WQ0035324_Permit Modification_20190301

MEMORANDUM
To: Debra Watts:
From: Michael Rogers
Date: March 1, 2019
RE: A request to revise the monitoring plan language in a permit issued December 2018
Permit No.: WQ0035324
Attached is a revised permit where the monitoring plan language has been revised to reflect a
modification to the monitoring plan, which was granted by letter in 2017. The permit was issued in
December 2018. However, the permit did not reflect a modification to the monitoring plan, which was
granted by letter in 2017. Justin Ballard with ATC contacted me and asked about it and requested the
permit be revised to reflect the monitoring plan change granted in 2017. Therefore, I revised the permit
and forwarded it to you a week or two ago. But you said the language was confusing and asked me to
clarify.
Accordingly, I asked for a table (sticky tab I) from Justin to more clearly show monitoring plan. They
also submitted a revised page to the modification request in 2017 (sticky tab 2). There had been a typo on
this page referencing quarterly sampling (highlighted in orange). This caused some confusion.
I revised the monitoring section Part III of the permit a second time and is attached. Hopefully, this is
clearer.
,,

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Justin Ballard, P.G.
DSCA Program c/o Al Chapman
NCDWM
1646 Mail Service Center
Raleigh, NC 27699
NORTH CAROLINA
Environmental Quality
March 11, 2019
RE: Permit Modification Request WQ0035324 (REVISED)
Former Pro Cleaners- DSCA Site #92-0001
Wake County
Dear Mr. Ballard and Mr. Chapman:
Based upon your request for clarification and revision of the above referenced permit issued on December
27, 2018, we are sending this revised permit issued on March 11, 2019. Part III (Monitoring
Requirements) of the permit has been revised to reflect an approval to modify monitoring sent by letter on
May 9, 2017.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to
request an adjudicatory hearing upon written request within thirty (30) days following receipt of this
permit. This request must 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, 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made this permit shall be final and binding.
If you need any additional information concerning this matter, please contact Michael Rogers at 919-707-
3668 or [e-mail].
Sincerely,
Lor Linda Culpepper
Director, Division of Water Resources
cc: Wake County Environmental Health Department
Raleigh Regional Office, WQROS
WQ0035324 Permit File
D EQ" North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1636 Mail Service Center I Raleigh, North Carolina 27699-1636
;x ��-
1�� 919.707.9000

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
GROUNDWATER REMEDIATION PERMIT
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
PERMISSION IS HEREBY GRANTED TO
Petitioner for DSCA Site #92-0001
Wake County
FOR THE
continued operation of a 12,960 gallon per day (GPD) groundwater remediation facility to serve the Former Pro
Cleaners Facility located at 8377 Creedmoor Road, Raleigh, NC 27613, consisting of three existing groundwater
recovery wells, seven existing injection wells, two AF-500 filters serving as granular activated carbon (GAC) filter
treatment vessels in series, one 50-gallon holding tank, one injection pump, one In Situ Delivery (ISD) system for
adding CarBstrate to the injectant, one PLC alarm panel, and two concentrated 300-gallon substrate tanks to
remediate dry cleaning chemicals, with no discharge of wastes to the surface waters (partial secondary discharge to
City of Raleigh municipal sewer system), pursuant to the application received October 18, 2018, additional
information received on November 28, 2018, and additional information received on March 11, 2019 (revised
monitoring plan) by the Division of Water Resources (Division), and in conformity with the project plan,
specifications, and other supporting data subsequently filed and approved by the Division and considered a part of '
this permit.
This permit shall be effective from the date of issuance until July 31, 2021, and shall be subject to the
following specified conditions and limitations:
I. PERFORMANCE STANDARDS
1. This permit shall become voidable if the soils fail to adequately assimilate the remaining wastes, and may
be rescinded unless the facilities/wells are installed, maintained, and operated in a manner which will
protect the assigned water quality standards of the surface and groundwaters. In the event that the facility
or injection wells fail to perform satisfactorily, or the injection zone fails to adequately assimilate the
injected fluid, the Permittee shall take immediate corrective actions, including the repair, modification, or
abandonment of the facility/wells, as required by the Division of Water Resources. The Permittee may be
required to reduce or eliminate the permitted activity to protect the assigned water quality standards of
surface and groundwaters [15A NCAC 2T .1605(a)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface or
groundwaters resulting from the operation of this facility [ 15A NCAC 2B .0200; 2L .0100].
WQ0035324 Non -Discharge (rev. 9/12/2016) Page 1 of 5

3. Any residuals generated from these treatment facilities must be disposed in accordance with General Statute
143-215.1 and in a manner approved by the Division [15A NCAC 2T .1100].
4. Diversion or bypassing of the untreated groundwater from the treatment facilities is prohibited [15A NCAC
2T .0108(b)(1)].
5. Adequate measures shall betaken to divert stormwater from the disposal area and prevent wastewater runoff
from the subsurface disposal field [15A NCAC 2T .0108(b)(1)].
H. FACII.ITY OPERATION AND MAINTENANCE REQUIREMENTS
1. The facility shall be properly maintained and operated as a non -discharge system to prevent the discharge
of any wastewater resulting from the operation of this facility. The groundwater treatment system shall
consistently achieve at least 95% removal of the influent contaminants or 2L Groundwater Quality
Standards (whichever is higher) prior to discharge to the infiltration gallery. If the treatment system fails
to consistently achieve this standard, additional treatment units or changes in operational needs may be
required [15A NCAC 2T .1604(g)].
2. The groundwater recovery, treatment and disposal system shall be inspected daily after permit
modification is completed (hook up for secondary discharge to municipal sewer); then weekly if no
problems with the system modification are observed. If it is determined that the system is
malfunctioning, all repairs should be made as soon as possible and reported to the Raleigh Regional
Office with 48 hours. All components of the groundwater recovery, treatment, and disposal system shall
be properly weather -proofed to prevent freezing and failure of the system. [15A NCAC 2T .0108(b)].
3. Upon classification of the wastewater treatment and remediation facilities by the Water Pollution Control
System Operators Certification Commission (WPCSOCC), the Permittee shall designate and employ a
certified operator to be in responsible charge (ORC) and one or more certified operator(s) to be back-up
ORC(s) of the facilities in accordance with 15A NCAC 8G .0201. The ORC shall visit the facilities in
accordance with 15A NCAC 8G .0204 or as specified in this permit and shall comply with all other
conditions specified in these rules [15A NCAC 2T .0117].
4. The Permittee shall maintain a log or report including dates and times of inspections, maintenance, repairs
or corrective actions taken by the Permittee, and removal of all residuals from this facility. Residual
removal information shall include the name of the hauler, permit authorizing the disposal of a letter from a
municipality agreeing to accept the residuals, date the residuals were hauled, and volume of residuals
removed. This record shall be maintained by the Permittee and include three years of data and shall be
made available to the Division or other permitting authority, upon request [15A NCAC 2T .I607(a)].
5. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the disposal site or facility at
any reasonable time for the purpose of determining compliance with this permit (including inspection,
observation, and sampling associated with injection and any related facilities as provided for in N.C.G.S.
87-90), may inspect or copy any records or annual facility report that must be maintained under the terms
and conditions of this permit, and may obtain samples of groundwater, surface water, injection fluids, or
leachate[N.C.G.S. 143-215.3 (a)(2)].
1. Monitoring will be according to the attached monitoring plan (Table 1).
2. Prior to sampling the parameters in the on -site wells, the measurement of water levels must be taken. The
depth to water in each well shall be measured from the surveyed point on the top of the casing. The
WQ0035324 Page 2 of 5

measuring points (top of well casing) of all monitoring wells shall be surveyed relative to a common datum
[15A NCAC 2L .0110].
3. Any laboratory selected to analyze parameters must be Division of Water Resources certified for those
parameters required [15A NCAC 2H .0800].
4. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be provided
[15A NCAC 2T .0108(c)].
IV.
1. Copies of all reporting forms including Annual Reports required in this Permit shall be submitted to the
addresses below [15A NCAC 2T .1607]:
UIC Program Water Quality Regional Operations Section
NC Division of Water Resources and DWR Raleigh Regional Office
1636 Mail Service Center 1628 Mail Service Center
Raleigh, NC 27699-1636 Raleigh, NC 27699
2. The Permittee shall retain records of all monitoring information, including calibration and maintenance
records, continuous monitoring data and reports required by this permit, for at least 3 years from the date
of the sample measurement, report or application. Records of this monitoring information shall include,
but not be limited to, the following [15A NCAC 2T .1607]:
a. the date, exact place, and time of sampling or measurements,
b. the individual who performed the sampling or measurements,
c. the date the analyses were performed,
d. the analytical techniques or methods used, and
e. the results of such sampling, measurements, and analyses.
3. The Permittee shall submit an Annual Report summarizing the volume and injection pressures of
effluent discharged into the injection wells and the summary results of related groundwater, influent, and
effluent monitoring. Isoconcentrations (horizontal and vertical direction) and water level
contour/potentiometric surface maps shall be prepared on an annual basis and submitted with this report.
If an annual report containing this information (e.g. corrective action plan) is required by a regulatory
agency, the Permittee may submit two (2) copies of that report in lieu of the preceding information within
thirty days of its publication [15A NCAC 2T .I607(c)].
V. NON-COMPLIANCE NOTIFICATION
The Permittee shall report by telephone to the Raleigh Regional Office, telephone number 919-7914200,
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 [15A NCAC 2T .0108(b)(1)]:
a. Any occurrence at the groundwater remediation facility which results in any unusual operating
circumstances, or in the treatment of significant amounts of contaminated groundwaters which are
abnormal in quantity or characteristic, such as the dumping of the contents of a basin or tank, the known
passage of a slug of hazardous substance through the facility, or any other unusual circumstances;
b. Any process unit failure, due to known or unknown reasons, that renders the groundwater treatment
and disposal system, including injection wells, incapable of adequate treatment and disposal, such as
mechanical or electrical failures of pumps, aerators, compressors, etc.;
c. Any non-compliance with a permit condition due to a malfunction of the system;
WQ0035324 Page 3 of 5

d. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion of the influent to such station or facility; or
e. Any time that monitoring or other information indicates that the groundwater treatment and disposal
system is not in compliance with any specified permit limitations, that any contaminant may be causing
an endangerment to an underground source of drinking water.
2. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at telephone number [phone] or to the Emergency Management's switchboard at (919)
733-3300. Also, persons reporting such occurrences by telephone shall file a written report within five
(5) days following first knowledge of the occurrence. This report must outline the actions taken or
proposed to be taken to ensure that the problem does not recur [15A NCAC 2T .0108(b)(1)].
VI. APPLICABLE BOUNDARIES
The COMPLIANCE BOUNDARY for the waste disposal area is specified by regulations in 15A NCAC
2L, Groundwater Classifications and Standards. The Compliance Boundary for the disposal system
individually permitted after December 30, 1983 is established at either (1) 250 feet from the waste disposal
area, or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area. An
exceedance of Class GA Standards at or beyond the Compliance Boundary is subject to remediation action
according to 15A NCAC 2L .0106(d)(2).
2. The REVIEW BOUNDARY is established around the waste disposal area midway between the Compliance
Boundary and the perimeter of the waste disposal area. Any exceedance of Class GA Standards at the
Review Boundary may require action in accordance with 15A NCAC 2L .0106(d)(1).
VII. GENERAL CONDITIONS
1. Issuance of this permit does not constitute approval for reimbursement from the Leaking Petroleum
Underground Storage Tank Cleanup Fund (15A NCAC 2P) or any other fund. Additionally, the issuance
of this permit does not remove the Permittee's responsibility to comply with the corrective action
requirements of the Division of Waste Management. Furthermore, the Permittee should notify and report
all changes concerning the remedial system to the Division of Waste Management. It is the Permittee's
responsibility to comply with the requirements of all involved agencies.
2. This permit shall become voidable unless the facilities are constructed in accordance with the conditions of
this permit, the approved plans and specifications, and other supporting data [15A NCAC 2T .0110].
3. This permit is effective only with respect to the nature and volume of wastes described in the application
and other supporting data [N.C.G.S. 143-215.1]
4. This permit is not transferable. In the event the facilities change ownership, or there is a name change of
the Permittee, a formal name change request must be submitted to the Division accompanied by
documentation from the parties involved, and other supporting materials as may be appropriate. The
approval of this request will be considered on its merits and may or may not be approved [15A NCAC 2T
.0104].
5. A set of approved plans and specifications for the subject project must be retained by the Permittee for the
life of this project [15A NCAC 2T .0108(b)(1)].
6. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statute 143-215.6A to 143-
215.6C.
WQ0035324 Page 4 of 5

7. The annual administering and compliance fee must be paid by the Permittee within thirty (30) days after
being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate action to
revoke this permit as specified by 15A NCAC 2T .0105 (e)(3).
8. The issuance of this permit does not preclude the Permittee from complying with any and all statutes, rules,
regulations, or ordinances, which may be imposed by other government agencies (local, state, and federal),
which have jurisdiction.
9. Requirements for System Closure
l . 30 days prior to initiation of closure of a groundwater remediation system, the permittee shall submit
the following documentation to the Division [15A NCAC 02T .1608]:
a. the reason(s) for closure,
b. a letter from the oversight agency authorizing closure of the system, and
c. a description of the proposed closure procedure.
2. The following closure procedures shall be followed [15A NCAC 02T .1608]:
a. injection well closure procedures as specified in 15A NCAC 02C .0240, and
b. 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.
3. Within 30 days following upon completion of the closure of a groundwater remediation system, the
permittee shall submit the following documentation to the Division [15A NCAC 02T .1608]:
a. a description of the completed closure procedure;
b. the dates of all actions taken relative to the procedure; and
c. a written certification that the closure has been accomplished, and that the information submitted is
complete, factual and accurate.
10. If the Permittee wants to continue operation of this system, at least six (6) months prior to the expiration of
this permit, the Permittee shall request its extension. Upon receipt of the request,. the Commission will
review the adequacy of the facilities described therein, and if warranted, will extend the permit for such
period of time and under such conditions and limitations as it may deem appropriate [ 15A NCAC 2T .0109].
41-.
Permit issued the IS day of , 2019
NORTH CAROLINA ENVIRO ENTAL MANAGEMENT COMMISSION
for
Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0035324
WQ0035324 Page 5 of 5

