WQ0036881_Regional Office Physical File Scan Up To 9/27/2022

-- K
I v.
Water Resources
Environmental Quality
April 11, 2018
Matthew S. Williams, Corp. Director
Northrop Grumman Guidance and Electronics Co., Inc.
101 Continental Blvd.
El Segundo, CA 90245
RE: Acknowledgement of Application
Non -Discharge Groundwater Remediation Permit
Former Clifton Precision Site
Permit No. WQ0036881
Cherokee County
Sent via Email
Dear Mr. Williams:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
I WAN
oM,anaw���
Zv[�`'
���Me Wo
The Water Quality Regional Operations Section (WQROS) acknowledges receipt of your
permit modification application and supporting documentation received on April 5, 2018, for the
above referenced permit. Your application package has been assigned the number listed above,
and the primary reviewer is Michael Rogers.
Central and Asheville Regional Office staff will perform a detailed review of the provided
application, and may contact you with a request for additional information. To ensure maximum
efficiency in processing permit applications, the Water Quality Regional Operations Section
(WQROS) requests your assistance in providing a timely and complete response to any additional
information requests.
Please note that processing standard review permit applications may take as long as 60 to
90 days after receipt of a complete application. If you have any questions, please contact Michael
Rogers at 919-807-6412 or [e-mail].
Sincerely,
6cJf Debra J. Watts, Supervisor
Animal Feeding Operations & Groundwater
Protection Branch
Division of Water Resources
cc: Asheville Regional Office, WQROS
Permit File WQ0036881
-J"'Nothing Colnpares_-__k___
State of North Carolina I Environmental Quality I Division of Water Resources
Water Quality Regional Operations Section
1636 Mail Service Center I Raleigh, North Carolina 27699-1636
/ 919-707-9129

ppppr
ore, Andrew W
From: Moore, Andrew W
Sent: Monday, June 18, 2018 1:10 PM
To: 'Sami Fam'
Cc: Rogers, Michael; 'Kurt Batsel'; Dave Falatko
Subject: RE: [External] WQ0036881 Permit Modification
Sami,
Thank you for your questions/clarifications to the Division's Additional Information Request. Follow-up comments are
below.
Comment #1—The'discrepancy between Figure 8 and Figure 10 has been resolved. The remedial wells as proposed, do
not meet the well constructions standard in 15A NCAC 02C .0225(g)(9)(B). The Division has determined that the
proposed well construction, as described below and on the referenced figures, will satisfy the requirements for a
variance as provided in 15A NCAC 02C .0241. The well construction variance will be incorporated into the permit once
revised as provided in 15A NCAC 02C .0241(d).
Comment #2 — The Division is satisfied that the design will preclude surficial contaminants from entering the wellhead
and the wells may be constructed as proposed with respect to piping.
Comment #3 — The discrepancy between Figure 8 and Figure 10 has been resolved. The air injection wells as proposed,
do not meet the well constructions standard in 15A NCAC 02C .0225(b)(4)(B) or 15A NCAC 02C .0108(i). The Division has
determined that the proposed well construction, as described below and on the referenced figures; will satisfy the
requirements for a variance as provided in 15A NCAC 02C .0241. The well construction variance will be incorporated into
the permit once revised as provide in 15A NCAC 02C .0241(d).
Comments #4 and #5 —The proposed monitoring plan as described below has been clarified and is acceptable.
Comment #6 — Michael Rogers in our Central Office has provided the list of proposed injectants and well maintenance
products to DHHS_for review. He'll follow-up once comments are received from DHHS.
Comment #7 — This comment is resolved.
Feel free to contact me if you have any questions.
Andrew W. Moore, P.G.
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Sami Fam [mailto:[e-mail]]
Sent: Monday, June 11, 2018 10:00 AM
To: Moore, Andrew W <andrew.w.moo,[e-mail]>
Cc: Rogers, Michael<[e-mail]>;'Kurt Batsel' <[e-mail]>; Dave Falatko
<D"[e-mail]>
Subject: [External] WQ0036881 Permit Modification
Hi Andy -
Thanks for your quick review and comments regarding our permit modification request. We have compiled some
questions/clarifications about your comments and also responded to some of the simple questions. Once we receive
your response to this email, we will compile a more formal response by letter that should satisfy the Division of Water
Resources (DWR).
Comment #1: Well construction details: The well construction details D and E provided on Figure 10'for the top of grout
and grout/seal type are a mistake, the details A and B provided on Figure 8 correctly show how we want to construct the
wells in regards to the grout type and depth. O'ur intent is to use a bentonite-a mended Portland cement grout mixed in
the ratios and manner described on Figure 8 and set to the depths as noted on Figure 8. All of these wells will be located
in high traffic areas, so they all have to'be finished with flush -mounted well vaults, so the grout has to be terminated
some distance below grade to allow connections to the well and install the well vault. Our standard approach for a
remedial injection well is to install a pitless adapter at 3-feet below grade to protect the pipe and prevent water pipes
from freezing inside the vault, so terminating the grout at 4-feet below grade.allows some working space above the
grout to install the pitless adapter. For the sparge well, we typically connect the sparge gas.line to the well below grade
and below the inside of the well vault at 1.5-feet below grade to protect the connection and minimize the chance of
breaking the high pressure gas line connection to the well, so we show the grout placed to 3-feet below grade to allow
for this connection to be made, however, we can raise the grout level for the sparge wells to 2-feet below grade and still
have working space above it.
Comment #2: Well head piping and connections: As discussed in our response to comment #1, we prefer to have
connections to the well below grade and below the inside of the well vault to protect the pipe and associated
connections. We understand the concern and intent of the regulations in regards to surficial contaminants entering the
well, so we do completely seal the wells with threaded PVC fittings at the top, and the side connections use compression
0-rings to create a liquid -tight seal on the pitless adapter (remedial injection well) and the saddle fitting (sparge
well). All of the fittings are considered liquid -tight fittings, and the use of PVC well casing allows for these connections
to seal the well completely once installed.
Comment #3: Grout seal for sparge wells: Detail E on Figure 10 when it refers to the top of bentonite hole -plug is a
mistake, detail B on Figure 8 shows our intended construction for the sparge wells; to bring the grout up to 3-feet below
grade. Our reasoning for the depth to the top of grout for both remedial injection wells and sparge wells was discussed
in the previous responses. However, as noted previously, we will raise the depth to the top of grout for the sparge wells
to 2-feet below grade as this should still allow the side connection to the well.

PPFP
nt #4: Sampling Locations: Northrop proposed installing additional wells near wells MW-12 and MW-18 in the
P
rimMeasures Plan and as shown on Figure 3 in the design drawings of the UIC permit modification. We will clarify
text that these new wells are being proposed/sampled. In summary, we will sample the wells listed in section G3 of
permit modification plus the new wells near MW-8 and MW-12 and continue with the existing monitoring plan (April 18,
2014 version).
Comment #5: We acknowledge that once the.sampling plan is approved, it cannot be reduced. We may add selected
additional monitoring wells as needed.
Comment #6: Northrop Submitted Risk Assessment Evaluation of Groundwater or Soil Remediation Additives Containing
for Methanol addition on April 9, 2018. (cover letter attached). With regards to the other additives mentioned in the
comment letter:
Section H-1 summarizes that we expect to use 1) DAP (approved additive). Miracle grow is essentially solubilized DAP. If
the DWR prefers that we use DAP and not Miracle grow that is easy to do, 2) Section H1 states that may use sodium or
potassium hydroxide. Those are both essentially the same (hydroxide base). If the DWR prefers sodium hydroxide, we
can use that, although potassium hydroxide is less reactive with clays and is slightly preferable. 3) Muriatic acid/HCI is
not an additive and is only used to clean the wells (as needed). Once the cleaning is completed, the acid is pumped
out. If the DWR prefers, we can use sulfuric acid, which is an approved additive.
Comment #7:
No groundwater injection is proposed. The word groundwater is a typographical error and should be tap -water
Thanks for your help with the permit modification.
Sarni Fam
Innovative Engineering Solutions Inc.
25 Spring Street
Walpole, MA 02081
508-623-1221 direct
781-718-0440 cell
508-668-5175 fax
[e-mail]
Website: http://www.iesionline.com/index.htm

June: 1,201,8:
Sent Via; EMail
.Mifthe-w St. Willi,ams;Cprp...j3i:rector,,
rummaw t� iddarice4rid.BleettordO C-O',ine.
-N. — `G , pithr6p IG ".
101— Conti— -Ital.-- Blvd.
-.-.- - Conti— I - -1-
El-Segundo,.CA. 90245
.Subje6,
Permit.
J. t., N 0- NVQ 0.6881
ion e
Fbft6&ClifioA`Pf-edii Site
(herdkee County
;Dear Mr .'W�llams
ROYCOOPE'R
Governor
LINDA "C L PEP
* TIRL
Interim,Di.reclor-
After inspection of and revew,of`the;pernrt modificationi application, most of needed
tnformatron.is i the 'I" need,
1p, .. p,,4pp application zlarificati6n and:.additional.
information.. Welhave,,ihe.,f6lt6wing',,,Co'm'ments,reques s:
Detail A,'Figffre,& and Detail Dfigurp 10A'pp, appear rlp match each other with, respect to.
pa. .
and grout depth N - d 'they I LSANCAC .grout. type lAnd,.*mkfa&e. or o ey,.appear . &JftO,,dt
.0225(g)(9)(B,)which requires grout to- Iapd,. 8-tftfatd.Please'clarifypropose modifications.
to:well construction.
5kN J6 -piping, wiring, and .wnts'. shall �,Oftt& the W, 6A(� 0 AU rin ­",unl' b�&the Ditecior based: on a, design. ell
throuAfhef of,, -the pp casing, ,unless otherwise:-,ap ;approved
pr_
fr d6inorisithwd t0:;-PrecJu'd -, W 11.1 wellhead.. Plea''se . icia, co-ntdffii, ws,:, provide
my,reasons :why .remedial, wells, cannot beconstrqptpd, to this rule; _or propose well design,.
modifications.,
I SA'NCAC-02Q0225(b)(4)(B) requires thatair iniedlon wells .b,ez,.c-ons-tru-cted'in a6cordance.
.with. 'the ,.well.-,construdii'o'n-s"tandards ;applicable 't6,.m6nit6riha,wells: .;specified .,in- 02C i0108..
15A NCA.-,C� 020 ;grout .0I08.(i);;Ydqkfirbs-'thA t - be, :Oaced �iff the annular ;space between the
outermostcasin- an the �.borehole,wall -&m'.the� . land. s 0
surface the top -ofthe, benionite seal;
Detdil.B Figure' & of the -applicatidn.show§ the.top �.of the., &ementgioutat,3 feet below ground .
'surface; I wh— U 0)Figurp z10 of wtk ion onlyshowse ntonit 'e ho , leplug , to' , 6fe
belbwgroundksurfice. o-r,pr,q pbsid well desiga.-ModificAtibris.,
gtate;4146A Okofina.j Environmenikoumity ItivoiiomotWaier Resources
'1"tirt Quafity._P"a! *Operations _Section.
1636,m4iIservice, C iih.Carolina:27699.4.636 enterRaIei.&,,Nb
919-707-9129'

