NC0000311_Plan of Action_20010221

NPDES DOCUWENT !;CANNIN` COVER :SHEET
NPDES Permit:
NC0000311
M-B Industries WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Plan of Action �` )
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Permit
History
Document Date:
February 21, 2001
This document is printed on reuse paper - izore any -
content on the reYerse side

WATERS EDGE ENVIRONMENTAL, LLC
4901 WATERS EDGE DRIVE, SUITE 100 • RALEIGH, NC 27606 • PHONE [phone] • FAx [phone]
February 21, 2001
Ms. Jackie Nowell
North Carolina Department of Environment and Natural Resources
Division of Water Quality- NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: Authorization to Construct Plan
Mitchell -Bissell Industries, Incident # 13005
Rosman, North Carolina
Waters Edge Environmental Job No. R 1-17
Dear Ms. Nowell:
The subject M-B Industries, Inc. (M-B) owns and operates a metal working/fabrication
facility located along US Highway 64 west of Rosman, Transylvania County, North
Carolina. Typical processes at the facility include; chrome plating, zinc plating, cyanide
brine heat treating (ceased in December 1980), and various machining activities.
Presently, wastewater is treated by a permitted wastewater treatment system that
discharges to the West Fork of the French Broad River. M-B is currently classified as a
small quantity generator of hazardous waste under the Resource Conservation and
Recovery Act (RCRA). The primary hazardous materials shipped off site are F006
wastes associated with electroplating operations. M-B also generated solvents from
cleaning activities (F001 wastes) in the past. M-B presently uses a Safety-Kleen
application for cleaning activities at the facility.
On August 16, 1995, the North Carolina Department of Environment and Natural
Resources (NCDENR), Hazardous Waste Section (HWS) conducted a RCRA inspection
of the M-B facility. Laboratory analytical results from four water supply well (WSW)
samples obtained on September 29, 1994, by the HWS indicated that WSW #1 and WSW
#2 demonstrated elevated levels of trichloroethene (TCE) and tetrachloroethene (PCE).
However, samples obtained on August 16, 1995, by the HWS indicated that WSW #2 and
WSW #3 had elevated levels of TCE and PCE, similar to the September 1994 laboratory
results. Based on the RCRA inspection and WSW analytical results, a Notice of
Violation (NOV), dated February 22, 1996, was issued. As a result of the NOV,
Aquaterra Engineering, Inc. (Aquaterra) commenced site analysis activities in March of
1996.

M-B Authorization to Construct
February 21, 2001
01-031
Page 2 of 5
During the initial site investigation, performed on May 21-23, 1996, twelve soil borings
were advanced in regions designated as potential source areas in the NOV. Further
inspection of the soil in two areas of concern was performed on October 10, 2000.
Historic soil concentrations for the constituents of concern (COC) at this site indicate
high levels of PCE in an area inside the southwestern portion of the original building, in
an area formerly used for drum storage. More detailed information regarding the soil
sampling events can be found in Table 1.
During the initial site investigation in May 1996, each of the four WSW were sampled,
and effluent samples were obtained from each of two septic systems located on site.
Subsequent studies have been performed on the four WSW on March 3, 1998, August 9,
1999, February 24, 2000, and October 13, 2000. As a supplement, ten shallow and four
deep monitoring wells were installed on the site between August 1999 and February
2000. Each well was sampled shortly after installation, with a complete sampling event
performed on October 12-13, 2000.
An analysis of the most recent analytical results for the ground water sampling event on
October 11 & 12, 2000, indicates the continued presence of PCE in WSW #2 and #3, as
well as an apparent migration downgradient to encompass monitoring wells MW-8, MW-
/'"1*1 10, MW-11, MW-12, MW-13, and MW-17. The highest concentration of PCE, 510
µg/L, was found in well WSW #3. The continued presence of TCE has been detected in
wells WSW #3 (at a concentration of 18 µg/L) and MW-13. Further information
regarding the historic ground water analytical results can be found in Table 2, with the
analytical report for the results from the most recent sampling event presented in
Appendix A.
Following the decision by Aquaterra to cease all environmental consulting activities
within North Carolina, the responsibility for managing the remediation of the M-B
facility had been transferred to Waters Edge Environmental, LLC (Waters Edge). Waters
Edge agrees with the original Corrective Action Plan and Corrective Action Plan
Addendum set forth by Aquaterra, in which remediation of the site will be achieved
through the use of a pump and treat system, supplemented by an additional soil vapor
extraction (SVE) system (Appendices B and C).
The design of this remediation system is based on the hydraulic conductivity of the
subsurface soil and partially weathered bedrock (PWR), the chemical properties of the
compounds to be removed, and the air and water discharge requirements. The hydraulic
conductivity of the PWR,was estimated using data from the October 12, 2000 pump tests
performed on WSW #2 and #3.
As shown in Figures 2 and 3, the pump and treat system will utilize four extraction wells.
Of these wells, two will be new ground water extraction wells: EW-19, a shallow well in
the source area in the southeastern portion of the original building which will be set at the