Table 1
Monitoring Requirements
Groundwater Remediation Permit WQ0035324
Former Pro Cleaners
DSCA Site DC920001
8377 Creedmoor Road, Raleigh, North Carolina
H&H Job No. DSO-130
Quarterly for the following analyses:
Semiannually for the following analyses:
Annually for the following analyses:
-extraction wells will be sampled from the
-monitoring wells and water supply wells will
-monitoring wells will be sampled for VOCs
ISDTM system's GAC influent groundwater
be sampled for VOCs by EPA Method 8260
by EPA Method 8260, nitrate, nitrite, sulfate,
stream for VOCs by EPA Method 8260
-field analysis will be performed on
sulfide, methane, ethane, ethene, ammonia
-field analysis will be performed on extraction
monitoring well and water supply well
nitrogen, and total organic carbon
well samples for oxidation-reduction potential,
samples for oxidation-reduction potential, pH,
-water supply wells will be sampled for VOCs
pH, dissolved oxygen, conductivity, and
dissolved oxygen, conductivity, and turbidity
by EPA Method 8260
turbidity
-field analysis will be performed on
monitoring well and water supply well
samples for oxidation-reduction potential, pH,
dissolved oxygen, conductivity, and turbidity
-extraction wells EW-8 and EW-9A
-monitoring wells MW-IOA, MW-IOB, MW-
-monitoring wells MW-5, MW-IOA, MW-
I IA, and MW-I I and water supply wells at
IOB, MW-11A, MW-11B, MW-12, MW-16,
8404 and 8405 Azalea Place and 8401, 8404,
MW-24S, and MW-24D and water supply
8405, 8408, and 8409 Camellia Drive
wells at 8404, 8405, 8408, and 8409 Azalea
Place and 8401, 8404, 8405, 8408, 8409,
8412, and 8413 Camellia Drive
Table 1 (Page 1 of 1)
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Rogers, Michael
From: Rogers, Michael
Sent: Friday, March 15, 2019 4:08 PM
To: Bolich, Rick
Subject: FW: [External] FW: Modification Request for Groundwater Remediation Permit
W00035324 (Former Pro Cleaners DSCA Site)
Attachments: WQ0035324 Revised Permit Sent 3-15-19.pdf
FYI
From: Rogers, Michael
Sent: Friday, March 15, 2019 4:06 PM
To: 'Justin Ballard' <[e-mail]>
Cc: Chapman, Al <[e-mail]>
Subject: RE: [External] FW: Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro
Cleaners DSCA Site)
See revised permit attached.
From: Justin Ballard [mailto:[e-mail]]
Sent: Monday, March 11, 2019 9:40 AM
To: Rogers, Michael <[e-mail]>
Subject: RE: [External] FW: Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro
Cleaners DSCA Site)
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Michael,
Per our discussion on Friday, please see the attached table that now reflects the proposed permit required monitoring
wells and water supply wells. I had initially provided this table as an all -encompassing sampling reference to show which
wells would be sampled; however, per your request, I have removed monitoring well MW-8B from the proposed
sampling schedule. This well will be sampled on a semi-annual basis but was not included in the original permit and so is
not included on the attached table. Please let me know if you have any questions. Thanks.
Justin Ballard, PG
Hart & Hickman, PC
From: Justin Ballard
Sent: Wednesday, February 27, 2019 3:57 PM
To: 'Rogers, Michael' <[e-mail]>
Subject: RE: [External] FW: Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro
Cleaners DSCA Site)
How's this?
Justin Ballard, PG
Hart & Hickman, PC

From: Rogers, Michael <[e-mail]>
Sent: Wednesday, February 27, 2019 3:55 PM
To: Justin Ballard <[e-mail]>
Subject: RE: [External] FW: Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro
Cleaners DSCA Site)
One more thing, please make the font bigger on Table 1 and resend.
From: Justin Ballard [mailto:[e-mail]]
Sent: Wednesday, February 27, 2019 2:46 PM
To: Rogers, Michael <[e-mail]>
Subject: [External] FW: Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
report.._ spacgov_
Michael,
As discussed, please find the attached revised page 3. Thank you and sorry again for the confusion.
Justin Ballard, PG
Hart & Hickman, PC
From: Justin Ballard
Sent: Wednesday, February 27, 2019 11:08 AM
To: 'Rogers, Michael' <[e-mail]>
Cc: Bolich, Rick <[e-mail]>
Subject: RE: Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners DSCA Site)
Thanks Michael. Please see the attached revised table. So are you modifying the permit to reflect the attached table?
Justin Ballard, PG
Hart & Hickman, PC
From: Rogers, Michael <[e-mail]>
Sent: Wednesday, February 27, 2019 10:31 AM
To: Justin Ballard <[e-mail]>
Cc: Bolich, Rick <[e-mail]>
Subject: Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners DSCA Site)
Attached is the Mod approval letter. Also, please revise the table to be an attached separate document and indicate
that EW-8 and 9A are the influent sampling station as stated below. This will be attached to the permit.
Thanks

Note that ATC' s request includes the sampling of monitoring well NM -8B, which is not currently pan of
the permit requirements but will be sampled on a semi-annual basis to provide continued monitoring for
the groundwater extraction area. Further, quarterly monitoring of extraction wells EVE'-8 and EW-9A will
continue under the current permit requirements -,Ya sampling of the ISDTm system's GAC influent
groundwater stream.
From: Justin Ballard [mailto:[e-mail]]
Sent: Wednesday, February 27, 2019 8:28 AM
To: Rogers, Michael <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Thanks Michael.
Sorry for the confusion. See the attached table below. This sampling reflects our modification request from April
2017. I've re -attached this document but unfortunately, can not find your approval of this request. The approval letter
appears to have been lost during my transition from ATC Associates to Hart & Hickman. I've tried locating this but to no
success. I feel certain the sampling outlined below was approved because we initiated it for 2018. That report is being
prepared and I will send you a copy (per the permit) once it is complete.
Quarterly for the following analyses:
Semiannually for the following
Annually for the following analyses:
-extraction wells will be sampled for
analyses:
-monitoring wells will be sampled for
VOCs by collecting
-monitoring wells and water supply
VOCs, nitrate, nitrite, sulfate, sulfide,
- field analysis of all samples for
wells will be sampled for VOCs
methane, ethane, ethene, ammonia
oxidation-reduction potential, pH,
-field analysis of all samples for
nitrogen, and total organic carbon;
dissolved oxygen, conductivity, and
oxidation-reduction potential, pH,
-water supply wells will be sampled
turbidity
dissolved oxygen, conductivity, and
for VOCs; and
turbidity
-field analysis of all samples for
oxidation-reduction potential, pH,
dissolved oxygen, conductivity, and
turbidity
-extraction wells EW-8 and EW-9A
-monitoring wells MW-8B, MW-10A,
-monitoring wells MW-5, MW-86,
(erroneously listed in the permit as
MW-10B, MW-11A, and MW-11B);
MW-10A, MW-10B, MW-11A, MW-
IW-8 and IW-9)
and
11B, MW-12, MW-16, MW-24S, and
-water supply wells at 8404 and 8405
MW-24D; and
Azalea Place and 8401, 8404, 8405,
-water supply wells at 8404, 8405,
8408, and 8409 Camellia Drive
8408, and 8409 Azalea Place and
8401, 8404, 8405, 8408, 8409, 8412,
and 8413 Camellia Drive
Note that the permit reflects that MW-4 will be sampled, however, this well has been abandoned since before the
original permit was issued.
Justin Ballard, PG
Hart & Hickman, PC
From: Rogers, Michael <[e-mail]>
Sent: Tuesday, February 26, 2019 10:09 AM
To: Justin Ballard <[e-mail]>

Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
We looked at the modification request package dated 5/9/17 (page 3) and your email below and it's a little
confusing. Would you please break down each list into monitoring frequencies something like below. Also add influent
sampling.
Quarterly for
analysis
Semiannually for
_analysis
Annually for
analysis
Well xxx
Well xxx
Well xxx
From: Rogers, Michael
Sent: Thursday, February 14, 2019 9:47 AM
To: 'Justin Ballard' <[e-mail]>; Bolich, Rick<[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
I'll look into this. If the permit needs to be revised, I will modify and get my super to sign. It will probably be next week.
From: Justin Ballard[mailto:[e-mail]]
Sent: Saturday, February 9, 2019 7:46 AM
To: Rogers, Michael <[e-mail]>; Bolich, Rick <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
J�,
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
t.`s_p.`9
Thanks Michael. I'm not sure why but this never made it to me, thank you for sending. Is it possible that the permit
modification approval letter has the original permit sampling requirements and not the revised ones that were approved
in 2017? The below reflects what that revision is (semi-annual vs quarterly plus some changes to sampling
analyses). Thanks again for sending this to me.
Collect groundwater samples from five monitoring wells (MW-8B, MW-10A, MW-106, MW-11A, and MW-11B)
on a semi-annual basis and five monitoring wells (MW-5, MW-12, MW-16, MW-245, and MW-24D) on an annual
basis for analysis of VOCs by EPA 8260, nitrate (nitrogen), nitrite (nitrogen), sulfate, sulfide, methane, ethane,
total ammonia nitrogen, and total organic carbon; and
• Collect groundwater samples from water supply wells 8404 and 8405 Azalea Place and 8401, 8404, 8405, 8408,
and 8409 Camellia Drive on a semi-annual basis and water supply wells 8408 and 8409 Azalea Place and 8412 and 8413
Camellia Drive on an annual basis.
Justin Ballard, PG
Hart & Hickman, PC
From: Rogers, Michael <[e-mail]>
Sent: Friday, February 8, 2019 5:08 PM
To: Justin Ballard <[e-mail]>; Bolich, Rick <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)

This went out in December.
From: Justin Ballard [mailto:[e-mail]]
Sent: Friday, February 8, 2019 3:26 PM
To: Rogers, Michael <[e-mail]>; Bolich, Rick <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Hi Michael,
I wanted to check in with you and Rick to see if it would be possible to get an update on the attached permit
modification request. I had to report a noncompliance notification for this site recently to Rick and during that call, I
think he mentioned that this wasn't on his current list of needed site inspections. Rick, please correct me if I have that
wrong. Thanks to both of you for your help with this.
Justin Ballard, PG
Hart & Hickman, PC
From: Rogers, Michael <[e-mail]>
Sent: Tuesday, October 16, 2018 2:30 PM
To: Justin Ballard <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
Yes, you can bring by the copies of the application form (we already have the bound copies) along with the check. If I
am not here in room 640M, leave with Gwen or Debra at other end of the hall.
Thanks
From: Justin Ballard [mailto:[e-mail]]
Sent: Tuesday, October 16, 2018 12:49 PM
To: Rogers, Michael <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
• ternal email. Do not click links or open attachments unless verified. Send all suspicious email as an
Michael,
I've updated the attached to include the application and access agreement allowing me to sign on the property owner's
behalf. I have a meeting at DEQ this Thursday and so I was thinking about dropping two copies off at the Archdale
building on my way down. Is that okay? And can I give you the check as well (for the permit modification request) or do
I need to wait until you issue me an invoice? Thanks.
Justin
From: Rogers, Michael <[e-mail]>
Sent: Friday, October 5, 2018 4:10 PM
5

To: Justin Ballard <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
My contact info is below. We usually don't get mail mixed up. Our emails get mixed up sometimes... my email is
Michael. Rogers..., and Mike in W_SRO is Mike.Rogers...
Michael Rogers, P.G. (NC & FL)
Underground Injection Control (UIC) Manager, Hydrogeologist
NCDEQ - DWR
Water Quality Regional Operations Section
Mail Address: 1636 Mail Service Center, Raleigh, NC 27699
Street Address: Archdale Bldg., 512 N. Salisbury St., Raleigh, NC 27604
Direct No. 919-707-3668 (new number)
From: Rogers, Michael
Sent: Tuesday, October 2, 2018 1:37 PM
To: 'Justin Ballard' <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
No preference.
From: Justin Ballard [mailto:[e-mail]]
Sent: Tuesday, October 2, 2018 1:19 PM
To: Rogers, Michael <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
. =,. • External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Okay, will do. Do you have a preference of how the hard copies are bound? Thanks.
From: Rogers, Michael <[e-mail]>
Sent: Tuesday, October 2, 2018 12:11 PM
To: Justin Ballard <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
Please send two hard copies.
From: Justin Ballard [mailto:[e-mail]]
Sent: Tuesday, October 2, 2018 11:06 AM
To: Rogers, Michael <[e-mail]>
Subject: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners DSCA
Site)

Mr. Rogers,
Per our phone conversation in September regarding modification of the remediation system at the former Pro Cleaners
DSCA Site (DSCA ID: DC920001), please find the attached request. This request covers connection of the system
discharge to the City of Raleigh's municipal sewer system to allow for an increase in groundwater treatment volume. A
hard copy of the attached will go out in today's mail along with a disc that includes:
-Groundwater Monitoring Report for the December 2015 through September 2016 monitoring period
-Groundwater Monitoring Report for the November 2017 monitoring event
-Operation and Maintenance (O&M) Report for the June 2016 through March 2017 O&M period
I will forward you other groundwater monitoring and O&M reports as they become available. Please let me know if you
have any questions or need any additional information. Thanks.
Justin Ballard, PG, Senior Project Geologist
Hart & Hickman, PC
3921 Sunset Ridge Rd, Ste 301 • Raleigh, NC 27607
. Direct: 919-723-2507 • Mobile: [phone]
www.harthickman.com

rt&'v I z/V/&
WATER QUALITY REGIONAL OPERATIONS STAFF REPORT
Date: 11/29/2018
To: WQ Regional Operations CO
Central Office Reviewer:
Regional Office Inspector:
County: Wake
Permittee:
Facility Name: Former Pro Cleaners
Permit # WQ0035324
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ❑ Renewal
❑ Minor Modification ® Major Modification
[] Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Geothermal Water Return
Was a site visit conducted in order to prepare this report? ❑ Yes or ❑ No.
a. Date of site visit:
b. Person contacted and contact information:
c. Site visit conducted by:
d. Inspection Report Attached: ❑ Yes or ❑ No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Disposal and Iniection Sites:
(If multiple sites either indicate which sites the information applies to copy and paste a new section into the
document for each site, or attach additional pages for each site
a. Location(s):
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
f
IV INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow
❑ Closed -loop heat pump system
® In situ remediation (51)
FORM: ??? 1

WATER QUALITY REGIONAL OPERATIONS STAFF REPORT
❑ Closed -loop groundwater remediation effluent injection (5U Non -Discharge")
❑ Other (Specify: _
2. Does system use same well for water source and injection? ® Yes ❑ No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ❑ No
What is/are the pollution source(s)? What is the distance of the injection well(s) from the
pollution source(s)?
4. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
5. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
V. EVALVATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: Heart & Hickman (H&H) In -Situ
Delivery's (ISD) treatment performance is limited by the injection rate of the injection wells and the aquifer's
ability to accept treated groundwater. H&H plans a major modification to the current remediation system by
use of a secondary discharge of treated groundwater into the City of Raleigh's municipal sewer. This will allow
for greater recovery and treatment of contaminated groundwater. H&H does not specify in the modification
request: 1) volume of treated groundwater to be disposed of in the sewer, but that it will be agreed upon
between the City of Raleigh and H&H prior to discharge of treated groundwater, 2) volume of water that the
ISD is capable of treating and how that compares with the additional volume to be treated and discharged to
Raleigh's sewer system, and 3) how they plan to discharge treated groundwater into the sewer system. After
emailing Justin Ballard with H&H with Raleigh Regional Office's (RRO) questions (see attached email
correspondence), the RRO is satisfied with the answers. The DWR RRO approves H&H's permit modification
request as outlined in the October 2, 2018 Non -Discharge Remediation Permit Application.
2. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ❑ No. If yes, please explain
briefly.
3. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
4. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
FORM: ??? 2

Rogers, Michael
From: Bolich, Rick
Sent: Monday, December 3, 2018 11:08 AM
To: Rogers, Michael
Cc: Byers, Brion N; Evan Kane
Subject: WQ003S324 staff report
Attachments: WQ0035324 staff report.tif
Rick Bolich, L.G.
Assistant Supervisor
NC Dept. of Environmental Quality
Division of Water Resources, Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27699-1628
919-791-4232
[e-mail]

