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WQ0006992_Permit Rescission_20200929
cf- Water Resources Environmental Quality January 26, 2017 W. Scott Snow, P.E. Environmental Engineer Oracle Flexible Packing / LLFlex 220 Polo Road Winston-Salem, NC 27105 Subject: Permit Rescission Permit No. WQ0006992 Non -Discharge Groundwater Remediation Permit Forsyth County Dear Mr. Snow: ROY COOPER Governor MICHAEL S. REGAN Secretarl- S. JAY ZIMMERMAN Director Reference is made to your request for rescission of the subject permit located at 220 E. Polo Road, Winston- Salem, North Carolina. Staff from the Winston-Salem Regional Office has agreed that a permit is no longer required. Therefore, in accordance with your request, Non -Discharge Groundwater Remediation Permit WQ0006992 is rescinded, effective immediately. If in the future, you wish to operate a Non -Discharge Groundwater Remediation system, you must first apply for and receive a new permit. Operating an injection system without a valid permit may result in the assessment of civil penalties and/or the use of other enforcement mechanisms available to the state. If it would be helpful to discuss this matter further. please do not hesitate to call Michael Rogers at (919) 807-6412. Sincerely, L6, J, l 4 Jay Zimmerman, P.G., Director Division of Water Resources cc: Winston-Salem Regional Office - WQROS Central Files - Permit No. WQ0006992 Forsyth County Environmental Health Dept. ''`Nothing Compares::_,. State of North Carolina I Environmental Quality I Division of Water Resources Water Quality Regional operations Section 1636 Mail Service Center I Raleigh, North Carolina 27699-1636 919-707-9129 Non -Discharge Permit Rescission/Closure Report Checklist Permittee/Facility Name: ('�]Lj..,jf- -- Permit No.: WQ Q UO (� Z Reviewer- AL Date: 1. PERMIT INFO Permit issued date: o u ' Expiration date: i p_3 Zj 2. PERMIT RESCISSION REQUEST REC'D FROM PERMITTEE (tabbed w/ post-ito Date Received /0 Letter or Email received from Permittee requesting permit rescission? (Yes or No). Did Request include Reason for Closure? —� (Yes or No). v Did Request include document from oversight agency authorizing closure of permit? (Yes or No). All Annual Fees Paid? v (Yes or No). Did Request include a description of the proposed closure procedure? (Yes or No). Comments: 3. PERMIT RESCISSI N ftEQUEST FORM SENT TO RO (tabbed w/ post-it�_� Date Sent to RO a V1 / Date Received Back fro RO // /S' 6 RO Approved Rescission Request (Yes or No). If no, explain: Comments: .4- AAA 4. CLOSURE ACTIVIT ES PORT (tabbed w/ post -it) Date Received: / o Draft Permit Rescission APPROVAL LETTER Attached? � (Yes or No). Injection Well(s) Was injection well(s) properly abandoned per 15A NCAC 2C .0240? (Yes/No/N/A). If abandoned, Date GW-30(s) received: If ell(s) converted to other purposes, Date Injection Well Status Form Received: Infiltration Gallery Was infiltration Gallery closed such that the gallery was rendered permanently unusable for the disposal or infiltration of treated effluent fluids and will not serve as a source or channel of contamination? _)(Yes/No/N/A). Record of disposal of contaminated soil/materials received? (Yes or No). Evidence provided excavation has no residual contaminated soil? (Yes or No). * Non -Discharge Permit Closure Checklist (1-31-2017) Dates provided for all closure activities? U (Yes or No). Closure Report'complete, accurate, factual, and accurate per person signing report (i.e., sealed)? / (Yes or No). Comments: 5. BIMS Wells Tab reflect GW-1 s/GW-30s (if applicable) have been entered and/or well type and well status modified:_ (Yes or No). If not received, then request from consultant and CC Permittee. After receipt from these parties, enter as -built well construction into BIMS; and well abandonment data or well type and well status, if applicable. 6. AFTER PERMIT RESCISSION APPROVAL LETTER is SIGNED BY SUPERVISOR and PERMIT is OFFICIALLY RESCINDED Date Completion Letter Sent to Permittee plus CCs: Date Permit Rescinded in Events Tab in BIMS: Date copies of all documents are put is permit folder in S Drive and submitted to be filed: FINADpL COMMENTS, if any /L2G aw-t- cjjo.4 L Non-Discharge Permit Closure Checklist (1-31-2017) Rogers, Michael From: Kevin Slaughter <KSlaughter@harthickman.com> Sent: Monday, February 06, 2017 3:34 PM To: Rogers, Michael Cc: Matt Bramblett; Snow, William Scott Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Michael, Thanks again for your assistance with this process Kevin From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Monday, February 06, 2017 3:27 PM To: Kevin Slaughter <KSlaughter@harthickman.com> Cc: Matt Bramblett <MBramblett@harthickman.com>; Snow, William Scott <WilliamScottSnow@oraclepkg.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Please find attached the Permit Rescission Approval Letter. Regards, From: Kevin Slaughter [mailto:KSlaughter@harthickman.com] Sent: Tuesday, January 31, 2017 4:26 PM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Matt Bramblett <MBramblett@harthickman.com>; Snow, William Scott <WiIlia mScottSnow@oraclepkg.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Thanks Michael! From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Tuesday, January 31, 2017 4:25 PM To: Kevin Slaughter <KSlaughter@harthickman.com> Cc: Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 didn't notice that... it's been crazy here today. Disregard the form I sent. I'll change well type in BIMS w/out needing the form. From: Kevin Slaughter [mailto:KSlaughter@harthickman.com] Sent: Tuesday, January 31, 2017 3:59 PM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Michael, That's great news! "Rogers, Michael From: Wang, Shuying Sent: Wednesday, January 25, 2017 9:50 AM To: Rogers, Michael Cc: Knight, Sherri; Wang, Shuying Subject: RE: Termination of Non -Discharge Permit W00006992 - Oracle Flexible Packaging - Plant 604 HI Michael, It will be your decision. I agree with your point-- it is reasonable to assume they only removed 596 tons of contaminated infiltration soil/gravel and piping. However, the report stated: "Once overburden soil above the HDPE liner was scraped to the side and stockpiled, the gallery contents (gravel, distribution piping, liner material, and piezometers) were excavated." Based on this statement, we can assume that at least 4024 cubic yards of washed gravel (based on the dimension/size of the gallery) should have been excavated from the gallery. But why only 596 tons... If these 596 was contaminated, it will be reasonable to ask them to document how did they determine the rest clean. In addition, we need to consider the potential for the permeable fill portion (washed gravel) of the infiltration gallery would retain the ability to be used for infiltration. Therefore, I think that the requirement of .1608(b)(2) can be met by excavating the subsurface permeable fill materials or by covering them with uncontaminated low -permeability material. If the gravel was not removed or backfilled to the pit, an uncontaminated low -permeable layer should apply on the top of permeable gravel. The report only indicated that clean fill dirt was trucked in following removal of the former gallery contents, but did not document what type of dirt was in term of permeability. Thus, I think it is reasonable to ask the additional information to document the closure meeting the requirement. If this is no clear, please let me know. Thank you! Shuying Wang, P.G. Hyd rogeologist Division of Water Resources NC Department of Environmental Quality Winston-Salem Regional Office Phone: (336) 776-9702 Mobile: (336) 403-5429 Fax: (336) 