contaminant
4-Tray
(ppmV)
4-Tray
(lb/hr) J
6-Tray 6-Tray
I (ppmV) (lb/hr)
acetone 110.0111
O.00001
0.0122 O.00002
1,1,1-trichloroethane
0.0006 0.00000 0.0006 J10.00000
1,1-dichloroethane
0.0059
O.00001
0.0059
0.00001
1,1-dichloroethylene
0.0055
0.00001
0.0055 0.00001
1,2-dichloropropane
0.0007 0.00000 0.0007 0.00000
c-1,2-dichloroethylene
0.0134 O.00003 0.0134
O.00003
chloroform (trichloromethane)
0.0007 0.00000
0.0007
0.00000
cyclohexane
10.0008 O.00000 JIO.0008
0.00000
m-xylene 110.0016
J10.00000 0.0016 110.00000
http://64.9.214.199/cgi-bin/emod_run.pl 9/22/2008

QED Stripper Model
Page 2 of 3
Imethyl chloride 110.0016
0.00000
0.0016
0.00000
methyl ethyl ketone (MEK) 110.0071 J10.00001
0.0076 110.00001
methylene chloride 110.0010 0.00000
0.0010 O.00000
o-xylene 0.0016
O.00000 110.0016
110.00000
p-xylene 0.0016
O.00000
0.0016
O.00000
t-1,2-dichloroethylene 0.0008 O.00000
0.0008 J10.00000
tetrachloroethylene (PERC,PCE)
0.0287
0.00011
0.0287
0.00011
toluene
10.0009
O.00000
0.0009
O.00000
trichloroethylene (TCE) 110.0120 J10.00004
710.0120
0.00004
vinyl chloride (chloroethylene) 0.0013 J10.00000
0.0013 0.00000
L�Notes II
Copyright -- QED Treatment Equipment, PO Box 3726, Ann Arbor, MI 48106.
g-> 1-800-624-2026 or 1-734-995-2547 FX-> 1-734-995-1170. E-mail-
[e-mail]. WEB->www.gedenv.com.
QED modeler estimates unit performance for the listed contaminants. Results
ma -
1. dissolved -phase contaminant within a water matrix
2. clean stripper air
3. no surfactants, oil, grease or other immiscible phase(s) in the influent
4. unit operated within the given parameters and as instructed in the O&M
manual
Stripper performance shall meet or exceed either the required effluent
concentration(s) or effluent estimates, whichever is greater, for the
conditions supplied and assumes the influent concentrations of each contaminant
are less than 25$ solubility in water. QED makes no claim of the model's
accuracy beyond the 259 solubility in water limit.
Contact Us
Fill out your contact and project information and click Send to have a QED Treatment application
specialist contact you.
Name - ]Mark Allan Cokain
Company;_ .. ........_...._..........
Company
Phone- Phone Fax- Fax
e-mail - [e-mail] Project Greensboro. Average of actual, estimated a
_........... .. ....... .... ......... ......... ............__...... .....................__ ........ ......... .._ ......... ......................... ...
Application Notes
Send Reset
Save Data
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QED Stripper Model
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Use the following URL to reconstruct your data form for future remodeling with
changes. This URL can be saved in any text file for record keeping and later
retrieval. This run's URL:
......._............................................_............. __.. ...............
http://64.9.214.199/cgi-bin/remodel.pl?
u=e&tw=55&ta=55&f=1&a=0&s=2.xp&n=Mark+&e=[e-mail]&p=Gr
een&c=160,36.28;50,3.68;65,25.97;70,23.68;105,3.68;200,58.17;235,3.62
;242,3.01;300,7.42;310,3.68;315,25.78;330,3.68;340,7.42;20,7.42;405,3
http://64.9.214.199/cgi-bin/cmod_run.pl 9/22/2008

