WQ0018087 Application 200819

DAK Americas
August 2, 2020
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Permitting Section
Non -discharge Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Renewal Application of Permit for Surface Disposal of Residual Solids
Permit No.: WQ0018087
DAK Americas LLC
Cape Fear Facility
Brunswick County
Leland, North Carolina
File: 14974/51431
Dear Department of Environmental Quality:
DAK Americas LLC requests the renewal of Permit No. WQ0018087 without modification for the
surface disposal unit (SDU) at the Cape Fear Facility in Leland, North Carolina.
The site ceased manufacturing operations in 2013 and the SDU was subsequently closed under the
Disposal Unit Closure Plan, DAKAmericas LLC Cape Fear Facility (Closure Plan) approved
(letter dated February 16, 2015,) by Jim Gregson of the Wilmington Regional Office of the North
Carolina Department Environment and Natural Resources (NCDENR). No additional waste
activated sludge will be added to the SDU and the operation of the SDU has been modified to
include post -closure care as described in the Closure Plan.
This renewal application package includes:
1. Cover letter requesting renewal without modification,
2. Maintenance and Operations Plan, and
3. A copy of the current permit.
Site maps are included in the Maintenance and Operations Plan.
Sincerely,
Kent Erickson
Cape Fear Site Manager
Cape Fear Site • 1205 Culbreth Drive • Suite 100 + Wilmington, NC 28405
[phone] (phone) • [phone] (fax)

State of North Carolina
DWR
Department of Envir•onntental Quality
Division of Water Resources
Division of Water Resources 15A NCAC 02T .1100— SURFACE DISPOSAL OF RESIDUALS
FORM: SDR 11-15
1. APPLICANT INFORMATION:
1. Applicant's name: DAK Americas LLC
Applicant type: ❑ Individual 0 Corporation ❑ General Partnership ❑ Privately -Owned Public Utility
❑ federal ❑ State ❑ Municipal ❑ County
Signature authority's name per I_S_A NCAG 02T ,O106: Kent Erickson Title: Cape Fear Site Manager
Applicant's mailing address: 1205 Culbreth Drive, Suite 100
City: Wilmiri ton State: NC Zip: 28405-
Telephone number: [phone] Email Address: kerickson(2alpckpolyester.com
2. Consultant's name: NIA License Number (for P.E.), NA
Affiliation: ❑ On Staff ❑ Retained (Firm: N/A)
Consultant's mailing address: NIA
City: NIA State: NIA Zip: N/A -
Telephone number: (_) _-NIA Email Address: NIA
3. Soil Scientist's name: NIA License Number: NIA
Affiliation: ® NIA ❑ On Staff ❑ Retained (Finn: NIA)
Soil Scientist's mailing address: NIA
City: NIA State: NIA Zip: N/A
Telephone number: (_) _-N/A Email Address: NIA
4. Fee submitted: JQM (See Instruction B)
II. PERMIT INFORMATION:
1. Application is for (check all that apply): ❑ new, ❑ modified, ® renewed permit
2. If this application is being submitted to renew or modify an existing permit, provide the following:
Permit number: WOOOI8087
Date of most -recently issued permit: February 22.2016
Date of most -recently certified Attachment A (if different than the permit): NIA
Date of most -recently certified Attachment B (if different than the permit): N/A
11L FACILITY INFORMATION:
] . Name of residuals disposal facility: Cape Fear Manufacturing Facility
City: Leland State: NC Zip: 2845 1 -
Coordinates: Latitude: 34' 31' 46" Longitude: 78' 03' 43"
Datum: NAD 1983 Level of accuracy: 1 meter
Method of measurement: GIS
County where facility is located: Brunswick
FORM: SDR 06-16 Page 1 of 3

2. Facility contact (person familiar with residuals preparation/disposal):
Name: Penny Mahoney Title: Senior Director of Sustainability
Mailing address: 1205 Culbreth Drive, Suite 100
City: Wilmington State: NC Zip: 28405-
Telephone number: [phone] E-mail address: [e-mail]
IV. PROJECT INFORMATION (This section is not required for permit renewal without modification):
1. If project disturbs more than one acre, provide date when an erosion and sedimentation control plan was submitted to the
Division of Land Resources for approval:
2. If project includes any stream or wetland crossings, provide date when Nationwide 12 or 404 permit was submitted for
approval:
3. Provide buffers used to maintain compliance with any applicable river basin rules in 15A NCAC 2l3 ,Q200 (e.g., Neuse River
basin buffer rules):
3. Estimated volume of residuals to be disposed at the facility: (dry tons/year).
4. 100-year flood elevation feet mean sea level. Source:
5. Specify whether the surface disposal unit(s) located:
a. within the 100-year floodplain? ❑ yes or ❑ no
b. in a seismic impact zone? ❑ yes or ❑ no
c. less than 60 meters from a fault that has displacement in Holocene tune? ❑ yes or
d. within an unstable area? ❑ yes or ❑ no
6. Does the surface disposal unit(s) restrict base flood (100-year flood) flow? ❑ yes or
7. Please provide a description of the surface disposal unit(s) (e.g. lagoons, monofil, etc.): _
8. Depth of the seasonal high water table: feet.
9. Vertical distance between bottom of the disposal unit to the seasonal high water table:
minimum of three (3) foot separation.
❑ no
❑ no
feet. The Division requires a
10. Explain how access to the treatment and disposal units, by both human and animals, will be controlled:
11. Describe how runoff will be collected and disposed (The runoff collection system must have the capacity to handle runoff
from a 24-hour, 25-year storm event):
12. Describe the liner for the proposed or existing disposal unit (Attach all construction and design specifications):
13. Describe the leachate collection or decanting system for the disposal unit (Attach all construction and design specifications):
V. RESIDUALS SOURCE INFORMATION: (Required for all new, renewed, or modified residuals source)
Complete and submit the attached Residuals Source Certification and all associated documentation
Erg
Residuals Source
Certification
FORM: SDR 06-16 Page 2 of 3

Professional Engineer's Certification: (Application Involving New or Changes to Treatment or Surface Disposal Units)
attest that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I further attest that to the best of my knowledge
the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal
package may have been developed by other professionals, inclusion of these materials under my signature and seal signifies that I have
reviewed this material and have judged it to be consistent with the proposed design.
North Carolina Professional Engineer's Seal, Signature, and Date:
Applicant's Certification:
The applicant or any affiliate has not been convicted of an environmental crime, has not abandoned a wastewater facility without proper
closure, does not have an outstanding civil penalty where all appeals have been exhausted or abandoned, are compliant with any active
compliance schedule, and do not have any overdue annual fees under Rule 15A NCAC 021 0105.
® Yes 1� ❑ No, Explain; o,' �I
(Signature Authority's Name — PLEASE PRINT) / (Title)
attest that this application for ��` ^ f 1 m6�lC/tS h C
(Facility Name)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that the Division of Water Resources
may not conduct a technical review of this program and approval does not constitute a variance to any rules or statutes unless specifically
granted in the permit. Further, any discharge of residuals to surface waters or the land will result in an immediate enforcement action,
which may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the Division of Water
Resources should a condition of this permit be violated. I also understand that if all required parts of this application are not completed
and that if all required supporting information and attachments are not included, this application package will be returned to me as
incomplete.
Note: In accordance with North Carolina General Statutes § 143-215.6A and § 143-215.613, any person who knowingly makes any false
statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up to $25,000 per violation.
Signature: Date: 4—�z SAP 0
FORM: SDR 06-16 Page 3 of 3

r
OPERATIONS & MAINTENANCE PLAN
DAK Americas LLC
Cape Fear Facility
Leland, North Carolina