776-9797 Email: Shuying.Wang@ncdenr.gov 450 W Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 http://Portal.ncdenr.org/web/wq �toihing, Compares,—_.,, E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Rogers, Michael Sent: Tuesday, January 24, 2017 2:29 PM To: Wang, Shuying <shuying.wang@ncdenr.gov> Cc: Knight, Sherri <sherri.knight@ncdenr.gov> Subject: RE: Termination of Non -Discharge Permit WQ0006992 - Oracle Flexible Packaging - Plant 604 S- I got the hard copy of the closure report and reviewed. I have the following comments to your email: In regards to Item 1- It's reasonable to assume they only removed 596 tons of contaminated infiltration soil/gravel and piping. In regards to Item 2- The rule only states they need to close the gallery so it can't be used as an infiltration gallery anymore and is not a channel for contamination. The have met the requirements by removing (or plugging) all subsurface gravel and materials, and filling the gallery excavation with clean fill/soil and compacted to grade. Therefore, I think they complied per closure requirements per 2T .1608 (attached). Do you agree? Thanks, From: Wang, Shuying Sent: Monday, January 09, 2017 10:00 AM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Knight, Sherri <sherri.knight@ncdenr.gov> Subject: RE: Termination of Non -Discharge Permit WQ0006992 - Oracle Flexible Packaging - Plant 604 Good morning Michael! Not sure what level of review do you need from me. A very brief reading indicates a couple of things we may want to be clarified: 1. The report indicates that the abandoned infiltration gallery were approximately 106 ft long, 17 ft wide and 9.5 ft deep. The report also indicates that the gallery consisted of approximately 7 ft of washed gravel, which should be approximately 12614 cubic feet (106 ft x 17ft x 7 ft) or 4204 cubic yards. However, only approximately 595.7 tons of material were removed from site and trucked to EVO's facility for treatment and disposal. We would like to know why only such a small amount or volume was excavated from the pit and were removed from the site for treatment. We understand if the material is not contaminated, it does not have to be removed from the site for treatment. 2. The report also indicates that following removal of the former gallery contents, clean fill dirt was trucked in, spread and compacted within the gallery excavation area to within approximately 1.5 ft of land surface. I think that we need to ask for describing what type of material the clean fill dirt is in term of clay, silt, sand, or mix and where the dirt they got from just for documenting purpose. If you need me to review the report further, please let me know. Thank you! Shuying Wang, P.G. Nydrogeologist Division of Water Resources NC Department of Environmental Quality Winston-Salem Regional Office Phone: (336) 776-9702 `Mobile: (336) 403-5429 Fax: (336) 776-9797 Email: Shuying.Wane@ncdenr.eov 450 W Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 http://Portal.ncdenr.org/web/wq mr_"'"%4%thing, Compares,-«, - E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Kevin Slaughter [mailto:KSlaughter@harthickman.com] Sent: Friday, January 06, 2017 3:53 PM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Qi, Qu <gu.gi@ncdenr.gov>; Wang, Shuying <shuying.wangncdenr.gov>; Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com> Subject: Termination of Non -Discharge Permit WQ0006992 - Oracle Flexible Packaging - Plant 604 Michael, Please find the attached report for the above site in PDF format. A hard copy is also being sent to your attention by mail. If you have any questions or comments, please let us know. Thanks, Kevin J. Kevin Slaughter, Senior Environmental Scientist Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 Direct 704-887-4615 Mobile 980-613-9198 1 Main 704-586-0007 www.harthickman.com hart hickman s++.�MCX«wva�;w�.+��caxs svtut�ss Permit Rescission Request Form Information to be filled out by Central Office CE'VED!NCDF0T Permit No.: WQ0006992 NOV 1 5 2016 Permittee: Oracle Flexible, LLC 'later Quality Regions Facility Name: Plant 604 Regional Office: Winston-Salem County: Forsyth Date Rescission Requested: 10/24/2016 via email attached Received Original Request: ❑ Central Office = Regional Office Form of Received Request: 0 Letter/Email = Signed Annual Fee Invoice = Other form Annual Fees Paid to Date: Yes Information to be filled out by Regional Office Please Check Appropr' tely: OrSite Visit Performed Recommendations (check one block below): ❑ Rescind Pen -nit Immediately Reason for Approval ❑ Groundwater Concerns Addressed S Y�vi� ❑ Require Renewal with Suspended Actions Recommended Actions to be Taken ❑ Do Not Rescind/Recommend Renewal Reason for Denial Signature of RO Certifier (WQROS Section): Aq Typed or Printed Name of RO Certifier: l�JLf a;;i Date Certified: Return Completed an Signed Form to the WQROS Section. Thanks. Page 2 of 2 Rogers, Michael From: Rogers, Michael Sent: Thursday, November 10, 2016 1:07 PM To: 'Kevin Slaughter'; Wang, Shuying Cc: Knight, Sherri; Snow, William Scott; Matt Bramblett Subject: RE: Oracle Non -Discharge Permit - W00006992 Your welcome sir, and happy holidays. From: Kevin Slaughter [mailto:KSlaughter@harthickman.com] Sent: Thursday, November 10, 2016 12:49 PM To: Wang, Shuying <shuying.wang@ncdenr.gov>; Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Knight, Sherri <sherri.knight@ncdenr.gov>; Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Shuying and Michael, Thank you for your guidance on this project. Tentatively, the abandonment activities look like it will take place during the first half of December. As requested, documentation of the gallery abandonment (including photographs) will be provided following completion of field activities so the permit can be closed out. Thanks again, Kevin From: Wang, Shuying [mailto:shuying.wang@ncdenr.gov] Sent: Thursday, November 10, 2016 11:49 AM To: Kevin Slaughter <KSlaughter@harthickman.com> Cc: Rogers, Michael <michael.rogers@ncdenr.gov>; Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.gov> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Hi Kevin, Based on what you described, I do not think that any damages to the piping will result in a groundwater issue. So I do not have any objection to what you proposed to do with it. It may be only a facility safety concern. If it is a large diameter pipe and buried very shallow, once it is exposed to the surface and damaged, something or someone may be hurt or damaged. Since we do not have clear guidance for closing such piping, it will be your and the permittee's decision. Thanks for answer my questions! Shuying Wang, P.G. Hydrogeologist Division of Water Resources NC Department of Environmental Quality Winston-Salem Regional Office Phone: (336) 776-9702 Mobile: (336) 403-5429 Fax: (336) 776-9797 Email: Shuying.WangC@ncdenr.gov 450 W Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 http://porta1.ncdenr.org/web/wq Nothing Compares-,-,-, E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Kevin Slaughter[mailto:KSlaughter@harthickman.com] Sent: Thursday, November 10, 2016 11:24 AM To: Wang, Shuying <shuying.wang@ncdenr.gov> Cc: Rogers, Michael <michael.rogers@ncdenr.gov>; Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Hi Shuying, Atthough there are several documents related to the proposed system construction, no "As -Built" drawings related to piping installation have been located to date. Water discharge lines from the recovery wells to the former pump and treat system appear to be approximately 1.5" in diameter based on visual inspections inside recovery well vaults. Proposed system