WI0400109_Application_20090417

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 Dl3f& WT_Q G4
nu 4Fr r -�q
I. GENERAL INFORMATION:
1. Applicant's Name (generally the responsible party): CMC Holding Corporation
2. Signing Official's Name: Alan Payne Title:
3. Mailing address of applicant: 285 Ivy Circle
City: Elkin
Telephone number: 336-835-1902
4. Property Owner's Name (if different from Applicant): NA
S. Property Owner's mailing address: CMC Holding Corporation
care of Alan Payne 285 Ivy Circle
City: Elkin
State: NC Zip:28621
Fax number:
State: NC Zip: 28621
6. Name and address of contact person who can answer questions about the proposed injection project:
Name: Tom Lennon
Company: Piedmont Industrial Services Inc.
Title: Project Manager
Address: 1670-A Lowery Street
City: Winston-Salem State: Zip:
Telephone number; 336-722-6505 Fax number: 722-6529
Email Address: [e-mail]
11. PERMIT INFORMATION:
1. Project is: g 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 modifications, rill out sections I & II only, sign the certification on the last page of this
form, and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
For all renewals, you must submit a status report including monitoring results of all injection activities to
date.
Revised 8/07 UIC-5115T Page I of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells — In Situ Groundwater Remediation 1 Type 5T Wells — Tracer Injection
�litC�Iowli;w-vYLyL1Iinvai 1!r1
A. FACILITY INFORMATION
1. Facility name. CMC Landfill
2. Complete physical address of the facility:
City: Elkin County: Surry State: NC Zip:
B. INCIDENT DESCRIPTION
1. Describe the source of the contamination:
The Site is currently listed on the North Carolina Department of Environment and Natural Resources, Division of
Waste Management, Inactive Hazardous Sites Branch (hereafter the NCDENR ) Inactive Hazardous Waste
Sites priority List as CIVIC Landfill ID #: NONCD0000016. This listing results from prior subsurface disposal of
material generated at the former Chatham Manufacturing Company. In January 2009, the NCDENR included the
site on the October 2008 Inactive Hazardous Waste Sites priority List with a score of 51.02 and a rank of 26.
2. List all contaminants present in soils or groundwater at the site (contaminants maybe listed in groups, e.g.,
gasoline, diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
See Table 1 for a list of contaminants.
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
❑ Yes If yes, list maximum measured separate phase thickness feet
9 No If no, list maximum concentration of total VOCs observed at site: 20,900 (MW-2s in 1992) ppb
4. Agency managing the contamination incident:
❑ UST Section Superfund Section (including REC Program and DSCA sites)
❑ DWQ Aquifer Protection Section ❑ Solid Waste Section
❑ Hazardous Waste Section © Other: DWM- Inactive Hazardous Sites
5. Incident managers name Cheryl Marks and phone number 919-508-8465
6. Incident number or other site number assigned by the agency managing the contamination incident:
NCDENR ID# NONGD0000016
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 Management program permits under RCRA: NA
2. DWQ Non -Discharge or NPDES permits: NA
3. County or DEH subsurface wastewater disposal permits: NA
4. Other environmental permits required by state or federal law: NA
Revised 8/07 UIC-5115T Page 2 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 51 Wells —In Situ Groundwater Rernediation / Type 5T Wells — Tracer Injection
IV. INJECTION DATA
A. 1N.IECTION 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 of approved injectantsT or contact the UIC Program to determine if
the injeclants you are proposing have been reviewed by OEES.
Injectant: HRC-A same as 3DME
Concentration at point of injection: 10: 1 Dilution
Injectant:
Concentration at point of injection:
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'1/4 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. LocationllD 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: !f contaminated groundwater is to be used as the dilution or chase. fluid, this is not the proper permit
application form. You must ripply for a closed -loop groundwater remediation permit using application form
GWRS
Revised 8/07 UIC-51/5T Page 3 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Rernedistion 1 Type 5T Wells — Tracer Injection
B. PROPOSED OPERATING PARAMETERS
1. Duration of Injection:
Maximum number of separate injection events: I
1 Composed of 112 direct pus borings
Expected duration of each injection event:14 working days
Expected duration between events (if more than one event):
2. Injection rate per well: 3-7 gallons per minute (gpm)
3. Total Injection volume:1635 gallons per day (gpd), 22895 gallons per event (if separate events)
4. Injection pressure:150-600 pounds/square inch (psi)
S. Temperature at point of injection: NA OF
6. Briefly describe how the above parameters will be measured and controlled:
Measure rate of fluid to be pumped from cube. Pressure will be monitored at pump.
7. Estimated hydraulic capacity of the well: NA -direct push cods gpm
C. INJECTION WELL CONSTRUCTION DATA
I. Injection will be via:
❑ Existing wells) proposed for use as an injection well. Provide the data in (2) through (6) below to the best of
your knowledge.
© 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: Tom Lennon
NC Well Contractor Certification number: 2837
3. Date to be constructed: June 2009 Number of borings: 112
Approximate depth of each boring (feet}: 25 ft• for borings on top of mound and 20 R. for badngs at base of mound
4. Screened intervalllnjection interval of injection wells:
Depth: 6 to 25 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: NA -direct push rods
Casing depth: to ft.
6. Grout (NIA if injection is through direct push rods):
Type: ❑ Cement ❑ Bentonite ® other: NA -direct push rods
Grout depth: to ft.
Revised 8/07 UIC-5I15T Page 4 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
Type 5I Wells —In Situ Groundwater Remediation 1 Type ST 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 and sealed by him or
her.
B. HYDROGEQLOGIC 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 shaIl include:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity' transmissivity, and specific yield of the aquifer to be used for injection, including a
description of the test(s) used to determine these parameters; and
(4) the depth to the mean seasonal high water table.
C. INJECTION FLUID COMPOSITION
Describe the chemical, physical, biological and radiological characteristics of each injectant. Attach the Material Safety
Data Sheet (MSDS) for each injectant. if a private well or a well within 14 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. 1NJECTION 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:
(I) 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 he located so as to detect any movement of h jection 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 8107 UIC-5115T Page 5 of 7

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELLS) FOR INJECTION
Type 51 Webs —In Situ Groundwater Remediation 1 Type 5T Wells — Tracer Injection
other electron acceptors and donors. The monitoring schedule should be consistent with the puce 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'/a mile of the injection well(s) which penetrate the
proposed injection zone, including, but not limited to, monitoring wells and wells proposed for use as injection wells.
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. ail buildings within the property boundary;
c. existing and proposed injection wells or well fields)
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. a]1 surface water bodies within'/4 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 -sections) 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 lithoiogy
RZCEIVED i DENR I DWO
AOUEI" PRnT=rT1f'-1 ^;rT10N
Revised 8/07 U1C-51/5T Page 6 of 7

Table 1: List of Contaminants
Hazardous Substance
Sol
Groundwater
Hazardous Substance
Soil
Groundwater
Surface Water
Sediment
1,1-Dichloraethane
x
Chloroethone
x
1,2-Dichloroethane
x
Chlorobenzane
x
1,l-Dichidreethen e
%
Carbon disulfide
x
1,2-Dichldroethens
9
Arsenic
x
x
Tetrochlvraethene
x
Chromium
x
x
><
1,1,1-Trichlaroethane
x
Mercury
x
Trichloroethene
x
X
1,1,2-trichioroethone
x
Methylene chloride
x
x
x
Ynyl Chlaride
x
Acetone
x
x
x
Anthrocene
x
Carbon tetrachloride
X
Fluoranthene
x
Toluene
x
x
Pyrene
x
2-Hexontlne
x
Benzo(o)anthracene
x
bis(2-0%VheA A)ph I holate
x
]i
x
x
Chrysene
x
Naphthalene
x
x
Seri zo(b) fl u or on t h en e
x
2-Methylnophthoiene
x
Benzn ❑ ene
x
Acenaphthylene
x
Indeno (1,2,3-cd)pyre�e
x
Acenapntisene
x
DOenzo(c,h)onthrmena
X
❑ibenzefuran
x
Benzo(g,h,i)perylefse
x
Fluorene
x
Butyl benxyl p"holote
x
Phenanthrene
x
11enza(a)anthrocene
x
1,3-DiChldrobenzene
x
Oi-n-octylphthalate
x
1,4-Dichlorobenzene
x
Benzene
x
1,2-Oichicrobenzene
x
Ethyl benzene
x
Barium
x
x
x
xylenes (totol)
x
Selenium
X
cis 1,2 Dichloroethene
x
Lead
%
x
Chloroform
x
tons 142-Dichluroethend
x
Isopro"banzane
x
1,2,4-Trimethylbanzene
X
Antimony
x
Codmium
x
Copper
x
Manganese
x
Nickel
x
Zinc
x
N-propylbenzene
x
Styrene
k

Attachment A

1. Site Usage- The subject property consists of approximately 27 acres of land located in the eastern
portion of the Town of Elkin, North Carolina The subject property (site) consists of two distinct
areas. The northwestern portion of the property consists of grassy fields used by the Town of Elkin
Parks and Recreation Division for baseball and soccer fields. Portions of the property to the south of
the ball fields were previously used for the surface and subsurface disposal of solid waste generated
from the Chatham Manufacturing Facility. The southern portion of the property is bounded by the
Yadkin River. The southern portions of the site, particularly along the river bank, are densely wooded
with thick underbrush. A large trash pile is present on the ground surface in the southwestern portion
of the site. A Chain Link fence has been erected around the pile to prevent users of the ball fields from
contacting the surface waste piles. The materials in the piles have been previously categorized as
containing primarily wood, concrete, tile, sheet metal ductwork, and empty rusted drums.
2. Origin of Contamination- Solid waste generated from the Chatham Manufacturing Company
Facility. The covered debris pile where remedial activities will be conducted in Area 43
encompasses an area of approximately 42,000 square feet and is predominantly covered by a small
trees and brush. Buried debris identified in the test pits with Area #3 consisted predominantly of
inert materials which were likely utilized at the former Chatham Manufacturing facility. The
following materials were observed in the test pits: fabric, yarn, yarn spools, wood, brick, concrete
block, metal bands and saw blades, plastic drum lids and containers, insulation, rubber hoses,
starter motors, glass bottles, and card board. In addition to the above, partial crushed drums
containing materials that appeared to be paint/dyes and/or adhesive sludge were observed in test
pits TP-3, TP-4 and TP-5. All of these test pits were located in the vicinity of monitoring well
MW4, which has historically indicated the highest levels of groundwater impacts. See Attachment
H for maps showing the location of monitoring wells and test pit locations.
3. Previous Remedial Actions- None

Attachment B

1. Regional Geologic Setting- The site is located in the Sauratown Mountain Anticlinorium, near
the western most extent of the Piedmont physiographic province of North Carolina. According to
the Geologic Map of North Carolina (NCGS, 1985), the site is located in the Sauratown Mountain
Anticlinorium adjacent to the Yadkin River_ Site soils include alluvial deposits of soils comprised
of varying degrees of sand, silt and clay.
2. Litholo ical Changes- The site is underlain by metamorphic rock types suspected to include
granitic gneiss, biotite gneiss and shist.There are generally two aquifers present within the
Piedmont region. These aquifer units are described in detail below.
Saprolite Aquifer - The saprolite aquifer is the uppermost aquifer across much of the region, but is
locally absent where the water table occurs below the top of bedrock. The thickness of the
saprolite aquifer is typically less than 50 feet, but may extend to more than 104 feet. The aquifer
matrix is composed of unconsolidated residual soil, saprolite, and partially weathered bedrock. The
saprolite aquifer zone includes the transition (partially weathered rock) zone just above competent
bedrock. The transition zone is generally characterized by enhanced permeability in the regional
piedmont aquifer system. Ground water flow through the aquifer is by advective movement of
ground water through pore spaces within the unconsolidated aquifer matrix. Moving downward to
the partially weathered rock zone, ground water flow becomes progressively more confined to
relict fractures and moves less through the porous media.
Bedrock Aquifer - The bedrock aquifer extends from the top of competent bedrock to depths where
ground water flow becomes limited due to the absence of open fractures. Ground water flow
within the bedrock aquifer is primarily through fractures in the bedrock and is strongly controlled
by subsurface geologic structures such as faults, fracture zones, and iithologic contacts. The base
of the bedrock aquifer generally extends to depths of approximately 250 to 700 feet.
The potentiometric surface of ground water in the saprolite aquifer is generally a subdued replica
of the topography. The shallow ground water generally discharges to streams and rivers. There is
generally limited downward flow of ground water into the underlying bedrock aquifer.
Groundwater at the subject site flows to the south towards the Yadkin River.
3. As seen in the attached Groundwater Contamination Assessment prepared by SEC Donohue, a
hydraulic conductivity value of 5.49 x 104 centimeters/second has been previously calculated at
the site. Piedmont Industrial has not conducted test to determine transmissivity and specific yield.
4. See attached Table 1 for water table measurnments,

03/26/2009 09: 02 91973-2 —1
_.. _... SUFERFUf�lD SEA, T -y
PAGE 02110
CMC Holding Corp.
Solid Waste Disposal Areas
SEC Donohue
October 1992
Purpose: Monitoring Wcll Installation and groundwater contamination assessment.
8 Monitoring wells installed in August 1992. 3 well pairs and 2shallow, gcneraily around area 3
and 4. Auger with split spoon sample and rock core (granitic gneiss, part of Cranberry gneiss).
ID
Total
Water
Rock
Depth
Depth
Depth
MW-1S
24.2
10.71
26.0
MW-11)
42.1
10.8
27.23
MW-2S
19.5
10.23
19.5
MW-2D
38.1
10.06
22.3
MW-3S
20.2
14,6
21.0
MW-3D
34.5
14.38
19.5
MW-4
19.5
9.0
19.5
MW-5
18.0
14.75
Sampling 9/21/1992
NNW-2S MW-2D
chloroethane 2600 ug/i carbon disulfide 5 ❑g/l
1,1 dichloroethane 4300
1,1 dichloroethene 2000
1,1,1 trichloroethane 12000
MW-3 S MW-3D
chloroethane 59 ugll 1,2 dichlorobenxene 53 ug/1
1,1 dichloroethane 7 1,4 dichlorobenzene 15
chloroethane 390
1,1 dichloroethane 100
MW-4
chloroethane 1900 ug/1
l ,1 dichlorocthene 460
MW-5
1,1 dichloroethane 13 ug/l

03/26/2009 09:02 91973� 1 SUPERFUND SEC"'-N PAGE 03/10
STATE ME
.No►�cD ctmo <D [ro
CMC HOLDING CORPORATION
SOLID WASTE DISPOSAL AREAS
ELKIN, NORTI4 CAROLINA
GROUNDWATER CONTAMINATION ASSESSMENT
PREPARED BY.
SEC DONOHUE
(FORMERLY SIRRINE ENYIRONWNI'AL CONSULTANTS)
3504-B REGENCY PARKWAY
may, NORTH CAROLINA 27511
SEC DONOHUE pROTECT No. R-2413
OC'TOBER 1992

03/26/2009 69:02 91973?•^,I
SUPERFUND SE[ ---,J
PAGE 04i30
�r
j:
CMC Holding Corporation
Elkin, North Carolina
SEC Donohue Project No. R-2413
IIe REGIONAL GEOLOGY & HYDROGEOLOGY �
A-eoLv�
The CMC Holding Corporation site is located in the Inner Piedmont physiograplaic
and geologic provinces. This area is characterized by gently rolling hills and wide valleys
and is generally well -drained. The structural geology of the Elkin area is complex. The
primary structural features in the region are northeast -southwest trending faults. These
structural features were probably formed as a result of Proterozoic and early Paleozoic
tectonism and, as such, are found throughout the region. 'ne Brevard Fault Zone is a
major structural, feature which represents a deep-rooted crustal sbear:(Horton & McConnell,
1991), The Brevard Fault Zone splays into at least three other faults in the vicinity of Elkin.
These three faults (Bowers Creek, Ridgeway, and Yadkin Faults) are also thought to
represent major crustal discontinuities. Minor faults parallel to the major faults are also
common in this area.
Rocks in the Inner Piedmont geologic belt are characterized as highly deformed and
metamorphosed Precambrian to Cambrian schists and gneisses, which are occasionally
interrupted by large and small-scale felsic and rnafic igneous intrusions. The Inner
Piedmont is interpreted by many geologists to represent an allochthonous (transported from
another area) terrane which may have originated from what is now western Africa (Horton
& 'McConnell, 1991). Rock types commonly found in this region are schists, gneWes,
amphibolites, and other metamorphic rocks. Quartzite veins and dikes are common in this
area and may be formed by primary felsic intrusions or as a result of secondary
mineralization along fractures and joints.
14/5/92 3 R92R2413.t4

03/26/2009 09:02 919733' l
SUPERFUND SEC' T" -4
PAGE ©5/So
CMC Bolding Corporation
Eltdn, North Carolina
SEC Donohue Project No. R-2413
S
Thick mdntles of residual soil are formed on top of bedrock in this area. This
residual soil is commonly referred to as saprolite. The thickness of saprolite is generally
between 20 and 50 feet in this region, but ranges from near zero in areas where erosional
forces have caused scouring to well over 100 feet on some hilltops.
In the vicinity of Elkin, aquifers exist within three basic geologic units, 'nese units
are, from shallowest to deepest, fluvial deposits, saprolite, and fractured bedrock. The
fluvial material, deposited by- rivers, -and the saprolite ' weathered froht bedrock, are
unconsolidated sediments. Collectively, these are referred to as overburden. The fluvial
deposits have the highest average hydraulic conductivity of these three units, followed by
saprolite, and then bedrock. However, becawse the fluvial deposits and saprolite axe
relatively thin, the bedrock aquifer is the most important in terms of economic usage in this
area.. local bydrogeology is discussed in more detail in Section V..
Precipitation provides the majority of recharge to the aquifers in the region. Allzial
and saprolite aquifers tend to be recharged directly by precipitation, and therefore,
commonly occur as water table aquifers. Bedrock aquifers can be recharged by infiltration
from surface water or by leakage from groundwater in the overlying saprolite or alluvium.
Groundwater in the Ellin region is not widely used because of the ready availability
of surface water. A moderate amount of agricultural activity takes place in the region, and
groundwater is used extensively for crop irrigation. The Town of Elkin supplies its
residential and commercial customers with treated surface water obtained from the Yadkin
River at a location upstream from the site.
�._..... _ . _... 10/5/92 4 R42R7413,004

03/26/2009 09:02
919 73: , —1
SUPERFUND SECT ,4
PAGE 06/10
CMC Folding Corporation
Edon, North Carolina
SEC Donohue Project No. R-2413
V. S'li'1"E HYDROGEOLOGY
WIN
The majority of the overburden in the vicinity of the site is a reddish brown to
yellowish brown silt (ML) with few to some fine to medium sand, trace to some clay, and
occasional mica Two types of overburden (unconsolidated deposits) are present at the site:
fluvial deposits and saprolite. Most of the overburden at the site was fluvial and was
deposited by the Yadkin Diver during flood episodes. Some of the overburden in the
northern portion of the site is likely to have been derived from weathering of the granitic
gneiss bedrock, The overburden derived from the bedrock (saprolite) is differentiated from
the fluvial deposits by the presence of relict rock textures and the lack of the horizontal
stratification typically found in the fluvial deposits. The drLIing did not encounter signi5cant
deposits of fine-grained material, such as silt oI clay that could retard the flow of
groundwater, at the interface between the unconsolidated deposits and the bedrock.
The bedrock beneath the site is a highly deformed granitic gneiss. This rock is
believed to be part of the Cranberry gneiss formation. The gneiss has a fairly typical
mineral assemblage' composed primarily of quartz and feldspar. There is a minor amount
of bictite (mica) and amphibole in the rock, which is responsible for producing its
characteristic banded appearance. The biotite and amphibole are dark minerals that tend
to concentrate together and elongate: parallel to the direction of shear stresses.
10/5/92 14 R92I 2413.0N

03/26120@13 09: 02 91973'^^* 1
SUPERFUND SE(,-, jy
PAGE 07110
CMC Holding Corporation
Elkin; North Caroliaa
SEC Donobue Project No. R-2413
Frequent fractures were observed in the rock cores recovered from the three deep
monitoring well.borings. Rock coring'runs in ail three borings had very low recovery rates
because of the high degree of fracturing. Logs of the rock cores are provided in Appendix
F. Most of the fractures noted in, the rock cores were parallel to the foliation planes. The
foliation planes in the rock cores ranged from about 74 degrees from horizontal to about
30 degrees from horizontal. Fractures at high angles to the foliation planes were
occasionally identified. Some secondary mineralization, mostly iron oxide (limonite), was
present on many of the fractures in the rock cores. The secondary mineralization is an
indication that groundwater dogs tbrough these fractures, and that the fractures are fairly
extensive.
Water level measurements were obtained from all wells during groundwater sampling.
The elevation of the water table was determined by subtracting the depth to the water
surface from the elevation of the top of casing in each well. The borizontal location and
elevation of each well casing was determined by Foothills Forestry & Surveying. The
vertical elevations established at each well are referenced to the National Geodetic 'vertical
Datum established in 1929. An indelible mark was made on each well casing where the
elevation was determined. This mark was used as the reference point to determine the
depth to the water in each well. Table 7 is a summary of the water level data, and
elevations obtained during this investigation.
Two aquifers are identified at the site; a shallow (water table) aquifer, and a. deep
(bedrock) aquifer. For the purposes of discussion, these aquifers are described as separate
hydrogeologic units.' However, there is no discernible confining layer which would restrict
10/5/92 15 R92RIA13.004

e3r26r2e]tg e9: @2 91973-7iA01 1
SUPERF'UND SE-- "
PAGE earl �t
CMC Holding Corporation
Elkin, North Carolina
SEC Donobue Project No. R-2413
or prevent the flow of subsurface fluids between the overburden and the bedrock. The two
units are discussed as separate aquifers because they are composed of two distinct geologic
media Growadwater flows primarily through pore spaces between grains of sediment in the
overburden deposits, and groundwater flows almost exclusively through fractures in the
bedrock
Figure 3 is a contour map of the water table aquifer based on water level
measurements- obtained from the shallow wells during this investigation. The direction of
flow for the water table aquifer is shown as an arrow on Figure 3, and is generally to she
south. The horizontal hydraulic gradient of the water table is appxoaaffiately 4.016.
The elevations of the groundwater in the deep monitoring wells were not used to
construct the water table contour neap because these wells are screened in a different
geologic medium. However, there was virtually no difference between the groundwater
elevations in the shallow and deep well pairs, There is a slight downward vertical hydraulic
gradient (0.43 feet) between the shallow and deep well in the MW-1 well cluster. In the
MW-2 well cluster, there is a moderate (4.29 foot) upward hydraulic gradient. In the MW-3
well cluster, there is a slight (0.05 foot) upward gradient. The vertical, hydraulic gradients
indicate that groundwater flows from areas of higher elevation into the Yadldn, River, where
both the shallow and bedrock aquifers discharge.
10/5/92 16 R92R2413.004

03/26/2009 09:02 91973?"°11 SLIPERFUND SEr-".N PAGE 09/11j
CMC i-joldin.g Corporation
Ellda, North Carolina
SEC Donohue Project No. R-24
13
values of the saprolite obtained
The arithmetic average of the hydraulic conductivity value is
second. 1'hi.s
from the field hydraulic conductivity testy is 5.49 x 1�` centimeters) teed to
frdeposits as they
fakl typical for a granitic saprolite, but is relatively low for Au`' 9aue of 5.49 x 10"
Y A hydraulic conductnnty
have a high percentage of said.
o �e trea5onablg far the average hydraulic conductivity .of e
centimeters/second vppears
averburdcn and the bedrock aquifers.
10/5 j92
17
R92R2413.004

