WI0400106_MODIFIED APPLICATION_20110214

''MA Th
engineering and constructing a better tomorrow
February 7, 2011
Mr. Thomas Slusser, Hydrogeologist
North Carolina Division of Water Quality
Aquifer Protection Section — Groundwater Protection Unit
2728 Capital Boulevard
Raleigh, North Carolina 27604
Subject: Modified Application for Perinit to Construct and/or
Use a Well(s) for Injection
CMI Waste Water Treatment Plant
Elkin, North Carolina
Site ID NONCD 0001092
MACTEC Project 6228-08-4691
Dear Mr. Slusser:
On behalf of CMI Industries, Inc., MACTEC Engineering and Consulting, Inc. {MACTEC} is
providing the following supplemental documents to the Modified Application for Permit to
Construct andlor Use a Well(s) for Injection that was recently submitted for the CMl Waste
Water Treatment Plant on January 26, 201 L
■ Two Certification pages signed by Mr. dames A. Gvenden, Trustee for CMI; and,
• One additional complete copy of the Modified Application far Permit to Construct anchor
Use a IVell(s) for Injection for your use.
If you have questions concerning this submittal, please contact the undersigned at (704) 357-
8600.
Sincerely,
MACTEC ENGINEERING AND CONSULTING, INC.
Mark P. Fitardi, P.G.
Senior Geologist
Enclosures
RECEIVED 1 DENR 1 Dvvo
Aquifer PratA(,tinn Sert;on
FEB 14 2011
MACTEC Engineering and Consulting, Inc.
2801 Yo6mont Road, Suite 100 ■ Charlotte, NC 28208 • Phone- 704.357.8600 * Fax [phone]
www.mactec.com
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l9.rw

A 14
MACTEC
engineering and constructing a better tomorrow
January 26, 2011
Mr. Thomas Slusser, Hydrogeologist
North Carolina Division of Water Quality
Aquifer Protection Section — Groundwater Protection Unit
2728 Capital Boulevard
Raleigh, North Carolina 27604
Subject: Modified Application for Permit to Construct and/or
Use a Well(s) for Injection
CMI Waste Water Treatment Plant
Elkin, North Carolina
Site ID NONCD 0001092
MACTEC Project 6228-084691
Dear Mr. Slusser:
On behalf of CMI Industries, Inc., MACTEC Engineering and Consulting, Inc. (MACTEC) is
submitting this Modified Application for Permit to Construct and/or Use a Nell(s) for lr jection
(Application) for the subject property located in Ellin, Surry County, North Carolina. This
permit application was prepared in general accordance with the North Carolina Department of
Environment and Natural Resources Division of Water Quality guidance UIC-51/5T dated August
2007 and presents a modified scope of work for injection based on the results of pilot testing
conducted at the site in June 2010. In conjunction with this Application, MACTEC will be
submitting a Remedial Action Plan Addendum to the NCDENR shortly.
If you have questions concerning this report, please contact the undersigned at [phone].
Sincerely,
MACTEC ENGINEERING AND CONSULTING, INC.
Mark P. Filardi, P.G. Ow tC , F.G.
Senior Geologist Principal Geologist
Enclosures
RECEIVED / DENR / , W6,
Aquifer Profpctior, ,�prtiara
MACTEC Engineering and Consulting, Inc. �FB 4 Lull
2801 Yarkmant Road. Suite 100 • Charlotte• NC 28208 ■ Phone: [phone] . Fox: 704,357.8638
www.mactec.com

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells In Situ Groundwater Remediation 1 Tape 5T Wells — Tracer Injection
• Do not use this faun for rcmcdiation systems that extract contaminated groundwater, treat it, and reiniect 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 trade to this form will result in the application package being returned,
Application Number (to be completed by DArQ): W10400106
1. GENERAL INFORMATION:
1. Applicant's Name (generally the responsible party): CMI Industries
2. Signing Official's Name*: James A. Ovenden Title: Trustee
* Signing Official must he in accordance with instructions in part VI on page 7.
3. Mailing address of applicant: 219 Muirfield Drive
City: Spartanburg State: SC Zip: 29306
Telephone number: Fax number:
4. Property Owner's Name (if different from Applicant): 84 202-6255
5. Property Owner's trailing address: Same as:ApPlicant _
Citv' State: Zip:
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Paul Johnstone Title: Chief Scientist
Company: MACTEC engineering and Cons_ult_in!z. Inc.
Address: 1327 Miller Road, Suite A
City: Greenville State: SC Zip: 29607
Telephone number: [phone] _ Fax number:. [phone]
Email Address- P5JOHNSTONPAmactec.com
IL PERNQT INFORMATION:
1. Project is_ _ New X Modification of existing permit _ 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. W10400106 and the issuance date July _13,,2009
For renewal without modifications, fill out sections I & H 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, submit a status report including monitoring results of all injection activities to date.
Revised 6/09 UIC-5I.. ST RECEIVED I DR4R I DWq
Aquifer ProtgCti n �emion Page t of 7
FEB 14 2011

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Rernediation 1 Type 5T Wells — Tracer Injection
III. INCIDENT & FACILITY DATA
A. FACILITY INFORMATION
1. Facility name: CMI Waste Water Treatment Plant
2. Complete physical address of the facility. 304 East Main Street
City. Elkin County: Surry State: NC Zip. 28621
B. INCIDENT DESCRIPTION
I . Describe the source of the contamination:
Remedial Investigation (RI) activities were completed by Trigon Engineering; Consultants, Inc. (Trigon) in 2005-
2008 to locate and delineate potential sources, fitrther asses the vertical and horizontal extent of solvents within
the regolith and bedrock aquifers, and support risk assessment of the WWTP. The RI indicates that the primary
contaminants of concern (COCs) identified in groundwat beneath the site are 1,1,1-Trichloroethane and its
daughter products, 1,1-Dichloroethane and 1,1-dichloroethene. Additional volatile organic compounds including
1,2-Dichloroethane, benzene, carbon tetrachloride, trichloroethene and vinyl chloride have also been detected at
concentrations that exceeded the 2L Standards. The RI concludes that buried residual waste material serves as the
primary source of COCs to groundwater at the site.
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 et:henes, chlorinated ethanes. metals, pesticides/herbicides, etc):
Volatile Organic Compounds (1,1,1-Trichloroethane, 1.1-Dichloroethane, 1.1-Dichlnroethene, 1,2-
Dichloroethane, benzene, carbon tetrachloride, trichl.oroethene and vinyl chloride).
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
X Yes If yes, list maximum measured separate phase thickness: approximately 1 feet
No If no, list maximum concentration of total VOCs observed at site:
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 Other:
5. Incident managers name Janet Mac onald and phone number _ [phone] _
6. Incident number or other site number assigned by the agency managing the contamination incident-
NONCD0001092
C. 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 llllana;ement program permits under RCRA: lV
2. DWQ Non -Discharge or NPD1 S permits: NPDES Permits
3. County or DEH subsurface wastewater disposal permits: NA
4. Other environmental permits required by state or federal law: NA
Revised 6/09 L'lC-5L15T Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT A_NDIOR USE A "ELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Rernediation f Type 5T W'ells— Tracer Injection
1v. INJECTION DATA
A. INJECTION FLUID DATA
1. List all proposed injectants.
NOTE: Any substance to be injected as a tracer or to promote in situ remediation musa he revi",ed by the
Occupational and Environmental Epidemiology Section (OEES) of the Division of Public Health, Department of
Health and Human Services. Review the list of a rmroved iniectants or contact the UIC Program to determine if
the h jectants you are proposing have been reviewed by OEES.
A. Bedrock Zone
Injectant: _ Hydrogen Release Compound Primer (HRC Primer)
Concentration at point of injection: 100% concentration
Percent if in a mixture with other injectants:
Injectant: 3D Micro Emulsion )Hydrogen release compound)
Concentration at point of injection: 10% solution by volume { 10.1 water to 3QMe mix ration)
Percent if in a mixture with other injectants:
B. Overburden Zone
' Injcctant: 3D Micro Emulsion
Concentration at point of injection:_ 5'0 solution by volume (20: ] water to 3DMe Fria ratio)
Percent if in a mixture with other injectants:
Injectant:
Concentration at paint of injection:
Percent if in a mixture with other injectants:
?. Source of fluids used to dilute or chase the ipjactants listed above:
None
X Municipal water supply
Groundwater from private well or any well within 'I mile of injection site
_ Air
Other:
3. If any well within '/. mile of injection site. a private well, or surface water is to be used as the fluid source, supply
the following information:
a. LocatiodflD number of source: NA
b. Depth of source:
c. Formation: NA
d. RockiSediment
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 recogltized in soil or groundwater on the site.
Re,,ised 6109 UIC-5I15T Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT ANDIOR USE A WELL(S) FOR INJECTION
Type 51 Wells -- In Situ Groundwater Remediation 1 Type 5T Wells — Tracer lnjecHan
NOTE: If contaminated grou► dwaier is to be used as the dilution or chase fluid, thus is not the proper permit
application form. You mast apply for a closed -loop groundwater remediation permit using application int•m
GPYRS
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection: 5.5 weeks
a. Maximum number of separate injection events: I
b. Expected duration of each injection event: 5.5 weeks
c. Expected duration between events (if more than one event): NA
2. injection rate per well: A, 0.5 1 B. 5.0 gallons per minute (gpm) (A. Bedrock. B. Overburden)
3, Total Injection volume: up to 5A0 gallons per day (gpd); gallons per event (if separate events)
4. Iniection pressure: <300 pounds!square inch (psi)
5. Temperature at point of injection: Ambient "F
6. Briefly describe how the above parameters will be measured and controlled:
Flow will be controlledimodified at each well using regulating flow meters.
7. Estimated hydraulic capacity of the well: gpm
C. 1NTECTION WELL CONSTRUCTION DATA
1. Injection will be via:
a. X Existing well(s) proposed for use as an injection well. Provide the data in (2) through (6) belmv to the best
of your knowledge.
b. X Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below
as proposed construction specifications.
c. X_Proposed temporary well(s) to be constructed for use as a one-time injection well via direct push.
2. Well Drilling Contractor's Name: Geologic Exploration
NC Well Contractor Certification number: 2854
3. Date to be constructed: February 2011 Number of borings: a. 6: b. 2: c. 150
Approximate depth of each boring (feet): a. 32'-120': b. 40': c. 22'
4. Screened interval Infection internal of injection wells: -4 l L S tip/
Depth: 15 to 120 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
5. Well casing (NIA if injection is through direct push rods):
Type: X PVC _ Stainless steel i Other:
Casing depth: 0 to 20 ft. (for,2 proposed new wells)
6. Grout (NIA if injection is through direct push rods):
Type: X Cement Bentonite
Grout depth: 0 to: 20 ft.
Other:
Revised 6/09 UIC-51/5T Page 4 ()f 7

APPLICATION FOR PERIMIT TO CONSTRUCT AINDIOR USE A VVELL(S) FOR INJECTION
Type 51 Wells — In Siru Groundwater Remediation 1 Trpe 5T Wells — Tracer Injection
it. ATTAC)EIMEN"TS
Provide the following items as separate attachments with the given headings:
A. SITE HISTORY
Provide a brief description of the site history including:
(1) site usage historically and present,
(^_) origin of the contamination,
(3) previous remedial action(s).
NOTE. G.S. 89E--I8 requires that arn- geologic plans, reports, or documents in which the performance is related to the
public wel(are or safeguarding of the environment be prepared by a licensed geologist or subordinate under their
direction. G.S. 89E--13 requires that all drax7ngs. reports, or documents imulving geologic work prepared or approved
by a licensed geologist, or ❑ subor dinars= tinder their direction, he .rigned and sealed hJ, the licensed geologist.
B. HYDROGEOLOGIC DESCRIPTION
Provide a hydrogeologic descriptiom 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:
(I) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity, transmissixity, 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
ION
Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety
Data Sheet (MSDS) for each injectant. If a private well or a well within '/. mile of the injection site is used as the source
well, 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 proiect:
(2) explanation and/or calculations of how the proposed iniec:tant volume and concentration were determined;
(a) 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
(4) sumn-iary 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 PROCEDLiRE 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:
(1) a detailed diagram of the surface and subsurface portions of the system; and
(4) a planned injection schedule.
Revised 6,99 UIC-5115T Page 5 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELLS) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation i Type ST ►Vclis — Tracer injection
F. MONITORING PLAN
Provide a plan for monitoring the results of the injection, including:
(1) a list of existing and proposed monitoring wells to he 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 Hells must be located so as to detect any movement of injection fluids, process hv-
products, or formation fluids outside the injection area or cone. The monitoring parameters should include the target
contaminants 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 oaygen, and
rather eleetr-on acceptors and donors. The monitoring schedule should be consistent with the puce of the anticipated
reactions and rate n(tra►r.sport of the injectants and contaminants.
G. FELL DATA
Provide a tabulation of data on all existing or abandoned wells within '/< rile of the injection well(s) which penetrate the
proposed injection zone. including. but not lnnited to, nionitoring wells and welts 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' t.opographic map of the area, at a scale of 1:24.000 and
showing the location of the proposed injection site.
(2) Site snap including:
a. ail 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 'I. mile of the injection well or well system;
e. aH surface water bodies within '.t mile of the injection well or well system; and
f. all existing or abandoned wells within ,r mile of the injection well(s) which penetrate the proposed
injection zone, including, but not limited to, monitoring wells and wells proposed far use as injection
wells.
(3) Potentiometric surface amp(s) including:
a. direction of groundwater movement
b. existing and proposed monitoring weds
c. existing and proposed injection wells
(4) Contaminant plume map(s) including:
a, the horizontal extent of the contaminant plume, including isoconcentrat"son lines
b. existing and proposed monitoring wells
c. existing and proposed injection wells
(5 ) Cross -sections) to the lmown or projected depth of contarnixnation, including:
a. horizontal and vertical extent of the contaminant plume. including isoconcentration lines
b. major changes in lithology
c. existing and proposed monitoring wells
d. existing and proposed injection wells
Revised 6/09 UiC-51 5T Page 6 of 7

V1.
APPLICATION FOR PERMTr TO CONSTRUCT AND/OR USE A WELL(S) FOR DiJECTION
Type 51 Wells --In Situ Groundwater Recnediation 1 Type 5T Wells — Tracer Injection
CERTIFICATION (to be signed as required below or by that person's authorized agent)
NCAC 15A 2C .0211(b) requires that all permit applications shall be signed as follows:
1. for a corporation: by a responsible corporate officer
2, for a partnership or sole proprietorship: by a general partner or the proprietor, respectively
3, for a municipality or a state, federal, or other public agency: by either a principal executive officer or
ranking publicly elected official
4, for all others: by the well owner,
If an authorized agent is signing on behalf of the applicant, then supply a letter signed by the applicant that
names and authorizes their agent.
I hereby certify under penalty of law that I have personally examined and am familiar with the information
submitted in this document and all attachments therein, 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 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 the approved specifications and conditions of the Permit.
Printed Name and Title: 7ZO 3, �c ---
Signature: Date. 2- G -1 s
CONSC-T)FPROPERTY 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.)
As owner of the property on which the injection well(s) are to be constructed and operated, I 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(s) conform to the Well Construction Standards
(Title 15A NCAC 2.0 .0200).
Printed Name and Title:
Signature-, Date:
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]
Revised. 61ii9 L]IC-SIIST LEIVEL)1 r) iW j oft Poe 7 of7
�tdfer P�o(adi,,n ecljon
FEB 14 2011

UIC Permit Application A.fodiflcaion January 24, 2011
CM1 WaTP- 304 Eosi Main Sneed, Elkin, NC Page 3
MAC.TEC Project: 6228-08-4691
V. ATTACRMENTTS

UIC Permit Application Modification January 24, 011
CMI W147P- 304 East Main Street, Elkin, NC Page 6
MAC'T'EC Project: 6228-08-4691
ATTACHWNT A
SITE HISTORY

trIC Permit Application Adfhcarron Jaruat7- 24, 2011
(Vt H WTP- 304 East Main Street, Elkir, NC Prrge ?
AMCTEC Project: 622$-0,7 4b91
SITE HISTORY
11 Site Usa a and I-Iist
The Site is located within the floodplatn along the Yadkin River in Elkin and is pan of a larger tmxtile mill
complex that was formerly owned by Chatham, Inc. prior to sale of portions of the pr+operty to InterfaceFabric
to 2000. Other operations and facilities are located hydraulically upgzadient of the facility that are owned and
operated by InterfaceFabric.
Historical assessment activities were performed at the site between 1991 and ?002 by SPATCO, SPA
Eriviro=cntal & Engineering, Inc., and Sevee & Maher Engineers. Inc. Remedial investigation (RI)
activities were completed by Trigon Engineering Consultants, Inc. (Trigon) in 2005 to 2005 to locate and
delineate potential sources. further assess the vertical and horizontal extent of solvents withitn the regolith and
bedrock aquifers, and perform data evaluation. The previous investigations have included excavating
exploratory test pits, removing and testing various waste materials, sampling soil, groundwater. sediment, and
surface water at the site. Numerous Type 11 and Type III regolith and bedrock monitoring wells were
installed during the previous assessment activities, 40 of which have been sampled regularly through 2006.
(2) Origin of Contamination
The results of the RI completed by Trigon indicate that industrial wastes (i.e. trash, blankets, plastic, rusted
drums, fly ash, etc.) are buried within the floodplain along the Yadkin River at depths ranging from 5 to 20
feet bgs. The primary contaminants of concern (COCs) identified in groundwater beneath the Site are TCA
and it's daughter products, 1,1-DCA and 1,1-DCE. Additional volatile organic compounds (VOCs)
including 1,2-Dichloroethane, benzene, carbon tetrachloride, trichloraethene (TCE) and vinyl chloride have
also been detected at concentrations that exceed the 2L Standards. The RI concludes that the residual waste
material serves as the primary source of hazardous constituents to groundwater at the site and that the
constituents have generally leached from the waste materials through the overburden soils into groundwater.
3) Premus Remedial Action
To date. remedial actions at the site have been limited to the disposal of waste materials encountered during
exploratory test pit excavations in May 2005, October 2005 and September '-10W These wastes reportedly
included fabric, rusted drums, plastic dram liners, flyash and various other types of buried waste,
Between June 2 and 4, 2010. MACTEC installed three of the 10 proposed injection wells at the site (RV-
1. IW=?, and IW-3). MACTEC proposed to install the injection wells to approximate depths of 85 feet

UIC Petmtt Application Modiftwoon Januaty 24, 2011
CM1 O'K'TP- 304 East Main Street, Elkrn. NC Page 8
ANCTECProjec►; 6478-08-4691
bgs each and subsequently test the wells for specific yield and field VOC measurements in the upper,
middle and lower thirds of the bedrock interval. MACTEC planned to use these data to refine the depths
and construction details of the remaining seven proposed injection wells. However, no significant
fractures were encountered between the surficial casing (set at 25 to 26 feet bgs) and proposed total depth
(85 feet bgs) during installation of the three injection wells. Therefore, MACTEC extended and
completed each well as an open borehole well to a depth of 120 feet bgs. Based on the lack of observed
water -bearing fractures in the three injection wells, MACTEC did not install the remaining seven
proposed injection wells.