Theproposed 'monitoring pla
jn.Attachment..,G3. of the. apPlication -is ihad quateand!
needs some revisions. .Most 6,fihd 'w'ells-,t)rot)osed,are.!t6jectloq.p.prfq aftc elfftonito'r''.. Ils
ingwe
that are inside, the mjectionzone,_ rid., may not be d4eqyatp, to.detect,the.movernent
of injection:
,fluids and/or injection Orocess byproducts outside." fth o, _'einje_ipp zone--. H60V#,,if the wells,
'in the Corrective -Action "M o n tRbri-49 Pldft-*.(."AMP) are.lincludecl, this improves the monitoring
:add the following to
network to help comply with: 15-A XC AG 2C.0225(o)(2). Please
the P MW W MW-3" AW 2 M-3, g' :CW
W 12, M, '43 MW 28 6
..CMP-4; and SW-3, -Also; since.r N4W_-8 and ..'MW-12 inthe: 'MR aid constructed _in
,please. install I additional wells i the,same area installeddeeper; transition zone, an or
bedrock -'(additional'w4fswer0propOsectj -the-.MP-" , e An if appropriate").
").
• S 1. cdori..5,1.1.of tfid;EAB IMWork Plan.,staie&."the wells: iomonitored,may charigeAth:dach
samplingevent deperidin ­ the"-pte-Vidiis�c1a ;and "fr.bfttoperations. " Once -a monitoring
_eq_ qq_ e-
on " ­ . ­ .. . Id, current
is, 'priov'ed, it :is. incorporated into the .,permliand" m-a'-y,-,, not without: a permit
4p
The, additives'! -Mefhanof potassium- hy4roxide (Section 'H.L)j
Hydrochloric/ dridtic a_cid-,(EAB,lM`Work .PNn.D.df page. 14), and ,U 616_kG o, (Sectio'n-H.5..)
are proposed for either injection otwell. ffiaititeriance, Upon linitial preliiminary review, ew, ;these. 8e
compounds -,d'o,n6tappeaiiohave-been .-'approved .previously ­ 9 ' yy ed b the ..,NC.DHHS- for -use in NC.
., The witfbe-co 0400"to, confirm:, Ifthase:addifives are not,,'approvocl and y6,u wiskIto
use,Ahem-j'the approval process will; d"t - be accomplished. '.Ihfbhn'6tion on,, this,, process; is,
On the Div- i-s' i vebsite af'
• What will 'bbIthe ,.source d.f.-t ektrddted groundwater thai.will-.be q iolfluifi.theplfl
buffer
ancl/or amendments described'in Sectibh-H.5. ofthe ,qp application,; I�W
p�i, jori,�and,, .thp Work,,
NAr.1. Sectio
bj8 is or.cfto e erImine compliance with 6ANGAO,021A202and BA.
IVCACO2C.'0251(
lft'summary :bfthe,MP(,I)-,sdmpleall :of.the wells ..'listed .iiics �ffoq.68: ffh'--% m ion (in6ludi -the
p P e: AP AP
referenced 1',additional proppsod constituents:and the:frequency propo
sed is�res6ncled,4nd -(2) c6ritin'tie-to conduct- the monitoring that was required .in th& first versio-n"of'the,
�l 4. 'p 2,01 ilLb6submitted ;annually,
'
If you have Ahy,queAlons -in tegAtds 'to, this additional ,ipf6r A
Moore.. n reply to this � it at (823.29.645 As.' Jll,be.rowvAcation t.
WA I w he next two weeks: Also,
me ize.ft',keplAdernerit; Send
,plea§eLniail dny�torkdetedrpages/inaps:to.th..e-tappli6Aiion,in.,sa fbrffiAt.,qhd's`
one copy';to; 'A. h A d rpwMoore,,JIIAshevilk Regional Officetan one copytome:
Thank idn.
ybu for your

PPPPFF,
Best-.R-e9 ards,
1
lxQ9qP,l PA: c
UIC:',Pk.ogram.,Manager,,�.�'liydrogeologist,
Division of Water Resources

Ppe 79791638-B930-4064-A60C-31826A532086
PP
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
Permit No. WQ0036881
Date: May 8, 2018 County: Cherokee
To: Michael Rogers Permittee/Applicant: Northrop Grumman
Central Office Reviewer Facility Name: Former Clifton Precision Site
I. GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ❑ Renewal
❑ Minor Modification ® Major Modification
a. Date of Inspection: NA
b. Person contacted and contact information: NA
c. Site visit conducted by: NA
d. Inspection Report Printed from BIMS attached: ❑ Yes ❑ No.
e. Physical Address' of Site including zip code:
f. Driving Directions if rural site and/or no physical address:
g. Latitude: Longitude:
Source of Lat/Long & accuracy (i.e., Google Earth, GPS, etc.):
II. DESCRIPTION OF INJECTION WELL(S) AND FACILITY
1. Type of injection system:
❑ Geothermal Heating/Cooling Water Return
® In situ Groundwater Remediation
® Non -Discharge Groundwater Remediation
❑ Other (Specify:
2. For Geothermal Water Return Well(s) only
a. For existing geothermal system:
Were samples collected from Influent/Effluent sampling ports? ❑ Yes ❑ No.
Provide well construction information from well tag:
b. Does existing or proposed system use same well for water source and injection? ❑ Yes ❑ No
If No please provide source/supply well construction info (i.e., depth, date drilled, well contractor,
etc.) and attached map and sketch location of supply well in relation to injection well and any other
features in Section IV of this Staff Report.
3. Are there any potential pollution sources that may affect injection? ❑ Yes
What is/are the pollution source(s)?
/1 •
What is the distance of the injection well(s) from the pollution source(s)?
4. What is the minimum distance of posed injection wells from the property boundary? 340 feet
5. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
Rev. 6/1/2015 Page 1

DocuSign Envelope ID: 79791638-B930-4064-A60C-31826A532086
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
7. For Groundwater Remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ® Yes ❑ No. If No,
attach map of existing monitoring well network if applicable and recommend any changes to the groundwater -
monitoring program.
8. Does the map included in the'Application reasonably represent the actual site (property lines, wells, surface
drainage)? ® Yes ❑ No. If No, or no map, please attach a sketch of the site. Show property boundaries,
buildings, wells, potential pollution sources, roads, approximate scale, and north arrow.
9. For Non -Discharge groundwater remediation systems only:
a. Are the treatment facilities adequate for the type of waste and disposal system? ® Yes ❑ No ❑ N/A.
If no, please explain:
b. Are the site conditions (soils, topography, depth to water table, etc.) consistent with what was reported by
the soil scientist and/or Professional Engineer? ® Yes ❑ No ❑ N/A. If no, please explain:
III. EYALUATIONAND RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, explain.
2. List any items that you would like WQROS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item
Reason
Clarification on Remedial Well Construction
Detail A Figure 8 and Detail D.Figure 10 do not
appear to match each other with respect to grout
type and grout depth from land surface nor do
they appear to meet 15A NCAC 02C
.0225(g)(9)(B), which requires grout to land
surface.
Demonstration as to why remedial wells cannot
15A NCAC 02C .0225(g)(22) requires that all
be constructed to 15A NCAC 02C
piping, wiring, and vents shall enter the well
.0225(g)(22)
through the top of the casing unless otherwise
approved by the Director based on a design
demonstrated to preclude surficial contaminants
from entering the wellhead.
Clarification on Oxygen Sparge Well
15A NCAC 02C .0225(b)(4)(B) requires that air
Construction
injection wells be constructed in accordance with
the well construction standards applicable to
monitoring wells specified in 02C .0108. 15A
NCAC 02C .0108(i) requires that grout be placed
in the annular space between the outermost
casing and the borehole wall from the land
Rev. 6/1/2015 Page 2

PppepID-.'79r791638-B930-4064-A60C-31826A532086
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
surface to the top of the bentonite seal. Detail B
Figure 8 of the application shows the top of the
cement grout at 3 feet below ground surface,
whereas Detail E Figure 10 of the application
only shows bentonite holeplug to 6 feet below
ground surface.
Clarification on proposed monitoring network
See additional staff review comments below
to meet 15A NCAC 02C .02250) and 15A
NCAC 02T .1607
Any information needed to approve
Methanol (Section H.L), potassium hydroxide
injectants/well maintenance chemicals -
(Section H.1.), Hydrochloric/muriatic acid (EAB
proposed in the application. [15A NCAC 02C
IM Work Plan pdf page 14), and Miracle Gro
.0225 and 15A NCAC 02C .0112(g)]
(Section H.5.) are proposed for either injection or
well maintenance and do not appear to be
approved for use in NC.
The source of the extracted groundwater that
To determine compliance with 15A NCAC 02L
will be used to flush the pH buffer and/or
.0202 and 15A NCAC 02C .0225(e)(5)(C).
amendments described in Section H.5. of the
application and in the EAB IM Work Plan
Section 2.
3. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
4. Recommendation
❑ Deny. If Deny, please state reasons:
❑ Hold pending receipt and review of additional information by regional office
® Issue upon receipt of needed additional information
❑ Issue
Rev. 6/1/2015 Page 3