03/26/2009 09:02 9197214-�j
SUPERFUM) 5E"TT-JN
PAGE 1o/10
TABLE I
NVELL CONSTRUCTION SUMMARY
CMC HOLDING CORPORATION
GROUNDWATER ASSESSMENT
WELL NUMSER
DEPTH OF B0770 I
OF SURFACE CASING
[
TOTAL DEFT
OF BORING (EM
SCREEN
INTERVAL
(FT)
MW-ID
27.28
42.1
31.5-41.8
MW-1 S
--
24.2
11.8-22-2
MW-2D
22.30
38.1
27.7-38.0
MW-2S
19.5
8.6-79.0
Mai-3I]
19.60
34.5
24.2-34.5 -
MW-3S
-
20.2
9.4-20.0
MW4
--
19.5
8.7-19.0
MW 5
__
18.0
8.a-18.0
-- Indicates surface casing not installed (shallow monitoring well).
10/5j92
R92R2413.00

TABLE 1: Historical Summary of Groundwater Gauging Data
DATE
WELL
I❑
CASING
ELEV-
DEPTH TO
WATER
(FT}
TOTAL DEPTH
OF WELL
[FT]
WATER TABLE
ELEV-
(FT)
SCREENED
INTERVAL
(FT)
02/08/05
MW-1s
895.70
11.11
24-50
884-59
11.8.22.2
02/07/07
MW-1s
895.70
12-19
24.50
883.51
11.8-22.2
02/08/05
MW-1 D
895.76
11-25
42.10
884.51
31.5-41 A
02/07/07
MW-1 D
895.76
12.32
42.10
883.44
31-5-41.8
02/08/05
MW-2s
887.49
6.6g
19.50
880.80
8.6-19.0
01/31/07
MW-2s
887.49
7.14
19.50
880.35
8-6-19.0
04/06/07
MW-2s
887.49
6.95
19.50
880.54
8.6.19.0
12/15/08
MW-2s
887.49
15.11
19.50
872.38
8.fi 19.0
02108M6
MW-21D
887.61
7A0
38.10
880.51
27.7-38.0
02J07107
MW-2Q
887.61
7.85
38.10
879.76
27.7-38.0
12/15/08
MW-21D
887,61
14.05
38.10
873.56
27.7-38.0
02/09/05
MW-3s
882.45
14.11
2020
868.34
9.4-20.0
02J07107
MW-3s
882.45
15.72
20.20
866.73
9-4-20.0
D4106/07
MW-3s
882.45
15.9
20.20
866.55
9.4-20.0
02/09105
MW-3D
882.28
13-98
34-50
868.30
24.2-34.5
02107/07
MW-3D
882.28
14.49
34.50
867.79
24.2-34.5
04106/07
MW-31D
882.28
14.4
34.50
867-88
24.2-34.5
02/09/05
MW-4
886,58
6,20
19-50
880.38
8.7-19.0
01/31/07
MW-4
886.58
6.58
19.50
880-00
8.7-19.0
04106/07
MW-4
886.58
7.85
19.50
878-73
8.7-19.0
12/15/08
MW-4
886.58
--12.29
19.50
874.29
8.749.0
02/08/05
MW-5
882.60
14.05
18
868.55
8-0-18.0
02/08/07
MW-5
882.60
15
18
867.60
8-0-1 &0
04/06/07
MW-5
882,60
14-93
18
867-67
8-018.0
02/09/06
MW-6
880.81
11.35
17.35
869.46
6.0.16,0
02/07/07
MW-6
880.81
11-6
17-35
869.21
6.0-16.0
04106/07
MW-6
880.81
11.55
17.35
869.26
6-0-10.0
12/16/08
MW-6
880.81
13-07
17.35
867.74
6-0-16.0
02/09/05
MW-7
883.82
14.58
20.36
869-24
8.0-18.0
(12107107
MW-7
883.82
14-98
20.36
868.84
8.0-18.0
04106)07
MW-7
883.82
14-9
20.36
868-92
8.0-18.0
17J15/08
MW-7
883.82
16
20.36
867.82
8.0-1&0
02109M5
MW-8
883.75
14.20
19-6
869.55
3.0-18.0
02/07107
MW-8
883.75
14.20
19.6
869.55
3.0-1&0
04/05/07
MW-8
883.75
14.40
19.6
869-35
3.0-18.0
12/15/08
MW-8
883.75
15.22
19.6
868-53
3.0-1&0
02109/05
MW-9
882.90
13.38
19.58
869.52
3.0-18.0
02107/07
MW-9
882.90
13-69
19.58
869-21
3.0-18.0
04/06/07
MW-9
882.90
14.05
19.58
868.85
3-0-18.0
12/15/08
MW-9
882.90
14-27
19.58
868.63
3.0-18A
02J10105
MW-10
887.44
16.84
22.55
870.60
5.0-20-0
1008M7
MW-10
887.44
Dry
22.55
Dry
5.0-20,0
04106/07
MW-10
887.44
17.2
22.55
870.24
5.D-20.0
02/10/05
MW-11
884.03
14.54
18.75
869.49
7.0-17.0
02/08/07
MW-11
884.03
15.2
1835
868.83
7.0-17.0
D4106107
MW-11
884.03
14.82
18.75
069.21
7.0-17.0
02110/05
MW-12
887.33
17.13
23
870.20
6.0-21.0
02/08/07
MW-12
887-33
Dry
23
Dry
6.0.21.0
04/06/07
MW-12
887.33
Dry
23
Dry
6.0-21.0
02/10/05
MW-13
884-74
11.96
19.75
872-78
8.0-18.0
02/08/07
M W-13
884.74
11.8
19.75
672.94
8.0.18.0
D4106107
MW-13
884.74
11.87
19.75
872.87
8.0-18.0
02/10/05
MW 14
884-68
13,62
20A0
971.06
6.6-18.0
07/08/07
MW-14
884.68
13-85
20.10
870-83
8.0-1&0
04/06/07
MW-14
884.68
13.82
20.10
670.86
8.0-18.0
04/06/07
MW-15
884.32
12.15
20
872.17
10.0-20.0
04/05/07
M W-16
886.50
6.65
17.7
879.85
1 Y.7-17.7
12J15/08
MW-16
886.50
13.03
17.7
873.47
123-17.7
04/05/07
MW-17
888-97
8.87
14-6
880.10
9.6-14.6
1211W08
MW-17
888.97
Dry
14.6
Dry
9.6-14.6
04105/07
MW-18
865-24
8
16.4
877.24
11.4-16.4
12/15/08
MW-18
885.24
Dry
16.4
Dry
11.4-16.4
04/05/07
MW-19
886-74
6-82
18
879.92
13.0-18.0
12/15/08
MW-19
886.74
11.76
18 -
874.98
13.0-18.0
Mean= 872.86

Attachment D

1. Injection Rationale- The chemical injection of the 3 D Microemulsion, consisting of HRC-A and
water, will be injected via a GeoProbe into approximately 20 injection points inside of the excavated
area to treat the hot spot. An additional 100 injection points outside of the excavated area will further
remediate the groundwater plume in the immediate vicinity of the soil source area. HRC-A produces a
sequential staged release of its electron donor components. The immediately available free lactic acid
is fermented rapidly while the control -release lactic acid is metabolized at a more controlled, more
gradual rate. The fatty acids are converted to hydrogen over a mid to long range timeline giving HRC-
A an exceptionally long electron donor release profile. This staged fermentation provides an
immediate, mid -range and very long term., controlled -release supply of hydrogen to fuel the reductive
dechlorination process which will remove chlorinated solvent -type contaminants in the groundwater
plume. Typical longevity is rated up to 2 years on a single injection and up to 5 years under optimal
conditions.
2. See attached Regenesis Technical Bulletins 1.0 and 2.0.
3. See attached Regenesis Technical Bulletin 3.0.

Attachment E

1. Construction Plans and Materials- Chemical Injection of HRC-A in Excavation: A total of
twenty injection points was proposed for installation within the injection area. The proposed injection
interval ranged from 15 to 21 feet below surface grade (BSG). A cross -sectional diagram depicting
the injection boring interval and excavation area is presented in Figure 2. As a result of variations in
surface topography and fluctuating water table elevations, a change in the injection interval is
proposed to accommodate treatment of the basal portion of the unconsolidated aquifer. Following
discussions with Mr. Drew Baird, with Regenesis, this will require extending the injection interval an
additional four feet BGS. The newly proposed injection interval will range from 15-25 feet SSG. To
more accurately accommodate the off -set 15 ft x 15 ft grid pattern the total number of injection points
has been reduced to a total of 18 points. As a result the mix has changed to 170 gallons of the
Microemulsion per each injection point. The aerial locations of the proposed 18 injection borings are
depicted in black on Figure 1. The volume of the area to be treated beneath the excavation is
approximately 37,500 cubic feet.
Chemical Injection of HRC-A for Plume: Outside Excavation A total of 100 injection points was
proposed for installation outside the injection area. To more accurately accommodate the off -set 15 ft
x 20 R grid pattern the total number of injection points has been reduced to a total of 94 points. The
proposed injection interval initially ranged from 7 to 21 below surface grade (BSG). As a result of
variations in surface topography and fluctuating water table elevations, a change in the injection
interval is proposed to accommodate treatment of the basal portion of the shallow aquifer. The newly
proposed injection interval for injection points located on the top of the waste pile will be from 11-25.
The newly proposed injection interval for injection points at the base on the waste pile will be from 6
to 20 feet below surface grade. A cross -sectional diagram depicting the newly proposed injection
intervals is presented in Figure 2, As indicated, the total number of injection points has been reduced
to 94 points. The aerial locations of the proposed 94 injection borings are depicted in figure 1. As seen
in Figure 1, a total of55 borings (depicted in red) will be installed and injected with a 11-25 foot
injection interval and a total of 39 borings (depicted in blue) will be installed and injected with a 6-20
foot injection interval. As a result in the reduction of boring locations the total amount of injected
material has change to 211 gallons per point. Prior to injection activities, the approximate injection
borings locations will be located on the ground surface. A tripod and level will be utilized to make
any minor adjustments to the injection interval caused by topographic relief. In addition, borings will
be periodically installed in various areas to collect macrocore samples in order to make any minor
necessary adjustment to the injection intervals to insure injection into the lower 14 feet of the
unconsolidated aquifer. The volume of the area to be treated beneath the plume area is approximately
367,500 cubic feet. Any final minor adjustments to the number of borings and/or injection interval
will be discussed with the NCDENR prior to injection implementation.
Injection point location maps are contained in Attachment E and H.
2. See attached regenesis installation instructions.
3. See Attached Diagram
4. The estimated injection rate is 5 GPM for the 112 Injection points. Therefore, it will take
approximately 14 days to complete the injection activities.

1 lid
* �J
HRC ADVANCED
REGENESIS
Advine.ed 1"hnolcgias far Groundwater A"o"rcrs
3-D Microemulsion (3DMe)TM
INSTALLATION INSTRUCTIONS
High -Volume, Wide -Area, Microemulsion Application
Introduction
3-D Microemulsion (3DMe)r" formerly known as HRC Advanced should ONLY be applied as
a high -volume, microemulsion. In this form it offers greater physical distribution of the 3DMe
material across a larger potential radius from a single injection point. The production of a 3DMe
emulsion involves the on -site, volumetric mixing of 10 parts water with I part delivered 3DMe
concentrate to form the injection -ready 3DMe microemulsion. This microemulsion suspension
can then be injected directly or further diluted to a predetermined ratio of 3DMe to water. The
following instructions provide details in the production and installation of 3DMe.
Material Overview Handling and Safety
3DMe concentrate is shipped and delivered in 4.25-gallon buckets. Each bucket has a gross
weight of approximately 32 pounds. Each bucket contains 30 pounds of 3DMe concentrate (net
weight) and a nominal volume of 3.7 gallons. At room temperature, 3DMe concentrate is a
liquid material with a viscosity of approximately 500 centipoise, roughly the equivalent of
pancake syrup. The viscosity of 3DMe is not temperature sensitive above 50 °F (10 'Q.
However, below 50 °F the viscosity may increase significantly. If the user plans to apply the
product in cold weather, consideration should be given to heating the material to above 60 °F so
that it can be easily handled. 3DMe concentrate should be stored in a warm, dry place that is
protected from direct sunlight. It is common for stored 3DMe concentrate to settle somewhat in
the bucket, a quick pre -mix stir by a hand held drill with a paint or "jiffy mixer" attachment will
rapidly re -homogenize the material. 3DMe concentrate is non -toxic, however field personnel
should take precautions while handling and applying the material. Field personnel should use
appropriate personal protection equipment (PPE) including eye protection. GIoves should be
used as appropriate based on the exposure duration and field conditions. A Material Safety Data
Sheet is provided with each shipment. Personnel who operate field equipment during the
installation process should have appropriate training, supervision, and experience and should
review the MSDS prior to site operations.
Regenesis 1 1011 Calle Sombra 1 San Clemente 1 CA 1926731949-366-80001 www.regenesis.com
3DMe Install lnslrttrl+ons. Updated040607 CS

3-❑ MICROEMULSION APPLICATION INSTRUCTIONS (cont)
Microemulsion Production 3DMe to Water Ratio
3DMe concentrate should be mixed with water on a volume to volume (vlv) basis to produce a
microemulsion starting at 10 parts water: 1 part 3DMe. Although microemulsions can be easily
produced using greater water volumes than 10 parts, e.g. 20 to 50 parts water to 1 part 3DMe, the
initial microemulsion should never be produced below a ratio of less than 10 parts water: 1 part
3DMe vlv. WARNING: Do not attempt to produce a microemulsion at less than 10 parts
water to I part 3DMe ratio vlv. This will produce an undesirable and unstable solution.
The field production of 3DMe microemulsion is a very simple procedure; however, it is critical
that the user follow the mixing directions outlined below.
***IMPORTANT - NEVER ATTEMPT TO ADD WATER TO THE 3DME
CONCENTRATE AS THIS WILL PRODUCE AN UNDESIRABLE AND UNSTABLE
EMULSION. ALWAYS ADD 3DME CONCENTRATE TO A LARGE VOLUME OF
WATER***.
As indicated previously the 10:1 ratio of water to 3DMe vlv is the minimum water ratio that can
be used, a greater ratio (more dilute solution ) can easily be achieved and is governed by: A) the
volume of 3DMe required to treat the estimated contaminant mass, B) the pore volume in which
the material is applied, C) the time available for installation (gallons/pump rate), and C) the
estimated volume of 3DMe microemulsion that•the target zone will accept over the time period
allocated for installation.
Conceptually, although a higher volume of water to volume of 3DMe will produce a larger
volume of the suspension, it will lower the concentration of 3DMe per gallon of solution. Thus,
the benefit of using a high water/3DMe vlv ratio in order to affect a greater pore volume of the
subsurface aquifer is offset by the dilution of the 3DMe per unit volume of suspension as well as
by the limitations of the subsurface hydraulic conductivity and effective porosity (capacity of the
aquifer to accept the volume of 3DMe microemulsion).
It is important that the user plan in advance the vlv 3DMe/water ratio to be employed at a project
site. The resulting volume of solution will dictate the site water requirements and the time
required for injection, etc. If upon injection of greater than 10:1 3DMe microemulsion, the
subsurface does not readily accept the volume of solution as designed, the user can adjust
downward the vlv water to 3DMe ratio until a more concentrated suspension is produced (this
solution should never drop below the required 10 parts water:I part 3DMe vlv production ratio).
For more information on designing a 3DMe/water ratios to meet specific site conditions, please
contact Regenesis Technical Services.
Direct -Push Application Requirements
One of the best methods to deliver the 3DMe microemulsion into the subsurface is to pressure
inject the solution through direct -push rods using hydraulic equipment, or to pressure
inject/gravity feed the microemulsion into the dedicated injection wells. The use of low-cost
push points or temporary injection points allows the applier to more cost effectively distribute
Regenesis 1 1011 Cal le Sombra 1 San Clemente 1 CA 1926731949-366-8440 / www.re enesis.com
3DASe Install Instructions, Updated 040607 C5
(Page 2)

3-D MICROEMULSION APPLICATION INSTRUCTIONS (cont)
the 3DMe material across shallow sites by employing multiple points per site. In the case of
treating deep aquifer sites, the use of the microemulsion applied via dedicated injection wells is
likely to be the most cost-effective remediation approach. Please note that this set of instructions
is specific to direct -push equipment. Please contact Regenesis Technical Services to assist you
with dedicated injection well applications.
In general, Regenesis strongly recommends application of the 3DMe microemulsion using an
injection pump with a minimum delivery rate of three gallons per minute (gpm) and a pressure
rating of between 150 to 200 pounds per square inch (psi). Note: the infection numb
requirements are different than the requirements of the mixing- um (see Mixing to
Generate 3DMe Microemulsion). High pressure, positive displacement pumps and progressive
cavity pumps are appropriate for injecting 3DMe. For low permeability lithologies (clay, silt)
higher pressure pumps (800-1600 psi) may be necessary, while for more permeable lithologies
(gravel, sand) a lower pressure pump may be adequate. Examples of appropriate pumps are:
Rupe Models 6-2200, 9-1500 and 9-1600 (positive displacement), Geoprobe'P' GS-2000 (positive
displacement) and DP-800 (progressive cavity), Yamada (air diaphragm), Moyno (progressive
cavity), and Wilden (air diaphragm). Delivery rate is a critical factor in managing installation
time and costs. Generally, higher delivery rates (>6 gpm) are more cost effective for these types
of applications but pump selection should be on a site specific basis and account for the volume
of 3DMe solution and specific aquifer conditions present at the site.
The installation of the 3DMe microemulsion should span the entire vertical contaminated
saturated thickness. If the vertical extent of the application is confined to a limited interval, then
the microemulsion should be placed across a vertical zone extending a minimum of one -foot
above and one -foot below the screened interval of monitoring wells that are being used to
evaluate the performance of the project.
Producing the 3DMe Microemulsion
The application of 3DMe requires the creation of a microemulsion. Technically the optimal
suspension is a 3DMe-in-water suspension containing microemulsions. Before beginning the
mixing procedure the user should have in mind the desired water to 3DMe ratio vlv desired.
It is critical that the microemulsion be produced using a high -shear apparatus such as a
high speed centrifugal pump. The shearing provided by the vanes in these types of pumps is
sufficient to form and maintain a homogeneous milky emulsion. This Dump will be a different
Dump than that used to infect the 3DMe microemulsion into the subsurface. If the user is
uncertain as to requirements for the pump or the applicability of a certain pump, please contact
Regenesis Technical Services. Regenesis typically suggests using a water trailer/pump
apparatus commonly found at equipment rental facilities. Regenesis recommends using a
Magnum Products LLC model MWT500 or equivalent water trailer (fitted with centrifugal
recirculation pump). This "trash pump" or transfer pump is an ideal high shear pump and the
water tank (400 gallons) serves as an excellent mixing tank.
Regenesis 1 1 al l Calle Sombra I San Clemente 1 CA 1926731949-366-80001 www.regenesis.com
3DMe Install Instructions, Updated 040607 C5
(Page 3)

3-❑ MICROEMULSION APPLICATION INSTRUCTIONS (cant)
To ensure that -proper microemulsion suspension is generated Regenesis suggests a two-step
process that simply re uires mixing at least 10 narts water to 1 part 3DMe concentrate usin
water at a temperature > 601.
Step 1) Regenesis recommends that the
homogenized using a drill equipped with a
settling may have occurred during shipment.
3DMe concentrate in each bucket be re-
paint or "jiffy" mixer attachment as minor
Step 2) to calculate the volume of water necessary to produce a 10:1 vlv microemulsion,
each bucket of 3DMe concentrate containing 3.7 gallons of material should be mixed
with 37 gallons of water.
Example: 6 buckets x 3.7 gallons 3DMe concentrate/bucket yields a total of 22.2 gallons of
3DMe concentrate. Thus, a 10:1 vlv solution will require 222 gallons of water (22.2 gallons
3DMe concentrate x 10 gallons water yields 222 gallons of water). A nominal total volume
microemulsion would result from the summation of the 3DMe concentrate volume (22.2 gallons)
and the water volume (222 gallons). This yields a total fluids delivery volume of approximately
244 gallons.
The previously calculated water volume (222 gallons) should be transferred into an appropriately
sized mixing tank. The water should be circulated by the high shear centrifugal pump and each
of the six 3DMe buckets slowly poured into the tank. Each bucket of 3DMe concentrate should
be poured at a slow rate (approx. 1 minute per bucket and the contents of the tank continually
recirculated using the high hear centrifugal pump. A period of 1-2 minutes should be allowed
between addition of each subsequent bucket of 3DMe concentrate to allow the centrifugal pump
to continue to shear and mix the water/3DMe concentrate. Upon addition of the entire volume of
3DMe concentrate the pump should remain on to allow the solution mixture to recirulate. The
recirculation of the 3DMe microemulsion should continue until the material is injected to
maintain microemulsion consistency.
Application of Microemulsion Using Direct -Push Methods
1) Prior to the installation of the microemulsion, any surface or overhead impediments should
be identified as well as the location of all underground structures. Underground structures
include but are not limited to: utility lines, tanks, distribution piping, sewers, drains, and
landscape irrigation systems.
2) The planned installation locations should be adjusted to account for all impediments and
obstacles.
3) Pre -mark the installation locations, noting any points that may have different vertical
application requirements or total depth.
4) Set up the direct -push unit over each specific point and follow the manufacturer's standard
operating procedures (SOP). Care should be taken to assure that probe holes remain vertical.
Regenesis 1 1011 Calle 5ombra I San Clemente 1 CA 192673 1949-366-80001 www.mgenesis.com
3DMe Install Instructions. Updated 040607 C5
(Page 4)

3.D MICROEMULSION APPLICATION INSTRUCTIONS (cant)
5) For most applications, Regenesis suggests using drive rods with an D.D. of at least 1.25-
inches and an I.D. of at least 0.625-inches LD (Geoprobe or equivalent). However, the
lithologic conditions at some sites may warrant the use of larger 2.125-inch D.D./1.5-inch
I.D. drive rods.
6) The most typical type of sub -assembly currently being used is designed for 1.25-inch direct -
push rods and is manufactured by Geoprobe. Other brands of drive rods can also be used but
require the fabrication of a sub -assembly that allows for a connection between the pump and
drive rod.
7) For mixing large volumes of the microemulsion, Regenesis recommends using a Magnum
Products LLC model MWT500 water trailer (fitted with centrifugal recirculation pump) or
equivalent unit. However, single large volume poly tanks are adequate. We suggest filling the
tank with an appropriate quantity (e.g. from the example above 222 gallons) of water before
start of mixing operations. The tank should be configured so that both a hose and a fire
hydrant or larger water tank can be connected to it simultaneously and filled with water
quickly and easily. This will dramatically reduce the time needed to fill the tank with mixing
water.
8) Regenesis highly recommends preparing the microemulsion before pushing any drive rods
into the subsurface. NOTE: it is best if the micro -emulsion is produced a single day
application volumes.
9) After the microemulsion mixing/shearing step has been completed as described above, the
microemulsion is ready to be applied. Check to see if a hose has already been attached to the
inlet side of the centrifugal pump. If this has not been done, do so now.
10)1f a non -water trailer tank is being used for mixing the microemulsion a stand alone
centrifugal pump and hose system should be used for the shearing: and mixing operations.
11) Advance drive rods through the ground surface, as necessary, following SOP.
12) Push the drive rod assembly with an expendable tip to the desired maximum depth.
Regenesis suggests pre -counting the number of drive rods needed to reach depth prior to
starting injection activities to avoid any miscalculations.
13) After the drive rods have been pushed to the desired depth, the rod assembly should be
withdrawn three to six inches. The expendable tip can be dropped from the drive rods,
following SOP.
14) If an injection tool is used instead of a direct -push rod with an expendable tip, the application
of material can take place without any preliminary withdrawal of the rods.
15) In some cases, introduction of a large column of air may be problematic. This is particularly
the case in deep injections (>50 ft) with large diameter rods (>I.5-inch O.D.). To prevent the
injection of air into the aquifer during the application, fill the drive rods with 3DMe emulsion
Regenesis 11011 Calle 5ombra 1 San Clemente 1 CA 1926731949-366-80001 www.reizenesis.com
3DMe Instal! Insmictrons, Updated 040607 C5
(Page 5)