drawings indicate that the treated water transfer line from the remediation system to the infiltration gallery is 2" PVC piping which terminates with 4" perforated PVC piping within the infiltration galleries (which will be excavated and removed during abandonment activities). The transfer piping depth below land surface is unknown. Water discharge piping appears to exit vaults at approximately 2' below land surface, but it is unknown if piping maintains this depth, or drops to a deeper depth. System discharge piping depth to infiltration galleries is also unknown although it almost certainly deeper where it passes underneath the railroad spur line. I hope this helps, Kevin From: Wang, Shuying[mailto:shuying.wang@ncdenr.gov] Sent: Thursday, November 10, 2016 10:36 AM To: Kevin Slaughter <KSlaughter@harthickman.com>; Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Hi Kevin, Do you know what the diameter of the piping is and how deep it is from the surface? Thank you! Shuying Wang, P.G. Hydrogeologist Division of Water Resources NC Department of Environmental Quality Winston-Salem Regional Office Phone: (336) 776-9702 Mobile: (336) 403-5429 Fax: (336) 776-9797 Email: Shuying.Wang@ncdenr.gov 450 W Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 http://porta1.ncdenr.org/web/wq E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Kevin Slaughter[mailto:KSlaughter@harthickman.comJ Sent: Thursday, November 10, 2016 10:25 AM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Wang, Shuying <shuying.wang@ncdenr.gov>; Snow, William Scott<WilliamScottSnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Michael, As suggested, H&H originally considered pressure grouting the transfer piping from the recovery wells to the remediation system, and from the remediation system to the infiltration galleries. However, due to the lack of impacts in the system inlet and discharge water, the length of piping involved (estimated 2,000-3,000 ft), and the transfer line to the infiltration galleries passing under a rail road spur (would most likely require a permit from railroad to inject pressurized grout under rail line), H&H came to the conclusion that cutting off the transfer piping at both ends and gluing a PVC cap over each end should be sufficient. Based on your recommendations, H&H proposes that in addition to the originally proposed abandonment method, the end of each transfer line be filled with a hydraulic cement plug (a minimum of 10 times the piping diameter) prior to the PVC cap being glued on. The hydraulic cement plug will act as a second layer of protection if the PVC cap were to ever fail or end of piping were broken off. As stated in the closure plan, H&H's contractors would remove and dispose of all piping located within the infiltration galleries. Please let me know if this is acceptable for the reasons given above. Thanks, • Kevin From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Wednesday, November 09, 2016 1:37 PM To: Kevin Slaughter <KSlaughter@harthickman.com> Cc: Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com>; Wang, Shuying <shuying.wang@ncdenr.gov> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 You may proceed with closure. However, Ms. Wang recommends the treatment system piping below the grade be filled with slurry if possible, instead of just capped. Please provide documentation/photographs of the closure. After receipt we will close out the permit. Thanks From: Kevin Slaughter[mailto:KSlaughter@harthickman.com] Sent: Wednesday, November 09, 2016 10:10 AM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Oracle Non -Discharge Permit - WQ0006992 Michael, I hope you have been doing well. I wanted to check on the approval process for closure of Non -Discharge Permit WQ0006992. H&H would like to start closure work before winter sets in but is holding off contractor scheduling pending final closure permit approval. If you have an estimated approval date, I would greatly appreciate it so I can begin the scheduling process. Please let me know if you have any additional questions. Thanks again, Kevin From: Rogers, Michael[maifto:michael.rogers@ncdenr.gov] Sent: Thursday, October 27, 2016 9:45 AM To: Snow, William Scott <WilliamScottSnow@oraclepkg.com> Cc: Qi, Qu <qu.gi@ncdenr.gov>; Kevin Slaughter <KSlaughter@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.gov>; Wang, Shuying <shuving.wang@ncdenr.gov>; Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Closure of Non -Discharge Permit - Oracle WQ0006992 OK, thanks. From: Snow, William Scott [maifto:WilliamScottSnow@oraclepkg.com] Sent: Monday, October 24, 2016 4:39 PM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Qi, Qu <qu.gi@ncdenr.gov>; Kevin Slaughter <KSlaughter@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.gov>; Wang, Shuying <shuying.wang@ncdenr.gov>; Matt Bramblett <MBramblett@harthickman.com> Subject: Closure of Non -Discharge Permit - Oracle WQ0006992 4 Michael, Please accept this note as an official permit closure request for Oracle Flexible Packaging, 220 Polo Road, in Winston-Salem, NC (Non -Discharge Permit WQ0006992). Oracle will implement the Work Plan submitted by Hart & Hickman to permanently close the infiltration gallery and convert the existing pump and treat recovery wells into monitoring wells. These wells, in conjunction with, the existing monitoring wells will be maintained per Subchapter 2C until conditions warrant their permanent abandonment. Also, please note that the current permit fee invoice is in the process of being paid and should be received by your office on or before November 4cn If you have any questions or need additional information pertaining to this request, please contact me at your earliest convenience. Best Regards, W. Scott Snow, P.E. Environmental Engineer Oracle Flexible Packaging / LLFlex 220 Polo Road Winston-Salem, NC 27105 (336) 777-5878 (office) (336) 829-9538 (mobile) From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Thursday, October 20, 2016 10:06 AM To: Matt Bramblett Cc: Qi, Qu; Snow, William Scott; Kevin Slaughter; Knight, Sherri; Wang, Shuying Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle WQ0006992 The plan looks good. However, We need the following additional 2 items addressed to move forward: The annual fees of $1310 needs to be paid. We need a letter or email from Oracle requesting the permit be rescinded. Thanks From: Matt Bramblett imailto:MBramblett@harthickman.com Sent: Thursday, October 20, 2016 9:13 AM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Qi, Qu <gu.gi@ncdenr.gov>; Snow, William Scott<WilliamScottSnowCp@oraclepkg.com>; Kevin Slaughter <KSlaughter@harthickman.com>; Knight, Sherri <sherri.kniRht@ncdenr.Rov>; Wang, Shuying <shuYing.wang@ncdenr.gov> Subject: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle Michael, Please find the attached work plan for the above site for your review. With your approval, we will schedule the work right away. If you have any questions, please let me know. Thanks, Matt Matt Bramblett, PE, Principal Hart & Hickman, PC 12923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 Direct 704-887-4620 1 Mobile 704-560-8009 1 Main 704-586-0007 www.harthickman.com hart hickman Rogers, Michael w 61 �c e� . Sod 4v So &-Ae K L-,/ From: Kevin Slaughter <KSlaughter@harthickman.com> Sent: Wednesday, November 09, 2016 10:10 AM To: Rogers, Michael Cc: Snow, William Scott; Matt Bramblett Subject: RE: Oracle Non -Discharge Permit - W00006992 Michael, I hope you have been doing well. I wanted to check on the approval process for closure of Non -Discharge Permit WQ0006992. H&H would like to start closure work before winter sets in