WI0100091_Complete File - Historical_20180413

— S c Vv ?-O I C 0 0'7 t
Shrestha,.Shristi R
Subject:. Discuss about expired permits WI0100091 and M0100126
Location: debra's office
Start: Fri.4/13/2018 2:00 PM .
End::: Fri 4/13/2018 2:30 PM
.Recurrence: (none)
Meeting Status: Meeting organizer
-Organizes:, Shrestha; Shristi R
Required Attendees: Watts; Debra; Rogers; Michael
Can we move this to later in the afternoon so we can, get the archiving work done in the morning?
Shristi
Here are .Andrew's comments about the permits.
W]A.100091
Injection -related activities are summarized in the 7/28/2011 FINAL Redevelopment Areas Remedial Action Plan.
issued to DWM,:which I found in.DWM's laserfiche files. I attempted to.attach to this_email, but _it's .too , large.. A
review'of ARO's: files indicateswe did -not receive a notification of initiation of injections; any monitoring.data, or,a
final.project evaluation for this permit: According the noted report; injection of ORC-Advanced occurred:November
2010. A review of BIMS indicates, no injection event record -was submitted.. It's not clear_ whether the approved
monitoring was conducted.. During the application review process, CO -issued a request for additional information on .
:7/2/2010, which included a request to install an additional downgradient monitoring well, the addition of arsenic to. the.
monitoring plan, and clarification on the frequency and duration of monitoring, The ARO does not have a copy of the
response; which was apparently. received 7/23/2010 by CO: The response regarding monitoring was incorporated into
the.permit. A review of,the 8/14/2013 Quarterly Long -Term Monitoring Reports (attached), issued to DWM, indicates
monitoring -was conducted in.the injection vicinity.m accordance with.the original application: There is no imication::
that an additional downgradient monitoring well was, installed., Arsenic .was analyzed in the baseline, sample, but not in
any of thepost-injection sampdi
ling.. A review. of the 8/14/2013 monitoring report -indicates there were no analyzed
constituents -detected> 2L downgraent of the:mjection area (MW737) following injections: Benzene and napathalene .
were etecte o owmg iri�ections wit n t e;injection zone (M _ ut were below pre -injection levels
during the: 6/2013 monitoring. Monitorin : has continued in MW-36 through 2/2015, which is the last available
monitoring report in laserfiche (report attached). Benzene and naphthalene were still below pre-mjec ion eeve sat that
time.
WI0100126

Inj ection-related activities are summarized in the 7/28/2011 FINAL Redevelopment Areas Remedial Action Plan
issued to DWM. A review of ARO's files indicates we did not receive a notification of initiation of injections, any
monitoring data, or a final project evaluation for this.permit. According to the noted report, injection of ABC occurred
3/2011. A review of BIMS indicates no injection event record was submitted. Monitoring appears to have been
conducted as proposed in the -application, including the.construction of additional monitoring well MW-67.
Constituents were all < 2L as of 5/2012 monitoring. Monitoring data is summarized in the 8/14/2013 .Quarterly Long -
Term Monitoring Reports.
Feel free to contact me if you have any questions.
Andrew W. Moore, P.G.
Environmental .Specialist - Asheville. Regional. Office*
Water Quality Regional 'Operations Section
N DEQ - Division of Water Resources
828 296 4684 office
email: AndreW.W.MOoreCZDncdenr.00V

Shrestha, Shristi R
From: Moore, Andrew W
Sent: Wednesday, February 07, 2018 9:55 AM
To: Shrestha, Shristi R
Cc: Davidson, Landon
Subject: WI0100091 and, WI0100126
Attachments: SF_F_NCD003166675_02-24-2015_SERB_CONTR.pdf, SF_F_NCD003166675_
08-14-2013_SERB_CONTR (2).pdf
Shristi,
I've had a chance to review BIMS, ARO's file, and DWM's online files related to the subject injection permits. Here
is what I found.
WI0100091
Injection -related activities are summarized in the 7/28/2011 FINAL Redevelopment Areas Remedial Action Plan
issued to DWM, which I found in DWM's laserfiche files. I attempted to attach to -this email, but it's too large. A
review of ARO's files indicates we did not receive a notification of initiation of injections, any monitoring data, or a
final project evaluation for this permit. According the noted report, injection of ORC-Advanced occurred November
2010. A review of BIMS indicates no injection event record was submitted. It's not clear whether the approved
monitoring was conducted. During the application review process, CO issued a request for additional information on
7/2/2010, which included a request to install an additional downgradient monitoring well, the addition of arsenic to the
monitoring plan, and clarification on the frequency and duration of monitoring. The ARO does not have a copy of the
response, which was apparently received 7/23/2010 by CO. The response regarding monitoring was incorporated into
the permit. A review of the 8/14/2013. Quarterly Long -Term Monitoring Reports (attached), issued to DWM, indicates
monitoring was conducted in the injection vicinity in -accordance with the original application. There is no indication
that an additional downgradient monitoring well was installed. Arsenic was analyzed in the baseline sample, but not in
any of the post -injection sampling. A review of the 8/14/2013 monitoring report indicates there were no analyzed
constituents detected > 2L downgradient of the injection area (MW-37) following injections. Benzene and napathalene
were detected > 2L following injections within the injection zone (MW-36), but were below pre -injection levels
during the 6/2013 monitoring. Monitoring has continued in MW-36 through 2/2015, which is the last available
monitoring report in laserfiche (report attached). Benzene and naphthalene were still below pre -injection levels at that
time.
WI0100126
Inj ection-related activities are summarized in the 7/28/2011 FINAL Redevelopment Areas Remedial Action Plan
issued to DWM. A review of ARO's files indicates we did not receive a notification of initiation of injections, any
monitoring data, or a final project evaluation for this permit. According to the noted report, injection of ABC occurred
3/2011. A review of BIMS indicates no injection event record was submitted. Monitoring appears to have been
conducted as proposed in the application, including the construction of additional monitoring well MW-67.
Constituents were all < 2L as of 5/2012 monitoring. Monitoring data is summarized in the 8/14/2013 Quarterly Long -
Term Monitoring Reports.
Feel free to contact me if -you have any questions.
Andrew W. Moore, P.G.
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section.
NCDEQ — Division of Water Resources
828 296 4684 office
email: [e-mail]

2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Lahr and may be disclosed to third parties.
From: Shrestha, Shristi R
Sent: Monday, January 22, 2018 11:14 AM
To: Moore, Andrew W <[e-mail]>
Cc: Davidson, Landon <[e-mail]>
Subject: RE: [External] RE: WI0100067 Brock's Cleaners Facility
Andrew,
There are several other IN -Situ permits that have no Final project evaluation reports. The ones that I have done initial
reviews are W10100089, W10100091 and W10100126.1 sent emails for all these permits . For the first 2 the email
bounced back and the last one I haven't heard back. Can you please let know if you know anything about these sites?
If you have a contact number or a final report that we can look at and close out the permits.
Thank you,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
[e-mail]
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
From: Moore, Andrew W
Sent: Friday, January 19, 2018 9:11 AM
To: Shrestha, Shristi R <[e-mail]>
Cc: Davidson, Landon <[e-mail]>
Subject: RE: [External] RE: W10100067 Brock's Cleaners Facility
Shristi,
Rescindine the subiept infection hermit is acceptable to the ARO. We have reviewed the Julv 31.2011. hermit and

MW-14s as well as conducting the approved monitoring plan. It appears that the Final Project Evaluation was never
submitted to the UIC Program or the ARO, but I was able to find it on laserfiche (attached).
A review of the monitoring data from the Final Project Evaluation indicates that PCE and TCE concentrations were
reduced downgradient of the injection area as a result of the injections. However, PCE and TCE degradation products,
including cis-1,2-dichloroethene and vinyl chloride, were detected downgradient of the injection area at
concentrations higher than 2L and their pre -injection levels during the final monitoring period of the injection permit.
We understand that the facility is still within the DSCA Program and that monitoring is still conducted under the
DSCA Remediation Unit. We understand that additional bedrock injections have occurred at the site under injection
permit WI0100255, which was issued via a deemed permitted status. A review of the October 10, 2016, Groundwater
Monitoring Report indicates that monitoring continues to be conducted downgradient of both injection areas. When/if
the UIC Program sends the permit rescission to the DSCA Program, we request that you recommend that they
continue to monitor downgradient of the injection area to ensure no impacts to potential receptors from the
degradation byproducts.
Feel free to contact me if you would like to discuss further.
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: Andrew.W.Moore0_ncdenr.aov )
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
correspondenceEmail . from this address
North Carolina Public Records Law and may be disclosed to third patties.
From: Shrestha, Shristi R
Sent: Thursday, January 11, 2018 9:52 AM
To: Moore, Andrew W <andrew.w.moore(&ncdenr.gov>; Davidson, Landon <landon.davidson(e,ncdenr. og.v>
Subject: FW: [External] RE: WI0100067 Brock's Cleaners Facility
Good morning,
I have received a rescission request for the facility with the final project evaluation report. Please let me know if ARO
agrees with this request.
Thank you,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shresthaRmcderingov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
Email correspondence to and from this address is subject to the
North Carolina Publir. Racnrds Lain and may lea dikcinsad to third nartiafi_

From: Christie Zawtocki[mailto:CZawtockigharthickman.com]
Sent: Wednesday, January 10, 2018 7:31 AM
To: Shrestha, Shristi R <shristi.shrestha@ncdenr�ov>
Cc: Meyer, Billy <bill y} meyer(a ncdenr.gov>
Subject: [External] RE: WI0100067 Brock's Cleaners Facility
Shristi,
The Brock's Cleaners site is still being managed by the DSCA Program with periodic groundwater monitoring
continuing at the site. I've copied Billy Meyer, the DSCA Program project manager for this site, on this e-mail The
attached report from 2014 provides an evaluation of the injection, and the attached 2016 report provides more recent
groundwater data for the site. Additional injection is not currently planned at this site. Thus, on behalf of the
Petitioner for this site, we request that the permit be rescinded.
Please let me know if you have any questions or need any additional information.
Thanks,
Christie Zawtocki, PE, Principal
Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203
Direct 704-887-4614 1 Mobile [phone] Main 704-586-0007
www.harthickman.com
hart hick a
WATER E��NMUVALSO=045
From: Shrestha, Shristi R [mailto:shristi.shrestha(a ncdenr.govl
Sent: Friday, January 05, 2018 1:01 PM
To: Christie Zawtocki <CZawtocki(a harthickman.com>
Subject: W10100067 Brock's Cleaners Facility
Good afternoon,
We are in the process of closing our expired permit and it looks like Brock's Cleaners with the permit
number W10100067 is one of them. Our records show that the permit expired 2/29/2013. I did not
find any Final Project Evaluation report in our records. If you have a digital copy of the report please
send it to me. Also, let us know what the intent for this facility is. If you want to rescind the permit I
would need a permit rescission request from the owner which can be in the form of an email too.
Please contact me at the number below if you have any questions or concerns regarding this. Thank
you for your cooperation.
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Denartment of Environmental Quality

919 807-6406 office
shristi.shresthaCcDncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
1
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Shrestha, Shristi R
From: Shrestha, Shristi R
Sent: Thursday, August 24, 2017 3:26 PM
To: '[e-mail]'
Subject: WI0100091 Former Ecusta Paper Mill
Good afternoon,
We are in the process of closing our expired permit and it looks like Former Ecusta Paper Mill site with the permit
number W10100091 is also in the list. Our records show that the permit expired 07/31/2012. While going through our
records I didn't find injection records and final project evaluation report. If you have a digital copy of the FPE report
you can send by email too. IER forms can be found in the following link. http://deg.nc.gov/about/divisions/water-
resources/water-resources-permits/wastewater-branch/ground-water-protection/grow nd--water-.reporti ng-forms. If
you want to rescind the permit I would need a permit rescission request from the owner which can be in the form of
an email too.
Please contact me at the number below if you have any questions or concerns regarding this. Thank you for your
cooperation.
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shresthap_ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

5I Final Project Evaluation (FPE) Checklist
Permittee/Applicant: J , v eP L L C &C4�
Permit No.: WI 0 10 f5o c1 1
Reviewer: 5 6 Y-C s 4-r; ck sftla
Date: � JJ 2. st .2-6l 7-
1. Permit issued date: 3 2 & 10 Expiration date: � � �3 f � ZO 12
2. BIMS: Check to see if there is a current renewal Application for this permit number under
review or newer permit issued (search by facility address). If this is case, no FPE is needed at
this time. Al
3. Intent of Permittee for this site (i.e., permit complete and no further injection activities planed,
future injection activities are planned, permit to be renewed,
etc.):
4. FPE or equivalent received? N Date rec'd: If FPE or Al is needed, date
sent: Date received:
5. Proposed monitoring reports received for most part? h/
6. Proposed sampling frequency complied with (e.g, monitored for 4 quarters)?
7. Proposed parameters analyzed?
8. Any clear evidence of daughter products? If evident, RO may want to review.
9. GW-ls or equivalent received? Date: `As Built' well construction info
entered into BIMS? ; Date:
10. Status of injection wells (i.e., active- to be use as monitoring wells, abandoned,
etc.)
11. If abandoned, GW-30s Records received? Date: Status entered/changed into
BIMS? Date:
12. (Note- if we have not received GW-1 s/30s for DPT wells, and obtaining these records is
problematic, injection well status forms (GW-68) may suffice. Bottom line, we need some
kind of a record, even e-mail from the Permittee/consultant, with info on when the well points
were plugged.)
13. Any outstanding NOVs,in BIMS?
14. Completion Letter Sent date: BIMS updated- `Permit Completed'_
Notes:
Revised 9-20-2016

State of North Carolina
Department of Environment and Natural Resources RECEIVED / DENR / DM
Division of Water Quality Aquifer Protection Section
APR 26 2010
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FO INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
• Do not use this form for remediation systems that extract contaminated groundwater, treat it, and reinject the treated groundwater.
• Submit TWO copies of the completed application and all attachments to the address on the last page of this form.
• Any changes made to this form will result in the application packagebeingreturned.
Application Number (to be completed by DWQ)W T dvd—,Cl
I. GENERAL INFORMATION:
1. Applicant's Name (generally the responsible party): Davidson River Village, LLC
2. Signing Official's Name: John B. Hanselman Title: Member
3. Mailing address of applicant: 36 Washington Street, Suite 220
City: Wellesley State: MA Zip: 02481
Telephone number: 781-431-8101 ext 104
Fax number: 781-431-8105
4. Property Owner's Name (if different from Applicant): John B. Hanselman
5. Property Owner's mailing address: Same as above
City:
State: Zip:
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Amar C. Bumb, Ph.D., PE Title: Principal Engineer/Hydrogeologisi
Company: Shaw Environmental & Infrastructure, Inc.
Address: 3 Independence Pointe, Suite 107
City: Greenville State: SC Zip:29615
Telephone number: 864-289-8533 Fax number: 864-254-9286
Email Address: [e-mail]
II. PERMIT INFORMATION:
1. Project is: C! New ❑ Modification of existing permit 7- Renewal of existing permit without modification
❑ Renewal of existing permit with modification
2. If this application is being submitted for renewal or modification to an existing permit, provide:
existing permit number and the issuance date
For renewal without modifications, fill out sections I & II only, sign the certification on the last page of this
form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
For all renewals, you must submit a status report including monitoring.results of all injection activities to
date.
Revised 8/07 UIC-5I/5T Page 1 of 7