M-B Authorization to Construct
February 21, 2001
01-031
Page 3 of 5
partially weathered rock interface (estimated at a depth of 40' below ground surface
(bgs)); and EW-11, a new deep extraction well (approximately 100' bgs) with a 30 to 50
foot -screened interval located near monitoring well MW-11. Two of the existing water
supply wells will also be incorporated into the pump and treat system; WSW #2 and #3
(see Figure 3). Waters Edge feels that this will both target the source area and limit the
downgradient migration of the COC. Based on Waters Edge's knowledge of this site,
along with the pump tests and experience with chlorinated solvents, each extraction point
is estimated to have an effective radius of influence (ROI) of approximately 100-150 feet;
however, this will be verified by a limited drawdown test conducted during system
startup. The ground water with elevated VOCs will be sufficiently encompassed by the
ROI. It is anticipated that this initial action will reduce the PCE concentrations in the
downgradient wells sufficient to eventually allow natural attenuation supplemented with
carbon filtration systems attached to several of the existing private supply wells to reduce
VOC concentrations to below North Carolina Groundwater Standards (NCGS).
The pump and treat system will utilize a shallow tray aeration treatment system, with an
initial throughput of approximately 60 gpm, with a maximum capacity of 160 gpm,
should adjustments be deemed necessary from subsequent sampling events (Appendix
B). Waters Edge has proposed this reduction from Aquaterra's original 250-gpm
capacity system to more reasonably reflect field experience with pumping capacity for
multiple wells located within the same aquifer. The system is being designed to provide
for the efficient removal of PCE, thereby eliminating the need for secondary carbon
treatment to meet the current NPDES discharge limits (Appendix C). Treatment system
upgrades such as bag filtering to remove some isolated incidents of elevated chromium
and lead concentrations may be added at a later date pending evaluation of additional
ground water sampling data.
To supplement the active removal of the COC in the source area, Waters Edge will install
a Soil Vapor Extraction (SVE) system in the delineated source area in the southeastern
portion of the original building (see Appendix D). The SVE system will initially consist
of two SVE wells installed approximately 25 feet apart (see Figure 2). The wells will be
2 inches in diameter, drilled to approximately 2-feet above the water table (approximately
8-feet bgs), and screened a minimum of two feet above the water table. Based on data
from the boring logs included in Aquaterra's Corrective Action Plan and Addendum
(contained in proposed NPDES permit modification in Appendix D), it is assumed that a
25-foot ROI can be achieved by these SVE wells.
The SVE system will consist of a Roots 36 URAI 10 HP blower (or equivalent), moisture
separator, vacuum relief valve, Warrick level switches, and inline filter/silencer, and
transfer pump from moisture separator to air stripper (see Figure 4 and 4A). The blower
and motor has been sized to produce 200 ACFM airflow at 12" of Hg. The SVE system
is oversized to allow for additional SVE wells to be installed if warranted. Based on
worst -case soil data and air emissions calculations from the system, the SVE system will

M-B Authorization to Construct
February 21, 2001
01-031
Page 4 of 5
not require an air permit. From 15A NCAC 2D.0518, total volatile organic carbons must
be less than 40 lbs./day. Air emissions presented in Aquaterra's Corrective Action Plan
Addendum were calculated to be less than 15-lbs./day total VOCs. All liquid produced
by the SVE system will be discharged to the air stripper for treatment.
The piping from the wells to the SVE will be Schedule 80 PVC and will either be
trenched under the concrete slab or piped along walls and/or overhead pipe racks. Each
SVE effluent pipeline will be constructed with a ball valve and vacuum gauge, located at
the system manifold connection. This will serve as a throttling device for the vapor
recovered from the SVE points, to allow for precise adjustment of the flow rates.
The proposed NPDES permit application is contained in Appendix D and additional
information requested by DENR (Ms. Natalie Sierra) is contained in Appendix E. Based
upon the Authorization to Construct Guidance Document, we have supplied the following
information:
1. Letter designating consultant as the authorized representative- Appendix F
2. Three Sets of Detailed Plans and Specifications- These plans and
specifications were contained in the NPDES permit modification contained in
Appendix D. We have included three copies of the drawings, which are
shown in Figures 2 to 5A, which are sealed by a licensed NC Professional
Engineer. These drawings are also stamped "Final Plans- Not for
Construction." Manufacturer's specifications are included in the CAP,
NPDES permit, and attached to the Addendum to the Corrective Action Plan.
We have included these specifications in Appendix B.
3. Two sets of design calculations and hydraulic profiles are included in the CAP
and CAP Addendum (contained in the proposed NPDES permit modification
in Appendix D).
4. Three copies of the Flow Schematic are included as Figure 4A and 5A.
5. Since this is not a modification to an existing facility, no Construction
Sequence Plan for continuous operation is required.
6. Since the shallow tray stripper has been demonstrated as an effective
treatment for volatile organic compounds, it is felt that the facility will be able
to meet the permit requirements. Manufacturer's specifications and
performance data are included in Appendix B.
Some of the initial activities for the well installation have been initiated since the CAP
has been accepted. We would like to begin construction of the treatment system as soon
as we get authorization from you. A tentative schedule is as follows:

Activity
Extraction and SVE Well Installations
Piping
Treatment System Installation
System Startup and Troubleshoot
M-B Authorization to Construct
February 21, 2001
01-031
Page 5 of 5
Completion Date
February 2001
March -April 2001
4 Weeks After Approval
8 Weeks After Approval
If there are any questions, please contact us at 919.859.9987.
Sincerely,
WATERS EDENVIRONMENT, LLC
Phillip L. Rahn, PG
Senior Project Manager
}
Henry Nemargut, PE
Project Engineer
01-031 /PLRJMNM/aht
cc: Mr. Edwin Morrow Jr.—M-B Industries

c
B, BEIBBINS WELL
0 100 200 400
Scale in Feet
151D. DOBBINS WELL
LEGEND
• Deep Well (Top of Bedrock)
4- Water Supply Well
a Shallow Well
Property Line
WATERS EDGE ENVIRONMENTAL, LLC
Title
Project
SITE VICINITY MAP
M-B INDUSTRIES
Transylvania County, North Carolina
Author
Inbb
Drawing
R1-17
Layers
Date
1-17-99
Job No.
R1-17
Revision
02-06-01
Figure
1
Seale
1' = 200'

NOTE'
SECONDARY DEPT
3277 SF
4-SLI➢E DEPT
2753 SF
TOOL ROOM
2197 Sr
EW-19
Q.C. DEPT.
SHIPPING 6
INVENTORY
2471 SF
RAW MATER
1833 SF
PRESS DEPT
1833 SF
FINAL PLANS - NOT FOR CONSTRUCTION
BLACKING
1833 SE
7
SHIPPING E.
RECEIVING
ORAGE 42 SF
STORAGE 42 SF
CHROME
PLATING
950 SF
z_
= 4
y
z
cem
PI CO
R1 CO
LII.
IA
K7 N
-r
N
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u
6
i
TOOL ROOM
1200 SF
FCE
BREAK AREA
VELDING 6 BUFFING
1810 SF
ZINC PLATING
2275 SF
AYP
DEPT.
4002 SF
BENDING AREA
2841 SF
—I I— — —
I I VIDE
I I CUTTING
748 SF
I I
COOLIND DEPT.
2470 SF
CT LP
AYP STORAGE
2530 SF
SHIPPING 6
RECEIVING
P.091 SF
Author
m66
Drawn g
R1-17
Job No.
R1-17
Revision
02-06-01
Layers
Figure
2
Date
11-6-00
PRESS REIOM
2073 SF
SCREW MACHIES
A MACHINING
1711 SF
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LEGEND
Extraction Well
SVE Proposed SVE Point Location
Scale
NTS
Title
Interior SVE Points & Ground
Water Extraction Well Location Map
Project
M-B INDUSTRIES
Transylvania County, North Carolina

SECONDARY DEPT
3277 SF
EV-19
4-SLIDE DEPT
2753 SF
TOOL ROOM
2197 SF
0,C. DEPT
SHIPPING &
INVENTORY
2471 SF
RAV MATERAL
1833 SF
STORAGE 42 SF
ORAGE 42 SF
CHROME
PLATING
950 SF
z_
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z
Ex cc
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to CO
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z�
am
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1200 SF
Li
w
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BREAK ANEh
WELDING & BUFFING
1810 SF
CODLIND DEPT.
2470 SF
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2841 SF
RLP
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NOTE! ••,re,,n•,,N,,
FINAL PLANS - NOT FOR C❑NSTRUCTI❑N
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1833 SF
SHIPPING &
RECEIVING
AYP
DEPT.
4002 SF
AYP STORAGE
2530 SF
VIDE
CUTTIN:
748 SF
I I
I I
PRESS ROOM
2073 SF
SCREV MACHIES
6 MACHINING
1711 SF
SHIPPING &
RECEIVING
2091 SF
LEGEND
Extraction Well
SVE Proposed SVE Point Location
Author Drawing Layers Data Title
mbb R1-17 11-6-00 Interior SVE Points & Ground
ATERS EDGE ENVIRONMENTAL, LLC Water Extraction Well Location Map
Job No. Revision Figure Scale Project
R1-17 02-06-01 2 NTS M-B IN➢USTRIES
Transylvania County, North Carolina

NOTE!
MW-6
6RA�Et PAIN
FINAL PLANS - NOT FOR CONSTRUCTION
MW-5
Proposed Out
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ater
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36
PIPE TRENCH DETAIL
Exlu ng Ground
1m
Scale b, Feet
LEGEND
-SVE Proposed SVE Point Location
_ 1-4 Soll Boring Location C1996)
�SB-9 Soll Boring Location C2000)
® Deep Well (Top of Bedrock)
WSW
® Water Supply Well
Shallow Well
X Proposed Recovery Well
�� Property Line
— River Bed
Former River Bed
NOTE'
Discharge from the Ground Water Treatment
Building CGWT-BLD) will be connected to
existing discharge from the Waste Water
Treatment Plant (WWTP)
WATERS EDGE ENVIRONMENTAL, LLC
Author
mbb
Drawing
R1-17
Job No.
R1-17
Revision
02-06-01
Layers
Figure
3
Date
11-8-00
Seale
1' - 100'
Title
DPE Distribution Lines Location Map
Project
M-B INDUSTRIES
Transylvania County, North Carolina

Fran %has
1
r NEMN-.•
NOTES ��h„�����++��
FINAL PLANS - NOT FOR CONSTRUCTION
•
1m Tams
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WATERS EDGE ENVIRONMENTAL, LLC
Author
mbb
Drawing
R1-17
Layers
Data
11-8-00
Concrete Slab
Title
Right Side Vks
SVE BLOWER SCHEMATIC
Job No.
R1-17
Rein
02-06-01
Figure
4
Seals
NTS
Project
M-B INDUSTRIES
Transylvania County, North Carolina