TABLE OF CONTENTS
1.0 Introduction....................................................................................................................................................... ...... 1
.... .....................
1.1 SDU Description...........................................................................................................................................................................1
1.1.1 Surface Reinforcement Layer.........................................................................................................................................1
1.1.2 Floating Modular Layer....................................................................................................................................................1
1.1.3 Biogas Venting System......................................................................................................................................................2
1.1.4 Impermeable Geomembrane Layer............................................................................................................................2
1.2 Stormwater Controls and Conveyances............................................................................................................................2
1.3 Fencing............................................................................................................................................................................................ 2
1.4 Objectives.......................................................................................................................................................................................2
2.0 Inspection-, .......................... ............................... ..................................................................................................................... ...... 3
2.1 Cover.................................................................................................................................................................................................3
2.2 Biogas ventilation system........................................................................................................................................................3
2.3 Berm.................................................................................................................................................................................................3
2.4 Stormwater Conveyance System..........................................................................................................................................4
2.5 Fencing............................................................................................................................................................................................4
3.0 Maintenance......................................................................................................................................................................................5
3.1 Cover.................................................................................................................................................................................................5
3.2 Biogas Ventilation System.......................................................................................................................................................5
3.3 Berm.................................................................................................................................................................................................5
3.4 Stormwater Conveyance System..........................................................................................................................................5
4.0 Monitoring..........................................................................................................................................................................................6
4.1 Groundwater, ................................................................................................................................................................................ 6
4.2 Methane...........................................................................................................................................................................................6
5.0 Repair...................................................................................................................................................................................................7
5.1 Cover.................................................................................................................................................................................................7
5.2 Biogas Ventilation System.......................................................................................................................................................7
5.3 Berm.................................................................................................................................................................................................7
5.4 Stormwater Conveyance System..........................................................................................................................................7
5.5 Fence................................................................................................................................................................................................7
5.6 Contingency Plan.........................................................................................................................................................................7
6.0 Documentation.................................................................................................................................................................................8
6.1 Inspection Checklists.................................................................................................................................................................8
6.2 Groundwater Monitoring Reports.......................................................................................................................................8
6.3 Methane...........................................................................................................................................................................................8
6.4 Repairs.............................................................................................................................................................................................8
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Figures
1 Site Location
2 Site Layout
Groundwater Monitoring Network
4 Methane Monitoring Points
Appendices
A Inspection Form
B Contingency Plan
Groundwater Monitoring Report
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1.0 INTRODUCTION
This Surface Disposal Unit [SDU) Operation and Maintenance Plan (Plan) pertains to the post closure operation
and maintenance of a SDU located at the DAK Americas, LLC (DAK Americas) Cape Fear Facility (CFF) in Leland,
NC (Figure 1). Since its construction in 1973, the SDU has received stabilized Class B Waste Activated Sludge
(WAS) generated by the CFF wastewater treatment plant (WWTP). Production operations at the CFF stopped in
December 2013. The SDU has been covered in accordance with the Surface Disposal Unit Closure Plan, DAK
Americas LLC Cape Fear Facility (OBG, 201S). The SDU is permitted under the Department of Water Resources,
permit number WQ0018087.
1.1 SDU DESCRIPTION
The SDU encompasses approximately 12-acres, and consists of a former land application sprayfield that has
been bermed and covered to contain solids derived from historical waste water treatment at the CFF (Figure 2).
The SDU stopped receiving solids and was covered on August 10, 2015, in accordance with the Surface Disposal
Unit Closure Plan, DAKAmericas LLC Cape Fear Facility (OBG, 2015). At the time this Plan was prepared, the
underdrain and leachate collection system was continuing to produce a small volume of leachate. Leachate
generation has been dropping steadily since the cover was completed, and is anticipated to stop soon. Once
leachate generation has stopped, the underdrain system will be capped, in accordance with the Surface Disposal
Unit Closure Plan, DAKAmericas LLC Cape Fear Facility (OBG, 2015). The cover system consists of four layers,
where each layer provides a distinct function. The four layers and their corresponding functions are listed
below, in order from the bottom up:
1) Surface Reinforcement Layer
2) Floating Modular Layer
3) Gas Venting System
The gas venting system will vent biogas generated to the air outside the impermeable geomembrane.
4) Impermeable Geomembrane Layer
The impermeable layer will prevent infiltration of precipitation and promote runoff of stormwater.
The following subsections provide details for each layer of the cover system and discuss how they function.
1.1.1 Surface Reinforcement Layer
The purpose of the surface reinforcement layer is to stabilize the SDU surface to facilitate installation of the
other three layers of the cover system. The surface reinforcement layer consists of a single layer of biaxial
geogrid that covers the entire SDU surface. The biaxial geogrid is a polypropylene mesh with a minimum rib
thickness of 1,78 mm and normal aperture (mesh opening) dimension of 25 mm. The biaxial geogrid was placed
directly on top of the SDU and anchored into the existing berm. The biaxial geogrid functions to distribute loads
over a larger area of the SDU.
1.1.2 Floating Modular Layer
The purpose of the floating modular layer is to keep the gas venting system and impermeable geomembrane
layer above the SDU surface. The floating modular layer consists of thick panels of insulation individually
encapsulated in watertight casings of geomembrane. These modular floats have been arranged in a contiguous
grid to cover the entire surface of the SDU. Adjacent modular floats were fastened together by thermally welding
a strip of geomembrane between each casing. Floats have also been fastened to cables that secure the floats to
the berm. The cables span the entire SDU and are anchored into the berm via the anchor trench. Floats are
fastened to the cables with a loop of geomembrane thermally welded to each casing. The boundary between
casings has not been sealed so that biogas can travel readily to the biogas collection system.
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1.1.3 Biogas Venting System
Anaerobic decay of the SDU contents and production of biogas is anticipated to continue after installation of the
cover system. Biogas is a mixture of methane, carbon dioxide and trace gases such as hydrogen sulfide. The
biogas venting system consists of a network of gas collection pipes that passively vent to the atmosphere outside
the cover. The network of collection pipes is horizontally sandwiched between the floating modular layer and
the impermeable geomembrane layer.
1.1.4 Impermeable Geomembrane Layer
The impermeable geomembrane layer consists of high density polyethylene (HDPE) with a nominal thickness of
80-mil (0.08-inch). This layer will be assembled by welding sections of HDPE sheets together, near their edges,
to create a single continuous sheet to cover the entire SDU surface. Weighted channels will facilitate the
collection and routing of stormwater off of the cover. The perimeter of the impermeable geomembrane layer will
be anchored into the existing berm.
1.2 STORMWATER CONTROLS AND CONVEYANCES
Several stormwater controls and conveyances have been installed to route stormwater off of the SDU cover.
These consist of the following:
m channels formed in the SDU cover
r channels along the outside of the berm lined with grass and permanent reinforcement matting.