DocuSign Envelope ID: 79791638-B930-4064-A60C-31826A532086
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
5. Signature of report preparer(s):
5C147F
Signature of WQROS Regional Supervisor:
Date:
IV. ADDITIONAL REGIONAL STAFF REVIEW COMMENTS/ATTACHMENTS (If Needed)
Overall, the proposed monitoring network in the application is: (1) inadequate for the Enhanced Anaerobic
Bioremediation injections, (2) somewhat vague with regard to proposed additional monitoring wells, (3)
displays some minor inconsistency with the EAB IM Work Plan document provided with the application, (4)
and does not address/discuss the monitoring required as part of the active groundwater remediation system.
With regard to (1), the proposed monitoring plan in Attachment G:3. of the application predominately consists
of performance monitoring wells within the injection zone and may not be adequate to detect the movement of
injection fluids or injection process byproducts outside of the injection zone. However, there is an adequate
monitoring network if the wells in the Corrective Action Monitoring Plan (CAMP) are included. This includes
the following wells: MW-35, MW-12, MW-13, MW-28, MW-36, RW-2, RW-3, RW-5, CMP-1, CMP-3, CMP-
4, and SW-3. With regard to (2), MW-8 and MW-12 are included in the monitoring plan with the application.
However, both of these wells are constructed in regolith. There are several references to constructing additional
transition zone and bedrock wells at the locations of MW-8 and MW-12 "if appropriate". See Figure 3 in
application. We need clarification on whether these wells will, or will not, be constructed. With regard to (3),
Section 5.1.2 of the EAB IM Work Plan states "the wells to monitored may change with each sampling event
depending on the previous data and current operations." We need to clarify that once a monitoring plan is
approved, it is incorporated into the permit and may not change without a permit modification. With regard to
(4), the application indicates the currently operating groundwater treatment injection system will continue to
operate, however, there is no discussion of the monitoring associated with that portion of the system. Overall,
the Division needs to make clear to the applicant, that they will be required to sample all of the wells listed in
Section G3 of the application for the constituents and the frequency proposed until the permit is rescinded and
the data must be submitted annually. In addition, we need to make clear that the applicant shall continue to
conduct the monitoring that was required in the first version of the permit. Note that this monitoring includes
the additional CAMP wells noted above.
Rev. 6/1/2015 Page 4

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Qtotect
`� rm Macon County
of,a Public Health
Josh Crawford
Divisio Uf I REDc
APR 2 3 2018
Water Quality Regional poe
NEW -WELL CONSTRUCTION
CONSTRUCTION AUTHORIZATION
PRIVATE DRINKING WATER WELL
031.118-P 031518-S
6554718631 RAUM 8.90
Off of Crawford Road
64W to R on Carl Slagle Rd.; to R on Crawford Rd. 1/4 of mile to L on first gravel drive on L, cross bridge, follow road to
top of mountain to site.
Permit Conditions
Well shall be constructed in compliance with all NCAC 2C Rules.
Maintain minimum setbacks as applicable.
Diagram (Not to Scale)
d7
Parking
Area
Proposed
5 BR '
Drip Repair 100'
' Area
h , 25' Min '
5
!�P - 100, Min
cut 100,
---------------'
40,
Driveway
> 100'
N
Initial OSWW
'his permit is valid for a period of five vears except that It may hp rPvnkarl at anv Hmn If if Ic rlatarmi—i that thorn hap hen . m.rori.l k-- i., —, f� �
circumstance upon which the permit Is Issued. Well location, Installation, and protection must meet state regulations, The well shall be Inspected and approved by Macon County
Public Health before It Is put into use. The location of the well indicated by MCPH is to provide protection from possible sources of contamination. Flow volume (well yield) is NOT
guaranteed at any site by MCPH.
A WELLHEAD COMPLETION INSPECTION MUST BE APPROVED BEFORE FINAL POWER IS GRANTED QR THE WELL IS PLACED INTO
SERVICE. PLEASE SCHEDULE A WELLHEAD INSPECTION AFTER PUMP INSTALLATION. QUESTIONS? [phone]
Issue Date: 3/28/2018 Tanner Stamey, REHSI 27 uthorized State Agent

Af0A1? "AV 0P tGA&AYJ AAA
31 July 2014
Northrop Grumman Corporation
2980 Fairview Park Drive
Falls Church, Virginia 22042-4511
Joseph P. Kwan
703-280-4035
[e-mail]
Mr. Andrew Moore
WQROS - Groundwater Protection Branch
Division of Water Resources
North Carolina Department of Environmental and Natural Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Re: Engineer's Certification
Groundwater Remediation Permit Number WQ0036881
Former Clifton Precision Site, Murphy, North Carolina
EPA ID No. NCD 044 438 406
Dear Mr. Moore:
Northrop Grumman Guidance and Electronics Company, Inc. (Northrop Grumman), is
submitting the attached Engineer's Certification for Groundwater Remediation Permit
Number WO0036881 (the Permit). The document certifies that the permitted facility at
the Former Clifton Precision Site has been constructed in accordance with the Permit
and approved plans and construction specifications.
Start-up testing for the remediation system is tentatively scheduled for the week of
August 11th. If you have any questions regarding this submittal, please contact me at
[phone] [e-mail]) or Kurt Batsel at [phone] (batsel@dextra-
group.com). Thank you for your continuing support on this project.
Sincerely,
Joseph P. Kwan
Corporate Director, Environmental Remediation
on behalf of Northrop Grumman Guidance and Electronics Company, Inc.
Attachment: Engineer's Certification
cc: John Johnston - USEPA
Rob McDaniel - NCDENR
Thomas Slusser - NCDENR
Kurt Batsel - Dextra
Meri Scappatura - Moog
Jeff Gwinn - Orion

Permit No. WQ0036881
Northrop Gnimman Guidance and Electronics Company, Inc.
ENGINEER'S CERTMCATI N ,
Partial `.- Final
I, ,:as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of
the project,
��w�.w C\�� �v�G�Cs���-<<<��;; '{�����-�;►:.� � Cine:Wk.�e.e. .�v�'c;�a
Project Name Location and County
for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of this permit, the approved plans and specifications, and other supporting
materials.
Signature Registration No. =Sod Z. - -- -- -
Date
WQ0036881 permit.docx Page 8 of 8

Central Files: APS SWP
12/11/13
Permit Number WQ0036881 Permit Tracking Slip
Program Category Status Project Type
Non -discharge In review New Project
Permit Type Version Permit Classification
Groundwater Remediation , A Individual
Primary Reviewer Permit Contact Affiliation
thomas.slusser Andrew Romanek
Coastal SW Rule 651 E 4th St Ste 100
Chattanooga TN 37403
Permitted Flow
Facilit
Facility Name Major/Minor Region
Former Clifton Precision Site Minor Asheville
Location Address County
1995 NC Hwy 141 Cherokee
Murphy NC 28906 Facility Contact Affiliation
Owner
Owner Name
Owner Type
Northrop Grumman Guidance and Electronics Company Inc
Non -Government
Owner Affiliation
Joseph P. Kwan
Corporate Director
-
2980 Fairview Park Dr
Dates/Events
Falls Church VA
22042
Scheduled
Orig Issue App Received Draft Initiated Issuance
Public Notice. Issue Effective
Expiration
12/09/13
^
Regulated Activities
Re uested/Race/ivy d;Events
Outfall NULL
Waterbody Name
Additional information received
RO staff report received
RO staff report requested
Additional information requested
Stream Index Number
RECEIVED
Division of Wad Re&oufo*
MAY - 2 2014
Water Quality Regbnal ppeM"ons
— Asheville Reninnni nfF;—
Current Class Subbasin

Central Files: APS _ SWP
4/29/2014
Permit Number WQ0036881 -
Permit Tracking Slip
Program Category
Status Project Type
Non -discharge
Active New Project
Permit Type
Version Permit Classification
Groundwater Remediation
1.00 Individual
Primary Reviewer
Permit Contact Affiliation
thomas.slusser
Andrew Romanek
Coastal SINRule
651 E 4th St Ste 100
Permitted Flow
Chattanooga TN 37403
,
144,000
Facility
Facility Name Major/Minor Region
Former Clifton Precision Site Major Asheville
Location Address County
1995 NC Hwy 141 Cherokee
i
Facility Contact Affiliation
Murphy NC 28906
Owner
.Owner Name
Owner Type
Northrop�Grumman Guidance and Electronics Company Inc
Non-Govemment
Owner Affiliation
Joseph P. Kwan
Corporate Director
2980 Fairview Park Dr
Dates/Events
Falls Church
VA 22042
Scheduled
Orig Issue App Received Draft Initiated Issuance
Public Notice Issue Effective
Expiration
4/18/2014 12/9/2013 3/24/2014
4/18/2014 4/18/2014
4/11/2019
Regulated Activities
Requested /Received Events
Groundwater remediation
RO staff report received
2/3/14
RO staff report requested
1/7/14
Additional information requested
4/11/14
Additional information requested
2/25/14
Additional information received.
4/15/14
Additional information received
3/18114
Outfall
tNaterbody Name Streamindex Number Current Class Subbasin

oore, /�ndrew W
From: Romanek, Andrew <[e-mail]>
Sent: Tuesday, March 18, 2014 3:21 PM
To: Slusser, Thomas; Moore, Andrew W; Davidson, Landon
Cc: [e-mail]; Duffey, James; Mcdaniel, Robert
Subject: RE: Murphy Site - Fleming Property Question
Attachments: 2014-0318-Murphy-Revised Permit Application Attachment G.pdf
Thomas —
Thanks for pointing out that language. We agree that this could work for the Fleming property and have mortified the
proposed compliance boundary accordingly to exclude her well (see Figure G-1 of the attachment). We have also revised
and provided more detail on the proposed monitoring program in the attachment. As previously discussed, this includes
adding a new well southwest of the reinjection area and just upgradient of the creek. It also includes additional startup
monitoring for the Fleming well. Please take a look and let us know if this addresses NCDENR comments.
FYI, we have a visit to Ms. Fleming's set up for tomorrow and will broach the subject with her again regarding provision
of Town water or bottled water. We will let you know what she says. We shouldn't g_•t our hopes up, but she does seem
receptive to input from our field engineer, who will be conducting the visit tomorrow.
Thanks,
Andrew
From: Slusser, Thomas [mailto:[e-mail]]
Sent: Monday, March 10, 2014 2:14 PM
To: Romanek, Andrew; Moore, Andrew W; Davidson, Landon
Cc: [e-mail]; Duffey, James; Mcdaniel, Robert
Subject: RE: Murphy Site - Fleming Property Question
Greetings Andrew,
Thank you for proposing some options. In talking with my supervisor I recently learned about a rule provision that
should prove useful to the Fleming property situation. Rule 15A NCAC 02T .0105(h) allows for water supply wells to be
in a compliance boundary as long as standards can be met at the modified compliance boundary. The exact'-mguage is:
(h) Setbacks and required separation distances shall be provided as required by individual rules in this Subchapter. Setbacks to streams
(perennial and intermittent), perennial waterbodies, and wetlands shall be determined using the methodology set forth in 15A NCAC 02B
0233(4)(a) Setbacks to wells are for those wells outside the compliance boundary Where wells would:otherwise beinside the compiion'
boundary as estob fished in 15A°NCAC 02L 0107 the applicant'may request the: compliance boundary be established closer to the waste
gJsposal area and this shall bexgranted provided the ground�vatier standards"can be met at the netviy establtshed compliance boundary;
Perhaps the Fleming water supply well could function as a monitoring well of the moclirie: d compliance boundary as
allowed for in the above rule. Given this new information, and the options you proposed, please let us know how you
would like to proceed. We can certainly have another conference call to discuss options in greater detail. if do not think
that any of these options would delay permit issuance apart from the time to evaluate the proposed action.
Thank you,
--Thomas.
ph# 91.9-807-641.2 1 fax# [phone]