7
2'
PARTICULATE
FILTER
KNOCK-
OUT
TAN K
CENTRIFICAL
PUMP
FILTER
X
INLET
SILENCER
55
GALLON
HOLDING
TANK
DISCHARGE
SILENCER
SVE BLOWER
Author
mbb
Job No.
R1-17
o�: CARO` °..
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Revision,
02-14-01
Figure
4A
Scale
NTS
LEGEND
0 PRESSURE INDICATOR
BALL VALVE
BLEEDER VALVE
00 FLOW METER
N SAMPLE PORT
V WATER TABLE
Title
SVE Piping Diagram
Project
M—B INDUSTRIES
Transylvania County, North Carolina

VS 3�I(19IJ
SUBMERGED
PUMP
i
0
Et Et
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w
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RECOVERY
WELL
(TYPICAL)
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AIR
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SHALLOW
TRAY
Al R
STRIPPER
VOCs TO
ATMOSPHERE
X DISCHARGE
TO SURFACE
WATERS
LEGEND
00
y
THROTTLE VALVE
FLOW METER
SAMPLE PORT
WATER LEVEL
Author
mbb
Drawing
R1-17
Layers
.Date
02-08-01
Job No.
R1-17
Revision
02-14-01
Figure
5A
Scale
NTS
Title
Ground Water System Piping Diagram
Project
M—B INDUSTRIES
Transylvania County, North Carolina

NOTE:
1 6.0
ZH CARO
•l3n,� Control Panel
(
Air
Blower
Transfer
Pump
SHALLOW TRAY STRIPPER
No: 3631
17669
el`..„O ��Y1 ;•,a�,r
FINALPLANS... NOT FOR CONSTRUCTION
10.0
— Effluent to West Fork of French Broad River
Author Drawing Layers Date
A.TERSEDGE ENVIRONMENTAL, ILC mbb R1-17 0 9-3-97
Job No. Revision Figure Scale Project
M—B INDUSTRIES
R1-17 02-06-01 5 nts Transylvania County, North Carolina
Title
Treatment System Schematic

Table 1. Soil Laboratory Analytical Results - M-B Industries, Rosman, North Carolina
May 22, 1996
Parameter
Soil Boring ID (Sample Depth)
SB-1 SB-1 SB-2 SB-2 SB-3 SB-3 SB-4 SB-4 SB-5 SB-5
(0-1 ft) (4-5 ft) (0-1 ft) (1-2 ft) (0-1 ft) (1-2 ft) (0-1 ft) (4-5 ft) (0-1 ft) (3-4 ft)
Inorganics (mg/kg)
Aluminum 8,600 7,600 9,490 5,700 6,800 5,600 9,800 8,200 8,700 10,000
Total Cyanide 0.66 <0.10 0.43 0.31 0.39 1.02 0.05 0.23 0.47 0.12
Zinc 66 39 35 32 110 480 23 24 26 26
Arsenic <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5
Barium 37 27 32 20 28 21 29 39 27 42
Cadmium <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1
Chromium 40 6.6 53 34 20 31 7.4 8.2 7.8 8.4
Lead 16 3.9 8.5 9.3 6 4.8 5.1 4.3 4.3 4.4
Mercury <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10
Selenium <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50
Silver <1.0 <1.0 <1.0 1.1 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0
SVOCs (µg/kg) No Compounds Detected Above Method Detection Limits
vOCs (µg/kg)
Tetrachloroethene <7 <7 19 11 8 <6 <7 36 <7 <6
Oil & Grease (mg/kg) 34 27 29 <10 70 <10 <10 <10 <10 41
SB soil boring
mg/kg milligrams per kilogram or parts per million
pg/kg micrograms per kilogram or parts per billion
SVOCs semivolatile organic compounds according to SW-846 Method 8270
VOCs volatile organic compounds according to SW-846 Method 8260
ft feet below ground surface

Table 1 (cont.) Soil Laboratory Analytical Results - M-B Industries, Rosman, North Carolina
May 22, 1996 Soil Boring ID (Sample Depth)
Parameter
SB-12
Duplicate
SB-6 SB-6 SB-7 SB-8 SB-9 SB-10 SB-11 of SB-11 BG-1
(0-1 ft) (2-3 ft) (1.5-2 ft) (3-4 ft) (3-4 ft) (3-4 ft) (7 ft) (7 ft) (1.5-2 ft)
Inorganics (mg/kg)
Aluminum 10,000 11,000 4,300 10,000 8,300 12,000 10,000 11,000 14,000
Total Cyanide 0.27 0.14 0.15 0.16 ND 0.72 ND 0.29 0.22
Zinc 29 36 24 48 52 53 86 100 55
Arsenic <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5
Barium 28 29 27 34 29 40 36 35 35
Cadmium <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0
Chromium 41 24 3.4 8.8 17 63 8.3 10 8.1
Lead 5.6 5.6 2.2 7.9 5.6 12 4.9 4.8 16
Mercury <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10
Selenium <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50
Silver <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0
S VOCs Gig/kg)
Di-n-octyl phthalate <330 <-330 <330 <330 460 <330 <330 <330 NA
VOCs (pg/kg)
Tetrachloroethene <7 <6 <6 <8 <-7 <6 <6 <6 NA
Toluene <7 <6 <6 <8 11 17 <6 <6 NA
Oil& Grease (mg/kg) 68 52 <10 <10 <10 <10 16 302
SB soil boring
mg/kg milligrams per kilogram or parts per million
pg/kg micrograms per kilogram or parts per billion
SVOCs semivolatile organic compounds according to SW-846 Method 8270
VOCs volatile organic compounds according to SW-846 Method 8260
ft feet below ground surface
NA not analyzed