III.
I1
APPLICATION FOR PEl ivi T TO CONSTRUCT AND/OR USE A W—kLL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
INCIDENT & FACILITY DATA
FACILITY INFORMATION
1. Facility name: Former Ecusta Paper Mill -- Building 27 Area
2. Complete physical address of the facility:
1 Ecusta Road
City: Brevard
B. INCIDENT DESCRIPTION
C.
• Transylvania State: NC Zip: 28712
1. Describe the source of the contamination:
Building 27 was a former transportation garage for vehicle refueling. Underground storage tanks (USTs) had
been previously removed with no contamination detected at the time of removal. On January 29, 2009 the
demolition contractor (DH Griffin) begin removal of the concrete footers and pits. As they dug down along side of
one of the pits they encountered a strong petroleum odor. Shaw collected a soil sample B27-CR-1 and analyzed
it for VOCs and SVOCs. The results of the sample indicated contamination was present.
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g.,
gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Gasoline with BTEX and naphthalene present
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
❑ Yes If yes, list maximum measured separate phase thickness
feet
❑X No If no, list maximum concentration of total VOCs observed at site: BTEX - 5,431
ppb
4. Agency managing the contamination incident:
❑ UST Section ❑X Superfund Section (including REC Program and DSCA sites)
❑ DWQ Aquifer Protection Section ❑ Solid Waste Section
❑ Hazardous Waste Section ❑X Other: US EPA Region 4, Jennifer Wendell, RPM
5. Incident managers name James Bateson
and phone number 919-508-8449
6. Incident number or other site number assigned by the agency managing the contamination incident:
No incident number has been assigned
PERMITS
List all permits or construction approvals that have been issued for the facility or incident, including those not
directly related to the proposed injection operation:
1. Hazardous Waste Management program permits under RCRA: NCDO03166675
2. DWQ Non -Discharge or NPDES permits: NPDES 0000078
3. County or DEH subsurface wastewater disposal permits:
4. Other environmental permits required by state or federal law:
l//C, ]elm; W T--0 1.0crD'- 7_
Revised 8/07 UIC-5I/5T Page 2 of 7

APPLICATION FOR PER11­�T TO CONSTRUCT AND/OR USE A .,: , �LL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
IV. INJECTION DATA
INJECTION FLUID DATA
List all proposed injectants.
NOTE: Any substance to be injected as a tracer or to promote in situ remediation must be reviewed by the
Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of
Health and Human Services. Review the list of pproved injectantsT or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by OEES.
Injectant: Oxygen Release Compound (ORC) Advanced
Concentration at point of injection: 20 to 50 weight percent slurry
Concentration at point of injection:
Concentration at point of injection:
Concentration at point of injection:
Concentration at point of injection:
2. Source of fluids used to dilute or chase the injectants listed above:
❑ None
I] Municipal water supply
❑ Groundwater from private well or any well within 'Amile of injection site
❑.Air
❑ Other:
3. If any well within'/4 mile of injection site, a private well, or surface water is to be used as the fluid source, supply
the following information:
a. Location/ID number of source: Not Applicable
b. Depth of source:
C.
d. Rock/Sediment type:
e. In Attachment C, provide a current, complete chemical analysis of the water from the source well, including
analyses for all contaminants suspected or historically recognized in soil or groundwater on the site.
NOTE: If contaminated groundwater is to be used as the dilution or chase fluid, this is not the proper permit
application form. You must apply for a closed -loop groundwater remediation permit using gpplicationform
GWRS.
Revised 8/07 UIC-5I/5T Page 3 of 7

I�
'A
APPLICATION FOR PEhiriiT TO CONSTRUCT AND/OR USE A wi�LL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 2
Expected duration of each injection event: 30 days
6�
Expected duration between events (if more than one event): 6 to 12 monthps
2. Injection rate per well: 5.0 gallons per minute (gpm) U j A +A
3. Total Injection volume: 200 (max per pt) gallons per day (gpd), 7,000 gallons per event (if separate events)
4. Injection pressure: 20 pounds/square inch (psi)
5. Temperature at point of injection: 70 OF
6. Brieflv describe how the above parameters will be measured and controlled:
Flow meter and pressure gauge will be used.
7. Estimated hydraulic capacity of the well: 10 (short term) gpin
INJECTION WELL CONSTRUCTION DATA
1. Injection will be via:
❑ Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of
your knowledge.
CAI Proposed well(s) to be constructed for use as an injection well. Provide the data in (2through (6) below as
proposed construction specifications. ��X
2. Well Drilling Contractor's Name: ESN Southeast ��--`�y-"y ° v �? Ft S T-N%
NC Well Contractor Certification number: Allen Merril - NC2004 14VI.1 w,evf-P Cp
%OS' 4-�C fpe U` i- leas c y .vL
3. Date to be constructed: June/July 2010 Number of borings: 40 (max)
Approximate depth of each boring (feet): 14
a�� 6
4. Screened interval/Injection interval of injection wells:
Depth: 5 to 15 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
5. Well casing (N/A if injection is through direct push rods):
Type: ❑ PVC ❑ Stainless steel x❑ Other: Direct -push rods
Casing depth: to ft.
6. Grout (N/A if injection is through direct push rods):
Type: ❑ Cement
Grout depth:
❑ Bentonite
to ft.
0 Other: Direct -push Rods
Revised 8/07 UIC-5I/5T Page 4 of 7

APPLICATION FOR PER<,-"_T TO CONSTRUCT AND/OR USE A,.-. iL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
V. ATTACHMENTS
wide the following items as attachments with the given headings:
A. SITE HISTORY
Provide a brief description of the site history including:
(1) site usage historically and present,
(2) origin of the contamination,
(3) previous remedial action(s).
NOTE: G.S. 89E-18 requires that any geologic plans, reports, or documents in which the performance is related to the
public welfare or safeguarding of the environment be prepared by a licensed geologist or subordinate under his or her
direction. G.S. 89E-13 requires that all drawings, reports, or documents involving geologic work which shall have been
prepared or approved by a licensed geologist or a subordinate under his or her direction be signed and sealed by him or
her.
B. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic description, soils description, and cross section of the subsurface to a depth that includes the
known or projected depth of contamination. The hydrogeologic description shall include:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity, transmissivity, and specific yield of the aquifer to be used for injection, including a
description of the test(s) used to determine these parameters; and
(4) the depth to the mean seasonal high water table.
C. INJECTION FLUID COMPOSITION
Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety
Ja Sheet (MSDS) for each injectant. If a private well or a well within '/4 mile of the injection site is used as the source
�11, include chemical analysis of source fluid here.
D. INJECTION RATIONALE
Attach a brief description of the rationale for selecting the injectants and concentrations proposed for injection, including:
(1) goals of the injection project;
(2) 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; and
(3) summary results of modeling or testing performed to investigate the injectant's potential or susceptibility to change
(biological, chemical or physical) in the subsurface.
E. INJECTION PROCEDURE AND EQUIPMENT
Provide a detailed description of all planned activities related to the proposed injection including but not limited to:
(1) construction plans and materials;
(2) operation procedures;
(3) a detailed diagram of the surface and subsurface portions of the system; and
(4) a planned injection schedule.
F. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to be used;
(2) a list of monitoring parameters and analytical methods to be used; and
(3) a schedule for sampling to monitor the proposed injection.
NOTE: The selected monitoring wells must be located so as to detect any movement of injection fluids, process by-
--Iducts, or formation fluids outside the injection area or zone. The monitoring parameters should include the target
waminants as well as secondary or intermediate contaminants which may result from the injection and other
parameters which may serve to indicate the progress of the intended reactions, such as pH, ORP, dissolved oxygen, and
Revised 8/07 UIC-5I/5T Page 5 of 7

APPLICATION FOR PEkiviir TO CONSTRUCT AND/OR USE A Wir LL(S) FOR INJECTION
Type 51 Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
other electron acceptors and donors. The monitoring schedule should be consistent with the pace of the anticipated
reactions and rate of transport of the injectants and contaminants.
G. WELL DATA
Provide a tabulation of data on all existing or abandoned wells within'/4 mile of the injection well(s) which penetrate the
proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells.
Such data shall include a description of each well's use (water supply, monitoring, etc), total depth, screened or open
borehole depth interval, and well construction or abandonment record, if available.
H. MAPS
Attach the following scaled, site -specific maps:
(1) Area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and
showing the location of the proposed injection site.
(2) Site map including:
a. all property boundaries;
b. all buildings within the property boundary;
c. existing and proposed injection wells or well field(s)
d. any existing sources of potential or known groundwater contamination, including waste storage,
treatment or disposal systems within'/4 mile of the injection well or well system;
e. all surface water bodies within'/4 mile of the injection well or well system; and
f. all existing or abandoned wells within 'A mile of the injection well(s) which penetrate the proposed
injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection
wells.
(3) Potentiometric surface map(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(4) Contaminant plume map(s) including:
a. the horizontal extent of the contaminant plume, including isoconcentration lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(5) Cross-section(s) to the known or projected depth of contamination, including:
a. horizontal and vertical extent of the contaminant plume, including isoconcentration lines
b. major changes in lithology
Revised 8/07 UIC-5I/5T Page 6 of 7

VI.
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
CERTIFICATION
I, John B. Hanselma orsignms, of3iciai) , hereby certify under penalty of law that
I have personally examined and am familiar with the information submitted in this document and all attachments
thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information,
I believe that the information is true, accurate and complete. I am aware that there are significant penalties,
including the possibility of fines and imprisonment, for submitting false information. I agree to construct,
operate, maintain, repair, and if applicable, abandon the injection well(s) and all related appurtenances in
accordance with thelapproved specifications and conditions of the Permit.
iJ
' 1
Signature: ;�� � Date: 4 ci
I
Title: Member
IV
If authorized agent is acting on behalf of the applicant, supply a letter signed by the applicant authorizing the
above agent.
VII. CONSENT OF PROPERTY OWNER (if the property is not owned by the applicant)
("Owner" means any person who holds the fee or other property rights in the well being constructed. A well is
real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement in writing.)
1, John B. Hanselrp,@Qt d „mi,, of xorzrr. owoeri , as owner of the property on which the
injection well(s) are to be constructed and operated, hereby consent to allow the applicant to construct each
injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure
that the injection well(Zconfalto the Well Construction Standards (Title 15A NCAC 2C .0200)
Signature: Date: 1
Title:
Membe/
IV
Submit TWO copies of the completed application package, including all attachments, to:
UIC Program
Aquifer Protection Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
RECEIVED / DENR / DWQ
Aquifer Protection -PQction
APR 26 2010
Revised 8/07 UIC-5I/5T Page 7 of 7

Z
V. ATTACHMENTS
REFERENCES
North Carolina Department of Environment and Natural Resources, 2007, Guidelines forAssessment
and Cleanup, Inactive Hazardous Sites Program, August.
Shaw Environmental Inc., 2007, PhasellEnvironmental Site Assessment, Ecusta Paper Mill, Pisgah
Forest, North Carolina. June 22.
Shaw Environmental Inc., 2008a, Field Sampling Plan, Ecusta Paper Mill, Pisgah Forest, North
Carolina. Rev 1, August.
Shaw Environmental Inc., 2008b, Quality Assurance Project Plan, Ecusta Paper Mill, Pisgah Forest,
North Carolina. Rev 1, August.
Shaw Environmental Inc., 2008c, Site -Specific Health and Safety Plan for Remediation Activities,
Former Ecusta Paper Mill, Pisgah Forest, North Carolina. May.
Shaw Environmental Inc., 2009e, Aquiferpump Test Work Plan, Former Ecusta Paper Mill, Pisgah
Forest, North Carolina. February.
A. SITE HISTORY
The property was first developed in 193 8 as a paper manufacturing plant by Ecusta Paper Company
(Figure 1). In 1949, Olin Industries acquired the facility. Cigarette papers were the only products
manufactured at the facility until the mid- 1950's when cellophane and rayon production was added
with the construction of the film plant. In 1958, printing and lightweight paper production
capabilities were added. A wastewater treatment plant was put into service in 1974, followed by the
installation of the sludge landfill and the ASB in 1976. In 1985, in conjunction with the purchase of
the property by a corporation of former Olin employees, cellophane and rayon production was
discontinued. In 1987, P.H. Glatfelter Company purchased the property which operated the business
until 2001 when PURICO (IOM) Limited purchased the facility, former RFS Ecusta. In 2002, RFS
Ecusta declared bankruptcy and all production ceased. In late 2003, The Ecusta Business
Development Corporation, LLC (EBDC) acquired the facility. Limited production of flax pulp
resumed on site while some of the buildings and warehouse facilities were leased for use by local
businesses. In January 2008, DRV purchased the property from EBDC and demolition activities
started in summer 2008.
UIC Attachments-ECUSTA Bldg 27, Rev l.doc 07/21/10 3:29 PM

2___
Building 27 was a former transportation garage used for vehicle refueling. Underground storage
tanks (USTs) had been previously removed with no contamination detected at the time of removal.
On January 29, 2009 the demolition contractor (DH Griffin) begin removal of the concrete footers
and pit. As they dug down along side of a pit they encountered a. strong petroleum odor. Shaw
collected a soil sample B27-CR-1, which was analyzed for VOCs and SVOCs.
On February 10, 2009, Shaw received the laboratory results indicating high levels of volatiles and
semi volatiles being present. TCRA removal request #6 was submitted to USEPA and NCDENR.
While excavating the maintenance pit on February 11, 2009, affected soil was noted at four feet
below land surface level based on visual observations and soil screening using a PID. Confirmation
soil samples were collected from the excavation walls and floor when PID results were less than 5
ppm. Shaw excavated approximately 280 cubic yards of soil. This soil was stored in Building 89
warehouse for disposal.
Shaw conducted a soil and groundwater investigation in May 2009 to delineate the horizontal and
vertical extent of petroleum hydrocarbons in the area of Building 27. A direct push rig installed 35
soil borings (SB-1 through SB-35) and three monitoring wells MW-35 through MW-37 on May 12-
14, 2009. The excavation, direct push borings, and monitoring wells are shown on Figure 2. PID
readings for the borings and monitoring wells are in Table 1. The soil analytical results for the
borings and monitoring wells are presented in Table 2. Two additional monitoring wells (MW-38
and MW-39) were installed on September 16, 2009 to help further delineate the groundwater plume
at Building 27. The groundwater analytical results for the monitoring wells are presented in Table 3.
B. HYDROGEOLOGIC DESCRIPTION
The subject site is located in the Blue Ridge geologic province adjacent to the Brevard fault zone.
The Brevard fault zone is a linear, southeast -dipping thrust fault that forms the boundary between
the Inner Piedmont geologic belt to the southeast and the Blue Ridge geologic belt to the northwest.
The geology in the vicinity of the site consists of moderate to high grade metamorphic rocks of
middle to late Proterozoic age. The rock units include meta -sedimentary and meta -igneous rocks,
including gneisses, amphibolites, metagabbros, and quartzite schist. According to the Geologic Map
of North Carolina (NCGS, 1985), the site is located within the Brevard fault zone which is
characterized by mylonitic and cataclastic rocks.
The general geologic stratigraphy, based on soil borings and monitoring wells that have been
completed at Building 27 area, is shown on Geologic Cross Section Location Map Figure 3 and the
UIC Attachments-ECUSTA Bldg 27, Rev l.doc 07/21/10 3:29 PM