but is holding off contractor scheduling pending final closure permit approval. If you have an estimated approval date, I would greatly appreciate it so I can begin the scheduling process. Please let me know if you have any additional questions. Thanks again, Kevin From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Thursday, October 27, 2016 9:45 AM To: Snow, William Scott <WilliamScottSnow@oraclepkg.com> Cc: Qi, Qu <qu.gi@ncdenr.gov>; Kevin Slaughter <KSlaughter@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.gov>; Wang, Shuying <shuying.wang@ncdenr.gov>; Matt Bramblett <MBramblett@harthickman.com> Subject: RE: Closure of Non -Discharge Permit - Oracle WQ0006992 OK, thanks. From: Snow, William Scott [mailto:WilliamScottSnow@oraclepkg.com] Sent: Monday, October 24, 2016 4:39 PM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Qi, Qu <gu.gi@ncdenr.gov>; Kevin Slaughter<KSlaughter@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.gov>; Wang, Shuying <shuying.wang@ncdenr.gov>; Matt Bramblett <MBra mblett@harthickman.com> Subject: Closure of Non -Discharge Permit - Oracle WQ0006992 Michael, Please accept this note as an official permit closure request for Oracle Flexible Packaging, 220 Polo Road, in Winston-Salem, NC (Non -Discharge Permit WQ0006992). Oracle will implement the Work Plan submitted by Hart & Hickman to permanently close the infiltration gallery and convert the existing pump and treat recovery wells into monitoring wells. These wells, in conjunction with, the existing monitoring wells will be maintained per Subchapter 2C until conditions warrant their permanent abandonment. Also, please note that the current permit fee invoice is in the process of being paid and should be received by your office on or before November 41n If you have any questions or need additional information pertaining to this request, please contact me at your earliest convenience. Best Regards, W. Scott Snow, P.E. Environmental Engineer Oracle Flexible Packaging / LLFIex 220 Polo Road Winston-Salem, NC 27105 (336) 777-5878 (office) (336) 829-9538 (mobile) From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Thursday, October 20, 2016 10:06 AM To: Matt Bramblett Cc: Qi, Qu; Snow, William Scott; Kevin Slaughter; Knight, Sherri; Wang, Shuying Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle WQ0006992 The plan looks good. However, We need the following additional 2 items addressed to move forward: The annual fees of $1310 needs to be paid. We need a letter or email from Oracle requesting the permit be rescinded. Thanks. From: Matt Bramblett [mailto:MBramblett@harthickman.com] Sent: Thursday, October 20, 2016 9:13 AM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Qi, Qu <gu.gi@ncdenr.gov>; Snow, William Scott<WilliamScottSnow@oraclepkg.com>; Kevin Slaughter <KSlaughter@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.gov>; Wang, Shuying <shuying.wang@ncdenr.gov> Subject: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle Michael, Please find the attached work plan for the above site for your review. With your approval, we will schedule the work right away. If you have any questions, please let me know. Thanks, Matt Matt Bramblett, PE, Principal Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 Direct 704-887-4620 Mobile 704-560-8009 1 Main 704-586-0007 www.harthickman.com hart hickfT an WAf'+�F x. v.','±s::stiEk€aa"A.:: SAt UTi"M'S Rogers, Michael From: Snow, William Scott <WilliamScottSnow@oraclepkg.com> Sent: Monday, October 24, 2016 4:39 PM To: Rogers, Michael Cc: Qi, Qu; Kevin Slaughter; Knight, Sherri; Wang, Shuying; Matt Bramblett Subject: Closure of Non -Discharge Permit - Oracle W00006992 Michael, Please accept this note as an official permit closure request for Oracle Flexible Packaging, 220 Polo Road, in Winston-Salem, NC (Non -Discharge Permit WQ0006992). Oracle will implement the Work Plan submitted by Hart & Hickman to permanently close the infiltration gallery and convert the existing pump and treat recovery wells into monitoring wells. These wells, in conjunction with, the existing monitoring wells will be maintained per Subchapter 2C until conditions warrant their permanent abandonment. Also, please note that the current permit fee invoice is in the process of being paid and should be received by your office on or before November 0 If you have any questions or need additional information pertaining to this request, please contact me at your earliest convenience. Best Regards, W. Scott Snow, P.E. Environmental Engineer Oracle Flexible Packaging / LLFlex 220 Polo Road Winston-Salem, NC 27105 (336) 777-5878 (office) (336) 829-9538 (mobile) From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Thursday, October 20, 2016 10:06 AM To: Matt Bramblett Cc: Qi, Qu; Snow, William Scott; Kevin Slaughter; Knight, Sherri; Wang, Shuying Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle WQ0006992 The plan looks good. However, We need the following additional 2 items addressed to move forward: The annual fees of $1310 needs to be paid. We need a letter or email from Oracle requesting the permit be rescinded. Thanks From: Matt Bramblett [mailto:MBramblett@harthickman.com] Sent: Thursday, October 20, 2016 9:13 AM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Qi, Qu <qu.gi ncdenr.gov>; Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Kevin Slaughter <KSlaughter@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.eov>; Wang, Shuying <shuying.wang@ncdenr.gov> Subject: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle Michael, Please find the attached work plan for the above site for your review. With your approval, we will schedule the work right away. If you have any questions, please let me know. Thanks, Matt Matt Bramblett, PE, Principal Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 Direct 704-887-4620 Mobile 704-560-8009 1 Main 704-586-0007 www.harthickman.com hart 0 hlckman Rogers, Michael From: Wang, Shuying Sent: Monday, January 30, 2017 4:32 PM To: Rogers, Michael Cc: Wang, Shuying; Knight, Sherri Subject: FW: Oracle IHSB Site# NCD067441394 See below. Shuying E-mail correspondence to and from this address may be subject to the North Carolina Public Records Caw and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Qi, Qu Sent: Thursday, October 09, 2014 12:20 PM To: Snow, William Scott <scottsnow@oraclepkg.com> Cc: Wang, Shuying <shuying.wang@ncdenr.gov>; Knight, Sherri <sherri.knight@ncdenr.gov>; Slusser, Thomas <thomas.slusser@ncdenr.gov>; Speer, David <DavidSpeer@oraclepkg.com>; Pierce, Gregory <gregpierce@oraclepkg.com>; Ware, Bonnie <bonnie.ware@ncdenr.gov>; Day, Collin <collin.day@ncdenr.gov> Subject: RE: Oracle IHSB Site# NCD067441394 Mr. Snow: A quick file review shows that the site was determined to be REC eligible and you were recommended to participate in the REC program in 2008. Based on our records you did not choose to participate and therefore, your site's status is "independent remediation without State's supervision". We have not received any documents or lab results and a thorough review of the site is not possible. However, based on the information you provided in this e-mail, the Inactive Hazardous Site Branch does not have any objections to rescind the Groundwater Remediation Permit (WQ0006992). Contact me if you have any questions or want to discuss the status of your site further. as PG Inactive Hazardous Sites Branch Superfund Section Division of Waste Management qu.gi@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records taw and may be disclosed to third parties unless the content is exempt by statute or other regulation. My phone/fax number is (919) 707-8213 