UIC Pet? it Application Modification Januar v 24, 2011
CM1 R'PfTP• 304 East Main Street, Elkin, NC Page 9
MACTEC Project: 6228-08-4691
ATTACHEMENT B
HYDROGEOLOGIC DESCRIPTION

VIC Pamir APPliatxr on Mod{f cation Jarnuun 24, 2011
CAV Hlf TP- 304 East Main Sirw. Elk n, NC Page 10
NIACTEC Priiecr. 6228-08-1591
MTROGEOLOGIC DESCRIPTIQN
(1) Regional Geolo 'c� Setting
The site is located near the boundary between the Piedmont and Blue Ridge Physiographic Provinces of
North Carolina and is underlain by meta -igneous and meta -sedimentary tacks of the late Prerarnbrian or early
Paleozoic Era. Furthermore, the site lies within the Brevard fault zone, where the Sauratown Mountain
Anticlinorium and the Smith River Allochthon converge, creating complex structural geology. The results of
subsurface explorations during the RI indicate that the Site is underlain by fractured biotite-chlorite gneiss.
Bedrock beneath the upper portion of the Site has weathered to a saprolitic soil mantle while bedrock beneath
the lower portion of the Site is overlain by recent alluvial deposits along the Yadkin River.
(2) Chances in Lithology
Two hydraulically connected zones of contaminated groundwater are present beneath the Site: the water table
and bedrock aquifers. The water table aquifer extends to a depth of approximately 25 feet bgs and is
composed of weathered bedrock residuum on the upland portions of the Site and alluvial deposits near the
Yadkin River. Groundwater flow in the water table aquifer follows surficial topography and flows south-
southeast to the Yadkin River. Based on the results of baseline groundwater sampling activities conducted in
June 2009, the primary COCs present in the surfncial aquifer are 1.1,1-Trichloroethane (1,1.1-TCA) at a
maximum concentration of 177600 ugll (E13MW-14), 1,1-Dichloroethane (1,1-DCA) at a maximum
concentration of 2,580 ugq in EBMW-7 and 1,1-Dichloroethene (1,1-DCE) at a concentration of802 ugll in
EBMW-14. Please note that EBMW-7 and EBMW-14 were the only two wells screened across the water
table aquifer that were sampled during the baseline sampling event. The dissolved phase plume in the water
table aquifer is estimated to be approximately 700 feet long, 200 feet wide and 7 feet thick,
The bedrock aquifer underlies the water table aquifer. Prior to installation of the three pilot injection wells in
June 2010, MACTEC understood that the bedrex:k aquifer was composed of weathered bedrocklsaprolite
fmtn approximately 30 to 85 feet bgs and fractured gneiss from approximately 85 to greater than 200 feet
bgs, based on previous wort: conducted by others at the Site. However, competent bedrock was encountered
consistently at 21-23 feet bgs during installation of the three iriiection wells in June 2010. In addition.
significant water -bearing fractures were not encountered above 120 feet bg►s. Consistent with the water table
aquifer, the primary COCs in the bedrock aquifer are 1,) , I -TCA (3217,000 ug11 in EBMW-9 ). 1.1-DCA
(39,200 ug1l in EBMW-I8) and 1.1-DCE (19,900 ug4 in EBMW-9) based on the June 2010 groundwater
data.. The extent of contamination in the bedrock aquifer is estimated to be approximately 650 feet long i (H)

UIC Penno Applivo6on Modification danvan• : 4. 2011
CAAff H'tiTP- 304 East Maur Save[, Elkin. NC Page ! 1
AIACTEC Protect: 622fi 08-d691
feet wide and 150 feet thick However, the analytical data indicate that the majority of contaminant mass is
located within 85 feet of the amuttd surface
t 3 } Aquifer bpperties
Based on previous work conducted by others (Trigon, 2007), limited data are available regarding the
relative permeability of the hydrologic units in the iloodplain area. To estimate the permeability of the
fill and filitalluvial deposites in th e WWTP area, baildownlrecovery tests were conducted in :monitoring
wells MWE-1 and EBMW-4 by previous investigators (Bain & Palmer, 1992). Based on these
investigations, the estimated horizontal field permeability (4) of time fill/alluvial deposits in the area of the
equalization basin ranges from approximately 2 x le to b x 104 centimeters per second (cn-dsec),
generally consistent with gain -size analyses of these materials reported by Sevee & Maher, 2001.
Localized horizontal confining layer; may he present within the alluvium and effective vertical
pemmeabilities (kt) within the fii€/aliuvial deposits may be significantly less tl= horizontal permeabilities
(k,,) in areas of the site. Field permeability data is unavailable for the filllalluvia] deposits on the western
portions of the WWTP property to the south of the Flyash Basin.
The single permeability test performed in shallow bedrock (EBMW-1, screened at 23.5 to 33.5 feet below
ground surface) confirms that bedrock permeabilities are fracture controlled. with variations in individual
fracture permeability in the new vicinity of the well ranging from 1 x 10-5 to 2 x 10-7 cnvsec. Variations
in bedrock permeability of several orders of magnitude are indicated, depending on degree of weathering
and frequency of relict fractures intersected. Because of the foliated nature of the gneisses and schists at
the site, anisotropy in permeability may exist. PermeabiIities in directions parallel to bedding or foliation
may be several orders of magnitude greater than in directions normal (perpendicular) to foliation. Joint
and fracture orientations may also significantly influence directional permeabilities. Based on geologic
trapping in the Elkin area, a general northeast strike can be anticipated for major fracture sets.
Complimentary features normal to this orientation can be anticipated. Steeply dipping joints and fractures
have been obsen�ed. Measure field permeabilities at specific well locations (which may not interesct
near -vertical fractures) may significantly underestimate actual field permcabilities due to the steeply
dipping fracture orientations within the rock mass.
To supplement the historical permeability testing summarized above, MACTEC performed yield testing
in injection wells IW-I. IW-2 and IW-3 on September 21. 2010, to evaluate whether the wells could be
used for injection purposes. Given that fractures were not observed during installation of the wells and
that shallow bedrock monitoring wells at the site continue to exhibit the highest VOC impacts, MACTEC

tNC Permit Appllcarion Madilicawn Jamey 24. 011
CMI F1'B7P- 304 East Main 5tmet. EIhn, NC Page I?
AIACTEC Project: 62-78•08-4491
isolated the shallow bedrock zone by setting upper and lower well packers at 30 feet and 80 feet bgs.
respectively in each well. Following inflation of the packers, water was pumped from the test interval
using a Crrundfos• kedi-Flaw pump set approximately one foot above the lower packer. The initial depth
to water measurement recorded in well IWA after inflation of the packers, but before pumping was 17.30
feet below top of casing (btoc). The well was pumped at an approximate rate: of 3 gallons per minute
(gpm) for a period of 11 minutes before the water level between the packers dropped below the pump
intake. The depth to water after ] 1 minutes of pumping was recorded at 18.10 feet btoc. Therefore, the
water level in the well above the upper packet had dropped 0.80 feet during pumping, indicating little
seepage of groundwater around the upper packer. After a 30 minute recharge period, the pump was
started again and ran for four minutes while discharging. nine gallons before going dry again. MACTEC
then reversed the flow on the pump and pumped clean water into the test interval under a pressure of 80
pounds per square inch (psi) while measuring flow using a conventional in -line flow meter. A total of 32
gallons of clean water were pumped into the test interval before depth to water measurements above the
upper packer began to steadily rise, indicating that water was being forced around the upper packer under
pressure. Similar results were observed during the yield tests performed in wells IW-2 and fW-3.
(41 Mean Seasonal Hip Water Table
Depth to grolLmdwater measurements recorded in June 2009 in the existing shallow bedrock monitoring wells
(EBMW-5, EBMW-8. EBMW-9, EBMW-14, EBMW-1 S and EBMW-222) proposed to serve as injection
wells ranged fmm 5.65 to 14.81 feet below the top of we]1 casing, or approximately 3 to 12 feet bgs.

UIC Pennd Application Mod f aadon Jamia;:r 24, 011
CM1 W TP- 304 East Main Srreet, Elkin, NC Page 13
MACTEC Project: 6338-08-4691
ATTACHMENT C
INJECTION FLUID COMPOSITION

UIC Pernur Application AlodiTcation January 24. 0IJ
CAR K'H TP- 304 East Main Street, DO?. NC Page 14
M..4C7E'C Project: 6.'8-08-4691
INJECTION FLUE) COMPOSITION
In accordance with the Remedial Action Plan (RAP) Addendum prepared by MACTEC and submitted to the
NCDENR concurrent with this UIC Permit Modification, injection will be conducted using an electron donor
compound in the overburden aquifer (3DMe) and shallow bedrock zone (3DMe with HRC Primer) for the
treatment of CVOCs in groundwater at the Site. Hieing of the injectants will be conducted on -site using
municipal water. Hydrogen Release Compound Primer (HRC Primer) is a water -like compound that releases
lactic acid for fermentation by subsurface microbes, in turn producing hydrogen to `Jump start" the reductive
dechiorination process. it is a non -hazardous, food grade compound composed of glycerol poiylactate and
lactic acid, and is typically applied via direct -injection into the source area. It is expected to remain active for
up to three months. 3-D Microemulsion is a time -release electron donor compound which incorporates
esterified lactic acid with esterified fatty acids to stimulate reductive dechlorination for extended periods.
3DMe is composed of a hydrogen release compound -partitioning electron donor (HRC-PED), fatter acids,
glycerol tripolylactate and glycerol that, when combined, behave as surfactants, with a hydrophilic end and
lipophylic end. As a result, the molecules tend to align themselves with the hydrophilic ends in water, while
the lipophylic ends bind to organic compounds. 3DMe has a iow positive Hydrophile/Lipophile Balance
index allowing it to sorb organic contaminants, but have significant solubility in water to move through the
saturated soil matrix and fractured bedrock zone beneath the Site. Material. Safety Data Sheets. (MSDS) have
been included for the HRC Primer and 3DMe injectants.

U1C Perrnif Application A7odif cWion Janum7 24. 1411
CM! u'H P- 304 East Maid Str, eer, Ellin, NC Page 15
AIAMC Projccr: 6,128-08-4691
ATTACHMENT Q
INJECTION RATIONALE

U1CPernri Applrcallon Marfifirrrriorr .Inuu«n! 24. 011
C,141;IWTP- 304 Fast Main &ree, Elke'n. NC Page 16
M.4CTEC Praiser: 6128-08-4691
IN.tECTION RATIONALE
(1) ltnjection_Proiect Goals
The primary goal of the proposed retnediation is to reduce the concentrations of CVQCs in groundwater
to mitigate potential off --site migration of impacted groundwater above the groundwater quality standards
defined in 15A NCAC 2L.02021 QIL Standards) while promoting longer term monitored natural
attenuation. The proposed injection program has been modified from the original application based on
the results of the pilot injection well tests. The revised program includes in -situ chenucal injection to the
impacted shallow bedrock and saturated overburden zones directly into the targeted chemical treatment
zone at approximately 15 to 120 feet bgs at three areas at the Site identified as Area A, Area B. and Area
C on Figure 1.
Bedrock injection will be performed via six existing wells (EBMW-5, EBMW-8, F13MW-9, EBMW-10,
EBMW-18. and EBMW-77) and the two new shallow bedrock wells. Biostimulation in bedrock will use
3DMe and HRC Printer in combination. Dosages for the bedrock wells have been estimated based on the
estimated length of fracture zones in the open hole or screen segment of the wells. Table 1 provides the
quantities of 3DMe and HRC Primer to be injected at each bedrock well. As shown on the table. each
well will receive 80 to 160 pounds (lbs) of HRC Primer, followed by 200 to 400 gallons of a I M 3DM.e
emulsion (water to 3DMe concentrate),
Overburden injection will be performed via approximately 150 DPT bore -holes installed over au area of
approximately 52,000 square feet (see Figure 1) using direct -push drilling techniques (DPT). During
probe insertion, injections will be performed at three elevations. The first injection will occur at a depth
approximating the top of groundwater (15 to 17 feet bgs), the second injection will be two feet lower (17
to 19 feet bgs), and the final injection will occur at the depth of refusal. The 3DMe emulsion for the
overburden points will be diluted at a 20:1 ratio (water to concentrate) in order to provide better
distribution, Table 1 provides the volumes of emulsion to be injected at each point in Areas A. B_ and C.
(2) Description of Contaminant/lnjectant Interactions
Reductive dechlorination is the mechanism by which chlorinated compounds are biodegraded into less
harmful constituents such as ethene and ethane. The two proposed products, HRC Primer and 3DMe, are
anticipated to promote the reductive dechlorinization of TCA and other chlorinated compounds detected in
the subsurface. It is anticipated that intermediate compounds Mill include the daughter products of TCA and
TCE, such as 1,1-dichloroethene. 1.2-dichloroethene, 1,14chlomethane and vinyl chloride.

TABLE 1
3DMe and HRC Primer Dosages
CMI Waste Water Treatment Plant
Elkin, North Carolina
MACTEC Project 6228-08-4691
Injection
Points
Overburden
3DMe 30Me 10:1 3DMe 10:1
Concentrate Emulsion Emulsion
(Ibs) (Ibs) (gal)
Additional Total 3DMe
Mix Water Volume
(gal) (gal / pt)
Total HRC an
3DMe
HRC Primer Volume
(lbs / pt) (gal t)
Area A 80
8,100
89,100
10,677
9,710
255
0
295
Area B 40
3,81t7
41,910
5,022
4,570
240
0
240
Area C 30
2,220
24,420
2,927
2,670
187
0
187
Bedrock
Area A
EBMW-8 1
15❑
1,650
395
0
395
80
404
EBMW-10 1
300
3,300
395
0
395
120
409
New well 1
210
2,31❑
278
0
278
160
297
Area 9
EBMW-5 I
150
1,65❑
198
11
198
SO
207
EBMW-9 1
150
1,650
198
U
198
80
207
New well ;
300
3,300
395
U
395
160
414
Area C
EBMW-18 i
150
1,650
198
t1
198
80
207
EBMW-22 1
210
2,310
278
0
278
0
278
Totals 15t.
15,75❑
173,250
20,961
16,950
37,945
760
38,033
Source: Regenesis October 22, 2010 Proposal 2DBO9325 Prepared by / pate: GW 1/12j11
Notes: Checked by / Date: MPF 1/26/11
Ibs = pounds
gal = gallons
pt = point

t YC Permn Appheatran Madtfiewim Janawy 24, 2011
CW O HTP- 304 Eci_ri Again Street, Elkin, ArC Page 17
MACTE'C Nnjecr: 6228-08-4691
IIRC Primer is a thin, water -like compound that will be imtrodueed to the shallow bedrock aquifer via
injection into existing and proposed monitoring wells. It releases lactic acid into the aquifer over a period of
several weeks. HRC Primer makes lactic acid more immediatclN, available for fermentation by subsurface
microbes. The lactic acid is in turn used by other microbes to produce hydrogen, the key ingredient in the
anaerobic contaminant degrading process Ireductive dechlorination).
3DMe is a patented molecule (patent pending) specifically designed to time release a combination of highly
efficient electron donors. Additionally, 3DMe was designed with a relatively high hydrophilicllipophilic
balance (HLB), allowing dilute suspensions to be well distributed across contaminant plumes. Upon
application to the subsurface, 3DMe begins to produce hydrogen and to distribute hydrogen generating
compounds to the subsurface through a series of hydration and fermentation reactions. This process provides
for an immediate as well as time -release supply of hydrogen to fuel the demands of the anaerobic reductive
dechlorination process. Typical longmity for 3DMe is up to ? years or more on a single injection and up to 4
years or more under optimal conditions.
(315ununary of Modeling or Pilot Testin,�
Modeling an&or pilot testing have not been conducted at the site. However, 3DMe has been successfully
used to treat CVOCs in groundwater at sites throughout the United States and at similar concentrations as
those observed at the CMl VIWTP site. The RAP evaluated the injection approach in accordance with the
REC Program guidelines and provides for conducting the injection activities in phases pending availability of
funds, so that adjustments can be made based on observed results.

UIC Peomil Application Modification Jaattary 24, 2011
C,Wl WHTP- 304 Easr Main Street, Ella,, NC Page 18
MACTEC Project: 6228-08-4641
ATTACHMENT E
INJECTION PROCEDURE AND EQUIPMENT

LUC Permit 4pplicXion MiAlica[ion Januan, 24, 2011
CMf HIM- 304 East Main Strevl, Elkin, NC Page 19
U,IOW Prnjrcl: 622&-08-46y1
INJECTION PROCEDURE. AND EQWMENT
(1) Construction Plans and Materials
Bedrock Injection
Based on the results of pilot testing, productive fractures are ntost frequently encountered in the upper 10
feet of bedrock (20-30 feet bgs), with additional low -capacity fractures encountered between 70 and 100
feet bgs. Two new bedrock wells will be drilled to 40 feet bas and cased from the surface to 20 feet bgs
adjacent to existing wells EBMW-12 and EBMW-14. The initial boring will be advanced using an eight -
inch auger to the top of weathered bedrock. A four -inch Schedule 40 polyvinyl chloride (PVC) casing
will be installed and grouted in place. After allowing the grout to harden overnight, a 3-7/8-inch air -
rotary drill will be inserted through the casing and the boring will be advanced to a total depth of 40 feet.
Cuttings will be containerized in open -top drums provided by the contractor for disposal. The new
bedrock injection wells will be completed with a lockable steel above -grade enclosure and compression
cap. Subsequent to new well installation, bedrock injection will be performed via six existing wells
((.BMW-5, EBNIW-8. EBMW-9, EBMW-10, EBMW-18, and EBMW-?^) and the two new shallow
bedrock wells.
Overburden Injection
The depth to groundwater in the overburden is approximately 16 feet. The top of weathered bedrock was
encountered at approximately 20-21 feet bgs during pilot testing, yielding a saturated thickness of 4 to 5
feet in the overburden. Injection into the saturated overburden will be performed using direct -push
drilling techniques (DPT). kpproximately 150 DPT boreholes will be installed over an area of
approximately 52,000 square feet (see Figure 1). Prior to DPT borehole installation, a two-inch augered
boring will be installed at four locations to determine the local depth to top of bedrock. The new bedrock
wells near EBMW-12 and EBMW-14 will be used for two of the borings, one will he located near
EBMW-8, and one located near the midpoint of Area C, between EBMW-16 and FAMW-2- Adjacent
DPT points will be driven to refusal and the ultimate refusal depths should approximate the depth to
bedrock determined by the auger borings.
A track -mounted DPT brill rig using 1-5-inch to 2.5-inch drill rods Aith retractable injection tips will be
used to install the injection points, During probe insertion, injections will be performed at three
elevations. The first injection will occur at a depth approximating the top of groundwater (15 to 17 feet
bgs), the second injection will be two feet lower (17 to 19 feet bgs), and the final injection will occur at
the depth of refusal. Figure 1 shows the three injection areas and the approximate locations of the

LAIC Permit Application Modr►icadon .lainiar} i4, 2011
C'MJ ATTP- R4 Easy Main 5rre+et. Elksm NC Pam ?U
AMCTECProject 62118-4S-d691
injection points. Actual locations will be adjusted as necessary depending upon surface obstacles and
underground utility locations.
As the drill rod is advanced, approximately one third of 3DMe solution volume shown on Table 1 will be
injected at each of the three intervals, spaced approximately two feet apart vertically from the top of
goundwater to refusal. The solution will be injected using a positive displacement pump. fluid
discharge from the pump is coruiected directly to the DPT rods for injection into the matrix. The DPT
rods will be equipped with slotted, retractable drive points that permit injection at multiple levels during
the same push. The positive -displacement injection pump has a dead -head pressure capability in excess
of 1.000 pounds per square inch (psi); however, because of the shallow depth of the injections, pressures
are not expected to exceed 300 psi before fracturing of the matrix occurs. Injection will proceed in a top -
down manner at the aforementioned two -foot intervals from the top of the water table to refusal.
After injection is complete, the overburden injection borcholes will be properly abandoned using Portland
cement ggmut.
f 21 Operation _Procedures
The proposed injection(s) will be conducted in accordance with the 3DMe manufacturers guidelines, as
specified in the attached Installation instructions.
[3 f 5urfac_e and Subsurface Svstem Diagram
In -Situ chemical injection is proposed for the site via specifically design low pressure (i.e., <300 psi)
injection wells using mixing tanks and low pressure pumps. This remedial action does not involve the
construction of permanent structures, other than the monitoring wells.
(4) Injection Schedule
The following table summarizes the proposed schedule.
TASK
Schedule to Complete Task
Bedrock Well Installation
10 days
Bedrock and Overburden Injection
30 days
Construction Completion Report
30 day.
Performance Monitoring - Analytical Sampling
(4- ost injection events)
30 monfhs
(months 3, 9, 18, and 30 post injection)

UIC Permir APPl+cntion Mod f cation Januan• 24. 011
CMI WW P- 304 East Main Street, Elkin. NC Page 21
MACTEC Project: 62 28-Q8-4691
A I"T'ACHM ENT F
MGNITORINTG PLAN

UIC Perma .4pplicarian Mndlfica twn .lamiur y 34, 2011
CAff HH772- 304 East Alain Street, Elhn. NC Page 22
AUCTEC Projecl- 622X08-4691
MONITORING PLAN
BaseHne Groundwater Monitoring
Less than 24 hours prior to injection, water levels will be measured and groundwater ele%-ations will be
calculated from selected monitoring wells in Area A, Area B, Area C, and bedrock monitoring wells as
shown on Table 2. Field parameters consisting of pH. oxidation reduction potential (ORP). dissolved
oxygen (DO), temperature, and specific conductance will be measured in the monitoring wells shown in
Table 2.
Past -Treatment Groundwater Monitoring
Pending availability of funds, periodic past -injection groundwater field monitoring and sampling will be
conducted for the first year following the completion of 3DMe4MC Primer application at the well
locations shown in Table 2. Table 2 includes monitoring of the same wells that were sampled during the
baseline sampling event (overburden -monitoring wells EBMW-7 and EBMW-14 and bedrock source area
monitoring wells EBMW-1, EBMW-5, EBMW-8, EBNfW-9, EBMW-10. EBMW-18, EBMW-19.
EBMW-21, EBMW-22, and EBMW-23), plus additional well locations and surface features (ditches) to
monitor the impacts of injection on groundwater in the overburden and shallow bedrock (up to 45 feet
bgs). The objective of the groundwater monitoring is to evaluate effectiveness of groundwater treatment
by assessing trends of CVOC concentrations in shallow bedrock and to assess distribution of 3DMe'1 RC
Primer in the shallow bedrock zone via monitoring of field parameters such as temperature, specific
conductance, DO, ORP, and pH.
Field measurements of temperature, specific conductance, DO, ORP, and pH and groundwater quality
monitoring for CVOCs will be conducted at the frequency noted in Table 2. The data will be used to
evaluate effectiveness of the injection activities. Groundwater samples will be collected from the saute
wells that were sampled during the baseline sampling event plus additional well locations (as shown on
Table 2) and submitted to an analytical laboratory for analysis of VOCs by United States Environmental
Protection Agency (EPA) Method 8260E and select natural attenuation parameters: methane, ethane, and
ethene by RSK-173, sulfate by ASTM D516-90, ferrous iron by SM- 3500-Fe D-44, total dissolved solids
by EPA Method 160.1, and chloride by SM 4500-CL-E.