Cross Section in Figure 4. This cross section provides a general representation of the subsurface
conditions below the area of Building 27 which includes monitoring wells MW-35 through MW-39.
In general, a silty clay is present from ground surface to 3 feet bgs which is underlain by a sand
down to approximately 5 to 8 feet bgs. A gravelly sand is present from 8 feet bgs to 13 feet bgs. A
gray clay (saprolite) is present below the gravelly sand down to weathered rock at the bottom of the
borings. Boring and Well Construction logs from the Building 27 Area are presented in Appendix
A.
The area hydrogeologic setting consists of a vadose or unsaturated zone within the alluvium above
the groundwater table. The groundwater table lies within the alluvium and is recharged by
infiltrating precipitation. The groundwater in the shallow water table aquifer moves horizontally
until it discharges into surface waters. The surface of the water table is typically a subdued replica
of the topographic surface and is generally near the ground surface in streams/valleys (discharge
areas) and is somewhat deeper beneath ridges and hills (recharge areas). Specifically, at the mill it is
expected that shallow groundwater moves under relatively flat gradients with eventual discharge to
the Davidson River.
The occurrence and movement of groundwater in the Inner Piedmont and Blue Ridge provinces is
generally within two separate, but interconnected, water bearing zones. A shallow water -bearing
zone occurs within the saprolite zone, and a deeper zone occurs within the underlying bedrock.
Groundwater in the shallow saprolite zone occurs in the interstitial pore space of the saprolite. The
depth to groundwater in the saprolitic zone can range from 20 to more than 50 feet along ridges and
upland areas. In low lying stream valleys, the groundwater level will approach the local surface
water elevations in stream channels. Groundwater flow in this zone is typically governed by water
table conditions. This means that groundwater will flow under unconfined conditions and generally
mimic the surface topography as modified by highly permeable bedding for underground utilities.
Therefore, groundwater movement will be from upland areas (recharge zones) to nearby surface
streams (discharge zones).
The occurrence and movement of groundwater in the deeper water -bearing zone within crystalline
bedrock is controlled by secondary joints, fractures, and faults within the bedrock. Groundwater
within the bedrock zone may be under confined or unconfined conditions. The occurrence and
movement of groundwater is difficult to predict on a small scale due to the erratic nature of the
secondary openings that control groundwater flow in bedrock. Small surface water features generally
do not provide an accurate indication of the direction of groundwater movement in bedrock.
UIC Attachments-ECUSTA Bldg 27, Rev l.doc 07/21/10 3:29 PM

However, on a regional scale, the direction of groundwater movement will generally be from upland
areas (North) to major surface streams downgradient (South).
Shaw personnel gauged Building 27 area shallow monitoring wells MW-35 through MW-39 on
March 10, 2010 for groundwater elevations (Table 4). The groundwater potentiometric surface for
March 2010 is illustrated on Figure 5-A in the immediate vicinity of Building 27 and on Figure 5-B
for the overall site. The groundwater potentiometric surface map indicated that groundwater flowed
generally toward the southeast at an average hydraulic gradient of 0.013 feet per foot (ft/ft) between
monitoring wells MW-35 and MW-37.
Aquifer Tests
Aquifer tests (slug tests) were conducted at the former Ecusta Mill site from February 24, 2009
through March 6, 2009 in the Caustic Area (approximately 1,000 ft from the former Building 27)
and from March 29, 2010 to April 1, 2010 at the Electrochemical Building (approximately 1,000 ft
from the former Building 27). Rising and falling head slug tests were performed by placing a
LevelTrollTM 700 pressure transducer/datalogger in the monitoring well and recording background
water levels until the water level in the well stabilized. Slug test data (both falling head and rising
head tests) were analyzed to determine hydraulic conductivity values. Slug test analysis results for
the Caustic Area are summarized in Table 5 and for the Electrochemical Building are summarized in
Table 6. The data analysis was performed with the aid of AQTESOLVTM software using the the
Hyder et al. (1994) solution, also known as the KGS Model for slug tests in a partially penetrating
well in an unconfined aquifer.
The hydraulic conductivity for the gravelly clayey sand (above the first clay layer — zone of interest
at Building 27) ranged from 1.05 x 10-4 centimeters per second (cm/sec) (0.30 feet per day [ft/day])
to 1.78 x 10-3 cm/sec (5.05 ft/day) with a geometric mean value of 8.77 x 10-4 cm/sec (2.49 ft/day)."
The geometric mean value of hydraulic conductivity for the clay layer was 1.28 x 10-6 cm/sec (3.63
x 10-3 ft/day).
The hydraulic conductivity for the shallow wells ranged from 1.69 x 10-5 cm/sec (0.048 ft/day) to
1.46 x 10-2 cm/sec (41.4 ft/day) with a geometric mean value of 6.53 x 10-4 cm/sec (1.85 ft/day).
Higher values of hydraulic conductivities were obtained in areas where soils were disturbed during
removal of footings. The hydraulic conductivity variation in undisturbed soils below the
Electrochemical Building range from 1.97 x 10-4 cm/sec (0.56 ft/day) to 1.31 x 10-3 cm/sec (3.71
ft/day). TJ
UIC Attachments-ECUSTA Bldg 27, Rev l.doc 07/21/10 3:29 PM

Groundwater Flow Rate
Groundwater flow rate (VGW) was calculated using the equation:
VGW=KI/0e
Where "K" is the hydraulic conductivity, "I" if the hydraulic gradient, and 0e is the effective
porosity. Using effective porosity value of 20 percent, average hydraulic gradient of 0.013 ft/ft, and
geometric mean value of hydraulic conductivity for the caustic area, the groundwater velocity in the
shallow zone was calculated to be 59.1 feet per year (ft/yr). When geometric mean value of
hydraulic conductivity for the Electrochemical Building was used, the groundwater velocity in the
shallow zone was calculated to be 43.9 ft/yr. Therefore, the range of groundwater flow rate at
Building 27 is estimated to be 43.9 to 59.1 ft/yr.
C. INJECTION FLUID COMPOSITION
ORC Advanced will be used for injection. The Material Safety Data Sheet (MSDS) for the ORC
Advanced is included in Appendix B.
D. INJECTION RATIONALE
The purpose of this corrective action is for the completion of the project remediation activities and
meet the requirements as described in the 5A NCAC 02L regulations, commonly known as the
Groundwater 2L Standards, which require groundwater BTEX concentrations to be at 1.0 µg/L for
benzene, 550 µg/L for ethylbenzene, 530 µg/L for xylenes, and 21 g/L for naphthalene. All other
petroleum hydrocarbon constituents are currently below the Groundwater 2L Standards.
The benzene, toluene, ethylbenzene, and total xylenes (BTEX) groundwater contamination are
shown on Figure 6 surrounding Building 27 area. The objective of this remediation of Building 27
area groundwater is to supply controlled release of molecular oxygen to the subsurface environment
where it will accelerate the rate of naturally occurring aerobic biodegradation of petroleum
hydrocarbons in groundwater and saturated soils for periods of up to 12 months (on a single
application). ORC AdvancedTM is one such commercially available product to provide controlled
release of oxygen. After the reaction of magnesium oxides in ORC Advanced with water to form
oxygen, the resulting material, magnesium hydroxide, is mildly basic. The amounts of magnesium
oxide and magnesium hydroxide in the initial product have an effect similar to lime, but with lower
UIC Attachments-ECUSTA Bldg 27, Rev l.doc 07/21/10 3:29 PM

6
alkalinity.
The amount of ORC Advanced needed is a function of groundwater BTEX concentrations and
amount of residual BTEX in soil. The maximum concentrations observed were 101 µg/L for
benzene, 1120 µg/L for ethylbenzene, 3,952 µg/L for xylenes, and 221 µg/L for naphthalene. For
relatively low level of contamination observed at Building 27 and 15-foot injection spacing and
approximately 7 feet of saturated zone, a dosage rate of 46 lbs/liner ft of saturated zone was
calculated (see attached calculation). Therefore, 50 lbs of ORC Advanced will be used per injection
point.
ORC Advanced TM is a product of Regenesis and is a NCDENR approved chemical oxidation
compound for concentration reduction of petroleum hydrocarbon constituents in groundwater.
E. INJECTION PROCEDURE AND EQUIPMENT
ORC Advanced is typically applied using direct injection techniques. This process requires ORC
Advanced to be mixed with water to form injectable slurry which is then pressure injected using a
pump to the zone of contamination. Once in the aquifer, tiny ORC Advanced particles can sorb to
and/or reside in the soil matrix and produce a controlled release of oxygen for periods up to 12
months.
Grid Injection Layout
The groundwater in the area of Building 27 where the BTEX and naphthalene in groundwater are
higher than the Groundwater 2L Standards will be treated by means of injecting 50 lbs of ORC
Advanced in approximately 200 gallons of water in each of the injection points into the
groundwater. The radius of influence for injection is estimated to be approximately 10 to 15 feet
based on the average hydraulic conductivity of shallow gravelly clayey sand zone is 8.77 x 104
cm/sec (2.49 ft/day). Therefore, 15 -foot spacing for injection points will be used. Approximately 31
injection points will advance to 14 ft-bgs to the top of the clay for injections. Figure 7 shows the
injection points for groundwater remediation.
Injection
ORC Advanced slurry will be injected using DPT. Injection points with 5-foot screens will be
advanced to the top of the clay and retrieved back one foot before injection to start. Within the
UIC Attachments-ECUSTA Bldg 27, Rev l.doc 07/21/10 3:29 PM

source zone, temporary injection points will be used to facilitate injection. A manifold system will
be used and the ORC Advanced slurry will be pumped into groundwater using a day tank and a
pump. The amount of slurry needed for the next 30-minute will be prepared in the day tank using
portable water and ORC Advanced in powder form. Injection rate will be monitored and adjusted to
ensure that temporary mound at injection points does not result in surface runoff of the ORC
Advanced slurry. Injections will start from the edge of the plume and progress inwards. This will
ensure that as groundwater is displaced, it will pass through the treatment zone and groundwater will
be reduced to less than the Groundwater 2L Standards for the BTEX constituents.
Potential Rebound and Additional Treatment
Chemical oxidation is a very slow reaction and requires contact between the reagent and impacted
soil/groundwater. Contact with groundwater in the dead-end pores or in low permeability clayey
soils is limited by slow diffusion processes. Therefore, there is a possibility, especially in the source
areas, groundwater BTEX concentrations might increase 6 to 12 months after the injection of the
ORC Advanced slurry. Should groundwater BTEX concentrations increase to greater than the
Groundwater 2L Standards for the BTEX constituents, a second treatment may be required. If
second treatment is required, the ORC Advanced slurry will be reinjected in the affected areas.
F. MONITORING PLAN
Accurate delineation of impacted BTEX affected groundwater, an understanding of subsurface
conditions and characteristics, and identification of impacted groundwater migration rates and
direction are critical for evaluating the occurrence of natural attenuation, for designing reagent
application to reduce the BTEX values, and for establishing regulatory support for its use at a site.
These data are available. Therefore, no new monitoring wells are required. Existing monitoring
wells at the Site will be utilized for monitoring the progress of in -situ remediation.
Baseline Sampling
Monitoring wells in Building 27 area were sampled in March 2010. The results of March 2010
groundwater sampling will be considered as the baseline sampling event.
Groundwater Monitoring Frequency and Duration
Post injection sampling will start one quarter after the injections have been completed. Groundwater
BTEX and naphthalene sampling will be performed on a quarterly basis. Groundwater sampling
will continue until groundwater 2L standards are met, which is estimated to be approximately one
UIC Attachments-ECUSTA Bldg 27, Rev Ldoc 07/21/10 3:29 PM

1
year. In addition to groundwater BTEX and naphthalene laboratory analysis, water levels will be
recorded for all monitoring wells on a quarterly basis.
Closure Plan
After the BTEX and naphthalene remediation goals have been confirmed for two consecutive
quarters, a final groundwater remediation closure report will be prepared. Upon approval of the final
report by the USEPA and NCDENR, existing monitoring wells will be abandoned.
G. WELL DATA
All wells within 1/4-mile of the caustic area are monitoring wells. See Figure 1 and Table 1 for
the requested information.
H. MAPS
Please see attached Figures 1 through 7.
UIC Attachments-ECUSTA Bldg 27, Rev I.doc 07/21/10 3:29 PM

M
Table 3
Summary of Detected Analytes in Groundwater Samples from Building 27 Area
Former Ecusta Paper Mill Site, Brevard, NC
Analyte
Groundwater
2L Standard
MW-11
MW-35
Date Sampled
6/19/2009
10/29/2009
3/10/2010
6/19/2009
6/19/2009 FD
20/20/2009
3/9/2010
3/9/2010 FD
pH
6.5 to 8.5
6.17
6.24
6.61
5.41
5.41
5.94
6.40
6.40
Turbidity (NTU)
in high metals
6.50
8.70
3.00
0.50
0.50
1.40
4.60
4.60
METALS
Aluminum
NE
ND
144
165
ND
ND
134
116
131
Arsenic
50
ND
ND
ND
ND
ND
ND
ND
ND
Barium
2,000
42.1
57.6
42.8
63.2
59.3
60.2
32.8
35.7
Calcium
NE
28,200
43,700
30,600
28500
26800
62,800
43,200
47,200
Cobalt
NE
ND
ND
ND
9.5
7.5
ND
ND
ND
I o
300
MK4f 60
587
M_ 5'870
84.2
92.0
58.2
106
118
Magnesium
NE
5,330
6,090
6,900
10600
9920
19,900
14,600
15,700
9 anew
50
JNK2 51♦
ND
�f3�
ND
E3
ND
t69T0M
ND
ND
14
11.5
12.7
Potassium
NE
ND
ND
ND
Sodium
NE
7,000
18,100
9,140
17100
16100
18,400
10,700
11,600
Vanadium
NE
ND
ND
ND
ND
ND
ND
ND
ND
Zinc
1,050
ND
ND
17.9
--qD-J
ND
ND
ND
ND
Mercury
1.05
ND
ND
0.28
ND
ND
ND
ND
ND
VOCs
Benzene
1
ND
ND
ND
ND
ND
ND
ND
ND
cis-1,2-Dichloroethene
70
ND
ND
ND
ND
ND
ND
ND
ND
Eth (benzene
550
ND
ND
1.2
ND
ND
ND
ND
ND
p-Isopropyltoluene
NE
ND
ND
ND
ND
ND
ND
ND
ND
Methylene Chloride
4.6
ND
ND
ND
ND
ND
ND
ND
ND
Naphthalene
21
ND
ND
ND
ND
ND
ND
ND
ND
Toluene
1,000
ND
ND
ND
ND
ND
ND
ND
ND
m&p-X lene
530
ND
I ND
2.9
ND
ND
ND
ND
ND
o-Xylene
530
ND
ND
ND
ND
ND
ND
ND
ND
SVOCs
1-Meth (naphthalene
2-Methyl nahthalene
NE
ND
ND
ND
ND
ND
I ND
ND
ND
14
ND
ND
ND
ND
ND
ND
ND
ND
Naphthalene
21
ND
ND
ND
ND
ND
ND
ND
ND
All concentrations are in micrograms per liter (ug/L).
ND - not detected
NE - not established and/or not applicable
R -- Rejected as methylene chloride was detected in the method blank at 7.4 ug/L.
.® Exceeds 2L standards
Page 1 of 2