Stormwater discharged from the surface of the SDU is discharged in accordance with the requirements of NPDES
permit NCS000392, for as long as this permit remains active and this permit is in effect.
1.3 FENCING
Once work is completed, a security will encompass the entire SDU. The security fence restricts public and
wildlife access, as required by 15A NCAC 02T .1109(c)(2)(G) and (H). The closed SDU will be accessible for
maintenance through one locked gate. Signs will be posted at the access gate that warn of hazards within the
security fence. Signs will warn of the following hazards:
++ Engulfment
Drowning
Combustible Atmosphere
Snakes.
1.4 OBJECTIVES
The purpose of this Plan is to establish a process for post -closure care of the SDU and its related components
that is:
■ Protective of human health and the environment
■ Specifically compliant with the requirements of the North Carolina Permit for the Surface Disposal of
Residual Solids WQ0018087 (SDU Permit), as well as the North Carolina (15A NCAC 02T.1109) and Federal
(40 CFR Part 503 Subpart C) regulations pertaining to Surface Disposal of Sewage Sludge
r In accordance with the Guidelinesfor the Closure of Permitted Wastewater Ponds and.Lagoons (NCDENR, June
22, 2012)
Generally in accordance with the requirements for RCRA Post -Closure Care (40 CFR Part 264 Subpart G).
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2.0 INSPECTION
The SDU will be inspected at least annually, to ensure it is not compromised and that it is functioning as
designed. Inspections will be documented on inspection forms (Appendix A) and photographs. These items will
be used in documenting compliance (Section 6.0) as well as for identifying needed repairs (Section 5.0) Before
inspection, previous inspection forms will be reviewed to verify that areas previously identified as needing
repair have been addressed and to call attention to areas previously identified as causing concern. The sections
that follow identify key items of each component to be evaluated during inspection.
2.1 COVER
The cover will be inspected to identify and assess the following:
■ breaks in seams, tears, holes
■ bulges associated with inadequate gas venting performance
■ debris on top of the cover
■ areas subjected to excessive stretching
■ deformation of the stormwater channels built into the cover
■ displaced stormwater channel ballast weights
■ obstruction to flow in the stormwater channels built into the cover
■ excessive pooling of stormwater
■ depressions indicating potentially submerged biogas collection pipes
■ deterioration of the seals where the biogas vents penetrate the cover
miscellaneous conditions that pose a threat to the integrity of the cover.
2.2 BIOGAS VENTILATION SYSTEM
The biogas ventilation system will be inspected to identify and assess the following:
m deterioration of biogas vents outside of the cover
■ evidence of blockages in the venting system (bulges or bubbles on the cap)
■ presence of debris or vegetation around discharge vents.
2.3 BERM
The integrity of berm will be inspected to identify and assess the following:
■ leachate seepage through the berm
■ soil disturbance resulting from anchoring the cover into the berm, burrowing animals, etc.
■ slope failure
* erosion
■ development of deep rooted vegetation or excessive grass height
■ loss of vegetation providing erosion control and exposed soil
■ miscellaneous conditions that pose a threat to the integrity of the berm.
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2.4 STORMWATER CONVEYANCE SYSTEM
Stormwater conveyance features outside of the cover will be inspected to identify and assess the following:
• obstruction of drainage channels outside the cover
w evidence of stormwater flow bypassing the grass lined channels
n erosion of grass lined channels
• obstruction of flow in grass lined channels
■ development of deep rooted vegetation or excessive growth in grass lined channels
■ miscellaneous conditions that pose a threat to the functionality of the stormwater drainage system.
2.5 FENCING
The security fencing encompassing the SDU will be inspected identify and assess the following:
• evidence of tunneling or burrowing beneath the fence
■ failing or missing gate locks
• ability of the fence to restrict access to people and animals
■ development of excessive vegetation between the SDU berm and fence
■ development of excessive vegetation within a 10-ft boundary outside the fence.
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3.0 MAINTENANCE
Routine maintenance will be necessary for the cover, biogas ventilation system, berm, and stormwater
conveyance system, as described in the sections that follow. No routine maintenance is anticipated for the fence
surrounding the SDU.
3.1 COVER
Cover maintenance will consist of removing debris from the cover and stormwater channels. Maintenance will
be performed quarterly. Most debris is anticipated to be wind-blown, such as, pollen, dust and landscaping
clippings. Debris shall be removed by leaf blowers, spraying with water and by hand. During maintenance, the
cover will be inspected for signs of damage, and repairs will be made, if necessary, as described in Section 5.1.
3.2 BIOGAS VENTILATION SYSTEM
Normally, maintenance of the biogas ventilation system will be performed quarterly, concurrently with cover
maintenance (Section 3.1). Maintenance will consist of removing debris and vegetation from around gas vents.
During maintenance, the biogas ventilation system will be inspected for signs of damage, and repairs will be
made, if necessary, as described in Section 5.2.
3.3 BERM
Berm maintenance will be performed semiannually, and will consist of mowing to suppress the growth of deep
rooted vegetation. During maintenance, the biogas ventilation system will be inspected for signs of damage, and
repairs will be made, if necessary, as described in Section 5.3.
3.4 STORMWATER CONVEYANCE SYSTEM
The stormwater system will be maintained for as long as the stormwater permit (NPDES permit NCS000392) for
the site remains active. Maintenance will consist of following activities, at the prescribed frequency:
Landscaping of grass lined channels
■ Clearing of debris and sediment from stormwater features (as needed based on inspection).
During maintenance, the stormwater conveyance system will be inspected for signs of damage, and repairs will
be made, if necessary, as described in Section 5.4.
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4.0 MONITORING
Groundwater and methane monitoring will be performed throughout the three-year post -closure period, as
described in the sections that follow.
4.1 GROUNDWATER
Groundwater monitoring will be performed annually, every December, during the three-year post -closure
period, for the parameters specified in the SDU Permit. The monitoring network will include two upgradient and
four downgradient monitoring wells (Figure 3). Approximately three years after closure, and with the approval
of the DWR, groundwater monitoring will cease and the monitoring wells will be closed and abandoned.
The property boundary adjacent the SDU will be monitored quarterly during the post -closure period, to ensure
the LEL for methane is not exceeded, as required by 15A NCAC 02T.1109(c)(2)(F). The property boundary is
closest to the east side of the SDU; therefore, three points east of the SDU, along the property boundary (Figure
4), will be monitored. Monitoring will be performed with a portable gas meter, capable of measuring LEL, and
calibrated with methane gas. LEL will be measured at each monitoring point for a duration of 5 minutes. In the
unlikely event that the methane LEL is exceeded at the property boundary, a continuous monitoring device will
be installed and LEL will be monitored for 48 hours to provide further information regarding the air quality. If
the exceedance is confirmed by the continuous monitoring, measures will be taken to reduce ambient biogas
concentrations at the property boundary to below the methane LEL.
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5.0 REPAIR
Repairs to the various elements of the SDU will be performed on an as -needed basis. Anticipated potential
repairs are described in the sections that follow.
5.1 COVER
Potential repairs include:
■ Weld broken seams in the 11DPE cover
• Patch holes or tears
■ Cut in and add additional cover material at locations under excessive tension
■ Repair any problems observed in drainage from the cover.
5.2 BIOGAS VENTILATION SYSTEM
Potential repairs include:
4 Reseal biogas ventilation pipe to the cover and penetration points
r Clear blocked vent pipes.
5.3 BERM
Potential repairs include:
F# Regrading and reseeding of eroded areas
Filling of animal burrows.
5.4 STORMWATER CONVEYANCE SYSTEM
Potential repairs include:
■ Promote growth at areas lacking vegetation
Restoration of eroded channels.
5.5 FENCE
Potential repairs include:
Rehanging of gates
Replacement of damaged posts or sections of chain link
t+ Replacement of signs
5.6 CONTINGENCY PLAN
The Post -Closure SDU Contingency Plan will be implemented if an incident might threaten human health or the
environment, as required by 40 CFR Part 264.227 (Appendix B).
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6.0 DOCUMENTATION
Inspections, monitoring, and repairs will be documented as described in the sections that follow.
6.1 INSPECTION CHECKLISTS
Inspection checklists (Appendix A) will be completed for annual inspections. Copies of the completed inspection
checklists will be retained by the owner.
6.2 GROUNDWATER MONITORING REPORTS
Two copies of the results of the groundwater sampling and analysis entered on Form GW-59 (Appendix C), along
with attached copies of laboratory analyses, will be submitted to the DWR on or before the last working day of a
three-month period following the sampling month. Copies of the completed forms will be retained by the
owner.
6.3 METHANE
Methane monitoring reports will be documented in a logbook or memorandum on a quarterly basis. Copies of
the completed documentation will be retained by the owner.
6.4 REPAIRS
Repairs made will be documented with a logbook entry, memorandum, or subcontractor invoice, and retained
by the owner.
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Figures
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MAP LOCATION
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DATE: 10/29/15
DAK AMERICAS LLC
CAPE FEAR FACILITY
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GROUNDWATER MONITORING
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Appendix A — Inspection
Form
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DAK AMERICAS, LLC
CAPE FEAR FACILITY
Directions
SDU POST -CLOSURE INSPECTION CHECKLIST
Date: Personnel:
Location: Closed Surface Disposal Unit Inspector Company:
Phone #:
Fencing: Walk the perimeter fence.
Cover: Walk along all the welded seams between HDPE sheets and look for the following defects and signs of faulty operation.
Berm Integrity: Walk the perimeter of the top and the base of the SDU berm and look for the following defects and signs of faulty operation.
Stormwater Conveyance Outside of the Cover: Walk the perimeter of the top and the base of the SDU berm and look for the following defects and signs of faulty
operation.
Biogas Vents: Inspect each vent.
Indicate whether or not the following inspection items, or miscellaneous defects, are observed. Indicate the approximate location of an observed flaw on a
Contractor Drawing set.
Inspection Feature
Circle
One
Description and Comments
FENCING
Evidence of tunneling or burrowing
Attention
Not an
beneath the fence
needed
issue
Failing or missing gate locks
Attention
Not anneeded
issue
Ability of fence to restrict access of
Attention
Not an
animals and people
needed
issue
Development of excessive vegetation
Attention
Not an
between the SDU berm and fence
needed
issue
Development of excessive vegetation
Attention
Not an
within a 10-ft boundary outside the fence
needed
issue
Page 1 of 4