Street address: Green Square Complex DENR Office Building 217 W Jones Street, Raleigh, NC 27603 Mailing address: 1646 Mail Service Center, Raleigh, NC 27699 From: Snow, William Scott [mailto:scottsnow(�i)oraclepkg.com] Sent: Wednesday, October 08, 2014 4:14 PM To: Ware, Bonnie Cc: Qi, Qu; Wang, Shuying; Knight, Sherri; Slusser, Thomas; Speer, David; Pierce, Gregory Subject: Oracle IHSB Site# NCD067441394 1 Oracle Flexible Packaging (OFP) 220 Polo Road Winston-Salem, NC 27105 IHSB Site# NCD067441394 DWR Groundwater Permit WQ0006992 Hi Bonnie, OFP is exploring a permit closure request to the NC Division of Water Resources (DWR) for a pump and treat Air Stripper GW remediation system (GW Permit WQ0006992) at our Polo Road site in Winston-Salem. One qualification for this request is to obtain a letter from the oversight agency (DWM - IHSB) authorizing shutdown of the remediation system. Therefore, the purpose of this email is to provide background information and discussion of OFP's intent. Please keep in mind, this is not a request for site closure or a NFA letter, only to rescind the GW system permit. I refer you to Section III of the attached DWR permit (GW Permit — Polo Rd 2016.pdf) which contains quarterly GW system monitoring requirements. Quarterly and annual monitoring well sampling requirements are outlined in a separate DWR letter (DENR Monitoring Letter 1997.pdf). Note the site map (GW Map — Polo Road IHSB) included for reference. Also attached is the temporary GW system shutdown notification letter from June 2010 (Shutdown Notice 22Jun10.pdf) which describes the lack of target organic detection in monitoring wells and system influent for several years prior to shutdown. Since July 2010, OFP has continued to conduct this monitoring in order to eliminate the concern of bounce back. The attached spreadsheet (MW's 604 IHSB.xlsx) shows that no target compounds have been measured above 2L standards or vapor intrusion groundwater screening levels (GWSL). Acetone, detected in MW-14 in April 2011 and 2012, was at a level 250 times below the 2L standard and several orders of magnitude lower than GWSL. Since over four years has passed since temporary shutdown, OFP respectfully requests a letter or email authorizing permanent GW remediation system shutdown. It is my understanding that permit rescission would relieve all DWR- mandated monitoring requirements, however, OFP is willing to continue monitoring if so requested by DWM. In addition, should future remediation of the site be required, OFP anticipates that an alternative method of treatment would be utilized. Please let me know if you have questions or need additional information, or if you would like to meet at the site to discuss this request. I sincerely appreciate your time and consideration of this matter and look forward to hearing from you. Regards, W. Scott Snow, P.E. Environmental Engineer Oracle Flexible Packaging / LLFIex 220 Polo Road Winston-Salem, NC 27105 (336) 777-5878 (office) (336) 829-9538 (mobile) hart hickman SMARTER ENVIRONMENTAL SOLUTIONS Via Email October 20, 2016 NC DEQ DWR Water Quality Regional Operation Section (WQRPS), Groundwater Protection Branch — UIC Program Manager 1636 Mail Service Center, Raleigh, NC 27699 Attention: Mr. Michael Rogers Re: Termination of Non -Discharge Permit WQ0006992 Oracle Flexible Packaging / LLFIex, Plant #604 220 E. Polo Rd. Winston-Salem, NC 27105 IHSB Site #NCD067441394 H&H Job No. ORA-013 Dear Mr. Rogers: On behalf of Oracle Flexible Packaging / LLFIex (Oracle), Hart & Hickman, PC (H&H) is providing this Work Plan to terminate Non -Discharge Permit WQ0006992. The non -discharge permit is associated with a groundwater pump and treat system located at 220 E. Polo Rd. in Winston-Salem, Forsyth County, North Carolina. A site location map and a site plan are included as Figures 1 and 2, respectively. As outlined in 15A NCAC 02T .1608 of the Division of Water Quality North Carolina Administrative Code, Oracle is seeking to terminate Non -Discharge Permit WQ0006992 which will expire on October 31, 2016. The former pump and treat system consisted of eleven groundwater recovery wells, an air stripping treatment system, and an infiltration gallery for on - site injection of treated groundwater. 2923 South Tryon Street, Suite 100 I 3334 Hillsborough Street Charlotte, NC28203 Raleigh, NC 27607 www.harthickman.corn 704.586.0007 main 919.847.4241 main Mr. Michael Rodgers October 20, 2016 Page 2 Operation of the pump and treat system started in the late 1980s. The system was shut down in July 2010 following several years of no measurable impacts in the treatment system influent and low to non -detect groundwater concentrations in the system treatment area. During the last six years of monitoring, there has been no significant rebound of groundwater constituents in site monitoring wells being sampled. For this reason, Oracle has made the decision not to renew its non -discharge permit. As required by the administrative code, attached is an email from Mr. Qu Qi with the Inactive Hazardous Sites Branch (IHSB) stating that IHSB has no objection with rescinding groundwater remediation permit WQ0006992. Oracle intends on converting the former recovery wells into groundwater monitoring wells. This will be accomplished by removing the submersible pumps, electric cables, and discharge piping from each recovery well. In addition, electric lines and groundwater recovery piping will be cut off and capped within each vault. Following removal of the recovery well pumps and down well piping, each monitoring well will be sealed with a lockable expansion plug and the 2-ft x 2-ft steel vault lid will be re -secured with bolts. Groundwater recovery piping entering the above ground air stripping treatment system and the treated water discharge line to the infiltration gallery area will be cut off and capped at the former treatment system location. In addition, power to the system will be permanently disconnected by a licensed electrician. For closure of the infiltration gallery trenches, Oracle will subcontract for the excavation of the infiltration gallery gravel materials. An impermeable liner currently separates l to 2 ft of overburden soil from the gravel located within the gallery trenches. This overburden soil will be scrapped off and stockpiled for reuse. Infiltration gallery gravel and PVC distribution piping located within the trenches will then be excavated for off -site disposal at a facility permitted to accept such materials. Treatment system discharge piping and electrical level sensor wiring will be cut off where it enters the galleries, and the treatment system piping will be permanently capped below grade. S-\AAA-Masser Prujpcts\0rac1e\0RA-013 Polo Road In6ltrawn CmIlery Closur6Work Plm.doc hart hiekman WARTFF. AlSOLUT)ONS Mr. Michael Rodgers October 20, 2016 Page 3 Once the former gallery material has been removed, clean fill will be imported from off -site, placed in the trenches, and compacted in lifts. The upper 1 to 2 feet of gallery fill material will be composed of overburden soil previously stockpiled. The trenches will be filled slightly above land surface to avoid stormwater accumulation. Disturbed areas will be covered with grass seed and straw. On Oracles behalf, within 30 day of system closure, H&H will submit a letter report describing the completed closure procedures. The report will include a certification that the closure was accomplished in accordance with this work plan and that the information submitted is complete, factual and accurate. We look forward to your review and approval of this work plan. If you have any questions, please do not hesitate to contact us. Sincerely, Hart & Hickman, PC J. Kevin Slaughter Senior Environmental Scientist MVB/vmg Enclosures I,it!!I//// CAPO,�fri, o� �� .