Table 3 (Cont.)
Summary of Detected Analytes in Groundwater Samples from Building 27 Area
Former Ecusta Paper Mill Site, Brevard, NC
Analyte
Groundwater
2L Standard
MW-36
MW-37
MW-38
MW-39
Date Sampled
6/19/2009
10/21/2009
3/9/2010
6/19/2009
10/21/2009
3/10/2010
10/22/2009
3/10/2010
10/22/2009
3/10/2010
pH
6.5 to 8.5
6.20
6.08
6.22
5.49
5.86
6.44
6.23
6.61
6.00
6.47
Turbidity (NTU)
in high metals
5.80
5.10
3.80
1.10
5.30
3.90
3.90
2.00
0.30
2.40
METALS
Aluminum
NE
153
233
ND
ND
ND
143
254
ND
ND
ND
Arsenic
50
13.1
8.1
7.5
ND
ND
ND
10.3
8.1
ND
ND
Barium
2,000
96.0
68.7
50.9
77.8
55.7
42.7
30.1
26.2
44.5
41.7
Calcium
NE
28200
19,700
31,800
23100
22,900
23,800
28,400
24,400
25,200
29,200
Cobalt
NE
28.5
5.2
ND
17.2
ND
ND
5A
ND
ND
ND
Iron
300
27700
20,300
20,500
16100
12,800
12,600
10,000
8,780
9,770
8,160
Magnesium
NE
6800
5,380
8,350
8110
6,690
6,600
5,940
5,050
5,990
6,600
Manganese
50
471
367
387
223
175
171
909
459
330
245
Potassium
NE
ND
ND
ND
ND
ND
ND
ND
ND
5,440
5,340
Sodium
NE
19800
20,100
19,800
10700
11,700
13,500
7,350
6,430
9,000
6,970
Vanadium
NE
7.0
5.4
ND
ND
ND
ND
ND
ND
ND
ND
Zinc
1,050
ND
ND
ND
ND
ND
ND
11.8
ND
ND
ND
Mercury
1.05
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
VOCs
Benzene
1
101
39.5
54.2
ND
ND
ND
6.8
1.9
ND
ND
cis-1,2-Dichloroethene
70
ND
ND
ND
1.2
ND
ND
ND
ND
ND
ND
Eth (benzene
550
1120
961
649
ND
1.3
1.6
1 4
2.1
ND
1.5
p-Isopropyltoluene
NE
ND
ND
23.9
ND
ND
ND
ND
ND
ND
ND
Methylene Chloride
4.6
61.5 R
ND
ND
ND
ND
ND
ND
ND
ND
ND
Naphthalene
21
179
221
155
ND
ND
7.0
7.8
6.1
37.7
12.8
Toluene
1,000
258
110
ND
ND
ND
ND
ND
ND
ND
m&p-X lene
530
3260
1560lal
ND
2.1
4.1
5.7
5.2
2.5
3.6
o-Xylene
530
692
339
ND
ND
ND
ND
ND
ND
ND
SVOCs
1-Meth (naphthalene
2-Meth Ina hthalene
NE
ND
11
ND
ND
ND
ND
ND
ND
ND
26
ND
14
ND
ND
ND
ND
ND
ND
ND
32
ND
Naphthalene
21
52.3
ND
74.5
ND
ND
ND
ND
ND
17
ND
All concentrations are in micrograms per liter (ug/L).
ND - not detected
NE - not established and/or not applicable
R -- Rejected as methylene chloride was detected in the method blank at 7.4 ug/L.
Exceeds 2L standards
Page 2 of 2

� 1
V. AT]
CHMENTS
North Carolina DepaNment of Environment and Natural Resources, 2007,
and Cleanup, Inactive Wazardous Sites Program, August.
Shaw Environmental Inc., N07, Phase HEnvironmental Site Assessment,
Forest, North Carolina. June 2.
Shaw Environmental Inc., 200M, eld Sampling Plan, Ecusta
Carolina. Rev 1, August.
for Assessment
Paper Mill, Pisgah
Pisgah Forest, North
Shaw Environmental Inc., 2008b, Quah'W Assurance PrIaSa�fetoy
, Ecusta Paper Mill, Pisgah Forest,
North Carolina. Rev 1, August. .
Shaw Environmental Inc., 2008c, Site-Speci Health Planfor Remediation Activities,
Former Ecusta Paper Mill, Pisgah Forest, Nort Carol
Shaw Environmental Inc., 2009e, Aquifer pump
Forest, North Carolina. February.
A. SITE HISTORY
Work Plan, Former Ecusta Paper Mill, Pisgah
The property was first developed in 93 8 as a paper manufacturin lant by Ecusta Paper Company
(Figure 1). In 1949, Olin Indust 'es acquired the facility. Cigarette apers were the only products
manufactured at the facility u 1 the mid- 1950's when cellophane and on production was added
with the construction of e film plant. In 1958, printing and light eight paper production
capabilities were added. wastewater treatment plant was put into service in 974, followed by the
installation of the slu e landfill and the ASB in 1976. In 1985, in conjunction ith the purchase of
the property by a rporation of former Olin employees, cellophane and rayo roduction was
discontinued. In 87, P.H. Glatfelter Company purchased the property which operat d the business
until 2001 w n PURICO (IOM) Limited purchased the facility, former RFS Ecusta. I 2002, RFS
Ecusta de ared bankruptcy and all production ceased. In late 2003, The Ecusta usiness
Develo ent Corporation, LLC (EBDC) acquired the facility. Limited production of fla pulp
res d on site while some of the buildings and warehouse facilities were leased for use by cal
;ses. In January 2008, DRV purchased the property from EBDC and demolition activi
in summer 2008.
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36 AM

Building 27 was a former transportation garage used for vehicle refueling. Underground storage
tanks (USTs) had been previously removed with no contamination detected at the time of removal.
On January 29, 2009 the demolition contractor (DH Griffin) begin removal of the concrete footers
and pit. As they dug down along side of a pit they encountered a strong petroleum odor. Shaw
collected a soil sample B27-CR-1, which was analyzed for VOCs and SVOCs.
On February 10, 2009, Shaw received the laboratory results indicating high levels of volatiles and .
semi volatiles being present. TCRA removal request #6 was submitted to USEPA and NCDENR.
While excavating the maintenance pit on February 11, 2009, affected soil was noted at four feet
below land surface level based on visual observations and soil screening using a PID. Confirmation
soil samples were collected from the excavation walls and floor when PID results were less than 5
ppm. Shaw excavated approximately 280 cubic yards of soil. This soil was stored in Building 89
warehouse for disposal.
Shaw conducted a soil and groundwater investigation in May 2009 to delineate the horizontal and
vertical extent of petroleum hydrocarbons in the area of Building 27. A direct push rig installed 3 5
soil borings (SB-1 through SB-35) and three monitoring wells MW-35 through MW-37 on May 12-
14, 2009. The excavation, direct push borings, and monitoring wells are shown on Figure 2. PID
readings for the borings and monitoring wells are in Table 1. The soil analytical results for the
borings and monitoring wells are presented in Table 2. Two additional monitoring wells (MW-38
and MW-39) were installed on September 16, 2009 to help further delineate the groundwater plume
at Building 27. The groundwater analytical results for the monitoring wells are presented in Table 3.
B. HYDROGEOLOGIC DESCRIPTION
The subject site is located in the Blue Ridge geologic province adjacent to the Brevard fault zone.
The Brevard fault zone is a linear, southeast -dipping thrust fault that forms the boundary between
the Inner Piedmont geologic belt to the southeast and the Blue Ridge geologic belt to the northwest.
The geology in the vicinity of the site consists of moderate to high grade metamorphic rocks of
middle to late Proterozoic age. The rock units include meta -sedimentary and meta -igneous rocks,
including gneisses, amphibolites, metagabbros, and quartzite schist. According to the Geologic Map
of North Carolina (NCGS, 1985), the site is located within the Brevard fault zone which is
characterized by mylonitic and cataclastic rocks.
The general geologic stratigraphy, based on soil borings and monitoring wells that have been
completed at Building 27 area, is shown on Geologic Cross Section Location Map Figure 3 and the
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36 AM

Cross Section in Figure 4. This cross section provides a general representation of the subsurface
conditions below the area of Building 27 which includes monitoring wells MW-35 through MW-39.
In general, a silty clay is present from ground surface to 3 feet bgs which is underlain by a sand
down to approximately 5 to 8 feet bgs. A gravelly sand is present from 8 feet bgs to 13 feet bgs. A
gray clay (saprolite) is present below the gravelly sand down to weathered rock at the bottom of the
borings. Boring and Well Construction logs from the Building 27 Area are presented in Appendix
A.
The area hydrogeologic setting consists of a vadose or unsaturated zone within the alluvium above
the groundwater table. The groundwater table lies within the alluvium and is recharged by
infiltrating precipitation. The groundwater in the shallow water table aquifer moves horizontally
until it discharges into surface waters. The surface of the water table is typically a subdued replica
of the topographic surface and is generally near the ground surface in streams/valleys (discharge
areas) and is somewhat deeper beneath ridges and hills (recharge areas). Specifically, at the mill it is
expected that shallow groundwater moves under relatively flat gradients with eventual discharge to
the Davidson River.
The occurrence and movement of groundwater in the Inner Piedmont and Blue Ridge provinces is
generally within two separate, but interconnected, water bearing zones. A shallow water -bearing
zone occurs within the saprolite zone, and a deeper zone occurs within the underlying bedrock.
Groundwater in the shallow saprolite zone occurs in the interstitial pore space of the saprolite. The
depth to groundwater in the saprolitic zone can range from 20 to more than 50 feet along ridges and
upland areas. In low lying stream valleys, the groundwater level will approach the local surface
water elevations in stream channels. Groundwater flow in this zone is typically governed by water
table conditions. This means that groundwater will flow under unconfined conditions and generally
mimic the surface topography as modified by highly permeable bedding for underground utilities.
Therefore, groundwater movement will be from upland areas (recharge zones) to nearby surface
streams (discharge zones).
The occurrence and movement of groundwater in the deeper water -bearing zone within crystalline
bedrock is controlled by secondary joints, fractures, and faults within the bedrock. Groundwater
within the bedrock zone may be under confined or unconfined conditions. The occurrence and
movement of groundwater is difficult to predict on a small scale due to the erratic nature of the
secondary openings that control groundwater flow in bedrock. Small surface water features generally
do not provide an accurate indication of the direction of groundwater movement in bedrock.
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36 AM

q
However, on a regional scale, the direction of groundwater movement will generally be from upland
areas (North) to major surface streams downgradient (South).
Shaw personnel gauged Building 27 area shallow monitoring wells MW-35 through MW-39 on
March 15, 2010 for groundwater elevations (Table 4). The groundwater potentiometric surface on
March 15, 2010 is illustrated on Figure 5. The groundwater potentiometric surface map indicated
that groundwater flowed generally toward the southeast at an average hydraulic gradient of 0.013
feet per foot (ft/ft) between monitoring wells MW-35 and MW-37.
Aquifer Tests
Aquifer tests (slug tests) were conducted at the former Ecusta Mill site from February 24, 2009
through March 6, 2009 in the Caustic Area (approximately 1,000 ft from the former Building 27).
Monitoring wells MW-1 through MW-4, MW-16/S/1/D, and PZ-30A/B/C through PZ-34A/B/C in
the caustic area near former Building 70 were selected for slug testing to determine general
hydraulic conductivity distribution at the site. Rising and falling head slug tests were performed by
placing a LevelTrollTM 700 pressure transducer/datalogger in the monitoring well and recording
background water levels until the water level in the well stabilized. Slug test data (both falling head
and rising head tests) were analyzed to determine hydraulic conductivity values. Slug test analysis
results are summarized in Table 5. The data analysis was performed with the aid of AQTESOLVTM
software using the the Hyder et al. (1994) solution, also known as the KGS Model for slug tests in a
partially penetrating well in an unconfined aquifer. The hydraulic conductivity for the gravelly
clayey sand (above the first clay layer — zone of interest at Building 27) ranged from 1.05 x 10-4
centimeters per second (cm/sec) (0.30 feet per day [ft/day]) to 1.78 x 10-3 cm/sec (5.05 ft/day) with
an geometric mean value of 8.77 x 104 cm/sec (2.49 ft/day). The geometric mean value of hydraulic
conductivity for the clay layer was 1.28 x 10-6 cm/sec (3.63 x 10-3 ft/day). The geometric mean
value of hydraulic conductivity for the sandy/gravelly zones within the clay layer was 1.11 x 10-5
cm/sec (3.15 x 10-2 ft/day).
C. INJECTION FLUID COMPOSITION
ORC Advanced will be used for injection. The Material Safety Data Sheet (MSDS) for the ORC
Advanced is included in Appendix B.
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36 AM

D. INJECTION RATIONALE
The purpose of this corrective action is for the completion of the project remediation activities and
meet the requirements as described in the 5A NCAC 02L regulations, commonly known as the
Groundwater 2L Standards, which require groundwater BTEX concentrations to be at 1.0 µg/L for
benzene, 550 µg/L for ethylbenzene, 530 µg/L for xylenes, and 21 g/L for naphthalene. All other
petroleum hydrocarbon constituents are currently below the Groundwater 2L Standards.
'."! The benzene, toluene, ethylbenzene, and total xylenes (BTEX) groundwater contamination are
shown on Figure 6 surrounding Building 27 area. The objective of this remediation of Building 27
area groundwater is to supply controlled release of molecular oxygen to the subsurface environment
where it will accelerate the rate of naturally occurring aerobic biodegradation of petroleum
hydrocarbons in groundwater and saturated soils for periods of up to 12 months (on a single
application). ORC AdvancedTM is one such commercially available product to provide controlled
release of oxygen. After the reaction of magnesium oxides in ORC Advanced with water to form
oxygen, the resulting material, magnesium hydroxide, is mildly basic. The amounts of magnesium
oxide and magnesium hydroxide in the initial product have an effect similar to lime, but with lower
alkalinity.
The amount of ORC Advanced needed is a function of groundwater BTEX concentrations and
amount of residual BTEX in soil. The maximum concentrations observed were 101 µg/L for
benzene, 1120 µg/L for ethylbenzene, 3,952 µg/L for xylenes, and 221 µg/L for naphthalene. For
relatively low level of contamination observed at Building 27 and 15-foot injection spacing and
approximately 7 feet of saturated zone, a dosage rate of 46 lbs/liner ft of saturated zone was
calculated (see attached calculation). Therefore, 50 lbs of ORC Advanced will be used per injection
point.
ORC AdvancedTM is a product of Regenesis and is a NCDENR approved chemical oxidation
compound for concentration reduction of petroleum hydrocarbon constituents in groundwater.
E. INJECTION PROCEDURE AND EQUIPMENT
ORC Advanced is typically applied using direct injection techniques. This process requires ORC
Advanced to be mixed with water to form injectable slurry which is then pressure injected using a
pump to the zone of contamination. Once in the aquifer, tiny ORC Advanced particles can sorb to
- and/or reside in the soil matrix and produce a controlled release of oxygen for periods up to 12
months.
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36 AM