Table 1 (cont.) Soil Laboratory Analytical Results - M-B Industries, Rosman, North Carolina
October 10, 2000. Soil Boring ID (Sample Depth)
Parameter P-1 P-2 P-3 P-4 P-5
Soil Water Soil Water Soil Water Soil Water Soil Water
(8-9 ft) (5-6 ft) (5-8 ft) (4-5 ft) (6-7 ft)
Inorganics (mg/kg) (P -) (mg/kg) (18a-) (mpg) Olga-) (m8/1(8) (µO-) (mg/kg) (µg/L)
Chromium 120 5.4 250 31 87 12 20 0.38 17 0.24
Lead 24 0.88 7.5 0.72 8.8 0.41 9.3 0.25 10 0.16
1'OCs (µ'/kg) (tg -) (ktg/kg) (µg/L) (µg/kg) (nil-) (µg/kg) (µ8/1-) (µg/kg) (lag/1-)
Tetrachloroethenc <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 6000 4700 740 500
1,2.4-Trimethylbenzene <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 100 <5.0 <54 <5.0
Total Xylenes <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 200 10 <54 <5.0
P = Probe Designation
mg/kg (L) = milligrams per kilogram (liter) or parts per million
jug/kg (L) = micrograms per kilogram (liter) or parts per billion
VOCs = volatile organic compounds according to SW-846 Method 8260
ft = feet below ground surface

Table 2. Ground Water Laboratory Analytical Results - M-B Industries, Rosman, North Carolina.
Sample ID
Sample Date
Alurnnium
Total
Cyanide
Zinc
Arsenic
Inorganics (mg/L)
Banum Cadmium Hexavalent
Chromium
Chromium
Lead
Selenium
Silver
cis-1,2
dichloroethene
VOC's (pg/L)
Tnchloroethene Tetrachloroethene
SVOC's
(pg/L)
WSW-1
3/3/98
<0.05
0.002
0.032
<0.005
<0.010
<0.010
NA
<0.010
<0.005
<0.005
<0.010
<5
<5
<5
ND
8/9/99
<0.25
<0.002
0.022
<0.01
<0.005
<0.001
<0.05
<0.005
<0.01
<0.02
<0.002
<2
<2
<2
NA
2/24/00
<0.20
NA
0.25
<0.005
<0.01
<0.001
NA
<0.005
<0.003
<0.005
<0.005
<2
<2
<2
NA
10/13/00
<0.10
<0.005
<0.005
<5.0
<5.0
<5.0
WSW-2
3/3/98
<0.05
<0.002
<0.01
<0.005
<0.010
<0.010
NA
0.2
<0.005
<0.005
<0.010
<5
<5
53
ND
8/9/99
<0.25
<0.002
<0.01
<0.01
<0.005
<0.001
0.13
0.12
<0.01
<0.02
<0.002
<2
<2
33
NA
2/24/00
<0.20
NA
0.022
<0.005
<0.01
<0.001
NA
0.125
<0.003
<0.005
<0.005
<2
<2
26.2
NA
10/13/00
<0.10
0.13
0.07
<5.0
<5.0
41
WSW-3
3/3/98
0.08
0.002
3.6
0.008
<0.010 '
<0.010
NA
0.011
0.21
<0.005
<0.010
<5
5
150
ND
8/9/99
<0.05
0.003
<0.01
<0.01
<0.005
<0.001
<0.05
<0.005
<0.01
<0.02
<0.002
<2
14
700
NA
2/24/00
<0.20
NA
<0.02
<0.005
<0.01
<0.001
NA
0.03
<0.003
<0.005
<0.005
<2
6.9
309
NA
10/13/00
<0.10
0.012
<0.005
<5.0
18
510
WSW-4
3/3/98
<0.05
<0.002
0.08
<0.005
<0.010
<0.010
NA
<0.010
0.043
<0.005
<0.010
0
<5
<5
NA
8/9/99
<0.25
<0.002
0.016
<0.005
<0.01
<0.001
<0.05
<0.005
<0.01
<0.02
<0.002
<2
<2
<2
NA
2/25/00
<0.20
NA
0.089
<0.005
<0.005
<0.001
NA
<0.005
<0.003
<0.005
<0.005
<2
<2
<2
NA
10/13/00
Not Sampled
WSW-5
3/3/98
<0.05
<0.002
0.043
<0.005
<0.010
<0.010
NA
<0.010
0.018
<0.005
<0.010
NA
NA
NA
ND
(Duplicate
of WSW-4)
8/9/99
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NC Ground Water Quality
Standard
NA
0.154
2.1
0.05
2
0.005
0.05
0.05
0.015
0.05
0.018
7
2.8
0.7
NA
WSW water supply well
mg/L milligrams per liter or parts per million
pg/L micrograms per liter or parts per billion
SVOCs semivolatile organic compounds according to SW-846 Method 8270
VOCs volatile organic compounds according to SW-846 Method 8260
NA not applicable
ND non detect
Numbers in bold indicate concentrations over the NC Ground Water Quality Standards