• `ESS I © 2 ��i Q " SEAL 25069 /rill it, Matt Bramblett Principal and Project Manager cc: Scott Snow, Oracle (PDF by Email and Hard Copy by Mail) Sherri Knight, Division of Water Resources (PDF by Email) Qu Qi, Inactive Hazardous Sites Branch (PDF by Email) S::AAA-Master Projead'vOnclehORA-013 Polo Road lnfihntio . Gallen Ciosim%Wcttk Plan doc hart � hickman SMARTER ENVIMONMEN?AL SOLUTIONS From: Qi, Qu <qu.gi@ncdenr.gov> Sent: Thursday, October 09, 2014 12:20 PM To: Snow, William Scott Cc: Wang, Shuying; Knight, Sherri; Slusser, Thomas; Speer, David; Pierce, Gregory; Ware, Bonnie; Day, Collin Subject: RE: Oracle IHSB Site# NCD067441394 Mr. Snow: A quick file review shows that the site was determined to be REC eligible and you were recommended to participate in the REC program in 2008. Based on our records you did not choose to participate and therefore, your site's status is "independent remediation without State's supervision". We have not received any documents or lab results and a thorough review of the site is not possible. However, based on the information you provided in this e-mail, the Inactive Hazardous Site Branch does not have any objections to rescind the Groundwater Remediation Permit (WQ0006992). Contact me if you have any questions or want to discuss the status of your site further. Qu Qi, PG Inactive Hazardous Sites Branch Superfund Section Division of Waste Management qu.gi@ncdenr.gov Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. My phone/fax number is (919) 707-8213 Street address: Green Square Complex DENR Office Building 217 W Jones Street, Raleigh, NC 27603 Mailing address: 1646 Mail Service Center, Raleigh, NC 27699 From: Snow, William Scott[mailto:scottsnow@oraclepkg.com] Sent: Wednesday, October 08, 2014 4:14 PM To: Ware, Bonnie Cc: Qi, Qu; Wang, Shuying; Knight, Sherri; Slusser, Thomas; Speer, David; Pierce, Gregory Subject: Oracle IHSB Site# NCD067441394 Oracle Flexible Packaging (OFP) 220 Polo Road Winston-Salem, NC 27105 IHSB Site# NCD067441394 DWR Groundwater Permit WQ0006992 Hi Bonnie, OFP is exploring a permit closure request to the NC Division of Water Resources (DWR) for a pump and treat Air Stripper GW rerr►ediation system (GW Permit WQ0006992) at our Polo Road site in Winston-Salem. One qualification for this request is to obtain a letter from the oversight agency (DWM - IHSB) authorizing shutdown of the remediation tic �1 jars...'. � � f ; � "`�.�. _ �� ,, •'L ,... 1'= �F � �` r �:-.l✓,f• d Ll iii �s..a,•, `,_ � s� l:r� ..�j � �' i� � � „�} o t F � ��' ri mot' J '^ � ..✓ �: R i>•� „�_._� .' tt � � • " � ir,,.` ` �t �y''� � t t.� �,1{ ,. ,.,y � _ y t''� . �. � ?`"f+ .`�-.�l�.�j' :`�`�t G .`y r ti - � f -.. �-II•�j� f�^vr� y .. � ��, �,.,, '' - �\ -'�l.l jI N NZ t""'� X r ` .'.<� � _ �^�, ��. y�l ,�i'� �.,.— ti`v i , � r�.� � S � !',A1 � !� 1� •lY� ja .i. sy,' y.=✓ r �L. ;� ° lY! :i rl �3 � �, rr. .'ram. t, - l � s� ^•�}.S� 4f•(k st. %1 G.'' s..i �jF, rf ;., i •j �i r -t M " a ti �- C • l r ;r l- APPROXIMATE TITLE N 0 2000 4000 SITE LOCATION MAP SCALE IN FEET PROJECT ORACLE FLEXIBLE PACKAGING, INC. 220 POLO ROAD WINSTON-SALEM, NORTH CAROLINA U.S.G.S. QUADRANGLE MAP hart hickman 29235mrhTnonStreer-SuitelOC Chadone, North Carolina 28203 RURAL HALL, NORTH CAROLINA 1994 wa say uar (P) qua sswo�;s fie, `.4ARTER ENVIRONMENTAL SOLUT10N5 DATE 10-20-16 REVISION NO: 0 QUADRANGLE 7.5 MINUTE SERIES (TOPOGRAPHIC) JOB NO ORA-013 FIGURE: 1 Rogers, Michael From: Matt Bramblett <MBramblett@harthickman.com> Sent: Thursday, October 20, 2016 3:38 PM To: Rogers, Michael Cc: Qi, Qu; Snow, William Scott; Kevin Slaughter; Knight, Sherri; Wang, Shuying Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle W00006992 Michael, Per your voice message question regarding monitoring wells, Oracle is planning to keep and maintain the existing monitoring well network and the recover well conversions for future groundwater monitoring purposes. Therefore, we are not planning to abandon any wells as part of this phase of work. If you have any further questions, please let me know. Thanks, Matt From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Thursday, October 20, 2016 10:06 AM To: Matt Bramblett <MBramblett@harthickman.com> Cc: Qi, Qu <qu.gi@ncdenr.gov>; Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Kevin Slaughter <KSlaughter@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.gov>; Wang, Shuying <shuying.wang@ncdenr.gov> Subject: RE: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle WQ0006992 The plan looks good. However, We need the following additional 2 items addressed to move forward: The annual fees of $1310 needs to be paid. We need a letter or email from Oracle requesting the permit be rescinded. Thanks From: Matt Bramblett [ma ilto:MBra mblett@harthickman.com] Sent: Thursday, October 20, 2016 9:13 AM To: Rogers, Michael <michael.rogers@ncdenr.gov> Cc: Qi, Qu <gu.gi@ncdenr.gov>; Snow, William Scott <WilliamScottSnow@oraclepkg.com>; Kevin Slaughter <KSlaughter@harthickman.com>; Knight, Sherri <sherri.knight@ncdenr.gov>; Wang, Shuying <shuying.wang@ncdenr.gov> Subject: Work Plan - Infiltration Gallery Closure for Termination of Non -Discharge Permit - Oracle Michael, Please find the attached work plan for the above site for your review. With your approval, we will schedule the work right away. If you have any questions, please let me know. Thanks, Matt Matt Bramblett, PE, Principal Hart & Hickman, PC 12923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 Direct 704-887-4620 1 Mobile 704-560-8009 1 Main 704-586-0007 www.harthickman.com 14 hart hickman Rogers, Michael From: Rogers, Michael Sent: Tuesday, October 18, 2016 10:05 AM To: Wang, Shuying; Kevin Slaughter Cc: Knight, Sherri Subject: RE: Termination of Non -Discharge Permit W00006992 (Oracle) I was looking at our BIMS database and there is an annual fee of $1310 due on November 6. This will need to be paid before closing out the permit. Our Budget office contact person contact info is below. Teresa. Revis(@ncdenr. cov NCDENR/DWR Budget Office 6`1 Floor 1617 Mail Service Center Raleigh NC 27699-1617 919 807 6316 (TEL) 919 807 6490 (FAX) From: Wang, Shuying Sent: Tuesday, October 18, 2016 9:15 AM To: Kevin Slaughter <KSlaughter@harthickman.com> Cc: Knight, Sherri <sherri.knight@ncdenr.gov>; Rogers, Michael <michael.rogers@ncdenr.gov> Subject: RE: Termination of Non -Discharge Permit WQ0006992 (Oracle) Hi Kevin, It sounds about right. Sorry for late response! Shuying Wang, P.G. Hydrogeologist Division of Water Resources NC Department of Environmental Quality Winston-Salem Regional Office Phone: (336) 776-9702 Mobile: (336) 403-5429 Fax: (336) 776-9797 Email: Shuying.Wang@ncdenr.gov 450 W Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 http://portal.ncdenr.org/web/wq '--`Nothing Compares --�. E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Knight, Sherri Sent: Wednesday, October 12, 2016 5:00 PM To: Wang, Shuying <shuying.wang@ncdenr.gov> Subject: Fwd: Termination of Non -Discharge Permit WQ0006992 (Oracle) Sent from my iPhone Begin forwarded message: From: Kevin Slaughter <KSlaughter@harthickman.com> Date: October 12, 2016 at 10:34:42 AM EDT To: "Knight, Sherri" <sherri.knight@ncdenr.gov> Subject: Termination of Non -Discharge Permit WQ0006992 (Oracle) Sherri, I hope you have been doing well. H&H is preparing a work plan to terminate the Non -Discharge Permit above (for 220 Polo Rd) and I want to make sure everyone relevant gets copied. Original is going to Mike Rodgers, and