M
Grid Injection Layout
The groundwater in the area of Building 27 where the BTEX and naphthalene in groundwater are
higher than the Groundwater 2L Standards will be treated by means of injecting 50 lbs of ORC
Advanced in approximately 200 gallons of water in each of the injection points into the
groundwater. The radius of influence for injection is estimated to be approximately 10 to 15 feet
based on the average hydraulic conductivity of shallow gravelly clayey sand zone is 8.77 x 10-4
cm/sec (2.49 ft/day). Therefore,l5-foot spacing for injection points will be used. Approximately 31
injection points will advance to 14 ft-bgs to the top of the clay for injections. Figure 7 shows the
injection points for groundwater remediation.
Injection
ORC Advanced slurry will be injected using DPT. Injection points with 5-foot screens will be
advanced to the top of the clay and retrieved back one foot before injection to start. Within the
source zone, temporary injection points will be used to facilitate injection. A manifold system will
be used and the ORC Advanced slurry will be pumped into groundwater using a day tank and a
pump. The amount of slurry needed for the next 30-minute will be prepared in the day tank using
portable water and ORC Advanced in powder form. Injection rate will be monitored and adjusted to
ensure that temporary mound at injection points does not result in surface runoff of the ORC
Advanced slurry. Injections will start from the edge of the plume and progress inwards. This will
ensure that as groundwater is displaced, it will pass through the treatment zone and groundwater will
be reduced to less than the Groundwater 2L Standards for the BTEX constituents.
Potential Rebound and Additional Treatment
Chemical oxidation is a very slow reaction and requires contact between the reagent and impacted
soil/groundwater. Contact with groundwater in the dead-end pores or in low permeability clayey
soils is limited by slow diffusion processes. Therefore, there is a possibility, especially in the source
areas, groundwater BTEX concentrations might increase 6 to 12 months after the injection of the
ORC Advanced slurry. Should groundwater BTEX concentrations increase to greater than the
Groundwater 2L Standards for the BTEX constituents, a second treatment may be required. If
second treatment is required, the ORC Advanced slurry will be reinjected in the affected areas.
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36 AM

7-
F. MONITORING PLAN
Accurate delineation of impacted BTEX affected groundwater, an understanding of subsurface
conditions and characteristics, and identification of impacted groundwater migration rates and
direction are critical for evaluating the occurrence of natural attenuation, for designing reagent
application to reduce the BTEX values, and for establishing regulatory support for its use at a site.
These data are available. Therefore, no new monitoring wells are required. Existing monitoring
wells at the Site will be utilized for monitoring the progress of in -situ remediation.
Baseline Sampling
Monitoring wells in Building 27 area were sampled in March 2010. The results of March 2010
groundwater sampling will be considered as the baseline sampling event.
Groundwater Monitoring Frequency
Groundwater BTEX and naphthalene sampling will be performed on a quarterly basis. In addition to
groundwater BTEX and naphthalene laboratory analysis, water levels will be recorded for all
monitoring wells on a quarterly basis.
Closure Plan
After the remediation BTEX and naphthalene goals have been confirmed for two consecutive
quarters, a final groundwater remediation closure report will be prepared. Upon approval of the final
report by the USEPA and NCDENR, existing monitoring wells will be abandoned.
G. WELL DATA
All wells within t/4-mile of the caustic area are monitoring wells. See Figure 1 and Table 1 for
the requested information.
H. MAPS
Please see attached Figures 1 through 7.
UIC Attachments-ECUSTA Bldg 27.doc 04/05/10 10:36 AM

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• I i 1

Tables
UIC Attachments-ECUSTA Bldg 27.doc 03/26/10 8:42 AM

Table 1
PID Data for DPT Borings
Ecusta Building 27 Area
Boring
Date
Highest PID
Reading (PPM)
Depth of
Measurement
(ft-bgs)
Submitted for
VOC & Lead
Analysis
SB-1
05/12/09
0.0
10.0
SB-2
05/12/09
0.7
7.5
SB-3
05/12/09
0.4
10.0
SB-4
05/12/09
100
10.0
SB-5
05/12/09
177
10.0
SB-6
05/12/09
1.6
10.0
SB-7
05/12/09
110
10.0
SB-8
05/12/09
0.8
5.0
SB-9
05/12/09
5.3
10.0
SB-10
05/12/09
29.7
2.5
SB-11
05/12/09
1.7
10.0
SB-12
05/12/09
2.2
2.5
SB-13
05/12/09
0.2
10.0
SB-14
05/12/09
0.6
2.5
SB-15
05/12/09
0.7
10.0
SB-16
05/12/09
1.2
7.5
SB-17
05/12/09
1.6
5.0
SB-18
05/12/09
1.6
7.5
SB-19
05/13/09
0.8
10.0
SB-20
05/13/09
0.7
5.0
SB-21
05/13/09
0.8
10.0
SB-22
05/13/09
10.6
5.0
SB-23
05/13/09
4.6
5.0
SB-24
05/13/09
4.6
5.0
SB-25
05/13/09
8.4
10.0
SB-26
05/13/09
5.6
7.5
SB-27
05/13/09
5.5
10.0
SB-28
05/13/09
2.8
5.0
SB-29
05/13/09
1609
10.0
SB-30
05/13/09
1681
7.5
SB-31
05/13/09
15.7
7.5
SB-32
05/13/09
10.5
7.5
SB-33
05/13/09
352
10.0
SB-34
05/13/09
47.3
7.5
SB-35
05/13/09
33.5
10.0
MW-35
05/14/09
7.9
10.0
MW-36
05/14/09
1655
10.0
MW-37
05/14/09
4.4
10.0
Note: ft-bgs = feet below ground surface
Page 1 of 1

Table 2: Summary of Soil Analytical Results
Building 27 Area
Sample
ID
Sample
depth
(ft. bgs)
Date
Sampled
B T E X
Naphthalene
(mg/kg)
Benzene
(mg/kg)
Toluene
(mg/kg)
Ethylbenzene
(mg/kg)
Xylenes
(mglkg)
Residential Soil Cleanup Levels
18
3200
1560
3129
313
B27-SB4
7.5-10
5/12/2009
ND
ND
ND
ND
0.503
B27-SB5
7.5-10
5/12/2009
ND
ND
ND
ND
18.80
B27-SB-22
2.5-5
5/13/2009
ND
ND
ND
ND
ND
B27-SB-24
7.5-10
5/13/2009
ND
ND
ND
ND
ND
B27-SB-29
2.5-5
5/13/2009
ND
ND
0.469
4.022
0.482
B27-SB-30
5-7.5
5/12/2009
ND
ND
23.80
10.63
191.5
B27-SB-31
5-7.5
5/13/2009
ND
ND
ND
ND
ND
B27-MW-35
7.5-10
5/13/2009
ND
ND
ND
ND
ND
B27-MW-37
7.5-10
5/13/2009
ND
ND
ND
ND
0.048
Notes:
ft bgs = feet below ground surface
mg/kg = milligrams per kilogram
ND = not detected

Table 3: Summary of Groundwater Analytical Results
Building 27 Area
Sample
Location
Date
Sampled
B T E X
Naphthalene
u L
Benzene
u /L
Toluene
u /L
Ethylbenzene
u L
Xylenes
u /L
NCDENR 2L Standards
1
1000
550
530
21
MW-11
6/19/2009
ND
ND
ND
ND
ND
10/20/2009
ND
ND
ND
ND
ND
3/10/2010
ND
ND
1.2
2.9
ND
MW-35
6/19/2009
ND
ND
ND
ND
ND
10/20/2009
ND
ND
ND
ND
ND
3/9/2010
ND
ND
ND
ND
ND
MW-36
6/19/2009
101
258
1120
3952
179
10/21/2009
39.5
110
961
1899
221
3/9/2010
54.2
129
649
1994
155
MW-37
6/19/2009
ND
ND
ND
ND
ND
10/21/2009
ND
ND
1.3
2.1
ND
3/11/2010
ND
ND
1.6
4.1
7.0
MW-38
10/21/2009
6.8
ND
1.4
5.7
7.8
3/10/2010
1.9
ND
2.1
5.2
6.1
M W-39
10/21/2009
ND
ND
ND
2.5
37.7
3/10/2010
ND
ND
1.5
3.6
12.8
Notes:
Exceeds NCDENR 2L Standards
ug/L = micrograms per liter
NCDENR = Norht Carolina Department of Environment and Natural Resources
ND = not detected

Table 4: Potentiometric Elevations
Building 27 Area
Well
Location
Date
Gauged
TOC
Elevation
(ft)
Depth to
Water
(ft)
- Water
Elevation
(ft)
Depth to
Product
(ft)
Product
Elevation
(ft)
MW-11
3/10/2010
2120.98
8.40
2112.58
ND
N/A
MW-35
3/10/2010
2120.71
7.66
2113.05
ND
N/A
MW-36
3/10/2010
2121.36
9.40
2111.96
ND
N/A
MW-37
3/10/2010
2120.05
9.33
2110.72
ND
N/A
MW-38
3/10/2010
2121.20
10.20
2111.00
ND
N/A
MW-39
3/10/2010
2121.45
10.38
2111.07
ND
N/A
Notes:
TOC = Top of casing: elevations relative to a set datum
ft = feet
ND = Not Detected
N/A = Not Applicable

Table 5
Summary of Slug Test Results
Ecusta Caustic Spill Area
Srevard, North Carolina
Monitoring
Well
Depth of
Screen
(ft-bgs)
Height of
Water
Column in
Well (feet)
Depth to
Top of Clay
(feet)
Lithology
Across Screened
Interval
Hydraulic Conductivity (cmis)
Groundwater
Flow Rate
(ft/year)
Falling Head Test
Rising Head Test
Geometric
Mean
Wells Screened above the first Clay Layer (Sa rolite)
9.8'-19.8'
I3.49
NM
Sand/clay1.32E-03
1.28E-03
1.30E-03
7'-17'
10.32
NM
Sand/gravel/
sandy silt
4.12E-04
3.68E-04
3.89E-04
rMW-2
T-17'12.31
NM
Sand
Too Much Scatter
7.04E-01
7.04E-01
3=13'
8.08
13+
Silt
1.76E-04
2.49E-04
2.09E-04
3'-13'
4.00
14.5
Silt/Sand/ Gravel
5.25E-03
6.02E-04
1.78E-03
PZ-30A
10'-11'
5.81
15.0
Sand
6.63E-04
1.20E-03
8.92E-04
PZ-31A
T-8'
4.04
11
Sand
1.17E-03
3.77E-04
6.65E-04
PZ-31B
IT-14'
8.21
(?
Clay (?) (Based
onCGW-19)
2.93E-04
3.79E-05
1.05E-04
PZ-32A
10'-11,
5.34
15 ?
Sand
Too Much Scatter
1.46E-04
1.46E-04
PZ-33A
10'-11,
5.02
14.0
Sand
4.66E-04
1.06E-04
2.22E-04
AVERAGE
8.77E-04
36 to 91
Wells Screened in the First Clay Layer (Saprolite)
PZ-30B
16'-17'
11.60
15
clay
7.47E-07
Incomplete f-alling
Head Test
7.47E-07
PZ-32B
16-17'
10.66
15 (?)
sand/clay
6.72E-07
Incomplete Falling
Head Test
6.72E-07
PZ-33B
16-17
1.79
14.5
clay
Incomplete Test
2.92E-06
2.92E-06
PZ-34A
10'-11,
2.35
13.0
Sand (?)
Incomplete Test
1.81 E-06
1.81E-06
AVERAGE
1.28E-06
<1.0
Wells Screened in the Sa 3rolite Sandy/Gravelly Zone
PZ-30C
22'-23'
17.44
15
Sand/Clay
8.72E-06
Incomplete Falling
Head Test
8.72E-06
PZ-32C
22'-23'
15.92
18
sand ?
4.03E-04
5.57E-04
4.74E-04
PZ-33C
22'-23'
9.52
14.5
clay
Incomplete Test
3.57E-06
3.57E-06
PZ-34C
22'-23'
11.89
13
clay
2.65E-07
4.08E-06
1.04E-06
AVERAGE
1.11E-05
0.5to1.2
Dee er Wells
MW-16I
30'-35'
1 24.02
14.5
1 clay
1.46E-04
1.24E-04
1.34E-04
MW-16D
82'-87'
1 76.38
1 14.5
1 rock
1.04E-04
1.20E-04
I 1.12E-04
= top of casing, NM = nor

Appendix A
Boring and Well Construction Logs
UIC Attachments-ECUSTA Bldg 27.doc 03/26/10 8:42 AM

WELL CONSTRUCTION LOG
Project Name:
Former Ecusta Paper Mill
Client:
Renova/ DRV
Location:
Brevard, North Carolina
Drilling Company:
Landprobe
Dril Rig
Hollow Stem Auger
Project No.:
131497
Boring No.:
M W-35
Date:
14-May-09
logged by:
Jim Wilson
weather:
sunny
lWell ConstructDescription UbGS
I DepthSamples
Drilling Observations
(feet)
INO.1 lypelows ecov. JPIU
SPT Boring
Light to dark brown silty clay,
425" Diameter Borehole
0.00
dry, no odor
bentonite
3.0
Brown sand, dry, no odor
Top of screen at 5' bls
0.00
5
Gray gravelly sand, dry
Depth to Water 7' bls
6.0
0.40
Sand Filter Pack
7.90
9.0
10
0.30
Gray to white clay, moist,
2.0" Sch 40 PVC
no odor
12.0
0.00
Bottom of screen 15' bis
0.00
15
15.0
0.00
Bottom of Boring 16' bls
18.0
0.00
20
0.00
21.0
0.00
23.0
0.00
25
note: elevation data not
LEGEND
Photo -ionization
Sand Pack=1U.beV
available
Screen
detector
_.Well
Bentonite Seal
Concrete Seal
bis = Below Land Surface