3-17 MICROEMULSION APPLICATION INSTRUCTIONS (cont)
after they have been pushed to the desired depth and before the disposable tip has been
dropped or before the injection tip is operational.
16) Transfer the appropriate quantity of the microemulsion from the water trailer to the
working/application pump hopper or associated holding tank.
17) A volume check should be performed prior to the injection of the microemulsion.
Determining the volume discharged per unit time/stroke using a graduated bucket and
stopwatch or stroke counter.
18) Start the pump and use the graduated bucket to determine how many gallons of
microemulsion are delivered each minute or stroke per unit volume.
19) Connect the 1.25-inch ❑.D., 1-inch I.D. delivery hose to the pump outlet and the appropriate
sub -assembly. Circulate the microemulsion through the hose and the sub -assembly to
displace any air present in the system.
20) Connect the sub -assembly to the drive rod. After confirming that all of the connections are
secure, pump the microemulsion through the delivery system to displace any water or other
fluids in the rods.
21) The pump engine RPM and hydraulic settings should remain constant throughout the day to
maintain a constant discharge rate.
22) The material is now ready to be installed in the subsurface. Use the pumps discharge rate as
calculated in step 18 to determine the withdrawal rate of the drive rods needed for the
application.
23) Slowly withdraw the drive rods using Geoprobe Rod Grip or Pull Plate Assembly (Part
AT1222-For 1.25-inch drive rods). While slowly withdrawing single lengths of drive rod
(three or four feet), pump the pre -determined volume of microemulsion into the aquifer
across the desired treatment interval.
24) Remove one or two sections of the drive rod at a time. The drive rod may contain some
residual material so Regenesis suggests placing it in a clean, empty bucket and allowing the
material to drain. Eventually, the material recovered in the bucket should be returned to the
pump hopper for reuse.
25) Observe any indications of aquifer refusal such as "surfacing" around the injection rods or
previously installed injection points. If aquifer acceptance appears to be Iow, allow enough
time for the aquifer to equilibrate prior to removing the drive rod.
26) Repeat steps 19 through 25 until treatment of the entire contaminated vertical zone has been
achieved.
27) Install an appropriate seal, such as bentonite, above the microemulsion injection zone. The
seal should span across the entire vadose zone. Depending on soil conditions and local
Regenesis 1 loll Calle Sombra 1 San Clemente 1 CA 1926731949-366-80001 www.regenesis.com
3Dhfe Install Instructions, Updated 040607 C5
(Page 6)

3-D MICROEMULSION APPLICATION INSTRUCTIONS (cont)
regulations, a bentonite seal using chips or pellets can be used. If the injection hole remains
open more than three or four feet below the ground surface sand can be used to fill the hole
and provide a base for the bentonite seal. The installation of an appropriate seal assures that
the microemulsion remains properly placed and prevents contaminant migration from the
surface. If the microemulsion continues to "surface" up the direct -push borehole, an
oversized disposable drive tip or wood plug/stake can be used to temporarily plug the hole
until the aquifer equilibrates and the material stops surfacing.
28) Remove and clean the drive rods as necessary.
29) Finish the borehole at the surface as appropriate (concrete or asphalt cap, if necessary).
30) Periodically compare the pre- and post -injection discharge rates of the microemulsion in the
pump hopper or holding tank using any pre -marked volume levels. If volume level
indicators are not on the pumps hopper or holding tank use a pre -marked dipstick or
alternatively temporary mark the hopper or holding tank with known quantities/volumes of
water using a carpenter's grease pencil (Kiel crayon).
31) Move to the next probe point, repeating steps 1 l through 29.
Helpful Hints
1 y Application in Cold Weather Settings
As discussed in the Material Overview, Handling, and Safety section, cold weather tends to
increase the viscosity of 3DMe as well as decrease the ease of microemulsion formation. To
optimize an application in cold weather settings Regenesis recommends maintaining the 3DMe
concentrate and the associated water at a temperature �:60°F (16°C). The following procedures
can be used to facilitate the production and installation of a 10:1 vlv 3DMe microemulsion.
■ Raise and maintain the temperature of the 3DMe to at least 607 (16°C) prior to mixing with
water. A hot water bath can be used to heat up the 3DMe concentrate buckets. A Rubbermaid
fiberglass Farm Trough Stock Tank (Model 4242-00-GRAY) has been used for this process.
This trough can hold up to 16 buckets of 3DMe concentrate.
• Hot water (approximately 130-1707 or 54-77°C) should be added to the tank after the
buckets of 3DMe have been placed inside. The hot water should be delivered from a heated
pressure washer (HotsyoModeI No. 444 or equivalent) or steam cleaner unit.
• It is equally critical that a moderate water temperature (>60°F or 16°C) be used in the
production of the microemulsion. If on -site water supply is below 60°F use a hot water or
steam cleaner to generate a small volume (e.g. 5-10% of total water volume) of hot water
(130-170°F154-770C). This small volume of hot water should be added to remaining cold
water volume to raise the total volume temperature to >60°F. When the 3DMe concentrate
and water each reach a minimum temperature of 60°F or 16°C the two materials are ready for
mixing.
Regenesis 1 1011 Calle 5ombra I San Clemente/ CA 1926731949-366-8000 /www.regcnesis.com
3DMe Invai! Insirwifow. Updated 040607 CS
(Page 7)

3-D MICROEMULSION APPLICATION INSTRUCTIONS (cont)
• Upon achieving a minimum temperature of 60°F or 16°C (approximately 10-20 minutes).
When the 3DMe and the associated water volumes have reached a minimum temperature of
60°F or 16°C (approximately 10-20 minutes) they are ready for mixing.
• In exceptionally harsh winter temperature settings use of a separate insulated pump
containment structure and insulated delivery hoses may be necessary,
• Use a pump with a heater unit.
• PeriodicaIly check the temperature of the material in the hopper.
• Re -circulate the 3DMe microemulsion through the pump and hose to maintain temperature
adequate temperatures.
• Care should be taken to avoid the re -circulation of material volumes that exceed the volume
of the pump hopper or holding tank.
Table 1: Equipment Volume and 3DMe Microemulsion Weight per Unit
Length of Hose (Feet)
Equipment Volume Product Weight
1-inch OD; 0.625-inch ID hose (10 feet) 0.2 gallon 1.6 lbs.
1.25-inch OD; 0.625-inch ID drive rod (3 feet): 0.05 gallon 0.4 lbs.
1.25-inch OD; 0.625-inch ID drive rod (4 feet): 0.06 gallon 0.5 lbs.
2) Pump Cleaning
For best results, use a heated pressure washer to clean equipment and rods periodically
throughout the day. Internal pump mechanisms and hoses can be easily cleaned by re -circulating
a solution of hot water and a biodegradable cleaner such as Simple Green through the pump and
delivery hose. Further cleaning and decontamination (if necessary due to subsurface conditions)
should he performed according to the equipment supplier's standard procedures and local
regulatory requirements.
NOTE:
Before using the Rupe Pump, check the following:
Fuel level prior to engaging in pumping activities (it would be best to start with a fu I i
tank)
Remote control/pump stroke counter LCD display [if no display is present, the electronic
counter will need to be replaced (Grainger Stock No. 2A540)]
Monitor pump strokes by observing the proximity switches (these are located on the top of the
piston).
3) Bedrock Applications
When contaminants are present in competent bedrock aquifers, the use of direct -push technology
as a delivery method is not possible. Regenesis is in the process of developing methods for
Regenesis 1 tall Calle Sombra 15an Clemente 1 CA 1926731949-366-80001 www.regenesis.com
3DMe Install Ins►rucrions, Updared 040607 CS
(Page g)

3-D MICROEMULSION APPLICATION INSTRUCTIONS (cant)
applying 3DMe via boreholes drilled using conventional rotary techniques. To develop the best
installation strategy for a particular bedrock site, it is critical that our customers call the
Technical Services department at Regenesis early in the design process.
The microemulsion can be applied into a bedrock aquifer in cased and uncased boreholes. The
microemulsion can be delivered by simply filling the borehole without pressure or by using a
single or straddle packer system to inject the material under pressure. Selection of the
appropriate delivery method is predicated on site -specific conditions. The following issues
should be considered in developing a delivery strategy:
■ Is the aquifer's hydraulic conductivity controlled by fractures?
• Backfilling may be the better delivery method in massive, unfractured bedrock. This is
particularly true in an aquifer setting with high permeability and little fracturing (such as
that found in massive sandstone).
■ Down -hole packer systems may be more advantageous in fractured bedrock aquifers.
■ In this case the fracture type, trends, and interconnections should be evaluated and
identified.
Are the injection wells and monitoring wells connected by the same fractures?
■ Determine if it is likely that the injection zone is connected to the proposed monitoring
points.
• If pressure injection via straddle packers is desired, consideration should be given to the
well construction. Specific issues to be considered are:
■ Diameter of the uncased borehole (will casing diameter allow a packer system to
be used under high pressures?).
■ Diameter of the casing (same as above).
■ Strength of the casing (can it withstand the delivery pressures?).
• Length of screened interval (screened intervals greater than 1 0 feet will require a
straddle packer system).
For further assistance or questions please contact Regenesis Technical Services at 949-366-8000.
Regenesis 1 1411 Calle Sombra 1 San Clemente 1 CA 192673 1949-366-80001 www.regenesis.com
3DMe Install Instructions. Updated 040607 C5
(Page 9)

System Diagram
(injection Hose)
a ball valve and
pressure gauge
will be mounted
Mixing pump at the end of the
injection hose
KI
Hypro
3DME Holding Diaphragm
Tank Pump -,.o
Geoprobe
Geoprobel.25"
rod
Expendable
Drive Point

Attachment F

1. Monitoring Wells to be utilized: The following groundwater monitoring wells will be sampled to
monitor the effectiveness of HRC-A injections: MW-2S, MW-2D, MW-4, MW-16 through MW-19,
and MW-6 through MW-9.As seen in Figure 5 in Attachment H, MW-4 will be located within the
plume injection area. Monitoring wells MW-2s, MW-2D, MW-17 and MW-19 will he located on
the immediate perimeter of the plume injection area.
2. Groundwater samples collected during these events will be analyzed by EPA Method 8260 in.
addition to the following geochemical parameters: dissolved oxygen, oxidation reductions potential
(ORP), ferrous iron, specific conductivity, pH, and temperature. Laboratory analysis of the samples
will include alkalinity, nitrate, sulfate, chlorides, total organic carbon (TOC), methane, ethane, total
and dissolved iron and manganese. Additionally, collected groundwater samples will be analyzed for
5 metabolic acids: lactic, pyruvic, acetic, propior is and butyric. The laboratory analytical results
derived from these sampling events will determine the long-term effectiveness of groundwater
remediation.
3. Completion of two groundwater monitoring events. The first at two years after treatment and the
second at five years after treatment..

Attachment G

1. Limited Receptor Survey information- In February 2007, Piedmont completed a limited
potential receptor survey as part of the Environmental Site Assessment at the site. Results of the
limited potential receptor survey indicated that the nearby Yadkin River could be considered a
potential at risk receptor. However, surface water analytical results did not indicate the presence of
any targeted volatile organic compounds present in the river. According to information provided
by the Town of Elkin, a public water supply is available for the subject site and surrounding areas.
According to Mr. Robert Fuller, Public Works and Utilities Director for the Town of Elkin, no
water supply wells are located within 1500 feet of the: site. The nearest surface water intake,
utilized by the City of Jonesville for a public water supply, is located 7,559 feet west of the subject
site. A visual recognizance of the surrounding area revealed no signs of water supply wells located
within approximately 1500 feet from the site. Therefore, no water supply wells are at risk
receptors.

Monitoring Well Construction Information
WELL
ID
CASING
ELEV.
TOTAL DEPTH
OF WELL
(FT)
SCREENED
INTERVAL
(FT)
MW-Is
895.70
24.50
11.8-22.2
MW-1 D
895.76
42.10
31.5-41.8
MW-2s
887.49
19.50
8.6-19.0
MW-2D
887.61
38.10
27.7-38.0
MW-3s
882.45
20.20
9.4-20.0
MW-3D
882.28
34.50
24.2-34.5
MW-4
886.58
19.50
8.7-19.0
MW-5
882.60
18
8.0-18.0
MW-6
880.81
17.35
6.0-16.0
MW-7
883.82
20.36
8.0-18.0
MW-8
883.75
19.6
3.0-18.0
MW-9
882.90
19.58
3.0-18.0
MW-10
887.44
22.55
5.0-20.0
MW-11
884.03
18.75
7.0-17.0
MW-12
887.33
23
6.0-21.0
MW-13
884.74
19.75
8.0-18.0
MW-14
884.68
20.10
8.0-18.0
MW-15
884.32
20
10.0-20.0
MW-16
886.50
17.7
12.7-17.7
MW-17
888.97
14.6
9.6-14.6
MW-18
885.24
16.4
11.4-16.4
MW-19
886.74
18
13.0-18.0

Last Revised: March 26, 2007
3-D Microemulsion (3DMe)TM
MATERIALS SAFETY DATA SHEET
Section 1— Material Identification
Supplier:
J
REGENESIS
1011 Calle Sombra
San Clemente, CA 92673
Phone: [phone]
Fax: [phone]
E-mail: info(a regenesis.com
• Glycerides, di-, mono [2-[2-[2-(2-hydroxy-l-oxopropoxy)- I -oxopropoxyl]-1-
oxopropoxy]propanoates]
Chemical Name(s): • Propanoic acid, 2-[2-[2-(2-hydroxy-l-oxopropoxy)-1-oxopropoxy]-I-
oxopropoxy]-1,2,3-propanetriyl ester
• Glycerol
Chemical Family: Organic Chemical
Trade Name: 3-D Microemulsion (3DMe)T111
Synonyms: HRC Advanced"" HRC-PED (Hydrogen Release Compound -- Partitioning
Electron Donor)
Product Use: Used to remediate contaminated groundwater (environmental applications)
Section 2 — Chemical Identification
CAS# Chemical
823190-10-9 HRC-PED
61790-12-3 or
112-80-1 Fatty Acids (neutralized)
201167-72-8 Glycerol Tripolylactate
56-81-5 Glycerol

Regenesis — 3-D Microemulsion MSDS
Section 3 — Physical Data
Melting Point: Not Available (NA)
Soiling Point: Not determined (ND)
Flash Point: > 200 °F using the Closed Cup method
Density: 0.9 -1.1 glcc
Solubility: Slightly soluble in acetone. Insoluble in water.
Appearance: Amber semi -solid.
Odor: Not detectable
Vapor Pressure: None
Section 4 — Fire and Explosion Hazard Data
Extinguishing Media: Use water spray, carbon dioxide, dry chemical powder or appropriate foam
to extinguish fires.
Water May be used to keep exposed containers cool.
For large quantities involved in a fire, one should wear full protective clothing and a NIOSH approved
self contained breathing apparatus with full face piece operated in the pressure demand or positive
pressure mode as for a situation where Iack of oxygen and excess heat are present.
Section 5 — Toxicological Information
May be harmful by inhalation, ingestion, or skin absorption. May cause
irritation. To the best of our knowledge, the chemical, physical, and
Acute Effects: toxicological properties of the 3-D Microemulsion have not been
investigated. Listed below are the toxicological information for glycerol,
lactic acid and fatty acid.
NA8050000
RTECS#
Glycerol
SKN-RBT 500 MG124H MLD 85.ICAE-,207,1986
Irritation Data: EYE-RBT 126 MG MLD BIOFX* 9-411970
EYE-RBT 500 MG124H MLD 85.ICAE-,207,1986

Regenesis -- 3-D Microemulsion MSDS
Section 5 — Toxicological Information (cons)
ORL-NUS LD50:4090 MG1KG
FRZKAP (6),56,1977
SCU-RBT LD50:100 MG/KG
NIIRDN 6,215,1982
ORL-RAT 1,1350:12,600 MG/KG
FEPRA7 4,142,1945
IHL-RAT LC50: >570 MGIM311H
BIOFX* 9-411970
IPR-RAT LD50: 4,420 MG/KG
RCOCB8 56,125,1987
IVN-RAT LD50:5,566 MG/KG
ARZNAD 26,1581,1976
Toxicity Data: IPR-MUS LD50: 8,700 MG/KG
ARZNAD 26,1579,1978
SCU-MUS LD50:91 MG/KG
NIIRDN 6,215,1982
IVN-MUS LD50:4,250 MG/KG
JAPMA8 39,583,1950
ORL-RBT LD50: 27 MG/KG
DMDJAP 31,276,1959
SKN-RBT LD50: >10 MG/KG
BIOFX* 9-411970
IVN-RBT LD50: 53 MG/KG
NIIRDN 6,215,1982
ORL-GPG LD50: 7,750 MG/KG
JIHTAB 23,259,1941
Behavioral (headache), gastrointestinal (nausea or vomiting), Paternal
Target Organ Data: effects (spermatogenesis, testes, epididymis, sperm duct), effects of fertility
(male fertility index, post -implantation mortality).
Only selected registry of toxic effects of chemical substances (RTECS)
data is presented here. See
actual entry in RTECS for complete information on lactic acid
and glycerol.
Fatty Acids
Acute oral (rat) LD50 value for fatty acids is 10000 mg/kg. Aspiration of liquid may cause
pneumonitis. Repeated dermal contact may cause skin sensitization.
Section 6 — Health Hazard Data
One should anticipate the potential for eye irritation and skin irritation with large scale exposure or in
sensitive individuals. Product is not considered to be combustible. However, after prolonged contact
with highly porous materials in the presence of excess heat, this product may spontaneously combust.
Handling: Avoid continued contact with skin. Avoid contact with eyes.
In any case of any exposure which elicits a response, a physician should be consulted immediately.
First Aid Procedures
inhalation: Remove to fresh air. If not breathing give artificial respiration. In case of
labored breathing give oxygen. Call a physician.
Ingestion: No effects expected. Do not give anything to an unconscious person. Call a

Regenesis — 3-D Microemulsion MSDS
physician immediately. DO NOT induce vomiting.
Section 6 — Health Hazard Data (cant)
Skin Contact: Flush with plenty of water. Contaminated clothing may be washed or dry
cleaned normally.
Eye Contact: Wash eyes with plenty of water for at least 15 minutes lifting both upper
and lower lids. Call a physician.
Section 7 — Reactivity Data
Conditions to Avoid: Strong oxidizing agents, bases and acids
Hazardous Will not occur.
Polymerization:
Further Information: Hydrolyses in water to form lactic acid, glycerol and fatty acids.
Hazardous Decomposition Thermal decomposition or combustion may produce carbon monoxide
Products: and/or carbon dioxide.
Section S — Spill, Leak or Accident Procedures
After Spillage or Neutralization is not required. The material is very slippery. Spills should
Leakage: be covered with an inert absorbent and then be placed in a container. Wash
area thoroughly with water. Repeat these steps if slipperiness remains.
Laws and regulations for disposal vary widely by locality. Observe all
Disposal: applicable regulations and laws. This material may be disposed of in solid
waste. Material is readily degradable and hydrolyses in several hours.
No requirement for a reportable quantity (CERCLA) of a spill is known.
Section 9 — Special Protection or Handling
Should be stored in plastic lined steel, plastic, glass, aluminum, stainless steel, or reinforced fiberglass
containers.
Protective Gloves: Vinyl or Rubber
Eyes: Splash Goggles or Full Face Shield. Area should have approved means of
washing eyes.
Ventilation. General exhaust.
Storage: Store in cool, dry, ventilated area. Protect from incompatible materials.

Regenesis — 3-D Microermulsion MSDS
Section ID — Other Information
This material will degrade in the environment by
Materials containing reactive chemicals should be
training.
hydrolysis to lactic acid, glycerol and fatty acids.
used only by personnel with appropriate chemical
The information contained in this document is the best available to the supplier as of the time of
writing. Some possible hazards have been determined by analogy to similar classes of material. No
separate tests have been performed on the toxicity of this material. The items in this document are
subject to change and clarification as more information becomes available.