Table 2
Downgradient Area Groundwater Results
December 2007 through August 2008
Detected Volatile Organic Compounds (ug/L)
Dow Corning Corporation
Greensboro Facility
Constituents I MAC I Dec 07 I Jan-15 OS I Mar 08 I May 08 I J n 08 I Aug-08
Yellow 1/2 Report Limit
" 131ue Est < Reporting limit (J)
Max Max Average Report limit Report limit Report limit Report limit Report limit Report limit
Actual Estimated+ Estimated+ npc n7 _Ian OR (Aar OR hAav OR hin 11R Aii , no
Acetone
700
2.2
2.2
2.20
150
100
10
10
91
80
2-Butanone
4,200
9.2
9.2
9.20
150
100
10
10
91
80
Chloroform
70
0.35
0.35
0.33
15
10
1
1
9.1
8
Chloromethane
2.6
ND
0
#DIV/0!
15
10
1
1
9.1
8
Cyclohexane
13:5"�..
3.5
3.5
3.50
15
10
1
1
9.1
8
1,1-Dichloroethane
70
51
35
2.4
4.4
34
29
51
51
25.97
15
10
1
1
9.1
8
1,1-Dichloroethene
7
54
31
=fl,2z'=:
28
28
54
54
23.68
15
10
1
1
9.1
8
cis-1,2-Dichloroethene
70
110
85
12
25
65
52
110
110
58.17
15
10
1
1
9.1
8
trans- 1,2-Dichloroethene
100
fl y
0.2
0.2
0.20
15
10
1
1
9.1
8
1,2-Dichloropropane
0.51
ND
0
#DIV/0!
15
10
1
1
9.1
8
Methylene Chloride
4.6
ND
0
#DIV/0!
15
10
1
1
9.1
8
Tetrachloroethene
0.7
510
350
1_4
3
260
150
510
510
212.40
15
10
1
1
9.1
8
Toluene
1,000
r-`afl:38
0.38
0.38
0.38
15
10
1
1
9.1
8
1,1,1-Trichloroethane
200
0
#DIV/0!
15
101
9.1
8
Trichloroethene
2.8
150
110
3_5
4_7
92
810
150
70.20
15
10
1
1
9.1
8
vinyl chloride
0.015
tND
D
0
#DIV/0!
15
10
1
1
9.1
8
Xylenes (total)
530
D
0
#DIV/0!
31
20
2
2
18
16
Total Chlorinated VOCs of Concern"'" I 875 I 611 I 19.9 I 38.4 I 479 I 320
Notes:
("Summation of tetrachloroethene, trichloroethene, 1,1-dichloroethene, 1,2-dichloroethene (total),
MAC - North Carolina Maximum Allowable Concentration for Class GA groundwater.
J = Estimated concentration less than the reporting limit.
ND = Analyte not detected at the reporting limit.
Red underlined = Reported concentration exceeds MAC.
Stripper simulation run using the max of actual data and Fe -ported estimate-a-5
;blue and green). 1/2 reporting limit data not included.
C:Projects/1 04-001 1/SWI/Aug08/Table 2 - DGArea-Dec07-Aug08 1 of 1 9/22/2008

QED Stripper Model
Page 1 of 3
)ED Air Stripper Model ver. c1.10 9/22/20W
Site Data
Name: Mark Allan Cokain e-mail: mark—[e-mail]
Project: Greensboro. Max of actual and estimated < reporting limits (J). 1/2
Reporting limit estimates omitted.
Units: English Altitude: 0 ft
Air Temp: 55 F Flow: 1 gpm
Water Temp: 55 F
Stripper: EZ-Stacker 2.xp - Click for details Stripper Air Flow: 140 cfm
Stripper Max Flow: 25 gpm
Water Results
Contaminant Influent Target 4-Tray F'Removal
Tray 6-Tray 6-Tray
(ppb) (ppb) Results (ppb) Removal
acetone IF2.2 FO I F—I ___1 10�0� <�,--7 F,0
1,1,1-trichloroethane
Influent value is <= 0 -- not modeled.
1,1-dichloroethane
51
0�
< 1
100.000 < 1
100.000
Air Results
Contaminant 4-Tray 4-Tray 71 6-Tray 6-Tray
11(ppmv) (lb/hr) (ppmV) (lb/hr)
acetone 110.0007 0.00000 0.0007 0.00000
1,1,1-trichloroethane
lnfluent value is <= 0 -- no modeled.
1,1-dichloroethane
10.0115 O.00003 0.0115 0.00003
1,1-dichloroethylene
0.0125 O.00003 110.0125 J10.00003
1,2-dichloropropane 117
c-1,2-dichloroethylene 110.0254
influent value is <= 0 -- not modeled.
O.00006 110.0254 110.00006
chloroform (trichloromethane) 110.0001
cyclohexane
110.00000 110.0001 O.00000
0.0009 O.00000 0.0009 0.00000
m-xylene IF
.influer...t value is <= 0 -- not modeled.
http://64.9.214.199/cgi-bin/cmod_run,pl 9/22/2008