WELL CONSTRUCTION LOG
Project Name:
Former Ecusta Paper Mill
Project No.:
131497
Client:
Renova/ DRV
Boring No.:
MW-36
Location:
Brevard, North Carolina
Date:
14-May-09
Drilling Company.
Landprobe
logged by:
Jim Wilson
Dril Rig
Hollow Stem Auger
weather:
sunny
Light to dark brown silty clay,
4.25" Diameter Borehole
0.00
dry, no odor
bentonite
3.0
Brown sand, dry, no odor
Top of screen at 5' bls
5.30
5
Gray gravelly sand, dry,
Depth to Water 7' bls
6.0
10.50
slight odor
Sand Filter Pack
1655
strong petroleum odor
9.0
10
334
Gray to white clay, moist,
2.0" Sch 40 PVC
slight odor
12.0
8.10
Bottom of screen 15' bls
=-
0.00
15 =_
15.0
0.00
Bottom of Boring 16' bis
18.0
0.00
20
0.00
21.0
0.00
23.0
0.00
25
note: elevation data not Sand Pack= I U.beVo o-iomz
available .Well Screen detector
Bentonite Seal
Concrete Seal bls = Below Land Surface

WELL CONSTRUCTION LOG
Project Name: Former Ecusta Paper Mill Project No.: 131497
Client: Renova/ DRV Boring No.: MW-37
Location: Brevard, North Carolina Date: 14-May-09
Drilling Company: Landprobe logged by: Jim Wilson
Dril Rig Hollow Stem Auger weather: sunny

WELL CONSTRUCTION LOG
Project Name:
Former Ecusta Paper Mill
Project No.:
131497
Client:
Renova/ DRV
Boring No.:
MW-38
Location:
Brevard, North Carolina
Date:
16-Sep-09
Drilling Company:
Landprobe
logged by:
Jim Wilson
Dril Rig
Hollow Stem Auger
weather:
cloudy
4.25" Diameter Borehole
bentonite
Top of screen at 5' bls
5
Depth to Water 8' bls
10
Light to dark brown silty clay,
0.00 dry, no odor
0.00
Brown sand, dry, slight odor
0.80
30.10 Gray gravelly sand, wet
strong petroleum odor
55.00
2.0" Sch 40 PVC
_ 12.0 65.00
Gray to white clay, moist,
13.10 no odor
15 15.0
_ 2.80 Light brown weathered rock,
_ wet, no odor
18.0 0.00
_ 20 0.00
_ 21.0
_ Sand Filter Pack 0.00
_ 23.0
Bottom of screen 25' bls 0.00
_ 25
Bottom of Boring 25' bls
LLUENU
note: elevation data not 6and Pack=I U.beVo o-iornza ion
available = Well Screen detector
Bentonite Seal
Concrete Seal bls = Below Land Surface

WELL CONSTRUCTION LOG
Project Name:
Former Ecusta Paper Mill
Client:
Renoval DRV
Location:
Brevard, North Carolina
Drilling Company:
Landprobe
Dril Rig
Hollow Stem Auger
Project No.:
131497
Boring No.:
M W-39
Date:
16-Sep-09
logged by:
Jim Wilson
weather:
cloudy
IWell Construct Description USG6
I UepthSamples
Drilling Observations
(feet)
INO.1 lypelows ecov.
onng
am No
Light to dark brown silty clay,
4.25" Diameter Borehole
0.00
dry, no odor
bentonite
3.0
Top of screen at 5' bls
0.20
5
6.0
3.40
Brown sand, dry, slight odor
Depth to Water 8' bls
8.90
Gray gravelly sand, wet
9,0
petroleum odor
10 —_
4.60
2.0" Sch 40 PVC
12.0
2.80
2.50
Gray to white clay, moist,
15
15.0
slight odor
1.90
Gray gravelly sand, wet
no odor
18.0
0.00
Light brown weathered rock,
wet, no odor
20
0.00
21.0
Sand Filter Pack
0.00
23.0
Bottom of screen 25' bls
0.00
25
Bottom of Boring 25' bls
note: elevation data not
LEGEND
Photo-i3nization
Sand Pack=10.bev
available
=_Well Screen
detector
Bentonite Seal
Concrete Seal
bis = Below Land Surface

PAGE I OF I
D
PROJECT: 131q17
LOCATION: d
DATE INSTALLED:
ELEVATION; TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY o
BORING:
DRILLER: Kew n Th a JIDEPTH
TO WATER FROM TOC:
SAMPLER TYPE;
GEOLOGIST: �C4 ► zvt_
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
P M
O
W
FID
C
s
GEOLOGIC DESCRIPTION / CON.IIVIENTS
(ft
E E�
/6"
%P�)
(sym)
&Que)iy -Qwd - ,%rqy
5; ily ` cl q y - RIgEI,
o
S: ley C),'Y
tot
SV
a
5. JAY Clay �Iq�h

PAGE 1 OF I
PROJECT:
LOCATION: l
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY:
BORING: g 27 - - z
DRILLER: Kf& T61, l
bEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST: leFf
E
A N
L
P/ID
S
T
P M
W
F�
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft)
E E�
/5"
��m)
(sym)
-z%
56-Z
o
�,�y �;)f _ GrctyA brown
S; Y S4,7d - %m',;s� "
5,B-Z
d.?
St f �y 5��� - Grayh, brown
1d `
sol
0
PO4 - Gefrysh browr"

1
PAGE 1 OF 1
s
PROTECT: 1311
LOCATION: 91127
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: L
BORING: 0 Z% - Sg.,T
DRILLER:
ey,lyj 11DEPTH
TO WATER FROM TOC:
SAMPLER.
TYPE:
GEOLOGIST; t
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
P M
0
W
FID
C
S GEOLOGIC DESCRIPTION / COMMENTS
(ft
E E�
/611
�Pm)
(sym)
sl�d�y grow,
s
s6 •�
0
5:1 �-y lab - grwf)
-7A
S�-3
013
cI-Cvfly
u) `
56-3
6.
Gtavcdl � - gf- wn

i
PAGE I OF 1
Z0
PROJECT: 1317
LOCATION:
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY:
BORING:
g17 - SB'
DRILLER: cv;,, lbomaj
DEPTH TO WATER FROM TOC:
SAMPLER TYPE;
GEOLOGIST; e�
D
E
S
A N
B
L
PID
I
U
S
T
P M
W
FID
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E E�
15"
� �)
(sym)
s �
$� • �
��3
S: try Saj)� . G/��;c% �tdn
7 h
51� -�1
Y�. y
S; �• y sue, GrayA bawl)
1p ►
Sg-�
IDS
S� ��y Sa,� Gruy�cti %roW�
4D.It, �C�ratorie +- ya2,Qr

i
ti.
PAGE 1 OF 1
PROJECT: j 3I Yq?
LOCATION: I Z
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: (,q r
BORING: 27 - -s-
DRILLER: ;
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST: �`
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
P M
0
W
FID
�P }
C
s
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E R
1611
(sym}
S, ily gr'owo."lk
s'
50 s
—7'fz
59•9,
13,E
Si )�y Sw)c gllgrh
i
5wr7Q)t4)' TOM 7X' A /D l Tefm4et, i 7Dl S4✓

PAGE 1 OF 1
olyl7
PROJECT: 131 VY2
LOCATION: gj� T
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY:
La
BORING: Q _ S -6
DRILLER: ev? o
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST; JeJT
D
S
B
PID
U
E
A N
L
/
S
p
M U
O
FID
C
T
P M
W
S
GEOLOGIC DESCRIPTION / COMMENTS
H
L B�
S
(ppm)
(ft)
E ]:R
1611
(vm)
b. q Grove1I y Suva Brao6is 5MV

1.
F I
PAGE 1 Or 1
- Z-0
PROJECT:
LOCATION: 17)dj Z
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: r L
BORING:
-Z . S
DRILLER: Kej,,A
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST:
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
P M
O
W
PID
�Pm)
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E R
/611
( )
M ro Y
-Zfz
s�
2.
sY;4� say
S �
c�� �
O • P
,S � �'� C �E �� D 14t,�
-7yz
58-7
Its
S�row�,,s 4ro
`
5B-?

i
PAGE 1 OF 1
PROJECT: 131
LOCATION: Mq 2
DATE INSTALLEb:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: (,G� r
BORING: Z?
DRILLER:
.0 o
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST:
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
O
S
FID
C
S
GEOLOGICIDESCRIPTION / COMMENTS
(ft)
L B
E
/611
(�n ��
Cam)
R
Swtd Pt"A fGr c
s�
se-?
/o
coy Rkth
-7 �
sa-�
rd. �
S:-I�'� sa4 BfoL04:.t
mbvJ well Z' ����-

PAGE I OF I
PROTECT: 131
qqj
LOCATION: Rat Z
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: v
BORING: 27 -
DRILLER:
DEPTH TO WATER FROM TOC:
SAMPLER
TYPE:
IGEOLOGIST, jeft
D
E
S
A N
B
L
PED
/
U
S
P
T
M U
P M
0
W
FED
�Pm)
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(fl:)
E EE
/6"
(SYM)
-z�.
SB•8
d.S
Go'-elly 5wnp onlum-,A
Sq?dy CIS y Qivch
- 7'r's.
56-�
6.6
Scna j Ck y Q jc,,c1t
ID
SB-S
D.S"
Sandy Clay Cra y

I
i•
PAGE 1 OF 1
. 2•�
PROJECT: 131 y
LOCATION: Z
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY;
BORING: 17
DRILLER: ✓; •l7,
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST: ,c
D
E
S
A N
B
L
PID
/
U
s
P
M U
0
FID
C
T
P M
W
s
GEOLOGIC DESCRIPTION / COMMENTS
(f
E E�
/611
(PPm)
( )
-1'h
SB-�'
i•fv
S���y f�n� � g�owq��1, ,�Isc,�j
S`
SB•9
I • z
SGnr9y cloy
,o
s�•q
s 3
clay

I
I
PAGE 1 OF 1
�0
PROJECT: 13I q 9
LOCATION: Z)
DATE INSTALLED:.
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: f,�,�
BORING: ? - 56jo
DRILLER: �; eM
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST: j r
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
P M
O
w
FID
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E E�
/6"
fPPpl)
(sym)
-2'�
56-!0
•?
6rqvel1Y Sahel - groww:A jfyy
s�
sero
3.1
sin�y C/1y �1�ck�s�, yr4y
—9
58HD
Nv feco►e.,ry
l�'
S6-Ib
1.3
Sri Clay 6r4y-A brown

PAGE I OF I
-12•a
PROJECT: 131 Y ')
LOCATION: 27
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY:
Lgaa
BORING: 27 - SO - I I
DRILLER:
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST:
D
S
B
PID
TJ
E
A N
L
/
S
P
M u
0
FID
C
T
P M
W
s
GEOLOGIC DESCRIPTION / COMMENTS
(PPm)
(ft
E ER
/61
(sym)
2h' 59-11 Jo4 gripwvr , Vy
s` S6-ll b.6 5;1�v SGn� Brown
Clay Qro�unis� r4�
�C�� y C'cY

PAGE 1 OF 1
IL 5- 2-
PROJECT: 131 �q�
LOCATION: Z
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: Lq,?Ji I.BOPJNG:
9Z 2 - $ - Z
DRILLER: Ce.v"b-a+
DEPTH TO WATER FROM TOC:
SAMPLER TYPE;
GEOLOGIST: Ac
D
E
S
A N
B
L
PID
/
Ti
S
P
T
M U
P M
0
W
FID
�� )
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E ER
/611
(sym)
5a14y JQf�,) Beown
y°
S8-12
grouhl"A cloy
(1n4 � f •c. � � P� s11�- `i `. ��n �
1�
c�d�� l�lo+r+L ra nkx� locg7�`a n .

i
i
PAGE I OF 1
2 -D
PROJECT:
LOCATION: Z?
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: land ol.t,
BORING: Z - Sg -I
DRILLER: &�
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST: 3,g
D
E
S
A N
B
L
PID
/
U
S
PM
W
S
GEOLOGIC DESCRIPTION / COMMENTS
..��T..
(ll)
E
/611
`/�FID
" pm)
C cliY1
,E
-Ph
YQ-13
p
Gt4velly Swj
S'
SB-13
b
S� Icy S�b ereW.,
�h y Q�aan
lo'
38.13
D2
ctaY Gay

PAGE 1 OF 1
IPROJECT: 131 y9? T nrAmTn-KT. 01A 7,
DATE INSTALLED:
4.1
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: l.�n
BORING: 9 1.7 - S9 -/ y
DRILLER: ev',
DEPTH TO WATER FROM. TOC:
SAMPLER TYPE;
GEOLOGIST: jt
P
T
H
M U
P M
L B
0
W
S
FID
(ppin)
C
S
GEOLOGIC DESCRIPTION / CONvLMENTS
(ft)
� R
/6��
(�)
59-N
b•b
Gravel I y 34J gl¢cat
6.0
Gr",) I sw, a afoco,'A b krr
Io'
50 iy
b•y
CIa y Gay
2 °

PAGE I OF I
PROJECT: 13Lql
LOCATION; gja,. 2
DATE INSTALLED:
ELEVATION; TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: Lqn� .�,
BORTNG: V - S6- S
DRILLER: Mepv:n ThnmcsDEPTH
TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST: j
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
P M
0
w
FID
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E E�
16"
(i�Pm)
(sym)
-Z`
I 58-IS
D.D
s, ley SC4 grown
`{
ScA�y C4
— 7 1/
SB-IS
0.6
C IQ Y gown
ion
S$-!�
D•�
Clay
y
Moo Sol bDr;r,l

PAGE 1 OF 1
PROJECT:
LOCATION: (a
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY;
BORING: 2? - 8-
DRILLER: An oM
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST; 3 t
D
E
S
A N
B
L
PID
/
U
S
p
T
M U
P M
0
W
FID
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E ER
/b"
(PPS)
(sym)
-1y:
SBIb
p.�
5: Ify s4r,�— grown
S'
SB-1�
o•�
Gr�vv,114 Saga --Prows
—7A
S6-1G
! 2
Cloy_ 614ch
«�
SB-1�
0.7
,
Clay Black

i
a
PAGE 1 OF 1
Z-6
PROJECT:
LOCATION: I
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY:
BORING:
DRILLER: ((c,v; —JIDEPTH
TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST: C
E
A N
L
P/ID
S
T
P M
W
Fm
S
GEOLOGIC DESCRIPTION / COMMENTS
{PPm)
(ft
E ER
1611
( )
-7V-z
S4.11
j, I
Clay
Sandy Cky - alit

PAGE 1 OF 1
Z'd
I
PROJECT:
ILOCATION: � 2
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: LFn J
BORING: Z ,. n.s
DRILLER: Ifev-
DEPTH TO WATERFROM TOC:
SAMPLER TYPE:
GEOLOGIST:d,�,
D
E
S
A N
B
L
PID
/
u
S
P
T
M U
P M
0
w
FID
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft)
E ER
/6 1'
(pPm)
(sym)
- z h
581Y
s;1 v sad - 9IQc'k
1. �
v4y sod • Uch
Clmve y