3-D Microemulsion (3DMe)TM
Introduction
3-D Microemulsion (3DMe)TM, a form of HRC Advanced, is the new paradigm in time -
release electron donors for groundwater and soil remediation. 3DMe is based upon a new
molecular structure (patent applied for) designed specifically to optimize anaerobic
degradation of contaminants in subsurface environments. This structure incorporates
esterified lactic acid (technology used in HRQ and esterified long chain fatty acids. The
advantage of this structure is that it allows for the controlled -release of lactic acid (which
is among the most efficient electron donors) and the controlled -release of fatty acids (a
very cost effective source of slow release hydrogen). Upon injection, the controlled -
release of lactic acid dominates serving to initiate and stimulate anaerobic dechlorination.
Over time the controlled -release of fatty acids will dominate, acting to continue microbial
stimulation. The expected single -injection longevity of this product is 1-2 years and in
excess of 4 years under optimal conditions, e.g. concentrated application in low
permeability, low consumptive environments.
3DMe is a slightly viscous liquid that incorporates a molecular structure composed of
tetramers of lactic acid (polylactate) and fatty acids esterified to a carbon backbone
molecule of glycerin.
The image to the left illustrates a
ball -and -stick version of the
glycerol ester in 3DMe. Oxygen
atoms are shown in red, carbon
atoms in grey, and hydrogen atoms
in white. The long chains represent
the fatty acid components of the
molecule.
4..
REGENESIS
Advanced Tn hnolog,er for 6ro undwu let Resowct,
All Rights Reserved 2006
1011 C a I I e Sombra, San Clemente, CA 926731 www. regen esi s-oo m

When 3DMe is placed in water, free lactic acid immediately begins to ferment which
initiates reductive dechlorination and subsequent contaminant treatment. Over time the
ester bonds begin to cleave, producing dissolved -phase lactic acid and fatty acids. 3DMe
also contains free fatty acids for additional electron donating capacity. Thus, 3DMe
provides the benefits of lactic acid, a rapidly fermented substrate and excellent hydrogen
source, as well as fatty acids, which are slower to ferment and provide hydrogen to a
contaminated site over extended time periods. This combination of lactic acid and fatty
acids provides a functional longevity of 1-2 years for most sites (>4 years under optimal
conditions). 3DMe creates an anaerobic system in a redox range where bacteria known
to be responsible for reductive dechlorination flourish. Maintaining these conditions
provides maximum utilization of the electron donor for reductive dechlorination, rather
than simply providing excess carbon per unit time which can result in excess methane
production, as simple soluble substrates often do.
3DMe Attributes:
o Incorporates proven Hydrogen Release Compound (HRC' } base materials
o Provides a persistent and significant source of hydrogen
o Typical single -injection longevity of 1-2 years and over 4 years under optimal
conditions
o Achieve wide subsurface distribution when applied as microemulsion
a Easily applied with readily available direct injection equipment
Molecular Diagram
The following chemical structure shows the glycerol ester (patent applied for). The top
"prong" is the tetramer of polylactate (look for 4 double bonded D atoms). The middle
and bottom "prongs" are fatty acids.
a 1 H, o C143 a Of]
ii;t--{'ll II ll t'If;
I1• [� II ]i
II I 1
t I . ll:{'ll. H. }I.{'Ei_C'= C{'li. II:C fI_C li.{'H:[ l{_C li.Cll,
I1•
1} 11
I i
Ei;r-114,111 '_ccIM I1.C'11_C'li_CII_i"II.cl1,cH,
w_
REGENESIS
Advanced TVthnolagPn for Gfound*ovie+ Rew mrs
All Rights Reserved 2006
1011 Calle Sombra, San Clemente. CA 926731 www.regenesis.com

3-D Microemulsion (3DMe)TM
11 Subsurface Transport Mechanisms 11
As described in 3-D Microemulsion Technical Bulletin 1.0 (Introduction), 3-❑
Microemulsion (3DMe)TM, a form of HRC Advanced J), is a unique compound (patent applied
for) which incorporates esterified lactic acid (the technology used in HRC), with esterified
fatty acids. The unmatched advantage of this product is that it allows for the immediate and
controlled -release of lactic acid which is among the most efficient electron donors. The
controlled -release of proprietary fatty acids provides a cost-effective source of controlled -
release hydrogen. This combination of organic acids, in turn, rapidly stimulates reductive
dechlorination for extended periods of time up to 4+ years under optimum conditions (e.g.
concentrated application in low permeability, low consumptive environments.).
3DMe is NOT Simple Emulsified Vegetable Oil
Vegetable oil is basically insoluble. Thus, to make it amenable to injection into the
subsurface, some vendors have added commercial emulsifying agents to simple vegetable oils
and produced emulsions claiming that the "stable" emulsion will transport the oil significant
distances down -gradient from the injection point. Unfortunately, this is not the case.
When so-called "stabilized" oil -in -water emulsions are forced out of the injection point into
subsurface aquifer materials the emulsifying agents are rapidly stripped from the oil droplet
due to the zeta potential of subsurface materials (charges on the surfaces of soil particles)
adhering to the hydrophilic "heads" of the emulsifying agents, and to organic matter within
the aquifer matrix sorbing to the vegetable oil itself. Upon the stripping of the emulsifying
agents the oil droplets rapidly coalesce in soil pores creating a separate phase (this is the basis
for many de -emulsification filters used in the petroleum production industry). When this
coalescence occurs in the aquifer, it retards further migration of any oil emulsion and, in fact,
often blocks groundwater flow. Use of emulsified oil products can result in significant
lowering of the aquifer hydraulic conductivity within aquifer settings (Edible ail Barriers for
Treatment of Perchlorate Contaminated Groundwater, Environmental Security Technology
Certification Program, US Department of Defense, November 2005.)
3DMe has a balanced HLB
3DMe is composed of molecules that are surface active. That is to say the molecules behave
as surfactants, with a hydrophilic or "water loving end", and a lipophilic or "oil loving end".
As a result, the molecules tend to align themselves with the hydrophilic ends in the water
matrix, while the lipophilic ends bind to organic compounds (such as the contaminant).
All Rights Reserved 20061 REGENEs3S 1 www_Tcgenesis.com
L4b
REGENESIS
Adrm ed la(Mosu¢in !vr 6;wmamie+ Rtwu—

As a measure of the tendency for a molecule to move into water, chemists refer to the
Hydrophile/Lipophile Balance index (HLB). The greater the HLB, the higher the tendency for
dissolution in water, thus, low HLB molecules are generally pushed out of the water matrix
and sorb onto surfaces and to organic compounds within the aquifer material.
3DMe was designed to have a low, yet positive HLB. This gives 3DMe the advantage of
being able to sorb organic contaminants (partition), yet have a significant solubility in water
allowing for aqueous transport (unlike emulsified oils). A comparison of estimated HLBs for
substrates is listed below.
Substance
HLB
Sugars
30
Lecithin
20
3DMe
G
Vegetable Oil
-G
3DMe Forms Micelles
When 3DMe is in water in concentrations in excess of about 344ppm, dissolved molecules of
3DMe begin to spontaneously group themselves into forms called "micelles". In colloidal
chemistry this concentration is referred to as the "critical micelle concentration" or CMC.
The grouping of the micellar structure is very orderly, with the charged or hydrophilic ends
(heads) of the fatty acids facing out to the water matrix and the hydrophobic ends (tails)
facing in together. The micellar structures formed from 3DMe are generally spherical, but
under certain circumstances can become lamellar. A depiction of a 3DMe micellar structure
is shown below:
s�
•
After a. Lindman
Depiction of 3-D ME Micellar Structure
The size of the 3DMe micelles formed is very small, on the order of .02 to .05 microns in
diameter. These will spontaneously form in aquifer waters when the CMC is exceeded. Thus.
JW
REGENESIS
All Rights Reserved 20061 REGENE5l51 www.regenesis.com Advvwd t.chnokq in ra Growdywvr Rcww�n

by loading the aquifer with volumes of injection water containing 3DMe in excess of
approximately 300 ppm, micelles will spontaneously form carrying the 3DMe product further
down -gradient,
Mixing and Application
Concentrated Delivery
When applied to the subsurface in concentrated form, 3DMe will behave much like HRC.
Once installed the material remains stationary and slowly releases soluble lactic acid and fatty
acids which diffuse and advert away from the point of application. In this fashion the
engineer is assured of a long-term, constant supply of electron donor emanating from the
point of application for a period of up to 4+ years (under optimal conditions). This is
particularly attractive when used to treat a flux of contamination from an up -gradient source
or when a very long term supply of electron donor is required.
High Volume Delivery
3DMe can also be used to treat large areas in a short period of time by using a high -shear
pump to mix the 3DMe with water prior to injection. This mixing generates a large volume of
a 3DMe colloidal suspension. The actual suspension of 3DMe generated by this mixing
ranges in size from micelles on the order of .02 microns to .05 microns in diameter to
"swollen" micelles, also termed "microemulsions", which are on the order of .05 to 5 microns
in diameter.
Once injected into the subsurface in high volumes followed by water the colloidal suspension
mixes and dilutes in existing pore waters. The miceileslmicroemulsions on the injection front
will then begin to sorb onto the surfaces of soils as a result of zeta potential attraction and
organic matter within the soils themselves. As the sorption continues, the 3DMe will "coat"
pore surfaces developing a layer of molecules (and in some cases a bilayer). This sorption
continues as the micelleslmicroemulsion moves outward.
Unlike emulsified oil, however, the sorbed 3DMe has a significant capacity to move beyond
the point of initial sorption. As the high concentration of 3DMe present in the initial injection
volume decreases, bound material desorbs. As long as this concentration exceeds the CMC,
micelles will spontaneously form, carrying 3DMe further out in to the contaminated aquifer
through advection and diffusion.
Additional Research Underway
Regenesis is currently undertaking a series of laboratory studies and in -field research efforts
to further define the extent to which 3DMe suspensions transport under various aquifer
conditions. These studies will generate information which will aid in understanding the
limitations to the transport of colloidal suspensions under realistic injection/aquifer dispersion
conditions.
REGENESIS
nmawl Techmalag n for Gro dmw Fewwm
All Rights Reserved 20061 REG1~NES1S I www.regenesis.rom

3-D Microemulsion (3DMe)TM
11 Micelle Distribution Column Experiment 11
Background
3-D Microemulsion (3DMe)T1-1, a form of HRC Advanced', is a state-of-the-art specialty
chemical substrate developed to provide a low-cost, slow -release electron donor to
stimulate the in -situ anaerobic degradation of contaminants in soil and groundwater.
Unlike emulsified -oil -type substrates, 3DMe was designed to provide superior
distribution in the subsurface, thereby reducing the cost of product application. 313Me
was also designed to avoid the significant reduction in subsurface hydraulic conductivity
often associated with emulsified -oil -type substrates. 3DMe is a slightly viscous liquid
that incorporates a molecular structure composed of tetramers of lactic acid (polylactate)
and fatty acids esterified to a carbon backbone molecule of glycerin.
Subsurface Transport
3DMe achieves superior subsurface distribution through surface-active properties that
promote the spontaneous formation of micellar structures (Shah, et aI., 1972; Lindman, et
al., 1982). This unique characteristic allows for moderate aqueous transport of the
substrate prior to its adsorption onto the aquifer matrix where it both partitions organic
contaminants from solution and promotes rapid biodegradation through efficient
hydrogen generation. (The surface-active properties of 3DMe, formation of micelles, and
recommended 3DMe application details are described in Regenesis 3-D Microemulsion
Technical Bulletin 2.0.)
Demonstration of 3DMe Movement
It is well known that slow -release electron donors, such as emulsified -oil -type substrates,
do not distribute well in soil and groundwater. In fact, extensive experiments using
emulsified -oil -type substrates in sand test cells demonstrated that the emulsified -oil
substrate moved less than 2 meters, even after 10 days of continuous emulsion feed.
Furthermore, no emulsified -oil substrate moved more than 8 meters, regardless of
injection volumes, and no additional water volume moving through the sorted emulsion
could facilitate further distribution (Borden, et al., 2005).
Experimental Design
In an effort to analyze the subsurface transport properties of 3DMe relative to the known
shortcomings of emulsified -oil -type products, a controlled laboratory experiment was
conducted using a dedicated aquifer simulation column (column) that was packed with
REGENESIS
Advanced ie,hnol"is� f.F GM—dwaser RrsnurtK
All Rights Reserved 2006
1011 Calle Sombra, San Clemente. CA 92673 1 www.regenesis.com

sand. The 6-inch-diameter, 20-foot-long column was constructed of transparent
polycarbonate. The column was filled with fine-grained sand and packed to prevent
channeling. The pore space was determined to be 30.5 percent (approximately 9 gallons).
The column was filled with water by peristaltic pumps at a rate of 2.5 gallons per hour
(see Figure 1).
A microemulsion of 3DMe was created by preparing a 1:3 3DMe-to-water mixture using
a common high -shear pump, and was further diluted with water to generate a final 1:50
microemulsion. To visually track movement of the microemulsion in the sand column, it
was dyed with methylene blue, which is absorbed by the hydrophobic portions of the
3DMe microemulsion. The dye does not partition into water.
After the column was first saturated with water, the 3DMe microemulsion was fed into
the column at a rate of 2,5 gallons per hour. After 2.0 hours, the microemulsion feed was
stopped and water was injected into the column at the same rate (2.5gallonslhour). This
water feed continued for 12 hours (about 3.3 pore volumes).
Movement of the dyed microemulsion and resulting dyed micelle suspension were
observed visually throughout the study. In addition, water effluent from the column was
analyzed for the methylene blue by UV -Visible Spectroscopy. Components of 3DMe in
the effluent were also confirmed by direct measurement with both liquid chromatography
and infrared analysis.
Results and Discussion
After 13 hours, an estimated 3.6 pore volumes of the 3DMe microemulsion (1:50
product -to -water mixture) had been fed into the column. As expected, due to the unique
hydrophilellipophile balance of the 3DMe material, the hulk of the microemulsion
appeared to adhere to the sand surfaces within the first 1 meter of the column, as
evidenced by the dark blue color (see Figure 2). However, it was at this time that the first
"break through" (material exiting the column) was detected by spectroscopy. Further
analysis clearly indicated that the material in the effluent was, in fact, colloidal 3DMe
(Micellar suspension), as evidenced by the presence of the intact esters, carboxyl, and
carbonyl peaks apparent under infrared spectrum analysis (see Figure 3). While the bulk
of the injected 3DMe remained stationary, micelles were forming and carrying the
material more than 20 feet, with only 3.6 pore volumes, in less than 13 hours.
Approximately 20 hours after 3DMe injection, the bulk of the microemulsion continued
to sorb onto soil near to the injection point (within the first 2 meters of the column), as
evidenced by a dark blue color. At that time, the column was switched to a water feed,
without any 3DMe, to emulate continued groundwater flow following 3DMe application.
A striking pattern began to emerge as a light -blue -colored "front" began to move down
the column.
41
REGENESfS
Advanced irr.hnologio rvi Grou­1watrr R&to—w.
All Rights Resented 2006
1011 CaIIe Sembra, San Clemente, CA 92673 1 Www.regenesis.corn

It is apparent that water continuing to flow past the 3DMe was redistributing the product
through the column as suspended micelles, which, in turn, were resorbing onto the
column in a forward -moving "front." As more water was fed through the column, the
3DMe continued to redistribute, forming a light -blue -colored pattern (see Figure 4).
Throughout the 12-hour period of the water feed, a 3DMe micelle suspension of low
concentration was documented exiting the 20-foot-long column, as evidenced by
microscopy and validated by liquid chromatography as well as infrared analysis.
Summary
3DMe was designed to achieve superior distribution in the subsurface and the advanced
performance capability of the material was clearly demonstrated in a controlled
laboratory column study. During the study, it was shown that 3DMe, when injected into
the subsurface, initially sorbed onto the sand matrix. However, once in place, the material
redistributed gradually through micelle formation and sorption in a distribution "front."
3DMe micelles were documented to move 20 feet through the sand column in 13 hours
(3.6 pore volumes). The ability of 3DMe to remain relatively stationary, yet form
micelles that continually redistribute, clearly demonstrates the product's superior
subsurface distribution capability. This is significant when compared to other electron -
donor substrates. Highly soluble substrates such as lactate and sugar solutions rapidly
ferment and "wash out," requiring the expense of multiple injections. Emulsified-oiltype
products have been clearly documented to sorb within the first 2 meters of the injection
and then remain immobile, significantly limiting the effective radius of any injection
point. In addition, emulsified oils often coalesce in the subsurface, reducing hydraulic
conductivity.
The scientific evidence clearly demonstrates that the unique transport properties of 3DMe
make this product an advantageous choice for stimulating effective in -situ anaerobic
biodegradation.
L�
REGENESIS
Adyancrd irchnalown Poi GrpundwNtr Rr~rt,
AD Rights Reserved 2006
1011 C a I I e Sombra. San Clemente. CA 92673 1 www.reganesis.com

Figure 1
Figure 2
'4'
REGENESIS
Advanced T*1hn0169ies for Gr 0.ndwa let ResOurC eS
All Rights Reserved 2006
1011 Celle Sambra, San Clemente. CA 926731 www.regenesis.com

Figure 3
Infrared Spectrum of Organic Material Exiting ASV at 13 Hours
13 Hour Sample - Organic Esters and Acids
0.01
0.009
0.008
0.007
�7
0.006
CC
0.OD5
0.004
0.003
0.002
0.001
0
1500
1550 1600 1650 1700 1750 1800
Wavelength (nrn)
Figure 4
Micelle Formation and 3DMe Redistribution with Water Feed
REGENESIS
Advanced Ter hno I ogi es far CFOU ndw al er Rmour re%
All Rights Reserved 2006
1011 C a I I e Somhra, Says Clemente, CA 92673 ) www.regenesis.com
i
i
CStCf, carboxyl aC1il
aarbanyi peaks

References
Shah, ❑.Q., Tamjeedi, A., Falco, J. W., and Walker, R. D., 1972, Interfacial Instability
and Spontaneous Formation of Microemulsions, Am. Inst. Chem. Eng. J., 18:111-1 I20.
Lindman, B., Kamenka, N., Brun, B., and Nilsson, P.G., 1982, On the Structure and
Dynamics of Microemulsions Self -Diffusion Studies, (ed.) Robb, I.D., Microemulsions,
Plenum Press, NY.
Bordon, R.C., Lieberman, M.T., and Zawtocki, C.E., 2005, Enhanced Anaerobic
Bioremediation Using Emulsified Edible Oil, Workshop, Eighth International In -Situ and
On -Site Bioremediation Symposium, Baltimore, Md.
C4`
REGENESIS
Adr.enced ftc hnalagles for 6raan4",)itr Rewwetr,
All Rights Reserved 2006
1011 Calla Sarnbra, San Clemente, CA 92673 1 www.reganesis.com

10
HRC ADVANCED*
• Three Stage Electron Donor Release —
FIGURE 1: THE 3-D MICROEMULSION MOLECULAR
Immediate, Mid -Range and Long -Term Hydrogen Production
STRUCTURE
— Provides free lactic acid, controlled -release lactic acid and long
o
release fatty acids for effective hydrogen production for periods of
Fatty Acids CC
CC
up to 3 to 5 years.
LLJ
• Low -Cost
Lactic Acid
Tetramer dL
U5
--- 3-0 Microemulsion is 252 to 420 per pound as applied
d
�
Cl
• Maximum and Continuous Distribution via Micellar Transport
a
a
Unlike oil products, 3DMe forms micelles which are mobile in
a
groundwater and significantly enhance electron donor distribution
o
after injection.
Wide-Area/High Volume Microemulsion Application
— High volume application increases contact with contaminants and
Ester Bonds
reduces number of injection points required for treatment —
minimizes overall project cost.
3-D Microemulsion is delivered in 55 gallon drums,
300 gallon totes, tankers or buckels.
3-D Microemulsion (3DMe)_­ is a form of HRC Advanced° and has a molecular structure specifically designed to maximize the cost-
PERFORMANCE
effective anaerobic treatment of contaminants in subsurface soils and groundwater. This structure (patent pending) is composed of
Case Study #]
free lactic acid, controlled -release lactic acid (polylactate) and certain fatty acid components which are esterified to a carbon backbone
o
C3A
site in Massachusetts showed high
molecule of glycerin (Figure 1).
levels of PCE and its daughter products
3DMe produces a sequential, staged release of its electron donor components. The immediately available free lactic acid is
TCE and cis-DCE which had been
fermented rapidly while the controlled -release lactic acid is metabolized at a more controlled rate, The fatty acids are converted to
consistently present for more than two
hydrogen over a mid to Ion -ran a timeline Ivin 3DMe an exception longelectron donor release prof (Figure 2). This staged
g g g g p y p
years. 3DMe was applied in a grid
fermentation provides an immediate, mid -range and very long-term, controlled -release supply of hydrogen (electron donor) to fuel the
configuration around monitoring well 16.
reductive dechlorination process.
Typical 3DMe single application FIGURE 2: 3-0 MICROEMULSION RELEASE PROFILE
—
In Figure 4, the contaminant concentration
longevity is rated at periods of up to LACTATE
results indicate a rapid decrease in the
3 to 5 years. With 5 years occurring POLYLACTATE ESTERS
parent product PCE and evidence of
reductive dechlorination as demonstrated
under optimal conditions, e.g. low
permeability, low consumption FREE FATTY ACIDS & FATTY ACID ESTERS
by the relative increases E. daughter
environments.
products TCE and cis-QCE.
t) 1 YEAR 2 YEAR 3 YEAR 4 YEAR
3DMe applications can be configured in several different ways including
x grids, barriers and excavations. The material itself can be applied to the
o subsurface through the use of direct -push injection, hollow -stem auger,
existing wells or re -injection wells.
m
3DMe is typically applied in high -volumes as an emulsified, micellar
suspension (microemulsion). The microemulsion is easily pumped into the
a subsurface and is produced on -site by mixing specified volumes of water
e and delivered 3DMe concentrate. Detailed preparation and installation
d instructions are available at www.regenesis.com.
0 3DMe is usually applied throughout the entire vertical thickness of the
;_. determined treatment area. Once injected, the emulsified material moves
C-2 out into the subsurface pore spaces via m[cell ar transport, eventually
coating most all available surfaces. Over time the released soluble
a components of 3-D Microemulsion are distributed within the aquifer via
the physical process of advection and the concentration driven forces
7— of diffusion.
MORE OH MICELLES
Micelles (Figure 3) are groups (spheres) of molecules with the
hydrophilic group facing out to the water and the "tails" or lipophilic
moiety facing in. They are formed during the 3-0 Microemulsion
emulsification process and provide the added benefit of Increased
distribution via migration to areas of Power concentration.
FIGURE 3: MICELLE REPRESENTATION
es -00- •
4P AN
■0,990-
• a
Case Study #2
A site in Florida was characterized
with PCE contamination approaching
225 ug1L A total of 1,080 pounds of
3DMe was applied via 16 direct -push
injection points to reduce PCE concen-
trations. Monitoring results in well
MW-103 indicated a PCE reduction of
approximately 67% within 75 days of
the 3DMe application. PCE concentrations
continued to decline by 96% one year
after application and daughter products
remained at low levels. Total Organic
Carbon (TOC) levels remained elevated
at 17-19 mg7L after 275 days demon-
strating the longevity of 3DMe (Figure 5),
HRC ADVANCED'
The microemulsion is easily prepared on -site and applied 3-1) Mlcmemulsion is typicaIN applied through permanent
in high -volumes Tor maximum subsurface distribution, wells or by using direst -push injection.
aa,00e
n,000 —
1a.oao —
,s,000 -
9, Dee —
0,000 —
S poe
250
200
150
100
50
a
■
■
1
1
PRODUCT
1�
-Bd! -641 -"„ 4D9 -3S1 -20 -203 -139 -10 22
firm ;Days}
FIGURE 4: MW-IS CONTAMINANT CONCENTRATION DATA
ohnnl 11 T ILI IGr TIflY 1D1111rmnu
59 95 141 177 Z73 M 476
Loa
in
so
a
—
a,
m
c7
40
a
C/a
20
w— -- 0
50 0 sa 100 ISO 200 250 Sao 350
rant (dale)
FIGURE 5: 11*103 CONTAMINANT CONCENTRATION DATA

Preconstruetion Report
CMC Landfill
Elkin, North Carolina
NCDENR ID #: NONCDODOOO 16
March 19, 2009
Prepared For.
CMC Holding Corporation
N OW
ON
x
1491 �
Thomas P. Lennon, L.G.
�Prineipal Geologist
Piedmont Industrial Services, Inc.
1670-A Lowery Street
Winston Salem, NC 27101
[phone]
fax [phone]
RECEIVED 1 DENR ? DWQ
AQUjFFR'PROTFr.TfnN (,FCTION
yilete10
......�R
■ SEAL
r
• w
^ 2098 i
•//C;�{]LQ�7 �c;�•• Q yam►"
Jason Projec eo oM. p .G.
gist
MAR 2 7 2009 ,

TABLE OF CONTENTS
1.0 Introduction
2.0
Remedial Activities 1
2.1
Site Preparation 1
2.2
Baseline Soil Assessment 2
2.2.1
Soil Sampling Results 3
2.2.2
Soil Remediation 3
2.2.3
Revised Soil Remediation 4
2.3
Baseline Groundwater Assessment 5
2.3.1
Groundwater Sampling Results 5
2.3.2
Groundwater Remediation 6
3.0
Post Remedial Activities in Accordance with the RAP 7
3.1
Optional Post Remedial Activities 7
4.0
Planned Progress Reporting 8
5.0
Scheduling of Remedial Activities 8
TABLES
Table 1: Summary of Surface Water and Groundwater Sampling Results
Table 2: Geochemical Data for December 2008 Groundwater Sampling Event
Table 3: December 2008 Groundwater Analytical Results
Table 4: December 2008 and January 2009 Soil Analytical Results for VOCs by EPA
Method 8260
Table 5: December 2008 and January 2009 Soil Analytical Results for TCLP (VGC, SVOC,
PCB)
Table 6; December 2008 and January 2009 Soil Analytical Results for TCLP-Metals
Table 7: Soil Sample PID Readings
Table 8: Historical Summary of Groundwater Gauging Data
Table 9: Estimated Timeline for Remedial Activities
FT[-'TTRF.0
Figure 1: Soil Source Area "hot spot" Excavation and Site Map
Figure 2: December 16, 2008, Geoprobe sampling location map within the 50' X 75' soil
excavation area --
Figure 3:
December 17, 2008, and January 14-15, 2009, Geoprobe sampling location map
within the 50' Y 75' soil excavation area
Figure 4:
Soil Source Area "hot spot" Excavation Map for Non -Hazardous Disposal
Figure 5:
Groundwater Contour Map
Figure 6;
2008 Total VGC's Isoconcentration Map
Figure 7:
2007 Total VOC's Isoconcentration Map
Figure 8:
Soil Source Area `hot spot' injection Map
Figure 9:
Groundwater Plume Injection Area Map