QED Stripper Model
Page 2 of 3
Imethyl chloride
II influent value is <= 0 --- riot modeled.
methyl ethyl ketone (MEK)
0.0025 J10.00000
0.0027 0.00000
methylene chloride influent value is <= 0 -- not _modeled.
o-xylene T_nfluent- value is <= 0 -- not modeled.
p-xylene _
?n.f.lu.e_i value is <- 0 -- not modeled.
t-1,2-dichlorcethylene
0.0001 110.00000 0.0001
0.00000
tetrachloroethylene (PERC,PCE)
0.0689
O.00026
0.0689
O.00026
toluene
10.0001
0.00000
0.0001
O.00000
trichloroethylene (TC
10.0256
O.00008
0.0256
O.00008
vinyl chloride (chloroethylene) influent value is <= 0 -- riot modeled.
otes
(Copyright -- QED Treatment Equipment, PO Box 3726, Ann Arbor, MI 48106. 1
'H-> 1-800-624-2026 or 1-734-995-2547 FX-> 1-734-995-1170. E-mail-
[e-mail]. WEB->www_�cedenv.com.
The QED modeler estimates unit performance for the listed contaminants. Results
assume -
1. dissolved -phase contaminant within a water matrix
2. clean stripper air
3. no surfactants, oil, grease or other immiscible phase(s) in the influent
4. unit operated within the given parameters and as instructed in the O&M
manual
Stripper performance shall meet or exceed either the required effluent
concentrations) or effluent estimates, whichever is greater, for the
conditions supplied and assumes the influent concentrations of each contaminant
are less than 25a solubility in water. QED makes no claim of the model's
accuracy beyond the 25-W solubility in water limit.
Contact Us
Fill out your contact and project information and click Send to have a QED Treatment application
specialist contact you.
Name - Mark Allan Cokain
Company P Y
Company
Send Reset
ave Data
http://64.9.214.199/egi-bin/emod_run.pl 9/22/2008

QED Stripper Model
Page 3 of 3
Use the following URL to reconstruct your data form for future remodeling with
changes. This URL can be saved in any text file for record keeping and later
retrieval. This run's URL:
http://64.9.214.199/cgi-bin/remodel.pl?
u=e&tw=55&ta=55&f=1&a=0&s=2.xp&n=Mark+&e=[e-mail]&p=Gr
een&c=160,2.2;,0;65,51;70,54;,0;200,110;235,0.35;242,3.5;,0;,0;315,9.
2;,0;,0;,0;405,0.2;40,510;10,0.38;35,150;,0;
http://64.9.214.199/cgi-bin/cmod_run.pl 9/22/2008