SDU POST -CLOSURE INSPECTION CHECKLIST
Inspection Feature Circle One description and Comments
COVER
Breaks inseams, tears, or hates
Attention
Not anneeded
issue
Bulges associated with inadequate gas
Attention
Not an
venting performance
needed
issue
Debris on top of cover
Attention
Not anneeded
issue
Areas subjected to excessive stretching
Attention
Not anneeded
issue
Deformation of the stormwater channels
built into the cover, displaced ballast
Attention
Not an
weights
needed
issue
Obstruction to flow in the stormwater
Attention
Not an
channels built into the cover
needed
issue
Excessive pooling of stormwater
Attention
Not an
needed
issue
Depressions indicating potentially
Attention
Not an
submerged biogas collection pipes
needed
issue
Deterioration of the seals where the
biogas vents penetrate the cover
Attention
Not an
needed
issue
Miscellaneous conditions that pose a
threat to the integrity of the cover
Attention
Not an
needed
issue
Page 2 of 4

SDU POST -CLOSURE INSPECTION CHECKLIST
Inspection Feature Circle One Description and Comments
BERM INTEGRITY
Leachate seepage through the berm
Attention
Not anneeded
issue
Soil disturbance at cover -berm boundary,
Attention
Not an
animal burrows, etc.
needed
issue
Slope failure
Attention
Not an
needed
issue
Erosion
Attention
Not an
needed
issue
Development of deep rooted vegetation
Attention
Not an
or excessive grass height
needed
issue
Loss of vegetation proving erosion
Attention
Not an
control or exposed soil
needed
issue
Miscellaneous conditions that pose a
Attention
Not an
threat to the integrity of the berm
needed
issue
STORMWATER
CONVEYANCE OUTSIDE THE COVER
Obstruction of drainage channels outside
Attention
Not an
the cover
needed
issue
Erosion of riprap aprons connecting
ballasted cover channels to the grass
Attention
Not an
lined channels
needed
issue
Evidence of stormwater flow bypassing
Attention
Not an
the grass lined channels
needed
issue
Erosion of the grass lined channels
Attention
Not an
needed
issue
Obstruction of flow in grass lined
Attention
Not an
channels
needed
issue
Development of deep rooted vegetation
or excessive growth in grass lined
Attention
Not an
channels
needed
issue
Miscellaneous conditions that pose a
threat to the functionality of the
Attention
Nat an
stormwater drainage system
needed
issue
Page 3 of 4

SDU POST -CLOSURE INSPECTION CHECKLIST
Inspection Feature Circle One Description and Comments
Biogas Vents
Deterioration of biogas vents outside of
the cover
Attention
needed
Not an
issue
Obstruction to flow of biogas out of the
vents
Attention
needed
Not an
issue
Additional Comments:
Items to be observed in next inspection:
Recommended maintenance activities:
Page 4 of 4

Appendix B —
Contingency Plan
OBG r0i
THERE'S A WAY

DAK Americas, LLC
Leland, North Carolina
September 2015
rim

TABLE OF CONTENTS
1. Facility Identification and General Information...................................................................................................................1
2. Emergency Coordinator..................................................................................................................................................................2
3. Implementation of Contingency Plan........................................................................................................................................3
4. Emergency Response Procedure for Catastrophic Breaches & Release.....................................................................4
Figures
Contingency Plan Site Map
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1. FACILITY IDENTIFICATION AND GENERAL INFORMATION
Facility Name: DAK Americas, LLC
Location: 3500 Daniels Road Northeast, Leland, NC 28451.
Type of Facility: Waste Storage Facility
Waste Description: Biological solids generated via wastewater treatment (non -hazardous waste)
Method of Storage: A single, covered, above -ground impoundment with biogas ventilation
Quantity of Waste: 12.9 acres, 8-ft tall (170,000 cubic yards)
oBG 1 9/17/2015 FINAL 1 1
am I:`Dak-Americas.14974\51431.Cape-Fear-Decor\Docs\Reports�0 & M

2. EMERGENCY COORDINATOR
-.............._.._......._................ ........ ....._...........
.. . .
Primary Coordinator
Name:
Street Address:
City, State, Zip:
Phone (Office):
Phone (Home):
Backup Coordinator
Name:
Street Address:
City, State, Zip:
Phone (Office):
Phone (Home):
OBG 1 9/17/2015
nt W. Erickson
1205 Culbreth Dr.. Suite 100
Wilmington, NC 28405
[phone]
(9101538-5216
Penny C. Mahoney
1205 Culbreth Dr., Suite 100
Wilmington, NC 28405
[phone]
[phone]
ONFINAL 1 2
:\Dak-ArrL6cas.14974\51431,Cape-Fear.Decor\0ocs\Reports\0 & M

3. IMPLEMENTATION OF CONTINGENCY PLAN
The Contingency Plan will be implemented if an incident might threaten human health or the environment. The
emergency coordinator has the full authority to make this decision.
A catastrophic breach of the impoundment berm and release of SDU waste might call for implementation of the
Contingency Plan. A release has the potential to contaminate groundwater via infiltration or surface water via
stormwater runoff.
Take the following steps if a berm is catastrophically breached and waste is released:
1) Immediately notify NCDEN R DWR of the incident by phone
2) Immediately seal the breach
3) Immediately contain released waste
4) Take any other necessary steps to stop or prevent catastrophic failure
5) If the breach cannot be sealed or the release returned to the sealed impoundment in a manner quick
enough to protect human health and the environment, then transfer the waste to an appropriate waste
disposal facility
6) Notify the NCDENR DWR of the problem in writing within seven days after detecting the problem
OBG 1 9/17/2015 � FINAL 1 3
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4. EMERGENCY RESPONSE PROCEDURE FOR CATASTROPHIC BREACHES & RELEASE
Immediately Upon Discovery of the Catastrophic Breach and Release
The emergency coordinator will contact the NCDENR Division of Water Resources - Wilmington Regional Office
(910-796-7215) and report the incident. The report will include the following:
■ Name and telephone number of the reporter
■ Name and address of the facility
M Time and type of incident
• Identification and quantity of materials involved
rt The possible hazards to human health and the environment outside the facility
During the Emergency Control Phase
d Obtain immediate service from a grading and excavation contractor
• Use earth -moving equipment (excavators, bucket loaders, etc.) to seal the breach with earthen material
■ Use earth -moving equipment to contain the released waste with temporary dikes
■ If ongoing release cannot be stopped, then transfer the waste to an appropriate waste disposal facility
Following Attainment of Control
m If released waste is solid in nature, or can be stabilized with soil, use earth -moving equipment to return the
waste to the impoundment
■ If released waste is too fluid to move with earth -moving equipment, or cannot be stabilized with soil, obtain
immediate service from a contactor that can return the waste to the impoundment with a pump or vacuum
truck
n If released waste cannot be returned to the impoundment in a manner quick enough to protect human health
and the environment, then transfer the waste to an appropriate waste disposal facility
Required Written Report
Within seven (7) days of a catastrophic breach, the emergency coordinator will file a report with the NCDENR
Division of Water Resources - Wilmington Regional Office. The report will include the following information:
■ Name and telephone number of the reporter
Name and address of the facility
Date, time and type of incident
■ Identification and quantity of materials involved
The possible hazards to human health and the environment outside the facility
o Estimated quantity and disposition if recovered waste.
OBG 1 9/17/2015 � FINAL 1 4
�Dak-Americas.14974\51431.Cape-Fear-Decon\Docs\Reports\o & M

Contingency Plan Site
Map
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Appendix C —
Groundwater Monitoring
Report
OBG rim THERE'S A WAY