plan on copying yourself, and Qu Qi. Is this sufficient, or am I leaving anyone out? Thanks for your assistance! Kevin J. Kevin Slaughter, Senior Environmental Scientist Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 Direct 704-887-4615 Mobile 980-613-9198 1 Main 704-586-0007 www.harthickman.com Id hart hiCkman Rogers, Michael From: Kevin Slaughter <KSlaughter@harthickman.com> Sent: Friday, October 07, 2016 9:58 AM To: Rogers, Michael ©fl- G Cc: Matt Bramblett Subject: RE: Infiltration Gallery Abandonment Requirements WO0006992 Thanks Michael, Have a great weekend! From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Friday, October 07, 2016 9:47 AM To: Kevin Slaughter <KSlaughter@harthickman.com> Subject: RE: Infiltration Gallery Abandonment Requirements WQ0006992 Yes, this will suffice. From: Kevin Slaughter [mailto:KSlaughter@harthickman.com] Sent: Thursday, October 06, 2016 4:45 PM To: Rogers, Michael <michael.rogers@ncdenr.gov> Subject: RE: Infiltration Gallery Abandonment Requirements WQ0006992 Michael, I hope you have been doing well. Oracle / has given H&H approval to produce a closure plan for the non -discharge permit referenced above and attached email. I know that 15A NCAC 02T .1608 requests that "a letter be included from the oversight agency authorizing closure of the system". Attached is an email regarding closure of this permit by Mr. Qu Qi with the Inactive Hazardous Sites Branch. Would this suffice for the letter portion of the closure plan, or would I need an actual letter from Mr. Qi? Thanks, Kevin From: Rogers, Michael [mailto:michael.rogers@ncdenr.gov] Sent: Monday, June 06, 2016 12:39 PM To: Wang, Shuying <shuying.wang@ncdenr.gov>; Kevin Slaughter <KSlaughter@harthickman.com> Cc: William Scott Snow (scottsnowC@oraclepkg.com) <scottsnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com>; Watts, Debra <debra. watts@ncdenr.gov>; Knight, Sherri <sherri.knight@ncdenr.gov>; Gonsiewski, James J <iim.gonsiewski@ncdenr.gov> Subject: RE: Infiltration Gallery Abandonment Requirements WQ0006992 Attached is the closure requirements from 2T. As Shuying mentioned below, provide the closure plan to both the CO and RO. IF you are requesting the permit be rescinded, include that request in the package. Also, please include the permit number of the system you are proposing to close in the subject line of any emails. Thanks. From: Wang, Shuying Sent: Monday, June 06, 2016 11:22 AM To: Kevin Slaughter <KSlaughter@harthickman.com>; Rogers, Michael <michael.rogers@ncdenr.gov> Cc: William Scott Snow (scottsnow@oraclepkg.com) <scottsnow@oraclepkg.com>; Matt Bramblett <MBramblett@harthickman.com>; Watts, Debra <debra.watts@ncdenr.gov>; Knight, Sherri <sherri.knight@ncdenr.gov>; Gonsiewski, James J <iim.gonsiewski@ncdenr.gov> Subject: RE: Infiltration Gallery Abandonment Requirements Hi Kevin, Once you determine how the infiltration gallery is to be closed, please submit a revised closure plan to Michael Rogers, DWR Water Quality Regional Operation Section (WARPS), Groundwater Protection Branch and send a copy here (DWR WQROS WSRO). I am not aware of any soil sampling requirements for infiltration gallery closure. Michael may have something different. In your future correspondence regarding this issue, please do not forget to copy Michael Rogers, the Central Office contact person. Thank you! Michael, could you please give Kevin a further reply regarding the soil sampling concern for the closure? Thank you! Shuying Wang, P.G. Hydrogeologist Division of Water Resources NC Department of Environmental Quality Winston-Salem Regional Office Phone: (336) 776-9702 Mobile: (336) 403-5429 Fax: (336) 776-9797 Email: Shuying.Wang@ncdenr.gov 450 W Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 http://portal.ncdenr.orp,/web/wq f, c . j "-Nothing Compares. --,...- E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Kevin Slaughter[mailto:KSlaughter@harthickman.com] Sent: Monday, June 06, 2016 10:12 AM To: Gonsiewski, James J <iim.gonsiewski@ncdenr.gov> Cc: Wang, Shuying <shuVing.wang@ncdenr.gov>; William Scott Snow (scottsnow@oraclepkg.com) <scottsnow@oradepkg.com>; Matt Bramblett <MBramblett@harthickman.com> Subject: Infiltration Gallery Abandonment Requirements Jim, I hope you are doing well. H&H is assisting Mr. W. Scott Snow with Oracle Flexible Packaging / LLFIex (Oracle) to obtain permanent closure of the infiltration gallery at the Oracle facility located at 220 Polo Rd, Winston-Salem, NC. The current Non -Discharge Permit #WQ0006992 will expire on October 31, 2016. Although pressure grouting the diffuser piping and capping the infiltration gallery area with an impervious liner is currently being considered as an option (previously suggested by Thomas Slusser in email below), Oracle may decide for future land use purposes to completely remove the gallery piping and gravel material. Once excavated, the gallery material will be properly disposed of and any gallery excavations will be refilled with clean compacted fill dirt. Am I correct that you would be the contact person when H&H submits documentation prior to initiation of gallery closure procedures to receive oversight agency authorization for closure of the system as detailed in 15A NCAC 02T .1608 (a)(2)? It also appears from prior emails regarding closure of the subject gallery and reviewing 15A NCAC 02T .1608 "Requirements For Closure", that there are no sampling requirements required for permanent gallery closure. H&H would like to confirm that soil sampling is not a requirement for infiltration gallery closure if Oracle decides to choose the gallery excavation option. If you have any comments or can offer additional guidance, I would greatly appreciate it_ Thanks again, Kevin J. Kevin Slaughter, Senior Environmental Scientist Hart & Hickman; PC ( 2923 South Tryon Street; Suite 100 1 Charlotte, NC 28203 Direct 704-887-4615 Mobile 980-613-9198 ( Main 704-586-0007 www.harthickman.com haft tiGkCT an From: Slusser, Thomas[mailto:thomas.slusser@)ncdenr.gov] Sent: Tuesday, November 25, 2014 2:32 PM To: Wang, Shuying <shuying.wang@ncdenr.gov>; Snow, William Scott <scottsnow(d)oraclepkg.com> Cc -.-Knight, Sherri <sherri.knight@)ncdenr.gov>; Basinger, Corey <corev. basinger(cDncdenr.gov> Subject: RE: Permit and Infiltration Gallery Closure - Oracle WQ0006992 Greetings Scott, The closure plan described below adequately addresses the piping , but what of the permeable material in the remainder of the infiltration gallery? I do not have the infiltration gallery design specifications in front of me, but we need to consider the potential for the permeable fill portion of the infiltration gallery would retain the ability to be used for infiltration. 15A NCAC 02T .1602(3) defines "infiltration gallery" as a subsurface ground absorption system expressly designed for the introduction of wastewater into the subsurface environment. Normally the piping is placed in permeable material in an excavation cut into the subsurface in order to facilitate infiltration of the wastewater. 