Table 5
Pilot Test Recovery Well Groundwater Analysis
Detected Volatile Organic Compounds (ug/L)
Results in Micrograms per Liter
Dual -Phase Extraction Pilot Study
Dow Corning Corporation
Greensboro, North Carolina
Constituents MAC 6/11/2008 6/25/2008 6/26/2008 6/27/2008
Yellow ':.. 1/2 Report Limit
Est < Reporting limit (J)
(J,B)
Report limit
Max Average Median Jun 08
Acetone
700
- 45i8.
Y}
45.5
91
2-Butanone
4,200
1900
71
1900
91
1,1-Dichloroethane
70
`f?j'20#. '
19
15
11
20
9.1
1,1-Dichloroethene
7
4.55;.
6.1
4.6
3.4
6.1
9.1
cis- 1,2-Dichloroethene
70fn
i"`.r
15
12
9.1
19
9.1
Methylene Chloride
4.6
.. t '
—
4:55:
'.4.55,
4.'55
11
9.1
Tetrachloroethene
0.7
140
110
91
68
1 140
9.1
Toluene
1,000
61
5.7
5.1
4.2
61
9.1
1, 1, 1 -Trichloroethane
200
;>' 4.55.
4.6
3.7
2.1
4.6
9.1
Trichloroethene .
2.8
r ; n'2b `;' .
18
14
10
25
9.1
I Total VOCs * I I 285.1 I 182.95 I 149.95 I 112.35
Notes:
MAC - North Carolina Maximum Allowable Concentration for Class GA groundwater.
B= Constituent detected in blank.
Stripper simulation using the maximum of actual data and reported estimate
data (blue and green). 1/2 reporting limit data (yellow) included for analytes
which were not detected.
= s ima a concen ra on ess than the reporting limit.
ND = Analyte not detected at the reporting limit.
*Excludes Acetone + 2-Butanone, which are potentially laboratory artifacts or airborn contaminants.
Red underlined = Reported concentration exceeds MAC.
C:Projects/104-0011/SWI/Aug08lrable 2 - DGArea-Dec07-AugO8 1 of 1 9/29/2008

QED Stripper Model
Page 1 of 2
Name: Mark Allan Cokain e-mail: [e-mail]
Project: Greensboro Pilot Test Well Stripper Simulation. Maximum Values Used.
Units: English Altitude: 0 ft
Air Temp: 55 F Flow: 1 gpm
Water Temp: 55 F
Stripper: EZ-Stacker 2.xp - Click for details Stripper Air Flow: 140 cfm
Stripper Max Flow: 25 gpm
Water Results
Contaminant
Influent
Target
4-Tray
4-Tray
6-Tray
6-Tray
(ppb)
(ppb)
Results
%
Results
(ppb)
Removal
(ppb)
Removal
toluene 1161 10 �! < 1 100.000 < 1 100.000
trichloroethylene (TCE) 25 < 1 100.000 < 1 100.000
tetrachloroethylene (PERC,PCE) 140 < 1 100.000 < 1 100.000
c-1,2-dichloroethylene 1100.00q< 1 100.000
1,1-dichloroethylene JF6.1 o I F 1 100.000 < 1 100.000
1,1,1-trichloroethane
4.6 0�
< 1 100.000
< 1
100.000
1,1-dichloroethane
1100.0001<
1 100.000
Air Results
Contaminant 4-Tray 4-Tray 6-Tray 6-Tray
(ppmv) 11(lb/hr) (ppmv) 11(lb/hr)
toluene 10.0148 110.00003 I10.0148 I10.00003
:richloroethylene (TC 10.0043 O.00001 110.0043 J10.00001
:etrachloroethylene (PERC,PCE) 0.0189 O.00007 0.0189 0.00007
c-1,2-dichloroethylene 0.0044 0.00001
0.0044
0.00001
1,1-dichloroethylene 10.0014
0.00000
0.0014
O.00000
1,1,1-trichloroethane 110.0008
O.00000
0.0008
10.00000
1,1-dichloroethane 110.0045 J10.00001 0.0045 O.00001
methylene chloride 0.0029 O.00001 0.0029 O.00001
acetone 0.0140 O.00002 0.0153 O.00002
methyl ethyl ketone (MEK) 110.5224 110.00084 0.5609 0.00090
Copyright -- QED Treatment Equipment, PO Box 3726, Ann Arbor, MI 48106.
PH-> 1-800-624-2026 or 1-734-995-2547 FX-> 1-734-995-1170. E-mail-
>info@credenv. com. WEB->www. q-edenv. com.
The QED modeler estimates unit performance for the listed contaminants. Results
http://64.9.214.199/cgi-bin/cmod_run.pl 9/29/2008