PAGE 1 OF 1
-13-0
PROJECT:
LOCATION: Z
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY:
BORING:
-
929 - SsIT
DRILLER: f ���
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST: Jt
D
E
S
A N
B
L
PID
/
U
s
P
M U
O
FID
C
T
P M
W
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E ER
/6"
(PPS)
(sym)
-1W
59-19
D,o
5,41 S�r� frawn•'s4
S �
Sg-� I
�•�
•S: �� Ste!/ VrGWni 5►i
so-!q
p. �
S� Icy s�14 grown,
10'
a
S'i+y spa Q�owr�,s�,

i
PAGE 1 OF 1
0
PROJECT: Q
LOCATION: 011. 27
DATE INSTALLED:
ELEVATION; TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY:
BORING: 27 - S - 20
DRILLER:
DEPTH TO WATER FROM TOC:
SAMPLER TYPE
JGEOLOGISI; jt
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
P M
0
W
FID
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft
E E
/6"
(PPS)
( )
x
-2%'
SB•2a
b y
Su��y Ala y _ grbwn,s1,
s"
SQ-2o
6.7
clgl
1b'
SB-20
b, I
=
GrRveily Sid- B�i1WA�a+�

H•
PAGE 1 OF 1
- -o
PROJECT: 9?
LOCATION: Z
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY: (� .�
BORING: 27 - -2
DRILLER: t OM
DEPTH TO WATER FROM TOC:
SAMPLER TYPE:
GEOLOGIST; ti
p
D
E
S
A N
B
L
PID
/
U
S
P
T
M U
P M
O
w
FID
C
S
GEOLOGIC DESCRIPTION / COMMENTS
(ft)
E EE
/6"
�P�)
(�)
- Z rz
sB-Z P
a • t
c���el l y s� � ���w�
s `
Sa-21
0.3
Scn`�'1 Clsy 4�ow�
- ? %
58-21
6.1
grown
10
s(3-Zt
a
coavdly Sand 8•own

PAGE I OF 1
PROJECT: 131 ?)
LOCATION: 9J&
DATE INSTALLED:
ELEVATION: TOC:
DRILLING METHOD:
TOTAL DEPTH OF WELL:
DRILLING COMPANY:
BORING: ) - s 8 - &
DRILLER: e jo
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Appendix B
Material Safety Data Sheet (MSDS) for the ORC Advanced
UIC Attachments-ECUSTA Bldg 27.doc 03/26/10 8:42 AM

Oxygen Release Compound (ORCI)
MATERIAL SAFETY DATA SHEET (MSDS)
Last Revised: October 1852005
Section 1- Material Identification
Supplier:
REGENESIS
1011 Calle Sombra
San Clemente, CA 92673
Phone: [phone]
Fax: [phone]
E-mail: infogregenesis.com
Chemical Description: A mixture of Magnesium Peroxide (MgO2), Magnesium
Oxide (MgO), and Magnesium Hydroxide [Mg(OH)2]
Chemical Family: Inorganic Chemical
Trade Name: Oxygen Release Compound (ORC°)
Product Use: Used to remediate contaminated soil and groundwater
(environmental applications)
Section 2 — Chemical Identification
CAS#
Chemical
14452-57-4
Magnesium Peroxide (MgO2)
1309-48-4
Magnesium Oxide (MgO)
1309-42-8
Magnesium Hydroxide [Mg(OH)2]
7758-11-4
Dipotassium Phosphate (HK204P)
7778-77-0
Monopotassium Phosphate (H2K04P)
Assay:
25-35% Magnesium Peroxide (M902)
JAOperations\MSDS\ORC Page 1

Regenesis — ORC MSDS
Melting Point:
Boiling Point:
Flash Point:
Self -Ignition Temperature:
Thermal Decomposition:
Density:
Solubility:
pH:
Appearance:
Odor:
Vapor Pressure:
Hazardous Decomposition
Products:
Hazardous Reactions:
Further Information:
Stability:
Conditions to Avoid:
Incompatibility:
Hazardous Polymerization:
Section 3 - Physical Data
Not Determined (ND)
ND
Not Applicable (NA)
NA
Spontaneous Combustion possible at z 150°C
0.6 — 0.8 g/cc
Reacts with Water
Approximately 10 in saturated solution
White Powder
None
None
Not Known
Hazardous Polymerization will not occur
Non-combustible, but will support combustion
Section 4 — Reactivity Data
Product is stable unless heated above 150 °C. Magnesium
Peroxide reacts with water to slowly release oxygen.
Reaction by product is Magnesium Hydroxide
Heat above 150 °C. Open Flames.
Strong Acids. Strong Chemical Agents.
None known.
JAOperations\MSDS\HRC MSDS Page 2

Regenesis — ORC MSDS
Section 5 - Regulations
Permissible Exposure Not Established. Should be treated as a nuisance dust.
Limits in Air
Section 6 — Protective Measures, Storage and Handling
Technical Protective Measures
Keep in tightly closed container. Keep away from
Storage:
combustible material.
Handling:
Use only in well ventilated areas.
Personal Protective Equipment (PPE)
Respiratory Protection:
Recommended (HEPA Filters)
Hand Protection:
Wear suitable gloves.
Eye Protection:
Use chemical safety goggles.
Other:
NA
Industrial Hygiene:
Avoid contact with skin and eyes
Protection Against Fire &
NA
Explosion:
Disposal:
Dispose via sanitary landfill per state/local authority
Further Information:
Not flammable, but may intensify a fire
After Spillage/Leakage/Gas
Collect in suitable containers. Wash remainder with copious
Leakage:
quantities of water.
Extinguishing Media:
NA
Suitable:
Carbon Dioxide, dry chemicals, foam
Self contained breathing apparatus or approved gas mask
Further Information:
should be worn due to small particle, size. Use extinguishing
media appropriate for surrounding fire.
After contact with skin, wash immediately with plenty of
First Aid:
water and soap. In case of contact with eyes, rinse
immediately with plenty of water and seek medical attention.
Section 7 — Information on Toxicology
JA0perations\MSDS\11RC MSDS Page 3

Regenesis — ORC MSDS
Toxicity Data: Not Available
Section S — Information on Ecology
Water Pollution Hazard 0
Raging (WGI):
Section 9 — Further Information
After the reaction of magnesium peroxide with water to form oxygen, the resulting
material, magnesium hydroxide, is mildly basic. The amounts of magnesium oxide
(magnesia) and magnesium hydroxide in the initial product have an effect similar to lime,
but with lower alkalinity.
The information contained in this document is the best available to the supplier at the time
of writing, but is provided without warranty of any kind. Some possible hazards have been
determined by analogy to similar classes of material. The items in this document are
subject to change and clarification as more information become available.
JAOperations\MSDS\HRC MSDS Page 4

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CAUSTIC MONITORING WELLS
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APPROXIMATE SCALE IN FEET
CLIENT: PM:
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LOCATION: CHECKED:
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PISGAH FOREST, NORTH CAROLINA
DESIGNED: DETAILED: PROJECT NO.: FIGURE:
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This page intentionally left blank.

d�
HCDEHR
North Carolina (Department of .Environment and Natural Resources
Beverly Eaves Perdue
Governor
John B. Henselman
Davidson River Village, LLC
36 Washington St., Suite 220
Wellesley, MA 02481
Division of Water Quality
Coleen H. Sullins Dee Freeman
Director Secretary
August 31, 2010
Ref: Issuance of Injection Permit W10100091
Davidson River Village, LLC
Dear Mr. B.umb:
In accordance with the application received on April 26, 2010, and additional information received July 23, 2010, we are
forwarding permit number WI0100091. This permit is to inject ORC Advanced to remediate groundwater contaminated
with petroleum products in the vicinity of Building 27 at the Former Ecusta Paper Mill facility located 1 Ecusta Road,
Brevard, Transylvania County, NC 28712. This permit shall be effective from the date of issuance until July 31, 2012,
and shall be subject to the conditions and limitations stated therein, including the requirement to submit a final project
evaluation as stated in PART V11 — MONITORING AND REPORTING REQUIREMENTS. Please read the entire
permit to ensure that you are aware of all compliance requirements of the permit.
Please note that the monitoring plan as originally presented in the application has been modified per the
Additional Information Letter dated July 21, 2010, and received by the Division of Water Quality on July 23, 2010.
You will need to notify this office and the Asheville Regional Office by telephone 48 hours prior to initiation of operation
of the facility. In order to continue uninterrupted legal use of the injection facility for the stated purpose, you must submit
an application to renew the permit 120 days prior to its expiration date. Please contact me at 919-715-6166 or
[e-mail] if you have any questions about your permit.
Best Regards,
/4.0
Michael Rogers, P.G. INC & FL)
Environmental Specialist
Underground Injection Control Program
cc: Landon Davidson - Asheville Regional Office
Amar C. Bumb - Shaw Environmental, Inc., 3 Independence Pointe, Suite 107, Greenville, SC 29615
WI0100091 Permit File
James Bateson - Division of Waste Management.
Jennifer Wendell = US EPA Region 4
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748
Internet: www.ncwateroualitv.orq
An Equal Opportunity 1 Affirmative Action Employer
Ile
NofthCal-olina
;Vaft(rallY

Rogers, Michael
From: Bumb, Amar [Am ar. Bum [e-mail]]
Sent: Wednesday, September 01, 2010 11:07 AM
To: Rogers, Michael
Cc: Bumb, Amar; Kenyon, Ronald; Welch, Amanda; Cavanaugh, Paul
Subject: Sampling for B27 UIC Permit Application no. W10100091
Michael
DRV will sample monitoring wells at Building 27 for the following parameters during all sampling events:
Field Parameters
• Temperature
• pH
• Conductivity
• Dissolved oxygen
• Oxidation-reduction potential (ORP or Eh)
Laboratory Analysis by EPA Method 8260
• Benzene
• Toluene
• Ethylbenzene
• Xylenes
• Naphthalene
Amar fumb, AD, P.E., CGWP
Principal Engineer/Hydrogeologist
Shaw Environmental & Infrastructure
3 Independence Pointe, Suite 107
Greenville, SC 29615
[phone] direct
[phone] cell
[phone] fax
amar.bumb(cD_shawgrp.com
wvvw.shaw.qrp.com
****,Internet Email Confidentiality Footer**** Privileged/Confidential Information may be contained in this
message. If you are not the addressee indicated in this message (or responsible for delivery of the message to
such person), you may not copy or deliver this message to anyone. In such case, you should destroy this
message and notify the sender by reply email. Please advise immediately if you or your employer do not
consent to Internet email for messages of this kind. Opinions, conclusions and other information in this message
that do not relate to the official business of The Shaw Group Inc. or its. subsidiaries shall be understood as
neither given nor endorsed by it. The Shaw Group Inc.
hqp://www.shaw=.com

'JED I DENR / DWQ
,QOTFr.TIr1N RFMOH
f .iuL 23 2014
t�
Shaw Shaw Environmental, Inc.
July 21, 2010
Mr. Michael Rogers
Aquifer Protection Section
NC Department of Environment and Natural Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Shaw Environmental, Inc.
Three Independence Pointe, Suite 107
Greenville, SC 29615
864.254.9285
FAX: [phone]
Subject: Additional Information Request Dated July 2, 2010
UIOC Permit Application W10100091
Davidson River Village, LLC — Former Ecusta Paper Mill Site
Dear Mr. Rogers
With reference to additional information/clarifications requested in your letter dated July 2, 2010:
Groundwater Flow Direction — Please see attached Figure 5-13, an overall site potentiometric map for
March 2010. As shown in Figure 5-13, the generalized groundwater flow direction in the vicinity of
Building 27 is towards the southeast which is consistent with historic potentiometric maps developed for
the site. The localized potentiometric surface is influenced by the excavations that took place at
Building 27 to remove contaminated soil. This has resulted in higher groundwater levels at MW-39
then would be expected. I have also modified Figure 5-A that shows potentiometric surface map in the
immediate vicinity of Building 27 to be consistent with the overall groundwater flow map (Figure
5-13). Due to increased recharge between MW-36 and MW-39, one may get a false impression that
groundwater flow is to northeast. With overall groundwater flow to the southwest, MW-37 is properly
located to serve as the downgradient well and additional downgradient monitoring well is not required.
• Additional Monitoring Well - Since MW-37 is downgradient of the groundwater plume and injection
area, DRV feels that another downgradient well is not warranted.
• Groundwater Flow - A section on the groundwater flow calculations has been added. Since the original
UIC Permit Application, additional slug test results from the Electrochemical Building became available.
Therefore, the section on aquifer testing was also updated. New results are consistent with previously
reported hydraulic conductivity values.
• Monitoring Plan —
(1) Please see response above why an additional monitoring well is not needed.
(2) Arsenic in groundwater has been monitored for three quarters in site -wide wells that included
Building 27 Area wells. Table 3 has been revised to include all detected analytes at Building 27,
including metals. Although soils containing naturally occurring arsenic were identified at the Ecusta
Paper Mill site away from Building 27, arsenic has not exceeded Groundwater 2L Standards
anywhere on the Ecusta Paper Mill Site. Therefore, it has not been identified as contaminant of
concern (COC) at the Ecusta Paper Mill site. Thus, arsenic has not been added as an additional
parameter in the monitoring plan.
A Shaw Group Company

Letter of Certification
Construction Permit # 18,976-IW
Defense Fuel Supply Pipeline, Charleston AFB, South Carolina
2
(3) Monitoring plan has been updated to reflect that the post injection quarterly sampling will start one
quarter after the injections and will continue until groundwater 2L standards are met, which is
estimated to be approximately one year.
Please see attached revised pages for insertion/replacement into previously submitted UIC application. Should
you require any additional information, please call me at [phone].
Sincerely,
z0 ) �/°
Amar Bumb, PE # 2625
Project Engineer
CC: Mike Singer, DRV
Ron Kenyon, Shaw
Jennifer Wendel, USEPA Region 4
Jim Bateson, NCDENR
Harry Zinn, NCDENR
d i OENR / DWa a
'nnN S
A Shaw r;rrw in r rymmnv

IF
HCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
July 2, 2010
Amar C. Bumb, Ph.D., P.E.
Shaw Environmental & Infrastructure, Inc.
3 Independence Point, Suite 107
Greenville, SC 29615
Re: Additional Information Request
Injection Well Permit Application WI01.00091.
Davidson River Village, E1✓C - Former Ecusta Paper Plant
Transylvania County
Dear Dr. Burnb:
Natural Resources
Dee Freeman
Secretary
While reviewing the referenced permit application our staff identified some items that need clarification and/or
additional information. Therefore, please address the following items:
• In the text part of the application (Section B.) the groundwater flow direction is `generally toward
the southeast'. However, the Potentiometric Surface Map (Figure 5) shows groundwater flow
direction to the northeast.
• If, according to Figure 5, the correct groundwater flow direction is to the northeast, there is no
monitoring well downgradient of the injection area and outside the cone of influence to evaluate the
injection effectiveness and potential plume displacement. Please install 1 additional monitoring well
northeast and downgradient of the injection area, and outside the zone of influence at a sufficient
distance that could monitor the injection effectiveness- possibly at a distance similar to MW-37.
This well would need to be sampled prior to injection activities for baseline data. Also, include the
new well construction.
• Please provide porosity or specific yield of the target aquifer and estimated groundwater flow
rate/velocity along with the calculations used to determine these numbers.
• Please submit a modified sampling plan reflecting: (1) the additional monitoring well; (2) the
additional parameter of arsenic; and (3) a timeline showing when the post injection sampling starts
(i.e., 1 day after injection, 1 week after injection, etc.), the frequency, and the planned estimated
duration (i.e., 1 year, 2 years etc.).
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] \ FAX 1: 919-715-0588; FAX 2: 919-715-6048 \ Customer Service: 1-877-623-6748
Internet: wvvw.ncwaterguality.orq
An Equal Opportunity \ Affirmative Action Employer
One
Nort12Ca1:olina
`tuinlff