Byers, Brion N
From: Justin Ballard <[e-mail]>
Sent: Wednesday, November 28, 2018 1:40 PM
To: Byers, Brion N
Cc: Rogers, Michael; Bolich, Rick
Subject: [External] RE: Former Pro Cleaners - WQ0035324 - Permit Modification
Brion,
Please see my comments below in blue and let me know if you have any further questions. Thanks!
Justin
From: Byers, Brion N <[e-mail]>
Sent: Tuesday, November 27, 2018 2:00 PM
To: Justin Ballard <[e-mail]>
Cc: Rogers, Michael <[e-mail]>; Bolich, Rick <[e-mail]>
Subject: Former Pro Cleaners - WQ0035324 - Permit Modification
Mr. Ballard,
I have been reviewing your Permit Modification request for the Former Pro Cleaners (DSCA Site #92-0001) and have a
few questions.
1) Permit No. WQ0035324 effective August 1, 2016, specifically states that the permit is for a 12,960 gpd
groundwater remediation facility. Since your modification requests to increase the volume of recovery,
treatment, and discharge of additional groundwater to the City of Raleigh's sewer system, what additional
volumes are expected? How much will the City of Raleigh allow to be discharged to their sewer system? The
original UIC permit application requested a 12,960 gpd limit; however, treatment rates over the past year have
been approximately 1,000 gpd. As such, we are not asking for an increase to the approved 12,960 gpd but
rather approval to modify how the treated. groundwater is discharged (i.e. no longer strictly to the injection well
network). For the portion that will go to the City of Raleigh's sewer system, we have asked the City to grant us a
7,000 gpd in our City of Raleigh Industrial User Permit application. Note that I have received verbal approval for
that amount but expect to have the final Industrial User Permit sometime in the next 1-2 weeks. 1 can forward to
you once I receive if you'd like.
2) With the additional groundwater being treated, is there an expected drop in effectiveness and/or efficiency of
the GAC filters? What is the effective treatment rate for the GAC filters? Do you expect any need for additional
sampling and/or maintenance of the system? The current GAC filter setup is designed for'the 12,960 gpd
amount that was applied for in the original permit application. As such, we do not expect a drop in effectiveness
and/or efficiency since we will still be well below that threshold. However, we are proposing to increase our
current quarterly GAC sampling (pre, mid, and post-GAC samples for each event) to monthly sampling to
monitor the GAC vessels ability to handle the additional treatment volume.
3) Lastly, the permit modification request did not state how H&H plans to discharge excess treated groundwater to
the City of Raleigh's sewer system, could you explain how you plan to connect to the sewer system? H&H
proposes to discharge treated groundwater into the City of Raleigh's sewer system via a proposed conduit that
will be connected to existing sewer infrastructure. The conduit will have a flow meter so that we are able to
monitor discharge volumes. The installation will occur at a manhole located approximately 30' from system. All

WATER QUALITY REGIONAL OPERATIONS STAFF REPORT
Condition Reason
5. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
6. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ® Issue upon receipt of needed additional information; ❑
Issue- sample results pending; ❑ Deny. If deny, please state reasons:
7. Signature of report preparer(s):
Signature of APS regional super
Date:
Attachments:
Email correspondence between Justin Ballard (Hart & Hickman) and Brion N. Byers (DWR: RRO).
I
FORM: ??? 3

installation work will be permitted and inspected by the City of Raleigh and the discharge will be permitted by
the City of Raleigh Industrial User Permit.
Please feel free to call me if you have any questions.
Thank you,
Brion
Brion N. Byers, P.G.
Hydrogeologist
Division of Water Resources - Raleigh Regional Office
Department of Environmental Quality
[phone] office
brion. byersa-ncdenr.gov
Physical: 3800 Barrett Drive, Raleigh, NC 27609
Mailing: 1628 Mail Service Center, Raleigh, NC 27699-1628
r' '^Nothing Compares_ -,-�
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

Rogers, Michael
From: Justin Ballard <[e-mail]>
Sent: Tuesday, October 16, 2018 2:31 PM
To: Rogers, Michael
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324
(Former Pro Cleaners DSCA Site)
Will do, thanks Michael.
From: Rogers, Michael <[e-mail]>
Sent: Tuesday, October 16, 2018 2:30 PM
To: Justin Ballard <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Sitei
Yes, you can bring by the copies of the application form (we already have the bound copies) along with the check. If I
am not here in room 640M, leave with Gwen or Debra at other end of the hall.
Thanks
From: Justin Ballard[mailto:iballa*[e-mail]]
Sent: Tuesday, October 16, 2018 12:49 PM
To: Rogers, Michael <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
Michael,
I've updated the attached to include the application and access agreement allowing me to sign on the property owner's
behalf. I have a meeting at DEQ this Thursday and so I was thinking about dropping two copies off at the Archdale
building on my way down. Is that okay? And can I give you the check as well (for the permit modification request) or do
I need to wait until you issue me an invoice? Thanks.
Justin
From: Rogers, Michael <[e-mail]>
Sent: Friday, October 5, 2018 4:10 PM
To: Justin Ballard <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
My contact info is below. We usually don't get mail mixed up. Our emails get mixed up sometimes... my email is
Michael. Rogers..., and Mike in W_SRO is Mike.Rogers...

Michael Rogers, P.G. (NC & FL)
Underground Injection Control (UIC) Manager, Hydrogeologist
NCDEQ - DWR
Water Quality Regional Operations Section
Mail Address: 1636 Mail Service Center, Raleigh, NC 27699
Street Address: Archdale Bldg., 512 N. Salisbury St., Raleigh, NC 27604
Direct No. 919-707-3668 (new number)
From: Rogers, Michael
Sent: Tuesday, October 2, 2018 1:37 PM
To: 'Justin Ballard' <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
No preference.
From: Justin Ballard [mailto:[e-mail]]
Sent: Tuesday, October 2, 2018 1:19 PM
To: Rogers, Michael <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to #
n
Okay, will do. Do you have a preference of how the hard copies are bound? Thanks.
From: Rogers, Michael <[e-mail]>
Sent: Tuesday, October 2, 2018 12:11 PM
To: Justin Ballard <[e-mail]>
Subject: RE: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners
DSCA Site)
Please send two hard copies.
From: Justin Ballard [mailto:[e-mail]]
Sent: Tuesday, October 2, 2018 11:06 AM
To: Rogers, Michael <[e-mail]>
Subject: [External] Modification Request for Groundwater Remediation Permit WQ0035324 (Former Pro Cleaners DSCA
Site)
Mr. Rogers,
Per our phone conversation in September regarding modification of the remediation system at the former Pro Cleaners
DSCA Site (DSCA ID: DC920001), please find the attached request. This request covers connection of the system
2

d;szharge to the City of Raleigh's municipal sewer system to allow for an increase in groundwater treatment volume. A
hard copy of the attached will go out in today's mail along with a disc that includes:
-Groundwater Monitoring Report for the December 2015 through September 2016 monitoring period
-Groundwater Monitoring Report for the November 2017 monitoring event
-Operation and Maintenance (O&M) Report for the June 2016 through March 2017 O&M period
I will forward you other groundwater monitoring and O&M reports as they become available. Please let me know if you
have any questions or need any additional information. Thanks.
Justin Ballard, PG, Senior Project Geologist
Hart & Hickman, PC
3921 Sunset Ridge Rd, Ste 301 • Raleigh, NC 27607
Direct: 919-723-2507 • Mobile: [phone]
www.harthickman.com I at .0 0

NORTH CAROLINA
ROY COOPER Environmental Quality
Gawynew
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim arvaor
October 19, 2018
Justin Ballard, P.G.
DSCA Program c/o Al Chapman
NCDWM
1646 Mail Service Center
Raleigh, NC 27699
RE: Acknowledgement of Application No. WQ0035324
Non -Discharge Groundwater Remediation Permit
Former Pro Cleaners- DSCA Site #92-0001
Wake County
Dear Mr. Ballard and Chapman:
The Water Quality Regional Operations Section (WQROS) acknowledges receipt of your
permit renewal application and supporting documentation received on October 18, 2018. Your
application package has been assigned the number listed above, and the primary reviewer is
Michael Rogers.
Central and Raleigh Regional Office staff will perform a detailed review of the provided
application, and may contact you with a request for additional information. To ensure maximum
efficiency in processing permit applications, the Water Quality Regional Operations Section
(WQROS) requests your assistance in providing a timely and complete response to any additional
information requests.
Please note that processing standard review permit applications may take as long as 60 to
90 days after receipt of a complete application. If you have any questions, please contact Michael
Rogers at 919-707-3668 or [e-mail].
North Carolina Department of Environmental Quality I Division of Water Resources IAFOGW Section
512 North Salisbury Street 11636 Mail Service Center I Raleigh, North Carolina 27699-1636
919.707.9129

Sincerely,
6O►-Debra J. Watts, Supervisor
Animal Feeding Operations & Groundwater
Protection Branch
Division of Water Resources
cc: Raleigh Regional Office, WQROS
Permit File WQ0035324

WATER QUALITY REGIONAL OPERATIONS SECTION
APPLICATION REVIEW REQUEST FORM
Date: 10/19/2018
To: RRO- WQROS: Danny Smith and Rick Bolich
From: Michael Rogers, WQROS — Animal Feeding Operations and Groundwater Protection Branch
Telephone: [phone] E-Mail. [e-mail]
A. Permit Number: WQ0035324
B. Applicant: DSCA Program
C. Facility Name: Former Pro Cleaners Site #92-0001
D. Application:
Permit Type: Non -Discharge Groundwater Remediation
Project Type: Permit Modification
E. Comments/Other Information:
❑ I would like to accompany you on a site visit.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please return a completed WOROS Staff
Report.
When you receive this request form, please write your name and dates in the spaces below, make a copy of
this sheet, and return it to the appropriate Central Office Groundwater Protection Branch contact person
listed above.
RO-WQROS Reviewer:
COMMENTS:
Date:
NOTES: If my schedule will allow I would like to go out on the inspection.
Thanks for your support!
FORM: WQROS-ARR ver. 092614 Page 1 of 1

North Carolina Department of Environmental Quality - Division of Water Resources (DWR)
Non -Discharge Groundwater Remediation Permit Application Form
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED UNLESS ALL APPLICABLE ITEMS ARE INCLUDED,
�EQ1DV�
„VUi'! __ ; I iilJ
APPLICATION INFORMATION
OCT = t-, Z018
Application Date:
10/2/2018
water Quality R=,gio
Application Type:
Modification
*New Projects — DWR to assign
Application/Permit No.
**Renewals/Modifications/Permit Rescission
Request — Enter Permit No.
WQ0035324 ,
Fee Submitted: (refer to fee schedule at
https://deg.nc.gov/about/divisions/water-
Choose an item.
A
resources/water-resources-permits/wastewater-
branch/ground-water-protection/non-discharge-
groundwater-remediation
*For New Projects: Complete this page, signature page, and supply all attachments.
**For Renewals/Permit Rescission Request: Complete this page and signature page.
**For Modifications: Complete this page, signature page, and supply relevant attachments.
Applicant's Name (specify the name of the
municipality, corporation, individual, etc.):
Beardsley Towne North LLC c/o Westwood Financial
(Petitioner for DSCA Site ID DC920001)
Owner or Signing Official's Name and Title
(person legally responsible for the facility
and its compliance):
Justin C. Ballard, PG — Agent for Petitioner for DSCA
Site ID DC920001
Mailing Address:
DSCA Program c/o Al Chapman, 1646 Mail Service
Center, Raleigh, NC 27699
Telephone Number:
919-707-8602
Email Address:
[e-mail]
Facility Name (name of the project site; be
consistent throughout application package):
Former Pro Cleaners — DSCA Site ID DC920001
Physical Address:
8377 Creedmoor Road, Raleigh, NC 27613
Cou nty:
Wake
Geographic Coordinates:
Lat 35.901581 ; Lon-78.682565
Contact Person (who can answer questions
about application):
Justin C. Ballard, PG — Agent for Petitioner for DSCA
Site ID DC920001
Non -Discharge GW Remediation Application Rev. 4-6-2018 Page 1

Telephone Number: 1 252-548-9191
Email Address: I [e-mail]
request this permit be rescinded (Yes or No
No)
ATTACHMENTS
The following shall be included as separate attachments to this application form. Failure to
include the following information as part of the application package will result in the
application package being returned as incomplete.
A. Site Description and Incident Information. As specified in 15A NCAC 02T .1604(a), the
applicant must briefly describe the site, noting pertinent site information including:
(1) Contaminant(s) of concern,
(2) Source(s) and dates) of the contaminant release,
(3) Remedial actions to date,
(4) Current land use,
(5) Potential receptors, and
(6) Incident number and name of oversight agency.
B. Soils Evaluation. As specified in 15A NCAC 02T .1604(b), for systems with proposed
discharge within seven feet of land surface and above the seasonal high water table, a soil
evaluation of the disposal site shall be provided to the Division by the applicant. If required by
G.S. 89F, a soil scientist shall submit this evaluation. This evaluation shall be presented in a
report that includes the following components:
(1) Field description of soil profile. Based on examinations of excavation pits or
auger borings, the following parameters shall be described by individual
diagnostic horizons to a depth of seven feet below land surface or to bedrock:
(A) Thickness of the horizon;
(B) Texture;
(C) Color and other diagnostic features;
(D) Structure;
(E) Internal drainage;
(F) Depth, thickness, and type of restrictive horizon(s);
(G) pH;
(H) Cation exchange capacity; and
(1) Presence or absence and depth of evidence of any seasonal high water
table.
(2) Recommendations concerning annual and instantaneous loading rates of
liquids, solids, other wastewater constituents and amendments. Annual
hydraulic loading rates shall be based on in -situ measurement of saturated
hydraulic conductivity in the most restrictive horizon.
Non -Discharge GW Remediation Application Rev. 4-6-2018 Page 2