IARIX 2
6mundivaItr Mon[toOng SrheduIt fur 1;loslimu[aIlop I'cKomi anet
CM ►Yatle WaItr Trem Inrenl Plaal - El kill. North CurolIns
11AC Fi Project 6Z29-419-4691
Sampling
Frequency [from
Parameters
Category
Locations (1)
Injection
All Samples
Baseline
A: F13MW-13,-12, 8,-7.-K,2€, µ .W
Less than 24 hours
Field
Groundwater Elevations
(pre injretioul
I%V-12+, i1V-14+, PAMW-i
prior In injection
W EBMW-I I,-If1,-1,-15; 5 6, r 7 FPA,W
CFAMW-^_, FHMW-d,-23; 24,-t8
and EBMW-29
Iietlrmk: l;t3tr %9.-11L-J
At EHIr1W-13,-12.-8,-7,44, +
1'riC'r kn injection
Fluid
pH, Oxidation -Reduction Polenlial, Dissulvcd Oxygen, -1 emperuture. SIHxiPc
IW-12+, IW-144
Cunduclance.
H EBMW-I 1,-16,-[: S 6, r 7
C FAMW-2. EBMW4, 23,-24
and E13MW-29
ditch byELIMW-23.-1I.-14
I3ii,C1 iml,Jnlion
A: EBMW-I3,-12, -8,7; 14, y� !f
Months I, 3, 9, 11
Field
Oiu%l nduater Ele%muvns
1:1ii�ii%vtie':s
IW-12+, 1W-14+, FAMW-I
Iwithin lirctyCar1
13: FHMW-I),-Iti: I.-15:5 �, 1 7
C: CAMW-2. E13MW-4,-23; 24, }t R 7
and EBMW-29 pniposod
flcdnxk:l'BMW-4,-1(1,-IR:19,21:??
__
_
A: F..BMW-13,-1?, -8. 7; 14, k
_ _ __
Months 1, 3, 9, I8
_
Field
pl I. Oxidation-Redvgfan Prtrntiai, Dissolved oxygen, Temperature, Specific
[W-121. IW-14+
C'ootloclance.
i3: EBMW-11,-I
C: FAM W-2, E BM N'4-23.-24 f s
and EBMW-29
ditch: by 1.13MW-23, -11. -14
t3r71rex:. F):3X1W-4� -
htonllrs 3, 9, 1It
Lah
A_ 1-[1MW-7,-8,43,-14 and IW-12+ Y
TCL VCICs (FPA Method 82MR),
W EBMW-1. 5 6 i 7 PT' ,v,w y t s
C: FAMW-23 and EBMW-'-9 proposed "
ditch: by EBMW•14
i3cdrtx:k:._]::I311ti 'ti}�2�19.- - -
FTIM W-), -S.- 14 kind 1W-12►
Months 3 and IS
Lab
Chkuide{SM 45t)O-CL.E); sLtMic {ASTM W116-913}, ferrous iron ISM 3300-
Fe D04 y, and Total 13Lssnlved Solids CFPA 160,1 J.
CBM�V-1 8 -14 and I%V-12+ - ^
Months 3 and 18
Cub
liviviltanc, Elhan and t therm PA Mcdwd RSK 175).
Naturai Aucntiatiun
A: EUMW-7,-S. 14 Y x
Annually, as handing
TC'L VC s �A Method 52R)13)-
MankoTing
13:1.BMW-I.5 6 1 7 FPiu u'
prrmils
p11.Oxidalion-Reduction t1otentia1, Diasolvod Oxygcn,1ranperature, Specific
(Ixwl huntimulatiUa
C':1_BMW-29, 1:13MW-23
I
Conductancc.
clTtvitvencsrman itimingI
Hedriiek: 113MW-9,-IIl.-IS; lµ,-?I,-T2
Invcsligatitie 13eii%cA W isic
DiiII cuttivgs and purge walrr
Prior to disp i+ Al
I.ab
TCL. VCIC s {EPA Iv[ctluxl R2htll3l,
Nolrs: (1) IWA2+ and IW-14* ate injection wrils to be drilled im❑ llic top of twhased rLxk Ascvnt In EBMW-12 and EBMW-14.
rin-cpeclively. F.13MW-29 in Area C is a convened injecliosr pvW, lmalad upprnximalely 513 feel norlheasl or
I13h1W-I I and 9t! feet wLxr (if F.BMW16.
Ovcrhurdcn welLe and clraIlow bedrock wells with a inlaI depth of 45 feel rr lees nre considered nc monitoring poilsis for the
ovoburden injection atcaLs A, 13, aral C. "Bedrot1" wrlla 113%tr a (OW elelith grealcr Man 45 Nei and are inl+niloicd
Ir1 del co changer in conlaniinant conecntralions and 1n0ueams due to injmlions-
(2) Sampling rroyucnny conlingvnt ttixin availabilily of funds
Vrywred bylVale. OW Ii31iI
P:16224% Hivinknnrulaiivlx'•2004V28.O8.4691 CM WW" (KELP)%RAP Addenduni%Table 2 sangrliagF?NAL!gIs% Checked bx/1} W RV I1YI I

UIC Perim Application Modification January 24, 2011
CM W1iTP- 304 Easr Main Street. Ellmi. NC Page 23
MACTEC Project: 6 —78.08 4691
Lung -Term Groundwater Monitoring
Long term groundwater monitoring andlor further treatment applications will be recommended lased on
the results of the past -treatment groundwater monitoring results, depending on availability of funds as the
project proceeds.

UIC Permit Application Mortification January 24, ?011
C!417 grK TP- _404 East Main Street, Elkin, NC Page ?4
MACTEC Project: 61?8-08-4691
ATTACHMENT G
WELL DATA

C.IC Permit Application Mod yicatinn Jaoman, 24. 2011
CAV HIVTP- 304 East Main Street, Elkin, NC Page 25
M.ACTEC.Projecr: 6 28-08-4641
WELL DATA
Based on information contained in the RI Report prepared by Trigon, there are no known users of
groundwater in the immediate vicinity of the injection area. The nearest known well was reported to be a
residential water well located more than `/s-mile to the east and cross -gradient of the site on Highway 268.
Based on well construction data fmm the RI, eight wells are known to be screened within the proposed
injection zone. Six of these eight wells will be utilized as injection wells for the proposed remedial action. A
summary well construction details for the eight wells located within 'I -mile of the injection site was
presented in the initial Application, dated February 21, 2009.

UIC Permit Application Mort fcarion
CMI WFt'TP- 304 East Main Srrw4 Elan, NC
M.9 CTEC Project. 6228-08-4691
ATTACHMENT H
MAPS
January 24, 2011
Page 26

UIC Permrr App2icarion Modifrcanon
CMI WFP P- 304 East Umn Street. E1ktn, NC
MALT ' Projecr: 6228-08-4691
January 24.2011
Page 2 7
MAPS
As previously discussed, the injection program has been modified to include in -situ chemical injection to the
impacted shallow bedrock and saturated overburden zones directly into the targeted chemical treatment zone
at approximately 15 to 120 feet bgs at three areas at the Site. These arm and the approximate location for
the overburden and shallow bedrock injection points are shown on Figure 1.

Documents Associated with
the July 10, 2009
CMI Industries
Injection Well Permit

AMACThC
engineering and constructing a better tomorrow
February 27, 2009
Mr. Thomas Slusser, Hydrogeologist
North Carolina Division of Water Quality
Aquifer Protection Section — Groundwater Protection Unit
2728 Capital Boulevard
Raleigh, North Carolina 27604
Subject: Application for Permit to Construct and/or
Use a Well(s) for Injection
CMI Waste Water Treatment Plant
Elkin, North Carolina
Site ID NUNCD 0001092
MACTEC Project 6228-084691
Dear Mr. Slusser:
RRECEIVED/ DENR / a WQ
gtrifPr Prafertion Section
iAi? U 5 2009
On behalf of CMI Industries, Inc., MACTEC Engineering and Consulting, Inc. (MACTEC) is
submitting this Application for Permit to Construct and/or Use a Well(s) for Injection for the
subject property located in Elkin, Surry County, North Carolina. This permit application was
prepared in general accordance with the North Carolina Department of Environment and Natural
Resources Division of Water Quality guidance UIC-51/5T dated August 2007 and the Remedial
Action Plan prepared by MACTEC and submitted to the NCDENR in January 2009.
If you have questions concerning this report, please contact the undersigned at [phone].
Sincerely,
MACTEC ENGINEERING AND CONSULTING, INC.
Mark P. Filardi, P.G. Andrew M. Clark, P.G.
Senior Geologist '-principal Geologist
For
WE Permission
Enclosures
MACTEC Engineering end Consulting, Inc.
2801 Yorkmont Rand, 5uire 100 0 Chorlo�te, NC 28208 0 Phana 7D4.357 8600 • Fax- 704.357.8638 www.mactec.com

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells — In Situ Groundwater Remediation 1 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 package being returned.
Application Number (to be completed by DWQ): L� 1 0
I. GENERAL INFORMATION:
I. Applicant's Name (generally the responsible parry): CMI Industries
2. Signing Official's Name: .lames A. Ovenden Title:
3. Mailing address of applicant: 219 Muirfieid Drive
City: Spartanburg State: SC Zip: 29306
Telephone number: Fax number:
4. Property Owner's Name (if different from Applicant): Same as Applicant
5. Property Owner's mailing address: Same as Applicant
City: State: Zip:
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Andrew M. Clark
Company: MACTEC Engineering and Consulting, Inc.
Address: 2801 Yorkmont Road, Suite 100
City: Charlotte
Telephone number: 704-357-5630
Email Address: [e-mail]
U. PERMIT INFORMATION:
Title: Principal
State: NC Zip: 28208
Fax number: 704-357-8638
1. Project is: ® New ❑ Modification of existing permit ❑ 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 NA and the issuance date NA
For renewal without modirications, fill out sections I & 11 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-5I15T Page 1 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation / Type 5T Wells — TR5'*�OOSNiI! r
Bft
III. INCIDENT & FACILITY DATA A4u►fiarPrnt"inn QAf'"On
A. FACILITY INFORMATION
1. Facility name: CMI Waste Water Treatment Plant
2. Complete physical address of the facility: 304 East Main Street
City: Elkin County: - Surry State: NC Zip: 28621
B. INCIDENT DESCRIPTION
I. Describe the source of the contamination:
Remedial Investigation (RI) activities were completed by Trigon Engineering Consultants, Inc. (Thgon) in 2005-
2008 to locate and delineate potential sources, further assess the vertical and horizontal extent of solvents within
the regolith and bedrock aquifers, and support risk assessment of the WWTP. The RI indicates that the primary
contaminants of concern (COCs) identified in groundwater beneath the Site are TCA and it's daughter products,
1,1-DCA and 1,1-DCE. Additional volatile organic compounds (VOCs) including 1,2-Dichloroethane, benzene,
carbon tetrachloride, trichloroethene (TCE) and vinyl chloride have also been detected at concentrations that
exceed the 2L Standards. The RI concludes that the residual waste material serves as the primary source of
hazardous constituents to groundwater at the site and that the constituents have generally leached from the
waste materials through the overburden soils into groundwater.
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, pesticidesltierbicides, etc):
1,1,1-Thchoioroethane, 1,1-Dichloroethane, 1,1-Dichloroethene, 1,2-Dichloroethane, benzene, carbon
tetrachloride, trichloroethene, vinyl chloride
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
9 Yes If yes, list maximum measured separate phase thickness ap roximately 1 feet
❑ No If no, list maximum concentration of total VOCs observed at site: ppb
4. Agency managing the contamination incident:
❑ UST Section ® Superfund Section (including REC Program and DSCA sites)
❑ DWQ Aquifer Protection Section CI Solid Waste Section
❑ Hazardous Waste Section ❑ Other:
5. Incident managers name Kim Caulk
and phone number 919-508-8451
h. Incident number or other site number assigned by the agency managing the contamination incident:
NONCD0001092
C. 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:
I. Hazardous Waste Management program permits under RCRA: NA
2. DWQ Non -Discharge or NPDES permits: NPDES Permits
3. County or DEH subsurface wastewater disposal permits: NA
4. Other environmental permits required by state or federal law: NA
Revised 8/07 UIC-51/5T Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells —In Situ Groundwater Remediation l Type 5T Wells — Tracer Injection
IV. INJECTION DATA
A. INFECTION FLUID DATA
I. 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 (GEES) of the Division of Public Health, Department of
Health and Human Services. Review the List o gMroved injectantsT or contact the UIC Program to determine if
the injectants you are proposing have been reviewed by GEES.
Injectant: Hydrogen Release Compound Primer _
Concentration at point of injection: 100% Concentration
Injectant: 3 D Micro emulsion (Hydrogen release compound)
Concentration at point of injection: 10% solution by volume 10 parts water to 1 part 3DME
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
Injectant:
Concentration at point of injection:
2. Source of fluids used to dilute or chase the injectants listed above:
❑ None
® Municipal water supply
❑ Groundwater from private well or any well within '/4 mile 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: NA
b. Depth of source: NA
c. Formation: NA
d. Rock/Sediment type: NA
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 applyfor a closed -loop groundwater remediation permit using application fogn
GWRS
Revised $107 UIC-5I15T Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells — In Situ Groundwater Remediation 1 Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: 2
Expected duration of each injection event: 2 weeks
Expected duration between events (if more than one event): 6 months
2. Injection rate per well: 2-10 gallons per minute (gpm)
3. Total Injection volume: 2,454 gallons per day (gpd); 24,541 gallons per event (if separate events)
4. Injection pressure: <100 pounds/square inch (psi)
5. Temperature at point of injection: Ambient OF
6. Brieflv describe how the above tiarameters will be measured and controlled:
Flow will be controlled/modified at each well head using regulating flow meters.
7. Estimated hydraulic capacity of the well: gpm
C. 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.
K Proposed well(s) to be constructed for use as an injection well. Provide the data in (2) through (6) below as
proposed construction specifications.
2. Well Drilling Contractor's Name: A. Multiple Contractors B. Geologic Exploration
NC Well Contractor Certification number; A. Various B. 2854
3. Date to be constructed: B. April 2009 Number of borings: A. 6 B. 10
Approximate depth of each boring (feet): A. 33-75' B. 85'
4. Screened interval/Injection interval of injection wells:
Depth: 0 to 85 feet below ground surface (if multiple intervals, indicate shallowest and deepest depth).
5. Well casing (NIA if injection is through direct push rods):
Type: © PVC ❑ Stainless steel ❑ Other:
Casing depth: Q to f 20 ft. (gyp eF
6. Grout (NIA if injection is through direct push rods):
Type: ® Cement ❑ Bentonite ❑ Other:
Grout depth: 0 to -20 ft. ODp of rock)
Revised 8107 UIC-5115T Page 4 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Weds —In Situ Groundwater Remediation / Type 5T Wells — Tracer Injection
V. ATTACHMENTS
Provide 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 andsealed by him or
her.
E. 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 injectaot. Attach the Material Safety
Data Sheet (MSDS) for each injectant. If private well or a well within''/. mile of the injection site is used as the source
well, 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-
products, or formation fluids outside the injection area or zone. The monitoring parameters should include the target
contaminants 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, OAP, dissolved oxygen, and
Revised 9/07 U[C-5V5T Page 5 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation l 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 'I. 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'/, mile of the injection well or well system;
e. all surface water bodies within '/{ mile of the injection well or well system; and
f. all existing or abandoned wells within''/, 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-5115T Page 6 of 7

APPLICATION FOR PERNUT TO CONS RUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remedlation / Type 5T wells -- Tracer Injection
Vi. CERTIFICATION
TA-A't.qinuAns=no!'k;+ hereby c under penalty of law that
I,v t• - J YY P Y
1 bare personally examizted 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 bolicve that the information is true, accurate and complete. 1 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 the approved specifications and conditions of the Permit.
Signature: Datc:
Titic.
Ij 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 or land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement in writing.)
I Same as AptpliGat3�e nrnrorwrty owners , 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(s) conform to the Well Construction Standards (Title 15A NCAC 2C .0200)
Signature: Date:
Title:
Submit TWO copies of the completed application package, including all attachments, to:
UIC Program
Aquifer Protection Section RECEIVED 1 DENR I DVVQ
North Carolina DENR-DWQ AgUfar Pmtwirm SArtion
1636 Mail Service Center M�{ �] Raleigh, NC 27599-1636 +
Telephone [phone]
ti
Revised 9/07 UIC-5I15T Pap? of 7

UIC Permit Application
CM-1 WWTP- 304 East Main Street, Elkin, NC
MACTEC Project: 6228-08-4691
ATTACHMENT A
SITE HISTORY
February 27, 2009
Page 6

UIC Permit Application Februaty 27, 2009
CMI WWTP- 304 East Main Street, Elkin, NC Page 7
Mr4CTEC Project: 6228-08-4691
SITE HISTORY
(1) Site Usagre and History
The Site is located within the floodplain along the Yadkin River in Elldn and is part of a larger textile mill
complex that was formerly owned by Chatham, Inc. prior to sale of portions of the property to InterfaceFabric
in 2000. Other operations and facilities are located hydraulically upgradient of the facility that are owned and
operated by interfaceFabric.
Historical assessment activities were performed at the site between 199I and 2002 by SPATCO, BPA
Environmental & Engineering, Inc., and Sevee & Maher Engineers, Inc. Remedial Investigation (RI)
activities were completed by Trigon Engineering Consultants, Inc. (Trigon) in 2005 to 2008 to locate and
delineate potential sources, further assess the vertical and horizontal extent of solvents within the regolith and
bedrock aquifers, and perform data evaluation. The previous investigations have included excavating
exploratory test pits, removing and testing various waste materials, sampling soil, groundwater, sediment, and
surface water at the site. Numerous Type 11 and Type III regolith and bedrock monitoring wells were
installed during the previous assessment activities, 40 of which have been sampled regularly through 2006.
(2) Orrin of Contamination
The results of the RI completed by Trigon indicate that industrial wastes (i.e. trash, blankets, plastic, rusted
drums, fly ash, etc.) are buried within the floodplain along the Yadkin River at depths ranging from 5 to 20
feet bgs. The primary contaminants of concern (COCs) identified in groundwater beneath the Site are TCA
and it's daughter products, 1,1-DCA and 1,1-DCE. Additional volatile organic compounds (VOCs)
including 1,2-Dichloroethane, benzene, carbon tetrachloride, trichloroethene (TCE) and vinyl chloride have
also been detected at concentrations that exceed the 2L Standards. The RI concludes that the residual waste
material serves as the primary source of hazardous constituents to groundwater at the site and that the
constituents have generally leached from the waste materials through the overburden soils into groundwater.
(3) Previous Remedial Action
To date, remedial actions at the site have been limited to the disposal of waste materials encountered during
exploratory test pit excavations in May 2005, October 2005 and September 2006. These wastes reportedly
included fabric, rusted drums, plastic drum liners, flyash and various other types of buried waste.

UIC Permit Application
CAI WWTP- 304 East Main Street, Elkin, NC
MACTEC Proiect: 6228-08-4691
ATTACHEMENT B
HYDROGEOLOGIC DESCRIPTION
February 27, 2009
Page 8

UIC Permit Application February 27. 2009
CMl WWTP- 304 East Main Street, Elkin, NC Page 9
MACTEC Project: 6228-08-4691
HYDROGEOLOGIC DESCRIPTION
1 Re oval Geologic Setting
The site is located near the boundary between the Piedmont and Blue Ridge Physiographic Provinces of
North Carolina and is underlain by meta -igneous and meta -sedimentary rocks of the late Precambrian or early
Paleozoic Era. Furthermore, the site lies within the Brevard fault zone, where the Sauratown Mountain
Antielinorium and the Smith River Allochthon converge, creating complex structural geology. The results of
subsurface explorations during the RI indicate that the Site is underlain by fractured biotite-chlorite gneiss.
Bedrock beneath the upper portion of the Site has weathered to a saprolitic soil mantle while bedrock beneath
the lower portion of the Site is overlain by recent alluvial deposits along the Yadkin River.
(2) Changes in Litholo�
Two hydraulically connected zones of contaminated groundwater are present beneath the Site: the water table
and bedrock aquifers. The water table aquifer extends to a depth of approximately 25 feet bgs and is
composed of weathered bedrock residuum on the upland portions of the Site and alluvial deposits near the
Yadkin River. Groundwater flow in the water table aquifer follows surficial topography and flows south-
southeast to the Yadkin River. Based on the December 2007 1 January 2008 sampling data, the primary
COCs present in the surficial aquifer are TCA (maximum concentration of 116,000 ugll), I,I-DCA (26,000
ugll) and 1,1-DCE (9,320 ugll), The dissolved phase plume in the water table aquifer is estimated to be
approximately 700 feet long, 200 feet wide and 10 feet thick.
The bedrock aquifer underlies the water table aquifer and is composed of weathered bedrocklsaprolite from
approximately 30 to 85 feet bgs and fractured gneiss from approximately 85 to greater than 200 feet bgs.
Data from the RI indicate that bedrock below approximately 70 feet bgs is relatively homogenous and has a
lower occurrence of water bearing fractures relative to the upper bedrock zone (i.e. less than the 70 to 85-foot
bgs zone). Groundwater flow in bedrock follows fractures generally oriented northeast -southwest with an
approximate dip angle of 60" north/northeast to east/northeast. Consistent with the water table aquifer, the
primary CRCs in the bedrock aquifer are TCA (309,000 ugll), k,I-DCA (48,500 ug/l) and I,1-DCE(16,300
ugll) based on the December 2007 1 January 2008 groundwater data. The extent of contamination in the
bedrock aquifer is estimated to be approximately 650 feet long, 100 feet wide and 150 feet thick. However,
the analytical data indicate that the majority of contaminant mass is located within 85 feet of the ground
surface, where bedrock is generally more highly fractured.

U1C Permii Application February 27, 2009
CMI WWTP- 304 East Main Street. EIA3n, NC Page 10
MACTEC Project: 62 28-08-4691
3 Aquifer Properties
A single permeability test was performed in shallow bedrock (EBMW-1, screened from 23.5 feet to 33.5 feet)
by others in 1992. The test reportedly confirmed that bedrock permeability is controlled by fractures, with
variations in individual fracture permeability ranging from 1 x 10-5 to 2 x 10-7 cmisec. Variations in bedrock
permeability of several orders of magnitude are indicated, depending on degree of weathering and the
frequency of fractures intersected. Pilot/performance testing of the paired overburden and bedrock recovery
wells EBMW-5 and EBMW-6 was conducted by others in 1998. The results of the test indicated a limited
10-foot capture radius at a pumping rate of 2.8 gallons per minute (gpm) at shallow bedrock monitoring well
EBMW-5, Based on these and other data obtained during preparation of the RAP, MACTEC used the
following aquifer properties to scope the injection:
• Rock Type: Granite and schist
• Total Porosity: 0.05
• Effective Porosity: 0.02
• Hydraulic Conductivity: 0.03 Wday
• Hydraulic Gradient: 0.06
■ Seepage Velocity: 32.9 ftlyr
■ Pore Volume: 684,050 gals
(4) Mean Seasonal High Water Table
Historical depth to groundwater measurements recorded between 2001 and 2006 in the existing shallow
bedrock monitoring wells (EBMW-1, EBMW-5, EBMW-8, EBMW-9, EBMW-10 and EBMW-18) proposed
to serve as injection wells ranged from 9.74 to 16.79 feet below the top of well casing, or approximately 7 to
15 feet bgs.