APPENDIX
Appendix A:
Site Photographs
Appendix B:
Health and Safety Plan
Appendix C:
Technical Methods
Appendix D:
Boring Lags
Appendix E:
Laboratory Reports
Appendix F:
Waste Profile Information
Appendix CT:
Budgetary Cost Estimate
Appendix H:
Laboratory Report for Backfill Material
Industrial Service - CMC ii 3/19/2009

1.0 Introduction
Piedmont Industrial Services, Inc. (Piedmont) was contracted by CMC Holding Corp. ("CMC") to prepare
a Preconstruction Report for the purpose of implementing remedial activities at the subject site in
accordance with the February 2008, Remedial Action Plan (RAP). The subject site consists of
approximately 27 acres of land located in the eastern portion of the Town of Elkin, North Carolina (Parcel
ID: 4951-15-83-774). The Site is currently listed on the North Carolina Department of Environment and
Natural Resources, Division of Waste Management, Inactive Hazardous Sites Branch (hereafter the
"NCDENR") Inactive Hazardous Waste Sites Priority List as CMC Landfill ID #: NONCD0000015. This
listing results from prior subsurface disposal of material generated at the former Chatham Manufacturing
Company. In January 2009, the NCDENR included the site on the October 2008 Inactive Hazardous Waste
Sites Priority List with a score of 51.02 and a rank of 26.
2.0 Remedial Activities
The purpose of this Preconstruction Report is to document initial remedial activities completed in Areas 2
and 3 and to document existing conditions in the soil and groundwater derived from the baseline soil and
groundwater assessment. The laboratory analytical results from the baseline soil and groundwater
assessment were utilized for waste profiling purposes and to determine appropriate adjustments to the
approved February 2008, Remedial Action Plan (RAP).
All remedial activities completed to date have been completed in accordance with the August 2007, NCDENR-
inactive Hazardous Sites Program Guidelines for Assessment and Cleanup, the February 2008, RAP and the
October 2008 Preconstruction Report. A summary ofremedial activities completed to date, including proposed
adjustment and implementation of the February 2008 RAP will be detailed in the following report.
2.1 Site Preparation
On December l through December 9, 2008, Piedmont completed site improvements necessary to implement
the baseline sampling event and future remedial action. Site preparation activities included the following
activities.
• Completed repairs and improvement to the existing gravel road and drainage culvert in Area 3. In
addition to road repairs, a gravel lot (approx 0.3 acres in size) was installed in the southern portion.
of Area 3 to be used for a heavy equipment and truck turn -around and lot.
• The excavation area and chemical injection area (approx 30,000 ft), in Area 3, was cleared of
vegetation. The majority of waste was mulched onsite. 30 tons of vegetative waste (large trees and
stumps) that could not be mulched was transported and disposed of at the Surry County Landfill in
Mount Airy, North Carolina.
• After the vegetation was removed, the proposed soil sampling location grid (Figure 1) for the
baseline sampling event and future remedial excavation was surveyed by Foothills Forestry &
Surveying in Elkin, North Carolina.
Piedmont Indust W Service - CMC 1 3/19/2009

■ Completed repairs to w.. drainage feature in Area 2. The slope .. zhe drainage feature was
excavated and re -graded to reduce the slope angle. Geotech fabric was then placed on the re -graded
slope and was covered by riprap to stop erosion along the drainage feature.
On March 12, 2009, Piedmont mobilized to the Site and closed the facility to Public access. In
doing so, the unimproved roads located in the southeast and southwest portions of the property were
closed with a highly visible cable between bollards and a No Trespassing sign was posted.
Additionally, No Trespassing signs were posted along the northern portion of the property along the
ball fields and the front gate was chained and closed. The park will remain closed until remedial
activities are completed.
Photographs of the initial remedial activities are contained in Appendix A. Health and Safety documentation is
included in Appendix B.
2.2 Baseline Soil Assessment
As detailed in the February 2008 RAP, a baseline soil assessment was to be conducted within the proposed 75'
x 50' soil source area in order to establish geochemical parameters and profile the waste material for proper
disposal. Health and Safety documentation for the baseline soil assessment is included in Appendix B.
On December 16 and 17, Piedmont collected 28 soil samples with a Geoprobe for the baseline soil
assessment. As specified in RAP, Geoprobe soil borings were installed in the 10'9" x 12'6" grid intervals
within the defined 75' x 50' soil source excavation area (Figures 1, 2 and 3). Geoprobe operations were
completed by Probe Technologies Inc in accordance with the technical methods provided in Appendix C. A
licensed geologist was on -site to guide and document the boring activities. Boring logs are contained in
Appendix D. The Geoprobe was utilized to collected one soil sample within each grid interval from a depth
of 8' to 13' below surface grade. Due to the nature of the subsurface debris buried in this area, a total of
seventy six Geoprobe borings were attempted within the soil source area to obtain the required 28
composite soil samples. Sample locations are depicted on Figures 2 and 3.
Collected soil samples were placed in laboratory prepared containers and shipped on ice to Empirical
Laboratories (NC ID # 643) in Nashville, Tennessee on December 17, 2008, for the testing of analytical
parameters specified in the RAP. On December 31, 2008, Empirical Laboratories notified Piedmont that the
eight -teen (18) soil samples (B-1A through B-8A and B-19 through B-28) collected on December 16, 2008
were out of holding time for the detection of VOCs by EPA Method 8260 (Figure 2). As a result, on January
14 and 15, 2009, Piedmont remobilized to the site to resample each of the grid intervals that contained
samples out of holding time. Geoprobe operations were completed by Terraquest Environmental in
accordance with the technical methods provided in Appendix C. A licensed geologist was on -site to guide
and document the boring activities. Boring logs are contained in Appendix D. A summary of headspace
(PID) screening data is listed in Table 7.
Due to the excessive amount of subsurface debris, a total of fifty three Geoprobe borings were attempted
within the soil source area to obtain the 18 composite soil samples. The location of the Geoprobe borings
where composite soil samples were collected at an interval of 8' to 13' below grade surface is shown on
Figure 3 (samples B 1-B through B8-B and B 19-B through B28-B). Collected soil samples were placed in
laboratory prepared containers and shipped on ice to Empirical Laboratories (NC ID # 643) in Nashville,
Tennessee on January 15, 2009, for the testing of the complete analytical parameters specified in the RAP
including EPA Method 8260.
Piedmont Industrial Service - CMC 2 3/19/2009

2.2.1 Soil Sampling Results
All analytical testing was completed by Empirical Laboratories (NC ID # 643) in Nashville, Tennessee. A
summary of laboratory results are included in Tables 4-6. To date, a total of 28 soil samples were submitted
for laboratory analysis as specified in RAP. As indicated in Tables 4-6, a total of 46 soil samples were
collected and analyzed for the detection, of volatile organic compounds by EPA Method 8260. Analytical
results for the 18 soil samples that were out of holding time are included. All of the 46 collected samples
were analyzed by EPA Method 1311 (Toxicity Characteristic Leaching Procedure) (TCLP) for (VOCs,
SVOCs, Metals, and PCBs).
A complete copy of the laboratory test results and chain -of -custody are contained in Appendix E. A
summary of analytical results for VOCs by EPA Method 8260 is presented in Table 4. A summary of
analytical results for TCLP (VOCs, SVOCs and PCBs) is presented in Table 5. A summary of analytical
results for TCLP Metals is presented in Table 6.
As indicated in Table 4, the following VOCs were detected in concentrations exceeding the, October 2008,
N. C Inactive Hazardous Sites Branch Protection of Groundwater Soil Iemediation Goals: benzene,
toluene, xylenes, 1, 1 dichloroethane, 1,1 dichloroethene, methylene chloride, tetrachloroethene,
trichloroethene, 1,1,1 trichloroethane, 1,4 dichlorobenzene and vinyl chloride. As indicated in Tables 5 and
6, the soil analytical results for TCLP (VOCs, SVOCs, PCBs and metals) detected no targeted compounds
or metals above their respective TCLP regulatory limit.
2.2.2 Soil Remediation
As indicated in the February 2008 RAP, the analytical results derived from the baseline soil sampling event
would determine whether the waste removed from the scil source area is hazardous or non -hazardous.
Additionally, it would determine if the waste material needed to be disposed of at a Subtitle C or Subtitle D
disposal facility or if the waste needed to be treated through a MSD unit.
As indicated above, the analytical results derived from the baseline soil sampling indicates that the waste to
be removed from 75' x 50' x 5' soil source area is non -hazardous and can be disposed of in a landfill
without pretreatment. Based on the results of this assessment, the waste material has been pre -approved for
disposal as a special waste at Republic Services Inc. Foothills Env'Ironmental Landfill in Lenoir, North
Carolina. Waste profiling information is contained in Appendix F.
According to the February 2009 RAP, the initial 8 feet of overburden in the specified 75" x 50' soil source
area (approx. 30,000 ft3) in Area 3 would be removed with a track excavator. The overburden would then
be sorted.and stockpiled on site, on plastic and adjacent to the excavation. Although unlikely, if
encountered, any intact drums or drums containing residue would be segregated and containerized for
appropriate off site disposal. All stockpiled soil from the 8 ft of overburden would then be covered with
plastic and utilized for backfill following excavation and remedial activities in the soil source area "hot
spot" excavation.
Due to large volume of subsurface debris encountered during Piedmont's baseline soil assessment
additional disposal of waste material from the 8 ft. of overburden will likely be necessary to remove
Piedmont Industrial Service - CMC 3 3/19/2009

subsurface obstructions prior Lu the chemical mixing and injection of.—_V compounds within the soil
source area after excavation activities.
2.2.3 Revised Soil Remediatioia
As indicated above, the analytical results derived from the baseline soil sampling event on composite soil
samples collected at a depth of 8' to 13' bgs determined that the waste to be removed from 75' x 50' x 5'
soil source area is non -hazardous (Tables 4-6). Due to large volume of subsurface debris encountered
during the baseline soil assessment, Piedmont will remove and stockpile the top 1-2 ft. of soil cover on site,
on plastic and adjacent to the specified 75' x 50' soil source excavation area. Additionally, Piedmont will
remove and separate the large subsurface debris material from the excavation in the 2-8 ft. interval to the
extent of being practical and feasible. All bulky trash items will be sent to the landfill. According to
representatives at Republic Services Inc,, no additional waste profile sampling will be required to dispose
of the debris material removed from the 0-8 ft. interval. Any concrete block or stone that is removed from
the excavation will be relocated to the northern portion of Area 3, to subsequently be covered with soil
along with other concrete waste already located in this area. All remaining soil from the overburden will be
stockpiled with the initial 1-2 ft. of cover and utilized for backfill following excavation and remedial
activities in the soil source area excavation.
Following removal and sorting of the 8' of overburden, the 75' x 50' x 5' soiI source area "hot spot"
(approx. 18,750 ft3) at a depth between 8' to 13' below grade surface bgs will be excavated. The removal
and disposal of the large debris material in the 4-8 ft. interval along with the removal and disposal of the
"hot spot" in the 8-13 ft. interval will remove subsurface obstructions prior to the chemical mixing and
injection of HRC compounds within the soil source area. The non -hazardous waste material derived from
the 8' of overburden and all material from the 8' to 13' interval will be temporarily stockpiled on plastic
adjacent to the excavation and loaded into dump trucks. The loading area for the dump trucks is presented
in Figure 4. The dump trucks will transport the waste material from the Site to the Republic Services Inc.
Foothills Environmental Landfill in Lenoir, North Carolina.
Following the completion of the analytical soil testing, a summary of the analytical laboratory results were
provided to Mr. Drew Baird at Regenesis (suppliers of HRC, HRC-X and HRC-A) in order to confirm the
effectiveness and appropriate amounts and types of Regenesis products to be mixed in the base of the
excavation at the 13' to 16' interval. The revised volumes and types of Regenesis products that will be
utilized for soil and groundwater remediation in the base of the excavation are discussed in Section 2.3.2.
Piedmont will conduct the excavation of the 75' x 50' x 13' soil source area in three phases to avoid having a
75' x 50' x 13' excavated area open. Each phase will consist of the removal of one-third of the total
excavation area to a depth of 13' bgs. After the completion of each phase, the proper volume of HRC
compounds will be mixed in the base of the excavation at the 13' to 16' interval (see Section 2.3.2). Following
the mixing of HRC compounds, the excavation will be backfilled with stockpiled fill material and clean off -
site fill dirt from the Vulcan Materials quarry in Elkin. Health and Safety documentation for the soil
excavation and disposal activities is included in Appendix B. A budgetary cost estimate to complete the
proposed revised soil remediation activities is contained in Appendix G.
On March 12, 2009, Piedmont collected a composite soil sample from the material that will be utilized as
backfill for the above mentioned excavation from the Vulcan Materials quarry in Elkin. The collected soil
sample was placed in laboratory prepared containers and shipped on ice to Research & Analytical (R&A)
Laboratories (NC ID 9 34) in Kernersville, North Carolina for laboratory analysis. The soil sample was
Piedmont Industrial Service - CMC 4 3/19/2009

analyzed by EPA Method pz-d0 for the detection of VOCs. As indicated in the laboratory test results in
Appendix H, no volatile organic compounds were detected in the backfill soil sample.
2.3 Baseline Groundwater Assessment
As indicated in the February 2008 RAP, the analytical results derived from the completion of the baseline
groundwater assessment will be used to determine geochemical parameters and volumes of HRC
compounds that will be utilized for the remediation of soil and groundwater. Health and Safety
documentation for the baseline groundwater assessment is included in Appendix B.
On December 16, 2008, Piedmont collected groundwater samples for the baseline groundwater assessment.
The following monitoring wells located in the immediate vicinity of the soil source area were sampled to
document baseline conditions: MW-2S, MW-2D, MW4, MW-6 through NM-9 and MW-16 and MW-19
(Figure 1). Monitoring wells MW-17 and MW-18 were specified for sample collection in the RAP.
Unfortunately, the wells were dry and as a result could not be sampled.
Groundwater sampling activities were completed in accordance with the technical methods specified in
Appendix C. Prior to sampling each of the monitoring well, the depth to water was gauged using an
electronic level probe (Table 8). After recording depth to groundwater measurements and prior to sample
collection, the monitoring wells were purged by removing three well volumes of water from each of the
wells. The following geochemical parameters: dissolved oxygen, (QRP), specific conductivity, pH, and
temperature were recorded prior, during and after purging activities (Table 2). A disposable Teflon bailer was
used to purge the wells. A groundwater contour map based on the December 2008 gauging data is shown
on Figure 5.
Collected samples were placed in laboratory prepared containers and shipped on ice to Empirical
Laboratories (NC ID # 643) in Nashville, Tennessee for laboratory analysis.
2.3.1 Groundwater Sampling Results
As specified in RAP, collected groundwater samples were analyzed by EPA Method 8260 and for the
following geochemical parameters: dissolved oxygen, oxidation reductions potential (GRP), ferrous iron,
specific conductivity, pH and temperature. Additional laboratory analysis of the samples included alkalinity,
nitrate, sulfate, chlorides, total organic carbon (TCC), methane, ethane, total and dissolved iron and
manganese. The groundwater samples were also analyzed for 5 metabolic acids: lactic, pyruvic, acetic,
propionic and butyric.
A complete copy of the laboratory test results and chain -of -custody are contained in Appendix E. A
summary of analytical results for the December 2008 groundwater sampling event is presented in Table 3.
A historical summary of groundwater sampling results is presented in Table 1.
As indicated in Tables 1 and 3, the following monitoring well samples detected VGC contaminant
concentrations exceeding 15A NCAC 2L water duality standards: MW-2S, MW-4, MW-6, MW-7 and
MW-8. The following VGCs were detected in concentrations exceeding 15A NCAC 2L water quality
standards: benzene, 1,1dichloroethane, 1,2 dichloroethane, 1,1 dichloroethene, methylene chloride,
tetrachloroethene, trichloroethene, 1,1,1 trichloroethane and vinyl chloride. As in previous assessments, the
highest VQC concentrations were detected in monitoring well MW4. No VGCs were detected in the
groundwater samples collected from wells MW-16 and MW-19. A total VQCs isoconcentration map based
Piedmont Industrial Service - CMC 5 3/19/2009

on the December 2008 grouh-,, ater sampling event is shown on Figu-- ..- For comparison, a previous
historical VOC isoconcentration Map from the February 2008 RAP is shown on Figure 7. Overall the shape
of the VOC plume has remained relatively the same with the highest concentrations of VOCs being
detected in monitoring well MW-4.
Additional laboratory analysis of the samples included alkalinity, nitrate, sulfate, chlorides, total organic
carbon (TOC), methane, ethane, ferrous iron, total and dissolved iron and manganese. The collected
groundwater samples were also analyzed for 5 metabolic acids: lactic, pyruvic, acetic, propionic and
butyric. The summary of these results are presented in Table 3. The additional laboratory analysis of the
samples will provide a baseline to determine the long term effectiveness of groundwater remediation.
2.3.2 Groundwater Remediation
As specified in the RAP, the removal of the soil source area "hot spot" and the chemical mixing of HRC
and HRC-X and injection of HRC, HRC-X and HRC-A was proposed to remediate existing soil and
groundwater impacts. Following the completion of the analytical testing, a summary of the collected data
along with pertinent groundwater reaps were provided to Mr. Drew Baird at Regenesis in order to confirm
the effectiveness and appropriate amounts and types of Regenesis products to be utilized in the proposed
remedial action.
Utilizing the recommendation from Regenesis and the results of the baseline sampling event to finiher
refine the approved RAP the following groundwater remedial action is proposed:
■ Chemical Mixing of HRC and HRC-X.- Piedmont will blend in -situ soils at the base of the soil
source excavation with a track excavator bucket at a vertical interval of 13' to 16' bgs (see Section
2.2.3). Based on the previous and recent baseline groundwater assessment analytical results and
correspondence with Regenesis, 330 lbs of HRC and 690 lbs of HRC-X will initially be mixed at
the base of the excavation to address groundwater and soil impacts, The excavations will then be
back filled with stockpiled soils and clean off -site fill dirt.
Chemical Injection of HRC A in Excavation: Additional injection within the excavation will be
necessary after the excavation is backfilled to address groundwater impacts in the immediate
vicinity of the soil source area. Based on the previous analytical results and correspondence with
Regenesis, 1,894 gallons of 3D Microemulsion consisting of 1,410 lbs of HRC-A and 1,690 gallons
of water will need to be injected inside of the filled excavated area. The Microemulsion will be
injected via a Geoprobe into 20 injection points on a 15' x 15' offset grid with 15 feet between
points and 15 feet between rows inside of the filled excavation area at a vertical interval of 15' to
2V bgs for a total of 20 injection points (Figure 8). A total of 93 gallons of the 3D Microemulsion
will be injected for each injection point. The injection of HRC-A into the base of the excavation
replaces the injection of 480 lbs of HRC and 720lbs of HRC-X that was initially proposed in the
approved RAP.
Chemical Injection of HRC A for Plume: Based on the analytical results of assessment activities
to date and correspondence with Mr. Drew Baird at Regenesis, 22,764 gallons of 3D Microemulsion
consisting of 17,220 lbs of HRC-A and 20,640 gallons of water will need to be injected outside of
the excavated area to remediate the groundwater plume in the immediate vicinity of the soil source
area. According to Mr. Drew Baird at Regenesis, the Microemulsion will be injected via a Geoprobe
into 100 injection points on a 15' x 20' offset grid (15 ft between points and 20 ft between rows)
Piedmont Industrial Service - CMC 6 3/1912009

outside of the excava,ed area at a vertical interval of 7' to 21 ogs (Figure 9). A total of228 gallons
of the 3D Microemulsion will be injected for each injection point. Based on Piedmont's assessment
activities, the spacing of injection points may vary depending on subsurface debris within the
injection area. The total numbers of injection points, interval between points and the volume of
injected chemicals have changed from the 150 injection points and 156 gallons of the 3D
Microemulsion for each injection point initially proposed in the approved RAP.
The mixing of HRC and HRC-X and the injection of HRC-A will be done in accordance with the
manufactures specifications. A Health and Safety plan pertaining to the chemical mixing and injection of
HRC compounds in contained in Appendix F. A budgetary cost estimate to complete the proposed injection
of HRC-A to remediate the groundwater plume and the injection area is contained in Appendix G.
3.0 Post -Remedial Activities in Accordance with RAP
As indicated in the RAP the following post remedial activities will be completed:
■ Completion of two groundwater monitoring events. The first at two years after treatment and the
second at five years after treatment. The following groundwater monitoring wells will be sampled
during these events: MW-2S, MW-21), MW-4, MW-16 through MW-19, and MW-6 through MW-9.
Groundwater samples collected during these events will be analyzed by EPA Method 8260 in addition
to the following geochemical parameters: dissolved oxygen, oxidation reductions potential (GRP),
ferrous iron, specific conductivity, pH, and temperature. Laboratory analysis of the samples will
include alkalinity, nitrate, sulfate, chlorides, total organic carbon (TOC), methane, ethane, total and
dissolved iron and manganese. Additionally, collected groundwater samples will be analyzed for 5
metabolic acids: lactic, pyruvic, acetic, propionic and butyric. The laboratory analytical results derived
from these sampling events will determine the long -terns effectiveness of groundwater remediation.
■ Post -Remedial Activities will also include the abandonment of monitoring wells (MW-10 through
14, MWA S and 1D, MW-15, MW-5, MW-3S and 3D) except for those required to monitor
treatment progress in the vicinity of Area 3. All monitoring wells will be abandoned in accordance
with applicable state guidelines.
A budgetary cost estimate to complete the post -remedial activities is contained in Appendix G.
3.1 Additionally Proposed Post -Remedial Activities
Following completion of the baseline sampling and site visit completed with NCDENR personnel,
Piedmont proposes to complete the following Post -remedial activities that were not addresses in the
February 2008 RAP: I -
■ Piedmont will move and provide adequate sail cover for the surface concrete debris located in the
northern portion of Area 3. Any large concrete block removed from the remedial excavation will be
relocated to this area and covered with enough soil to provide proper drainage and provide a surface
adequate for the reseeding of grass to stabilize the soil cover.
I Piedmont industrial Service - CMC 7 3/19/2009

• Piedmont will provide additional backfill over the entire work area to provide an adequate soil cover
over the remaining buried debris. The area will subsequently be graded to provide proper drainage
and provide a surface adequate for the reseeding of grass to stabilize the soil cover.
A budgetary cost estimate to complete the additional post -remedial activities is contained in Appendix G.
4.0 Planned Progress Reporting,
The following is a revised schedule for progress reporting activities:
• Weekly written or telephone progress reports will be provided each Monday to the NCDENR during
the soil and waste remedial action.
• A Construction Completion Report will be submitted to the NCDENR in May of 2009.
Periodic Progress Reports will include the completion of two groundwater monitoring events the first
at two years after treatment and the second at five years after treatment (with report). The laboratory
analytical results derived from these sampling events will determine the long-term effectiveness of
groundwater remediation.
5.0 Scheduling of Remedial Activities
As indicated in above, the site has been cleared and prepared for the continuation of the proposed remedial
activities. As of March 12, 2009, the park has been closed to the public and will remain so until the
proposed remedial action field work is completed. An estimated timeline to complete the proposed
remedial activities at the Site is shown in Table 9. It is estimate that it will take approximately 60 days to
complete excavation and injection activities. Pending approval from the NCDENR, a mid to late April
2009 starting date is proposed for Implementation of the proposed remedial action.
Piedmont Industrial Service - CMC 8 3/19/2009