C. Hydrogeologic Evaluation. As specified in 15A NCAC 02T .1604(c), a hydrogeologic
evaluation of the disposal site shall be provided to the Division by the applicant. This
evaluation shall be conducted to a depth that includes the depth of existing contamination and
the total depth of the injection well(s) or infiltration gallery(ies). This evaluation shall be based
on borings for which the numbers, locations, and depths are sufficient to define the
components of the hydrogeologic evaluation. In addition to borings, other techniques may be
used to investigate the subsurface conditions at the site. These techniques may include
geophysical well logs, surface geophysical surveys, and tracer studies. This evaluation shall be
presented in a report that includes the following components:
(1) A description of the regional and local geology and hydrogeology;
(2) A description, based on field observations of the site, of the site topographic
setting, streams, springs and other groundwater discharge features, drainage
features, existing and abandoned wells, rock outcrops, and other features that
may affect the movement of the contaminant plume and treated wastewater;
(3) Changes in lithology underlying the site;
(4) Depth to bedrock and occurrence of any rock outcrops;
(5) The hydraulic conductivity, transmissivity, and storativity (specific yield if
unconfined aquifer) of the affected aquifer(s);
(6) Depth to the seasonal high water table;
(7) A discussion of the relationship between the affected aquifers of the site to
local and regional geologic and hydrogeologic features; and
(8) A discussion of the groundwater flow regime of the site focusing on the
relationship of the plume and remediation system to groundwater receptors,
groundwater discharge features, and groundwater flow media.
D. Demonstration of Hydraulic Control. As specified in 15A NCAC 02T .1604(d), computer
modeling or predictive calculations based on site -specific conditions shall be provided to the
Division by the applicant to demonstrate that operation of the system will not cause or
contribute to:
(1) The migration of contaminants into previously uncontaminated areas, and
(2) A violation of the groundwater standards specified in 15A NCAC 02L .0202 at
the compliance boundary as described in 15A NCAC 02L .0107.
E. Maps and Cross -Sections. As specified in 15A NCAC 02T .1604(e), site plans or maps shall be
provided to the Division by the applicant depicting the location, orientation, and relationship of
facility components including:
(1) A scaled map of the site, with site -specific topographic contour intervals and
showing all facility -related structures and fences within the treatment, storage
and disposal areas;
(2) Locations of all test auger borings or inspection pits;
(3) The location of all wells (including usage and construction details if available),
designated wellhead protection areas, streams (ephemeral, intermittent, and
perennial), springs, lakes, ponds, other surface drainage features, and any other
Non -Discharge GW Remediation Application Rev. 4-6-2018 Page 3

site activities or features that may involve possible exposure to contamination
within 500 feet of all waste treatment, storage, and disposal sites;
(4) Setbacks specified in 15A NCAC 02T .1606;
(5) Delineation of property boundaries, review boundaries, and compliance
boundaries;
(6) The horizontal and vertical extent of the contaminant plume for each of the
contaminants of concern, including isoconcentration lines and plume cross -
sections;
(7) Cross -sections depicting soil and rock layers and features to a depth including
the depth of existing contamination and the total depth of the injection wells or
infiltration galleries; and
(8) Hydrologic features such as potentiometric surface / water table contours and
the direction of groundwater flow.
F. Engineering Design Documents. As specified in 15A NCAC 02T .1604(f), the following
documents shall be provided to the Division by the applicant:
(1) Engineering plans for the entire system, including treatment, storage,
application, and disposal facilities and equipment except those previously
permitted unless they are directly tied into the new units or are critical to the
understanding of the complete process;
(2) Specifications describing materials to be used, methods of construction, and
means for ensuring quality and integrity of the finished product; and
(3) Plans that include construction details of recovery, injection, and monitoring
wells and infiltration galleries.
NOTE: Recovery and monitoring wells shall be constructed in accordance with
the requirements of 15A NCAC 02C .0108. Injection wells shall be constructed
in accordance with the requirements of 15A NCAC 02C .0225(g).
G. Operating and Monitoring Plans. As specified in 15A NCAC 02T .1604(g), an operation and
monitoring plan shall be provided to the Division by the applicant. These documents shall be
specific to the site and include:
(1) The operating plan shall include:
(A) The operating schedule including any periodic shut -down times,
(B) Required maintenance activities for all structural and mechanical
elements,
(C) All consumable and waste materials with their intended source and
disposal locations,
(D) Restrictions on access to the site and equipment, and
(E) Provisions to ensure the quality of the treated effluent and hydraulic
control of the system at all times when any portion of the system ceases
to function.
(2) If injection wells are to be used then the operating plan shall also include:
(A) The proposed average and maximum daily rate and quantity of injectant;
(B) The average maximum injection pressure expressed in units of pounds per
square inch (psi); and
(C) The total or estimated total volume to be injected.
Non -Discharge GW Remediation Application Rev. 4-6-2018 Page 4

(3) The monitoring plan shall be prepared in accordance with 15A NCAC 02T .1607
and include:
(A) The monitoring well(s) that will be sampled,
(B) The constituent(s) for which those samples will be analyzed, and
(C) The schedule for sampling.
H. In Situ Remediation Additives. The following shall be provided to the Division by the
applicant if the remediation system includes additives to promote remediation in situ:
NOTE: Approved injectants can be found online http://deg.nc.gov/about/divisions/water-resourceslwater-
resources-permits/wastewater-branch/ground-water-protection/ground-water-approved-injectants . All other
substances must be reviewed by the Division of Public Health, Department of Health and Human Services as
required by 15A NCAC 02C .0225(a). Contact the UIC Program for more information (Ph# 919-807-6464).
(1) MSDS, concentration at the point of injection, and percentage if present in a mixture with
other injectants;
(2) A description of the rationale for selecting the injectants and concentrations proposed for
injection, including an explanation or calculations of how the proposed injectant volumes
and concentrations were determined;
(3) A description of the reactions between the injectants and the contaminants present
including specific breakdown products or intermediate compounds that may be formed
by the injection;
(4) A summary of results if modeling or testing was performed to investigate the injectant's
potential or susceptibility for biological, chemical, or physical change in the subsurface;
and
(5) An evaluation concerning the development of byproducts of the injection process,
including increases in the concentrations of naturally occurring substances. Such an
evaluation shall include the identification of the specific byproducts of the injection
process, projected concentrations of byproducts, and areas of migration as determined
through modeling or other predictive calculations.
Non -Discharge GW Remediation Application Rev. 4-6-2018 Page 5

Professional Engineer's Certification:
Name & Lic. No. of Professional Engineer:
Name of Engineering Firm:
Mailing Address:
City: State: Zip:
Telephone Number: Fax Number: ()
Email Address:
I, 1 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 (signing authority must be in compliance with 15A NCAC 2T .0106(b)
and c :
attest that this application for
<Q�yTrosd'��
B�RersSf W%S7W29S\ 'G. Ay4c4AL. �S�A S�T� �Ccr2�ac'
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that
if all required parts of this application are not completed and that if all required supporting information
and attachments are not included, d hcation package will be returned to me as incomplete.
Signature and Title: — eta v- — Qen-,-� ate: ��s (Zo r8
Fo 5tZE_ k
SEND TWO COPIES OF THE COMPLETE APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION AND MATERIALS, TO THE FOLLOWING ADDRESS:
DIVISION OF WATER RESOURCES — UIC PROGRAM
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 276"-1636
TELEPHONE NUMBER: [phone]
Non -Discharge GW Remediation Application Rev. 4-6-2018 Page 6

Waste Man agem en t
ENVIRONMENTAL QUALITY
January 6, 2016
JOE DYKSTRA
WESTWOOD FINANCIAL
11440 SAN VICENTE BOULEVARD
LOS ANGELES CA 90049
RE: Petitioner Eligibility
DSCA Site ID DC920001
8377 N Creedmoore Rd
Towne North Shopping Center
Raleigh, Wake County
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
LINDA CULPEPPER
Director
The Dry -Cleaning Solvent Cleanup Act (DSCA) Program (DSCA Program) has reviewed your petition to enter into
an agreement and considers Beardsley Towne North LLC c/o Westwood Financial an eligible petitioner. Enclosed,
please find the executed assessment and remediation agreement. By entering into this agreement, you agree to
cooperate with the DSCA Program to assist in the assessment and remediation of the dry-cleaning solvent
contamination at the Site. By entering into and complying with the agreement, you obtain the liability protection
afforded pursuant to N.C.G.S. § 143-215.104K.
The financial responsibility requirements for this site are detailed in appendix B.
The owner(s) of the property will be notified prior to the commencement of any site work to be conducted by the
DSCA Program's independent contractors.
If you have any questions, please contact me at [phone].
Sincerely,
Al Chapman, DSCA Project Manager
Division of Waste Management, NCDEQ
cc:
Attachments: Notification of Certification into the Dry -Cleaning Solvent Cleanup Act Program
Executed Administrative Agreement for State -Directed Assessment and Remediation
Petition
(Nothing Compares.
State of North Carolina I Environmental Quality I Waste Management
1646 Mail Service Center j 217 West Jones Street I Raleigh, NC 27699-1646
919 707 8200 T

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Waste Management
ENVIRONMENTAL QUALITY
Secretory
LINDA CULPEPPER
Director
Letter of Certification into the Drycleaning Solvent Cleanup Act Program
On December 13, 2001, pursuant to N.C.G.S. § 143-215.104G, the Dry -Cleaning Solvent
Cleanup Act (DSCA) Program has certified the site located at 8377 N Creedmoore Rd, Raleigh
in Wake County into the DSCA Program. The site has been assigned the DSCA identification
number DC920001.
Evidence of dry-cleaning solvent contamination has been documented arising from dry-cleaning
operations originating from the site.
Based on information submitted to the Division at the time of certification, the site is an
abandoned facility for the purposes of determining a site's financial responsibilities as required
by N.C.G.S § 143-215.104F(f)(2).
The site will remain certified in the DSCA Program as long as there is at least one eligible
petitioner who is complying with an agreement between the DSCA Program and that petitioner.
Pete Doom, Special Remediation Branch Supervisor
Division of Waste Management, NCDEQ
Nothing Compares.
State ofNccth Carolina Emimanuntal Quality Waste Minayanent
1646NWSenictCantu 217 Wnt loan Stmet RatrfhNC27699-1636
919 707 S200 T

NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WASTE MANAGEMENT
SUPERFUND SECTION
Dry -Cleaning Solvent Cleanup Act of 1997, as amended (DSCA) Program
IN THE MATTER OF:
PRO CLEANERS
UNDER THE AUTHORITY OF
THE DRY-CLEANING SOLVENT
CLEANUP ACT OF 1997, AS AMENDED,
N.C.G.S. § 143-215.104A, et seq.
BEARDSLEY TOWNE NORTH LLC C/O
WESTWOOD FINANCIAL
11440 SAN VICENTE BOULEVARD,
SUITE 200
LOS ANGELES, CALIFORNIA
90049
DSCA SITE I.D. DC920001
AGREEMENT
FOR ASSESSMENT AND REMEDIATION
PURSUANT TO THE DRY-CLEANING SOLVENT CLEANUP ACT OF 1997, AS
AMENDED, PART 6, ARTICLE 21A, CHAPTER 143, N.C.G.S. § 143-215.104A ET SEQ.
("DSCA")
I. INTRODUCTION AND STATEMENT OF PURPOSE
The North Carolina Department of Environmental Quality, Division of Waste Management
("Division") and Beardsley Towne North LLC c/o Westwood Financial ("Petitioner"),
collectively ("Parties"), hereby enter into this Agreement for Assessment and Remediation
("Agreement") pursuant to the Dry -Cleaning Solvent Cleanup Act of 1997, as amended, Part 6,
Article 21A, Chapter 143, N.C.G.S. § 143-215.104A et seq. ("DSCA").
In executing this Agreement, Petitioner agrees to cooperate with the Division's Dry -Cleaning
Solvent Cleanup Act Program ("Program") and the Division's independent contractors
("contractors" or "independent contractors") to assist in the assessment and remediation of the
dry-cleaning solvent contamination at the Site, as defined in Section II. E., below. By entering
into and complying with this Agreement, Petitioner obtains the liability protection afforded
pursuant to N.C.G.S. § 143-215.104K. Unless otherwise expressly provided herein, terms used
in this Agreement that are defined in DSCA or at 15A NCAC 2S .0102, shall have the meaning
assigned to them in those provisions, including any amendments thereto.
II. STATEMENT OF FACTS
A. On January 04, 2016, Petitioner filed with the Division a Petition for Certification for Pro
Cleaners pursuant to DSCA.
B. On December 13, 2001, the Division certified Pro Cleaners (hereinafter "Certified Facility
Site") pursuant to DSCA and informed Petitioner of its certification decision.
C. The Certified Facility Site is located at 8377 N Creedmoore Rd, Towne North Shopping
Center, Raleigh in Wake County, North Carolina.
DSCA ARAQ0140312

D. Petitioner is a potentially responsible party, within the meaning of N.C.G.S. § 143-
215.104B(b)(21), for assessment and remediation of dry-cleaning solvent contamination at
the Site, as defined in subsection E, below.
E. The "Site" consists of all areas at the Certified Facility Site where dry-cleaning solvent
contamination arising from dry-cleaning or wholesale distribution operations is found and all
areas where dry-cleaning solvent contamination originating at the Certified Facility Site has
come to be located.
F. The Division is authorized to enter into this Agreement pursuant to the authority vested in the
Environmental Management Commission pursuant to DSCA and duly delegated to the
Secretary of the North Carolina Department of Environmental Quality and further delegated
from the Secretary to the Division.
NOW, THEREFORE, for the purpose of assessing and remediating the dry-cleaning solvent
contamination at the Site, the Parties agree as follows:
III. WORK TO BE PERFORMED
It is Petitioner's desire that assessment and remediation at the Site as required or permitted under
DSCA, the rules adopted under DSCA and guidance documents provided by the DSCA Program
shall be performed by independent contractors selected by the Division. The Division's
contractors shall maintain a minimum level of insurance as defined in their contract with the
Division.
IV. DISPUTE RESOLUTION
If Petitioner objects to any Division notice of disapproval or decision made pursuant to this
Agreement, Petitioner shall notify the Division in writing of Petitioner's objections within
fourteen (14) calendar days of receipt of the notice of disapproval or decision. The Parties shall
then have an additional fourteen (14) calendar days from receipt by the Division of the notice of
disapproval or decision to reach an agreement. If an agreement cannot be reached within the
fourteen (14) calendar days, or within an additional period if mutually agreed upon by the
Parties, the Division shall provide a,written statement of its decision to Petitioner. Any decision
or action by the Division that cannot be resolved through the dispute resolution procedure
established herein may be subject to review pursuant to Chapter 150B of the North Carolina
General Statutes, to the extent such review is provided by law.
V. FINANCIAL RESPONSIBILITY REQUIREMENTS
Upon demand by the Division, Petitioner shall pay to the Division, on behalf of the Dry -
Cleaning Solvent Cleanup Fund ("Fund"), any amounts for which Petitioner is responsible
pursuant to N.C.G.S. § 143-215.104F(f). Petitioner shall have thirty (30) days from the date of
notice of such demand to make payment to the Division. These payments will only be required
by the Division when task -specific work has been completed by the Division's contractor.
DSCA ARAv20140312 2