Mailing Adc':-ess: 1636 Mail Service Center, Raleigh, NC 27699-1636
Physical Address: Room 640M, Archdale Building, 512 N. Salisbury St., I:aleigh, ITC 27604.
InternetAcL!ress: http://portal.ncclelli•.orghveb/wq/aps/gvv_pro
F-mai/CClrresp v'e 1D 471-141 'rJ'rrl LIVE to 1/iE :d f,78Y be d SCIOM110 <`1VPd O9,",1VS 14IIe5S ifte f0lter'F is
exempt by
From: Romanek, Andrew [mailto _RomanekAPC)cdmsmith.com]
Sent: Tuesday, March 04, 2014 5:02 PM
To: Slusser, - I-lomas; Moore, Andrew W; Davidson, Landon
Cc: batsel a �;eYtra-group.com; Duffey; James; Mcdaniel, Robert
Subject: Murphy Site - Fleming Property Question
Thomas, Andrew, and Landon -
Following up on our conference call last week, we are currently updating the reinjection monitoring plan
site to address NCDENR concerns and will route this sometime soon. Before we do so, we wanted to get
on the Fleming property. After further analysis, the private well on that property is within the proposed c
boundary. Our preferred approach is as follows:
• Re -approach the owner about connection to the Town water supply and if not amenable
botued water for drinking. /
rthe Murphy
ur thoughts
npliance
providing
If the owner is not amenable to either, continue to monitor concentrations and replace the existing carbon
filter periodically (at least quarterly).
Conduct increased monitoring during startup to ensure no negative changes and breakthrough from the carbon
filter.
Can you discuss and let us know if this is an acceptable approach as well as whether approval for this approach is
expected to hold up permit approval?
We have another option, which is to redraw the compliance boundary 50 feet beyond the Fleming parcel boundary. This
approach would put injection well INJ-4 exactly 47 feet from the Fleming boundary and just outside the compliance
boundary. If we went with this alternative, we could simply scratch reinjection via INJ-4 (not preferred) or we could
request an exemption to operate INJ-4 even though it does not meet the setback requirements by 3 feet. If NCDENR is
amenable to the latter and this is an easier approval than with the compliance boundary on the Fleming property, let me
know. Note that INJ-4 is downgradient of the Fleming property.
I know I am throwing a lot at you. Feel free to call with any questions.
Thanks,
Andrew
Andrew P. Romanek, P.E., BCEE I Associate I CDM Smith
651 East 4th Street, Suite 100 1 Chattanooga, TN 37403
T: 423.771.4495 1 M (new no.): 423.394.9986 1 [e-mail] I cdmsmith.com

FrV
Attachment G
Operating and Monitoring Plans
1. The monitoring plan shall be prepared in accordance with 15A NCAC 02T .1607 and
include:
a. The monitoring well that will be sampled,
b. The constituent(s) for which those samples will be analyzed, and
c. The schedule for sampling.
The proposed monitoring plan will contain the following components:
Upgraded Groundwater Treatment System (see Table G-1)
1. Startup chemical monitoring to ensure that performance objectives are met prior
reinjection
2. Quarterly chemical monitoring for the groundwater treatment system
Daily recordings of extraction well water levels as well as various measurements (flow
rates, pressures, etc.) for the treatment system. See Attachment 1 for a copy of the
planned operation logs.
Reinjection Compliance and Effectiveness (see Table G-2)
Startup chemical and water level monitoring to assess changes in plume
concentrations and movement
2. Continued chemical monitoring for the residential well currently treated with a carbon
filtration system. Monitoring will continue to be conducted quarterly with the
exception of increased monitoring during the first three months of the startup period.
3. Semi-annual monitoring in accordance with the EPA and NCDENR approved Corrective
Action Monitoring Plan (CAMP).
Note that the startup period for the upgraded groundwater treatment system will be 8 days
while the startup period for the reinjection system will be 12 months. The reinjection startup
program includes.23 sampling stations, as shown on Figure G-1. These stations comprise 14
monitoring wells, the 8 reinjection wells, 1 private well, and 1 surface water station. The
specific frequencies for sampling during the 12-month startup period are identified in Table G-
2. MW-64, a regolith well adjacent*to Slow Creek, will be installed and monitored per NCDENR
request to monitor the area immediately downgradient of the compliance boundary.
Groundwater levels will be recorded during each sampling event to document the aquifer
response to reinjection, and these data will be used for mapping of the potentiometric surface.
The analyses will include VOCs by Method 8260B and the standard field parameters required
in the CAMP. In addition, carbon dioxide, hydrogen peroxide, pH, conductivity, and
temperature will be measured from groundwater samples as possible indicators of whether
reinjected water has migrated to the monitoring location.
Smith
2014-0318-Murphy-Revised Permit Application Attachment G.doa
G-1
I

Over the 12-month startup period, it is anticipated that the VOC mass downgradient of the site
will be reduced for two reasons. First, the current capture zone is expected to increase in
response to the increased extraction rates from RW-4. Second, the reinjection of clean water
into the offsite area will increase the recovery well capture zones. Short-term fluctuations in
the offsite VOC concentrations are expected as the groundwater flow field equilibrates to the
increased recovery rates and the reinjection.
Prior to the end of the 12-month startup period. Northrop Grumman and CDM Smith propose
to revisit the reinjection system monitoring program and semi-annual CAMP. The monitoring
programs will be revised and consolidated at that time to address reinjection and remediation
monitoring requirements moving forward. This revision will be based on observed results and
plume changes during the startup period. ' -
Smith
2014-0318-Murphy-Revised Permit Application Attachment GA..

Table G-1
Groundwater Treatment System Monitoring
Startup Monitoring (first eight days)
Parameter
Method
AS Influent
AOP Influent
Effluent
VOCs
USEPA 8260E
Daily
Daily
Daily
114-Dioxane
USEPA 8270C
Calcium
USEPA 215.2
Magnesium
USEPA 242.1
Total Alkalinity
USEPA 310.1
Hardness
USEPA 130.2
Total Dissolved Solids
USEPA 160.1
Temperature
Field Measurement
pH
Field Measurement
Conductivity
Field Measurement
Routine Performance Monitoring After Startup
Parameter
Method
AS Influent
AOP Influent
Effluent
VOCs
USEPA 8260B
Quarterly
Quarterly
Quarterly
1,4-Dioxane
USEPA 8270C
Calcium
USEPA 215.2
Not Analyzed
Magnesium
USEPA 242.1
Total Alkalinity
USEPA 310.1
Hardness
USEPA 130.2
Total Dissolved Solids
USEPA 160.1
Temperature
Field Measurement
Monthly
Monthly
pH
Field Measurement
Conductivity
Field Measurement
Hydrogen Peroxide
Field Measurement
Not Analyzed
Not Analyzed
Quarterly
Notes
AS - Air Stripper
AOP - Advanced Oxidation System
Table G-1 Page 1 of 1

Table G-2
Reinjection System Compliance Monitoring
Startup Monitoring (12 months)
"�q
Location
Description
Monthly Sampling
Quarterly Sampling
All 12 Months
Months 1
through 3
All 12 Months
Months 4
through 12
INJ-1
Bedrock Reinjection Well
X
INJ-2
Regolith / Transition Reinjection Well
X
INJ-3
Bedrock Reinjection Well
X
INJ-4
Regolith/Transition Reinjection Well
X
INJ-5
Bedrock Reinjection Well
X
INJ-6
Regolith / Transition Reinjection. Well
X
INJ-7
Bedrock Reinjection Well
X
INJ-8
Regolith /Transition Reinjection Well
X
MW-23
Regolith Monitoring Well
X
X
MW-25
Bedrock Monitoring Well
X
X
MW-33
Regolith Monitoring Well
X
X
MW-34
Regolith Monitoring Well
X
X
MW-40
Bedrock Monitoring Well
X
X
MW-41
Bedrock Monitoring Well
X
X
MW-44
Bedrock Monitoring Well
X
MW-46
IRegolith Monitoring Well
X
X
MW-47
Bedrock Monitoring Well
X
X
MW-60
Regolith / Transition Monitoring Well
X
X
MW-61
Bedrock Monitoring Well
X
X
MW-62
Regolith /Transition Monitoring Well
X
MW-63
IBedrock Monitoring Well
X
MW-64
New Regolith Monitoring Well
X
X
PW-9
Residential Well
X
X
CMP-4
Creek Monitoring Point
X
X
Sampling at each location for each event will include: Water level measurement, laboratory analysis of VOCs, and
field measurement of carbon dioxide, hydrogen peroxide,
pH, conductivity, and temperature.
Notes
A This well does not yet exist and will be installed prior to reinjection system startup.
B This well is currently used for water supply but is equipped with a carbon filtration system that is replaced quarterly.
Table G-2
Page 1� of 3

3 ,,o,3ho-

Attachment 1 OPERATION LOG A: EXTRACTION WELLS
GROUNDWATER TREATMENT AND OFFSITE REINJECTION SYSTEM
FORMER CLIFTON PRECISION FACILITY
Date
Initials
Extraction Wells
RW-1 S
RW-3
RW-4
RW-5
Water Level
(ft. BTOC)
Flow Rate
(gpm)
Water Level
(ft. BTOC)
Flow Rate
(gpm)
Water Level
(ft. BTOC)
Flow Rate
(gpm)
Water Level
(ft. BTOC)
Flow Rate
(gpm)
Design Limits ..
1.0 `
—
1.6
—
50
—
3.6
ft. BTOC - feet below top of casing
gpm - gallons per minute
S:\Northrop\02NG\0ffsite GWiS design\0&M Manuah2013-0430-0&M Schedule and Logs 8/5/2013 Page 1 of 1