Analytical Method
EPA 8260
m
C
C
G
C
p7
C
C
y
m
Itl
N
of
Q1
=
0]
C
C
C1
W
Al
9
m
r
Q1
m
N
#
C
r-
m
C
3
6
R1
[]
G1
d
r-
0
In
N
N
C
G
11l
m
C
C
P
[.
4
U
=
C
ry a
O
A
n
O
O
a?
7.
ym
❑
N
0
0L7
O
0_
N
D
i1
=
N
_
N w
C
`
CV0]
a
b
S
u ll
ugll
u 1l
u A
u 1l
ugll
ugll
u ll
ugli
ugA
ugA
u A
u A
U911
A
u n
u 1l
ugA I
ugil
u ll
ugli
u 1I
ugh
u A
MW-2S
12/16/2008
3.60
NO
NO
0.96
0.48
13
57,0
8.0
130.0
ND
3.80
13.0
ND
0.28
::5:i::
0.57
7.9
:-A.5 •
2/=4:
3.0
3.7
0.31
1-10
279,4
MW-20
12/1612008
ND
NO
NO
NO
NO
NO
NO
NO
1.4
NO
0.37
0.18
ND
NO
NO
NO
NO
ND
11
NO
NO
NO
NO
3-05
MW-4
12MV2008
ND
�:21:0:
NO
NO
NO
6.1
1960 V
NO
4,200
NO
240.0
34.0
67.0
ND
NO
ND
NO
•:O1;0 ;
:1.000
NO
NO
NO
NO
6.619.1
VW-6
12I1612008
NO
NO
NO
ND
NO
NO
0,46
NO
11.0
ND
4.9
0.38
NO
NO
NO
ND
ND
0.38
NO
NO
NO
NO
NO
17A
MW-7
12/16/2008
NO
ND
ND
ND
ND
NO
0.95
NO
2.7
NO
25.0
5.2
NO
NO
ND
ND
ND
;-
NO
NO
NO
ND
NO
40.7
MW-8
12/1612008
0,86
ND
NO
NO
NO
3-0
110-0
NO
184.0
0.49
36.0
7.0
1.8
NO
NO
ND
1 5.9
!,X91:
•:13.4:
0.69
0.8
ND
0.30
363.7
MW-9
12MW2008
NO
NQ
ND
NO
NO
I ND
NO
I NO
0.2
NO
NO
ND
NO
NO
ND
NO
ND
NO
NO
NO
NO
NO
NQ
0.2
MW-16
12/16/2008
NO
NO
NO
NO
I NO
I NO
ND
NQ
NO
NO
NO
NO
ND
ND
NO
NO
NO
ND
NO
NO
NO
NO
N0
0.00
MW-17
12/16/2008
DRY
MW-18
12/16/2008
DRY
MW-19
12J1812008
NO
NO
NO
ND
I NO
I NO I ND
I NO
ND ND
I ND
NO
NO
ND
NO
NO
NO
NO I NO
NO
NO
NO
NQ
0
15A NCAC 2L Standards
1
1000
550
1530
1 70
1 50 1 NS
I NS
1 70 0,38
1 7
70
1 4.6
1 100
1 0.7
70
1 2.8
10.0151 200
1.4
24
70
7p
NS
15ANCAC2BS18nd8f(J5"j
51
1 11
1 97
1670
1 LD
1 140 1 550
1 NS
I 20,ODD 1 37
1 5.400
4,900
590 1
10,000
3.3
61
1, 30
1 2.4 L 4-4
1 1001
4701
Lb
1 320
NS
ND Not detected
=15A NCAC 29 Standards. According to Connie Brewer QNCOENR-DWQ, Class C stream use lowest of Human Health Column or Freshwater Aquatic Life Column. LD=Limited Data her NCDENR-DWO,
m
tewL
N
p
�
Total Iron and
Soluble Iron and
[q
"'
47
M
M
" t
Analytical Method
MEE Organics
Metabolic Acids
!Ulan anese
Ma anese
�
ERA 300.E
In
m
-19
N
U
v
p
52
u
nN
W
C:c
c
a
`�
rn
rn
c
a
m
m
�
O
m
°
g
2
N
an
us
w
¢
0.
r>7
LL
rru
[]
uA
UQA
u/1
ull
uA
uA
uA
uA
un
uA
uli
ull
I mil
rrroA
I mgA
I m
mn
i m11
700
4.0
7.7
ND
ND
NO
NO
NO
13.200
7.370
30.0
6,2130
310
21.7
-0.0501
55.2
0.023
1 4.4
MW-25
12/1612008
MW 2❑
12/16/2008
2.6
NO
ND
NO
ND
NO
NO
NO
15,100
2.690
30.0
2,430
110
13.2
<0.0501
132
1.4
1 1.7
MW-4
12/16/2008
2.800
28.0
9.8
NO
NO
ND
NO
NO
52,500
2 060
18.500
1,790
168
23.3
<0.05
20.5
4.5
3.2
MW-6
12/1612008
8,400
NO
NO
NO
NO
ND
NO
NO
18.000
188
30.0
98A
37.8
4.3
<0.05
<0-5
3.6
3.8
MW-7
1211612WS
6,800
NO
ND
NQ
NO
NO
NO
NO
24,700
996
175
752
94.5
5-0
<0.05
a0.5
5.8
3.7
MW-8
12/16/2008
280
2-4
1.8
NO
NO
NO
ND
NO
57,800
3,520
905
2,710
191
14.8
<0,05
37.2
2.3
3.0
MW-9
1211W2008
3.3
NO
NO
N[]
ND
ND
NO
ND
397,000,
4,730
30.0
2.770
97.3
9.5
0.29
26.7
0.45
62
MW-16
1211612008
2.1
Np
ND
ND
NO
NO
NO
NO
115,0001
1950
30.0
116
114
3.7
2.2
15.7
0.24
1.2
MW-17
1211fi12008
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
MW-18
12/1612008
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
MW-19
12/16/2008
1.0
NO Np NO NO
NO
151,000
2.240
30.0
3,0
21.7
7.5 0.41
16.15A
NCAC 2L Standards
NS
=NSNS
NS NS NS NS
NS
NS
I
NS
i
N5
NS
NS
NS NS
NS15A
NCAC 2t3 Standards
N5
NS NS NS NS
N5
N5
NS
NS
NS
NS
NS NS
NS
NS
N5
Results In bald exceed 2L Standards
Shaded Results exceed 213 Standards

TABLE 2:
GenchemlcaAl Data
CMG Hoking
EJkln, NC
Well Number
Well
Depth
Depth to
Water
(FT.
Before Purga
Middle Purqe
After Purge
pH
Conductivity
(PSlcm)
Dissolved 02
(mgll)
Redox (mV)
Temp °C
pH
Conductivity
(PS1Cm)
Dissolved 02
(mgd)
Redox (mV)
Temp °C
pH
Conductivity
(PS/CM)
Dissolved 02
(mg l)
Redox (mV)
Temp °C
Mw-2s
19.50
15.11
6.6
530
2.0
133
9.9
7.0
585
3.5
53
11.1
6.8
540
1.9
92
11,2
MW-2d
38,00
14.05
8.1
503
2.0
140
12.1
B.2
250
1.67
129
12
7.2
271
2.68
175
12.3
MW-4
19.50
12,29
7.4
371
1.1
89
12.4
7.2
51B
1.55
67
13.1
7.1
394
1,55
140
13.3
MW-61
17.35
13.07
7.7
146
3.21
B7
13.3
7.5
143
2.98
11
13.6
7.0
144
3.7
160
12.3
VW-7'
20.36
16.00
7.7
255
2.9
62
12.4
7.4
259
97
97
13.1
6.7
205
2.41
34
1IA
MW-8'
19.60
15.22
7.3
455
1.8
123
13.3
7.4
480
1.48
81
13,1
7.3
521
2.7
B9
11.4
MW-9'
19.85
14,27
6.6
300
2.7
78
12
6.5
1 324
3.36
114
11.5
7,8
290
2.7
150
._-
MW-i6
17.7
13.03
6
146
2.2
119
10.3
6.1
245
2
122
11.5
7
283
3.05
164
VW-19
18
11.76
7.3
6
6.21
45
10.3
6.5
64
1 5.91
45
10.3
7.2
131
5.74
127
MW-17
DRY
MW-18
DRY
Notes. Data Collected on 12115(before S middle)MG108(after)
' = 1 inch Diamelm Well
mgA= milligrams per Ifter
pStcm= microseimens per centimeter
mv= m1MV0 is

TABLE 8 storical Summary of Groundwater iging Data
DATE
WELL
ID
CASING
ELEV.
DEPTH TO
WATER
(FT)
TOTAL DEPTH
OF WELL
(FT)
WATER TABLE
ELEV.
(FT)
SCREENED
INTERVAL
(FT)
02/08/05
MW-1s
895.70
11.11
24.50
884,59
11.8-22.2
02/07/07
MW-15
895.70
12,19
24.50
883.51
11.8-22.2
02/08/05
MW-11)
895.76
11.25
42.10
884.51
31.5-41.8
02/07/07
MW-1 D
895.76
12,32
42.10
883.44
31.5-41.8
02/08/05
MW-2s
887.49
6.69
19.50
880.80
8.6-19.0
01/31107
MW-2s
887.49
7.14
19.50
880.35
8.6-19.0
D4106107
MW-2s
887,49
6.96
19.50
880.54
8.6-19.0
12/15108
MW-2s
887,49
15.11
19.50
872.38
&6-19.0
02/08105
MW-2❑
887.61
7,10
38,10
88ff.51
27.7-38.0
02/07/07
MW-2❑
887.61
7,85
38,10
879.76
27.7-38.0
12/15/08
MW-2D
887.61
14.05
38A0
873,56
27.7-3&0
02109/05
MW-3s
882.45
14A 1
20.20
866,34
9A-20.0
02/07/07
MW-3s
882.45
15.72
20.20
866.73
9.4-20.0
04106/07
MW-3s
882A5
15.9
20.20
866.55
9A-20.0
02/09/05
MW-3D
882.28
13,98
34,50
868.30
24.2-34.5
02107/07
MW-3D
882.28
14.49
34.50
867.79
24.2-34.5
04ID6107
MW-3D
882,28
14A
34.50
867.88
24.2-34.5
02/09/05
MW-4
886.58
6.20
19.50
880.38
8.7-19.0
01/31/07
MW-4
886,58
6,58
19.50
880,00
8.7-19.0
04/06/07
MW-4
886,58
7,85
19.50
87&73
8.7-19.0
12/15/08
MW-4
886,58
12,29
19.50
874.29
8.7-19.0
02/08105
MW-5
882,60
14.05
18
86&55
8.0-18.0
02/08107
MW-5
882,60
15
18
867.60
8.D-18.0
04/06107
MW-5
882,60
14.93
18
867.67
8.0-18.0
02/09105
MW-6
880.81
11,35
17.35
869.46
6.0-16.0
02/07/07
MW-6
880.81
11.6
17.35
869.21
6.G-16.0
04/06107
MW-6
880.81
11.55
17.35
869.26
6.0-15.0
12/15/08
MW-6
880.81
13.07
17.35
867.74
6.0-16.0
02/09/05
MW-7
883.82
14.58
20.36
869,24
8.0-18.0
02/07/07
MW-7
883.82
14.98
20.36
868.84
8.0-18.0
0410&07
MW-7
883.82
14.9
20.36
868,92
8.0-18,0
12/15/08
MW-7
883,82
16
20.36
867.82
&0-18,0
02109/05
MW-8
883.75
14.20
19.6
869.55
3.0-18.0
02107/07
MW-8
883.75 1
14.20
19.6
869.55
3.0-18.0
041D6107
MW-8
883.75
14,40
19.6
869.35
3.0-18.0
12/15/08
MW-8
683,75
15.22
19.6
868,63
3.0-18.0
02/09/05
MW-9
882.90
13,38
19,58
869,52
3.D-18.0
02/07/07
MW-9
882.90
13.69
19.58
869.21
3.0-18.0
04106107
MW-9
882.90
14,05
19.58
868.65
3.0-18.0
12/15108
MW-9
682.90
14,27
19,58
868.63
3.0-18.0
02/10105
MW-10
887.44
16.84
22.55
870.60
5.0-20.0
02/08107
MW-10
887.44
Dry
22,55
❑
5.0-20.0
04/06/07
MW-10
887.44
17.2
22,55
870.24
5.0-20,0
02/10/05
MW-11
884.03
14.54
18,75
869.49
7.0-17.0
02/08/07
MW-11
884.03
15.2
18,76
868.83
7.0-17.0
04/06/07
MW-11
884,03
14.82
18,75
869.21
7.0-17.0
02/10/05
MW-12
887,33
17.13
23
870.20
6.0-21.0
02/08/07
MW-12
887.33
Dry
23
Dry
6.0-21.0
04/06/07
MW-12
887.33
Dry
23
Dry
6.0-21.0
02/10/05
MW-13
884,74
11.96
19.75
872.78
8.0-18.o
OM8107
MW-13
884,74
11.8
1935
872.94
8.0-18.0
04106/07
MW-13
884,74
11.87
19.75
872.87
8.0-18.6
02/10/05
MW-14
884,68
13,62
2D.10
871.06
8.0-16.0
02108/07
MW-14
884M
13,85
20.10
870.83
SA-18.0
04/06/07
MW-14
884.68
13.82
20.10
870.86
8.0-18.0
04/05107
MW-15
884,32
12.15
20
872.17
10.0-20.0
04/05107
MW-16
886.50
6.65
17.7
879.85
12.7-17.7
12/15/08
MW-16
886.50
13,03
17.7
873,47
12.7-17.7
04/05/07
MW-17
888,97
8,87
14.6
880,10
9.6-14,6
1211W08
MW-17
688,97
Dry
14.6
Dry
9.6-14.6
04/05/07
MW-18
885.24
8
16.4
877.24
9.6-14,6
12115/08
MW-18
885.24
Dry
16.4
Dry
9.6-14.6
04/05/07
MW-19
886.74
6.82
18
879.92
13.0-18.0
12/15/08
1 MW-19
886.74
11.76
18
874.98
13.0-18.0

0 0
Tar $ A41MtT KMOSIAM
RR WX9&2 AT INTERSECTION GP
RA&JMW t PAVED ROAD
95 E- 1295t4.54
���ST
f
1. }
1
4
a7s
TP5 p
874
e■ - 9g l
13 ' ❑TP4 i1` 87i
REp2EAriC7gmC MUDS YTP3pTp8©6, f 4 a7o
NOTICE: ELECTRp6c EIPA111N0 FLES ARE Not To BE EANSSWEL CERTnM DOCLWEKTS
PN aA� Af �1TEIR�i
sr+exstertpl N NOW -OW "W)
RE LNr
S 3Y ,15
309.45' N
s (DENT) rroofh
LAKE DISTRICT PROPERTIES
Irw-1-S LLC
1 D.B. I05]/225
w-t-o
spy
F�*
uWrpwN� >��t
[@7 ATIERS]
DE"ATEO 111F$
oCan1 - 20'
Y HAROLD ADAMS et ux.
sEcoNOARr sal+ 1 ❑� 1 D.B. 840/693
WO TPI
N- 11281,41 • _ _ - :•TP
rA1w�¢-p f r
E- 13356.55 J WW-2-s r
i] 7x
1 I */ �w'1
Sir TPi �_ ` DRi :.
9dlci J
_ r z r aa7,82
rax-sa4.a
11 asa.;T10eeas3
i J77 IySt - a °
MW-151
GROUND AT UW-15
(Aba Mao) i I Mw-s ..3
CHA THAM LAND CORP.' • �_� _ — OF Ito
D.B. 770/I082 PP '""-sue ,dam Ism +94
-13 MW-+1 MW-10 VX!
M -12
WW-14
S/ L10 IRpN -Y�' �JTidIPY �YIIII)ir SW-2
YADKIN RIVER -�
SW-1 7AOM LiTW;r
Foothills Forestry & Surveying
WX '_
N. sr$10M
E- !Zsl0.27
CHA THAN! HOLDINGS
nr s CORP,
D.B. 77011087
1
N 1134 '.6
E 17Ni3,353f
r
I
BOUNDARY i14
BOUNDARY LM WIN
CENIE4 OF S MEAN
rP"82S
Cz,
AAM/=DVKW AMC
I�i]1
P
Avon~ MU [rlb
oFG-AIY� rd,
asr Mr rN)
fW
G1'9lAO JUWFP• A aMA
&
WJW&MOU (go
GRAPHIC SCALE
Piedmont Industrial Semces Inc. ISO 0 75 ISO 300 Boo
I6Tfl Fi Lowery Street P.O. Box 525 o��r a.- aws
IIkin, N.C. 28621 PUMN NIL, ,
Winston Salem, N.C. 27101 .a7r Z-. �ss ..+
[phone] (Tele.) t336) 835-M6 (Fels-)
(33t'a) 722-6529 (Fax) (33B} 835-8386 (Fax} �� ( [N FEET }
1 inch = 150 ft"
SW-4
0
Figure 5:
Groundwater Contour Mop
Contour Interval is 2 feet
I ;r-J
fR�

0
n�
x
i
RppyVrsouc
E• tpesp.27
�.
F�
�f
RR SPKE{Sy AT MTERSECIM Or,
RAl1.It0AD rk PARED ROAD
N. tf944.65
C: t T3 1.51 BE��•
S�
•��SS
C
Pit NAIL At MTERLIK
wTvt9ECr" cR1tM ■ WQKJO o DRr[y
'T[ L■ r
10a r ■
ti� �/a'snLlD EaaF, nuotn
�' • � tanrl
LAKE DISTRICT PROPERTIES
,_D LLC
■ECRSATiNft Ft•
D.B. 1051/225
401WORW4 VPEU
(BY mints) yytF.
+� DENT DEPTH - 20' e�
CJbD STAKED 17/08/06
Nana, ELECTRONIC DRAwm FR.ES ARE NOT rD DE C0NSOERED MRTWU D=%"r9
— il
HAROLD ADAMS et ux.
D.B. 040/693
HRC—A 3D Microemulsion
r -
Injection paints in the
75' X 50' Soil source
l Area
�9 �p y
� •
RECREAF.9IrcR1. f1ELD5
SC[¢/p4RY 1�
E�pppp
QE'✓��2�i
artaf7-O
� �
CHATHAM HOLDINGS CORP.
D.B. 77011087 —
_ r �
i� 11Yf-rS �r MW-7
SAW- I5A 1 `
■D,A�ARr LI,4 wTN
CENTER OF STREM
A UW-9
S uw-3-S
D
CHATHAM LAND CORP.' — •� - - - - - r �•GF
A•B. 770/1062 - ® MW-s�_�Atst
y 0 WDN
NORTH 8A OF RRNERR
cm
Swdt%S
A7+[1•/rt1vwom, par
acorn uArx
�$
--me
ra.Jvw mu r+•
rfo-F�nC e0v
Nit nr r✓pJ
w
QNZW IIfr NW A r C4
0
sawx+rr u m s Ter rsq
mW--tt UW-10 +IF nLr ® MW-12 Figure 8:
MW-t4
® �_ N Sail Source Area 'hot spat' Injection
YADKIN RIVER
7 'rAAnw L,xwre
GRAPHIC SCALE
720 80 0 00 '20 350
{ IN FEET
I inch • 120 !t

0 0
PK RAID Ar �IE11LuE
7eY i 11 *Is1AR* eENpmurc KTU=eoN (r1H %
RR ¢7fi{ AT NTRSEC7M OF
itA� RoAo PAYE) ROAD S S 3 � 45' III
p� 13944.65
E• 1295r.54 SZRF^F
��ASZ
�PlN ,1
DISTRICT PROPERTIES
LLC
D.B. 2051 /225
NCi10E: ELECTRO-C ORAVIW FILM ARE NDT 70 BE CONSIDERED CERTIMU OOCLMENTS
�iFS7'FATp7 Y,IES
.IAM.4 -
„ . vE:'TM ao'
_ 1P6© Groundwater Plu e Injection Area
.(Approximately k3 ,000 square feet)
,2+aisSs, 4 TP5
•� ` Y 1
4 ins - ;l
R RECRE.e 71oKu FFUUs g❑ W-4-
Uw-1 \111,° C �1 HAROLD ADAMS et ux.
SECOYOARY' rar 1 \ 1 D.B. 840/693
ELE�.aa►�� I —I TPI -P 11
N- I 1281.41
C" �
Ed 1335&56
CHATHAM HOLDINGS CORP. I v� 2ny 79
D.B. 770/1087 l
- L-SW. 1
8;oco � f 77.12 uq/I
000uDAltr [JW
ooe-
r f 65 vg A J
MW-15
11 CR-884.0 / �Z
~~ % MW-15 �-
GR-U2- 2t
006WARY LW "TH
CERM Cs s7RCAY _- CR(Dl1f1D AT VW-15
(Abwdenod) jl 0.2 r SIIf-j 1
—
uW-]-S
_ 1 �_ i 6a2.B -
PP
CHATHAM LAND Ci1RP. OF
I7.8. 770/1082M -10 Yw-s®_� �,I g __�R►
r YW-11_,�pY W
Mx-12
Mx-s4 � �
SW-2
SR�/ap-(sauOargN� 'SiAa4rGowrY A
�•3R SAW t�R�Y,in YADKIN RIVER -�
MOM C"Tr
Foothills Forestry & Surveying
P.C. Box 525 pmL;CrA� 051M ISO
Ellin, N.C. 28621
[phone] (Tele-)
[phone] (Fax)
d aeawn 4CWSM A PCU
A A.a .,#. s Q-4
GRAPHIC SCALE
75 IN -Me
( 1N FEET )
1 inch = 150 tL
6U0
SW-4
0
`o
Figure 9:
Groundwater Plume Injection Area Map

CMC Holding Corp.
Environmental Site Assessment Report
Piedmont Industrial Services, Inc.
June 14, 2005
Purpose: Monitoring We]1 Installation and groundwater contamination assessment sampling-.
9 Monitoring wells installed February 2005.
m
Total
Water
Depth
Depth
MW-6
16.0
8.0
MW-7
18.0
8.0
MW-8
18.0
8.0
M W-9
18.0
12.0
MW-10
20.0
10.0
MWA 1
17.0
12.0
MW-12
21.0
8.0
MW-13
18.0
12.0
MW-14
18.0
12.0
Sampling February 9, 2005, results in ug/L.
Rock
Depth
16.0
18.0
18.0 (installed through trash, 4-16'?)
20.0
20.0 (trash 1- 6')
17.0 (trash 4-5)
21.0
18.0 (trash 13- 8')
18.0 (trash 2-12')
MW-8
MW-9
chlorobenzene
2.4
no detects
chloroethane
16.0
1,1 dichloroethane
64.6
MW-10
1,1 dichloroethene
14.3
chloroethane
5.0
cis 1,2dichloroethene
2.6
carbon disulfide
1.2
1,1,1 trichloroethane
20.2
1,1 dichloroethane
7.0
trichloroethene
1.4
vinyl chloride
I.4
MW-11
chlorobenzene
21.1
MW-12
chlorobenzene
146.0
MW-13
1,2 dichlorobenzene
1.0
chlorobenzene 8.9
1,4 dichlorobenzene
3.4
1,4-dichlorobenzene 1.8
cis 1,2dichloroethene
43.2
trichloroethene
2.7
MW-14
vinyl chloride
5.3
no detects