SUBMIT FORM ON YELLOW PAPER ONLY
GROUNDWATER QUALITY MONITORING:
COMPLIANCE REPORT FORM
Facility Name:
Permit Name (if different):
Facility Address:
jc'i
act Person: _
LocationlSite Name:
Please Print Clearly or Type
(Street)
County
(SlateV 17m;
SAMPLING INFORMATION
WELL ID NUMBER (from Permit):
Well Depth: ft.
Depth to Water Level 82546: ft. below measuring point
Measuring Point is ft. above land surface
Volume of water pumped/bailed before sampling:
Samples for metals were collected unfiltered: ❑ YES I
Telephone#:
No. of wells to be sampled:
Date sample collected:
Well Diameter:
Screened Interval:
Relative M,P. Elevation:
DEPARTMENT OF ENVIRONMENT a NA7URAL RESOURCES
DIVISION OF WATER RESOURCES - INFORMATION PROCESSING UNIT
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 Phone: [phone]
PERMIT Number: Expiration Date:
Non -Discharge UIC
NPDES Other
TYPE OF PERMITTED OPERATION BEING MONITORED
❑ Lagoon ❑ Remediation: Infiltration Gallery
❑ Spray Field ❑ Remediation:
in.
ft. to �ft.
ft.
gallons
NO and field acidified: ❑ YES ❑ N
❑ Rotary Distributor ❑ Land Application of Sludge
❑ Water Source Heat Pump ❑ Other:
FIELD ANALYSES:
pH 00400:
Spec. Cond. 0009a
Odor ocom: _
Appearance
units
WAS DRY
Temp, 00010: °C at time of
teMhos sampling,
Date sample analyzed:
Laboratory Name:
Certification No.
PARAMETERS NOTE: Values should reflect
dissolved and colloidal concentrations.
COD ao335
ri
Nitrite (NO,) as N 00615
nri
Pb - Lead o1o51 uglL
Coliform: MF Fecal 31616
)1001
Nitrate (NO.) as N 00620
mglL
Zn - Zinc 01092 mglL
Coliform: MF Total 31504
11001
Phosphorus: Total as P 00665
mg/L
{Nora, use MPN memos for highly turbid samples)
Orthophosphate 70507
mg1L
Other (Specify Compounds and Concentration Units):
Dissolved SOIidS:TOtal 70300
mg/L
AI - Aluminum 01105
mg1L
pH (Lab) 00403
units
Ba - Barium 01007
ug1L
TOC ooaao
i
Ca - Calcium o0916
mi
Chloride 00940
mglL
Cd - Cadmium 01027
ug1L
Arsenic 01002
1
Chromium: Total w34
uglL
Grease and Oils 00552
mglL
Cu - Copper 01042
mi
ORGANICS: (by GC, GC1MS, HPLC)
Phenol 32730
ug1L
Fe - Iron 01045
11
(Specify test and method #. ATTACH LAB REPORT.)
Sulfate 00945
mglL
Hg - Mercury 71900
uglL
Lab Report Attached? ❑ Yes (1) ® No (0)
Specific Conductance oco95
uMhos
K - Potassium 00937
mglL
VOC 78732 method #
Total Ammonia 00610
ni
Mg - Magnesium 00927
mglL
method #
(Ammonia Nitrogen; NH, as N; Ammonia Nitrogen, Total)
Mn -Manganese close
uglL
method #
TKN as N 00625
ni
Ni - Nickel 01067
uglL
method #
For Remediation Systems Only (Attach Lab Reports):
Influent Total VOCs:
mglL Effluent Total VOCs: ni VOC Removal%
Permitlee (crAuthorized Agent) Name and Title - Please print or type Signature of Permiltee (or Authorized Agent) (Date)
GW-59 Rev.8/2013
here:
X

Water Resources
ENVIRONMENTAL QUALITY
PAT MCCRORY
Clovemor
DONALD R. VAN DER VAART
.Secreraly
S. JAY ZIMMERMAN
DO'e N,
February 22, 2016
PENNY C. MAHONEY — DIRECTOR OF SUSTAINABILITY
DAK AMERICAS, LLC
3147 SOUTH 17111 STREET — SUITE 300
WILMINGTON, NORTH CAROLINA 28412
Dear Ms. Mahoney:
Subject: Permit No. WQ0018087
Cape Fear Manufacturing Facility
Surface Disposal of Class B
Residuals (Dedicated)
Brunswick County
In accordance with your permit adjudication request received December 8, 2015 for the now voided
permit issued November 10, 2015, and based upon subsequent discussions between the Permittee and the
Division of Water Resources, we are forwarding herewith Permit No. WQ0018087 dated February 22,
2016, to DAK Americas, LLC for the continued operation of the subject residuals management program.
Upon closure of the surface disposal unit (SDU) in accordance with the Department -approved Surface
Disposal Unit Closure Plan for the Cape Fear Facility of DAK Americas LLC, dated January 16, 2015, the
Permittee may submit a permit modification request to reduce the groundwater monitoring frequency, or
request a permit rescission.
Modifications to the subject permit are as follows: Four new monitor wells (MW-2B, MW-2C,
MW-2D & MW-2E) will be installed and will be monitored annually along with two existing wells (MW-
2 & MW-03A) for a list of groundwater monitoring parameters which has been expanded to include
Arsenic, Cadmium, Mercury and Selenium.
This permit shall be effective from the date of issuance until January 31, 2021, shall void Permit
No. WQ0018087 issued June 4, 2009, and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring requirements listed in Attachments A and C, for
they may differ from the previous permit issuance. Failure to establish an adequate system for collecting
and maintaining the required operational information shall result in future compliance problems. Please
note that the capacity of the surface disposal unit is 194,000 cubic yards, that approximately 170,000
cubic yards have been utilized, and that the unit is no longer accepting residuals, and no expansion of
the dikes is altolved
State of North Carolina I Environmental Quality I Water Resources I Water Quality Pennitting I Non -Discharge Permitting
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 807 6464

Ms. Penny C. Mahoney
February 22, 2016
Page 2 of 3
Please note that the following permit conditions have been removed since the last permit
issuance dated June 4, 2009:
A Old Condition I. I . —This condition has been met.
➢ Old Condition 1.2. — This condition has been met.
A Old Condition II.11. — This condition has been met.
➢ Old Condition I11.2. — This condition is inherently covered under new Condition 11.1.
➢ Old Conditions IV.6. & IV.7. — These conditions are inherently covered under new Condition
TVA.
➢ Old Condition VI.6. —This condition is inherently covered under new Conditions V1.6. & VI.7.
Please note the following permit conditions are new or have been modified since the last
permit issuance dated June 4, 2009:
➢ Condition I. I. — Addresses the closure plan and its implementation schedule.
➢ Condition 1.2. — Requires well installation approval and notification of the Regional Office.
➢ Condition 1.3. — Requires preparation of a new site map after well installation.
➢ Condition 1.5. — Describes the procedure for renewing the permit.
➢ Condition 11.7. -- Requires biological residuals to meet pathogen requirements.
A Condition 111.2. — Requires notification of the regional office prior to using a new disposal site.
➢ Condition 11I.3. -- States the minimum requirements for an Operation and Maintenance Plan,
A Condition II1.4. — Requires retaining an ORC and a backup ORC for the facility.
➢ Condition 111.6. -- Prohibits public access to the facility before and after closure.
A Condition 111.7. — Requires runoff from the cap to be handled through a stormwater NPDES
discharge permit.
➢ Condition 111.9. — Prohibits crops front being grown on the surface disposal unit.
➢ Condition 111.10. — Prohibits animal grazing on the surface disposal unit.
➢ Condition I11.11. — Describes the final cover system to be used on the surface disposal unit.
➢ Condition IV.5. -- Addresses the initial sampling and reporting of the new monitor wells.
A Condition IVA -- Requires the well construction record for a new well to be submitted with
the initial sampling data.
a Condition iV,10. — Requires the submission of an annual report before March I" of the
following year.

Ms. Penny C. Mahoney
February 22, 2016
Page 3 of 3
➢ Condition VI.6. —Allows the permit to be revoked or modified under certain conditions.
➢ Condition V1.7. — Prohibits expansion of the permitted facilities under certain circumstances.
➢ Attachment C — Expands the list of groundwater sampling parameters to include Arsenic,
Cadmium, Mercury & Selenium.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding,
If you need additional information concerning this permit, please contact David Goodrich at (919)
807-6352 or by email at david.goodriclt agnedenr.V .
Sincerely,
7—S. Jay Zimmerman, P.G., Director
Division of Water Resources
cc: Brunswick County Health Department (Electronic Copy)
Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Maureen T. Hoke, P.E. — O'Brien & Gere, (Maureen.Hokegobg com) (Electronic Copy)
Beth Buffington — Protection and Enforcement Branch (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