Please submit your responses with any corrected text pages/figures for insertion into the previously submitted
UIC Application within 30 calendar days of receipt of this letter. If you have any questions regarding your
permit please call me at [phone] or email me at Michael.Rogers� ncdenr.gov.
Thank you for your cooperation.
Best Regards,
Michael Rogers, P.G. (N & FL)
Environmental Specialist
cc: Landon Davidson — Asheville Regional Office
Central Office File — WI0100091
James Bateson, Incident Manager — Division of Waste Management
John B. Hanselman - Davidson River Village, LLC
Paae 2 of 2

4
i
a ,,
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
April 30, 2010
John B. Hanselman
Davidson River Village, LLC
36 Washington Street Suite 220
Wellesley, MA 02481
Subject: Acknowledgement of Application No. WI0100091
Former Ecusta Paper Mill - Building 27 Area
Injection In situ Groundwater Remediation Well (5I)
Transylvania
Dear Mr. Hanselman:
Natural Resources
Dee Freeman
Secretary
The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and
supporting materials on April 26, 2010. This application package has been assigned the number listed above and will be reviewed by
Michael Rogers
The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To ensure the
maximum efficiency in processing permit applications, the Division requests your assistance in providing a timely and complete
response to any additional information requests.
Please be aware that the Division's Regional Office, copied below, must provide recommendations prior to final action by the
Division. Please also note at this time, processing permit applications can take as long as 60 - 90 days after receipt of a complete
application.
If. you have any questions, please contact Michael Rogers
at 919-715-6166, or via e-mail at [e-mail]. If the reviewer is unavailable, you may leave a message, and they
will respond promptly. Also note that the Division has reorganized. To review our new organizational chart, go to
http:/,lh2o.enr.state.iic.us/documents/dwq orgTchart.pdf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerely,
for Debra J. Watts
Supervisor
cc: Asheville Regional Office, Aquifer Protection Section
Amar C. Bumb, PH.D, PE (Shaw Environmental & Infrastructure, Inc. - 3 Independence Pointe, Suite 107, Greenville, SC 29615)
.ermtt Applica on File_Wp101� . Z1911
AQUIFER PROTECTION SECTION
1636 IJiail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard. Raleigh, North Carolina 27604 One 7 Phone: [phone] , FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748 �C}1'�11�aY ©t.LIIc`l
Internet www.ncwateroualitv.oLq �
A.n Equal Opportunity 1 Affirmative Action Employer"

AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: June 18, 2010 County: Transylvania
To: Aquifer Protection Central Office Permittee: NCDENR APS UIC
Central Office Reviewer: B. Laverty/J. Stepp Project Name: Davidson River Village
Regional Login No: Application No.: WI0100091
RECEivLL ; ,._,,. w
L GENERAL INFORMATION AQUIFFR,PRnTF( Tr gFCT10N
1. This application is (check all that apply): N New ❑ Renewal �,U N 2 �- 1 1
El 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 ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
I a. Date of site visit: June 16, 2010
b. Person contacted and contact information: Amar Bumb [phone]
c. Site visit conducted by: Brett Laverty and Jonathan Stepp
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 Treatment Facilities:
i
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For Disposal and Infection Sites:
(If multiple sites either indicate which sites the information applies to, cop and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s): Ecusta Road Brevard, NC
b. Driving Directions: U.S. 280 to Brevard. Turn left on Ecusta Road just past the U.S. 276 intersection
c. USGS Quadrangle Map name and number: Pisgah Forest/35082-C6-TF-024
d. Latitude-82/14/18.01 Longitude: 35016' 2.21" N 820 42' 8.84" W
Z A'.a' WAND Ad�f� JOR MO,TIC:<J?TIONAPPL.TCAT]" XS! this section not neaded for renaw als or winor,
d3P4)(ll C atiU�''r_4:-skf ),to nett section)
Description Of Waste S And Facilities
1. :Please attach completed rating sheet. Facility Cl8sificatlon:
2. Are the nevv treatment facilities adequate forlhe type of waste and disi)osal syslenl?
FORM, Davidson River Village.docx 1

AQUIFER PROTECTION REGIONAL STAFF REPORT
❑ Yes ❑ No ❑ N/A. If no., please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reporrcd by
the. soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (neaps, plans; etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑ No ❑ N/A. If no, please explain:
5. is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No ❑
N/A. If no. please explain:
G. Are the proposed application rates for new sites (hydrau.lic or nutrient) acceptable'?
❑ Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-1..'ear floodplain and please explain
and recomruend ally mitigative measures/special conditions in fart IV:
8. Are there any buffer conflicts (new. -treatment facilities or new disposal sites)? ❑ Yes or ❑ No. if yes, please
attach a map showing conflict areas or attach any new maps you. haNe received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing Uround,% Ater monitoring program (number of wells, frequency of s7IonitCriri�F,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach reap of existing, nlonji.arincg u-c•Ii
network if applicable. Iudicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required'? ❑ Yes ❑ No ❑ N/A lf.yes, attach list of sites
with restrictions (Certification B?)
111. REAT,WAL AND MOD IF, ICA 770.1V A PPL XAT;PONS(jive previous section for itew or ingior n i o (fiflea dolt
st?stet�rs
Deegeriptio Of Waste(c) And Facilities N/A
1. Are there appropriately certified ORC's.for the Facilities? ❑ Yes or F No,
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
2. is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions {soils, topography, depth to %vain, table, etc) maintained appropriatel;, amd MIQ 1UaU;y,
assimilating the haste`? ❑ Yes or ❑Ito. If no, please. explain:
FORM: Davidson River Village.docx 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
4. Has the site changed. in any way that may affect pernill (drainage added, new hells inside the compliance
boundary, new development, etc.)? Il' yes, please ex;plainls the residuals rnanagemeut plan for the facilit\
adequate and/or acceptable to the Division?
❑ Yes or ❑ No. if no, please explain:
5. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please;
explain: _--
t. 1s the esistin; groundwater rnonii:orrng program (mrmbcr of wells, frequency of mt,rritoriug, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A.. Attach neap of existing, monitoring well network if
Applicable. Indicate the review and compliance boiuidarie.s. If No. explain and recommend any clianv s 1:o the
groundwater nzonitoring program:
7. Will seasona} or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/� A if yes, attach list oi' :itt:s
with restrictions (Certification B?)
b. Are there any buffer conflicts (treatment facilrlies or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a,
map showing conflict areas or attach any new maps you have received. from the applicant to be incorporated
into the permit:
9. Is the description of the facilities, type and/or volume of waste(s) as written in the existh g permit correct? ❑
Yes or ❑ No. If no, please explain:
10. Were monitoring wells properly constructed and. located? ❑ Yes or ❑ No ❑ NIA. If no, please explain:
i11. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
12. Clieck all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(.,) ❑ Currently under SOC; ❑ Currently under .IOC; ❑ Currently under
moratorium. If any itsms checked, please explain and attach any docun7errts that may help claxilI
I
answer/comments (such as NOV, NOD etc): Have all compliance dates/conditions in the existirr lx rrirrt
(SOC, JC}C, etc.) been complied «ith'? ❑Yes ❑ No ❑ Not Determined ❑ N/ A.. If no, pleese explain:
13. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
FORM: Davidson River Village.doex 3

AQUIFER PROTECTION REGIONAL STAFF REPORT
IV INJECTION WELL PERMITAPPLICATIONS (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 (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
® In situ remediation (fi)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify:
2. Does system use same well for water source and injection? ❑ Yes ®No,
I Are there any potential pollution sources that may affect injection? ® Yes ❑ No
What is/are the pollution source(s)? Nearby caustic and mercury release sites
What is the distance of the injection well(s) from the pollution source(s)? Approximately 1,000 feet
4. What is the minimum distance of proposed injection wells from the property boundary? 250 ft.
5. Quality of drainage at site: ❑ Good ® Adequate ❑ Poor
6. Flooding potential of site: [].Low ❑ Moderate ® High (for injection site itself)
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ® Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Iniection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat.pump or injection well operation (e.g. turbid water,
failure to assunilate injected fluid, poor heating cooling)?
❑ Yes ❑ No. If yes. ext�la.iti:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or la -t inspection? ❑ Yes ❑ No. if v s__eai)1ain:
i. For renewal or modification of groundsynter reniedlatioupermit,- of any type). will
continuecl/additional/modified injections liave an adverse impact on ni:iarati.on oftlie t�lu.iue or mana�xenzent c,f
the contamination incident:? ❑ Yes ❑ No. Ii'yes explain:
FORM: Davidson River Village:docx 4

AQUIFER PROTECTION REGIONAL STAFF REPORT
=3. Drilling.comractor: Name:
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
FORM: Davidson River Village.doex 5

AQUIFER PROTECTION REGIONAL STAFF REPORT
V. E VAL UATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: The site has been contoured to
promote positive drainage away from the Davidson River and towards a common ditch, which drains the
entire Ecusta site. The common ditch discharges to an existing water treatment plant and aeration
settling basin. Any spill or day lighting of injection fluid should be intercepted by the drainage ditch.
I am also aware from conversations with James Bateson (IHSB) that arsenic soil concentrations at the
former Ecusta site are high. Due to competition for sorption sites, arsenic solubility can be increased by
the presence of phosphate. From the MSDS sheets, it appears that the injection product (ORC) contains
appreciable amounts of phosphate. I would recommend adding arsenic to the post -injection monitoring
plan.
2. Attach Well Construction Data Sheet - if needed information is available:
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. 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
Provide greater detail on post -injection
monitoring plan timeline
Narrative only states that sampling will occur
on a quarterly basis.
5. 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:
Condition Reason
none
6. 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
Add arsenic to post -injection monitoring
plan
Presence of phosphate in the injection fluid
7. 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; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor:
Date: 6/18/2010
6 6 11- Zocb
FORM: Davidson River Village.docx

Rogers, Michael
From:
Laverty, Brett
Sent:
Tuesday, June 22, 2010 11:41 AM
To:
Rogers, Michael
Subject:
UIC Permit W10100091
Attachments:
UIC W10100091.pdf
Michael,
Here is the UIC regional staff report for the Ecusta site in Transylvania County.
Brett Laverty
Brett Laverty - brett.laverty(aD-ncdenr.gov
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and therefore may be disclosed to third parties.
1

0*0UIFER PROTECTION SECTION''
APPLICATION REVIEW REQUEST FORM
Date: May 11, 2010
To: ®
Landon Davidson, ARO-APS
❑
Art Barnhardt, FRO-APS
❑
Andrew Pitner, MRO-APS
❑
Jay Zimmerman, RRO-APS
From: Michael Rogers Groundwater Protection Unit
Telephone: [phone]
E Mail. Michael.Rogers(d»ncmail.net
A. Permit Number: WI 0100091
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, W-SRO-APS
Fax. [phone]
B. Owner: Davidson River Village, LLC (Former Ecusta Paper Mill)
C. Facility/Operation:_;
❑ Proposed ® Existing ❑ Facility ❑ Operation
D. Application:
1 Permit Type: ❑Animal ❑
-Surface Irrigation❑
Reuse
❑ H-R Infiltration
❑ Recycle ❑.
I/E Lagoon ❑ GW Remediation (ND)
® UIC — SI Groundwater R_ eme_datton W_ ell
For Residuals: ❑ Land App.
❑ D&M
❑
Surface Disposal
❑ 503
❑ 503 Exempt
❑
Animal
2 Prq ect Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑
Renewal
❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
NOTE:
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within, please take the following actions:
® Return a Completed APSARR Form within 30 days. However, if laboratory analytical results are
needed in conjunction with the report, submit the report along with lab results whenever received.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO.*
* Remember that you will be responsible for coordinating site visits and reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
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 -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer:
Date:
FORM: APSARR 67/06 Page 1 of 1

Michael F. Easley, Governor
North Carolina Department of Health and Human Services
Division of Public Health • Epidemiology Section
Occupational & Environmental Epidemiology Branch
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone]
August S, 2005
Carmen Hooker Odom, Secretary
MEMORANDUM o
TO: Evan Kane �c
Underground Injection Control Program cn o_�
Aquifer Protection Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist _ •• --
Medical Evaluation and Risk Assessment Unit co
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of a Non -Biological Product Oxygen Release Compound — Advanced (ORC-
AdvancedTm) by Regenesis to Enhance Biodegradation of Soil Contaminated with
Petroleum Compounds at LC Industries in Durham, North Carolina '
I am writing in response to a request for a health risk evaluation regarding the use of use
of a non -biological product Oxygen Release Compound — Advanced ' . ") by
Regenesis to enhance biodegradation of soil contaminated with petroleum compounds at LC
Industries in Durham, North Carolina. Based upon my review of the information submitted, I
offer the following health risk evaluation:
PRECAUTIONS DURING APPLICATION
Some effects or hazards reported to be associated with the chemicals proposed -for use are
a: follows:
• Exposure can cause irritation and burns to the skin, eyes, nose and throat
(Medical Management, Micromedex TOMEs Plus System CD-ROM Database,
Volume 65, 2005)
2. If the products are released into the environment in a way that could result in a
suspension of fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or
mixing), then it is imperative that proper personal protective equipment be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
® Location: 5505 Six Forks Road, 2nd floor, Room DI 9 Raleigh, N.C. 27609 An Equal Opportunity Employer

3. Persons working with this product should at least wear- goggles or a face shield, gloves,
and protective clothing. Face and body protection should be used for anticipated splashes
or sprays. Again, consult with an industrial hygienist to ensure proper protection.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never
be permitted in the application area during or immediately following application. Safety
controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent adverse reactions and
injuries.
6. Access to the area of application should be limited to the workers applying the product.
In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application.
7. According to the information submitted, the area is served by a public water supply.
However,,a domestic water supply well is located approximately 2,000 feet from the site
along Slater Road. Also, an unnamed small creek is located approximately 1,000 feet
south of the site. The creek drains into an unnamed pond north of Airport Road. Efforts
should be made to prevent contamination of existing or, future wells and nearby surface
waters that may be located near the application area.
Please do not hesitate to call me if you have any questions at [phone].
cc: Mr. Rick Stalling, LC Industries, 1810 E. Main Street, Durham, NC 27703
Mr. Ed Mackey, Weston Solutions Inc., 4917 Waters Edge, Raleigh, NC 27606
Mr. Michael Ranck, NCDENR, Aquifer Protection Section, 1636 Mail Service Center,
Raleigh, NC 27699-1636
Mr. Gene Burke, Vironex, Inc., 530 McCormick Drive Suite A, Glen Burnie, MD 21061
Mr. Everett Poore, Nortel Networks, 3001 East Chapel Hill, RT P, NC 27705