UIC Permit Application
CMI WWTP- 304 East Main Strew, Elldn, NC
MA CTEC Project: 6228-08-4691
ATTACHMENT C
INJECTION FLU D COMPOSITION
February 27, 2009
Page I I

VIC Permit Application February 27, 2009
CMI WK7P- 304 East Main Street, Elkin. NC Page 11
MACTEC Project; 6228-08-4691
INJECTION FLUID COMPOSITION
in accordance with the Remedial Action Plan (RAP) prepared by MACTEC and submitted to the NCDENR
on January 14, 2009, the first phase of injection will be conducted in the shallow bedrock zone using an
electron donor compound {3DMe with HRC Primer) for the treatment of CVOCs in groundwater at the Site.
Mixing of the injectants will be conducted on -site using municipal water. Hydrogen Release Compound
Primer (HRC Primer) is a water -like compound that releases lactic acid for fermentation by subsurface
microbes, in turn producing hydrogen to "jump start" the reductive dechlorination process. It is a non-
hazardous, food grade compound composed of glycerol polylactate and lactic acid, and is typically applied
via direct -injection into the source area. It is expected to remain active for up to three months. 3-D
Microemulsion is a time -release electron donor compound which incorporates esterified lactic acid with
esterified fatty acids to stimulate reductive dechlodnation for extended periods, 3DMe is composed of a
hydrogen release compound -partitioning electron donor (HRC-PED), fatty acids, glycerol tripolylactate and
glycerol that, when combined, behave as surfactants, with a hydrophilic end and lipophylic end. As a result,
the molecules tend to align themselves with the hydrophilic ends in water, while the lipophylic ends bind to
organic compounds. 3DMe has a low positive HydrophileJLipophile Balance index allowing it to sorb
organic contaminants, but have significant solubility in water to move through the saturated soil matrix and
fractured bedrock zone beneath the Site. Material Safety Data Sheets (MSDS) have been included for the
HRC Primer and 3DMe injectants.

UIC Permit Application February 27, 2009
CAI W►3TP- 304 East Main Street, Ellan, NC Page 13
MACTEC Project: 6228-08-4691
ATTACEN ENT D
INJECTION RATIONALE

UIC Permit Application February 27, 2009
CM-1 WWTP- 304 East Main Street, Ebbn. NC Page 14
MAC7ECProject.• 6228-08-4691
INJECTION RATIONALE
[ 1 ] Injection Project Goals
The primary goal of the proposed remediation is to reduce the concentrations of CVOCs in groundwater to
mitigate potential off -site migration of impacted groundwater above the groundwater quality standards
defined in 15A NCAC 2L.0202 (2L Standards) while promoting longer term monitored natural attenuation.
Q Desgiption of ContaminantOniectant Interactions
Reductive dechlorination is the mechanism by which chlorinated compounds are biodegraded into less
harmful constituents such as ethene and ethane. The two proposed products, HRC Primer and 3DMe, are
anticipated to promote the reductive dechlorinization of TCA and other chlorinated compounds detected in
the subsurface. It is anticipated that intermediate compounds will include the daughter products of TCA and
TCE, such as 1,1-dichloroethene, 1,2-dichloroethene, 1, 1 -dichloroethane and vinyl chloride.
HRC Primer is a thin, water -like compound that will be introduced to the shallow bedrock aquifer via
injection into existing and proposed monitoring wells. It releases lactic acid into the aquifer over a period of
several weeks. HRC Primer snakes lactic acid more immediately available for fermentation by subsurface
microbes. The lactic acid is in turn used by other microbes to produce hydrogen, the key ingredient in the
anaerobic contaminant degrading process (reductive dechlorination).
3DMe is a patented molecule (patent pending) specifically designed to time release a combination of highly
efficient electron donors. Additionally, 3DMe was designed with a relatively high hydrophilic/lipophilic
balance (HLB), allowing dilute suspensions to be well distributed across contaminant plumes. Upon
application to the subsurface, 3DMe begins to produce hydrogen and to distribute hydrogen generating
compounds to the subsurface through a series of hydration and fermentation reactions. This process provides
for an immediate as well as time -release supply of hydrogen to fuel the demands of the anaerobic reductive
dechlorination process. Typical longevity for 3DMe is up to 2 years or more on a single injection and up to 4
years or more under optimal conditions.
(3) Summary of Modeling or Pilot Test
Modeling and/or pilot testing have not been conducted at the site. However, 3DMe has been successfully
used to treat CVOCs in groundwater at sites throughout the United States and at similar concentrations as
those observed at the CMI WWTP site. The RAP evaluated the injection approach in accordance with the
REC Program guidelines and provides for conducting the injection activities in phases pending availability of
funds, so that adjustments can be made based on observed results,

UIC Permit Application
CMJ WWTP- 304 East Main Street, Elkin, NC
MACTEC Project: 6228-08-4691
ATTACffiIMNT E
INJECTION PROCEUDRE AND EQUIPMENT
February 27, 2009
Page 15

UIC Permit Application Februar}+ 27, 2009
CM! WWTP- 304 East Main Street, Elkin, NC Page 16
MACTEC Project: 6228-08-4691
INJECTION PROCEDURE AND EQUIPMENT
(1) Construction Plans and Materials
In -Situ chemical injection will be applied to the impacted shallow bedrock groundwater zone (directly
into the targeted chemical treatment zone at approximately 25 to 85 feet) via six existing (EBMW-1,
EBMW-5, EBMW-8, EBMW-9, EBMW-10 and EBMW-18) and 10 proposed monitoring wells. Based
on the subsurface geology and variation of concentrations with depth, the bedrock injection wells are
planned to be installed to approximately 85 feet below grade. The wells will be installed using auger
drilling methods to the top of bedrock and air rotary drilling for the remainder of the boring. The bedrock
wells will be constructed with 2-inch diameter PVC casing to top of rock with the remainder of the well
completed as an open borehole to allow flexibility in characterizing and targeting bedrock fractures. The
entire borehole (or selected treatment interval if impacted fractures have been identified) will be filled
with the HRC Priomer/3DMe solution. Multiple injections points will be used throughout the impacted
areas. The treatment application is focused on source area locations where the highest CVOC
concentrations have been observed.
(2) operation Procedures
The proposed injection(s) will be conducted in accordance with the 3DMe manufacturers guidelines, as
specified in the attached. Installation Instructions.
(3) Surface and Subsurface System Diagram
In -Situ chemical injection is proposed for the site via specifically design low pressure (i.e., <100 psi)
injection wells using mixing tanks and low pressure pumps. This remedial action does not involve the
construction of permanent structures, other than the monitoring wells.
(4) Injection Schedule
The following implementation schedule will initiate with public notice of the RAP, which began on February
5, 2009.
TASK
Schedule to Complete Task
Public Notice
30 days
Site Preparation and Test Pits
30 da s
Preconstruction Report
15 days
Bedrock Well Installation
20 days
Bedrock Injection
30 days
Construction Completion R ort
30 days
Performance Monitoring (4- ost 'm ection events)
One vear

UIC Permit Application
CMI WWTP- 304 East Main Street, Elkin, NC
MR CTEC Pmj ect: 6228-08-4691
ATTACHMENT F
MGNUORING PLAN
February 27, 2009
Page 17

L11C Permit Application February 27. 2009
CM! WW7'P- 304 East Main Street, Elkin, NC Page 18
MACTEC Project; 6228-08-4691
MONITORING PLAN
One pre -injection groundwater sampling event will be performed in March 2009 to assess current
groundwater quality. The sampling parameters will include VOCs, general chemistry, and field parameters
such as dissolved oxygen and oxidation reduction potential.
Quarterly post -injection groundwater sampling will be conducted for the first year following the completion
of 3DMe'BRC application at the same well locations as the Pre -Treatment groundwater monitoring activities.
The initial sampling event will be conducted approximately one month after injection, with subsequent
sampling events occurring in 3 month intervals thereafter. In addition, field parameter measurements will be
recorded approximately every two months following the treatment application, contingent upon availability
of funds. The objective of the groundwater monitoring is to evaluate effectiveness of groundwater treatment
by assessing trends of CVOC concentrations in shallow bedrock and to assess distribution of 3DMo(HRC
Primer in the shallow bedrock zone. A summary of the post -treatment groundwater monitoring plan is
presented in the attached table.

Summary of Proposed Groundwater Monitoring Program
Former CMl WWTP
Elkin. North Carolina
Sampling Event
Pre -Injection Sampling
Post -Injection
Sampling - Round i
Post -Injection
Sampling - Round 2
Post -Injection Sampling
- Round 3
Post -Injection Sampling
Round 4
Estimated Sampling Date
March 2049
1 month after Injection
4 months after injection
7 months after injection
10 months after
inaction
Well D
C.7[.]
p
>
a
[ y
c v E
m ELL 2
0W m`
s a
p
�
a
C Ej
c TvE
m Eu Lc
Om m
r a
U
O
>
a
C Vy
G1 Qz
c N mE
m fir e
0(5 m`
.[ a
U
>
p
C Ii
m
N u E
d EiL 2
0m m`
a
U
0
>
v
C y
m
=m ? E
m Ew 2
�m m
L a
Overburden welts 0-25'
EBMW-2
EBMW-3
EBMW-4
EBMW-6
EBMW-7 d
X
X
X
X
X
X
X
X
X
X
EBMW-11
EBMW-12
EBMW-13
EBMW-14 J
X
X
X
X
X
X
X
X
X
X
EBMW-15
EBMW-16
EBMW-24
EBMW-28
FAMW-1
FAMW-2
FPMW-2
FPMW-3
FPMW-4
FPMW-5
MW-01 01
M W-Ol -02
MWE-1
MWE-2
MWE-3
MWE-101
Shallow Rock Wells 30-55'
EBMW-1 ✓ X
X
X
X
X
X
X
X
X
X
EBMW-5 X
X
X
X
X
X
X
X
X
X
EBMW-8 J X
X
X
X
X
X
X
X
X
X
EBMW-8 V X
X
X
X
X
X
X
X
X
X
EBMW-10 X
X
X
X
X
X
X
X
X
X
EBMW-23 •r X
X
X
X
X
X
X
X
X
X
EBMW-27
Dee Rock Wells 60-200'
EBMW-17
EBMW-18
X
X
X
X
X
X
X
X
X
X
E8MW-19
X
X
X
X
X
X
X
X
X
X
EBMW-20
EBMW-21
X
X
X
X
X
X
X
X
X
X
EBMW-22
X
X
X
X
X
X
X
X
X
X
EBMW-25
EBMW-26
Notes:
1. Samples wail be analyzed for VOCs using USEPA Method 8260; samples will be analyzed for
General Chemistry parameters including ferrous iron, chloride, nitrate, nitrite, sulfate, sulfide. TOC.
ethaneiethane, and alkalinity using applicable methods.
2. Field parameters include dissolved oxygen and oxidation reduction potential.
Prepared bv.
Uherked by:

UIC Permit Application
CMI WWTP- 304 East Main Street, EUdn, NC
MACTEC Project: 6228-08-4691
ATTACffiIMNT G
WELL DATA
February 27, 2009
Page 19

U1C Permit Application
CM1 WWTP- 304 East Main Street, Elkin, NC
MACTEC Project: 6228-08-4691
WELL DATA
February 2], 2009
Page 20
Based an information contained in the RI Report prepared by Trigon, there are no known users of
groundwater in the immediate vicinity of the injection area. The nearest known well was reported to be a
residential water well located more than %z-mile to the east and cross -gradient of the site on Highway 268.
Based on well construction data from the RI, eight wells are known to be screened within the proposed
injection zone. Six of these eight wells will be utilized as injection wells for the proposed remedial action. A
summary well construction details for the eight wells located within %-mile of the injection site is presented
on the following table.

Summary of Well Construction and Usage DetaUs
Former CMI WWTP
Elkin, North Carolina
Well ID
Well Construction
Well Usage
Land Surface
Elevation (MSL)
Bottom of
Screen
>rlevation (MSL)
Total Well Depth
(ft bgs)
CM] WWTP Site
EBMW-1
96.4
63.14
33.26
M
EBMW-5
95.26
56.39
38.87
M
EBMW-8
96.98
65.19
31.79
M
EBMW-9
95.84
43.09
52.75
M
EBMW-10
97.32
41.49
55.83
M
EBMW-23
99.64
55.54
44.10
M
EBMW-27
99.27
57.27
42.00
M
EBMW-18
95.58
17.58
78.00
M
Note'
M - Monitoing
Prepared by:
Checked by:

a
1
Rp14�4Nv TRAMS
q _
I
f
I
r
1
r
r f
r
oE7l R4WD* AREA (ISO PWM)
I
EBM -3
COUAL12APON
BASIN
TRUCK
' TERMINAL
1 C3
L r..
PARCEL 1
CMI WWTP
PROPERTY
MWE--3
13
CHAIHA44 INC. PARCEL 2
PROPERTY CMI FLYASH DISPOSAL
AREA PROPERTY
�^ MWE-2 0
1 r
CHATHAM INC. BASIN -
PROPERTY + AREA 8 (154400 SF) EBMw-2
l RMW-4 C (MOW sr)-
FPMW-2 f l
INACTIVE
1 � q SEWER LINE
j EBMW-15$
F f 2 •■ EBMw-26
EBMw-23 • • ' • ■ BANHf]LE � 4- Q1 �- FPMW-4
■1■ €Bra -'is ❑ E�M�- §�- - '^-~ EBMW-17 APPROXIMATE SCALE 1N FEET
EDMW-24 1 • a a ■ • - M•A'E•I EBMW-9fD
100 50 0 100
Bu15�-1.'1~ • FPMW-5
_
EBMw-27 EBMW-18� - • . • _ll ,t EHYN'- 23
- ~ 0 ; E 3tW
F41W-1 EBMw-28 - - _MH-1D • \ EBMw-6
- ENTAL
e, qtgt: B NOTES• SERVICES DRAWINGBASE MAP AFTERSNo- 9O 1790, ENVI�GURE 2
_-- • et.w-21 EBMI , py-IN� R MONtTORINC WELL LOCATIONS AFTER BUNN
• ■EBMW-25 _ �N ELpN ENGINEERING SURVEY MAP, PROJECT NO.
r - - • 8020603. 6/8/04 (REVISED 10/24/05 and 10/02/06).
• LOCATIONS ARE APPROXIMATE.
PLOAI�N BMW-i3 * • ■ EBMw-2 �
K
E�W• MACTEC
_Ty ,� � � EXPLANATION �
AREA A (24,500 SF) ENGFNIERfmc & CONSMFING INC.
=� RAILROAD TRACKS OVERBURDEN WELLS CHARLOTTE, NORTH CAROLINA
Mw-01-1
STREAM BEDROCY WELLS
PROPERTY LINE (CURRENT) UPPER BEDROCK WELLS 25-45' (EXISTING) INJECTION LOCATION PLAN
— PROPERTY LINE (OLD) INTERMEDIATE BEDROCK WELLS 55-85' (EXISTING) CMI WWTP
- SEWER LIME UPPER BEDROCK WELLS (NEW) ELKIN, SORRY COUNTY, NORTH CAROLINA
OVERBURDEN INJECTION POINT 15' GRID ON 30' ROWS
i1W-01-2 • INJECT AT REFUSAL, 18' AND 16' PREPARED DATE CHECKED DATE
� BY 14DF 1 11/17/10 PSJ 11/29/10
REF: Lqr.ATf6;Z OF EXISTING MONITORING WELLS DRAWING PREPARCI7 BY TRIGON ENGINEERING CONSULTANTS, INC. FIGURE 5, DATED 2/2/07 JOB NO. 6228-08--4591 FIGURE 1

Documents Associated with
the July 10,, 2009
CMI Industries
Injection Well Permit

UIC Permit Application February 27 2009
CM1 WWTP- 304 East Main Street. Elkin, NC Page 22
MACTEC Project: 6728-08-4691
MAPS
The following maps/figures included in this UIC Permit Application were taken from either the RI Report
prepared by Trigon in 2007 or the RAP prepared by MACTEC in 2009.
(1) USGS Topographic Map
(2) Site Plan
(3) Potentiometric Surface Map
(a) March 2007 Groundwater Contour Map
(b) June 2007 Groundwater Contour Map
(4) Contaminant Plume Map
(a) Isoconcentration Map of Total VOCs in Bedrock Wells — October 2006
(5) Geologic Cross -Sections
(a) Locations of Cross Sections
(b) Cross Section A -A' with Isoconcentrations of Total VOCs
(c) Cross Section B-B' with Isoconcentrations of Total VOCs
(d) Cross Section C-C' with Isoconcentrations of Total VOCs
(e) Cross Section D-D' with Isoconcentrations of Total VOCs

r r - ■'r c � � � : �� �". " -ter. ,..t "''F -
F i_
.. •t .a � � tip:, . _ r..�•I, �•
���� � • � � - •,f • � •� _` SITE t.00A'flQH � f��`-- ': -
`}• .,^� •icy—' �� - ' .� � - - � : ��
Agr-
AS
.,�. •ram •J J�� ... 5 ._i•L �•
TV.�:
"' _ • r .. is '�' • �_=='. - .:�'S:•V� �---- �
• t6r� � f7a '" i' Imo_ �+ •_�I • �-. 1� . ._� - _�' -
Source; USDA NRCS USGS DRG Mosaic for Surry County, NC. N
0 2,000 4,000 6,000 A
Feet
rn SITE LDCATIQNICMI WVV1NDlNG PROPERTY
;.Vol
O�M
1 CMi WWTP
EL.KIN, SURRY COUNTY, NORTH CAROLINA
DATE CHECKED DATE JOB NUMBER FIGURE
y 62126- 08-464 1

E
CHAT14AM INC.
PROPERTY
V�
m
FLOOD
PLAIN
f
ZRA'�S
R�� f
EBMW-3
TRUCK
' TERMINAL
PARCEL I
CMI „'rb
PROI
fl
CHATHAM INC.
PROPERTY
PARCEL 2
CM PLYASH DISPOSAL
AREA PROPERTY
r---7
MWE-2 `.
l}
l
—
FLYASH
^,
FPMW-2
f
�
El
EBMW-],�5
I
�-
J
f
I' FAMW-2
E`BMW-26 _
,eE3MW-23
MWE-101 —
EBMW-I
FPMW-4
EBlIW14 EBMW-16
t_--~
EBMW-17
__--9WE-1 EBMW^9
EXPLANATION
�-EBMW-14
$EBMW-22
EBMW-1e *E�.
J -
FPHW-5 _
EBMW-5
/-EBMW-27
if
- _
W _ r►r
�.
EgMy_
� RAILROAD TRACKS
OVERBURDEN WELLS
•FAMW-I
•,�,
��� ER"W-e
_ EBMW-I0 ft
- STREAM
BEDROCK WELLS
_ EB� -12 �W-21� -OEBMW-7
PROPERTY LINE [CURREIiT?
_
£BMV--25
— — PROPERTY LINE COLD)
FW'
- - - - - - - SEWER LINE
e EBKV-13 EBMW-20 �
EBMWfl9
MACTEC
4�
MV-01-1 I
ENGINEERING & CONSULW, INC.
iv
f
CHARLOTTE, NORTH CAROLINA
r
WINE& Na MAP AFTER SPATCO E]sVfltuMAL
SERVICES WAWM Nm 9-1790. FIGURE 2
MmITORING WELL LOCATIONS AFTER BURN
--l' ENGINEERING SURVEY MAP, PROJECT NO.
NW-01-2 8MU 4/8M 4tEV= 2/24A5 wd 10MVW
LOCATIONS ARE APPROXIMATE:.
l
REF,, LOCATIONS OF EXISTING MONITORING WELLS BRAWING PREPARED BY TRIGON ENGINEERING CONSOLTANTS, INC. FIGURE 5, DATED 2/2/07,
SITE PLAN
cm I WWTP
ELKIN, SURRY COUNTY, NORTH CAROLINA
I PREPARED �PF I DATE g1 /14/a9 I CHECK I DATE 1 ) i'4I (7CI I
NO. 5228-08-4691
FIGURE
K,