QED Stripper Model
Page 2 of 2
1. dissolved -phase contaminant within a water matrix
2. clean stripper air
3. no surfactants, oil, grease or other immiscible phase(s) in the influent
4. unit operated within the given parameters and as instructed in the O&M
manual
Stripper performance shall meet or exceed either the required effluent
concentration(s) or effluent estimates, whichever is greater, for the
conditions supplied and assumes the influent concentrations of each contaminant
are less than 25o solubility in water. QED makes no claim of the model's
accuracy beyond the 259 solubility in water limit.
Contact Us
Fill out your contact and project information and click Send to have a QED Treatment application
specialist contact you.
Name - Mark Allan Cokain
Company
Company
Phone- Phone
Fax - Fax
e-mail - [e-mail] Project -Greensboro Pilot Test Well Str
ip Simulal.
Application Notes
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ave Data
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u=e&tw=55&ta=55&f=1&a=0&s=2.xp&n=Mark+&e=[e-mail]&p=Gr
een&c=10,61;35,25;40,140;200,19;70,6.1;50,4.6;65,20;330,11;160,45.5;3 .
15,1900;
http://64.9.214.199/egi-bin/emod_run.pl 9/29/2008

Table 5
Pilot Test Recovery Well Groundwater Analysis
Detected Volatile Organic Compounds (ug/L)
Results in Micrograms per Liter
Dual -Phase Extraction Pilot Study
Dow Corning Corporation
Greensboro, North Carolina
Constituents MAC 6/11/2008 6/25/2008 6/26/2008 6/27/2008
Yellow 1/2 Report Limit
Est < Reporting limit (J)
(J,B)
Report limit
Max Average Median Jun 08
Acetone
700
: 45;5.
21.875
91
2-Butanone
4,200
1900
71`
tij14
' 'S%,
497.78
91
1,1-Dichloroethane
70
r2i3, 'fi:z=
19
15
11
16.25
9.1
1,1-Dichloroethene
7
4:56
6.1
4.6
3.4
4.6625
9.1
cis 1,2-Dichloroethene
70
15
12
9.1
13.775
9.1
Methylene Chloride
4.6
Yeti
4.55' ;
�.4:55
6.1625
9.1
:-
Tetrachloroethene
0.7
140
110
91
68
102.25
1 9.1
Toluene
1,000
61
5.7
5.1
4.2
19
9.1
1,1,1-Trichloroethane
200
4.55
4.6
3.7
2.1
3.7375
9.1
Trichooroethene
2.8
.; 2& jy;:y
18
14
10
16.75
9.1
Total VOCs ' 286.1 182.95 149.95 112.35
Notes: Stripper simulation using the average of actual data and reported estimate
MAC - North Carolina Maximum Allowable concentration for class GA groundwater. data (blue and green). 1 /2 reporting limit data (yellow) included for analytes
B= Constituent detected in blank. which were not detected.
J = Estimated concentration less than the reporting limit.
ND = Analyte not detected at the reporting limit.
*Excludes Acetone + 2-Butanone, which are potentially laboratory artifacts or airborn contaminants.
Red underlined = Reported concentration exceeds MAC.
C:Projects/104-0011/SWI/Aug08/Table 2 - DGArea-Dec07-Aug08 1 of 1 9/29/2008