VI. ADDITIONAL PROVISIONS
A. To obtain a unique EPA ID number for the disposal of hazardous wastes generated during
the assessment and remediation of the Site, Petitioner agrees that Petitioner will be the
Operator on the RCRA Subtitle C Site Identification Form. For the purposes of disposing of
hazardous waste generated during the assessment and remediation of the Site, Petitioner
agrees that Petitioner will be the Generator on Hazardous Waste Manifests.
B. The Petitioner agrees to allow the Division and the Division's independent contractors to act
as its authorized representatives for the preparation, signing, filing and delivery of any
permit application, hazardous waste manifest, non -hazardous waste manifest, National
Pollution Discharge Elimination System ("NPDES") permit, for complying with reporting
requirements and for any administrative activities that may be necessary during the course
of assessment and remediation conducted pursuant to this Agreement on the Petitioner's
behalf. Contemporaneous with the execution of this Agreement, Petitioner has executed the
Limited Power of Attorney, Attachment 1, which is incorporated herein by reference,
granting this authority to the State and its independent contractors.
C. The Petitioner agrees to execute such amendments to this Agreement as may be required in
order to comply with the provisions of DSCA and rules adopted under DSCA. If Petitioner
is a property owner of the Certified Facility Site, Petitioner agrees to file such land use
restrictions as shall be required by the Division.
D. If, at any time, Petitioner becomes aware of information that may affect the priority of the
Site, Petitioner shall within thirty (30) days provide such information to the Division.
Activities that may alter a Site's priority include, but are not limited to, installation of
nearby water supply wells, new construction/redevelopment over or within contaminated
soil or groundwater at the Site, new occupancy of vacant structures within or near the Site,
or new uses of structures at or near the Site for daycares or schools. The Division may
revise the Site's priority ranking score using the most current version of the DSCA
Prioritization Ranking System.
E. Except as provided by this Agreement, the Division retains all its authority under the
Inactive Hazardous Sites Response Act of 1987, as amended, regarding inactive hazardous
substance or waste disposal sites in relation to the Site. If active dry-cleaning operations or
wholesale distribution operations are occurring at the Site, any hazardous wastes generated
by those operations shall be managed in accordance with Article 9 of Chapterl30A of the
North Carolina General Statutes and the rules adopted at 15A NCAC 13A.
F. The signatory for Petitioner to this Agreement certifies that he/she is authorized to execute
this Agreement on behalf of Petitioner.
DSCA ARAQ0140312 3

G. The Petitioner has designated the following representative(s) as the point of contact and the
Division will direct all correspondence related to this Agreement to:
JOE DYKSTRA
WESTWOOD FINANCIAL
11440 SAN VICENTE BOULEVARD
LOS ANGELES CA 90049
All documents submitted to the Division pursuant to this Agreement shall be mailed or
hand delivered to:
North Carolina Division of Waste Management
DSCA Program
Attn: Al Chapman
1646 Mail Service Center
Raleigh, NC 27699-1646
H. Petitioner shall not assign or transfer any interest in this Agreement without the prior
consent of the Division. If Petitioner is the owner or operator of the facility or abandoned
site, Petitioner shall not transfer the ownership or operation of the facility or abandoned site
to another person without the prior written consent of the Division. The consent form can
be downloaded from the Division's web site at www.ncdsca.org or by requesting a copy
from the Division.
I. If Petitioner is a property owner of the Certified Facility Site, Petitioner shall provide a copy
of this Agreement, a copy of the Required Minimum Management Practices Rules, codified
at 15A NCAC 2S .0200 and a copy of the Access Agreement executed by the property
owner to all owners and operators of any dry-cleaning business operating at the Certified
Facility Site before the execution of this Agreement and provide written documentation to
the Division demonstrating that Petitioner has complied with this subsection.
J. If Petitioner owns or operates a wholesale distribution facility or dry-cleaning business
engaged in dry-cleaning operations at the Certified Facility Site, Petitioner shall comply with
the Required Minimum Management Practices Rules, codified at 15A NCAC 2S .0200.
K. All actions taken pursuant to this Agreement shall be in accordance with applicable local,
state and federal laws and regulations.
L. Petitioner understands and agrees that pursuant to N.C.G.S. § 143-215.104T, the State, its
agencies, officers, employees, and agents shall be absolutely immune from any liability in
any proceeding for any injury or claim arising from negotiating, entering into, monitoring, or
enforcing a dry-cleaning solvent assessment agreement, a dry-cleaning solvent remediation
agreement, or a Notice of Dry -Cleaning Solvent Remediation under DSCA or any other
action implementing DSCA. Petitioner agrees to indemnify and save and hold harmless the
Division and its officials and employees from any and all claims or causes of action arising
from or on account of acts or omissions of Petitioner or its officers, employees, receivers,
DSCA ARAv20140312 4

trustees, agents, or assigns during the term of this Agreement relating to the Site. Neither the
Division nor any official or employee thereof shall be held to be a parry to any contract other
than (i) this Agreement involving Petitioner relating to the Site or (ii) any other contract
expressly executed by the Division or the State of North Carolina. Petitioner further agrees
that the Division and its officers and employees will not become potentially responsible
parties pursuant to N.C.G.S. § 143-215.104B(21) by virtue of negotiating, entering into,
monitoring, enforcing, or undertaking any other act relating to this Agreement and may not
be held liable for any acts of Petitioner's contractors or representatives in implementing this
Agreement.
M. The Division's authorization of assessment and/or remediation activities pursuant to this
Agreement shall be contingent upon the availability of monies in the Fund. The Division
shall have no obligation to authorize assessment and/or remediation activities at the Site for
which monies are not available in the Fund.
N. The Parties agree that Petitioner's entry into this Agreement and actions undertaken by
Petitioner in accordance with this Agreement do not constitute an admission of liability by
Petitioner. No approval hereunder or receipt of funds hereby shall be taken as a warranty as
to the sufficiency or efficacy of the assessment or remediation of the Site.
O. Except as provided under N.C.G.S. § 143-215.104K, nothing herein shall constitute a
satisfaction of, or release from, liability for any claim arising as a result of operation,
ownership or use of the Site by Petitioner, its agents, lessees, successors or assigns.
P. This Agreement may not be modified without the written consent of the Parties; provided,
however, Petitioner agrees to execute such amendments to this Agreement as required by
section VI.C.
Q. Petitioner agrees that, except as provided in Section VI.A., all products generated by, from or
as the result of assessment and remediation of the Site are and shall remain the property of
the Division. These products may include but are not limited to documents, remediation
equipment, pumps and monitoring wells. Provided, however, "products" shall not include
any dry-cleaning solvent as defined at N.C.G.S. § 143-215.104B(b)(9), any hazardous
substance as defined at N.C.G.S. § 130A-310(2), or any contaminant as defined at N.C.G.S.
§ 130A-310.31(b)(4).
R. The obligations under Section VI, Paragraphs, (J) (L) and (Q) above shall survive the
termination of this Agreement.
S. This Agreement shall continue in force until (1) it is terminated or dissolved by either or both
Parties pursuant to its terms, (2) the Parties execute a subsequent agreement governing the
assessment and/or remediation of the Site, (3) the Division issues a "no further action" letter
with respect to the Site or (4) the Division is unable to obtain the consent of any property
owner to file any restrictions on the current or future use of any portion of the Site that are
necessary to assure adequate protection of public health and the environment as provided in
rules adopted pursuant to G.S. 143-215.104D(b)(3).
DSCA ARAv/20140312

T. Termination under Section VI.S. (1) shall be effective upon ten (10) business days prior
written notice to the other Party. Termination by the Petitioner shall effect forfeiture of the
liability protection afforded pursuant to N.C.G.S. § 143-215.104K. Termination by the
Division shall entitle the Petitioner to initiate a contested case pursuant to N.C.G.S. Section
143-215.104S and N.C.G.S. Section 150B-23.
U. In the event that this Agreement is terminated, the Division shall retain all applicable
enforcement rights against Petitioner, and Petitioner shall retain all applicable defenses.
V. If Petitioner is a property owner of the Certified Facility Site, Petitioner. agrees to grant
access to the Division and the Division's independent contractors to undertake all work to be
performed at the Certified Facility Site. If Petitioner is not a property owner of the Certified
Facility Site, Petitioner shall obtain access for the Division and the Division's independent
contractors to undertake all work to be performed at the Certified Facility Site.
This Agreement shall be deemed executed on the date on which it is signed by the chief of the
Superfund $ectiyn of the Division or his designee.
M.
Jim Nateson. LG
Section
Division ofWash Manag ment
Nort a lina D artm t of En 'ror 6e tal Quality
Signa re of/for Petiti er] Stever J. Fogel
ecr(- any of .•Tdstwood Financial C xporation,
Manager of Bear daley Towne North :,LC
[Title of Signatory]
[Date]
DSCA ARAv20140312 6

AGREEMENT FOR ASSESSMENT AND REMEDIATION PURSUANT TO DSCA
ATTACHMENT 1
LIMITED POWER OF ATTORNEY
Steven J. Fogel, Secretary of Westwood Financial Corporation, a Delaware
I corporation, Manager of Beardsley Towne North LLC ("Petitioner"), do hereby
grant a limited power of attorney to the Division and to the Division's independent contractors,
as follows.
The Division and the Division's independent contractors shall have the limited power of attorney
for the preparation, signing, filing and delivery of any permit application, hazardous waste
manifest, non -hazardous waste manifest, National Pollution Discharge Elimination System
(NPDES) permit, for complying with any reporting requirements and for any administrative
activities that may be necessary in the course of assessment and remediation conducted pursuant
to the Agreement into which this Attachment 1 is incorporated.
This limited power of attorney shall terminate upanination of the Agreement.
Dated M? .e *
(Seal)
Signature of Petitioner
STATE OF
COUNTY OF
On this day of , personally appeared before me, the said named
to me known and known to me to be the person described
in and who executed the foregoing limited power of attorney and he (or she) acknowledged that
he (or she) executed the same and being duly sworn by me, made oath that the statements in the
foregoing limited power of attorney are true.
My Commission Expires
(Signature of Notary Public)
Notary Public (Official Seal)
DSCA ARAv07O5 Attachment t

CALIFORNIA ALL- PURPOSE
CERTIFICATE OF ACKNOWLEDGMENT
A notary public or other officer completing this certificate verifies only the identity
of the individual who signed the document to which this certificate is attached,
and not the truthfulness, accuracy, or validity of that document.
State of California
County of WAnrop.}eS }
On Qe6effbev 23, 2G15 before me, kOlVl6trm Wtn!! ( I?vblic ,
era insent name and tale of the Older
personally appeared Steven I ftd
T
who proved t me on the basis of satisfactory evidence to be the person(sl whose
namJee i lKe subscribed to the within instr ment and acknowledged to me that
he/
A �yexecuted the same in his/ Eer/their authorize capacity(i s), and that by
his//t elr signature( on the instrument the person .�} or the entity upon behalf of
whic�the person(?1 acted, executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that
the foregoing paragraph is true and correct.
XIOMARA ELIZABETH AGUILAR
WITNESS my hand and official seal. acommission # 2os7sos
cNotary Public - California z
~z Los Angeles County
- My Comm. Expires Feb 1412018
Ngta P c nature (Notary Public Seal)
ADDITIONAL OPTIONAL INFORMATION INSTRUCTIONS FOR COMPLETING THIS FORM
This form complies with eutveni California statutes regarding notary wording and,
DESCRIPTION OF THE ATTACHED DOCUMENT ifneeded, should be completed and attached to the document. Acknowledgments
from other states may be completed for documents being sent to that state so long
as the wording does not require the California notary to violate California notary
law.
(Title or description of attached document) • State and County information must be the State and County where the document
signer(s) personally appeared before the notary public for acknowledgment.
• Date of notarization must be the date that the signer(s) personally appeared which
(Title or description of attached document continued) must also be the same date the acknowledgment is completed.
• The notary public must print his or her name as it appears within his or her
Number of Pages Document Date commission followed by a comma and then your title (notary public).
• Print the name(s) of document signer(s) who personally appear at the time of
notarization.
CAPACITY CLAIMED BY THE SIGNER • Indicate the correct singular or plural forms by crossing off incorrect forms (i.e.
hedshe/titer- is /are ) or circling the correct forms. Failure to correctly indicate this
❑ Individual (s) information may lead to rejection of document recording.
❑ Corporate Officer • The notary seal impression must be clear and photographically reproducible.
Impression must not cover text or lines. If seal impression smudges, re -seal if a
(Title) sufficient area permits, otherwise complete a different acknowledgment form.
❑ Partner(s) • Signature of the notary public must match the signature on file with the office of
the county clerk.
❑ Attorney -in -Fact If Additional information is not required but could help to ensure this
❑ Trustee(s) acknowledgment is not misused or attached to a different document.
Other Indicate title or type of attached document, number of pages and date.
❑ �> Indicate the capacity claimed by the signer. If the claimed capacity is a
' 1 CEO CFO S
corporate officer, indicate the tit a (re. ecretary).
r.one &C )-g 73 'j ;35 • Securely attach this document to the signed document with a staple.

14 North Carolina Dry -Cleaning Solvent Cleanup Program
Department of Environmental Quality
Division of Waste Management
Superfund Section
DSCA PETITION FOR CERTIFICATION
The North Carolina General Assembly enacted the Dry -Cleaning Solvent Cleanup Act
and Amendments (DSCA) to facilitate the assessment and remediation of Dry -Cleaning
Facilities, Wholesale Distribution Facilities and Abandoned Sites (Facilities)
contaminated with Dry -Cleaning Solvent. In order for the DSCA cleanup fund to be
used at a Facility, the Facility must be certified by the Division of Waste Management
(Division) of the North Carolina Department of Environmental Quality (NCDEQ) as
meeting the eligibility requirements set out in the DSCA. Rules adopted by the
Environmental Management Commission (EMC) require any person petitioning for
certification of a Facility (Petitioner) to use this DSCA Petition for Certification (Petition).
This Petition is designed to enable the Petitioner to provide the Division with the
information necessary to demonstrate that the Petitioner and the Facility meet the
requirements for certification in the DSCA. Each Petitioner must complete this form and
sign the Acknowledgement page. If the Petitioner is a corporation, limited liability
company, partnership or other business entity, the Petition must be signed by an
individual with authority to bind the business entity, and the individual signing the
Petition must certify that he/she is authorized to legally bind the business entity to the
Petition.
In addition to this Petition, an Assessment and Remediation Agreement (ARA) must be
signed and executed in order for the Petitioner to receive the liability protection afforded
pursuant to N.C.G.S. § 143-215.104K. The ARA also gives the DSCA Program the
authority to undertake state -directed assessment and remediation at the site. The
DSCA Program cannot begin any work at a site until the ARA is executed.
A $1,000 application fee must be paid before the petitioner is
considered eligible. Payment must be in the form of a money order or certified
check to the Division of Waste Management and included with the completed petition
and signed agreement.
Please review the information in the Site and Petitioner Information
Summary and make any corrections necessary.
DSCA Petition October 2007 Page I

DSCA PETITIONER QUESTIONNAIRE
1. Indicate which of the following describes the Petitioner's relationship to the Facility Site. Check
all that apply:
® Property Owner ❑ Previous Property Owner
❑ ACTIVE Dry -Cleaning Business Owner ❑ Previous Business Owner
❑ ACTIVE Dry -Cleaning Business Operator ❑ Lessee
2. The Petitioner is a:
❑ Corporation ❑ Partnership
® Limited Liability Company ❑ Individual (including sole proprietor)
❑ Limited Partnership ❑ Other:
3. Provide the following information concerning the Petitioner:
Name: Beardsley Towne North LLC c/o Westwood Financial
Address: 11440 San Vicente Boulevard, Suite 200, Los Angeles, CA 90049
Telephone: [phone] Fax: [phone]
Email: [e-mail]
4 If the Petitioner is not an individual, designate an individual who is authorized to sign for the
business entity and will serve as the contact for the purposes of this Petition:
Name: Joe Dykstra, Westwood Financial
Address: 11440 San Vicente Boulevard, Suite 200, Los Angeles, CA 90049
Telephone. [phone] Fax: [phone]
Email: [e-mail]
5. If the Petitioner is not the property owner, provide the following information regarding the
Property Owner:
6. Does the Petitioner have, or has the Petitioner ever had, environmental liability insurance
coverage or general liability insurance coverage?
❑ Yes ® No
7. Please indicate the type of facility the contamination is attributed to:
® Dry Cleaning Business ❑ Wholesale Distributor ❑ Costume
❑ Uniform ❑ Linen ❑ Other:
8. Name and Location of the Facility (or Former Facility):
Name: Pro Cleaners
DSCA Petition October 2007 Page 2