CHATHAM INC
PROPERTY
i
r
i
Zap �a✓1ss f
r
i
� 1
f� l
i -
i
i
KWF
FLYASH 1
BASIN `
E KW-
/EBMW27
(85.85) ❑
f ..
EHMW_3
EQUALIZATION
BASIN
PARCEL 2
rl ' CMl FLYASH DISPOSAL
CHATHAM INC. .. l AREA PROPERTY
PROPERTY -�•
l
� 1
4TK=RMFNA.L
L- '
r „
hrwE-s An
PARCEL 1
CHI WWPTP
PROPERTY
EBKW--2
' (89.04)
�
1 l
❑ r
r
EBMW-I5
FAMW-2
1
tsr.sr] r
/ (86.63)
Q
❑ EBMW26
/ ❑EBMW 23
;
EB(MW S)
EBMW-1
(85.86]
MW1i101
(89.9I) EBMW-17 H5.0 —
❑
,
(83.96)
EBMW-9
EBMW-I4
\EBW-II
MT
MWE 1 (52,94) FPMW-5
[88.14]
(86.63)
[8736)
f
� {ei °3 EXPLANATION
EBMW-18
Ell -22
A (56.23)
EBRW-5
(82 73)
(85.07) � RAILROAD TRACKS ❑
EBMW-29
FAMW-1 (88.60)
(89.92) EBMW-12
\, I (87.17) ❑
EBMW-25
1 I 3 (87.10)
F AIOk�! (8sm) EIIMW-20
EBATW-19 _
i
Mw-01-2
(e3.a7y �
EBMW-14
EBMW-6 �
STREAM
W
BMW-10 EBM8
[85.32]
(84.66)
(22 99} _
y
a
,
,'
— • - — .. _ PROPERTY LINE (CURRENT)
(21
8fi 0 EBK -7
PROPERTY LINE (ILA)
GROUNDWATER CONTOUR LINE
[65.86) GROUNDWATER ELEVATION IN FEET
0
GROUNDWATER FLOW DIRECTION
NOTES: OVERBURDEN WELLS SHOWN IN BLACK; BEDROCK WELLS
SHOWN IN RED.
MONITORING WELL LOCATIONS AFTER BUNN ENGUMERING
SURVEY MAP, PROJECT NO, B020603 6W04 [REVISED 10f24105 AND
10102N6), LOCATIONS ARE APPROXIMATE.
BASE MAP AFTER SPATCO ENVIROMENTAL SERVICES
DRAWING No. 9-1790, FICURF 2.
GROUNDWATER DATA FROM MARCH 3007 SAMPLI NGEVENT+
GROUNDWATER CONTOURS BASED ON OVERBURDEN WELLS.
BEDROCK WELLS [EBMW-1,-5, -R, -9, -10, -17, -18, -19, -20, -21, -22,-23
•25, •26, -210 WATER ELEVATIONS SHOW FOR COMEPAR.ISON ONLY.
1
D1z
G>3> D l
l
r
MONITORING WELL (TRIGON 2006)
MONITORING WELL (SEVEE & MAHER 2001)
MONITORING WELL (SPATCO 1992)
MONITORING WELL (BPA 3005)
MONITORING WELL (ENSR 2001)
MONITORING WELL (SPA/ SPATCO 1992, BPA 1995-19-96)
MARCH zoo?
GROUNDWATER CONTOUR MAP
CMI INDUSTRIES, INC.
HWY 268 (EAST MAIN STREET)
NORTH ORTH CAROLINA
APPROVED BY PR[
1 B0R320SYTAL; 1" - 100' 1

ll
f
� l
MW1:�9 i
l �
� 11
•l i
r
EBAQiW-3
sQU BA �TIO14
1
PARCEL
CMIFLYASH DISPOSAL
rl CHATHAM INC. . - — AREA PROPERTY
PROPERTY .�•
1
l �
4TERmCNAL
l
PARC6LI
Cm WWTP
PROPERTY
MR+E-3
0
0
El
FPMW-3
FLYASH
1 i
o
CHATHAM INC.
PROPERTY
BASIN
1 a
EBMW-2
(86.47)
Q
1 ` EBMW-4
• [85.13]
$S.Q
FPMW-2
f
i
l
0
EBMW-15
FAMW-2
(65-07)
l
❑ EBMW-26
/
E 85., 3 `
❑ i85.6R]
E$MW-1
(63.19)
(R8A0)
yy-� MWE lUl EBhRW-i7
FPMW-4
❑ EB(9W 6)
( 3.61
S
f%
u EBMW-9 (6Q.6oj
8 lrl
%
EBMW-24 /
(85.42)
(84.77) (BN79) FPa°MW-S
~ I-
$ [27}
EXPLANATION
` ~ 1
EBMW-I2
(82,89) �
/EBMW-27£8MW-11
(B5,02) ❑ ❑
EBMW-18 (84a4 ) t.
EBMW-5
(80.24)
RAILROAD TRACKS
❑
MONITORING WELL (TRIGON 2006)
EBMW-28
(80.11)
E$mV_10 EBMW-8
ti EBMW-14
, (90.77)
EBMW-6
(8039)
/ ~
STREAM
MONITORING WELL (SI VEE & MAKER 2001)
;0 FAMW-1 (85.5)
(87..44) -*Q (8230)
-,
WELL im)
(06,07) EBmi -l2 Egh(W.21
►�
PROPERTY L�iE (CiTRREiYI)
MONITORING (5PATCO
EBMW-7
❑ (84.79) (8MW
��
PROPERTY LIKE (OLD)
MONITORING WELL (BPA 2005)
RS•0
E( 6.17) 5
es.I
T
%
GROUNDWATER CONTOUR LINE
�
MONITORING WELL (ENSR 20011
1
FLOOD
PLAIN
E 33 64) 3 EBMW-20�
(80.55)
(83.19)
GROUNDWATER ELEVATION IN FEET
a
MONITORING WELL (BPAI SPATCO 1992, SPA 1995.1906)
_
—�
GROUNDWATER FLOW DIRECTION
EBMW-19
(83.67)
ti
MWAl-1 NOTES. OVERBURDEN WELLS SHOWN IN SLACK; BEDROCK WELLS
SHOWN IN RED.
MONITORING WELL LOCATIONS AFTER BUNN ENGINEERING
-� SURVEY MAP, PROJECT NO. 8020603 613�04 (REVISED I012 IQS AND
_ 1MVM0 LOCATIONS ARE APPR03OMATE-
�� BASE MAP AFTER SPATCO EN VIROMENTAL SERVICES
DRAWING No. 9.1790, FIGURE L
MW-01-2 GROUNDWATER DATA FROM JUNE 2007 SAMSLING EVENT.
GROUNDWATER CONTOURS BASED ON OVERBURDEN WELLS,
BEDROCK WELLS (EBMW-1, -5. -8, -9, -10, -17, -18, •19, -20,-21,-22, -23
f -25, -26, -27) WATER ELEVATIONS SHOW FOR COMPARISON ONLY.
JUNE 2007
["IROUNDWATER CONTOUR MAP
CMI INDUSTRIES, INC.
HWY 268 (EAST MAIN STREET)
ELKIN, NORTH CAROLINA
APPROVED BY PROSELT No: 04I46.097
ENGTNEERING CONSULTANTS INC. r;kAwN 91: DRY HORIZONTAL: I-100'
313 GALLIMORE TIATRY kD.
GREENSBORO. N.C.(3361.668-0093 DATE: $fIa107 cl7siE 7, se7ET 13 J

�xvjo�
I
PARCEL
CFLATDIAM INC. I 1 AREA ROPERTYAL
PROPERTY 1
TRUCK
' TERNMAL
7
1 l ❑
MWE 213F
'..
f � t EBMii'-3
r PARCEL r J
Chu wwrr
r PROPERTY
Ir M1VFr3 0
' ❑ G BY'D
DLL
MW!•r9 1 O
WATER
TREATMENT
' FACLLITY
WDALIZATION
BASIN cl 1 MW•3
s rl Rf INC. BASIN �� 4 EIBMW-2PROQ J
1
12
EBMW-15
r
FAMW-2 EBM►V•26
E{ AR'❑23 EB?#[W I -•- _ FPMW4 r
0.30 EB1Y1W24 '� - - ERXW-17
❑ ', MWE ] EBh1K'•9 - _ (25.4) _
EBMW-16 (210,680.D) - ��
s'-1a _ -- --- ----- -- ------ — ❑�. EXPLANATION
_ EB1HP4'-S EH►INV-22
EBNI►►'-27 �EBMWfl _� � ---- - " _ (212,800+0) [13,670.0J � �la { j{ � RAILROAD TRACKS ❑ MONITORING WELL (TRIGQN 2006)
33 & MAF
EBMW-ID EFIMW-14
1 FAMW-1 EBMW-20 EB3FW-25 J (219,450.0j � j STREAM MOiVTIQRING WELL {SE►'EE IER 200f }
EaMR�-a � EaMV4'-s
;� ❑ (160,400.0) ' 1 — — • - PROPERTY LINE (CURRENT) MONTTORMG WELL (SPATCO 1992)
FBMW-17 # ; EBMW-7 Yu- `W _ PROPERTY LIME (OLD) MONITORING WELL (BPA 2a05)
EBiF'-11
-q -. ^ 15000NCENTRATIQN CONTOUR MQNT1.ORING WELL (EN5R 2001)
�1 FLOOD EBMW13 E(49.85)� (BQL) BELOW QUANT'ITATiON LIMITS ❑ MONITORING WELL (BPA/ SPATCO 1991, BPA 1995-1996)
PLAIN _
d9.85� i 2L ISA NCAC 2L SIANDAkD
EHAl1l'.19 'i ' ' (29.1) OCTOBER 2006 TOTAL, VOCs IN PARTS PER BILLION (ppb)
` (64.9) �_✓� fPB
�oa NOTES: ISOCONCENTRATION CONTOURS BASED ON SHALLOW AND
A6J dJ J INTERMEDIATE DEPTH BEDROCK WELLS, DATA FROM DEEP
BEDROCK WELLS EBMW20, .2I, -22, -25, AND -36 SHOWN FOR
_ f COMPARISON ONLY.
OVERBURDEN WELLS SHOWN IN BLACK; BEDROCK WELLS
SHOWN IN RED.
I%r_ MONITORING WELL LOCATIONS AFTER BUNK ENGINEERING
SURVEY MAP, PROJECT NO. 13020603 6/8101 (REVISED 10/14l05].
LOCATIONS ARE APPROXIMATE.
BASE MAP AFTER SPATCO ENVIRONMNTAL SERVICES
D 91790 RGLYRE2
ISOCONCENTRATION MAP OF TOTAL
VOCs IN BEDROCK WELLS- ❑CTOBER 2006
CMI INDUSTRIES, INC.
HWY 268 EAST MAIN STREET)
ELKIN, NORTH CAROLINA
APPROVED BY P o No: 0{1-0641)7
RAWaVGNc. ENGINEERING CONSULTANTS INC. DRAwN ovRx
: D
— — - -- 313 GAL.LIMORE DAIRY TU. xr . � • -o-
GREENSSORO, N.C.(336 -fij 68-UU93 DA'm law v1cuRE to,smeT9 J

a lavo-0l
rR
E
i
1
!�
❑
1
�
l
`
EQUALIZATION
n
0
BASIN
t
!
EBM
FLYASH
i
BASIN
EB-4
1
�
1
EBHW-15
/
FAMW-2
e-
_
EBMW-26
EBMW-23
MWE-IDl
r ~i
I
!
__►�
-
EBMW-24
j
EBMW-16
EBMW-1 *MWE-1 ,`���
EBMW-17
,
ESNW-9
I
FPMW-5
/
4
EB04W-11
_ -
EBMW-5 J
EBMW'27 >�
1=HMW-14
EBMW-28
__��r�-`
�r
*
, \ ` \
r r
EBMW-6
�
r
FAMW-1
�`
1
1
*
EHMW-S
' '
_
_
EBMW-10
EBMW-12
$
EBMW-7
/� 1
� 9-T APPROXIMATE SCALE IN FEET
EBMW-21
i
tiPN
50 25 0 50
EB14W-25 ,
^
t
EBMW-20
NOTES: BAW MAP AFTER SPATCO ENVIROMENTAL
EBMW-13
��
SERVICES DRAWING No. 9-1790. FIGURE 2
MONITORING WELL LOCATIONS AFTER FIUNN
ENGINEERING SURVEY ASAP, PROJECT NO.
j
0020603. 6/5/04 (REVISED 10/24/05 and 10/02/05).
I EBMW-19
LOCATIONS ARE APPROXIMATE
EXPLANATION
� MACTEC
i
�
STREAM
ENGINEERING & G4NStll17NG, INC
MW-D1-1
—
OVERBURDEN WELLS
CHARLOTTE. NORTH CARDUNA
I
— — -
PROPERTY UWE (CURRENT)
BEDROCK WELLS
_
,
PROPOSED REMEDIAL ACTION PLAN
^ —
PROPERTY UNE (OLD)
PROPOSED BEDROCK INJECTION POINT
- - - -
SEWER UNE
EXISTING WELL
SHALLOW BEDROCK AWIFER <80' BM)e✓MI
�
- - -
BEDROCK INJECTION
WWTP
r
ESTIMATED TREATMENT AREA
ELKIN. SORRY COUNTY, NORTH CAROLINA
(<5W INTO ROCK)
_ l
LOCATIONS OF EXISTING MONITORING WwaL.S DRAWING PREPARED BY TRIGON ENGINEERING CONSULTANTS. INC. FIGURE 5, DATEO 2/2/07.
BREPAREB M j DATE �1,7 4/O9 lECKED � I DID ell/ p rj
JIB NO. 6228-08-4691 FIGURE 4

CHATHAM INC.
iiiii PROPERTY
EBi fW-27❑ ❑
i EBMN
IFAMW-I
Kuhr
FLOOD
PLAIN
i
'
EBMW-13
1
\
i ES�f�►�_19
A
�
1
MW-01-I
_
Aiti►'-01-2
!
!
!
!
� 1
r J
EBa -3 J,
TRUCK
TERMINAL
PARCELS
P OPERTY
P
PARCEL 2
CW FLYASH ➢ISPOSAL
CHAT6AM INC. ' 1 AREA PROPERTY
PROPERTY ll
11
l
1
1
i,
ry • . r . r l ' l MIVE-2
(10
r '
L� 5
1 1
DR DIED
�
l
a
1
EBMW-�
a f
FPNW-2
�
l
J
l
EBMR'-15
❑
rIWE-101
FPMW4
RNnV-26
EBMNV-17
EBMW-
•f
d
�
FPMW-S
EBAiR-22
EXPLANATION
_
EBMW-
RAILROAD TRACKS ❑ MONITORING WELL ITRIGON 2006)
NOTES: OVER)iURDEN WELLS SHOWN IN BLACK; B91DROCK
WELLS SHOWN IN RED.
BASE MAP AFTER SPATCO ENVIROMENTAL
SERVICES DRAWING No. 9.1790. FIGURE 2
MONITORING WELL LOCATIONS AFTER BUNT+
ENGINEERING SURVEY MAP, PROJECT NO.
11020603. 51M4 (REVISED 10/24105 me 101021061.
LOCATIONS ARL APPROXIMATE.
PROPERTY LINE (CURRENT)
PROPERTY LINE (OLD)
MONITORING WELL (SEVEE & MAHER 2001)
MONITORING WELL (SPATCO 1992)
MONITORING WELL (BPA 2005)
MONITORING WELL(ENSR 2001)
MONITORING WELL (BPAISPATCO 1992, BPA 1995-1996)
LOCATIONS OF CROSS SECTIONS
CMI INDUSTRIES, INC.
HWY 268 (EAST MAIN STREET)
ELFIN, NORTH CAROLINA
APPROVED BY PROJECT r4u; 041. 97
HORIZONTAL: 1 " - N'
FIGURE n. SHEET 1

A
150
120
90
W60
I7s
z 30
W
-30
-60
-90
A'
A ,��44 L®h ti 9 ♦� ti 4 h� h"r
A �S } ,+._ 4'......... - 'O ti �............. yM a� Sri. j 'I ....... �O { 1 1� R y U� ��. �^ �.. ._
�Q ro sSIRFaCE ���4 6 �$ �` �� °� G' O �+ ��4° iv'q �4 a' 4`v
4
JL 60,884.7
11EpROC[C
—
* 1Q0,400.0
—
10.060 PPH f �
.. ........ - � �
.....
\ . - ...
� ......
... ............... . .... .......... f 212,800.0.
—
' .. .
_,
-
} Z19,450.0
PPH
+ 2I0�60.n
c _ -
r100�U00
r.
�
f
... .
.....................
r r ~
10,000 PPH
r
964,96
r
PPH
49'
* 3,448.0
_1,000
J 1 -
13,670.0.
— r
—2L
r
�
r
0
EXPLANATION
SCREENED U4TERVAL
1 . ISOCONCENTRATION LINE
WATER TABLE
60 120 ISO 240 300 360 420
HORIZONTAL SCALE IN FEET
064.9 OCTOBER 2006 TOTAL VOC CONCENTRATION
IN PARTS PER BILLION (PPS)
2L 15A NCAC 2L STANDARD OF 1,1,1 TRICHLOROETHANE
AND DEGRADATION PRODUCTS
. MW-01-1 WAS NOT SAMPLED IN OCTOBER 2006, THE DATA FROM THE SEPTEM 3ER 2006 SAMPLING EVENT IS INCLUDED IN THIS FIGURE.
NOTES: WELLS SURVEYED RELATIVE TO TBM OF ASSUMED ELEV.100.00 FT LOCATED ON LID OF WELL VAULT OF MWE-3. BASED ON
2001 ENSR SURVEY DATA, THE MWE-3 TBM CORRESPONDS TO A 1929 NATIONAL GEODETIC VERTICAL DATUM OF EL 886.7E FT.
GROUNDWATER DATA FROM OCTOBER 2006 SAMPLENG EVENT. STATIC WATER LEVEL BASED ON OVERBURDEN WELLS (BLACkC ,
BEDROCK WELLS (RED) SHOWN FOR COMPARISON ONLY.
480 540
17R.10ON
600 660 720
150
120
90
60
f=,
30 0
0 >
W
a
-30
-60
-90
CROSS SECTION A - A'
WITH ISOCONCENTRATIONS OF TOTAL VOCs
CMI INDUSTRMS, INC.
HWY 268 (EAST MAIN STREET)
ELKIN, NORTH CAROLINA
APPROVED 8Y PROSECT No: 042-06-097
niLIWN BY: GGL
SCALE: 1 " - 60'
DA7T�: 7lI107 PIGLME 12, 6EXSC 7

B
120
90
60
-30
-60
EXPLANATION -90
SCREENED WTERVAL
-i' ...... a�..:.-
4;; �¢
FL STATIC WATER � 73,400,0 _ ..... .. . . . .... . _ .. .
LEVEL 2.26 ', r YADKIN A RIVER
t
+1.100.ISO,
TOP OF 8FVIMCK ' WIPL
1' \
. ..... .................. ................... 1.1C1........ .. ...... .. ....... .... ....
JL
.... ............... .......................... ... \. .�.... ...-............
\ - loon PPS
- 2L
.............................. ...... ........ `. ` -f .... ......... I ......... I..........
49.95
............................ I............
■ 64.9 ❑CTOBER 2006 TOTAL VOC CONCENTRATION 0 30 60 90 120 150
IN PARTS PER BILLION (PPB) HORIZONTAL SCALE IN FEET
ISOCONCENTRATION LINE
$� WATER TABLE
2L 15A NCAC 2L STANDARD OF 1,1,1 TRICHLOROETHANE AND DEGRADATION PRODUCTS (PPS)
NOTES: WELLS SURVEYED RELATIVE TO TBM OF ASSUMED ELEV. 100.00 FT LOCATED ON LID OF WELL VAULT OF MWE-3. BASED ON
2001 ENSR SURVEY DATA, THE MWE-3 TBM CORRESPONDS TO A 1929 NATIONAL GEODETIC VERTICAL DATUM OF EL 986.78 FT.
GROUNDWATER DATA FROM OCTOBER 2006 SAMPLING EVENT. STATIC WATER LEVEL BASED ON OVERBURDEN WELLS {BLACK],
BEDROCK WELLS (RED) SHOWN FOR COMPARISON ONLY.
180 210
7AV
TRIGON
240
ENGINEERING CONSULTANTS INC. I DRAwN8y
313 GALLIMORE DAIRY'RD.
GREENSBORO, N.C.(336)-668-0093 nwTe: vlm
B'
120
60
-30
-60
-90
CROSS SECTION B - B'
WITH ISOCONCENTRATIONS OF TOTAL VOCs
CMI INDUSTRIES, INC.
HWY 268 (EAST MAIN STREET)
ELKIN, NORTH CAROLINA
APPROVED RY
�PIRUDJ-Rc-T
7 No: 042-0
GGL CALlo`
GE,SH1UR12U

C
120
90
60
-30
-60
-90
EXPLANATION
SCREENEDINTERVAL
ry40_ .............. . ........, .4 ......
4 ���4,�e�` Q��' q�d
�A vy
4
LCNI) Sus>=ACE
.-.- .
STATIC WATER LEVEL
4.72 ` 1 171.D 86,205
y l 1 ` ■ TOP OF BEpRQCIi KLN RIVER
lit I
l
` 1 tii l t 100.406 + WIDTH01
JL
630............ �. 1` - .'i . r . ..... . . . .. .
219,450
100,001i P['b
. . ......... .............. �..1.� �. ... .. ...... ........
391.000
r 10,000 PPB
i
63.949.0
f 1,000 PPS
.................. ... ...... . .. ... .... .. .......... •. .... ...... .. ......................
� r
r 2L
3.97
.................................................. _. ......... ... ........ . ............ .....
■ G4.9 DCTDBER 2006 TOTAL VOC CONCENTRATION 0 30 60 90 120 150 180
IN PARTS PER BILLION (PPE) HORIZONTAL SCALE IN FEET
ISOCONCENTRATION LINE
7 WATER TABLE
2L 15A NCAC 2L STANDARD OF 1,1,1 TRICHLOROETHANE AND DEGRADATION PRODUCTS
NOTES: WELLS SURVEYED RELATIVE TO TBM OF ASSUMED ELEV. 109.00 FT LOCATED ON LID OF WELL VAULT OF MWE-3. BASED ON
201)1 ENSR SURVEY DATA, THE MWE-3 TBM CORRESPONDS TO A 1929 NATIONAL GEODETIC VERTICAL DATUM OF EL 886.78 FT.
GROUNDWATER DATA FROM OCI'OBER 2006 SAMPLING EVENT. STATIC WATER LEVEL BASED ON OVERBURDEN WELLS {BLACK],
BEDROCK WELLS (RED) SHOWN FOR COMPARISON ONLY.
210
17AIC
TRIGON
�l
MGINEERIN
313 GALL]
GREENSEO]
0
60
-30
-60
-90
CROSS SECTION C - Cl
WITH ISOCONCENTRATIONS OF TOTAL VOCs
Cnu INDUSTRMS, INC.
HWY 268 (EAST MAIN STREET)
ELKIN, NORTH CAROLINA
APPROM BY PROIECP Na: 042.01
DRAWN By,, GGL SCAT^R; P -30'
DKrx: iwo P1GURE l i, sr=7 4