Sampling February 8, 2005, results in ug/L.
MW-IS & 1D
MW-2S
no detects
chloroethane
39.7
1,1 dichloroethane
390.0
MW-2D
1,1 dichloroethene
41.4
no detects
cis 1,2 dichloroethene
12.1
tetrachloroethene
124.0
MW-3S
1,1,1 trichloroethane
902.0
chlorobenzene
1.8
trichloroethene
27.5
chloroethane
1.0
vinyl chloride
3.6
1,2 dichlorobenzene
2.6
1,4 dichlorobenzene
1.6
MW-4
1,1 dichloroethane
2.0
benzene
3.9
toluene
38.2
MW-3D
ethylhenzene
1.1
1,2 dichlorobenzene
30.0
xylenes
4.9
1,4 dichlorobenzene
11.0
chloroethane 1500.0
chlorobenzene
25.2
1,1 dichloroethane 4420.0
chloroethane
94.3
1,2-dichloroethane
8.8
1,2 dichlorobenzene
59.5
isopropylbenzene
2.7
1,3 dichlorobenzene
4.5
tetrachloroethene
103.0
1,4 dichlorobenzene
20.4
1,1,1 trichloroethane 4030.0
1,1 dichloroethane
13.2
1,1,2 trichloroethane
3.0
1,1 dichloroethene
1.3
trichloroethene
69.0
cis 1,2 dichloroethene
14.2
1,2,4 trimethylbenzene 2.6
trans-1,2 DCE
1.4
vinyl chloride
54.1
1,1,1 trichloroethane
1.2
vinyl chloride
16.5
MW-7
MW-5
chlorobenzene
1.6
no detects
chloroethane
3.3
1,1 dichloroethane
76.5
MW-6
1,1 dichloroethene
33.2
no detects
cis 1,2 dichloroethene
3.7
vinyl chloride
4.5

CMC Holding Corp.
Solid Waste Disposal Areas
SEC Donohue
October 1992
Purpose: Monitoring Well Installation and groundwater contamination assessment.
8 Monitoring wells installed in August 1992.3 well pairs and 2shallow, generally around area 3
and 4. Auger with split spoon sample and rock core (granitic gneiss, part of Cranberry gneiss).
ID
Total
Water
Rock
Depth
Depth
Depth
MW-IS
24.2
10.71
26.0
MWA D
42.1
10.8
27.28
MW-2S
19.5
10.23
19.5
MW-2D
38.1
10.06
22.3
MW-3S
20.2
14.6
21.0
MW-3D
34.5
14.38
19.5
MW-4
19.5
9.0
19.5
MW-5
18.0
14.75
Sampling 8/21/1992
MW-2S MW-2D
chloroethane 2600 ug/1 carbon disulfide 5 ugil
1,1 dichloroethane 4300
1,1 dichloroethene 2000
1,1,1 trichloroethane 12000
MW-3S MW-313
chloroethane 59 ugll 1,2 dichlorobenzene 53 ugll
1,1 dichloroethane 7 1,4 dichlorobenzene 15
chloroethane 390
1,1 dichloroethane 100
MW-4
chloroethane 1900 ugli
1,1 dichloroethane 460
MW-5
1,1 dichloroethane 13 ug11

STATE FILE
Q-AkQ. L "'.r'k Cf i 1
►)ot'3c p cDzno a [ r.
CMC HOLDING CORPORATION
SOLID WASTE DISPOSAL AREAS
ELKIN, NORTH CAROLINA
GROUNDWATER CONTAMINATION ASSESSMENT
12:10011011:VIA
SEC DONOHUE
(FORMERLY SIRRINE ENVIRONMENTAL CONSULTANTS)
3500-B REGENCY PARKWAY
CARY, NORTH CAROLINA 27511
SEC DONOHUE PROJECT NO. R-2413
OCTOBER 1992

CMC Holding Corporation
Elkin, North Carolina
SEC Donohue Project No. R-2413
I1. REGIONAL GEOLOGY & HYDROGEOLOGY
�74
The CMC Holding Corporation site is located in the Inner Piedmont physiographic
and geologic provinces. This area is characterized by gently roiling hills and wide valleys
and is generally well -drained. The structural geology of the Elkin area is complex. The
primary structural features in the region are northeast -southwest trending faults. These
structural features were probably formed as a result of Proterozoic and early Paleozoic
tectonism and, as such, are found throughout the region. The Brevard Fault Zone is a
major structural feature which represents a deep-rooted crustal shear (Horton & McConnell,
1991). The Brevard Fault Zone splays into at least three other faults in the vicinity of Elkin.
These three faults (Bowens Creek, Ridgeway, and Yadkin Faults) are also thought to
represent major crustal discontinuities. Minor faults parallel to the major faults are also
common in this area.
Rocks in the Liner Piedmont geologic belt are characterized as highly deformed and
metamorphosed Precambrian to Cambrian schists and gneisses, which are occasionally
interrupted by large and small-scale felsic and mafic igneous intrusions. The Inner
Piedmont is interpreted by many geologists to represent an allochthonous (transported from
h
another area) terrane which may have originated from what is now western Africa (Horton
& McConnell, 1991). Rock types commonly found in this region are schists, gneisses,
amphibolites, and other metamorphic rocks. Quartzite veins and dikes are common in this
area and may be formed by primary felsic intrusions or as a result of secondary
mineralization along fractures and joints. j
10/5/92 3 R92R2413.DD4

W
CMC Holding Corporation
Elkin, North Carolina
SEC Donohue Project No. R-2413
Thick mantles of residual soil are formed on top of bedrock in this area. This
residual soil is commonly referred to as saprolite. The thickness of saprolite is generally
between 20 and 50 feet in this region, but ranges from near zero in areas where erosional
forces have caused scouring to well over 100 feet on some hilltops.
. �!44 4 1 �% M R =—e !0 M%
In the vicinity of Elkin, aquifers exist within three basic geologic units. These units
are, from shallowest to deepest, fluvial deposits, saprolite, and fractured bedrock. The
fluvial material, deposited by rivers, and the saprolite weathered from bedrock, are
unconsolidated sediments. Collectively, these are referred to as overburden. The fluvial
deposits have the highest average hydraulic conductivity of these three units, followed by
4 saprolite, and then bedrock. However, because the fluvial deposits and saprolite are
relatively thin., the bedrock aquifer is the most important in terms of economic usage in this
.. area. Local hydrogeology is discussed in more detail in Section V.
Precipitation provides the majority of recharge to the aquifers in the region. Alluvial
and saprolite aquifers tend to be recharged directly by precipitation, and therefore,
commonly occur as water table aquifers. Bedrock aquifers can be recharged by infiltration
from surface water or by leakage from groundwater in the overlying saprolite or alluvium.
Groundwater in the Elkin region is not widely used because of the ready availability
of surface water. A moderate amount of agricultural activity takes place in the region, and
groundwater is used extensively for crop irrigation. The Town of Elkin supplies its
residential and commercial customers with treated surface water obtained from the Yadkin
River at a location upstream from the site.
10 j5/92 4 R92R2413.004

CMC Holding Corporation
Elkin, North Carolina
SEC Donohue Project No. R-2413
V. SITE HYDRQGEOLOGY
The majority of the overburden in the vicinity of the site is a reddish brown to
yellowish brown silt (ML) with few to some fine to medium sand, trace to some clay, and
occasional mica. Two types of overburden (unconsolidated deposits) are present at the site:
fluvial deposits and saprolite. Most of the overburden at the site was fluvial and was
deposited by the Yadkin River during flood episodes. Some of the overburden in the
northern portion of the site is likely to have been derived from weathering of the granitic
gneiss bedrock. The overburden derived from the bedrock (saprolite) is differentiated from
the fluvial deposits by the presence of relict rock textures and the lack of the horizontal
stratification typically found in the fluvial deposits. The drilling did not encounter significant
deposits of fine-grained material, such as silt or clay that could retard the flow of
groundwater, at the interface between the unconsolidated deposits and the bedrock.
The bedrock beneath the site is a highly deformed granitic gneiss. This rock is
believed to be part of the Cranberry gneiss formation. The gneiss has a fairly typical
mineral assemblage' composed primarily of quartz and feldspar. There is a minor amount
of biotite (mica) and amphibole in the rock, which is responsible for producing its
characteristic banded appearance. The biotite and amphibole are dark minerals that tend
to concentrate together and elongate parallel to the direction of shear stresses.
14
R92R2413.004

CMC Hording Corporation
Elkin, North Carolina
SEC Donohue Project No. R-2413
Frequent fractures were observed in the rock cores recovered from the three deep
monitoring well borings. Rock coring runs in all three borings had very low recovery rates
because of the high degree of fracturing. Logs of the rock cores are provided in Appendix
F. Most of the fractures noted in the rock cores were parallel to the foliation planes. The
foliation planes in the rock cores ranged from about 70 degrees from horizontal to about
30 degrees from horizontal. Fractures at high angles to the foliation planes were
occasionally identified. Some secondary mineralization, mostly iron oxide (limonite), was
present on many of the fractures in the rock cores. The secondary mineralization is an
indication that groundwater flows through these fractures, and that the fractures are fairly
extensive.
I B. Aquifer , Description
Water level measurements were obtained from all wells during groundwater sampling.
The elevation of the water table was determined by subtracting the depth to the water
surface from the elevation of the top of casing in each well. The horizontal location and
elevation of each well casing was determined by Foothills Forestry & Surveying. The
vertical elevations established at each well are referenced to the National Geodetic Vertical
Datum established in 1929. An indelible mark was made on each well casing where the
elevation was determined. This mark was used as the reference point to determine the
depth to the water in each well. Table 7 is a summary of the water level data. and
elevations obtained during this investigation.
Two aquifers are identified at the site; a shallow water table aquifer, and a deep
arl � ( } 4 P
(bedrock) aquifer. For the purposes of discussion, these aquifers are described as separate
hydrogeologic units. However, there is no discernible confining layer which would restrict
10/5 J92 15 R92R2413AQ4

CMC Holding Corporation
Elkin, North Carolina
SEC Donohue Project No. R-2413
or prevent the flow of subsurface fluids between the overburden and the bedrock. The two
iunits are discussed as separate aquifers because they are composed of two distinct geologic
media Groundwater flows primarily through pore spaces between grains of sediment in the
overburden deposits, and groundwater flows almost exclusively through fractures in the
bedrock
Figure 3 is a contour map of the water table aquifer based on water level
measurements obtained from the shallow wells during this investigation. The direction of
flow for the water table aquifer is shown as an arrow on Figure 3, and is generally to the
south. The horizontal hydraulic gradient of the water table is approximately 0.016.
The elevations of the groundwater in the deep monitoring wells were not used to
construct the water table contour map because these wells are screened in a different
geologic medium. However, there was virtually no difference between the groundwater
elevations in the shallow and deep well pairs. There is a slight downward vertical hydraulic
gradient (0.03 feet) between the shallow and deep well in the MW-1 well cluster. In the
MW-2 well cluster, there is a moderate (0.29 foot) upward hydraulic gradient. In the MW-3
well cluster, there is a slight (0.05 foot) upward gradient. The vertical hydraulic gradients
indicate that groundwater flows from areas of higher elevation into the Yadkin River, where
both the shallow and bedrock aquifers discharge.
1 10 S 92 16 R92R2473.004

V
CMC Holding Corporation
Elkin, North Carolina
SEC Donohue Project No. R-2413
The arithmetic average of the hydraulic conductivity values of the saprolite obtained
from the field hydraulic conductivity tests is 5.49 x 104 centimeters/second. This value is
fairly typical for a granitic saprolite, but is relatively low for fluvial deposits as they tend to
have a high percentage of sand. A hydraulic conductivity value of 5.49 x 10-4
centimeters/ second appears to be reasonable for the average hydraulic conductivity of the
overburden and the bedrock aquifers.
17
R92R2413.004

CMC Holding Corporation
Elkin, North Carolina
SEC Donohue Project No. R-2413
The arithmetic average of the hydraulic conductivity values of the saprolite obtained
from the field hydraulic conductivity tests is 5.49 x 10' centimeters/second. This value is
fairly typical for a granitic saprolite, but is relatively low for fluvial deposits as they tend to
have a high percentage of sand. A hydraulic conductivity value of 5.49 x IW
centimeters/second appears to be reasonable for the average hydraulic conductivity of the
overburden and the bedrock aquifers.
10/5/92
17
R92R2413.004

TABLE 1
WELL CONSTRUCTION SUMMARY
CMC HOLDING CORPORATION
GROUNDWATER ASSESSMENT
WELL NUNMER
DEPTH OF BOTTOM
OF SURFACE CASING
(FI)
TOTAL DEPTH
OF BORING (F)
SCREEN
INTERVAL
(FI)
MW-11)
27.28
42.1
31.541.8
MW-1S
--
24.2
11.8-22.2
MW-2D
22.30
38.1
27.7-38.0
MW-2S
--
19.5
8.6-19.0
MW-3D
19.60
34.5
24.2-34.5
MW-3S
--
20.2
9.4-20.0
MW-4
--
19.5
8.7-19.0
MW-5
--
18.0
8.0-18.0
-- indicates surface casing not installed (shallow monitoring well).
10/5/92
R92RZ413.004

TM
SECDONO= BORING REPORT
BORING NO. MW-2S
PROJECT:
CLIENT: CMC HOLDING CORPORATION
CONTRACTOR: GROUNDWATER PROTECTION INC.
EQUIPMENT USED:
JOB NO: R-2413.00
PAGE NO: 1 OF 1
LOCATION: BACKGROUND
ELEVATION:
DATE START: _ 8114192
DATE FINISH: 8/14192
DRILLER: M. MCCONEHAY
PREPARED BY: R. BOLICH
GROUND WATER DEPTH TO: CA&NQ SAMPLER CORE
BARREL
DATE HRS AFTER
cow
WATER
OF
OD"C ►
CASING
BOTToU
OF HOLE
TYPE
WE
SIZE ID
WT
HAMHAMMER
FALL
DEPTH
IN
FEET
RECOVERY
pNCHESI
SAMPLER OVA SAMPLE
BPER RU MnR►�E
i INCHES U9�1
FIELD CLASSIFICATION AND REMARKS
$
10.0
�5 fl
zo.o
9
D
S-1
4-5'
9 11 S 2
S-3
4.15'
5-4
19-
19.5'
REDDISH BROWN SILTY F. SAND; TRACE M. SAND;
STIFF; MOIST; OCC MICA FLAKES AND ORGANIC DEBRIS,
NON STRATIFIED IN SAMPLE; NO ODOR OR STAINS.
(FLUVIAL DEPOSITS)
GREYISH BROWN AND REDDISH BROWN SILTY F-M
SAND; TR. CLAY; ABUNDANT MICA; NOT STRATIFIED IN
SAMPLE; WET; LOOSE; NO ORGANIC MATTER; NO ODORS
OR STAINS. (FLUVIAL (DEPOSITS)
REDDISH BROWN SILTY F-M SAND; AS ABOVE; TOP 3" OF
SAMPLE REDDISH BROWN SILT WITH TR. F. SAND; SOFT;
NO ORGANIC MATTER; SLIGHT SOLVENT ODOR; WET; NO
STAINING. (FLUVIAL DEPOSITS)
NO RECOVERY - REFUSAL.
24"
4
21"
4
22"
3
p
531fi„
BLOWSIFT. DENSITY I
BLOWS'FT.
CONSISTENCY
SAMPLE 1D.
COMPONENT %
GROUNDWATER ABBREV.
0-4 VERY LOOSE
5 • 16 LOOSE
11 • 30 MEDIUM DENSE
31 • SU DENSE
$I+ VERY DENSE
0 .2 VERY SOFT
3.4 SOFT
S • S MEDIUM snFF
9 • 15 STIFF
Ii-30 VERY STIFF
3I NAR❑
s SPLIT SPOON
T TUBE
U UNDISTURBED PISTON
G GRAB SAMPLE
X OTHER
NR !io RECOVERY
MOSTLY So • 10D%
SORE 30 - "%
LITTLE 1S - 2s%
FEW 5 - lU%
TRACE d%
WD • WHILE DRILLING
NE - NOT ENCOUNTERED
UR - NOT READ
R! MW-2S
BO.. NG H�.

,3BCDoNoinm BORING REPORT
BORING NO, MW-3S
PROJECT: _q()LID WASTE niSP AREAC'L�;'UAS,SFSSMFNT --
CLIENT: CMC HOLDING CORPORATION
CONTRACTOR: GROUNDWATER PROTECTION INC.
EQUIPMENT USED; r7IFr}RI[- H D-Ian
JOB NO: R-2413.OD
PAGE NO: 1 OF i
LOCATION. ALONG RIVER
ELEVATION:
DATE START: /9
DATE FINISH: 8/14/92
DRILLER: M. MCCONEHAY
PREPARED BY: R. BOLICH
(iROUNp WATER DEPTH TO: CORE
CASING SAMPLER
BARREL
DATE HRS AFTER
COMP
WATER
BOTTOM
OF CASING
BOTTOM
of HOLE
TYPE
0
SIZE 'D
HAMMER wr
HAMMER FALL
DEPTH
IN
FEEL
RECOVERY
nNCHEs�
SAMPLER OVA SAMPLE
BLOWSR„a„g DEPTH
PER
6iNCHES U*fni RANGE
FIELD CLASSiFiCATION AND REMARKS
10.0
15.0
s0.o
D
0
6
0
S-1
4-6'
S-2
9.11'
S-3
4-16•
S-4
20-21'
LIGHT GREYISH BROWN M-C SAND; SLIGHT TR SILT; OCC.
MICA; STRATIFIED; LOOSE; DRY; NO ODORS OR STAINS
(FLUVIAL DEPOSITS).
THINLY LAMINATED (1-2") BROWN SILT & F-C SAND;
HORIZONTALLY STRATIFIED; LAYERS WELL SORTED;
OCC. MICA IN SAND LAYERS; LOOSE TO MEDIUM DENSE
DRY; NO ODORS OR STAINING (FLUVIAL DEPOSITS).
STRATIFIED GREY F-C SAND; LITTLE SILT, TCP 2" =
LIGHT REDDISH BROWN SILT; LITTLE F. SAND; THEN
ABRUPT TRANSITION TO GREY SAND; GREY SAND IS
WET; OCC, ORGANIC MATTER (WOOD AND LEAVES) IN
SAND AND SILT LAYERS; SLIGHT MUSTY (?) ODOR ON
WET SAMPLE; NO STAINING (FLUVIAL DEPOSITS).
GREYISH BROWN SILTY F-C SAND THEN DARK REDDISH
BROWN WEATHERED HOCK (GNEISS).
16"
4
16" 1
4
13,
1
3
R4-
BLOWS FT. DENSITY
BLOWS'FT.
CONSISTENCY
SAMPLE ID.
COMPONENT %
GROUNDWATER ABBREV.
0 • i VERY LOOSE
5 • 10 LOOSE
11 • 3,0 MEDIUM DENSE
31 • 50 DENSE
51. VERY DENSE
0 - 2 VERY SOFT
3-4 SOFT
5 • i MEDIUM STIFF
9 - 1s STIFT
16 - 30 VERY STIFF
31. HARD
S SPLIT SPOON
T TUBE
U UNDISTURBED PISTON
G GRAB SAMPLE
X OTHER
HR HORECaVERY
MOSTLY 50 - 100%
SOME 30 -45%
LITTLE 15 -25%
FEW 5 - 1D%
TRACE -5%
WD - WALE DRILl14G
HE NOT ENCOUNTERED
VR • MOT READ
BORING NO. M W_3S'

SECDoNoHuF, BORING REPORT
BORING NO. MW-4
PROJECT: 20LIDWASTE DISP_ AREA GW AS$ESSMENT
CLIENT: CIVIC HOLDINGCORP_ORATiON
CONTRACTOR: GROUNDWATEE_PROTECTION INC.
EQUIPMENT USED:
JOB NO: R-2413.00
PAGE NO: 1 OF 1
LOCATION: AppA
ELEVATION:
DATE START: 8 J27192
DATE FINISH: 8/27/92
DRILLER: GEOrRGE WRIGH
PREPARED BY: R. BOLICH
GROUND WATER DEPTH TO; CASING SAMPLER CORE
BARREL
DATE MRS AFTER
Gcrp
WATER
BOTTOM
OF CASING
BOTTOM
OF HOLE
TYPE
SIZE ID
HAMIAZA WT
HAMMER FALL
DEPTH
IN
FEET
FlEceovtAy
(INCHES)
SAMPLER OVA SAMPLE
BLOWS R+dry DEPTH
PER IpF�I RANGE
6INCHES
FIELD CLASSIFICATION AND REMARKS
s.a
T a.o
15.0
20.0
a
o
3 5_
5.5
S-2
8.5-
S-3
13.5_
15.5
LIGHT YELLOWISH TO REDDISH BROWN SILTY F. SAND;
LITTLE M. SAND; OCC. MICA; MOIST; NON STRATIFIED;
HOMOGENEOUS; SOFT; NO ODORS OR STAINING.
(FLUVIAL DEPOSITS)
LIGHT REDDISH BROWN SILTY F-M SAND; TR. CLAY;
ABUNDANT MICA; MOTTLED; WET; SOFT-, NO ODORS OR
STAINING (FLUVIAL DEPOSITS).
GREY STRATIFIED SILT AND F-M SAND, STRATIFIED IN
LAYERS 3-1 D MM THICK; TR. CLAY; SATURATED;
ABUNDANT MICA; VERY LOOSE; SLIGHT MUSTY
PETROLEUM ODOR; NO STAINING.(FLUVIAL DEPOSITS)
ROUNDED MED. RIVER GRAVEL AT 18.4 FT.
AUGER REFUSAL AT 19.5 FEET.
14,.
4
2
21 "
3
4
2
21"
4
BLOWS;FT. DENSITY
BLOWS.FT. CONSISTENCY
SAMPLE ID.
COMPONENT %
GROUND WATER ABBREV.
0.4 VERY LOOSE
S • 10 LOOSE
11 • 30 MEDIUM DENSE
31 -yj DENSE
S1♦ VERY DENSE
0 • t VERY SOFT
S • 4 SOFT
S - 6 MEDU14 STIFF
!i - 15 STIFF
16 .30 VERY STIFF
31. HARD
S SPLIT SPOON
T TUBE
V UNDISTVRBED PISTON
G GRAB SAMPLE
X OTHER
NR NO RECOVERY
MOSTLY So - f0D%
SOME 30 •45%
LITTLE 15 • 25%
FEW 5 - 10%
TRACE �%
WO • WRLE DRILUNG
HE • NOT ENCOUNTERED
UR - NOT READ
BORING NO. MW-4