Address: 8377 N Creedmoore Rd
City: Raleigh County: Wake
Shopping Center: Towne North
9. is this an active Dry -Cleaning business:
❑ Yes ® No
10. Type of Facility (if active):
❑ Drop station only ❑ Perc dry-cleaning facility
❑ Non-perc dry cleaning facility ❑ Perc and non-perc dry-cleaning facility
11. Size and/or status of Dry -Cleaning business(http://www.ncdsca.org/RuiesRegs.htm):
❑ Small facility (fewer than 5 full-time equivalent employees)
❑ Medium facility (at least 5 but fewer than 10 full-time equivalent employees)
❑ Large facility (more than 10 full-time equivalent employees)
® Abandoned facility
❑ Wholesale Distributor
12. If the site is abandoned, provide the name of the last Dry -Cleaning Business that did business
at the Facility Site:
Name of Facility: Pro Cleaners
Address:8377 N Creedmoore Rd
13. Is there a water supply well located on the property where the facility is located:
❑ Yes ® No
14. Is the facility in an area scheduled for redevelopment:
❑ Yes ® No
If yes, will the building where the facility is located be removed: ❑ Yes ❑ No
If yes, when is the redevelopment scheduled:
15. If you are the current property owner, please give date property was purchased.
12/23/2015
16 If you are a previous property owner, please give dates you owned the property.
From To
17. If you are the current or past drycleaner, please give dates facility istwas in operation.
From To
DSCA Petition October 2007 Page 3

OTHER INSTRUCTIONS
Documentation of a dry-cleaning related release must be submitted.
Therefore, please submit copies of any reports documenting environmental
assessment or remediation activities previously conducted at this site.
This includes any Phase I or Phase II reports conducted for property
transfers.
2. Please make sure that the Acknowledgement page is signed and notarized.
3. Please make sure that you have initialed the applicable Appendices on the
Acknowledgement page.
4. Please be aware that you are required to provide access to the Certified Facility
Site as part of the Petition if you ARE the property owner.
If you are NOT the property owner of the Certified Facility Site, you will be
required to obtain access for the Division and the Division's independent
contractors in the Assessment and Remediation Agreement (ARA) to
undertake all work to be performed at the Certified Facility Site.
5 Completed petitions should be mailed to:
Division of Waste Management
ATTN: Al Chapman - DSCA Program
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
DSCA Petition October 2007 Page 4

ACKNOWLEDGEMENT
The Petitioner has indicated their status as a property owner. Therefore, Appendices A,
B and C apply to this Petitioner. Please proceed to these Appendices and read them
carefully since you will be certifying that you agree with or comply with these
Appendices.
Pleas i I the spaces below to ac owledge that you hav r d nd are in
com I' c with each applicable ndix.
Appendix A Appendix B Appendix C
Petitioner (or authorized representative) hereby swears and affirms that the information
provided in this Petition, inclusive of all appendices and attachments, is true and correct
to the best of Petitioner's knowledge.
Petitioner (or authorized representative) hereby affirms Petitioner's intent to make with
the Dry -Cleaning Solvent Cleanup Act Program such agreements as may be reasonably
required under the North Carolina Dry -Cleaning Solvent Cleanup Act for th
assessment and remediation of a Dry -Cleaning Business at the Facility Sitq1
If signing as an authorized representative, I also hereby affirm that m au orized to
execute this Petition on behalf of the Petitioner and that I am auth riz d to egally bind.
and hereby do legally bind, the Petitioner to this Petit" d to al ce ifica ons
contained in this Petition, inclusive of all appendices ch nts
This I-3� day of r CZ- , 20 !
Signature of Petitioner (or auth.rep.):
Name of Petitioner (or auth. rep. - typed or rinted : STEVEriJ. P0GEL
Secretary of Westwood Fina­)cial Corporation_,,
Title of Petitioner (or auth. rep. - typed or printed): Mar_age-c of Beardsley Towne North r zc
STATE OF
COUNTY OF
I, , a Notary Public of the county aforesaid, do
hereby certify that [name of Petitioner]
personally appeared before me this day and, having been duly sworn, executed the
foregoing DSCA Petition for Certification in my presence.
WITNESS my hand and official seal this day of , 20_
Notary Public
My Commission expires:
DSCA Petition October 2007
[SEAL]
Page 5
SEE ATTACM ACKNOWLEDGMENT

CALIFORNIA ALL- PURPOSE
CERTIFICATE OF ACKNOWLEDGMENT
A notary public or other officer completing this certificate verifies only the identity
of the individual who signed the document to which this certificate is attached,
and not the truthfulness, accuracy, or validity of that document.
State of California
County of LDS Aingttcs
On DeU rn}w ?-3, gnvS before me, kworg Chi h� �l�� filar ,rc �crvl t Vvhl i�
ere Inseamame ana 6116 of Ine officer)
personally appeared StIffim A ftel
who proved to me on the basis of satisfactory evidence to be the person��whose
name(l' is a� subscribed to the within instru ent and acknowledged to me that
he/s/he /tt3e executed the same in his/h rr/t it authorized capacity(), and that by
his/hp(r/th�it signatures l on the instrurfient the person,{, or the entity upon behalf of
'l" ?mot Y°'
which the person acted, executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that
the foregoing paragraph is true and correct.
XIOMARA ELIZABETH AGUiLAR
WITNESS my hand and official seal. Commission # 2057905 z
Notary Public - Catdornia z
/ z Los Angeles County s
s My Comm. Expires Feb 14, 2018
Note i 5x' nature (Notary Public Seal)
ADDITIONAL OPTIONAL INFORMATION INSTRUCTIONS FOR CONIPLETING THIS FORM
This form complies with current California statutes regarding notary wording and
DESCRIPTION OF THE ATTACHED DOCUMENT ifneeded, should be completed and attached to the document. Acknowledgments
from other states may be completed for documents being sent to that state so long
as the wording does not require the California notary to violate California notary
law.
(Title or description of attached document) • State and County information must be the State and County where the document
signer(s) personally appeared before the notary public for acknowledgment.
• Date of notarization must be the date that the signer(s) personally appeared which
(Title or description of attached document continued) must also be the same date the acknowledgment is completed.
• The notary public must print his or her name as it appears within his or her
Number of Pages Document Date commission followed by a comma and then your title (notary public).
• Print the name(s) of document signer(s) who personally appear at the time of
notarization.
CAPACITY CLAIMED BY THE SIGNER • Indicate the correct singular or plural forms by crossing off incorrect forms (i.e.
he/she/they,- is /ere) or circling the correct forms. Failure to correctly indicate this
❑ Individual (s) information may lead to rejection of document recording.
❑ Corporate Officer • The notary seal impression must be clear and photographically reproducible
Impression must not cover text or lines. If seal impression smudges, re -seal if a
(Title) sufficient area permits, otherwise complete a different acknowledgment form.
❑ Partner(s) • Signature of the notary public must match the signature on file with the office of
the county clerk.
❑ Attorney -in -Fact •♦ . Additional information is not required but could help to ensure this
❑ Trustee(s) acknowledgment is not misused or attached to a different document.
r Indicate title or type of attached document, number of pages and date.
Other
❑ Indicate the capacity claimed by the signer. If the claimed capacity is a
d' h '1 ' CEO CFO S t )
in officer, !cafe t e nt a (re. , , ecre ary .
r,i rrt wvr.Y.Nota!t/Cl; s • '.con: 3% 473 a Securely attach this document to the signed document with a staple.

APPENDIX A
ACCESS AGREEMENT A
(Petitioner is the Property Owner)
Pro Cleaners
8377 N Creedmoore Rd
Towne North Shopping Center
Raleigh
Wake County
DSCA Site ID No. DC920001
Name of Petitioner: Beardsley Towne North LLC c/o Westwood Financial
WHEREAS, the Petitioner is petitioning to the North Carolina Department of
Environmental Quality, Division of Waste Management (Division) for certification of the
Property into the Dry -Cleaning Solvent Cleanup Act Program (Program) pursuant to the
Dry -Cleaning Solvent Cleanup Act of 1997 as amended, Part 6, Article 21A, Chapter
143, N.C.G.S. § 143-215.104A et seq. (DSCA); and
WHEREAS, the Petitioner intends to enter into an Agreement for Assessment and
Remediation (ARA) with the Division concerning the Dry -Cleaning Solvent
contamination on the Property, and
WHEREAS, the Petitioner understands that the implementation of the ARA will require
that the Division and its independent contractors (contractors) have free and
unencumbered access to the Property for the purposes of investigating, assessing and
remediating Dry -Cleaning Solvent contamination on and around the Property; and
WHEREAS, the parties to this Access Agreement are the Division and the Petitioner, -
NOW THEREFORE, in consideration of the terms and conditions contained in this
Access Agreement, and for other good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged, the parties hereto agree as follows:
1. Grant of License and Permission. Petitioner hereby grants to (a) to the Division a
license to access the Property to monitor and enforce the ARA and (b) to the
Division's contractor(s) a license to access the Property to undertake all work to be
performed at the Property, including, but not limited to, the following purposes:
a) Inspecting, sketching and photographing the Property;
b) Taking such soil, water and air samples as may be necessary;
c) Taking other actions related to the investigation of surface or subsurface
conditions, such as installation of monitoring wells or excavation of
impacted soil;
d) Transportation of equipment onto and around the Property as necessary
to accomplish the investigation;
DSCA Petition October 2007 Page 6

e) Taking response actions necessary to mitigate any threat to human health
and the environment;
f) Remediating dry-cleaning solvent contamination at the Property as
needed; and
g) Undertaking such other activities as necessary to complete the work to be
performed as required or permitted under the ARA.
2. Conditions Precedent. The licenses created in Paragraph 1 shall take effect upon
the certification of the Property into the Program and shall remain in effect, unless
otherwise terminated pursuant to Paragraph 12 below, so long as the Property
remains certified under the Program.
3. Observation. Upon the Petitioner's reasonable notice and request, the Petitioner
and its consultants shall have the right to observe any activities performed by or on
behalf of the Division at the Property. Upon the Petitioner's reasonable notice and
request, the Division or its contractors shall allow the Petitioner to split samples of
any environmental samples obtained on behalf of the Division. All costs associated
with obtaining and analyzing the split samples shall be borne solely by the Petitioner.
4. Interference. The Division and its contractors shall endeavor to perform any
activities authorized hereunder at the Property in a manner that minimizes
interference with the use of the Property. The Division and its contractors will make
reasonable attempts to notify the Petitioner at least 48 hours prior to entering the
Property for the purposes stated in Paragraph 1.
5 Insurance. The Division's contractors have agreed to maintain the insurances as
defined in their agreement with the Division, provided however, that the Division
shall have no liability for its contractor's failure to maintain such insurance.
6. Site Repair. The Division or its contractors shall remove and shall have the right to
remove from the Property all equipment and other materials belonging to the
Division or its contractors within a reasonable period of time after the completion of
the activities at the Property authorized hereunder. To the extent practicable, the
Division's contractors shall restore the Property to the original condition it was in
prior to any activities authorized hereunder at the Property, and except as otherwise
agreed to by the parties. shall properly abandon any monitoring wells in accordance
with any applicable laws and regulations.
7 Protection of Wells and Equipment. The Petitioner shall not damage, remove, pave
over or cover any monitoring or remediation wells on the property. The Petitioner
also shall not tamper with or affect the operation of assessment or remediation
equipment installed on the property by the Division's contractors.
8. Notice. Any notices, reports, or other communications required or permitted under
this Access Agreement shall be addressed to the representative for each party as
set forth below:
DSCA Petition October 2007 Page 7

To Petitioner:
BEARDSLEY TOWNE NORTH LLC C/O WESTWOOD FINANCIAL
11440 SAN VICENTE BOULEVARD, SUITE 200
LOS ANGELES CA 90049
To the Division:
North Carolina Division of Waste Management -DSCA Program
Attn: Al Chapman
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
9. Limitations. All obligations of the Division pursuant to this Access Agreement shall
be contingent upon the availability of moneys in the North Carolina Dry -Cleaning
Solvent Act Fund.
10.Governing Law. This Access Agreement shall be governed by and construed in
accordance with the laws of the State of North Carolina, without reference to choice
of laws principles.
11.Integration Clause. This Access Agreement represents the entire understanding
and agreement between the parties hereto and supersedes any and all prior
agreements, whether written or oral, that may exist between the parties regarding
same. No amendment or modification to this Access Agreement or any waiver of any
provisions hereof shall be effective unless in writing and signed by both parties.
12.Termination. The licenses created in Paragraph 1 may be terminated upon delivery
of reasonable written notice to the Division, which termination shall be effective upon
receipt of such notice. However, such termination will also terminate the ARA and
cause the forfeiture of liability protection under the DSCA. If no such notice is
served and subject to provisions of Paragraph 2 above, the licenses created herein
shall remain in effect until such time as all work or activities under the Program have
been completed at the Property. The right and obligation set out in the first sentence
of Paragraph 6 shall survive the termination of this license.
13. Modification. This Access Agreement may not be amended except in writing by the
parties to this Access Agreement.
The parties each represent a9d warrantA
this Access Agreement is executed by their
duly authorized repsentatiybs of the accepted and agreed upon below.
and agPVeq, this � daAof
Sig nai4e-off etitiolgL r Sigri tory fir Petitioner)
(Signaffif,efor the D
120
DSCA Petition October 2007 Page 8

APPENDIX B
CERTIFICATION OF ABILITY TO PAY AND
ACCEPTANCE OF FINANCIAL RESPONSIBILITY
G.S. § 143-215.104F(b)(2) requires that any person petitioning for certification of a Dry -
Cleaning Facility or Wholesale Distribution Facility or Abandoned Site (collectively:
Facility Site) shall provide the North Carolina Department of Environmental Quality
(NCDEQ) with information necessary to demonstrate such person's ability to incur the
response costs specified in G.S. § 143-215.104F(f).
The Petitioner has indicated that this facility is an abandoned facility. Pursuant to G.S.
§ 143-215.104F(f), the required amount of response costs are as follows:
For abandoned dry-cleaning facility sites in activities related to dry-
cleaning operations during the calendar year preceding the date of the
Petition, one and one-half percent (1.5%) of the costs of assessment or
remediation not exceeding one million dollars ($1,000,000).
Moreover, G.S. § 143-215.104F(f) requires that each Potentially Responsible Party who
petitions NCDEQ to certify a Facility Site shall accept written responsibility in the
amounts specified in G.S. § 143-215.104F(f), and described above, for the assessment
or remediation of the Dry -Cleaning Solvent contamination identified in the Petition.
Note: if two or more Potentially Responsible Parties petition NCDEQ jointly, the
amounts specified in G.S. § 143-215.104F(f), and described above, shall be the
aggregate requirements for the financial responsibility of all Potentially Responsible
Parties who are party to the Petition. Unless an alternative arrangement is agreed to by
the co -petitioners, the financial responsibility requirements of G.S. § 143-215.104F shall
be apportioned equally among the co -petitioners.
The Petitioner shall demonstrate his ability to incur, and his written acceptance of
financial responsibility for, response costs in the amounts specified in G.S. § 143-
215.104F(f), and described above, for the assessment or remediation of the Dry -
Cleaning Solvent contamination identified in the Petition. The Petitioner shall make this
demonstration by signing the Acknowledgement in this Petition.
DSCA Petition October 2007 Page 9