D i D'
120
90
60
-30
-60
SCREENEDINTERVAL -90
■ aa.9 OC£OBER 2006 TOTAL VOC CONCENTRATION
IN PARTS PER BILLION (PPB)
411
Qh 4 �9 a• 4,l 4jZ
4 0�+
4,1
� lq
LAM SURFaCF 1 LL 4� l4
' UDROCK
1t
+l-200.250,
WLUTB
7,G56.O�f
l
■ y
,
zlz.aoo.o�
...................1,.. _ _ .......
210,6m.o
................. ................ ., .....
1............
100PGppH......- ...
�
1
�
�
1
�
............................. ......
...
.....
. .. . . .............
1 r
�S3
10,000 PPB ?
670.0
_
_ 1,D00 PP8
...................................................
.`..........�
J
J...................... .
_ ..
3L
/ ISOCONCENTRATION LINE 0 30 60 90 120
9- WATER TABLE HORIZONTAL SCALE IN FEET
2L 15A NCAC 2L STANDARD OF 1,1,1 TRICHLOROETHANE AND DEGRADATION PRODUCTS
NOTES, WELLS SURVEYED RELATIVE TO TBM OF ASSUMED ELEV. 100.00 FT LOCATED ON LID OF WELL VAULT OF MWE-3, BASED ON
2001 ENSR SURVEY DATA, THE MWE-3 TBM CORRESPONDS TO A 1929 NATIONAL GEODETIC VERTICAL, DATUM OF EL 886.78 FT.
GROUNDWATER DATA FROM OCTOBER 2006 SAMPLING EVENT, STATIC WATER LEVEL BASED ON OVERBURDEN WELLS [BLACK],
BEDROCK WELLS (RED) SHOWN FOR COMPARISON ONLY.
150 ISO
7�r
TRIGON
120
)0
G0
-30
-60
-90
CROSS SECTION D - DI
WITH ISOCONCENTBATIONS OF TOTAL VOCs
C. I DRAWN BV: [
F.
93 nn r�: 21tN7
CNH INDUSTRIES, INC.
HWY 268 (EAST MAIN STREET)
ELKIN, NORTH CAROLINA
APPROVED BY I Pk.OJECT Nw ("2-064917

qP A, *'�Aw
- MCDENR
North Carolina Department oflEnvironment and Natural Resources
Division of Watet Quala\!
Beverly Eaves Perdue Coleer, H Sullins
Governor Director
April 7. 2011
James A. Ovenden. Trustee
CMI Industries
219 Muirfield Drive
Spartanburg, SC 29306
Ref: Issuance of Injection Permit W10400106
CMI Industries' Wastewater Treatment Plant
Elkin, Surry County, North Carolina.
Dear Mr, Ovenden:
L+ee � reernar
Secrlrl8-�
In accordance with the application received on Februan- 14. 2011. and the supporting data received March 16. 2011. we
are forwarding permit number W10400106. This permit is to inject HRC 3DMe (Hydrogen Release Compound Primer
with 3D Micro Emulsion) to remediate groundwater contaminated with chlorinated solvents at the facility referenced
above. This permit shall be effective from the date of issuance until March 31. 2013. and shall be subject to the
conditionvand limitations stated therein. including the requirement to submit a final project evaluation as stated in PART
VII — MONTTORING AND REPORTIRG REQUIREMENTS. Please note that some of the monitoring: requirements
have chanced from your application. Please read the entire permit to ensure that you are aware of all compliance
requirements of the permit.
You will need to notify this 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 [phone] or da47d.goodrichtatcdenr.go►, if
you have any questions about your permit,
Best Regards,
David Goodrich, Hydrogeologist
cc: Sherri Knight. Winston-Salem Regional Office
Mark P. Filardi. MACTEC Engineering and Consulting. Inc.. 2801 Yorkmont Road- Suite 100. Charlotte. NC 28208
Janet MacDonald, NCDWM Superfund Section. 1046 Mail Service Center. Raleigh. NC 27699-1 W
W10400106 Permit File
k^IJI== R aP 7E-_' 7ION 3E--RO1
105 Ma Sewov C sntm Rawl?i. NCru aVItli 27c*4-1Int
w
acatovn. 2"28 t;auna! 9autSvare Rsfeurr iaaRl:.amnrbs+� {
PftW*: 9i9.733-3i29 - i:AY t 919-71aZltl 2 415 -1�us;o, jerv2— 1 ' 6- [tj Car(14]n*1
n[emet wxiw.rttwate uglify.❑

Goodrich, David
From: Goodrich, David
Sent: Thursday, March 17, 2011 9:29 AM
To: Wang, Shuying
Subject: FW: Well Construction Records for CMI WWTP
Attachments: Well construction Records.pdf
Shuying,
Here is the well construction information you requested for Permit WIU40D106. Please let me know if there is any othei
information we should ask for, or if the information they are providing to us herein is not adequate _
Thank you
David Goodrich
Aquifer Protection Section Central Office
From: Filardi, Mark fmailtoNPFII.ARDI5mactec.com]
Sent: Wednesday, March 16, 2011 2:07 PM
To: Goodrich, David
Subject: Well Construction Records for CMI WWTP
Hi Piave,
As.. discussed on Monday, please find attached well construction records and a proposed injection well schematic for the
CM WWTP site. I was only able to locate well records for 2 of the 8 existing wells that we have proposed to inject into.
Therefore, I've included a table from the RI Report prepared by others that includes some well construction details. I
have visited the IHSB files twice in hopes of finding more well records for wells previously installed at the site, but have
been largely unsuccessful. Based on my conversations with Kim Caulk, there's little hope that they wi11 be found.
Please let me know if you need anything further to Complete your review of the UIC Permit Application for the Site.
Regards,
Mark P. Filardi, P.G. I Senior Geologist
MACTEC Engineering and Consulting, Inc. I Charlotte, NC
Office [phone] 1 Fax [phone]
Email rn filardi mactec.com I Web www.mactec.com

Table 1
Summary of Well Construction Details and Recent Groundwater Quality Data
Former CMI WWTP
Elkin, North Carolina
Well Construction
ACC --cncentrations (10106) COC :.4ncerltrations (12107 and 01108]
Well iD
,
Land
Surface
Elevation
{MSL
Bottom of
Screen
Elevation
(MSU
Total Well
❑epth
{ft bys}
1•'.1-TCA11.1,2-TCA
1,1-0CA
i,1-DCE
1,1,1-TCA
1,1,2 TCA
1,1-DCA
1,1-DCE
Overburden welts 0-25'
EBMW-2
98.B8
80.99 17.89
NO
ND
ND
NO
ND
ND
ND
ND
EBMW-3
97.42
83.28
14.14
NO
NO
NO
ND
ND
ND
ND
ND
EBMW-4
95.25
79.37
15.88
46.8
NO
NO
4.0
ND
ND
NO
N❑
EBMW-6
95.41
75.42
19.99
180
NO
127
52
5 "
ND
442
424
EBMW-7
98.04
77.79
20.25
90
NO
10.800
3 930
HIM
NO
11 400
4 480
B W-11
94.44
78.85
15.59
115
NO
17.2
29.6
25
ND
25.0
18.6
-1
101.32
81.32
20.00
67 200
ND
ND
ND
116000
NO
ND
ND
M -
J[jMW
98.42
76.98
21.44
21,700
NO
12 000
3 Z80
42 200
hld
16.300
5,680
-14
95.86
77.14
113 2
34 200
NO
832
1 080 110.000
NO
NO
ND
-15
98,19
79.87
18.32
43.5
NO
10.3
33.8 26.0
ND
10.9
23.4
EBMW-16
96.05
78.97
17.08
523
NO
109
US 388
ND
495
635
EBMW-24
99.79
79.79
20.00
3.2
ND
N❑
NO ND
NO
NO
ND
EBMW-28
99.94
79.94
20.00
2.3
ND
ND
NO No
NO
I NO
ND
FAMW-1
98.99
84.81
1 14.38
116
NO
6.4
3.5 NS
NS
NS
NS
FAMW-2
106.46
81.99
24.47
NO
ND
ND
ND ND
ND
ND
ND
FPMW-2
96.64
77.94
18.70
ND
ND
ND
NO NS
NS
NS
NS
5PMW-3
99.61
80.06
19.55
NO
NO
ND
NO NS
NS
NS
NS
FPMW-4
93.99
77.77
16.22
0.5
NO
15.8
4.4 1.4
NO
10.0
2.3
FPMW-5
92.43
76.5
15.93
1.9
1 ND
0.9
0.3 NO
ND
1.3
ND
FMW-01-01
97.62
72.52
25.00
31,000
19.0
24.000
moo JL5.Lo
22.9
2E.000
9,320
MW-01-02
97.61
77.61
20.00
ND
N❑
ND
ND ND
NO
ND
ND
MWE-1
96.63
76.53
20.10
Fie
ND
36.0
233 660
NO
68.0
503
MWE-2
101.37
81.37
20.00
ND
ND
ND
NO NS
NS
NS
N5 I
MWE-3
I 100
82.03
17.97
ND
1
NC
NR
I NO NS
NS
NS
NS
MWE 101
96.77
78.T7
18.00
ND
ND
I NR
I ND ND
ND
ND
ND
L
Is
Shallnw Rork Wails i36.55'1
EBMW-1
96.4
63.14
33.26 1
3-0 20
NA
3 34C
1 160 6.100
ND
5 810
3,070
EBMW-5
95.26
56.39
38.87
193,1301)
NO
15,600
14.000 189.000
ND
16,500
-16 100
IEBMW-S
96.98
65.19
31.79
87 200
NO
1 4.8011)
5.500 24 000 I
NO
1 11.20
10,600
I'EBVIW-9
95.84
43.09
52.75
184.000
ND
1 9.920
13.009 214 000
ND
10.400
16300
EBMW-10
97.32
41A9
55.83
20 .000
NO
9,650
7A00 73,000
ND
NO
ND
£BMW-23
99.64
55.54
4.4.10
ND
ND
I ND
ND ND
ND
I ND
ND
EBMW-27
99.27
57.27
7 472700:
-NE)
ND
ND
ND Np
ND
I N❑
ND
Deep Rock Wells 60-200'
EBMW-17
93.46
3.46
90.00
11.9
ND
8.9
5.8 1.3
ND 1
5.3
2.6
EBMW-18
95.58
17.58
78,00
348 000
NC
33,190
6.901) 309 000
NO
48 500
NO
EBMW-19
100.64
0.64
130.00
54.9
NO
5.2
3.3 11.1
ND
4.7
ND
EBMW-20
102.69
-22.31
125.D0
41.5
NO
4.9
3.0 11.5
1 ND
1 3.5
1 A
EBMW-21
98.72
-26.28
125.00
2530
ND
136
90.0 1.540
NO
61
50.5
EBMW-22
94.29
-26.01
120.30
10 800
NO
1.920
1.050 80
ND
772
500
-25
-101.98
2000
34
NDEBMW
.
04
ND �ND
NO
ND
NO
EBMW-26
97.26
2.3
1,8
7 D
N
NO
ND
ND
12L Standards
200
-
Tp
1 7 11 200
1
7
Notes:
Concentration reported in units of u91L.
MW-01-01 also had concentrations of TCS. PCE and other CVOCs above the 2L Standard.
Concentrations in bold -face underlined type exceeded the 2L Standards. l Prepared br. n
" r �PP
" I ( K e. Checked hy. 4-. a. L f Itu 0 j
' JI c.�•s Sh^� [�rr,~� +�'S mac.'.- 41
WJLM
�g � 1 H * C✓Jr� � Yt � ! a = � � � t -

STICK—UP LOCKING
PROTECTIVE WELL COVER
CONCRETE PAD
GROUND SURFACE
CEMENT GROUT
OVERBURDEN
8—INCH DIA. BOREHOLE
❑ TO 20—FEET
4—INCH DIA. SCHEDULE 40 PVC PIPE
TOTAL
x �`
WELL DEPTH
40 FEET
BEDRO20
FEET
OPEN ROCK
BOREHOLE
20 TO 40—FEET
i�
r
Kip c/r W if. � f
MACTEC
PROPOSED INJECTION WELL DIAGRAM
ENGlNEfRING & CON51tM G, INC. CM I WWTP
CHARLCTfE, NORTH CAROUNA ELKIN, SURRY COUNTY, NORTH CAROLINA
PREPARED GATE CHECKED DATE JOB NO. $228—❑$-4691 FIG6RE
BY �

BPA Environmental &- Engineering, Inc.
MONITORING WELL INSTALLATION SKETCH
Project CM Well number EBMW-18
Geologist K.B. Vanhay Depth to water from TOC 11.60 ft
{" Constructed on 10/13/05 Elevation of water table 85.83 fr
Elevation of ground surface 95.58 ft Date of water table measurement 1/5/06
Elevation of top of well casing (loci 97.43 ft Total depth of well 78.0 ft
Reference point MWE-3 well vault Iid (El. 100 ft) NOTE.Drawing not to scale
�ackfill material
Sand
Thickness of surface seal
2.0 ft
type of surface seal
Concrete
Duter annular seal material
Cement out
cuter rasing material
Carbozxeel
Suter easing diameter
10.25 in ID
ntermediate annular seal material
Cement -grout
Bottom elevation of outer casing
65.58 ft (30.0 ft bls)
Inner casing material
Carbon steel
Inner casing diameter.
6.25 in ID
Inner annu Lar seal material
_ Cement grout
Bottom elevation of inner casing
30.58 ft (65.0 ft b1,$)
Type of riser pipe
PVC
Diameter of riser pipe
2.0 in ID
Type of filter seal
Bentonire
Top elevation of filter seal
32.58 ft (63.0 ft bls)
Type of filter pack
Sand
Top elevation of filter pack
30.58 ft (65.0 ft bls)
Top vkva6m of screen
27.58 ft (68.0 ft bls)
Well screen diameter
2.0 in ID
Screen size
0.010 in
Bottom elevation of screen
17.58 ft 78.0 ft bls)
Diameter of stage I boring
15.0 in
Diameter of stage 2 boring
10.0 in
Diameter of stage 3 boring
6.0 in

BPA. Environmental & Engineering, Inc,
MONITORING WELL INSTALLATION SKETCH
Project CM Well number EBMW-22
". Geologist K.B. Vanhoy Depth to water frorrt TQC
11.97 ft
.r
Constructed on - 10/12/05 Elevation of water table 84.70 ft
Elevation of ground surface 94.29 ft Date of water table measurement 1/5J06
Elevation of top of well casing (T0Q 96.67 ft Total depth of well 125.0 ft
Reference point MWE-3 well vault lid (El- 100 ft) NOTE: Drawing not to scale
Sackfill material
Thickness of surface seal
type of surface seal
?uter annular seal material
Outer casing material
?rater c akng diameter
.ntermediate annular seal material
Bottom elevation of outer casing
Inner casing material
Inner casing diameter
Inner annular seal maternal
Bottom elevation of inner casing
Type of riser pipe
Diameter of riser pipe
Type of filter seal
Top elevation of filter seal
Type of filter pack
Top elevation of filter pack
Tap dew of screen
Well screen diameter
Screen size
Bottom elevation of screen
Diameter of stage 1 boring
Diameter of stage 2 boring
Diameter of stage 3 boring
Sand
2.0 ft
Concrete
Cement grout
Carbon steel
10.25 in ID
Cement grout
56.29 ft (38.0 ft b1s)
Carbon steel
6.25 in ID
_Cement grout
29.29 ft (65.0 ft b1s)
PVC
2.0 in 1D
Bentonite
-8.71 ft (103.0 ft b1s)
Sand
-10.71 ft 105.0 ftbls)
—10.71 ft (105.0 ft b1s)
2.0 in ID
0.010 in
-30.71 ft (125.0 ft b1s)
15.0 in
10.0 in
6.0 in

S,�-;*A
NCDEHR
I11ortr 'Sal'oim Dnartment o" :::11viron 71ew and lgattl; a' Resources
Division o` W mr r:ualm
�UErlt �dVvS Fi rGUE Cohen r. Junin:
overno, Direcia-
Iebruary 24. 2011
James Ovenden
CMI Industries
219 Muifefd Drive
Spartanburg. tiC 29306
Subject: Acknowledgement of Application No. WI0400106
CMI Waste Water Treatment Plant
Injection In situ Groundwater Remediation Well (51)
Surr■
Dear Mr. Ovenden-
ti-
The .aquifer Protection Section of the Division of W ater Qualitv (Division) acknowledges receipt of your permit application and
supporting materials on February 14. 2011. This application package has been assigned the number listed above and will be reviewed
by David Goodrich.
The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To ensure the
ma%%mum efficiencv in processing permit applications, the Division requests your assistance: in providing a timely and complete
response to any additional information requests,
Pleu rye 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 Tong as 60 - 90 days after receipt of a complete
application.
11 %u- I­tve any questions, please contact David Goodrich at 919-715-6162. or via e-mail at [e-mail]. If the
reviewer is unavailable, you may leave a message. and they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerei _
for Debra d. Watts
Supervisor
&6cc�n_c
cc: Winston-Salem Regional Office, Aquifer Protection Section
MACTEC Engineering & Consulting. Inc (Paul Johnstone - 1327 Miller Road. Ste A. Greenville, SC 29607
Permit Application File W 10400106
-No- licar®lin"t

Documents Associated with
the July 10, 2009
CMI Industries
Injection Well Permit

LTXWJ
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverfy Eaves Perdue Cofeen H. Sullins
Governor Director
July 13, 2009
James Ovenden
CMI Industries
219 Muirfield Drive
Spartanburg, SC 29306
Ref: Issuance of Injection Permit WI0400I06
CMI Industries' Wastewater Treatment Plant
Elkin, Sum County. North Carolina.
Dear Mr. Ovenden:
Dee Freeman
Secretary
In accordance with the application received on March 5, 2009, and the supporting data submitted June 19. 2009, we are
forwarding permit number WI0400106. This permit is to inject HRC 3DMe to remediate groundwater contaminated with
chlorinated solvents at site referenced above. This permit shall be effective from the date of issuance until May 31, 2011,
and shall be subject to the conditions and limitations stated therein, including the requirement to submit a final project
evaluation as stated in PART VII — MONITORING AND REPORTING REQUIREMENTS. Please note that some of the
monitoring requirements have changed from your application. Please read the entire permit to ensure that you are aware
of all compliance requirements of the permit.
You will need to notify this 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 919-715-6164 or tomas slusser a;nedenr.gnr if you
have any questions about your permit.
Best Regards,
I
Thomas Slusser, L.G.
Hydrogeologist
Groundwater Protection Unit
cc: Sherri Knight. Winston-Salem Regional Office
Andrew Clark. MACTEC
W I0400106 Permit File
QUIPER PROTECTION SEDTION
1636 Mail Service (:enter. Raietgri. North Carolina 27699.1636
Location. 2728 Capital Boulevard. Raleigh. Norm Carolina 27604 Orit
Phone 919.733, 3221 r FAH 1 919-715.0588. FAX 2' 919-715.6D48 Customer Servrm 1.877.623.6748 N orth Cal o l i n a
Intemet www.nmateruuafity.mg ati ra ■l y
Ar<E.auar i?6p71lllnlly ArfnmaUVa 4IXran ernnlovE° � f/

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Govemor
Mark Filardi, P.G.
MACTEC Engineering and Consulting, Inc,
2801 Yorlanont Road, Suite 100
Charlotte, NC 28208
Division of Water Duality
Coleen H. Sullins
Director
June 24, 2009
Ref: Response to Additional Information Submittal
Injection Well Permit Application # WI0400106
Former CMI Wastewater Treatment Plant
Elkin, Surry County. NC
MACTEC Project: 6228-08 4691
Bear Mr. Fiiardi.
Dee Freeman
Secretary
Thank you for discussing with me your June 18, 2009, response to my request for additional information and the
upcoming pre -injection groundwater sampling event for the subject facility. I recommend that as part of this
upcoming groundwater sampling event monitoring wells EBMW-10 and EBMW-18 be analyzed for metals in order
to determine their presence in the proposed injection interval. At a minimum the specific parameters should be the
same as those previously detected in monitoring wells FAMW-1, FAMW-2, and MWE-9 mentioned in your
additional information submittal.
The analytical results for these groundwater samples do not need to be submitted prior to issuance of the injection
well permit, but they should be submitted to me and discussed as soon as they are available. If metals
concentrations are of concern, then we should discuss manipulating pH and oxidation-reduction potential in order
to maximize chlorinated solvent degradation while minimizing metals mobilization.
Lastly, the injection well permit is not needed to break ground for the proposed test pits downgradient of the fly asb
basin. The injection well permit is only needed to construct and operate wells for injection.
Let me know if you want to discuss further or if you have any questions. I can be reached by telephone at 919-71 i-
6164 or email at thomas.slusserlamcdenr.go
Best�
J� 6W4.
Thomas Slusser. L.G.
Hydrogeologist
Groundwater Protection Unit
cc: Stephen Berry. Winston-Salem Regional Office
W10400106 permit file
AOUIFER PROTECTION SECTION
1636 Mail Servlre Center. Raleigh. North Carolina 2769E-16K
LVCS90n 27 28 Capital BQA -vare- Rmgh. North Carolina 276D4 Onc
Rhone. 919-7 33.3221 l FAX 1 919-71SZ88. FAX 2. 91E-, t 0451 Nusmmer Service -8r � •623.674E I {]rt�th fC�1a*r�rolli na
lnterrret' www,ncwater�uallN•arR ,��LitL�i` l�i�Ly
Orr EQLot Opnoclunit4 ' AFrrrmallve I-Ldorr =_fop aver