Table 2 (cont.) Ground Water Laboratory Analytical Results - M-B Industries, Rosman, North Carolina.
Sample ID
Sample Date
Aluminum
Total
Cyanide
Zinc
Arsenic
Inorganics (mg/L)
Barium Cadmium Hexavalent
Chromium
Chromium
Lead
Selenium
Silver
cis•I,2
dichloroethene
VOC's (pg/L)
Tnch loroethene Tetrachloroethene
SVOC's
(pg/L)
MW-5
8/18/99
0.225
<0.010
<0.020
<0.005
0.141
<0.001
<0.01
<0.005
<0.003
<0.005
<0.005
<2
<2
<2
NA
2/23/00
5.6
NA
0.025
<0.005
0.095
<0.001
NA
0.007
0.007
<0.005
<0.005
<2
<2
<2
NA
10/13/00
0.17
0.041
0.056
<5.0
<5.0
<5.0
MW-6
8/18/99
0.196
<0.010
<0.020
<0.005
0.016
<0.001
<0.01
<0.005
<0.003
<0.005
<0.005
<2
<2
<2
NA
2/23/00
49.3
NA
0.132
0.007
0.0821
<0.001
NA
0.027
0.074
<0.005
<0.005
<2
<2
<2
NA
10/13/00
0.19
0.05
0.13
<5.0
<5.0
<5.0
MW-7
8/18/99
0.269
<0.010
<0.020
<0.005
0.028
<0.001
2.00
2.18
<0.003
<0.005
<0.005
<2
<2
3.9
NA
2/24/00
7.35
NA
<0.02
<0.005
0.054
<0.001
NA
0.199
0.003
<0.005
<0.005
<2
<2
<2
NA
10/12/00
<0.10
1.3
<0.005
<5.0
<5.0
<5.0
MW-8
8/18/99
<0.05
<0.010
<0.020
<0.005
0.018
<0.001
<0.01
<0.005
<0.003
<0.005
<0.005
<2
<2
58.3
NA
2/23/00
90.8
NA
0.325
0.012
1.84
0.002
NA
0.048
0.08
<0.005
<0.005
<2
<2
<2
NA
10/13/00
0.60
0.14
0.19
<5.0
<5.0
30
MVl'-9
9/17/99
0.326
<0.010
6.31
<0.005
0.123
<0.001
<0.01
<0.005
0.022
<0.005
<0.005
<2
<2
<2
NA
2/25/00
0.096
NA
1.21
<0.005
<0.01
<0.001
NA
<0.005
<0.003
<0.005
<0.005
<2
<2
<2
NA
10/13/00
4.9
<0.005
0.008
<5.0
<5.0
<5.0
MW-10
9/17/99
0.553
<0.010
0.18
<0.005
0.028
<0.001
<0.01
0.006
0.006
<0.005
<0.005
4
48
515
NA
2/23/00
0.085
NA
0.138
<0.005
<0.01
0.005
NA
<0.005
<0.003
<0.005
<0.005
<2
<2
9.7
NA
10/12/00
<0.10
<0.005
<0.005
<5.0
<5.0
19
MW-11
9/17/99
6.27
<0.010
0.043
<0.005
0.035
<0.001
<0.01
<0.005
0.003
<0.005
<0.005
<2
<2
12.7
NA
2/24/00
16.40
NA
0.034
<0.005
0.075
<0.001
NA
0.012
0.01
<0.005
<0.005
<2
<2
142
NA
10/12/00
0.15
0.030
0.046
<5.0
<5.0
250
MW-12
9/17/99
1.57
<0.010
<0.020
<0.005
0.04
<0.001
3.7
2.74
<0.003
<0.005
<0.005
7.7
8.2
20.8
NA
2/24/00
51.2
NA
0.077
<0.005
0.167
<0.001
NA
2.26
0.028
<0.005
<0.005
<2
<2
<2
NA
10/12/00
<0.10
1.9
0.046
<5.0
<5.0
8
WSIV water supply well
mg/L milligrams per liter or parts per million
pg/L micrograms per liter or parts per billion
SVOCs semivolatile organic compound% according to SW-846 Method 8270
VOCs volatile organic compounds according to SW-846 Method 8260
NA not applicable
ND non detect
Numbers in bold indicate concentrations over the NC Ground Water Quality Standards