Routine Semi -Annual Monitoring
Well Code
Station Description
Current CAMP.
.........................................................................................................
Semi -Annual Annual Water Level
Sampling Sampling
Groundwater
MW-1
Regolith Well
X
MW-6
Bedrock Well
X
MW-9
Regolith Well
X
MW-10
Regolith Well
X
X
MW-11
Transition / Bedrock Well
X
X
MW-12
Regolith Well
X
X
MW-13
Regolith Well
X
X
MW-14R
Bedrock Well
X
MW-17
ITransition Well
X
X
MW-18
Regolith Well
X
MW-19R
Bedrock Well
X
MW-20
Regolith Well
X
X
MW-22
Transition / Bedrock Well
X
MW-23
Regolith Well
X
MW-25
Transition / Bedrock Well
X
MW-27
Regolith Well
X
MW-28
Regolith Well
X
X
MW-29
Regolith Well
X
MW-30
ITransition / Regolith Well
X
MW-31
Transition / Regolith Well
X
MW-32
Transition / Regolith Well
X
X
MW-33
Regolith Well
X
X
MW-34
Regolith Well
X
X
MW-35
Regolith Well
X
X
MW-36
Bedrock Well
X
X
MW-37
Bedrock Well
X
X
MW-38
Bedrock Well
X
MW-39
Bedrock Well
X
MW-40
lBe&ockWell
X
X
MW-41
Bedrock Well
X
X
MW-42
Regolith Well
X
X
MW-43
Bedrock Well
X
X
MW-44
Bedrock Well
X
MW-45
Bedrock Well
X
X
MW-46
Regolith Well
X
MW-47
Bedrock Well
X
X
MW-49
Regolith Well
X
MW-50
Bedrock Well
X
MW-51
Bedrock Well
X
MW-52
Regolith Well
X
MW-53
Bedrock Well
X
Table G-2 Page 2 of 3

Well Code
Station Description
Current CAMP
.........................................................................................................
Semi -Annual Annual
Water Level
Sampling Sampling
MW-54
Regolith Well
X
MW-55
Bedrock Well
X
MW-56
Transition Well
X
MW-57
Transition Well
X
MW-60
Regolith/Transition Well
X
X
MW-61
IBedrock Well
X
X
MW-62
Regolith / Transition Well
X
X
MW-63
Bedrock Well
X
X
GW-1B
Bedrock Well
X
GW-7
Regolith Well
X
X
GW-7B
IBedrock Well
X
X
GW-8
Regolith Well
X
X
GW-8B
Bedrock Well
X
X
GW-5D*
Regolith (Deep) Well
X
GW-5B*
Bedrock Well
X
GW-IS
Regolith (Shallow) Well
X
GW-ID
Regolith (Deep) Well '
X
GW-2S
Regolith (Shallow) Well
X
GW-21)
Regolith (Deep) Well
X
X
GW-3S
Regolith (Shallow) Well
X
GW-31)
Regolith (Deep) Well
X
X
GW-4
Regolith Well
X
RW-IS
Regolith Recovery Well.
X
X
RW-ID
Bedrock Recovery Well
X
X
RW-2
Regolith Recovery Well
X
X
RW-3 IRegolith
Recovery Well
X
X
RW-4
Regolith Recovery Well
X
X
RW-5
Bedrock Recovery Well
X
X
PW-16
Bedrock Supply Well
X
X
Surface Water
CMP-1
Creek Monitoring Point
X
CMP-3
Creek Monitoring Point
X
CMP-4
Creek Monitoring Point
X
SW-3
Surface Water Station,
X
SW-6
Surface Water Station
X
SW-10
Surface Water Station'
X
SP-26
Ispring
X
Table G-2 Page 3 of 3

OPERATION LOG B: AIR STRIPPER, ADVANCED OXIDATION SYSTEM, AND TREATED GROUNDWATER INJECTION SYSTEM
GROUNDWATER TREATMENT AND OFFSITE REINJECTION SYSTEM
FORMER CLIFTON PRECISION FACILITY
----------------
----------------
TBD
gpm - gallons per minute
psi - pounds per square inch
cfm - cubic feet per minute
S:WnMmp`02NC\Ogsite GWfS design\OSM Mamral\2013-0430.0&M Schedule and Lags 8W013 Page 1 of

OPERATION LOG C: INJECTION WELLS
GROUNDWATER TREATMENT AND OFFSITE REINJECTION SYSTEM
FORMER CLIFTON PRECISION FACILITY
gpm - gallons per minute
psi - pounds per square inch
S:WOMrop1D]NC%=Ae GNTS design\GSM Manuar=1310430-0&M Schedule and Logs SISQ013 Page 1 of I

�
7
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7-0 Z.

PVLTIFER PROTECTION SECTION —GROUNDWATER—PR9TEC3'I6N FFN3I —
REGIONAL STAFF REPORT
Date: January 28, 2014 Permittee(s):_ Northrup Grummon
Permit No.: W00036881
To: APS Central Office County: Cherokee
Central Office Reviewer: Thomas Slusser Project Name: Former Clifton Precision Site
Regional Login No:
I. GENERAL INFORMATION
1. This application is (check all that apply): ❑ SFR Waste Irrigation System ❑ UIC Well(s)
® New ❑ Renewal -
❑ Minor Modification ❑ Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
® Closed -loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ❑ Yes or ® No.
a. Date of site visit:
b. Person contacted and contact information:
c. Site visit conducted by:
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For SFR Treatment Facilities:
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude: Method Used (GPS, GoogleTM, etc.);
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For UIC Injection Sites:
(If multiple sites either indicate which sites the information applies to copy and paste a new section into the
document for each site or attach additional pages for each site)
a. Location(s):
b. Driving Directions:
C. USGS Quadrangle Map name and number:
d. Latitude: Longitude: Method Used (GPS, GoogleTM, etc.);
APS-GPU Regional Staff Report (Sept 09) Page 1 of 8 Pages .

IN I a I 01CI 519M M sL�+lI!7@ I'll 11. ,
REGIONAL STAFF REPORT
II, NEWAND MAJOR MODIFICATIONAPPLICATIONS (this section not needed for renewals or minor
modirications, skip to next section)
Description of Waste System and Facilities
1. Please attach completed rating sheet. Facility Classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
❑ Yes ❑ No ❑ N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
❑ Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or ❑ No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
III. RENEWAL AND MODIFICATIONAPPLICATIONS We previous section for new or major modification
s stems
Description of Waste System and Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No.
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
APS-GPU Regional Staff Report (Sept 09) Page 2 of 8 Pages

REGIONAL STAFF REPORT
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please -explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV; NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
APS-GPU Regional Staff Report (Sept 09) Page 3 of 8 Pages

XQUIEER PR-OTE-CTION-SE-CTION = GROUNDWATER PROTECTION UNIT -
REGIONAL STAFF REPORT
IV. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description of Well(s) and Facilities — New, Renewal, and Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
❑ In situ remediation (5I)
® Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: _)
2. Does system use same well for water source and injection? ❑ Yes ® No
3. Are there any potential pollution sources that may affect injection? ® Yes ❑ No
What is/are the pollution source(s)? predominately volatile organics from former UST. What is the distance of
the injection well(s) from the pollution source(s)? 800 ft from predominate source area, though multiple source
areas may exist. Injections are directly into contaminant plume.
4. What is the minimum distance of proposed injection wells from the property boundary? Several of the proposed
injection wells are located on property not owned b the he applicant. However, the applicant has access
agreements in place with those properties. The minimum distance of proposed injection wells to a property
without an access agreement with the applicant is 55 ft.
5. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ® No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program: MW-44, MW-46, and MW-47 should be added to the semiannual sampling
to confirm that bedrock injections in INJ-3 and INJ-1 and regolith injections in INJ-2 do not cause the
migration of contaminants into previously uncontaminated or less contaminated areas. Though these wells are
not ideally placed (cross -gradient and/or potentially slightly upgradient) or constructed to evaluate the effects of
injection on contaminant migration, they should provide evidence of whether the intended purpose of the
injections (i.e. limiting contaminant migration) is being achieved and can be used to confirm that the injections
are not unintentionally contributing to contaminant migration. Data in reports provided to support the
application, including results of the Aquifer Performance Test, the geophysical survey, and VOC detections in
private water supply wells, indicate that preferential flow paths, which are poorly understood, may exist at the
site, and may result in unintended consequences with respect to the injections. Monitoring of MW-44, MW-46,
and MW-47 will provide evidence that the injections are, or are not, contributing to contaminant migration into
previously less, or uncontaminated areas.
APS-GPU Regional Staff Report (Sept 09) Page 4 of 8 Pages

REGIONAL STAFF REPORT
Additional monitoring of Slow Creek should be performed quarterly, at a minimum for the rirst year, ronowtng
injection system startup at a location anticipated to be the most impacted by the injection activities (likely
CNT-4) and a location upstream (CMP-1) in order to effectively evaluate the impact of injections on
contaminant discharge to Slow Creek.
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ❑ Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Injection Well Permit Renewal and Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes [:]No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes, explain:
3. For renewal or modification of groundwater remediation permits (of any type) will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. If yes, explain:
4. Drilling Contractor: Name:
Address:
NC Certification number:
5. Complete and attach NEW Injection Facility Inspection Report, if applicable
V EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the Application: Clarification and additional detail is
needed from the applicant regarding the monitoring performed as part of the startup plan provided in Appendix
G of the permit application. Step 1 of the startup plan does not specify the analyses that will be performed after
12 and 24 hours, nor does it specify the location from which the samples will be collected. I assume that the
analysis will be VOCs via EPA 8260 and pH and the sample will be collected from SP-7. However, this should
be confirmed by the applicant. Step 2 of the startup plan states "if treatment is being achieved, divert flow to
the reinjection wells..." However, treatment achievement is not quantified. I understand that the air stripper was
designed to reduce influent concentrations to 50% of 2L. Is this how treatment achievement will be quantified?
APS-GPU Regional Staff Report (Sept 09) Page 5 of 8 Pages

AQUIFER PROTECTION -SECTION = GROUNDWATER PROTECTION UNIT -
REGIONAL STAFF REPORT
Steps 3 and 5: see comment regarding Step 1. Step 4: see comment regarding Step 2. The applicant does not
specify the procedures that will be followed if the sampling of the effluent indicates an exceedance of a
threshold concentration (which have not been established. See comment regarding Step 2.) A plan or procedure
should be provided by the applicant in the case that an effluent concentration is detected above" the threshold
concentration either during startup or during routine monitoring following startup.
15A NCAC 2L .0107(d) prohibits the use of water supply wells within the compliance boundary. Well PW-9
appears to be an active well and within the compliance boundary. I assume the well use is not within the
applicant's control; the permit applicant should provide additional information about use of this well and
compliance with .0107(d).
2. Attach new Injection Facility Inspection Form, if applicable
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item
Reason
Additional information and detail regarding
To determine compliance with 15A NCAC 2T
startup plan monitoring.
.1607 and 15A NCAC 2T .1605(a)(2).
15A NCAC 2L .0107(d) prohibits the use of
To determine compliance with 15A NCAC 2L
supply wells within a compliance boundary.
.0107(d).
PW-9 appears to be within the compliance
boundary. Please verify compliance with
.0107(d). Please provide additional information
regarding the use and `control' of PW-9.
A separate map indicating water supply well
To ensure compliance with 15A NCAC 2T
status and monitoring frequency. Additionally,
1604(a)(2)(E).
please provide this office with a copy of the
risk assessment document submitted to
EPA/NCDENR and referenced in the
application.
The application of a compliance boundary to
To determine compliance with 15A NCAC 2T
this site is problematic as groundwater
.1607.
contamination already extends beyond the
compliance boundary to the southwest,
injection will be occurring in bedrock wells in
a complex hydrogeologic setting, and
APS-GPU Regional Staff Report (Sept 09) Page 6 of 8 Pages