QED Stripper Model
Page 1 of 2
QED Air Stripper Model ver. c1.10 9/29/2008
Site Data
Name: Mark Allan Cokain e-mail: [e-mail]
Project: Greensboro Pilot Test Well Stripper Simulation. Average Values Used.
Units: English Altitude: 0 ft
Air Temp: 55 F Flow: 1 gpm
Water Temp: 55 F
Stripper: EZ-Stacker 2.xp - Click for details Stripper Air Flow: 140 cfm
Stripper Max Flow: 25 gpm
Water Results
Contaminant Influent Tar et 4-Tra 4-Tra 6-Tra 6-Tra
J
Y
Y
Y
Y
(ppb)
(ppb)
Results
%
Results
o
(ppb)
Removal
(ppb)
Removal
toluene 111.9 L- < 1 1100.000 1< 1 1100.0001
trichloroethylene (TCE) 1100.0001 < 1 100.000
tetrachloroethylene (PERC,PCE) 102.25 < 1 100.000 < 1 Flo 0.000
c-1,2-dichloroethylene 13.78 < 1 100.000 < 1 100.000
1,1-dichloroethylene 4.66 FT-7 < 1 100.000 < 1 100.000
1,1,1-trichloroethane
3.74
< 1
100.000 < 1
100.000
1,1-dichloroethane
16.25
F < 1
100.000 < 1
100.000
Air Results 11
IContaminant 4-Tray 4-Tray 6-Tray 6-Tray
i� (ppmv) 11 (lb/hr) (ppmv) 11(lb/hr)
toluene 10.0046 O.00001 0.0046 0.00001
trichloroethylene (TC 10.0029 J10.00001 0.0029 0.00001
tetrachloroethylene (PERC,PCE) 0.0138 0.00005 0.0138 O.00005
c-1,2-dichloroethylene 0.0032 0.00001 0.0032 0.00001
1,1-dichloroethylene
10.0011
O.00000
0.0011
0.00000
1,1,1-trichloroethane
10.0006 J10.00000
0.0006
O.00000
I1, 1-dichloroethane I10.0037 IIO. 00001 IIO. 0037 IIO. 00001
methylene chloride 110.0016 110.00000 J10.0016 0.00000
acetone 110.0067 110.00001 O.0074 O.00001
methyl ethyl ketone (MEK) 110.1368 110.00022 0.1470 110.00024
Copyright -- QED Treatment Equipment, PO Box 3726, Ann Arbor, MI 48106. 1
PH-> 1-800-624-2026 or 1-734-995-2547 FX-> 1-734-995-1170. E-mail-
>infoLagedenv.com. WEB->www.gedenv.com.
The QED modeler estimates unit performance for the listed contaminants. Results
http://64.9.214.199/cgi-bin/emod_run.pl 9/29/2008

QED Stripper Model
Page 2 of 2
1. dissolved -phase contaminant within a water matrix
2. clean stripper air
3. no surfactants, oil, grease or other immiscible phase(s) in the influent
4. unit operated within the given parameters and as instructed in the O&M
manual
Stripper performance shall meet or exceed either the required effluent
concentration(s) or effluent estimates, whichever is greater, for the
conditions supplied and assumes the influent concentrations of each contaminant
are less than 25o solubility in water. QED makes no claim of the model's
accuracy beyond the 25% solubility in water limit.
Contact US
Fill out your contact and project information and click Send to have a QED Treatment application
specialist contact you.
Name - Mark Allan Cokain
Company,_......
; Company
Phone - Phone Fax - Fax
Project ..._ _--
e-mail - [e-mail] Greensboro Pilot Test Well Stripper Simulat
................. . .... . . ...... _........................... ... ... ............_........... ...... ........... ..........
._ ..... _.
Application Notes
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ave Data
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u=e&tw=55&ta=55&f=1&a=0&s=2.xp&n=Mark+&e=[e-mail]&p=Gr
een&c=10,19;35,16.75;40,102.25;200,13.78;70,4.66;50,3.74;65,16.25;330
16.16;160,21.88;315,497.78;
http://64.9.214.199/egi-bin/cmod_run.pl 9/29/2008