Table 2 (cont.) Ground Water Laboratory Analytical Results - M-B Industries, Rosman, North Carolina.
Inorganics (mg/L)
VOC`s (pg/L)
SVOC's
Sample ID
Sample Date
Aluminum
Total
Cyanide
Zinc
Arsenic
Barium
Cadmium Hexavalent Chromium
Chromium
Lead
Selenium
Silver
cis-1,2
dichloroethene
Trichloroethene Tetrachiorocthene
(pg/L)
MW-13
11/17/99
4.75
<0.010
0.04
<0.005
0.051
<0.001
<0.01
0.005
0.005
<0.005
<0.005
<2
6.9
83.7
NA
2/24/00
0.15
NA
0.125
<0.005
<0.01
<0.001
NA
<0.005
<0.003
<0.005
<0.005
<2
5.8
61
NA
10/12/00
<0.10
<0.005
<0.005
<5.0
8
100
MW-14
11/17/99
15.8
<0.010
0.075
<0.005
0.082
<0.001
<0.01
0.018
0.014
<0.005
<0.005
<2
<2
46.6
NA
2/24/00
64.0
NA
0.356
0.009
0.38
0.004
NA
0.069
0.053
<0.005
<0.005
<2
<2
57.5
NA
10/12/00
0.16
0.038
0.038
<5
<5
130
MW-15
11/17/99
6.4
<0.010
0.045
<0.005
0.08
<0.001
<0.01
0.007
0.004
<0.005
<0.005
<2
<2
<2
NA
2/24/00
11.5
NA
0.123
<0.005
0.098
<0.001
NA
0.014
0.009
<0.005
<0.005
<2
<2
<2
NA
10/13/00
'0.10
0.009
0.008
<5.0
<5.0
<5.0
MW-16
11/17/99
1.42
<0.010
0.025
<0.005
0.018
<0.001
<0.01
<0.005
<0.003
<0.005
<0.005
<2
<2
<2
NA
2/23/00
11.1
NA
0.44
<0.005
0.117
<0.001
NA
0.009
0.01
<0.005
<0.005
<2
<2
<2
NA
10/13/00
0.27
0.052
0.094
<5.0
<5.0
<5.0
MW-17
2/25/00
0.95
ND
<0.02
<0.005
0.01
<0.001
ND
<0.005
<0.003
<0.005
<0.005
<2
<2
6.4
NA
10/12/00
<0.10
<0.005
<0.005
<5.0
<5.0
12
MW-18
2/25/00
2.42
ND
<0.02
<0.005
0.019
<0.001
ND
<0.005
<0.003
<0.005
<0.005
<2
<2
<2
NA
10/12/00
0.17
0.032
0.024
<5.0
<5.0
<5.0
NC Ground Water Quality
Standard
NA
0.154
2.1
0.05
2
0.005
0.05
0.05
0.015
0.05
0.018
7
2.8
0.7
NA
WSW
mgiL
pg/L
SVOCs
I'OCs
NA
water supply well
milligrams per liter or parts per million
micrograms per leer or parts per billion
semivolarile organic compounds according to SW-846 Method 8270
volatile organic compounds according to SW-896 Method 8260
not applicable
ND non detect
Numbers in bold indicate concentrations over the NC Ground Water Quality Standards

Corrective Action Plan Addendum
Mitchell -Bissell Industries
Rosman, Transylvania County, North Carolina
Incident # 13005
November 8, 2000
Prepared For
Mitchell -Bissell Industries
Rosman, North Carolina
Prepared By
Aquaterra Engineering, Inc
Charlotte, North Carolina

•
Corrective Action Plan Addendum
Mitchell -Bissell Industries
Rosman, Transylvania County, North Carolina
November 8, 2000
I . Additional Soil and Ground Water Assessment Activities
On October 10, 2000 Aquaterra advanced five direct push borings (P-1 through P-5) inside the
M-B facility. Soil borings P-1, P-2 and P-3 were installed in the area of the former cess pool and
previous hand auger sampling locations SB-9 and SB-10 as described in the CAP. Soil borings
P-4 and P-5 were installed in the southeastern portion of the building (see Figure 1 for locations).
The borings were advanced to the water table to evaluate if soils and ground water had been
impacted. The soil samples were split in the field, with one portion placed into a zip -lock bag for
screening utilizing an organic vapor analyzer (OVA), and the remaining portion placed into
laboratory supplied jars for possible laboratory analyses.
Soil borings P-1 through P-5 were advanced to depths ranging from 11.0 feet to 13.0 feet. Soil
samples for laboratory analyses were obtained generally from one -foot intervals exhibiting the
highest OVA reading or based on subsurface conditions encountered. Soil samples were obtained
at intervals ranging from 4-5 feet in boring P-4 to 8-9 feet in boring P-1. Boring logs describing
details of subsurface conditions and OVA measurements are included in Appendix A.
Water samples were also collected from the shallow ground water at the termination depth of
each borehole. A screen -type, ground -water sampling device was driven to the desired depth and
then deployed to expose an approximate 4-foot screen interval. New tubing and a bottom check
valve was inserted into each borehole screen interval where the sample was collected. Each water
sample was collected directly from the tubing and into each container without purging.
The samples selected for laboratory analysis were placed in a cooler chilled to approximately
4°C and shipped to Prism Laboratories, Inc. in Charlotte, North Carolina, following chain -of -
custody procedures. The soil and ground water samples were analyzed for volatile organic
compounds (VOC's) by EPA Method 8260B and the metals chromium and lead according to EPA
Method 6010. The laboratory reports.of the soil•and ground water samples are summarized in
Table 1 and a copy of the laboratory report is included as Appendix B.
Results
VOC's were not detected in the soil and ground water samples obtained from borings P-1, P-2
and P-3 below the former cess pool. Chromium was detected at levels ranging from 87 to 250
mg/kg in the soil and 5.4 to 31 ug/L in the ground water. Lead was detected at levels ranging
from 7.5 to 24 mg/kg in the soil and 0.41 to 0.88 ug/L in the ground water.
VOC's were detected in the soil and ground water samples from the area of borings P-4 and P-5
at levels up to 6000 ug/kg of PCE in soil and 4700 ug/L in ground water at boring P-4.
Chromium was detected up to 20 mg/kg in the soil and up to 0.38 ug/L in the ground water. Lead
r was detected at levels up to 10 mg/kg in the soil and up to 0.25 ug/L in the ground water.