�1
SECDoNoHm BORING REPORT
BORING NO. MW-5
PROJECT: ,;n L 1f]Z�AjTF nI;P A 6 P A GW ASS ESSmEtjI _
CLIENT: CMC HOLDING CORPORATION
CONTRACTOR: GROUNDWATER PROTECTIONINIC, _
EQUIPMENT USED:
SOB NO: R �413.OD
PAGE NO: 1 OF 1
LOCATION: ALONG RULER
ELEVATION:
DATE START: 8/27/92
DATE FINISH: 8/27/92
DRILLER: GEORGE WRIGHT
PREPARED BY: R. JOHNSON
GROUND WATER DEPTH TO.- CASING SAMPLER GO RE BARREL
DATE HRS AFTER
COMP
WATER
BOTTOM
Of CASING
BOTTOM
OF HOLE
TYPE
SIZE ID
HAMMER WT
HAMMER FALL
DEPTH
IN
FEET
RECOVERY
nNCHEsa
SAMPLER OVA SAMPLE
BLOWS pAwcww DEPTH
PERI,>prna
iINCHES
FIELD CLASSIFICATION AND REMARKS
5.0
:0.0
15.0
z0.0
0
p
Q
S-1
4-6'
S-2
9-11'
S-3
14-
16,
LIGHT YELLOWISH BROWN SILTY F-M SAND; LITTLE
CLAY; OCCASIONAL MICA; MOIST; STRATIFIED (FLUVIAL
DEPOSITS).
BROWN SILT AND FINE TO MEDIUM SAND; TRACE SLAY;
STRATIFIED; OCCASIONAL MICA; MOIST TO WET; SOFT; NO
ODORS OR STAINING; (FLUVIAL DEPOSITS).
BROWN AND BROWNISH GREY MEDIUM SAND; LITTLE SILT;
TRACE FINE TO MEDIUM SUBROUNDE❑ GRAVEL; LOOSE;
NO ODORS OR STAINS (FLUVIAL DEPOSITS).
4
2
3
BLOWS/FT, DENSITY
BLOWS'FT.
CONSISTENCY
SAMPLE ID.
COMPONENT %
GROUNDWATER ABBREV.
9 .4 VERY LOOSE
5.19 LOOSE
ti . 30 MEIXUM DENSE
31 50. DENSE
51♦ VERY DENSE
0.2 VERY SOFT
3-4 SOFT
5 •8 MEDIUM STIFF
o - 15 STIFF
f6 • 30 VERY STIFF
31♦ HARD
S SPLIT SPOON
T TUBE
U UNDISTURBED PISTON
G GRAB SAMPLE
X OTHER
HR NO RECOVERY
MOSTLY 50 - Y99%
SOME 39.45%
LITTLE 1S - 2t-;%
FEW 5 • %D%
TRACE 4%
WD. WHILE DRILLING
HE NOT ENCOUNTERED
UR - NOT READ
9ORING NO. MW-5

CMC Holding Corp.
Solid Waste Disposal Areas
Sirrine Environmental Consultants
July 1992
Objective: to assess the site for the presence of sources of subsurface contamination and
characterize the waste disposal areas.
Page 1. Interviews with former Chatham employees indicated that solid waste and
construction/demolitions debris were disposed of in this area from the late 1950's through 1982.
According to former plant personnel, the materials disposed of at the site consisted of:
nylon sheets, polypropylene, tyvek, typar, lint and fiber waste, bale bands and wire, Iatex waste,
paint solids, cardboard and cardboard drums, flooring, concrete, bricks, and pallets, old fabric
rolls, empty drums.
April 1992 a geophysical survey was performed using EM and a magnetic survey over
approximately 25 acres to locate btu-ied metal drums. The site was divided into areas 1, 2, 3, 4.
Area 1; northwestern portion with two baseball fields and a soccer field. Area 2; between area 1
and Yadkin River. Area 3; northeastern portion of the site. Area 4; a small triangle -shaped
parcel west of area 2 along the river.
May 20 through 22, 1992 test pits were excavated to identify subsurface materials and samples
of subsurface materials collected for analysis.
Area 1. 2 test pits at geophysical anomaly. test pit 1 (IA), only naturally occurring materials.
test pit 2 (1A2) excavated 12', with soil sample collected (CMC-IA-12), no water encountered.
Area 2. 4 test pits at geophysical anomalies (2A, 2H, 2I, 2L). Test pits 2A and 2H, below 2 &
5' fill material consisting of nylon, polyester fabric, burned wood & paper, metal packing bands,
plastic bags, crushed metal drum lids, crushed 55-gallon steel drums coated wl paint (@7'). Soil
sample at 9' (CMC-211-09). Water @ 11' in pit 2H. Test pit 2A excavated to 13' (soil sample
CMC-2A-13), natural soil @12.5'.
Test pit 21 encountered fabric, wood and metal bands (no drums), fill approximately 8', no
sample collected.
Test pit 2L, 1st 3' natural silsa, waste as listed above at 3 to 7'. Natural materials below 7'.
Termination 10'. Inflow of water @9'. Soil sample @ 8' (CMC-2L-08).
Area 3. 4 test pits at geophysical anomalies (3A, 3E, 3H, 3J), Test pit 3J wl waste similar to
area 2, 2 drums wl blue & white viscous Iiquid (sample CMC-3J-D), natural soil @ 8'.
Test pit 3E, 1' fly ash at surface, beneath bricks, concrete, sheetrock, wood, at 4' paper drums,
PID reading 20 parts per million, water @ 6' wl solvent odor, water sample collected (CMC-3E-
GW).
Test pit 3A. large amount of trash similar to pits 3E & 3J (outside reported waste limits).
Drums wl blue -white substance similar to pits 3J & 3E (no sample collected).
Test pit 3H Natural materials, no sample.

Area 4. large amount of surface debris. 6 test pits at geophysical anomalies (4H, 4M, 4M1,
4M2, 4P, 4N). Test pit 4H encountered contact between natural soil and waste along east -west
axis. Southern portion contained waste similar to areas 2 & 3. Crushed steel dram near the
surface, crushed plastic drum @ 4' Water jai 10' sample (CMC-4H).
Test pit 4M1 fluvial sa to 5% plastic sheeting, cloth, twine, glass 5-9', fluvial sa to 10', sample
collected (CMC-4M 1). No water encountered.
Test pit 4M2, 4'natural soil, waste generally 4 to 12'. Depth unknown because trackhoe limits @
12'. No sample, no water.
Test pit 4P, 6' of natural fluvial deposits before waste encountered, waste @7' to greater than
12'. No water, soil sample @ 11' (CMC-4P).
Test pit 4N waste 3 to 6', water @ 4 to 5', no sample.
Test pit 4T waste 3 to 8', natural fluvial deposits above and below. No water, no sample.
Sample Analyses Results, 10 samples, 2 water, 1 sludge, 7 soil. Test methods SW-846 8240,
8270
Area 1. soil CMC-IA-2 (no organics detected)
Area 2. soil CMC-2H-09
Toluene 64 UG1KG
Ethylbenzene 12
soil CMG-2A-13 (no organics detected)
soil CMC-2L-08 (no organics detected)
Area 3. viscous liquid CMC-3J-D (lab states soil)
1,1,1-Trichlorethane 820 UG/KG
Toluene 3300
Ethylbenzene 20000
water CMC-3E-GW
Toluene 29000 UG1L
Naphthalene 29
Acenaphthene 39
Fluorene 45
Phenanthrene 160
Anthracene 52
Fluoranthene 220
Pyrene 120
Butylbenzylphalate 21
Benzo(a)Anthacene 64
Chrysene 66
bis (2-Ethylexyl) phthalate 89
Benzo(a) Pyrene 56
Indeno(1',2,3-cd) pyrene 25
Benzo(g,h,i) perylene 26

Area 4. water CMC-4H lab sample CMC-4M (no organics detected)
soil CMC4M 1 (no organics detected)
soil CMC-4P (no organics detected)
Background. soil CMC-BG (no organics detected)
Conclusions (page 22)
Sirrine assumed at the outset of this investigation that the presence of buried drums at the site
would be a good indicator of past burial of certain wastes, such as liquids or sludges, that pose
the most environmental concern. This assumption appears to have been verified based on
observations during excavation of the test pits.

U G
-----,:S OFOGRA Ph P(
SITE: Chatham Park LOCATION: NC HWY 268 Elkin
TOPOI map printed on 0311EVOS from *North Carolina.tpo" and "Unbbed.lpq"
80°52.000' W 80052,000, W 90osaonn' W Wr';R4 R0049.0n0' W
z
C
C
C
Ln
M
2
Cf
Co
O
W
M
Ap
_ �• ��. ,:
yak �f; ������ R �� • ` ti ,� .�, - � � � ifwbw
r
J.
�• .a : ••-- f .r as -
_ h 0
q.
Rol
_ •i �
is
Ville
_
r-7
.
• \ate Cl.
.��,r
-y' t_
•
30°52.000' W F101RI.nOn' W Rr1*5r1 ()nf!' W Wr,SR4 FE0o49-nnn, W
4 -5 1 "Lf
�y(^ �OWFEET 0 500 IMOMEiEiI;"
FrWed 9oeo TOPCf 02MI Nntnml G&Dgmp)w Holdp (wwvr.topo,com)
PRl1iARY HIGHWAY. HARD SURFACE
SECONDARY HIGHWAY, HARD SURFACE
LIGHT —DUTY ROAD HARD OR
ITES: t>
imPRMD SURFACE "NETIC
NORTH
— — — UNIMPRMD ROAD
STATE ROAD
�] U. Is. ROUTE
WERSTATE ROUTE
COUNTY 90 OF.
NORTH CAROLINA
0 COUNTY: Sury
APPRoximATE SrrE LUCAFiUN
PIEDMONT auun< Chaftm °"mTPL
1:24.000 R INDUSTRIAL ""r Chatham Papa TPL
_
SERVICES ' Elkin NC
4211-8 Indlono Awe _ �++wro ■�
WINSTON-SALEV, NC 27105 FIGURE 1 L _�
Z
6
ti
a
�9
m
z
f�
O
O
M
M

TP6
TP
a v l9
I Tr' G m
M W-1 ❑ °
GR=884. ° a e ❑ o °
T�' 5600
o, o o U
a ° � Ali IN` L — IS _I _ _ \ ��,_,
t 7i�p of 2I9 La�ll "�- `�
a MW'8
GR=882,9
MW-17 `
GR=886.4
- MW-6
--��° 17.12 u g /1
1 �W 7 0.65 ug/1 �.s.
i "6
R
j G884.D ' l
I I MW .84 ug/1 f �I-
ti1
,AW-1-5 I ��
;R = 882.2
Piedmont industrial
Services Inc.
1670-A Lowery Street
Winston-Salem, NC 27101
[phone]
o Plume Treatment interval at
base of waste pile 6-2Gft.
0 Plume Treatment interval at
Top of waste pile 11-25ft.
0 Excavation Pit Treatment
interval at Top of waste pile 15-
25ft.
A ' Cross Section
�� -� P
0.2�W-91 f � D" `� SW— 3
{
[North
0 75ft.
Figure 1: Map showing
approximate injection
wells and cross-section.

Cross Section
Figure 2: A to A' Cross Section
see Figure 1.
A
889 0
MW-19 at
/884.1
8841
BY194
Water.;: able: r - '�
otaI VC)c lsocatice
Cvrntour
874
i
ND
Plume inieddon;
well 11-25ft'
86920 interva
864
t i�r�r
Legend: l\�� Trash intermixed sir O Red/Tan to grey sand with
with fill some clay and silt
. Red clay intermixed (Fluvial Deposits)
Rounded medium F—1 Excavation Area
river grave! Monitoring Well
®Screened Interval
B-21 B-14A TP-3 B-6B 0 Intention well
Screened Interval Al
MW-4 at
883.58�
5000 ugl#
i
Excavation
err:+on w.011.5-
•3:.�ri inr.rr•sl .. -
100 ugf#_-
al injection interval for Excavation
.a will t x d 15,000 cubic f `
Some Medium Gravel
at Auger refusal at
00175ft Vertical Scale 1 "=5" 19-5h in MW-4

5/a'sau3 -
IRON R00{Pj
f- l2+60.77
4*
P% NA& At CEN-aftI E
T8Y 1; ftMA" MDR A= MNTERS cmw (wTH ERoommo GdY[)
RR SPKE(S) AT MTRSCTgN OF
� 'TIE UF
4RARROAD t PAYED W 3r32'44' w
N� 4A ,09.45'6E,2551.5
S�R�E
e�P1N j
•EPa'� 1
DISTRICT PROPERTIES
LLC
D.B. 1051 /225
NOTICE: ELECTRONIC DRAruNO FLL.ES ARE NOT TO BE CONSIOEREO CERT"D DOCUMENTS
il
oEsla+A1tQtEv urEs
1
tee, MQ9'�
pUITN _ 20'
IpEi
1
1 ❑ TP5
qqq
�rECREAnpNAt FIELDS , \ F 8[ k- 4,\
M 5611 uq%f' \
.
I &,� -. [7 T�9 \ \ HAROLD ADAMS et ux.
oo NAa rrR i 1 7 \\*� �1 . 1 \ >, 1 U.B. 840/693
£tEV -R9YT7 I �•� TPI Tp)tp_
\(P2rtMLJI®/179 uy/l
S J r r GR- a
. GR-4 y
elxx [ a3. a r f 17,12 �q
r r r ®Tfi 1 S / i�65 ug/I +
fR=69a.6 / i / F/1�1®N /•f�►�-
316117144
Gn=asp. z �-
80UW3AR1r UKE Wn.
GLNTER pP STRE AY _� GROUNO AT V*-!5 1 I r
_ (ADanapned) �, 0.2�V5w-3 l
- — 1MID NM'-3-PP
CHATHAM LAND CORP.
D.B. 77011082
CHATHAM HOLDINGS CORP.
D.B. 77011087
BOUWDART LINE
-13
Mw-14
ROCKU
MCAT" g+.1ra pS�Rn�C R�
L� sw-T
Piedmont Industrial Services Inc.
1670-A bowery Street
Winston Salem, N.C. 2710I
[phone] (Tele.)
[phone] (Fax)
uw-n
uw-12
a
uw-10 5 t ►'
00
sw-2
YADKIN RIVER
*rAaVW C, Wrr^
Foothills Forestry & Surveying
P.O. Box 525 ►warcr ma: agars 150
z a"Na ,a: 03-ty v
Elkin, N.C. 28621 fjW AM w�t+Iiy),r/rryvr C■
[phone] (Tele.) �+ of �`
ae4.M � .ors
JOAU
[phone](Fax)
rC)j
PoN571AUR-OW PMZ
--at
C3
In Arr(w1
p
P.M.* at-AW i t wli
�•
5uwAa -MR wnr tm
r wv
GRAPHIC SCALE
150 300
( IN FEET )
1 inch = 150 ft.
600
SW-4
A
Figure 3:
2008 Total VCCs Isoconcentration Mop

•/
S/a�SREI
E 17�4aS M1
IRON RCO(F)
r
N� 11'r1Aai
E� 12A30.27
e�
CHATHAM HOLDINGS CORP.
D.B. 770/1087
e UNIIM.. utE
TOM A 1: maRY WWoftAFN
RR SPIIKE(S) AT NTERSECTION OF
RAILROAD A PARED ROAD
1114,65
E� 129St 54
��PSt
o'
1,0c"
`r IWNAB AT CENAkRC
NIEIlSECTlp1 (nik 1110001[w000 pCVEj
TIC L"r
s 3232'44• w
i09.45
�r S/a'SOIA WON Ro7[r}
�1 EaD+T]
LAKE DISTRICT PROPERTIES
LLC
D.B. 1051 /225
uw-1-D
A
""TORINO W14L
($r OTAERs)
pESIL 19 2 411E5
XPTH -
DEPTN - 2D'
NOTICE: ELECTRONIC DRAIMNG FILES ARE NOT TO K CONSIDERED CERTIFIED DOMMENTS
11
� a7a
P5
1 ❑iP4 ; 4 ❑ TP7 a72
:r nCA �:.;:IAL FIELDS
-14 TP3❑TPB �A.?9 B70
CCCkkkrnBa+.t 7 _
}[I SiCGF7DARY TBY ' , �'
6a6 kHL 27 {Il❑ TPI _ are
EL£V.-a91
N- 11211.41 0
E- 13358.56 -/ /
�tY
1
DRY TP2❑IT'P11��� DGPRT-12
Mw»17i
ei�� SicCY/■ 857 74 ,
f {4 B73.c�
858 53
t
$ODNOARr LINEiwiH GRdea22 1
CENTER OF STREAM CROUND AT uW-15 1
� es
CHATHAM LAND CURP. _ � — � � � {{ � ••
Mw-I1 Lrw-10 a
r ® Lw-12e`�F
MW-14 0
HOfl TH $AKK �RrVER
Sw-1
Piedmont Industrial Services Inc.
1670-A Lowery Street
Winston Salem, N.C. 27101
[phone] (Tele.)
[phone] (Fax)
MIRY CDGPY7Y- SW-2 ~
YADKIN RIVER
7AZWW CLfi*W
Foothills Forestry & Surveying 150 O 75
P.O. Box 525 AVO"Fad: news
PUMG ACL. o 0*0
Ellin, N.C. 28621 .ag8A1z �ariw../+�c>
[phone] (Tele.) .roc am* 05
W
[phone] (Fax)
ra,
P0MeP/mn=ewr Par
8
ra.Arre lru Pow
i-)
cm-mmw Rpr
❑
A-j4r-)
OP
G1xM alWINI 1' Al rEU
0
TWAIZ.IT»S-tl 1'5V
GRAPHIC SCALE
ISO 300
( IN FEET )
inch = 150 It.
GOO
HAROLD ADAMS et ux.
D.B. 840/693
SW-4
A
Figure 2:
Groundwater Contour Map
Contour Interval is 2 feet

I
si
y�lS
S/8-SCUa
WON ROOF]
+JI
i
E+ IIa63, 33
E• 12a70.77
�.
4�
s9u 11: PRYARY KNCmARK
!� RR SPIKE(S) AT INTERSECTION OF.
�! RAILROAD h. PAVED ROAD
N- 1211994,6543
E-
I- 893.13 SCR
tAPt-4-Pg�
- I- Fx MIA AT CENTEIlLPQ
IJTERSEc7g11 IRinl s1laD[RCVD anvcl
! S Im r
TOA4ar
M0T10E; =TRO10C DMWrW nU3 Ate Nor TO BE COMM"M MWIEo OO@R"TS
%VSMw 1tiO4 KD(F)
[gEN }
j LAKE DISTRICT PROPERTIES
❑ �,1 _� LLC
D-R. 1051/225
VONTOPNO wEu
(ST
{gr 01NER51
q DE9peATED 5 A9ly�
1 •FN1947 �r
MP
rre - 20' �rrcv
gECREAifO.NAE FIELDS
— 1�
HAROLD ADAMS et ux.
D.B. 840/693
n � .
';ao• 1 1
[ECREA11Oe+I.I FIELDS (],„Y,. gY12777
} 1 h'� ti281.i1
{ E- 13356.56
L� l
CHA THAM HOLDINGS CORP.
D-B. 770/1087
_ r --
�i ww-7 rP�
I
J
RZ
Wflz,e Or SMEAU a 4eW-9 J
l l
_ � r • uw-3-s
_ `- � � � �_• 1 a uw-3-
PP Z6, _ _
CHAT
B M77011082 LAND RP. PP �= ® �W �_� � r{ � R
` LfW-13 4W-11 11W-10 •tP S ,FED It
►t —12 ® of rP
/ Y W-14
S/a- (W RtoM ^.7"r Cx*rr'
TM BANS 1, YADKIN RIVER
Piedmont Industrial Services Inc.
1670-A Lowery Street
Winston Salem, N.C. 27101
[phone] (Tele.)
[phone] (Fax)
n rsaO 57utE0 t2/OB/De
zxd 0- -
GRAPHIC SCALE
120 60 0 s0 120 360
[ IN FEET ]
1 Inch - 120 rL
co,
r�rns
Avow'.^R[A pal
--421
w mac n. Nn
cxo-+tvwc fNp1
rrs+ nr !a°1
0- Dr-IAwArr.,
Q
sAIKf �M, U ftr
Figure 1.-
Soil Source Area 'hot spot' Excovation
and Site Mop.

A LVL '1
NCDENR
North Carolina Department of Environment and Natura
Division of Water Quality
Beverly Eaves Perdue Coleen H_ Sullins
Governor Director
April 21, 2009
Alan Payne
CIVIC Landfill
285 Ivy Circle
Elkin, NC 28621
Subject: Acknowledgement of Application No. W10400109
CIVIC Landfill
Injection In situ Groundwater Remediation Well (51)
Surry
Dear Mr. Payne:
Resources
Dee Freeman
Secretary
The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and
supporting materials on April 17, 2009. 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 919-715-6629, 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 htM:llh2o.enr.state.nc.usldocumentsldwq_orgchart.pdf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerely,
0,__�
. for Debra J. Watts
Supervisor
6.6co-\3,
cc: Winston-Salem Regional office, Aquifer Protection Section
Torn Lennon (Piedmont Industrial Services, Inc 1670-A Lowery Street, Winston Salem, NC 27 10 1)
Permit Application File W10400109
AQUIFER PROTECTION SECTION
1636 Mail Service Center. Raleigh, North Carolina 27699-1636
Location: 2728 CapllaI Boulevard. Raieigh, North Carolina 27604 One
Phan: 919-733-32211 FAX 1: 919-715-0568; FAX 2: 919-715-6M %Customer Smice: 1 Z77-623-674 8 �O ��o�ina
InierRet: www.n[wateroualil+Loro r�
An Equal Qppwwnity I AfirmOve Adon Employer atural

Piedmont Industrial Services, Inc.
1670-A Lowery Street
Winston Salem, NC 27101
[phone]
fax [phone]
April 16, 2009
Mr. Tom Sussler
NCDWQ- UIC Program
1636 Mail Service Drive
Raleigh, NC 27699-1636
Phone [phone]
Subject: UIC Permit Information
CMC Holding Corporation Site
Elkin, NC
Dear Mr. Sussler:
KC-E` 0 r DENR 10WQ
AQ11,;.�a
On behalf of CMC Holding Corporation, Piedmont Industrial Services Inc. (Piedmont) is
submitting the enclosed information as requested by Ms. Cheryl Marks at the NCDENR-
IHSB for the above referenced site. According to Ms. Marks, completion of the attached
UIC permit information was requested by the NCDWQ-UIC Program. Per our April 16,
2009, phone conversation the UIC permit does not need to be signed by Piedmont or the
property owner. Piedmont Industrial has anticipated starting remedial activities within the
next 30 days. If possible, an expedited response by the NCDWQ-UIC Program would be
greatly appreciated.
any additional information

AwA
NCDEN R
North Carolina Department of Environment and Natural Resources
Beverly Eaves perdue
Governor
March 9, 2009
Mr. Thomas Slusser
U IC Program
NC Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Re: CMC Holding, Chatham Park
UIC Permit
Elkin, Surry County
Dear Mr. Slusser:
Division of Waste Management
Dexter R. Matthews
Director
Dee Freeman
Secretary
Thank you for your time yesterday to discuss the CMC site under federal bankruptcy. The intent of this letter is to
provide you with information to aid in your review and expedite the letter of concurrence.
In an effort to supply you with the appropriate documents, I have instructed Piedmont Industrial Services, the consultant
executing the remedial action plan to provide you with a completed permit form. I am also including some information
that I previously provided to Mr. Qi for your convenience.
As part of the remedial action, a hot spot of waste material is planned for removal along with any identified contaminated
soils. A groundwater plume of chlorinated solvents is located on a portion of the property as a result of the disposed
waste material. As part of the remedial action, HRC-A is proposed using direct push injection points that requires
concurrence with your program.
There are limited funds and time in which to execute the work plan because this site is in bankruptcy. I have instructed
the consultant to provide you with the information needed for compliance with your program as I did in the past with Mr.
Qi. Tom Lennon is the project manager with Piedmont Industrial Services and can be reached at [phone].
Execution of the remedy is scheduled to begin the end of Apr -it to comply with the plan of liquidation pursuant to the
United States Bankruptcy Court decision.
If you have additional questions about the requirements, please contact me at [phone].
Sincerely,
Che l�A arks H dro eolo ist
r]' Y g g
Inactive Hazardous Sites Branch
Superfund Section
Enclosure
1646 Mail Service Center, Raleigh, Nodh Garalina 27699.1646
Phone; 919-508-8400 l FAX; 919-715-4061 1 Internet: www.wastenotnc.org
k E9031 appprlunily 1 Affirmative Acton Employer
RECEIVED I DEAR/ DWQ
AQUIFFP pPnTFr:rinnt ;FCTIDN
MAR 2 7 2009
One
NorthCarolina
Aawrallf