15A NCAC 02T .1608(b)(2) requires that "infiltration galleries shall be closed such that the infiltration gallery will be rendered permanently unusable for the disposal or infiltration of fluids and will not serve as a source or channel of contamination." Permeable material surrounding the piping could still be used for infiltration and serve as a source of contamination to the extent that contaminants remain present in the permeable material or surrounding soil. The requirements of .1608(b)(2) can be met by excavating subsurface materials or by covering them with uncontaminated low -permeability material. I can provide additional information if you are interested in some options. Please submit a revised closure plan when you are able. Have a nice Thanksgiving, Thomas Slusser, L.G. Program Manager Underground Injection Control Program ph# 919-807-6412 http://portal.ncdenr.org/web/wq/aps/qwpro DWR - Groundwater Protection Branch 1636 Mail Service Center Raleigh, NC 27699-1636 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Wang, Shuying Sent: Tuesday, November 18, 2014 4:29 PM To: Snow, William Scott Cc: Knight, Sherri; Slusser, Thomas; Basinger, Corey Subject: RE: Permit and Infiltration Gallery Closure - Oracle WQ0006992 Hi Scott, Oracle Flexible Packaging / LLFlex has met the closure requirement 15A NCAC 02T .1608 (a), and you should pursue the proposed closure procedures to meet 2T Closure Requirements .1608 (b) and (c). Thomas, if I missed anything, please let Scott know directly, but copy me. Thank both of you! Effective October 22 at 5:00 pm, my new telephone number is 336-776-9702 Shuying Wang, P.G. Hydrogeologist NC DENR Winston-Salem Regional Office Water Quality Regional Operations Section Division of Water Resources Email: shuying.wang@ncdenr.gov Phone:336-776-9702 Fax: 336-776-9797 http://portal.ncdenr.org/web/wq/ps/gwp Please be advised: Beginning October 23, 2014, the Winston Salem Regional Office (WSRO) of the NC Department of Environment and Natural Resources (NCDENR) will begin moving to a new location. Starting October 22, 2014 at 5:00 pm, our new main telephone number will change to 336-776-9800. If you contact staff at their previous telephone number, you will be directed to their new direct telephone number. All regional office services, including file review, will continue and all appointments need to be prescheduled with WSRO staff during this transition. If you have any questions or concerns, please contact the main number provided above during our normal hours of operation, 8:00 am to 5:00 pm. E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties From: Snow, William Scott [ma iIto: scottsnow(a)oraclepkg.com] Sent: Tuesday, November 18, 2014 2:40 PM To: Wang, Shuying; Slusser, Thomas Cc: Knight, Sherri Subject: RE: Permit and Infiltration Gallery Closure - Oracle WQ0006992 Hello Folks, Oracle continues to pursue the possibility of permit closure for the above referenced site. If I interpret the permit language and associated regulations concerning system closure correctly, Oracle is required to provide the following: 1) The reason for closure — The remediation system has been inactive since July 2010 with no apparent bounce back in site contamination. In addition, no measurable contaminants were detected in groundwater for several years prior to system deactivation. Therefore, Oracle believes there is no reason to continue permit -sponsored operations. 2) Letter of permission from the oversight agency — Please recall the email dated October 9, 2014, from Qu Qi stating that DWM has no issue with rescinding the permit. 3) Description of proposed closure procedure — Oracle proposes hiring a well contractor to cut the infiltration gallery supply line pipe at the point of discharge from the groundwater remediation system. The pipe will be cut below grade and filled with grout prior to installing a cap and re-covering the disturbed area. A similar procedure is proposed at the four infiltration gallery stick ups. Cut pipe below grade, fill will grout, cap, and re- cover the disturbed area. I hope this email fulfills all requirements to proceed with system closure. However, if not, please let me know of any additional information needed or other procedures you might recommend. Sincerely, W. Scott Snow, P.E. Environmental Engineer Oracle Flexible Packaging / LLFIex 220 Polo Road Winston-Salem, NC 27105 (336) 777-5878 (office) (336) 829-9538 (mobile) From: Wang, Shuying [mailto:shuying.wang(cbncdenr.gov) Sent: Friday, October 03, 2014 11:53 AM To: Snow, William Scott Cc: Slusser, Thomas; Knight, Sherri Subject: RE: Permit and Infiltration Gallery Closure - Oracle WQ0006992 Hi Scott, I am glad to hear that you are looking into the matter. To get the permit reclosed, please follow 2T .1608 Requiremelits for Closure on the last second page of the attached 15A NCAC 02T. You may also want to check with the current permit. Thanks for emailing me. Shuying Wang, P.G. Hydrogeologist NC DENR Winston-Salem Regional Office Division of Water Resources, Water Quality Regional Operations Section 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4631 shuying.wang(d)ncdenr.gov http://porta1.ncdenr.org/web/wq/ps/gwp From: Snow, William Scott[mailto:scottsnow(cboraclepkkq.com] Sent: Friday, October 03, 2014 10:56 AM To: Wang, Shuying Subject: Permit and Infiltration Gallery Closure - Oracle WQ0006992 Hi Shuying, I hope you are doing well. Oracle is looking at the possibility of permit closure for our Polo Road facility in Winston- Salem (Permit WQ0006992). (This is NOT the Cunningham Ave site where the wells were closed due to the NCDOT road project). I am looking for the specific NCDENR Rules or Guidelines to follow in order to rescind the Operating Permit and close the infiltration gallery. Any assistance you can provide, including documents, links, or referrals, will be greatly appreciated. Thank you, W. Scott Snow, P.E. Environmental Engineer Oracle Flexible Packaging / LLFlex 220 Polo Road Winston-Salem, NC 27105 (336) 777-5878 (office) (336) 829-9538 (mobile) <DWQ 2003 Memorandum.pdf> J. Kevin Slaughter, Senior Environmental Scientist Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 Direct 704-887-4615 Mobile 980-613-9198 I Main 704-586-0007 www.harthickman.com hart hickman i�+•`�J??E► ix;y.1Pi,Y446 N'A.; iiQl�i�1�a Rogers, Michael From: Snow, William Scott <WilliamScottSnow@oraclepkg.com> Sent: Wednesday, August 17, 2016 4:44 PM To: Rogers, Michael Cc: Wang, Shuying Subject: RE: W00006992 Oracle Hi Michael, Oracle is still planning to close the permit. We are currently reviewing proposals to accomplish this and I expect to have decision soon so that we can move forward with completing this process by the permit expiration in October. Best Regards, W. Scott Snow, P.E. Environmental Engineer Oracle Flexible Packaging / LLFlex 220 Polo Road Winston-Salem, NC 27105 (336) 777-5878 (office) (336) 829-9538 (mobile) From: Rogers, Michael[mailto:michael.rogers@ncdenr.gov] Sent: Tuesday, August 16, 2016 5:08 PM To: Snow, William Scott; Kevin Slaughter; Matt Bramblett (MBramblett@harthickman.com) Cc: Wang, Shuying Subject: RE: WQ0006992 Oracle Disregard the email below if you are planning to close the GW remediation system. I ran a report on permits about to expire and sent the email without checking my Outlook for other emails in regard to this permit. I see where there has been some communication about closing the permit. Where are you at in this process? Thanks From: Rogers, Michael Sent: Tuesday, August 16, 2016 4:54 PM To: Snow, William Scott (scottsnow@oraclepkg.com) <scottsnow@oraclepkg.com> Subject: WQ0006992 Oracle Greetings - The permit above will expire 10/13/2016. If you want to renew, we need a renewal application, which can be found at link below. Michael Rogers, P.G. (NC & FL) Underground Injection Control (UIC) Program Manager - Hydrogeologist NCDEQ- DWR Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699 Direct No. 919-807-6412 http://deg.nc.gov/`about/divisions/water-resources/water-resources-permits/wastewater-branch/ground-water- protection/ground-water-applications NOTE: Per Executive Order No. 150, all e-mails sent to and from this account are subject to the North Carolina Public Records Law and may be disclosed to third parties.