REGIONAL STAFF REPORT
groundwater monitoring is very limited to the
west and southwest of the injection site. Please
provide further discussion on how GW
migration will be monitored at the compliance
boundary.
We need a separate, individualized monitoring
To determine compliance with 15A NCAC 2T
plan for the groundwater remediation permit.
• 1607.
We have reviewed the reports referenced in the
application but wish to review a single plan
designed specifically for the project meeting
.1607.
Based on the simulated groundwater flow in
To determine compliance with 15A NCAC 2T
the regolith, the closest down -gradient regolith
1607.
monitoring point is greater than 600 ft. down -
gradient (SW). Please provide additional
information addressing this issue which relates
to compliance with .1607.
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
Semiannual monitoring of MW-44, MW-46,
To determine compliance with 15A NCAC 2T
and MW-47 in addition to the routine
.1607.
monitoring described in the Offsite GWTS
Design Report and Corrective Action
Monitoring Plan Latest Revisions (August
2012).
Quarterly monitoring of Slow Creek for the first
To determine compliance with 15A NCAC 2T
APS-GPU Regional Staff Report (Sept 09)
Page 7 of 8 Pages

L\ OJVj% . 11"11 - ITAV U1 1" rV it 1.
REGIONAL STAFF REPORT
year following startup at upstream location
.1607.
(CMP-1) and at a point where concentrations
are anticipated to be the highest (likely CMP-4).
The monitoring data provided to:DENR should
To determine compliance with 15A NCAC 2T
not only include the current monitoring data in
.1607.
tabular form, but also all historical data for each
monitoring point. The April -May CAMP Report
provided with the permit application only has
data for current monitoring period.
7. Recommendation: ® Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report Preparer(s):
Signature of APS regional super-*
Date: l 2 �r• Z,,i 4
VI. ADDITIONAL INFORMATIONAND SITE MAP (Sketch of site showing house and waste irrigation
system, spray or drip field, location of well(s), and/or other relevant information- SHOW NORTHARROW)
APS-GPU Regional Staff Report (Sept 09)
Page 8 of 8 Pages

Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
1,1,1-Trichloroethane
Sample ..•
Descriptio
Sample Elate
200
< 1 < 1 < 1
,,
< 1 < 1
<
(water is treated
1
Active
<
Supply Well
through carbon
1 <
filter)
2/6/08
1
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
< 1
<
1
< 1
< 1
<
1
<
1
<
1
<
1
1,1-Dichloroethane
NE
< 1
<
1
< 1
< 1
<
1
<
1
<
1
<
1
1,1-Dichloroethene
7
< 1
<
1
< 1
< 1
<
1
<
1
<
1
<
1
2-Butanone
NE
< 5
<
5
< 5'
< 5
3.2
<
5
<
5
<
5
Acetone
NE
< 5
<
5
< 5
< 5
210 E
<
5
<
5
<
5
Bromodichloromethane
80*
< 1
<
1
< 1
< 1
<
1
<
1
<
1
<
1
Carbon disulfide
NE
< 1
<
1
< 1
< 1
<
1
<
1
<
1
<
1
Chloroform
80*0T32
' "7
<
1
< 1
9711r"
<
1
<
1
<
1
<
1
Chloromethane
NE
< 1
<
1
< 1
< 1
<
1-
<
1
<
1
<
1
cis-1,2-Dichloroethene
70
< 1
<
1
< 1
< 1
<
1
<
1
<
1
<
1
Methyl tert-butyl ether
NE
< 1
<
1
< 1
< 1
<
1.
<
1
<
1
<
1
Methylene Chloride
5
< 1
<
1
< 1
< 1
2.3
<
1
<
1
<
1
Tetrachloroethene
5
< 1
<
1
< 1
< 1
<.
1
<
1
<
1
<
1
Toluene
1,000
0.64'=4 J
<
1
< 1
< 1
0.44 J
<
1
<
1
<
1
Trichloroethene
5
< 1
<
1
< 1
< 1
1.1
<
1
<
1
P64 J
Vinyl chloride
2
< 1
<
1
< 1
< 1
<
1
<
1
<
1
<
1
µg/L- Micrograms per liter.
MCL- Federal Maximum Contaminant Level.
NE - MCL not established.
<- Not detected, result is the reporting limit (RL).
SM1:t�'1
Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
* - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
B - The associated method blank contains the target analyte at a reportable concentration. 1
E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260E unless otherwise indicated by an entry of "Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
Investigation.
Page 1 of 11
ZFr-

Table 4-5
Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
Compound
1,1,1-Trichloroethane
Sample ..-
Sample .. .
200
SupplyInactive
< 1 < 1
..Supply
< 1 < 1 < 1 < 1
< 3
, :.
0.33
J
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
<
1
<
1
2.5
9
1.2
<
1
< 3
0.23
J
1,1-Dichloroethane
NE
<
1
<
1
< 1
0.57
J
< 1
<
1
< 3
<
1
1,1-Dichloroethene
7
<
1
<
1
0.19 J
0.6
J<
1
<
1
< 3
0.24
J
2-Butanone
NE
<
.5 ti
<
5
< 5
<
5
< 5
<
5
< 15
<
5
Acetone
NE
<
5
<
5
< 5
<
5
b
< 5
<
5
< 15
<
5
Bromodichloromethane
80*
<
1
<
1
< 1
<
1
< 1
<
1
< 3
<
1
Carbon disulfide
NE
<
1
<
1
< 1
<
1
< 1
<
1
< 3
<
1
Chloroform
80*
<
1
<
1
< 1
<
1
< 1
<
1
< 3
<
1
Chloromethane
NE
<
1
<
1
< 1
<
1
< 1
<
1
< 3
<
1
cis-1,2-Dichloroethene
70
<
1
<
1
0.4 J
1.2
0.2 J
<
1
< 3
<
1
Methyl tert-butyl ether
NE
<
1
<
1
< 1
< .
1
< 1
<
1
28
26
Methylene Chloride
5
<
1
<
1
< 1
<
1
< 1
<
1
< 3.
<
1
Tetrachloroethene
5
<
1
<
1
0.33 J
0.8
:1
0.21 J
<
1
54
51
Toluene
1,000
<
1
<
1
< 1
<
1
< 1
<
1
< 3
<
1
Trichloroethene
5
<
" 1
<
1
4.2
13
2.8
<
1
< 3
0.35
J
Vinyl chloride
2
<
1
<
1
< 1
<
1
< 1
<
1
< 3
<
1
µg/L- Micrograms per liter. Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
MCL- Federal Maximum Contaminant Level. * - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
NE - MCL not established. B - The associated method blank contains the target analyte at a reportable concentration.
<- Not detected, result is the reporting limit (RL). E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260E unless otherwise indicated by an entry of "Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
Investigation. Page 2 of 11

Water Supply Data Summary
RCRA Facility Investigation.
Former Clifton Precision Site
Murphy, North Carolina
Sample ..
Date'Description /I Inactive .. pp
Sample
1,1,1-Trichloroethane 200 < 1 < 1 < 3 < 1 0.64 J < 1
1,1,2-Trichloro-1,2,2-trifluoroethane NE
0.31 J
0.43 J<
3
< 1
< 1
< 1
1,1-Dichloroethane NE
9.3
12
< 3
< 1
4.4
1.4
1,1-Dichloroethene 7
2.7
2
< 3
< 1
8.3.
2.3
2-Butanone NE
< 5
3 J
120
< 5
< 5
2.2 J
Acetone NE
< 5
< 5
< 15
< 5
< 5
< 5
Bromodichloromethane 80*
< 1
< 1
< 3
< 1
< 1
< 1
Carbon disulfide NE
< 1
< 1
< 3
< 1
< 1
< 1'
Chloroform 80*
< 1
< 1
< 3
< 1
14
< 1
Chloromethane NE
< 1
< 1
<- 3
< 1
< 1
< 1
cis-1,2-Dichloroethene 70
21
28
< 3
< 1
< 1
< 1
Methyl tert-butyl ether NE
< 1
< 1
< 3
< 1
< 1
< 1
Methylene Chloride 5
< 1
< 1 v
< 1
< 1
< 1
< 1
Tetrachloroethene 5
1.1
2
< 3
< 1
< 1
< 1
Toluene 1,000
< 1
< 1
< 3
< 1
< 1
< 1
Trichloroethene 5
150
210
< 3
1 < 1
< . 1
< 1
Vinyl chloride 2
0.2 J
0.3 J<
3
< 1
< 1
< 1
µg/L - Micrograms per liter. Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
MCL-Federal Maximum Contaminant Level. * Total trihalomethanes (chloroform + bromodichloromethane+dibromochloromethane+bromoform).
NE - MCL not established. B - The associated method blank contains the target analyte at a reportable concentration.
<- Not detected, result is the reporting limit (RL). E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260B unless otherwise indicated by an entry of "Not Analyzed."
C.IWOM Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
RInvestigation. Page 3 of 11

Table 4-5
Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
1,1,1-Trichloroethane
Sample ..•
Sample Date
200
Supply.ring
�
< 1 0.33 J < 1 "
:A
Inactive Supply Well
M�
Inactive Supply
:1
i
< 1
< 1
< 1
< 1 <
1
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
1 5
1:7
<
1
< 1
<
1
<
1
<
1
1,1-Dichloroethane
NE
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
1,1-Dichloroethene
7
0:85 J.
>1
0.83
0.93-
<
1
< 1
<
1
<
1
<
1
2-Butanone
NE
<
5
<
5
< 5
<
5
< 5
<
5
<
5
1.1 J
Acetone
NE
<
5
<
5
< 5
<
5
< 5
<
5
<
5
<
5
Bromodichloromethane
80*
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
Carbon disulfide
NE
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
Chloroform
80*
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
Chloromethane
NE
<
1
<
1
< 1
<
1
0.17 J
<
1
<
1
<
1
cis-1,2-Dichloroethene
70
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
Methyl tert-butyl ether
NE
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
Methylene Chloride
5
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
Tetrachloroethene
5
0.4� JI
F022' 3
`0_46
< .
1
< 1
<
1
<
1
<
1
Toluene
1,000
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
Trichloroethene
5
1.5
C51
}' `*1J-
<
1
< 1
<
1
<
1
<
1
Vinyl chloride
2
<
1
<
1
< 1
<
1
< 1
<
1
<
1
<
1
µg/L - Micrograms per liter.
MCL- Federal Maximum Contaminant Level.
NE - MCL not established.
<- Not detected, result is the reporting limit (RL).
Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
* - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
B - The associated method blank contains the target analyte at a reportable concentration.
E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260B unless otherwise indicated by an entry of "Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
Investigation.
Page 4 of 11

Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
1,1,1-Trichloroethane
Sample Code
Sample. ate
200
PW-32
Supply..
< 1
<
1
<
PW-33A
1
<
1
<
PW-34
1
pp
<
1
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
< 1
<
1
<
1
<
1
<
1
<
1
1,1-Dichloroethane
NE
< 1
<
1
<
1
<.
1
<
1
<
1
1,1-Dichloroethene
7
< 1
<
1
<
1
<
1
<
1
<
1
2-Butanone
NE
< 5
<
5
<
5
<
5
<
5
<
5
Acetone
NE
< 5
<
5
<
5
<
5
<
5
<
5
Bromodichloromethane
80*
< 1
<
1
<
1
<
1
-<
1
<
1
Carbon disulfide
NE
< 1
<
1
<
1
<
1
<
1
<
1
Chloroform
80*
< 1
<
1
<
1
<
1
<
1
<
1
Chloromethane
NE
< 1
<
1
<
1 .
<
1
<
1
<
1
cis-1,2-Dichloroethene
70
< 1
<
1
<
1
<
1
<
1
<
1
Methyl tert-butyl ether
NE
< 1
<
1
<
1
<
1
<
1
<
1
Methylene Chloride
5
< 1
<
1
<
1
<
1
<
1
<
1
Tetrachloroethene
5
< 1
<
1
<
1
<
1
<
1
<
1
Toluene
.1,000
< 1
<
1
<
1
<
1
<
1
<
1
Trichloroethene
5<
1
<
1
<
1
<
1
<
1
<
1
Vinyl chloride
2
< 1
<
1
<
1
<
1
<
1
<
1
µg/L - Micrograms per liter. Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
MCL - Federal Maximum Contaminant Level. * - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
NE - MCL not established. B - The associated method blank contains the target analyte at a reportable concentration.
<- Not detected, result is the reporting limit (RL). E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260E unless otherwise indicated by an entry of Not Analyzed."
'V Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
mith Investigation.- Page 5 of 11

Table 4-5
Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
Compo
1,1,1-Trichloroethane
Sample ..
Description /'
.- Date
200
Inactive Supply Well
0•
< 10 < 1 < 1
Inactive Supply
Well
0•
< 1
< 1
<
1
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
< 10
< 1
<
1
< 1
< 1
<
1
1,1-Dichloroethane
NE
3.2
J
< 1
<
1
< 1
< 1
<
1
1,1-Dichloroethene
7
< 10
< 1
<
1
< 1
< 1
<
1
2-Butanone
NE
440
1.1 J<
5
< 5
< 5
<
5
Acetone
NE
29
J
< 5
<
5
< 5
< 5
<
5
Bromodichloromethane
80*
< 10
< 1
<
1
1.9
< 1
<
1
Carbon disulfide
NE
44
< 1
<
1
< 1
< 1
<
1
Chloroform
80*
700
0.14.11
<
1
17
< 1
<
1
Chloromethane
NE
4.2
J
< 1
<
1
< 1
< 1
<
1
cis-1,2-Dichloroethene
70
< 10
< 1
<
1
< 1
< 1
<
1
Methyl tert-butyl ether
NE
< 10
< 1
<
1
< 1
< 1
0.75
Methylene Chloride
5
2
JB
< 1
<
1
< 1
< 1
<
1
Tetrachloroethene
5
< 10
< 1
<
1
< 1
< 1
<
1
Toluene
1,000
10
0.23 J
<
1
< 1
< 1
<
1
Trichloroethene
5
< 1
<
1
< 1
< 1
<
1
Vinyl chloride
]LIO
2
10
< 1
<
1
< 1
< 1
<
1
µg/L- Micrograms per liter. Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
MCL - Federal Maximum Contaminant Level. * - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
NE - MCL not established. B - The associated method blank contains the target analyte at a reportable concentration.
<- Not detected, result is the reporting limit (RL). E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOC§) by Method 8260B unless otherwise indicated by an entry of" Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
Investigation. Page 6 of 11

Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
Sample ..
Description /I
Sample..
<
1
Inactive
<
: •
..
1
< 1
<
1
< 1
<
.. Well
1
< 1
<
..
Active
..
1
1,1,1-Trichloroethane 200
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
1,1-Dichloroethane
NE
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
1,1-Dichloroethene
7
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
2-Butanone
NE
1.1 J<
5
< 5
<
5<
5
<
5
< 5
<
5
Acetone
NE
<
5
<
5
< 5
<
5
< 5
<
5
< 5
<
5
Bromodichloromethane
80*
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
Carbon disulfide
NE
0.49 J
<
1
< 1
<
1
< 1
<
1
< 1
<
1
Chloroform
80*
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
Chloromethane
NE
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
cis-1,2-Dichloroethene
70
<
1
<
1
< 1
< .
1
< 1
<
1
< 1
<
1
Methyl tert-butyl ether
NE
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
Methylene Chloride
5
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
Tetrachloroethene
5
0.19 J
0.22 J<
1
0.11 J
3.1
3
1.6
<
1
Toluene
1,000
<
1
<
1
< 1
<.
1
< 1
<
1
< 1
<
1
Trichloroethene
5
<
1
<
1
< 1
<
1
< 1
<
1
< 1
<
1
Vinyl chloride
2
<
1
<
1
< 1
<
1
< 1
<
1 J<
1
<
1
µg/L- Micrograms per liter. .
MCL- Federal Maximum Contaminant Level.
NE - MCL not established.
<- Not detected, result is the reporting limit (RL).
CM
Irigith
Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
* - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
B - The associated method blank contains the target analyte at a reportable concentration.
E - Estimated result, result exceeds, the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260E unless otherwise indicated by an entry of"Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
Investigation.
Page 7 of 11

Table 4-5
Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
Sample ..
,•
1,1,1-Trichloroethane
Description
200
Active
< 1 < 1 < 1 < 1 < 1 < 1 < 1
<
1
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
1,1-Dichloroethane
NE
<
1
<
1
<
1
< . 1
< 1
<
1'
< 1
<
1
1,1-Dichloroethene
7
<
1
<
1
Q-164 J
!< 1
< 1
<
1
< 1
<
1
2-Butanone
NE
<
5
<
5
<
5
< 5
< 5
<
5
< 5
<
5
Acetone
NE
<
5
<
5
<
5
< 5
< 5
<
5
< 5
<
5
Bromodichloromethane
80*
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
Carbon disulfide
NE
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
Chloroform
80*
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
Chloromethane
NE
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
cis-1,2-Dichloroethene
70
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
Methyl tert-butyl ether
NE
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
Methylene Chloride
5
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
Tetrachloroethene
5
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
Toluene
1,000
<
1
<
1
<
1
< 1
< 1.
<
1
< 1
<
1
Trichloroethene
5
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
Vinyl chloride
2
<
1
<
1
<
1
< 1
< 1
<
1
< 1
<
1
µg/L- Micrograms per liter.
MCL- Federal Maximum Contaminant Level.
NE - MCL not established.
<- Not detected, result is the reporting limit (RL).
Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
* - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
B - The associated method blank contains the target analyte at a reportable concentration.
E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260E unless otherwise indicated by an entry of "Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
Investigation. Page 8 of 11

Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
111,1-Trichloroethane
Sample Codel
Description /
Sample Date
200
PW-67 I PW-68/69
. 0
< 1 < 1
I PW-78
ct ve
Sup -I.. -'ell
I PW-80
Active
Supply We] —]—
< 1 < 1
<
Inactive Supply
1
[
<
Well
2/7/08
1
< 1
< 1
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
1,1-Dichloroethane
NE
< 1.
<
1
<
1
< 1
<
1
< 1
<
1
<
1
1,1-Dichloroethene
7
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
2-Butanone
NE
< 5
<
5
<
5
< 5
<
5
< 5
<
5
<
5
Acetone
NE
< 5
<
5
<
5
< 5
<
5
< 5
<
5
<
5
Bromodichloromethane
80*
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
Carbon disulfide
NE
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
Chloroform
80*
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
Chloromethane
NE
< 1
<
1
<
1
<" 1
<"
1
< 1
<
1
<
1
cis-1,2-Dichloroethene
70
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
Methyl tert-butyl ether
NE
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
Methylene Chloride
5
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
Tetrachloroethene
5
< 1
<
1
0.3�: J
< 1
<
1"
< 1
<
1
<
1
Toluene
1,000
< 1
0.46 J
<
1
< 1-
<
1
< 1
<
1
<
1
Trichloroethene
5
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
Vinyl chloride
2
< 1
<
1
<
1
< 1
<
1
< 1
<
1
<
1
µg/L- Micrograms per liter: Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
MCL- Federal Maximum Contaminant Level. * Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
NE - MCL not established. B - The associated method blank contains the target analyte at a reportable concentration.
<- Not detected, result is the reporting limit (RL). E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260B unless otherwise indicated by an entryof "Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
_SMIt Investigation. 4 Page 9 of 11

Table 4-5
Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
..
1,1,1-Trichloroethane
Sample ..
200
Inactive Supply Well
10/11/07 0:
< 1 < 1 < 1
00
< 1 < 1 < 1 < 1
< 1
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
1,1-Dichloroethane
NE
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
1,1-Dichloroethene
7
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
2-Butanone
NE
<
5
<
5
<
5
<
5
<
5
<
5
<
5
< 5
Acetone
NE
<
5
<
5
<
5
<
5
<
5
<
5
<
5
< 5
Bromodichloromethane
80*
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
Carbon disulfide
NE
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
Chloroform
80*
<
1
2.6
2.3
<
1
<
1
0.11 J
<
1
< 1
Chloromethane
NE
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1 ,
cis-1,2-Dichloroethene
70
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
Methyl tert-butyl ether
NE
<
1
1.1
1.1
<
1
<
1
<
1
< 1
Methylene Chloride
5
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
Tetrachloroethene
5
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
Toluene
1,000
<
1
<
1
<
.ri
<
1
<
1
<
1
<
1
< 1
Trichloroethene
5
<
1
<
1
<
.'I-<
1
<
1
<
1
<
1
< 1
Vinyl chloride
2
<
1
<
1
<
1
<
1
<
1
<
1
<
1
< 1
µg/L - Micrograms per liter.
MCL- Federal Maximum Contaminant Level.
NE - MCL not established.
<- Not detected, result is the reporting limit (RL)
Description is from the 2007 survey with the exception that parcels connected to To water in 2008 have been updated.
* - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
B - The associated method blank contains the target analyte at a reportable concentration.
E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL. .
Samples analyzed for48 volatile organic compounds (VOCs) by Method 8260E unless otherwise indicated by an entry of"Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility -
Investigation. Page 10 of 11