APPENDIX C
COMPLIANCE WITH STATE AND FEDERAL
ENVIRONMENTAL LAWS, RULES AND REGULATIONS
G.S. § 143-215.104F(b)(4) requires that every Potentially Responsible Party petitioning
for certification of a Dry -Cleaning Facility, Wholesale Distribution Facility or Abandoned
Site (collectively Facility Site) shall provide the North Carolina Department of
Environmental Quality (NCDEQ) with information necessary to demonstrate that the
Petitioner and any parent, subsidiary or other affiliate of the Petitioner, has substantially
complied with:
1. The terms of any dry-cleaning solvent assessment agreement, dry-cleaning
solvent remediation agreement. brownfields agreement, or any other similar agreement
to which the Petitioner or any parent, subsidiary or other affiliate of the Petitioner has
been a party;
2. The requirements applicable to any remediation in which the Petitioner has
previously engaged; and
3. Federal and State laws, regulations, and rules for the protection of the
environment.
By signing the Acknowledgement in this Petition, the Petitioner swears and affirms, to
the best of their knowledge, that the conditions stated above have been met.
DSCA Petition October 2007 Page 10

Via E-Mail and FedEx
October 2, 2018
Mr. Michael Rogers
North Carolina Department of Environmental Quality
Division of Water Resources
Underground Injection Control Program
1636 Mail Service Center
Raleigh, NC 27699-1646
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
,cCEIVFT!Nr,�FOIT)W ;
OCT 0 9 2018 6�,
Water Quality Regioniai " P J
Operations Sectinr
Re: Modification Request for Groundwater Remediation Permit WQ0035324
Former Pro Cleaners
8377 Creedmoor Road
Raleigh, Wake County
DSCA ID DC920001
H&H Project No. DSO-130
Dear Mr. Rogers:
Hart & Hickman, PC (H&H), under contract to the North Carolina Department of Environmental
Quality's (NCDEQ's) Dry-cleaning Solvent Cleanup Act (DSCA) Program, is submitting this
request for modifications to non -discharge Groundwater Remediation Permit WQ0035324. An
electronic copy of the modification request was submitted via email on October 2, 2018. The
original permit was approved on April 16, 2012, renewed on July 22, 2016, and covered
installation of an In -Situ Delivery (ISDTM) system and injection of CarBstrateTM for remediation
of chlorinated solvent compounds at the former Pro Cleaners (Site or subject Site). The
modification request covers connection of the system discharge to the City of Raleigh (City)
municipal sewer system to allow for an increase in groundwater treatment volume. Site history
and ISDTM system specifications are provided in Section 1.0, groundwater monitoring results and
trends related to groundwater remediation efforts are provided in Section 2.0, and details
regarding the requested ISDTM system modifications are provided in Section 3.0.
2923 South Tryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 301
Charlotte, NC 28203 Raleigh, NC 27607
704.586.0007 main 919.847.4241 main
www.harthickman.com

Mr. Michael Rogers
October 2, 2018
Page 2
1.0 Background Information and ISDT" System Specifications
The subject Site is located at 8377 Creedmoor Road in Raleigh, North Carolina. The property
currently contains Towne North Shopping Center, which is a multi -tenant shopping center. Pro
Cleaners operated an active dry-cleaning operation in the tenant space at 8377 Creedmoor Road
using tetrachloroethylene (PCE) from an unconfirmed date through 1998. Pro Cleaners currently
operates in a different tenant space in the Towne North Shopping Center; however, the current
location is a drop-off/pick-up dry-cleaning facility and no dry-cleaning operations have been
performed in the new space. The former Pro Cleaners space at 8377 Creedmoor Road is
currently occupied by Lux Salon (a hair salon). A release of dry-cleaning solvents was first
identified at the Site during a Phase II Environmental Site Assessment (ESA) in 1995.
Subsequent assessment activities indicated a plume of groundwater impacted by PCE and PCE
breakdown products extending downgradient to the north towards a residential neighborhood
across Strickland Road.
Historical remedial activities performed at the Site included operation of an air sparge (AS)/soil
vapor extraction (SVE) system from 1996 through 2001, excavation of impacted soil in 2007,
pilot -scale injection of Anaerobic Biochem Plus Zero Valent IronTM (ABC+TM) in 2009, and
beginning in 2013, groundwater remediation through injection of CarBstrateTM via an ISDTM
system. The system consists of seven injection wells (IW-IA, IW-2, IW-3, IW-4, IW-5A, IW-6,
and IW-7A) and three extraction wells (EW-8, EW-9A, and EW-10). Following extraction, the
groundwater is pumped through two granular activated carbon (GAC) AF-500 filters, into a
holding tank, then into the ISDTM system where the groundwater is amended with CarBstrateTM
on a weekly basis before re -injection into the subsurface. CarBstrateTM is a nutrient -amended
carbohydrate substrate that has a high solubility and low -retardation factor. It is a non -toxic,
food -grade product that includes the macro -nutrients necessary for effective microbial growth of
nitrogen and phosphorous, as well as a specific suite of trace metals that have been shown to be
critical for active anaerobic microbial activity. The ISDTM system contains an injection pump,
booster pump, solution tank, mixer, metering pump, air -actuated ball valves, flow meters,
Id
hart hickman
S:\AAA-MastffPmjeM\DSCA - DSO\DSO-130 Pm Ckaners\Renwdiation\UIC Permit Modification August
2018\DC920001_20181002_UICGmundwateeRemediationPe itModificationRequest.doe
SMARTER ENVIRONMENTAL SOLUTIONS

Mr. Michael Rogers
October 2, 2018
Page 3
compressor, pressure gauges, and a touch screen programmable logic computer (PLC)
component that provides a high degree of flexibility in system operation.
H&H performs operation and maintenance (O&M) at the Site on an approximate weekly basis.
O&M activities include recording flow measurements, amending the extracted groundwater with
CarBstrateTM, and monitoring injection pressures and pH of the extracted groundwater. In
addition, H&H collects quarterly groundwater samples from locations prior to the working GAC
vessel, in-between the working and polishing GAC vessels, and following the polishing GAC
vessel to ensure proper treatment of the extracted groundwater. Based on the GAC monitoring,
replacement of the carbon has been needed only twice with the most recent change out even
occurring in February 2017.
2.0 Groundwater Data Evaluation
Since groundwater remediation efforts began in 2009, sampling has been conducted at the Site
on a quarterly to semiannual basis. PCE concentrations have reduced substantially since startup
of the ISDTM system. Specifically, these reductions can be seen in monitoring wells MW-8B,
MW-LOB, MW-22S, MW-22D, and MW-23 and extraction wells EW-8 and EW-9/9A. The
remaining groundwater impacts are primarily centered around the downgradient property
boundary. In addition, a review of groundwater analytical data since project startup indicates
increasing trends in monitoring wells MW-5 and MW-I IA. Volatile organic compound (VOC)
groundwater analytical data are included in Table 1. A groundwater gradient map and PCE
isoconcentration contour map for the May 2018 sampling event are included as Figures 1 and 2,
respectively.
Samples have also been collected from the downgradient water supply wells on a quarterly to
semiannual basis. Low level VOC concentrations have been observed in the water supply well
network dating back to initial sampling efforts in the 1990s. Note that water supply wells with
VOC concentrations exceeding Title 15A NCAC 2L .0202 Groundwater Standards (2L
Id
hart hickman
S:\AAA-Masts Ptojects\DSCA - DSO\DSO-130 I m Clwt \ wrn diction\UIC Permit Modification August
2018\DC920001 _20181002_UIC Gmundw aterRemediationPermitModificatlonRequest. doc
SMARTER ENVIRONMENTAL SOLUTIONS

Mr. Michael Rogers
October 2, 2018
Page 4
Standards) were properly abandoned. A review of the data for the remaining water supply wells
indicates that while VOCs are present at concentrations below 21, Standards, these
concentrations appear stable and within historical ranges. VOC groundwater analytical data for
these water supply wells are included in Table 2. A water supply well results map for the May
2018 sampling event is included as Figure 3.
In addition to the VOC data discussed above, natural attenuation parameters were also collected
for select monitoring and water supply wells. The results of this data collection show changes in
aquifer conditions in the injection area that are reflective of enhanced reductive dechlorination,
including increases or presence of iron, total organic carbon, manganese, and methane and
decreases in oxidation reduction potential (ORP), dissolved oxygen, nitrate, and sulfate.
However, these changes in aquifer conditions are generally limited to the injection area and no
substantial changes in natural attenuation parameters have been measured in the perimeter
monitoring wells or downgradient water supply wells. Natural attenuation data are included in
Table 3.
3.0 Permit Modification Request
As discussed in Section 2.0, the remaining groundwater impacts are primarily centered around
the downgradient property boundary. Although groundwater is currently being extracted and
treated from this area, the ISDTM system's performance appears to have reached its daily
treatment limit. This limitation is driven by constraints on the aquifer's capacity to accept
treated groundwater via the injection well network. Currently, the ISDTM system is configured to
extract, treat, and inject equal amounts of groundwater as part of a recirculation process.
Therefore, in order to increase extraction and treatment volumes to further remediate the PCE
plume, H&H is requesting that the groundwater permit be modified to allow for a secondary
discharge into the City's municipal sewer system. A secondary discharge will allow the ISDTM
system to extract and treat groundwater from the downgradient property boundary without
injection restrictions. This modification will also enhance the ISDTM system's ability to maintain
hart hickman
S:\AAA-NfasW Projects\DSCA - DSO\DSO-130 Pro Cleanars\RetnediationWIC Pemrit Modification August
2018\DC920001_20181002_UICGrourdwaterR=ediationPamitModificationRequest. doc
SMARTER ENVIRONMENTAL SOLUTIONS

Mr. Michael Rogers
October 2, 2018
Page 5
hydraulic control of the PCE plume. Note that this requested modification does not include
alterations to the current injection process (i.e. the ISDTM system will continue to inject treated
groundwater that has been amended with CarBstrateTM).
As part of the sewer system connection process, an Industrial User Permit Application will be
submitted to the City's Public Utilities Department. Per conversations between H&H and the
City, the volume of discharged groundwater will be tracked with a meter and will not exceed an
agreed upon amount to be determined during the application process. In addition, post -treatment
groundwater will be sampled prior to discharge into the sewer system. Laboratory analytical
results will be provided to the City upon request.
Should you have any questions or need any additional information, please feel free to contact us.
Sincerely,
Hart & Hickman, PC
Justin Ballard, PG
Senior Project Geologist
Attachments
S:\AAA-Master Projects\DSCA - DSO\DSO-130 Pro Cleaners�Remediation\UIC Permit Modification August
2018\DC920001_20I81002_UICGroundwaterRemediationPermitModificationReque t.doc
Genna Olson, PG
Senior Project Manager
hart hickman
SMAMX ENVIRONMENTAL SOLUnONS

FIGURES

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Table 3: Analytical Data for Natural Attenuation Parameters
D5CA ID No.: DC920001
A
C
T
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N
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F
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m
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20.88
1/27/2012
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11/30/2012
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s00.00014
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17.79
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0.866
0.311
125.5
26
4.86
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1
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9/11/2013
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0.804
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03/27/2014
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6/20/2014
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9/25/2014
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4.79
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0.76
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193.6
20
6.08
15.13
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3/20/2015
11.51
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7/19/2012
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0.576
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27
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25.80
0.338J
12/3R012
6.91
0.535
0.00018
168.2
56
4.90
20.20
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0.574
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0.00019
125.3
21
5.34
16.70
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5/30/2013
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0.474
1.06
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98.2
22
4.80
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9/11/2013
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9/25/2014
1.53
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12/18/2014
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152.8
55
6.66
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9/15/2015
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12'17/2015
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6/29/2016
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49
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Page 14 of38

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Table 3: Analytical Data for Natural Attenuation Parameters
DSCA ID No.: DC920001
a
m
B
o
u
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N
O
O
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N
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m
9/cm
std unit
1 C
m r/L
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2/25/2013
5.49
1
1
138.9
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58
5.64
1 11.94
9/13/2013
3.61
203.0
59
5.58
22.31)
8408
9/22/2014
5.78
171.6
56
5.42
'III
Azalea
9/142015
6.90
191.7
47
6.90
19.51
9/292016
I0.44
174.7
56
5.99
19.48
11/92017
6.16
184.2
50
5.94
14.90
8409 Azalea
9/142015
6.02
I47.5
48
6.90
19.29
9/292016
7.82
200.7
51
5.82
20.26
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3/162015
10.85
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94
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16.79
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Page 19 of 38

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Page 22 of 38

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Table 3(1): Analytical Data for Natural Attenuation Parameters (User Specified Parameters) 1
DSCA ID No.: DC920001
T
v
v
o
Ep
0
o
p
ty
Units
mil,
mg 1,
mgL
mg
mgL
m/L
mdL
mvJL
mgL
maL
3/11/2005
2/62006
11/112008
2/42009
422009
7/1420019
10/7/2009
2/4/2010
4/21/2010
7/14/2010
10/21/2010
4/262011�
1
7/272011
11/12011
1/2620/2
0.138
0.0271
o _
7/202012
0.0ox79J
0.0228
0.37
0.07
12/32012
0.00217
0.0771
MW-11A
2/272013
0.006731
0.019J
0A91
n 01�
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5/292013
0.000898J
0.0129
0.0191
9/122013
0.166
0.066
0.60
12/11/2013
0.00185J
0.0125
0.015J
0.08
0.Ox
3/262014
0.0036
0.13
.1
6/182014
0.0076
0.1
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1 '
9/232014
0.016
0.094
0.27J
0.00601
12/162012
0.511
17
= 1.2
3/182015
0.009
0.041
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6/182015
0.056
0.59
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9/172015
0.037
0.39
0.0024J
0.9
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12/152015
0.022
0.15
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0.55
0.32
1.92
3/162016
0.0093
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1.92
6/292016
0.0061
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0.5
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9/28/2016
0.0083
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5/22/2017
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11/8/2017
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Page 24 of 38

Table 3(1): Analytical Data for Natural Attenuation Parameters (User Specified Parameters)
DSCA ID No.: DC920001
9
.pa
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fn
$
c
G
t
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3/17/2005
\A
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2/6/2006
7/14/2010
12/16/2014
3/20/2015
6/18/2015
%1W-ul3
9/162015
12
12/15/2015
en
0.0034J
3/172016
8.7
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6/302016
12
12
0.0060J
9/282016
12
0.00701
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1/25/2017
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0.0066J
3/102005
\A
7/142010
3/202015
6/172015
1
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9/162015
0.89
0_161
0.0035J
12/172015
n.43
0.42
O.00b:J
3/172016
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0.088
1/
6/302016
0 081
0.14
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9/282016
0.28
0.0081J
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9.5
11/92017
1.8
0.004oJ
3/92005
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7/142009
7/142010
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Page 25 of 38