AMACThC
engineering and constructing o better tomorrow
June 18, 2009
Mr. Thomas Siusser. L.G.
Groundwater Protection Unit
Aquifer Protection Section
North Carolina Department of Environment and Natural Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
RE: Response to Comments
Injection Well Permit Application #WI0400106
Former CM1 Waste Water Treatment Plant
NONCD 0001092
Elkin, Surry County, North Carolina
MACTEC Project: 6228-08-469I
Dear Mr. Slusser:
MACTEC Engineering and Consulting, Inc. (MACTEC), on behalf of CMI Industries (CMI), is pleased
to present this Response to Comments for the Injection Well Permit Application (# W10440106) for the
CMI Waste Water Treatment Plant facility (CMI WWTP) located in Elkin, Surry County, North Carolina.
MACTEC submitted the permit application to the NCDENR Groundwater Protection Unit on March 5,
2009. MACTEC subsequently received comments on the permit application via electronic mail on May
20, 2009. The continents are recited below as they appeared on correspondence from NCDENR and
italicized, followed by the MACTEC responses:
• Is geochemical data available for the most recent groundwater monitoring event? This information is
needed to evaluate geochemical conditions within and around the contaminant plume,
RESPONSE: MACTEC is in possession of groundwater quality data from 2007/2008 and has
attached these data to this correspondence for your use.
■ Please submit a neap of the locations of the proposed injection wells.
RESPONSE: MACTEC has attached a map of the proposed injection well locations.
■ Has contamination been detected in surface water samples of the Yadkin River?
RESPONSE: Surface water samples were reportedly collected at two locations (identified as USYR
and DSYR) along the northern bank of the Yadkin River on January 5, 2006 and October 3 and 4,
2006 by a previous consultant. As presented in Table 8 of the Remedial Investigation Report
prepared by Trigon and dated March 9, 2007 (attached), concentrations of 1,1,1-trichloroethane
(1,1,1-TCA), 1,1-dichloroethane (13-DCA), 1,1-dichloroethene (1,1-DCE) and methylene chloride
were detected in the surface water samples collected in January 2006 and 1,1,1-TCA was also
detected in the surface water samples collected in October 2006. However, none of the
concentrations exceeded the USEPA Region 4 Ecological Risk Freshwater Surface Water Chronic
MACTEC Engineering and Consulting, inc. RECEIVED 1 DENR I ❑WQAquifer Prot
2801 Yorkmonr Road, Suite i O:- • NC 28208 • Phone: [phone] • Fax- 704. 357.8638 www.rnaC i
JUN 19 2009

Respr►nse to Comments June 18, 2009
Injection Well Permit Application #K10400106
Former CMI Waste Water Treatment Platt
NONCD 0001092
MACTEC Project: 6228-084691
Screening Levels. Please note that Surface Water Standards (213 Standards) for the Freshwater
Aquatic Life Scenario have not been established by the NCDENR DWQ for the compounds detected
in the surface water samples collected from the Yadkin River in 2005. A copy of Table 8 and
corresponding Figure 5 showing the locations of the surface water samples from the RI Report are
attached for your reference.
• What does `projected " mean beneath the well labels on the cross-section maps?
RESPONSE: The use of "projected" means that the cross-section line(s) did not directly intersect the
wells, but the wells were located within close proximity of the cross-section line to provide
representative data. Please see the attached plan view of cross-section lines and well locations.
Site maps indicate the presence of a fTv ash basin northwest of the proposed injection area. These
waste structures are known to impact groundwater in North Carolina and throughout the nation with
metals such as arsenic, selenium, thallium, boron, iron, and manganese. Has this waste structure
been evaluated for groundwater impacts? Have metals been detected in groundwater related to this
waste structure? If there is a contaminant plume emanating from this waste structure, has it reached
the chlorinated solvent plume that is the object of the proposed injection operation? If yes, then what
is the horizontal and vertical extent of the,fly ash plume? These questions are important because if
metals are present in the chlorinated solvent plume then they could be mobilized due to the decrease
in redox potential and pH that is expected to result_ j'rom the proposed injection.
RESPONSE: MACTEC concurs that there is the potential that metals, naturally occurring or due to
historical releases, will be mobilized as a result of the reducing conditions that are anticipated with
the proposed injection. This concern is somewhat mitigated by injecting only into the fractured
portion of the bedrock aquifer as opposed to the soil horizon where naturally occurring metals are
expected to pose a greater concern. In addition, the reducing conditions that are expected will be
transient during the time of injection and within the area of injection. As groundwater migrates
through the fractures, reducing conditions are anticipated to dissipate, in which case metals that may
have been mobilized would be re -deposited. Phasing the injection activities and monitoring
reduction-oxidiation potential during the injection activities will allow for modifying the injection
rates so that the reducing conditions are maintained within the proposed injection zone as indicated on
the attached figure.
MACTEC further believes that the risk of temporarily mobilizing metals within a limited area are
outweighed by the expected benefits of promoting enhanced bioremediation of the elevated
concentrations of chlorinated compounds detected within the fractured bedrock aquifer.
Furthermore, a metals investigation was previously conducted in the vicinity of the fly ash basin,
equalization basin and floodpiain area by SPA Environmental and Engineering, Inc. The results of
this investigation were summarized in the "CAP -Related Supplementary Hydrogeologic
Investigations" report dated January 13, 2000. Arsenic, chromium and lead were detected above 2L
Standards in on -site monitoring wells FAMW-1, -2, and MWE-9, located near the flyash basin.
PIease note that these wells were installed into the overburden at the site with total well depths
ranging from 14.8 feet (FAMW-1) to 24.5 feet (FAMW-2) and the proposed injection activities are
within the deeper fractured bedrock zone below these overburden wells. The concentrations of
arsenic in MWE-9 and lead in FAMW-1 exceeded both the 2L Standards and background levels that
were determined from off -site monitoring wells. Also, cadmium, chromium, and lead were detected
in the background monitoring wells above 2L Standards.

Response to Comments Jane 18, 2009
Injection Well Permit Application #W10400106
Former CM! Waste 04ter Treatment Plant
NONCD 0001092
MACTEC Project. 6228-08-4691
MACTEC has proposed in -situ chemical injection into the impacted shallow bedrock groundwater
zone (targeted depth of 25 to 85 feet bgs) using a network of six existing and 10 proposed monitoring
wells. The depth to the top of screen in the existing wells proposed for injection ranges from 21.7
feet to 68 feet bgs. The minimum casing depth of the proposed injection wells is 20 feet bgs. As
such, injectants should not come into direct contact with groundwater in the overburden soils.
In addition, MACTEC has proposed to excavate test pits down -gradient of the fiyash basin prior to
commencement of injection activities to evaluate potential residual sources of constituents.
Representative samples from residual sources, if encountered, will be collected and analyzed for site -
specific contaminants of concern including VQCs and metals. These data will be used to refine the
scope of the proposed remedial action, if necessary, and presented in the Pre -Construction Report
prior to implementing injection activities. The Pre -Construction Report will provide specifics as to
the proposed phased injection program and monitoring activities that wilt consider methods to control
injection rates so that reducing conditions are maintained within the treatment zone.
Please contact the undersigned at 704-357-8600 if you have questions or need additional information
regarding this correspondence.
Sincerely,
MACTEC Enginee ' d Consulting, Inc.
Mark P. Fitar i.
Senior Geologist
I 1
drew M. Clark, P.G., RSM
Principal/Project Manager
Attachments: Groundwater Quality Data Table (partial)
Surface Water Quality Table (partial)
Proposed Remedial Action Plan showing Injection Well Locations
Locations of Cross Sections

GROUNDWATER QUALITY DATA TABLE (PARTIAL)
From
"2047 ANNUAL GROUNDWATER MONITORING REPORT for InterfaceFABRIC"
Prepared by
Sevee and Maher Engineers, Inc.
May 2008

TAPLE 3.4 (caefinttW)
SUMMARY OF GROUNDWATER ANALYTICAL RESULTS
WA.STRWATF.R TREATMENT PLANT PROP€.RTY
INTEN,FACP FABRIC, INC.
ELKIN, NORTH CAROLINA
----
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tr . No deecdr4, rq-" Itrort nnl —Ahtr
p- Prager] I fn 3 r J4 wlu 1p x 6 w fk� "..rlinp
MIRE - Metlly-Krl-Mde•I cilia
NAPR - NaphDlm=
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135IMB - ".0-Tnmrtbl4h�"
Ft_p-XY . Mp-YYlenr
axY -o-xvif t
1[71.-Tduc5lr

TAR LE 3-I (continued)
Sf I MMARY OF CROLI"WATER .A NALYTICA I_ RFSULTS
WASTE WATER TREATMENT PLANT PROPERTY
MTF.RI ACE FARRIC, INC.
KKK NORTH CAROLINA
t4':Ik p ]
"ample
L7arr
VOLs u LI{1J
f112E1CA
1122P('A
PCE
CC[.S
1121Y'A
WE
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k2l]L-'A
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c12PCR
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i'{i,n
riff
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0.175 0s
0.7
020
200
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2.9
70
0.3F
1
70
k D0
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Note ,
11) Voluble Organic compound IV W) of m trxLinnn rrprewtl In microgram per lilef fuA1L].
12) VaNe shnon In n Lh VOC in column header reprewol the 15A NCAC IL ifwundn,raer nvidard; mokts in rod ecctnw the indicrur4
15A NC:AZ 21- gro od"br stunJwd
f 3 i Symbr4 'r" and aceoeiuetl nlr ie rel+re,errts tlw sample quantituian Ibis. may be elmatcd doe to ss nple dihnion dw ing khnr Cory annlysis pr+ocedurex
]dl S)wW _ -" indicate,. lftplr was rwl tolslyxed for Use anr151f1unsl-
C'mrsutucnlahhreriarions:
V005:
BRM - B�amteltrane U N1 • Cill—Mcrhanc et2QCE • cis-1,2-17icirlpnxtkiene
CC1A - CMu+n relrxhlnri de I I l3C'A - 1,1-0ichlonxil ru it t I ZWE - rrsnM 1.2 • LI i chi ormlhene
MA-Chkrneflmc 12[SC',4- I,2-Pich]Oroe[hWlc MECL- Mcilsyiene dtkuridc
(IF - Chk/raferm l I WE - i, I-Diddomeantic 1 ] IMA - 1,1,1,2-Tcinchhauc0mne
Abbreviaaltmil
J - Enirrmted rtvrll drK 1v eXi eMlk oce Of ouc ec mnrc qualiry Crmi=01 rcquirnuerrt5
M-1-fin mirr5ia aslabliahed
p - Purged I to 3 w0l mkmoea prior to ht oow sampling
1122PUA - 1.}.7.2-Tetrachlnmcilwre KT - TridllQFot?$r•nc
PEE - TfArschlnmr hmc VC - Vinyi chimidc
TCA- 1,1,1-Tdchlo5octhutc
112TCA - 1.1,7rTricl:lrvaKlhmw

TABLE 34 (orRinlmed)
SUMMARY OF GROUNDWATER ANALMC AT. RESULTS
WASTEWATERTRFATM£i+['T PLANT PROPERTY
fly T1;RPAC•'F, FABRIC, INC.
ELKIN, NOTUF71 CAROLINA
V[lts (u •'L' '
t`,:II i1+
ialtglia
t7aoc
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V. ii
MF'-k5' t:tiX}
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50
24
170
t.4
350
350
10
200
21
700
0.W5
10.%t5r0r.
03AW01
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12/17/07
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(1) Vnlatilr.-g"is nmrps+uad[VOC7 uInIgr&.ttianx"Ple"Cd in mictograma per liter(uqyL).
[7t Vaiue slw beneaib V(1[' is udwnn hcabur mpre.4nt the 15A VCM, 21- gr mridwafer-Qmdwd: results in sal
cxrred the uldimrd ISA KCAC 2L goundwater slandard
(31 Symwi -e and anocimcil value rqq-=rits dw wurq+k q+rrnsittair+r+ limil. may be cicvatrd due u+ sarrrplc diiull—
during I.homtmy analysis pnr-edi .
(4) Symbol'—' Irdtca m sample was n A anatymt for the enreai tucnt
Constituent ahbarial irms!
Yam'
BbNZ - Bm/crtc i7ACl3. 1,2-Pichlnroben7enr
N-IM - e-Burylhcnrenc 13DCII - i,3-Fhrhlotohntreric
Cal, - C wbar llimlfikk t 4DCII - 1,4.15ichlvkvWna u
LIM-Cldmnba ur w EIT - Ethytbenrcm
AWerimial :
1- Estimated resell duc to ma d+u+cc of nne or mmc
gk-Wy canton roqu fuemenLS
p - Purged 1 N 3 wall aolumm prior to low fk)w wunpli nR
M731E - Mcdrg-ten-busyl cdw I i 5IM13 - {,3,5-Tr1mcthy lbenxer+r
NAPH - Naphtiukite mP-X Y - ra p-xykT-
123TCP-1,Z,G-]LY-v-XyTow
{ 74TMB - 1.3.4.TrirrrrYhylbe4ZePa T(.li_ - Toluene

SURFACE WATER QUALITY DATA TABLE (PARTIAL)
From
"REMEDIAL INVESTIGATION REPORT — CMI INDUSTRIES, VIWTP"
Prepared by
TRIGON ENGINEERING CONSULTANTS, INC.
March 9, 2007

TABLE 8
SUMMARY OF HISTORICAL STREAWIRIVER ANALYTICAL RESULTS
WASTEWATER TREATMEMT PLANT PROPERTY
ELKIN, NORTH CAROLINA
COMPOUND
SWE-2
SWE4
SS-1
SS-2
SS-3
USYR
SOYR
DSYR
STATE
2L STANOARD
NCOENR DWO Water Qt1a*
Stanoard to Support Aquatic life
For AN Fresh Water
USEPA Region 4 Ecological Risk
Freshwater Surface Water
Chronlc Screenln
12112171
1I313M2
8R4M2
6rAM
6R4192
1092
1992
199Q
1 1 1 2-Tot act loroelhane
1 1 1 Trlchloroatnane
220
5
20D
528
t 122-Tstrachtorpelhane
0.175
1 1,2-Tnchloroelhene
1.1-DirNoroethane
47
70
1.1.01chlumalnene
7
1.1-Dichl rooene
1 2 3-Tdchlorobanzena
1. 2 3-TncMro r na
0.005
1 2 4-Tr=lorobanzana
70
124-Tnmeth (benzene
350
1 24:)i"rro-B-Chlpro 'Opene
0.025
t 2-Dlbromoethane
0=4
t 2-Dichloroberiz"
24
1 d]lmlornethane
0,38
1 2-Odohl rp ne
0.51
1 3 5-Trirnon benzene
350
1 3-Dichlorobenzene
170
13-Dlchio ane
1 4-Dlchlorobanzene
1 4
22-0Ichlororo ane
4-1toluene
Benzene
1
Bromobenzene
Bromochlornmalhene
BromodlChloromslhans
0.5a
Brbmak=
4.43
Branwnelhene
Carbon Tatracnkxide
0269
Chloroberizana
50
ChlDraelhane
2 8W
Chloroform
70
Chloromethane
16
cis-1 2.Oichioroelhane
70
Ddbromcchloromethans
D,41
Dlbromametiwe
Dlchlorodlfluoromethane
1,40)
Oisopropyl ether
70
Etn Ibanzene
550
Hexachlorobutadiene
0.44
lsopropyllbanzAne
70
m.o.p-Xylarra
530
Mathylone Chloride
4.5
MaMyl tort-b ether
200
Naphthalene
21
n benzene
70
n (benzene
70
o-ChbrpWluane
hioratpluene
sooro t0Uene
sew—ButlylbarkZ918
70
styrafte
100
larl-Butylbanzone
70
TeNadldoroalhene
0.7
Toluene
1 00D
tran8-1 2-Dichlorpethens
100
Trtn woothene
2.8
Tricldoroflubromsthans
2,100
'Anyl Chloride
0,015
Total VOCs
BOIL.
267
BQL
BOIL
I BOL
I BQL
SOL
LICAJDogradaton Products
458
' 1892 Yadkin Rlver Samples not anaWad for VOCs.
Results in rnj=QrarnaABar fugA.l or ppb
Ramedlal Invesligation Tobias.
Revision Dale. 2d14120D7

TABLE 9
SUMMARY OF HISTORICAL STREAWRIVER ANALYTICAL RESULTS
WASTEWATER TREATMENT PLANT PROPERTY
ELKIN. NORTH CAROLINA
COMPOUND
SS-1
SS-2
SS-3
SS-4
SS-5
SS-8
STATE
21LSTANDAR❑
NCDENR DWQ Water Quality
Standard to SupportAquatic Life
For All Fresh Water
USEPA Reglon 4 Ecological Rlsk
Freshwater Surface Water
Chronlc Screening
9117101
9117101
9117101
W17101
9117MI
9117101
1,1,1, 2-Tetra chloroelhan e
1,1,1-Trialloroathane
200
1 1 2 2-Tetrachioroethana
0.175
1 t,2-Trichloroethane
1 1-Dichlomelhane
I
F
70
1 1-Dichloroethene
7
1 1-Dichloro ro ene
1 2, 3-Trichlorobenzene
12,3-Tfthloro ro ans
1 2,4-Trirhlorobanzene
70
1,2,4-TMmath benzene
350
1 2-DWo mo-3-Chloropropane
0,025
1 2-Dlbromoelhane
0.00D4
1 2-Dichlorobenzene
24
1 2-Dichloroetilane
0.38
1 2-Dlchlorom e
0.51
1,3,5-Trlmeth benzene
350
1,3-Dichlorobenzene
170
1 3-Dlchlororo e
i 4-Dlchlorobenzene
1,4
2,2-Dlahloroe
4-Isopropyltoluene
Benzene
1
Bromobanzene
Bromochloromelhane
Bromodichloromethane
0.56
Bromofarm
4.43
Bromomelhane
Carbon Tetraahlorlde
0.260
Chlorobenzene
50
Chloroelnane
2,8W
Chloroform
70
Chloromelhane
2.6
cis-t 2-Dichloroethene
70
Olbromocharomelnane
0.41
Dlbromomethane
Dichlorodi0uoromethane
1.400
04sopropyl ether
70
Eth nzene
550
Hexachlorobutadlene
C."
Ise benzene
70
m a X ene
530
Mathylene Chloride
4.6
Methyl tort -butyl ether
200
Naphthalene
21
n-Bu benzene
70
n-Propylbenzene
70
o-chlorololuerne
Chlorololuena
Iso rotaluene
seo-6 benzene
70
St a
100
lert-Bu benzene
70
Talrachloroethene
0.7
Toluene
1.000
Vans-1,2-❑Ichloroethene
100
Trichtoroethene
2.8
Trichlamfluoromethane
2,100
VI no Chionde
1015
Tolal VOCs
BQL
8QL
BOL
SOL
BOL
BQL
TCAVe radation Products
' Locations of Yadkin River samples SS-1 thru SS-e, la ken upstream and downstream of the WWTP Property, not avaitable.
Results in mlcrogramsAfler (pg/L) or ppb
Remedial Invesligadon Tables
Page 2 of 4 Revision Dale: 211912D07

TABLE 8
SUMMARY OF HISTORICAL STREAWRIVER ANALYTICAL RESULTS
WASTEWATER TREATMENT PLANT PROPERTY
ELKIN, NORTH CAROLINA
COMPOUND
SS-4
SS-5
SS-5 dup
SS-8
USYR
DSYR
STATE
2L STANDARD
NCDENR DWO Water quality
Standard to Support Aquatic LEfe
For All Fresh Water
USEPA Region 4 Ecological Risk
Freshwater Surface Water
Chronic Screenin
115l06
115106
115106
115105
115106
115106
1,1,1, 2-Tetrachlo roe the ne
-
11.1-Tnchloroethane
110
2.56
3801
200
528
1,1, 2, 2-Tatrachlometh a ne
0,175
1,1, 2-T Hchloroethane
1,1-Dichloroetha na
23-3
.390J
70
1,1-Dichloroethene
4-3J
.210J
7
-
303
11-DicNoro ra ne
-
1, 2, 3-T hchlorobe nze ne
1,2,3-Trichlororo ene
0-005
1,2,4-TH01crobenzene
70
1,2,4-THmeth lbenzena
350
1,2-Dibrcmo-3-Chloro ro ane
0-025
1,2-DibmrnWhane
0.0004
1,2-Dichlorobenzene
24
1,2-Dichlomethane
0.38
1,2-Dichlo ra ne
0-51
1,3,5-Trimeth benzene
350
1,3-Dichiorobenzene
170
1,3-Dichlora roane
-
1,4-Dichlorobenzene
1.4
22-Dlchlora roane
4-Isopropyttoluerie
Benzene
1
Bromobenzene
Bromochloromethane
-
Bromodichlommethene
0-56
Bromoform
4,43
Bromomethane
Carbon Tetrachloride
0,269
Chlorobenzene
50
Chioroethans
1 S'S
2,900
Chloroform
640J
360J
.380J
70
209
Chlorom"""'a
2-6
c s 1,2-Qlchloroethene
70
Dibromochloromethene
0.41
Dibramomethane
0ichlorodifluoromethane
1,400
Dilsopropyl other
70
Eth (benzene
550
Hexachlorobutadiene
0.44
Isopropylbenzene
70
rn,o.p-Xylene
530
Methylene Chlorlde
1901
4.6
-
1930
Methyl tert-butyl ether
200
Na hthalene
21
n-Batyfbenzene
70
n-Pry benzene
70
o-Chiorototuene
p-Chlorotoluene
Iso roolvene
sec,&;tylbenzene
70
Styrene
100
tert-Bu lbenzene
70
Tetrachloroethene
0.7
Toluene
1,000
trans-1,2-Dichlorcethene
100
Trichloroethene
2.8
Trfchlorofluoramethane -
2.100
Vin Chloride
0.015
Total VOCs
0.640
0-360
0.380
153.4
3.34
0.38
TCA1Degradation Products
-
2.53
4.34
-
Results In m i crograms4 iter (pglL) or ppb
Remedial Investigation Tables
Page 3 of 4 Revision Date: 212012007