THIS PAG'E BLANK

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
SURFACE; DISPOSAL OF CLASS B RESIDUALS PERMIT (DEDICATED)
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
DAK Americas, LLC
Brunswick County
FOR THE
continued operation of a residuals management program for DAK Americas, LLC and consisting of the
surface disposal of Class B residuals generated at the DAK Americas' Cape Fear Site to the approved
surface disposal unit with no discharge of wastes to surface waters, pursuant to the permit adjudication
request received December 8, 2015, and in conformity with other supporting data subsequently filed and
approved by the Department of Environmental Quality and considered a part of this permit. The use and
disposal of residuals are regulated under Title 40 Code of Federal Regulations Part 257. This permit does
not exempt the Permittee from complying with the federal regulations.
The disposal site, a 12-acre pond known as the Surface Disposal Unit (SDU) includes an underdrain system
that feeds into a sump that overflows to a gauge -monitored overflow pond. This facility includes a drainage
ditch adjacent to the southwestern corner of the 12-acre pond that has its flow pumped back for inclusion
into the system. The SDU was covered and ceased receiving residuals on August 10, 2015.
This permit shall be effective from the date of issuance until January 31, 2021, shall void Permit No.
WQ0018087 issued June 4, 2009 and shall be subject to the following specified conditions and limitations;
I. SCHEDULES
The Division shall be notified in writing when the Surface Disposal Unit (SDU) capping activities, and
decommissioning of the SDU's associated systems (underdrain system, sump, overflow pond, drainage
ditch, and appurtenances) conclude. The closure and post -closure care program for the SDU will be in
accordance with the Surface Disposal Unit Closure Plan (Closure Plan) and implementation schedule
submitted by DAK Americas LLC on January 16, 2015 and approved by the Division on letter dated
February 16, 2015, along with documents subsequently submitted to the Division. [15A NCAC 02T
.0108(b)(1), 02T .0108(b)(2), 02T ,1109(c)(3))
WQ0018087 Version 2.0 Shell Version 151201 Page 1 of 9

2. The Wilmington Regional Office, telephone number [phone], shall approve monitoring wells
M W-2B, M W-2C, M W-2D and M W-2E prior to installation, and the monitoring wells shall be installed
within 90 days of the effective date of this permit. The regional office shall be notified at least 48 hours
prior to the construction of any monitoring well, and such notification to the regional supervisor shall
be made from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. The
monitoring wells shall be constructed such that the water level in the well is never above or below the
screened (open) portion of the well at any time during the year, and in accordance with 15A NCAC
02C .0108. The general location and name for each monitoring well is marked on Figure 2. [15A
NCAC 02C .0108, 02T .0108(b)(2)]
3. Within 60 days of monitoring well completion, the Permittee shall submit two original copies of a site
map with a scale no greater than 1-inch equals 100 feet; however, special provisions may be granted
upon prior approval for large properties. At a minimum, the map shall include the following
information:
a. The location and identity of each monitoring well.
b. The location of major components of the waste disposal system.
c. The location of property boundaries within 500 feet of the disposal areas.
d. The latitude and longitude of the established horizontal control monument.
e. The elevation of the top of the well casing (i.e., measuring point) relative to a common datum.
f. The depth of water below the measuring point at the time the measuring point is established.
g. The location of compliance and review boundaries.
h. The date the map is prepared and/or revised.
Control monuments shall be installed in such a manner and made of such materials that the monument
will not be destroyed due to activities taking place on the property. The map and any supporting
documentation shall be sent to the Division of Water Resources, Water Quality Permitting Section,
Non -Discharge Permitting Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617. [15A NCAC
02C .0105(f), 02T .0108(b)(2)]
No later than six months prior to the expiration of this pen -nit, the Pennittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 021' .0105(d) requires an updated site map to be submitted with the permit renewal application.
[ 15A NCAC 02T .0105(d), 02T .0108(b)(2), 02T .0109]
11. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all times so
there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance
conditions due to improper operation and maintenance, the Permittee shall immediately cease disposal
of residuals to the surface disposal unit, contact the Wilmington Regional Office supervisor, and take
any immediate corrective actions. [G.S. 143-215.1]
2. This permit shall not relieve the Pennittee of responsibility for damages to groundwater or surface
water resulting from the operation of this residuals management program. [15A NCAC 02B .0200,
02L .0100]
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction, [ 15A NCAC 02C .0108]
4. Only residuals generated by the facilities listed in Attachment A are approved for surface disposal in
accordance with this permit. [G.S. 143-215.1]
WQ0018087 Version 2.0 Shell Version 151201 Page 2 of 9

5. Only the sites listed in Attachment Bare approved for residuals surface disposal. [G,S. 143-215.1]
6. Pollutant concentrations in residuals for surface disposal shall not exceed the following Ceiling
Concentrations (dry weight basis):
Distance from Surface Disposal Unit
Boundary to Closest Property Line
(meters)
Ceiling Concentration
(milligrams per kilogram)
Arsenic
Chromium
Nickel
0 to < 25
30
200
210
25 to < 50
34
220
240
50 to < 75
39
260
270
75 to < 100
46
300
320
100 to < 125
53
360
390
125 and greater
b2
450
420
[ISA NCAC 02T .1105]
7. Biological residuals that are placed in a surface disposal unit shall meet the pathogen reduction
requirements in 15A NCAC 02T .1106 and one of the vector attraction reduction alternatives in 15A
NCAC 02T .1107(b). Exceptions to these requirements shall be specified in Attachment A. [ISA
NCAC 02T. 1105]
8. Setbacks for surface disposal units shall be as follows:
Setback Description
Setback
feet
Habitable residence or place of public assembly under separate ownership or not to
400
be maintained as part of the project site
Property lines
50
Public right of way
50
Private or public water supply source, all streams classified as WS or B, waters
classified as SA or SB and any Class I or Class II impounded reservoir used as a
100
source of drinking water
Surface waters (streams — intermittent and perennial, perennial waterbodies, and
100
wetlands), any stream, lake, river, or natural drainage way
Surface water diversions (ephemeral streams, waterways, ditches), or any
downslope interceptor drains or downslope surface water diversions, or any
25
groundwater lowering ditches or surface drainage ditches that are not part of the
s stem
Subsurface groundwater lowering system
25
Wells with exception to monitoring wells
100
[15A NCAC 02T. 110 8]
The residual land application site was individually permitted on or after December 30, 1983; therefore,
the compliance boundary is established at either 250 feet from the residual land application area, or 50
feet within the property boundary, whichever is closest to the residual land application area. An
exceedance of groundwater standards at or beyond the compliance boundary is subject to remediation
action according to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in accordance with
North Carolina General Statute 143-215.6A through 143-215.6C. Any approved relocation of the
COMPLIANCE BOUNDARY will be noted in Attachment B. [15A NCAC 02L .0107(a)]
WQ0018087 Version 2.0 Shell Version 151201 Page 3 of 9

10. The review boundary shall be established midway between the compliance boundary and the residual
land application area. Any exceedance of groundwater standards at the review boundary shall require
action in accordance with 15A NCAC 02L .0106. [15A NCAC 02L .0108]
11. No wells, other than Division approved monitoring wells, shall be constructed within the compliance
boundary, except as provided by 15A NCAC 021.0107(g). [15A NCAC 021,.0107(d)]
ill. OPERATION AND MAINTENANCE REQ_i_TIREMENTS
The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards. [ 15A NCAC 02T .1110]
2. The Wilmington Regional Office, telephone number [phone], and the appropriate local
government official (i.e., county manager, city manager, or health director) shall be notified at least 48
hours prior to the initial surface disposal event to any new land application site. Notification to the
regional supervisor shall be made from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding
State liolidays. [15A NCAC 02T .0108(b)(1)]
3. The Perm ittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) Modifications
to the O&M Plan shall be approved by the Division prior to utilization of the new plan. The O&M Plan,
at the minimum, shall include:
a. Operational functions;
b. Maintenance schedules;
c. Safety measures;
d. Spill response plan;
e. Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including record keeping and actions to be taken
by the inspector in the event that noncompliance is observed pursuant to the noncompliance
notification requirements under the monitoring and reporting section of the permit;
f. Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring;
ii. Detailed description of monitoring procedures including parameters to be monitored;
iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for any
foreseen fluctuations in residuals duality and indicate the most limiting times for residuals to
meet pathogen reduction requirements (e.g. facilities that land apply multiple times per year
but have an annual sampling frequency, may need to sample during winter months when
pathogen reduction is most likely to be negatively affected by cold temperatures).
[I5A NCAC 02T .11001
WQ0018087 Version 2.0 Shell Version 151201 Page 4 of

4. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in responsible
charge (ORC) and one or more certified operators as back-up ORCs in accordance with 15A NCAC
08G .0201. The ORC or his back-up shall visit the facilities in accordance with 15A NCAC 08G. 0204,
or as specified in the most recently approved O&M plan (i.e., see Condition 1I1.3),'and shall comply
with all other conditions of 15A NCAC 08G. 0204. For more information regarding classification and
designation requirements, please contact the Division of Water Resources' Protection and Enforcement
Branch at [phone]. [15A NCAC 02T .0117]
5. A copy of this permit shall be maintained by DAK Americas, LLC and shall be made available to the
Division for inspection purposes and upon the Division's request. The spill prevention and control plan
shall be maintained in all residuals transport and application vehicles. [15A NCAC 02T .0108(b)(1)]
6. Appropriate measures shall be taken to prohibit public access to the surface disposal unit during active
use and after closure of the surface disposal unit. Such controls will include fencing and the posting of
signs indicating the activities conducted at each site. [15A NCAC 02T .1109(c)(2)(G)]
7. Adequate provisions shall be taken to prevent surface runoff from the SDU. All runoff collected in
accordance with 15A NCAC 02T .1 109(c)(2)(D) shall be disposed in a Division approved manner.
[15A NCAC 02T .1109(c)(2)(C)]
S. Adequate provisions shall be taken to prevent wind erosion from conveying residuals from the surface
disposal sites onto adjacent properties or into surface waters. [ISA NCAC 02T .1109(c)(2)(C)]
9. Food crops, feed crops and/or fiber crops shall not be grown on the surface disposal unit, unless
approval has been requested and received from the Division. [15A NCAC 02T .1109(c)(2)(I)]
10. Animal grazing shall not be permitted on the surface disposal unit, unless approval has been requested
and received from the Division. [15A NCAC 02T .1109(c)(2)(H)]
11. The final cover system for each cell of the surface disposal unit shall consist of four layers (a surface
reinforcement layer (biaxial geogrid polypropylene mesh), a floating modular layer, a biogas venting
system layer, and a high density polyethylene impermeable geomembrane layer), as described in
Section 5.0 of the Surface Disposal Unit Closure Plan. [ 15A NCAC 02T .1109(c)(3)]
12. This permit shall become voidable if operation of the surface disposal sites causes contravention of
surface water or groundwater standards, and may be revoked unless the surface disposal sites are
maintained and operated in a manner that will protect the assigned surface water and groundwater
quality standards. [15A NCAC 02T .0110]
13. Until the Division approves closure of the Overflow Pond, freeboard in the Overflow Pond shall not be
less than two feet at any time. The freeboard levels in the referenced Pond shall be monitored by an
individual gauge that is readily visible permanent markings indicating the maximum liquid level at the
top of the temporary liquid storage volume, minimum liquid level at the bottom of the temporary liquid
storage volume, and top of the dam elevations. Freeboard level in the referenced section of the unit
shall be monitored and recorded weekly (i.e., excluding weekends and State Holidays). [15A NCAC
02T .1109(b)(1)]
14. A protective vegetative cover shall be established on all protected areas and maintained on the
embankments of the 12-acre lagoon (i.e., outside toe of embankment to maximum liquid level), berms,
pipe rums, erosion control areas, and surface water diversions. Trees, shrubs, and other woody
vegetation shall not be allowed to grow on the unit dikes and embankments. All embankment areas
shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T .1109(b)(1)]
WQ0018087 Version 2.0 Shell Version 151201 Page 5 of 9

IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division -required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed. [ 15A NCAC 02T .0108(c)]
Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). Residuals that tests or is classified as a hazardous or toxic waste under 40
CFR Part 261 shall not be used or disposed under this permit. The analyses [corrosivity, ignitability,
reactivity, and toxicity characteristic leaching Procedure (TCLP)1 shall be performed at the
frequency specified in Attachment A, and the Pennittee shall maintain these results for a minimum of
five years. Any exceptions from the requirements in this condition shall be specified in Attachment A.
The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses);
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachloro phenol (100.0)
Benzene (0.5)
1, 1 -Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0.008
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Flexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200,0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
[ 15A NCAC 13A .0102(b), 02T .l 101, 02T .1105]
3. An analysis shall be conducted on residuals from each source generating facility at the frequency
specified in Attachment A, and the Permittee shall maintain the results for a minimum of five years.
The analysis shall include the following parameters;
Arsenic
pH
Nickel
Chromium
Percent Total Solids
[ 15A NCAC 021' .1101 ]
4. Laboratory parameter analyses shall be performed on the residuals as they are disposed in the surface
disposal unit, and shall be in accordance with the monitoring requirements in 15A NCAC 02B .0505.
[1 SA NCAC 02B .05051
5. Monitoring wells MW-2 (2A), MW-2B, MW-2C, MW-2D, MW-2E and MW-03A shall be sampled at
the frequencies and for the parameters specified in Attachment C. All mapping. well construction
forms, well abandonment forms and monitoring data shall refer to the permit number and the well
nomenclature as provided in Attachment C and Figure 2. [15A NCAC 02T .0105(rn)]
WQ0018097 Version 2.0 Shell Version 151201 Page 6 of 9

6. For initial sampling of the new monitoring wells, MW-2B, MW-2C, MW-2D and MW-2E, the
Permittee shall submit a Compliance Monitoring Form (GW-59) and a Well Construction Record Form
(GW-1) listing this permit number and the appropriate monitoring well identification number. Initial
Compliance Monitoring Forms (GW-59) without copies of the Well Construction Record Forms (GW-
1) are deemed incomplete, and maybe returned to the Permittec without being processed. [ 15A NCAC
02T .0105(m)]
Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail ,Service Center
Raleigh, North Carolina 27699-1617
[ 15A NCAC 02T .0105(m)]
8. The Permittee shall maintain records tracking all residual surface disposal events. At a minimum, these
records shall include the following:
a. Date and freeboard level measurements in the Overflow Pond;
b. Volume of residuals disposed of in the 12-acre lagoon in gallons per day, dry tons per year, or
kilograms per year;
c. Cumulative volume of residuals disposed of in the 12-acre lagoon in gallons or cubic yards;
d. Remaining available volume in the 12-acre lagoon in gallons or cubic yards (i.e., excluding
freeboard); and
e. An estimate of the remaining useful disposal life for the 12-acre lagoon in years (i.e., excluding
freeboard).
[ 15A NCAC 02T .l 111]
9. All records required as part of this permit shall be retained for a minimum of five years. [15A NCAC
02T .0108(b)(1)]
10. Three copies of an annual report shall be submitted on or before March I". The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Reportingf orms.
Instructions for reporting and annual report forms are available at
htt :1/ ortal.nedenr.or we,blw /a s/lau/re ortin , or can be obtained by contacting the Land
Application Unit directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[I5A NCAC 02T .I 111]
WQ0018087 Version 2.0 Shell Version 151201 Page 7 of 9

H. Noncompliance Notification
The Permittee shall report by telephone to the Wilmington Regional Office, telephone number (910)
796-7215, as soon as possible, but in no case more than 24 hours or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Surface disposal of residuals abnormal in quantity or characteristic.
b. Any failure of the surface disposal program resulting in a release of material to surface waters.
c. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
c. Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure that the problem does not recur. [ 15A NCAC 02T .0105(l), 02T .0108(b)(1)]
V. INSPECTIONS
1, The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan. [15A NCAC 02T .0108(b)]
2. Prior to each bulk residuals surface disposal event, the Permittee or his designee shall inspect the
residuals storage, transport and application facilities to prevent malfunctions, facility deterioration and
operator errors resulting in discharges, which may cause the release of wastes to the environment, a
threat to human health or a public nuisance. The Permittee shall maintain an inspection log that
includes, at a minimum, the date and time of inspection, observations made, and any maintenance,
repairs, or corrective actions taken. The Permittee shall maintain this inspection log for a period of five
years from the date of inspection, and this log shall be made available to the Division upon request.
[I 5A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the land application sites or facilities permitted herein
at any reasonable time for the purpose of determining compliance with this permit; may inspect or copy
any records required to be maintained under the terms and conditions of this permit; and may collect
groundwater, surface water or leachate samples. [G.S. 143-215.3(a)(2)]
Vll. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
This pennit shall become voidable if the residuals land application events are not carried out in
accordance with the conditions of this permit. [15A NCAC 02T .0110]
3. This permit is effective only with respect to the nature and volume of residuals described in the permit
application and other supporting documentation. [G.S. 143-215.1 ]
WQ0018087 Version 2.0 Shell Version 151201 Page 8 of 9