Attachment 3
Denial of Request to POTW

August 26, 2008
Project No. 104-.0011
Ms. Sharon Miller
Pretreatment Coordinator
City of Greensboro Water Resources Department
Industrial Waste Section
TZ Osborne Water Reclamation Facility
2350 Huffine Mill Road
McLeansville, North Carolina 27301
.D.ow Corning Corporation
Patterson Street Facility
Greensboro. North Carolina
Dear Ms. Miller:
On behalf of Dow Corning Corporation (Dow Corning), Cardinal Resources LLC (Cardinal
Resources.) requests permission to discharge treated groundwater to the City of Greensboro from
Dow Corning's Patterson Street facility. Cardinal Resources will be installing a remed.iation system
at the site to pump and treat groundwater impacted by chlorinated solvents.
The pumped groundwater will be treated with an air stripper, and levels of volatile organic corn=
pounds (VOCs) will be less than the maximum contaminant level - s when -treatment is completed.
The estimated volume of groundwater to be discharged is approximately 1.;000 gallons per day.
If your treatment facility can accept this.discharge, please inform us of any treatment conditions
that must be met. If you are unable to accept treated groundwater,. please let us know that as well
so that we can make other arrangements for disposal of' the treated water. For your convenience
in replying to this request, a signatory line has been added to this letter along with space for
comments. We would appreciate it if you could complete this and return it to our offices at the
address below.
Thank you for your assistance with this issue. If you have any questions or concerns, please
contact me at [e-mail] or 412.374.0989.
Sincerely,
CARDINAL RESOURCES LLC
(^ +�11n
J ye . O'Connor
Sonior Project Manager
JMO/wdi
Clean Water *Clean Environment *Worldwide
1505 .East Carson Street, Suite 200, Pittsburgh, Pennsylvania 15203
412.374.0989 - 888.374.09.89 - Fax: [phone]
Web://www,oardinalres.com

C RDINAL
Response to Request for Discharge:
❑ The City of Greensboro would be willing to accept treated groundwater if it meets the
conditions noted below
U The City of Greensboro is unable to accept treated groundwater for the reasons noted
below
Comments: ij� C1 Xi I'S_ 7c'7� -7e4j
c?`f ;�1. -c-
G2[ r �ri )� ,tom i� �� �✓ �:. �`t.'.r S �.�. a / GUc .f�d i7U/ �-4 ve �i.e c1�7� �'z�
Sigried: Q-u—
r /
Title: ? re

Attachment 4
Local Government Review Form

Attachment A. Focal Government Review Form
General Statute Overview: North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance
of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail, return receipt requested.
If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the certified
mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within the
15-day period.
Instructions to the Local Government: The nearby city and/or county government which may have or has jurisdiction over
any part of flee land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government_ Guilford County
(City/County)
Does the county lave jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located. Yes [ o [ If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/couniy have in effect a zoning or subdivision ordinance? Yes [ ] No [ ] (V * ( V_J
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes [ ]
No
Date �C� �'� Signature
(C4 T -/Co ty Manager)
State of tl �� &-O -ACL , County of Au RJ cd
On this dayof —0eh' 11 P.r ZL27$
' � ` Lin
" !' ,personally appeared before me, the said
name W a \a7� L� Lin IV e i 11 to me known and known to me to be the person described in
and who executed the foregoing document and he (or she) acknowledged that he (or she) executed the same and being duly sworn
by me, made oath that the statements in the foregoing document axe true.
My Commission expires /`T Q 0 .(Signature of Notary Public)
TA
EAA Guidance Document Version: June 23, 2005 (6-c
,Page 8 of 8®C0°

Attachment A. Local Government Review Form
General Statute Overview: North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance
of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
• Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail, return receipt requested.
■ If either (or both) local government(s) fails) to mail the completed form, as evidenced by the postmark on the certified
mail catd(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
• As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that die local government(s) failed to respond within the
15-day period.
Instructions to the Local Government: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government City of Greensboro
(City/County)
Does th *ca ' county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes �(] No [ ] If no, please sign this form, have it notarized, and return it to the applicant.
Does th crty/county have in effect a zoning or subdivision ordinance? Yes P`] No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes]
No [ ]
Date l 2/ 040
,
Signature P� W
rty Manager"County Manager)
..
n
State of , County of
On this �n day of ,aa ,personally appeared before me, the said
f
namAhAxec
to me known and known to me to be the person described in
and ed the foregoing document and he (or she) acknowledged that he (or she) executed the same and being duly sworn
by me, made oath that the statements in the foregoing document ate true.
My Commission expires_ 'LO'D�.(Signature of Notary Public)tklv a f%
Notary Public (Official Seal)
Vero- 14.
EAA Guidance Document Version: June 23, 2005
Page 8 of 8