TABLE 8
SUMMARY OF HISTORICAL STREAM/RIVER ANALYTICAL RESULTS
WASTEWATER TREATMENT PLANT PROPERTY
ELKIN, NORTH CAROLINA
COMPOUND
SS-4
SS-5
SS-5 dup
SS-6
USYR
DSYR
STATE
2L STANDARD
NCDEN R DWO Water Quality
Standard to Support Aquatic LHe
For All Fresh Water
USEPA Region 4 Ecological Risk
Freshwater Surface Water
Chronic Screening
115106
115106
115105
V5106
115106
115106
1,1,1, 2-T etrach loroethan e
1.1,1-Trichloroethene
110
2.56
.380J
200
528
1,1,2,2•Tetrachlomethana
0.175
1.1, 2-Trich loroethe ne
1.1.Oichloroethane
23.3
.380J
70
-
1,1-Oichlorcethene
4.3.1
.216J
7
303
1,1-Dichlororoene
1,243-Thchiorobenzene
1,2,3-Trichlororoane
0.005
1,2,4-Trichlorobenzene
70
1,2,4-Trirneth (benzene
360
1,2-01bromo-3-Chk�rO ro ne
0,025
1,2-Olbromoethane
0,0004
1,2-Olchlorobenzene
24
12-01chloroethane
0,38
1,2-OichlO ra ane
0.51
1,35-Trimeth benzene
350
1,3-Oichlorobenzene
170
1,3-Dlchlora roane
1, 4-Dichlo robe nzene
1.4
2,2-❑ichloro rone
4-Isopropyltoluene
-
Benzene
1
Bromobanzene
Bromochicromethane
-
Bromodichl0romethana
6.56
Br0m0r0rrn
4.43
Bromomethane
Carbon Tetrachloride
0.269
Chlorobenzene
50
Chlaroethane
15.8
2,800
Chloroform
.640J
.360.1
.380J
70
289
0Oeho
2.6Gho
cs .2michanrothena
70
Dibromochloromethane
0.41
Dibromomethane
DichlorutiiFl u0 r0methane
1.400
Dii sop ropyt ether
70
Eth !benzene
550
Hexachiorobutadiene
0.44
Ise ropylbenzene
70
m.o,p-XyIerLe
530
Methylene Chloride
.1901
4.6
1930
Methyl tert-b 1 ether
200
Naphthalene
21
n-Bu !benzene
70
n-Propylberizene
70
c-Chlorotoluens
-
Chlorotoluene
Ise ro luene
secB benzene
70
Stymne
100
tert-ByIbenzena
70
Tetrachloroethene
0.7
Toluene
1.000
trans-1 ,2-eichicroethena
100
TrichEaroathene
2.0
Trichlorofluoromethane
2.100
Vinyl Chlonde
0.015
7Otal Vocs
0.640
0.360
0.380
153,4
3.34
0.38
TCA/Deq radation Products
-
-
2.53
4,34
1 -
Results in micrograms/liter (pg1L) or ppb
Remedial Investigation Tables
Page 3 of 4 Revision Date: 2/20/2007

PROPOSED REMEDIAL ACTION PLAN
SHALLOW BEDROCK AQUIFER (<80' BGS)
From
"REMEDIAL ACTION PLAN AND QUARTERLY STATUS REPORT — FOURTH
QUARTER 2008"
Prepared by
MACTEC Engineering and Consulting, Inc.
January 14, 2009

TABLE 10
SUMMARY OF MONITORING WELL ANALYTICAL RESULTS
NATURAL ATTENUATION PARAMETERS
WASTEWATER TREATMENT PLANT PROPERTY
ELKIN, NORTH CAROLINA
EBMW-6
. • EBMW-11
YEBMW-13
k EBMW-14
EBMW-16
'' EBMW-17
hEBMW-18
EBMW-19
s_.EBMVII-23
r1EBMW-24
{_, EBMW-25
:ESMW-26
',EBMW-27
r)EBMW-28
FPMW-5
COMPOUND
106/06
1015106 dup
10110/06
10l9l06
1 10l5106
1 D15I06
10/4106
101101D6
10/10/06
10110l06 dup
1019106
1019106
1019106
10/9106 dup
1015l06
1 Dl9106
1019106
1014106
Alkalinity m 1L
134
134
15
30
44
26
140
104
116
118
82
6
120
12D
72
40
6
100
Sulfide (MOIL)
SOL
BQL
BQL
SQL
BQL
BQL
BQL
SQL
BQL
BQL
SQL
BQL
BQL
BQL
BQL
BQL
SQL
BQL
TOC m 1L
9.5
10.4
2,6
16.1
12-4
2.6
9.3
124
2.1
2.1
1.9
3.2
4
4.1
2.4
3
3-7
13.2
Dissolved Or anic Carbon m !L
3A
7.3
1.4
4
4.4
1.8
8.7
54.8
SQL
BQL
1.2
1.6
3.2
3.2
0.9
1.4
2.5
7-6
Ferrous (W) Iron (m !L)
24.1
23.0
BQL
26.9
19.7
BQL
0,250
0.900
BQL
BQL
BQL
2-22
1,34
1.36
0.250
0.220
0.250
18.7
Ferric {Fe*3) Iron m 1L)
13.1
12.3
0,490
11.2
-
0.117
0.279
-
0.0509
0.0616
1.18
39.38
0.24
0.10
0.511
0-101
-
Chlodde m !L
14.5
3.8
17
59.9
10.1
7-2
6.7
268
1-7
2.4
26.4
26.7
3.4
3.4
5-5
25.4
10.8
6.7
Sulfate m 1L
13
14
50
51
5
13
31
32
11
11
84
77
6
7
11
76
47
55
CO2 (mglL)
163
176
79.2
268
128
176
8QL
8.8
8.8
8.8
BQL
136
BQL
BQL
BQL
83.6
185
92.4
Methane m IL
0.246
0.223
BQL
0.032
0.276
BQL
BQL
SQL
BQL
BQL
SQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
Ethane m 1L
BOL
BQL
BQL
BQL
BQL
SQL
BQL
0.032
BQL
BQL
SQL
BQL
BQL
BQL
BQL
BQL
BOL
BQL
Ethene m 1L
BQL
BQL
BQL
BQL
BQL
BQL
BQL
0.057
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
Hydrogen nM
1.00
6,400
8.70
1.30
9.90
1.50
N IS
4,200
2.30
4,400
120
2.50
1,700
940
6,700
170
3,50
1.60
Dissolved Oxygen m IL
1.10
-
0,75
1.40
1.18
1.80
1-54
0.45
1A8
-
1.61
2,97
0.83
-
4-39
1.67
1.66
2-84
H
5.89
-
5.60
5.04
5.96
4,78
9-51
8.46
8.61
-
9.97
7,93
8.75
9.84
6.02 1
4.82
5,78
ORP(mV)
-65.40
-
67
-84.1
41.7
99.5
-214
-171
-137-8
-
6.0
165.5
-0.2
-
-95.6
70.9
164-7
-41.3
Temperature °C
17,26
-
17.67
16,57
18,08
19.32
17.07
16.82
17-71
-
17.21
17,43
17-01
18.48
17,84
16.91
18.01
Turbidity (NVTU)
3.50
-
3.0
600
23
0.50
47.6
5-2
1-9
-
27
370
50
40
1.0
1.40
-
5peciflc Conductance (pSlcm)
395
-
209
456
190
102
305
1170
237
-
777
334
222
155
352
173
268
Notes:
Units as noted
DO, pH, DRP temperature, turbidity and specific conductance are field measurements
NS = Not Sampled
Remedial Investigation Tables
Page 1 of 2
Revision Date: 211912007

LOCATIONS OF CROSS SECTIONS
From
"REMEDIAL INVESTIGATION REPORT — CMI INDUSTRIES, WWTP"
Prepared by
TRIGON ENGINEERING CONSULTANTS, INC.
March 9, 2007

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
May 20, 2009
Andrew Clark
MACTEC Engineering and Consulting, Inc.
2801 Yorkmont Road, Suite 100
Charlotte, NC 28208
Ref: Additional Information Request
Injection Well Permit Application # W10400106
CMI Industries
Dear Mr. Clark:
Dee Freeman
Secretary
The Aquifer Protection Section received the referenced permit application on March 5, 2009. Additional
information is needed to complete the review of this application package. Please provide the requested
information or a response to the following items:
• Is geochemical data available for the most recent groundwater monitoring event? This
information is needed to evaluate geochemical conditions within and around the contaminant
plume.
■ Please submit a map of the locations of the proposed injection wells.
• Has contamination been detected in surface water samples of the Yadkin River?
• What does "projected" mean beneath the well labels on the cross-section maps?
• Site maps indicate the presence of a fly ash basin northwest of the proposed injection area. These
waste structures are known to impact groundwater in North Carolina and throughout the nation
with metals such as arsenic, selenium, thallium, boron, iron, and manganese. Has this waste
structure been evaluated for groundwater impacts? Have metals been detected in groundwater
related to this waste structure? If there is a contaminant plume emanating from this waste
structure, has it reached the chlorinated solvent plume that is the object of the proposed injection
operation? If yes, then what is the horizontal and vertical extent of the fly ash plume? These
questions are important because if metals are present in the chlorinated solvent plume then they
could become mobilized due to the decrease in redox potential and pH that is expected to result
from the proposed injection.
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North 0arohns 27699.1636
Location 2728 Capilal Boulevara. Raleigh. Nonti Carolina 27664
Phone [phone] i FAX [phone]: FAX 2i 919-715-6048 � Customer Service 1-87+7-623.6749
Intemet: www.ncwaterouarrN.om
an Equal �.ipaonunm Mrmaiive roan EM00ye'
NorthCaro ina
,NlMll 1111

You are requested to provide a response by June 20, 2009. If you need additional time, then please
propose a deadline by which you will be able to provide a response.
Please contact me at 919-715-6164 or thoinas.slusser[F[incdenr. og_v if you have any questions.
B6 V e2l� 9j.
est Regards,
Slusser, L.G.
Hydrogeoiogist
Groundwater Protection Unit
cc: Sherri Knight, Winston-Salem Regional Office
WI0400106 Permit File

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March IL 2009
James A. Ovenden
CMI Industries
219 Muirfteld Drive
Spartanburg, SC 29306
Subject: Acknowledgement of Application No. W10400106
CMI Waste Water Treatment Plant
Injection In situ Groundwater Remediation Well (5I)
Surry
Dear Mr. Ovenden:
Dee Freeman
Secretary
The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and
supporting materials on March S, 3009. This application package has been assigned the number listed above and will be reviewed by
Thomas Slusser.
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 Thomas Slusser at 919-715-6164. 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://h2o.enr.state.nc.us/documents/dwg or2chart.pdf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincer ..
V �
for Debra J. tts
q.
Supervisor
cc: Winston-Salem Regional Office, Aquifer Protection Section
Andrew M. Clark (MACTEC En,ineering & Consulting, Inc., 2801 Yorkmont Rd., Ste. 100, Charlotte, NC 281-08)
Permit Application File W 10400106
AQUIFER PROTECTION SECTION
1636 !Nail Service Center, Raleigh, North Carolina 27699.1636
Location. 2728 Capllal Boulevard, Raleigh. North Carvlrrna 27604
Phone; 919-733-3221 t FAX 1: 919-7154588. FAX 2 91r-715-6048 I Customer Service: 1-877-623-6746
Intemet: www.ncwatertivality-orb
An EQus) Opportunity i Affirmative Action Employer
NonrthCarolina
naturally

AQUIFER PROTECTION REGIONAL STAFF REPORT
f
Date: March 8, 2011 County: Surry m
To: A uifer Protection Central Office Permittee: CMI Industries
Central Office Reviewer: David Goodrich Project Name: CMI Waste Water Treatment Plant"
Regional Login No: Application No.: WI0400106 r►
L GENERAL INFORMATION
1. This application is (cheek an that apply): ❑ New ❑ Renewal
❑ Minor Modification ® Major Modification ❑ Modification b
❑ 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.
a. Date of site visit: March. 8.2011
b. Person contacted and contact information: Mark Filardi. MACTEC. 704-357-8600,
[e-mail]
c. Site visit conducted by: Shuying Wang, WSRO
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:
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
e. Regulated Activities 1 Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For Disposals and Injection Sites:
(If multiple sites either indicate which sites the information applies to, coon and paste a new section into the
document for each site or attach additional pages for each site
a. Location: 307 East Main Street, Elkin, NC (Almost abandoned CMI's waste water treatmentplan)
b. Driving Directions: I-40 West take exit 189 and mere onto US 421 N then take exit 265A onto I-77 N
toward Elkin, then take exit 82 for NC 67 toward E1kinlronesville1BoonviIle for 0.2 mi, then turn
left at NC 67_W for 1.7 mi, then turn left at Elm St for 0.2 mi, then turn right at W Main StIU.S.
21 Busk, and continue to follow U.S. 21 Bus (N. Bridge St.) for 0.4 mi: turn right at E Market St
0.2 mi: continue onto B Main St./Hwy 268 E., then exit and cross the railroad at 307 E Main St/Hwy 268
E., enter the gate of the abandoned waste water treatment plan to sio in. The site is several hundreds feet
southwest of the waste water treatment clan. outside of the waste water treatment plan.
c. USGS Quadrangle Map name and number: Elkin North, 36080-C7-TF-024
d. Latitude: 36.24395504 Longitude: 80.84247318
FORM: 20110310-W I0400106

AQUIFER PROTECTION REGIONAL STAFF REPORT
IV. INJECTION WELL PEIQMITAPPLICATIONS {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 (5I)
❑ Closed -loop groundwater remediation effluent injection (5U Non -Discharge")
❑ Other (Specify: �]
2. Does system use same well for water source and injection? ❑ Yes ® No
3. Are there any potential pollution sources that may affect injection? ® Yes ❑ No
What is/are the pollution source(s)? Fly ash basins
What is the distance of the injection well(s) from the pollution source(s)? about 150 feet
4. What is the minimum distance of proposed injection wells from the property boundary? About50 feet from
The Yadkin River
5. Quality of drainage at site: ❑ Good ❑ Adequate ® Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ® High
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: (1) additional monitoring well are needed between proposed injection points
and the Yadkin River and (2) metals and general chemisgy parameters including ferrous iron chloride, nitrate
nitrite, sulfate, sulfide, TGC, ethane, and alkalinity should be also monitored to monitor impacts of the
iniectants on groundwater and surface water quality.
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.
Infection 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 assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes, explain:
FORM: 201 I 0310-WI0400106 4

AQUIFER PROTECTION REGIONAL STAFF REPORT
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? -El Yes ❑ No. If yes, explain: Groundwater monitoring data of the proposed
injections will be needed to determine.
4. Drilling contractor, Name: Geologic Exl2loration
Address:
Certification number: 2854
5. Complete and attach Well Construction Data Sheet.
Not available in WSRO�please request from the applicant .
FORM: 201103 l 0-W I0400106 5

AQUIFER PROTECTION REGIONAL STAFF REPORT
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application:
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: Not really, but additional monitoring is necessary to monitor if the proposed injection is going to have
any impact on the Yadkin River refer to Section IV item 7).
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
Well construction records Not provided in the application
S. 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
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
1) Additional monitoring wells and
parameters are needed.
Z) Submit a copy of the project summary
report to WSRO
1) See Section IV Item 7.
2) For WSRO compliance evaluation
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:
1 � I
S. Signature of report preparer(s): '
Signature of APS regional supervisor:
K
4
Date:
FORM: 201103 l Q- W I0400106 6

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: February 24, 2011
To: ❑
Landon Davidson. ARO-APS
❑
Art Barnhardt, FRO-APS
❑
Andrew Pitner, MRO-APS
❑
Jay Zimmerman, RRO-APS
From: David Goodrich, Land Application Unit
Telephone: [phone]
E-Mail: david.aoodrich(amcdennszov
A. Permit Number: WI0400106
B. Owner: CMI Industries
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
X Sherri Knight, WSRO-APS
Fax: [phone]
C. Facility/Oeration: CMl Wastewater Treatment Plant 5I Injection GW Remediation Program
❑ Proposed X Existing X Facility X Operation
D. Application
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ VE Lagoon X GW Remediation (ND)5I
❑ UIC - (5A7) open loop geothermal
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2. Project Tjpe: ❑New X Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Statutory Date:
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
X Return a Completed APSARR Form. - Please comment
❑ Attach Well Construction Data Sheet.
❑ 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 request_-, 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 07/06 Page 1 of 1

Documents Associated with
the July 10,, 2009
CMI Industries
Injection Well Permit

AQUIFER PROTECTION REGIONAL STAFF REPORT
Date: 05/20/2009 County: Surry
To: A uifer Protection Central Office Permittee: CMI Industries
Central Office Reviewer: Thomas Slusser Project Name: CMI WWTP
Regional Login No: NIA Application No.: W10400106
L GENERAL INFORMATION
l . This application is (chuk all that apply): ® New ❑ Renewal
❑ Minor Modification ❑ Major Modification
Surface Irrigation ❑Reuse ❑Recycle ❑High Rate infiltration ❑ Evaporation/lnfiltration 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,
a. Date of site visit: None
b, Person contacted and contact information: NIA
c. Site visit conducted by: NIA
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the RIMS record for this application correct?
® Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Disposal and Insection Sites;
(if multiple sites either indicate which sites the information_ applies to, copy and: paste a new section into the
document for each site or attach additional pages for each site
a. Location(s): 304 East Main Street, Elkin
h. Driving Directions: Not visited
c. LISGS Quadrangle Map name and number: Unknown
d. Latitude: Longitude:
IL NEWAND MAJOR MOIIIFICATIONAPPLICATI.ONS (this section not needed for renewals or minor
modifications, skin to next section
NIA
III. RENEWAL AND MODIFICATIONAPPLICATIONS Luse revious section Lor new or major modi ecalion
s 'stems
NIA
W10400106 APRSR

AQUIFER PROTECTION REGIONAL STAFF REPORT
IV INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities —View, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
® In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (SU Non -Discharge")
❑ Other (Specify:
2. Does system use same well for water source and injection? ❑ Yes ® No
3. Are there any potential pollution sources that may affect injection? ® Yes ❑ No
4. What is/are the pollution source(s)? Fly Ash Basin. What is the distance of the injection well(s) from the
pollution source(s)? Unknown b/c map lacks scale and location of injection wells
What is the minimum distance of proposed injection wells from the property boundary? Unknown b/c man
lacks scale
5. Quality of drainage at site: ❑ Good ❑ Adequate ® Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ® High
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 & ® No,
Maps have no scales
Infection Well Permit Renewal And Modification Only: N/A
V. EVALUATIONAND RECOMMIENDATIQNS
1. Provide any additional narrative regarding your review of the application.:
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
Map scales A map is not complete without a scale,
W10400106_APRSR 2

11
AQUIFER PROTECTION REGIONAL STAFF REPORT
S. 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 NIA
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
None NIA
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:
a
S. Signature of report preparer(s):
Signature of APS regional supervisor:
Date: M iq
ADDITIONAL REGIONAL STAFFRE117EW ITEMS
The request of Thomas SIusser for additional information addresses alI Regional Office concerns except: Map
scales.
W10400106 APRSR 3

North Carolina Department o€Health and Human Services
Division of Public Health • Epidemiology Section
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone]
Michael F. Easley, Governor
January 17, 2007
MEMORANDUM
Carmen Hooker Odom, Secretary
TO: Qu Qi
Underground Injection Control Program
Aquifer Protection Section
s 1N
FROM: Luanne K. Williams, Pharm.D., Toxicologist
Medical Evaluation and Risk Assessment Un4
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of Non -Biological Product by Regenesis to Enhance Biodegradation
of Contaminated Groundwater
I am writing in response to a request for a health risk evaluation regarding the use
of a non -biological product by Regenesis to enhance biodegradation of contaminated
groundwater. Based upon my review of the information submitted, I offer the following
health risk evaluation:
Ingestion may result in burns to the lips, tongue, and mouth. Exposure to
the eyes can cause distortion of cellar membranes, loss of corneal,
conjunctival and lens epithelium and loss of endothelium of the cornea
and blood vessels. Inhalation may produce upper airway edema,
respiratory failure, wheezing, pulmonary edema, and pneumonitis. Skin
exposure may cause pain, redness, irritation and severe burns
(Micromedex TOMES Plus System CD-ROM Database, Volume 71,
2007).
If the products are released into the environment in a way that could result
C,' in a suspension of fine solid or liquid articles e. grinding, blending,
P 4 P � g•. � g. g,
vigorous shaking or mixing), then proper personal protective equipment
should be used. The application process should be reviewed by an
industrial Hygienist to ensure that the most appropriate personal protective
K equipment is used.
r'
CD 3. Persons working with this product should at least wear goggles or a face
shield, gloves, and protective clothing. Face and body protection should
Locauon. 5505 Six Forks Road, 2"Flenr, Room Di a Raleigh, N.C. 27609 An Equal Opportunity Employer

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
inunediately following application. Safety controls should be in place to
ensure that the check valve and the pressure delivery systems are working
properly.
The Material Safety Data Sheets should be followed to prevent adverse
reactions and injuries.
5. 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. Violent reactions or ignition could occur under the appropriate conditions
with acids, alcohols, p-bis (1, 3-dibromoethyl) benzene, cyclopentadiene,
germanium, hyponitrous acid, maleic anhydride, nitroalkanes, 2-
nit ophenol, potassium peroxodisulfate, sugars, 2, 2, 3, 3-
tetraf7uoropropanol, and thorium dicarbide. Measures should be taken to
prevent such reactions (Micromedex TOMES Plus System CD-ROM
Database, Volume 71, 2007).
8. Measures should be taken to prevent contamination of existing or future
wells and surface waters that may be located near the application area.
Please do not hesitate to call me if you have any questions at [phone].
J C'J
Z]
w
r~

w �D y �v inQ
Goodrich, David
From:
Filardi, Mark [[e-mail]
Sent:
Monday, May 09, 2011 12:33 PM
To:
Goodrich, David
Cc:
Wang, Shuying; Flanik, Michael
Subject:
Injection Status at CMI WWTP, Elking, NC
Hi Shuying and David:
The purpose of this e-mail is to provide notice that MACTEC plans to commence injection activities at the CM WWTP
site on Monday, May 16"`, as specified in our approved UIC permit application.
Please let me know if you have questions.
Regards,
Mark P. Filardi, P.G. I Senior Geologist
MACTEC Engineering and Consulting, Inc. I Charlotte, NC
Office [phone] ! Fax [phone]
Email mpfilardi(d)mactec.com I Web www.mactec.com