The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under the Division's General Permit NCG010000, any requirements pertaining to wetlands under 15A
NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter
143 of the General Statutes. [15A NCAC 02T .0105(c)(6)]
In the event the residuals program changes ownership or the Permittee changes his name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner. [15A NCAC 02T .0104]
6. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T ,0110. [15A NCAC 02T .0110]
7. Unless the Division Director grants a variance, expansion of the permitted residuals program contained
herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b).
[ 15A NCAC 02T .0120]
8. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 22" d day of February 2016
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
.1`).
jz-S. Jay Zimmerman, P.G., Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0018087
WQ0018087 Version 2.0 Shell Version 151201 Page 9 of

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ATTACHMENT A - Approved Residual Sources
DAK Americas, LLC — Cape Fear Manufacturing Facility
Certification Date: February 22, 2016
Permit Number: WQ0018087 Version: 2.0
Approved
Maximum
Monitoring
Monitoring
Mineralization
Owner
Facility Name
ty
County
ty
permit
Biological
Dr Tons
y
Frequency for
Frequency for
Rate
[Raw =0.4;
Number
Residuals
Per Year '
Non -hazardous
Metals and
Aerobic = 0.3;
Characteristics 2
Nutrients _� 4
Anaerobic = 0.2;
Compost = 0. i
DAK Americas, LLC
Cape Fear Site
Brunswick
NCO000663
No
0 6
No Sampling
No Sampling
n/a
Required
Re uired
1. Maximum Dry Tons per Year is the amount of residuals approved for surface disposal from each permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition IV.2.
3. Testing of metals and nutrients as stipulated tender permit Condition IV.3.
C Monitoring frequencies are based on the actual dry tons disposed per year using the table below, unless specified above.
Dry Tons Disposed
short tons per ear
Monitoring Frequency
Established in 40 CFR503 and 15A NCAC 02T .1111
0
No Sampling Re uired
<319
1/Year
—319 - <1,650
l/ Quarter (4 times per year)
—1,650 - <16,500
1/60 Days (6 times per ear
=> 16,500
11month (12 times per year)
5. Industrial By Product residuals are exempt from meeting pathogen & vector attraction reduction requirements, provided they are not mixed with residuals that have been generated during the
treatment of domestic wastewater, the treatment of animal processing wastewater, or the biological treatment of industrial wastewater. The Industrial By Product residuals must be treated and
processed in a manner as to not meet the definition of `Biological Residuals" as defined in 15A NCAC 02T .1102(6).
6. The capacity of the surface disposal unit is 194,000 cubic yards, and approximately 170,000 cubic yards has been utilized.
If no land application events occur during a required sampling period (e.g. no land application occur during an entire year when annual monitoring is required), then no
sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data. Those required to submit the annual
report to EPA may be required to make up the missed sampling, contact the EPA for additional information and clarification.
WQ0018097 Version 2.0 Attachment A Page 1 of I

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ATTACHMENT B - Approved Surface Disposal Sites
DAK Americas, LLC — Cape Fear Manufacturing Facility
Certification Date: February 22, 2016
Permit Number: WQ0018087 Version: 2.0
Field
Owner
Lessee
County
Latitude
Longitude
Net Acreage
Dominant Soil Series
Footnotes
1
DAK Americas, LLC
Brunswick
34.3146220
-78.0343050
12
N/A
l
1. The capacity of the surface disposal unit is 194,000 cubic yards, and approximately 170,000 cubic yards has been utilized.
WQOO18087 Version 2.0 Attachment B Page 1 of 1

THIS ]SAGE BLANK

ATTACHMENT C — Groundwater Monitoring and Limitations
DAK Americas, LLC — Cape Fear Manufacturing Facility
Monitoring wells: MW-2 (2A), MW-2B, MW-2C, MW-2D, MW-2E & MW-03A
Permit dumber: WQ0018087 Version- 2.0
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
PCS Code
Parameter Description
Daily Minimum Daily Maximum
Frequency Measurement
Sample Type
Footnotes
01002
Arsenic, 'total (as Ar)
.01 mg/l
Annually
Grab
1,6
01027
Cadmium, Total (as Cd)
.005 mg/l
Annually
Grab
1,6
00940
Chloride (as Cl)
250 mgA
Annually
Grab
1,6
01034
Chromium, Total (as Cr)
0.05 mg/l
Annually
Grab
1, 6
01037
Cobalt, Total (as Co)
1 me
Annually
Grab
1,6
01042
Copper, Total (as Cu)
1.00 mg/l
Annually
Grab
1,6
01051
Lead, Total (as Pb)
0.015 mg/l
Annually
Grab
1,6
00927
Magnesium, Total (as Mg)
mg/l
Annually
Grab
1,6
71900
Mercury, Total (as Tig)
.001 mg/l
Annually
Grab
1,6
0I067
Nickel, Total (as Ni)
0.10 mg/1
Annually
Grab
1,6
00610
Nitrogen, Ammonia Total (as N)
1.5 mg/l
Annually
Grab
1,6
00620
Nitrogen, Nitrate Total (as N)
10 mg/1
Annually
Grab
1,6
00400
pH
5.50 su
8.50 su
Annually
Grab
1, 6, 7
00665
Phosphorous, Total (as P)
mg/l
Annually
Grab
1,6
01147
Selenium, Total (as Se)
.02 mg/l
Annually
Grab
1,6
70300
Solids, Total Dissolved --180 Deg.0
500 mg/l
Annually
Grab
1,6
GWVOC
Volatile Compounds (GW)
yes/no
Annually
Grab
1, 4, 5, 6
82546
Water level, distance from measuring point
R
Annually
Calculated
1, 2, 3, 6
01092
Zinc, Total (as Zn)
1.00 m911
Annually
Grab
1,6
1. Annual monitoring shall be conducted every December.
2_ The measurement of water levels shall be made prior to purging the wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH shall be made after purging and prior to sampling for the remaining parameters.
3. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point For each monitoring well. The measuring points (top of
casing) of all monitoring wells shall be surveyed relative to a common datum.
WQ0018087 version 2.0 Attachment C Page I of 2

ATTACHMENT tC — Groundwater Monitoring and Limitations
DAK Americas, LLC — Calve Fear Manufacturing Facility
4. Volatile Organic Compounds (VOC) - In December only, analyze by one of the following methods;
a. Standard Method 6230D, PQL at 0.5 µg/L or less
b. Standard Method 621 OD, PQL at 0.5 µg/I, or less
G. EPA Method 8021, Low Concentration, PQL at 0.5 1ig/l. or less
d. EPA Method 8260, Low Concentration, PQL at 0.5 µg/L or less
C. Another method with prior approval by the Water Quality Permitting Section Chief
Permit Number: WQGGIS087 Version: 2.a
Any method used must meet the following qualifications:
a_ A laboratory must be DWQ certified to run any method used.
b. The method used must, at a minimum, include all the constituents listed in Table VIII of Standard Method 6230D.
c. The method used must provide a PQL of 0.5 µg/L or less that must be supported by laboratory proficiency studies as required by the DWQ Laboratory Certification Unit. Any constituents
detected above the MDL but below the PQL of 0.5 µg/L must be qualified (estimated) and reported.
5. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the Wilmington Regional Office supervisor, telephone number (910) 796-72I5,
must be contacted immediately for further instructions regarding any additional follow-up analyses required_
6. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure 2 and this attachment.
7. Per 15A NCAC 02L .0202 (b) (3), a background minimum pH of 5.50 standard units has been established in accordance with historical measurements made in upgradient background
well MW-3A.
WQ0018087 Version 2.0 Attachment C Page 2 of 2

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FIGURE 1
453 DAK AMERICAS, LLC
'`.. J� ! +•" ."` ` 1 CAPE FEAR SITE
_° SURFACE DISPOSAL OF RESIDUAL SOLIDS
BRUNSWICK COUNTY
SITE LOCATION MAP

LEGEND
ED Property Boundary
2003 Groundwater
Contour (interval Is
i; Shown)
fF Existing Monitoring Well
Proposed Monitoring Well
Review Boundary
Proposed Groundwater
Monitoring Network
DAK Americ
Cape Fear
250 600
(This sketch includes comments from WIRO for the suggested
along the compliance boundary- Ref. Staff Report for Site Visis
FIGURE 7
FIGURE 2
DAK AMERICAS, LLC
CAPE FEAR SITE
SURFACE DISPOSAL OF RESIDUAL SOLIDS
BRUNSWICK COUNTY
W00018087
MONITOR WELL LOCATION MAP

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