CAP Addendum
M-B Industries, Inc.
November 8, 2000
Conclusions
Based on results of the recent soil and ground water assessment in conjunction with historical
ground water sampling activities, the highest PCE concentrations exist in the soil and shallow
ground water near the southeastern portion of the original building. As presented in the CAP;
potential sources of the release were thought to be the east leach field and the former cesspool
located under an addition to the facility. The depth of the former cesspool was reportedly less
than 4 feet below the former ground surface under the existing building. Results of the recent
investigation below the bottom depth of the former cess pool indicates that soil and shallow
ground water in this area does not appear to be impacted by VOC's.
Investigation results in the area of borings P-4 and P-5 indicate soil and shallow ground water are
impacted from VOC's (mainly PCE). This area in the southeastern portion of the original
building may be indicative of a potential source of the current ground water contaminant plume
based on historical concentration levels in nearby monitoring wells and direction of ground water
flow (i.e., elevated impact in downgradient shallow ground water well MW-1 1).
II. Remediation Plan Addendum
The location of the originally proposed ground water treatment system configuration in relation to
the recently suspected source area would appear to remain effective with additional extraction
points. In addition, treatment of impacted soil encountered at the suspected source area is
proposed with a soil vapor extraction system. Aquaterra believes that the recommended
remediation technology - Ground Water Extraction/Treatment with Natural Attenuation -
/ presented in Section 3.4 of the CAP remains the most feasible option to meet remediation
objectives with the following changes/additions:
Ground Water Extraction/Treatment System Revisions
The system will consist of the existing down -hole pumps situated in water supply wells
WSW-2 and WSW-3 which continue to exhibit elevated contaminant concentrations.
The proposed shallow extraction well at MW-11 will instead be a deep extraction well
with a 30 to 50 foot screen interval installed at the top of bedrock. In addition, a shallow
extraction well will be installed at the location of suspected source in the southeastern
portion of the original building to recover impacted ground water. See Figure 1 for
proposed and existing well locations and distribution lines.
The shallow tray aeration treatment system originally proposed has been upgraded to a
model that will handle higher influent concentrations. Appendix C gives manufacturer's
specifications for a treatment system that will result in efficient removal of PCE, which
will eliminate the initial need for secondary carbon treatment to meet the NPDES
discharge limits. Treatment system upgrades such as bag filtering to remove elevated
chromium and lead concentrations may be added pending evaluation of additional ground
water sampling data.
Soil Vapor Extraction System Addition
The recommended Soil Vapor Extraction System (SVE) specifications to treat impacted
soils in the southeastern portion of the original building are presented below. Figure 2
shows conceptual drawings of the SVE system.

CAP Addendum
M-B Industries, Inc.
November 8, 2000
• The system will initially consist of two SVE wells approximately 25 feet apart. The
wells will be 2 inches in diameter and drilled to the .water table (approximately 10-
feet below floor slab) and screened a minimum of five feet. above the water table.
The wells will be located near the area of soil borings P-4 and P-5. Based on the
boring logs, it is assumed that a 25-foot radius of influence can be achieved by these
SVE wells.
• The blower, motor and controller for the SVE system will be installed at the same
location as the pump and treat system (see Figure I) where a licensed electrician will
establish the electrical service. The control panel will be U.L. Listed and constructed
to NEMA 4 requirements. The SVE system will be skid mounted and anchored to
the ground. All liquid produced by the SVE system will be discharged to the air
stripper for treatment.
• The SVE system will consist of a Rotron moisture separator, Rotron vacuum relief
valve, Warrick level switches, Midco Flow Control Valve, Stoddard inline
filter/silencer, Appollo dilution valve, Wika vacuum gauge, Roots 36 URAI blower,
Leeson TEFC 10 hp 230v 3 ,ph motor, and transfer pump from moisture separator to
air stripper. The blower and motor has been sized to produce 200 ACFM airflow at
12" of Hg. The SVE system is oversized to allow for additional SVE wells to be
installed if warranted. Valves are designed into the system to allow for manual
adjustment of the airflow and vacuum through the wells.
• The piping from the wells to the SVE system will be Schedule 80 PVC and will
either be trenched under the concrete slab or piped along walls and/or overhead pipe
racks. Once the SVE piping reaches outside the building, the piping will be installed
in common trenches with the pump and treat piping.
• Based on worst -case soil data and air emissions calculations from the system
described above, the SVE system will not require an air permit. From 15A NCAC
2D.0518, total volatile organic carbons must be less than 40 lbs./day. Air emissions
were calculated to be less than 15-lbs./day total VOCs (See Appendix D for
calculations).
III. Ground Water Remediation System Status
In response to your comment "the work related to the groundwater remediation system
proposed in the original CAP should be initiated as soon as possible ", the NPDES
permit modification/application is in progress and will be modified as a result of the
recent assessment activities. Detailed information on system design and process is being
adjusted to effectively meet remediation goals and discharge limits. An Engineering
Alternatives Analysis and site specific engineering design and specifications are required
that will be included in the NPDES permit.