Table 3(l): Analytical Data for Natural Attenuation Parameters (User Specified Parameters)
DSCA ID No.: DC920001
9
=
ego
T
o
-
o
A
¢
z
a
A
12
t
F
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mg/L
mgL
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mgL
m&L
m/L
m/L
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mgL
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3/11/2005
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1 1/ 12/2008
2/4/2009
4/2/2009
7/15/2009
10/6/2009
2/3/2010
-
4/21/2010
-_
7/13/2010
10/20/2010
4/26/2011
-
1/26/2012
0.0383
0.0574
0.02J
0,00247
7/18/2012
0.0337
0.071
0.0291
>1.2
11/29/2012
0.0316
0.0352
0.0241
2/27/2013
0.0265
0.156
-
0.655
0.2
0.05
MW-16
5/30/2013
0.0374
0.111
0.011
0.08
9/10/2013
0.0818
1.37
0.45
12/11/2013
0.0369
0.076
0.0231
..2
0.05
3/26/2014
0.035
0.06
11.2
6/18/2014
0.042
0.049
1.1
9/25/2014
0.046
0.067
12/18/2014
0.05
0.066
--1.2
3/19/2015
0.039
0.05
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6/18/2015
0.041
0.3
0.00831
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9/15/2015
0.042
0.048
0.0042J
12/15/2015
0.039
0.0063
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1.92
3/172016
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6/28/2016
0.041
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-1.2
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9/29/2016
0.038
0.048
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0.17
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Page 26 of 38

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7
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m L
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m /L
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m /L
m /L
m /L
11/11/2008
12/1/2008
2/5/2009
4/3/2009
7,16/2001)
10/6/2009
-
2/3/2010
4/20/2010
7/15/2010
10/20/2010
7,26/2011
1,26/2012
MW-22D
7,17/2012
0.0387
0.0657
0.0231
0.006J
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0.2
0.4
11/30/2012
0.036
0.0542
0.021
>1.2
0.8
2/25/2013
OA234
0.0323
-
U99
0.12
0.02
5/28/2013
0.0288
0.0302
0.035J
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0.06
9/9/2013
0.0327
0.024J
0.006J
1.2
12/9/2013
0.0245
0.0275
0.0131
0.12
0.02
3/24/2014
0.023
0.026
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0.2
6/17/2014
0.019
0.025
0.25
9/23/2014
0.043
0.026
0.53
0.0029
12/17/2014
0.0071
0.0062
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3/17/2015
0.022
0.029
0.291
0.0083J
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6/ 16/2015
0.017
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9/15/2015
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Page 28 of 38

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6/152015
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Page 30 of 38

Table 3(1): Analytical Data for Natural Attenuation Parameters (User Specified Parameters)
DSCA ID No.: DC920001
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Page 31 of 38

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Page 38 of 38

�%�✓— ��Scrdi4�-Gz`_
Rogers, Michael
From:
Rogers, Michael
Sent:
Thursday, December 15, 2016 2:47 PM
To:
'Justin Ballard'
Subject:
RE: WQ0035324 DSCA Site #92-0001
Per our discussion, assume the monitoring frequency as stated in the permit, which includes a January sampling date.
-----Original Message -----
From: Justin Ballard [mailto:[e-mail]]
Sent: Wednesday, December 14, 2016 3:44 PM
To: Rogers, Michael <[e-mail]>
Subject: FW: WQ0035324 DSCA Site #92-0001
Michael,
Attached are the two figures we just spoke about. Please let me know if you have any questions. Thanks.
Justin Ballard PG I PROJECT MANAGER I ATC Group Services LLC
-----Original Message -----
From: Justin Ballard
Sent: Wednesday, December 14, 2016 9:55 AM
To: 'Rogers, Michael' <[e-mail]>
Subject: RE: WQ0035324 DSCA Site #92-0001
Mr. Rogers,
Per our phone conversation last week, please see the attached request for postponing the next scheduled groundwater
sampling event by one month (January). Thank you.
Justin Ballard PG I PROJECT MANAGER I ATC Group Services LLC
-----Original Message -----
From: Rogers, Michael [mailto:[e-mail]]
Sent: Friday, July 22, 2016 4:10 PM
To: Justin Ballard <[e-mail]>; Genna Olson <[e-mail]>
Cc: Bolich, Rick <[e-mail]>
Subject: RE: WQ0035324 DSCA Site #92-0001
Please discard the previous attachment. Debra forgot to sign the permit.
-----Original Message -----
From: Rogers, Michael
Sent: Friday, July 22, 2016 3:25 PM
To: 'Justin Ballard' <[e-mail]>; Genna Olson ([e-mail])
<[e-mail]>
Cc: Bolich, Rick <[e-mail]>
Subject: FW: WQ0035324 DSCA Site #92-0001

Please find attached the renewal permit for the above project.
Regards
-----Original Message -----
From: Michael Rogers [mailto:[e-mail]]
Sent: Friday, July 22, 2016 2:39 PM
To: Rogers, Michael <[e-mail]>
Subject:
This E-mail was sent from "RNPAC7DD0" (Aficio 2075).
Scan Date: 07.22.2016 14:39:20 (-0400)
Queries to: [e-mail]

Rogers, Michael
From: Justin Ballard <[e-mail]>
Sent: Wednesday, December 14, 2016 3:44 PM
To: Rogers, Michael
Subject: FW: WO0035324 DSCA Site #92-0001
Attachments: DC920001_20161214 GWSamplingScheduleRevision Request. pdf; Pro Cleaners Compliance
Boundary and Setbacks Figure (Full Scale).pdf; DC9201SL34-PCE 7D (1).pdf
Michael,
Attached are the two figures we just spoke about. Please let me know if you have any questions. Thanks.
Justin Ballard PG I PROJECT MANAGER I ATC Group Services LLC
-----Original Message
From: Justin Ballard
Sent: Wednesday, December 14, 2016 9:55 AM
To: 'Rogers, Michael` <[e-mail]>
Subject: RE: WQ0035324 DSCA Site #92-0001
Mr. Rogers,
Per our phone conversation last week, please see the attached request for postponing the next scheduled groundwater
sampling event by one month (January). Thank you.
Justin Ballard PG ( PROJECT MANAGER I ATC Group Services LLC
-----Original Message -----
From: Rogers, Michael [mailto:[e-mail]]
Sent: Friday, July 22, 2016 4:10 PM
To: Justin Ballard <[e-mail]>; Genna Olson <[e-mail]>
Cc: Bolich, Rick <[e-mail]>
Subject: RE: WQ0035324 DSCA Site #92-0001
Please discard the previous attachment. Debra forgot to sign the permit.
-----Original Message -----
From: Rogers, Michael
Sent: Friday, July 22, 2016 3:25 PM
To: 'Justin Ballard' <[e-mail]>; Genna Olson ([e-mail])
<[e-mail]>
Cc: Bolich, Rick <[e-mail]>
Subject: FW: WQ0035324 DSCA Site #92-0001
Please find attached the renewal permit for the above project.
Regards
Original Message-----

From: Michael Rogers [mailto:[e-mail]]
Sent: Friday, July 22, 2016 2:39 PM
To: Rogers, Michael <[e-mail]>
Subject:
This E-mail was sent from "RNPAC7DD0" (Aficio 2075).
Scan Date: 07.22.2016 14:39:20 (-0400)
Queries to: [e-mail]

Rogers, Michael
From: Justin Ballard <[e-mail]>
Sent: Wednesday, December 14, 2016 9:55 AM
To: Rogers, Michael
Subject: RE: WO0035324 DSCA Site #92-0001
Attachments: DC920001_20161214_GWSamplingScheduleRevisionRequest.pdf
Mr. Rogers,
Per our phone conversation last week, please see the attached request for postponing the next scheduled groundwater
sampling event by one month (January). Thank you.
Justin Ballard PG I PROJECT MANAGER I ATC Group Services LLC
-----Original Message -----
From: Rogers, Michael [mailto:[e-mail]]
Sent: Friday, July 22, 2016 4:10 PM
To: Justin Ballard <[e-mail]>; Genna Olson <[e-mail]>
Cc: Bolich, Rick <[e-mail]>
Subject: RE: WQ0035324 DSCA Site #92-0001
Please discard the previous attachment. Debra forgot to sign the permit.
-----Original Message -----
From: Rogers, Michael
Sent: Friday, July 22, 2016 3:25 PM
To: 'Justin Ballard' <[e-mail]>; Genna Olson ([e-mail])
<[e-mail]>
Cc: Bolich, Rick <[e-mail]>
Subject: FW: WQ0035324 DSCA Site #92-0001
Please find attached the renewal permit for the above project.
Regards
-----Original Message -----
From: Michael Rogers [mailto:[e-mail]]
Sent: Friday, July 22, 2016 2:39 PM
To: Rogers, Michael <[e-mail]>
Subject:
This E-mail was sent from "RNPAC7DD0" (Aficio 2075).
Scan Date: 07.22.2016 14:39:20 (-0400)
Queries to: [e-mail]

AVAkANWAW
IF
XF A I %W
ENVIRONMENTAL GEOTECHNICAL
BUILDING SCIENCES • MATERIALS TESTING
December 14, 2016
Mr. Michael Rogers
NCDEQ Division of Water Resources
Underground Injection Control Program
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
2725 East Millbrook Road
Suite 121
Raleigh, NC 27604
Tel: [phone]
Fax:[phone]
www.atcassociates.com
N.C. Engineering License No. C-1598
RE: Schedule Addendum Request for Groundwater Remediation Permit WQ0035324
Former Pro Cleaners
8377 Creedmoor Road
Raleigh, Wake County, North Carolina
ATC Project No. DC9201SL34
DSCA Site No. DC920001
Dear Mr. Rogers:
ATC Associates of North Carolina, P.C. (ATC), under contract to the North Carolina Department of
Environmental Quality's (NCDEQ's) Drycleaning Solvent Cleanup Act (DSCA) Program, is submitting
this request to allow for postponement of the next quarterly sampling event until January 2017. Currently,
the next quarterly sampling event is scheduled for December 2016, however, ATC is requesting the
schedule addendum in order to, -provide the Underground Injection Control Program with information
regarding potential revisions to the monitoring requirements referenced in Section IV of non -discharge
Groundwater Remediation Permit WQ0035324. The permit was approved on April 16, 2012 and covered
installation of an In Situ Delivery (ISDTM) system and injection of CarBstrateTM for remediation of
chlorinated solvent compounds.
If you have questions or require additional information, please do not hesitate to contact us at (919) 871-
0999.
Sincerely,
ATC Associates of North Carolina, P.C.
M/ipj�102/
Justin C. Ballard, P.G.
Project Manager
NC Professional Geologist #2257
4
Genna K. Olson, P.G.
Program Manager
NC Professional Geologist #1660

Justin Ballard
From: Goodrich, David <[e-mail]>
Sent: Friday, August 16, 2013 9:21 AM
To: Justin Ballard; Rice, Eric
Cc: Genna Olson; Chapman, Al
Subject: RE: Pro Cleaners Groundwater Remediation Permit WQ0035324
Mr. Ballard,
Thank you for contacting us regarding your situation and its impact on the sampling schedule.
Sampling in September is acceptable to us.
Regards,
David Goodrich
Aquifer Protection Section Central Office
From: Justin Ballard fmailto:justin.ballard(o)cardno.com]
Sent: Thursday, August 15, 2013 3:58 PM
To: Rice, Eric; Goodrich, David
Cc: Genna Olson; Chapman, Al
Subject: Pro Cleaners Groundwater Remediation Permit WQ0035324
Mr. Goodrich,
Per the above referenced permit, we are required to perform our next quarterly groundwater sampling event in August
2013. However, due to an issue with our NCDENR DSCA Program contract funding, we are requesting that you allow us
to push that event until September. We anticipate that by that time all issues will be worked out. Please let me know if
you have any questions and if this is acceptable. Thank you.
Justin C. Ballard, P.G. I Project Geologist I ATC Associates of North Carolina, P.C. I Raleigh, NC
[phone] direct 1 [phone] mobile
2725 East Millbrook Road I Suite 121 1 Raleigh, NC 27604
[phone] tel [phone] fax I www.atcassociates.com
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Rogers, Michael
From: Justin Ballard <[e-mail]>
Sent: Thursday, December 15, 2016 2:40 PM
To: Rogers, Michael
Attachments: DC920001_20130816_UIC Acknowledgement of Sampling Schedule Alteration.pdf
Justin Ballard PGI PROJECT MANAGER I ATC Group Services LLC
[phone]
A
2V C
725 E. Millbrook Road, Suite 121 1 Raleigh, NC 27604
j usti n. bal lard (d)atcassociates. com I www.atcgroupservices.com
This email and its attachments may contain confidential and/or privileged information for the sole use of the intended recipient(s). If you are
not the intended recipient, any use, distribution or copying of the information contained in this email and its attachments is strictly prohibited.
If you have received this email in error, please notify the sender by replying to this message and immediately delete and destroy any copies
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CREEDMOOR ROAD
AZALEA PLACE
MW-10
/
8401 MW-10
M
AZALEA PLACE
= -
9
/
I
MW-11A
8400
CAMELLIA DRIVE
0 100, 200' 300'
APPROXIMATE SCALE IN FEET
CREEDMOOR ROAD
/ I
I
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1
_ MW-1D / \
(ABANDONED\ /
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DESTR(
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— — — — — — — MW-9
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BMW-17 I
MW-19
(NOT LOCATED)
MW-20
(ABANDONED) MW-21
NO SURFACE WATER DIVERSIONS, GROUNDWATER
LOWERING DITCHES, SUBSURFACE GROUNDWATER
LOWERING DRAINAGE SYSTEMS, OR ROCK OUTCROPS
WITHIN 25'
SEE DISCUSSION IN COVER LETTER REGARDING PUBLIC
RIGHT—OF—WAYS AND PROPERTY BOUNDARIES
NO RESIDENCES, PLACES OF PUBLIC ASSEMBLY,
WATER SUPPLY WELLS, SURFACE WATER BODIES, OR
SWIMMING POOLS WITHIN 100'
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NOTES: ATTACHMENT 7D
1. FEATULOCATIONS,
NS,NORARETH THEY WN ARE NOT AN
PCE ISOCONCENTRATION CONTOUR MAP
LOCATIONS, NOR ARE THEY PRESENTED TO A STATED
ACCURACY
2. GROUNDWATER SAMPLES COLLECTED9/2&28/2016. FORMER PRO CLEANERS, 8377 CREEDMOOR ROAD
3. J VALUES INDICATED ESTIMATED CONCENTRATIONS
BETWEEN METHOD DETECTION LIMIT AND PRACTICAL TO WN E NORTH SHOPPING CENTER
QUANTITATIVE LIMITS.
RALEIGH, NORTH CAROLINA
COORDINATE SYSTEM: CAD FI-E DCSA ID PREP. BY REV. BY
SURVEY FEORHT CAROLINA STATE PLANE FIPS 3200, US SEE LOWER LEFT DC920001 AK AM
JWA
jffI C
r kT
ATC Associates of North Carolina, P.C.
Raleigh, North Carolina, 27604 [phone]
SCALE DATE PROJECT NO.
AS SHOWN 10/16 DC9201SL34