Water Supply Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
Compound
1,1,1-Trichloroethane
Sample ..
.
Sample Date..
200
< 1
.
..
< 1
1,1,2-Trichloro-1,2,2-trifluoroethane
NE
< 1
< 1
1,1-Dichloroethane
NE
< 1
< 1
1,1-Dichloroethene
7
< 1
< 1
2-Butanone
NE
< 5
< 5
Acetone
NE
< 5
< 5
Bromodichloromethane
80*
< 1
< 1
Carbon disulfide
NE
< 1
< 1
Chloroform
80*
< 1
< 1
Chloromethane
NE
< 1
< 1
cis-1,2-Dichloroethene
70
< 1
< 1
Methyl tert-butyl ether
NE
< 1
< 1
Methylene Chloride
5
< 1
< 1
Tetrachloroethene
5
< 1
< 1
Toluene
1,000
< 1
< 1
Trichloroethene
_ 5
< 1
< 1
Vinyl chloride
2
< 1
< 1
µg/L - Micrograms per liter.
MCL- Federal Maximum Contaminant Level.
NE - MCL not established.
<- Not detected, result is the reporting limit (RL).
Description is from the 2007 survey with the exception that parcels connected to Town water in 2008 have been updated.
* - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
B - The associated method blank contains the target analyte at a reportable concentration.
E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260E unless otherwise indicated by an entry of "Not Analyzed."
Compounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
Investigation.
Page 11 of 11

Surface Water Data Summary
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
CompoundSample
Sample Description /
Date
Water
< 1
Supply Spring
0.33 J
<
. 1
<
10/10/07
1
1,1,1-Trichloroethane 200
1,1,2-Trichloro'-1,2,2-trifluoroethane
NE
1.5
1.7
2.4
<
1
1,1-Dichloroethane
NE
< 1
<
1
<
1
<
1 .
1,1-Dichloroethene
7
d�$5 J
0 83 J
q 93f J
&5 J
2-Butanone
NE
< 5
<
5
<
5
<
5
Acetone
NE
< 5
<
5
<
5
<
5
Bromodichloromethane
80*
< 1
<
1
<
1
<
1
Carbon disulfide
NE
< 1
<
1
<
1
<
1
Chloroform
80*
< 1
<
1
<
1
<
1
Chloromethane
NE
< 1
<
1
<
1
s 014 J
cis-1,2-Dichloroethene
70
< . 1
<
1
<
1
<
1
Methyl tert-butyl ether
NE
< 1
<
1
<
1
<
1
Methylene Chloride
5
< 1
<
1
<
1
<
1
Tetrachloroethene
5
0 4`• J
D,,42, J
i VJG. 1 J<
1
Toluene
1,000
< . 1
<
1
<
1
<
1
Trichloroethene
5
FWJ
W7
M7
<
1
Vinyl chloride
2
< 1
<
1
<
1
<
1
µg/L- Micrograms per liter. * - Total trihalomethanes (chloroform + bromodichloromethane + dibromochloromethane + bromoform).
MCL- Federal Maximum Contaminant Level. B - The associated method blank contains the target analyte at a reportable concentration.
NE - MCL not established. b - The associated trip blank contains the target analyte at a detectable concentration.
<- Not detected, result is the reporting limit (RL). E - Estimated result, result exceeds the calibration range.
J - Estimated result, result is less than the RL.
Samples analyzed for 48 volatile organic compounds (VOCs) by Method 8260B unless otherwise indicated by an entry of "Not Analyzed."
CDCCompounds listed in this table are the VOCs reported above the RL in any sample reported during the RCRA Facility
��� 'Investigation. Page 3 of 3

and Proposed Modifications
Corrective Action Monitoring Plan
Former Clifton Precision Site
Murphy, North Carolina
well Code Onsite or Station Description
Offsite?
MW-1 Onsite Regolith Well
CAMP
Sampling sampling
Water Level
X
ProposedCurrent
Sampling
Sampling
I Water Level
X
Historically monitored forwater levels only
MW-2R
Onsite
Regolith Well
Not historically monitored
MW-3
Onsite
Regolith Well
Not historically monitored
MW-4
Onsite
Regolith Well
Not historically monitored
MW-5
Onsite
Transition Well
X
X
Sampling covered by "GW" well sampling
MW-6
Onsite
Bedrock Well
X
X
X
Sampling covered by RW-1D, GW-5B, GW-7B, and GW-8B
MW-7
Onsite
Regolith Well
Not historically monitored
MW-8
Onsite
Regolith Well
Historical sampling indicated low and stable VOC
concentrations. Interior to site.
MW-9
Onsite
Regolith Well
X
X
Upgradient. Use water level for potentiometric surface
mapping.
MW-10
Onsite
Regolith Well
X
X
X
X
Monitor VOCs along the northern downgradient property
boundary
MW-11
Onsite
Transition / Bedrock Well
X
X
X
X
Monitor VOCs along the northern downgradient property
boundary-
MW-12
Onsite
Regolith Well
X
X
X
X
MonitorVOCsonsite downgradientofformersource
areas
MW-13
Onsite
Regolith Well
X
X
X
X
Monitor VOCs along the northwestern downgradient
property boundary
MW-14
Onsite
Transition Well
Not historically monitored
MW-14R
Onsite
Bedrock Well
X
X
Not historically sampled for VOCs
W-15
Onsite
Regolith Well
Not historically sampled for VOCs. Nearby recovery well
RW-4, which is recommended for continued sampling.
W-16
IMW-17
Onsite
Regolith Well
shallow well with limited historicalsampling that was all
non -detect
Onsite
Transition Well
X
X
N
X
Very limited historical VOC detections but continue to
sample annually to monitor VOC concentrations (or lack
thereof) at the southwest property boundary
MW-18
Onsite
Regolith Well
X
X
Limited or no VOCs historically detected and considered
upgradient of site. MW-18 and MW-19R will be used for
potentiometric surface mapping.
MW-19
Onsite
Bedrock Well
MW-19R
Onsite
Bedrock Well
X
X
MW-20
Onsite
Regolith Well
X
X
X
X
Monitor VOCs on site downgradient of former source
areas to the north. Historically unstable concentrations.
Page 5 of 10

Table 2
CAMP Summary and Proposed Modifications
Corrective Action Monitoring Plan
Former Clifton Precision Site
Murphy, North Carolina
Current
CAMP
Proposed
Onsite or
Well ..
Offsite?
Sampling
Sampling
Sa m piing
Sampling
I
MW-21
Onsite Regolith Well
Redundant withMW-20
MW-22
Onsite
Transition / Bedrock Well
X
X
Historically monitored for water levels only
MW-23
Offsite
Regolith Well
X
X
Historical sampling for this well cluster showed low and
MW-24
Offsite
Regolith Well
stable VOC concentrations
MW-25
Offsite
Transition / Bedrock Well
X
X
MW-26
Onsite
Regolith Well
See rationaleforMW-18,-19,and-19R
MW-27
Onsite
Regolith Well
X
X
Limited historical VOC detections. Considered upgradient
of source areas.
MW-28
Onsite
Regolith Well
X
X
X
X
Monitor VOCs in regolith along the northern
downgradient property boundary
MW-29
Onsite
Regolith Well
X
X
Sampling conducted in nearby MW-28
MW-30
Onsite
Transition / Regolith Well
X .
X
Redundant with MW-10 and MW-28
MW-31
Onsite
Transition / Regolith Well
X
XII
Redundant with RW-2, RW-3, MW-28, and MW-32
MW-32
Onsite
Transition / Regolith Well
X
X
X
X
Monitor VOCs on site downgradient of formersource
areas
MW-33
Offsite
Re olith Well
g�gX�
X
;� "' `'
X
Add to sampling program for monitoring groundwater
Q0
reinjection performance
MW-34
Offsite
Regolith Well
X
X
X
Monitor the extent of VOCs off site to the north but
W��'Uo
switch to annual considering the relatively stable VOC
concentrations. Well results reported to Truett Baptist.
MW-35
Offsite
Regolith Well
X
X
X
X
Monitor the extent of VOCs off site to the west
MW-36
Onsite
Bedrock Well
X
X
X
X
Monitor VOCs in bedrock along the northern
clowngradient property boundary
MW-37
Onsite
Bedrock Well
X
X
X
X
Monitor VOCs along the western downgradient property
boundary
MW-38
Onsite
Bedrock Well
X
X
Very limited VOCs in previous sampling. MW-37 a better
marker for property boundary VOC concentrations in
bedrock.
MW-39
Onsite
Bedrock Well
X
X
Limited historical sampling and sampling performed
primarily showed any VOCs below reporting limits
MW-40
Offsite
Bedrock Well
Xa
X ¢
X
Add to sampling program for monitoring groundwater
reinjection performance
Page 6 of 10

y and Proposed Modifications
Corrective Action Monitoring Plan
Former Clifton Precision Site
Murphy, North Carolina
Onsite or
Current
CAMP
Proposed
Well ..
Offsite?
Sampling
Sampling
Sampling I Sampling
MW-41
Offsite
Bedrock Well
X
X
X
Monitor the extent of VOCs offsite to the north but switch
to annual considering the relatively stable VOC
Ti
4 ,.
concentrations. Well results reported to Truett Baptist.
MW-42
Offsite
Regolith Well
X
X
X
X
Monitor the extent of VOCs off site to the west but switch
to annual considering stable VOC concentrations
MW 43
Offsite
Bedrock Well
X
X
X
X
Monitor the extent of VOCs off site to the west but switch
n�
to annual considering stable VOC concentrations
MW-44
Offsite
Bedrock Well
X
X
Limited historical sampling and limited VOCs when
sampled
MW-45
Ofsite
Bedrock Well
X
X
r=
X=
X
Very limited historical VOC detections but continue to
T� .a
sample annually to monitor VOC concentrations (or lack
thereof) at the southwest property boundary
MW-46
Offsite .
Regolith Well
X
X
Not historically sampled. MW-34 a better markerforsite-
related VOCs.
MW-47
Offsite
Bedrock Well
X
X
X
X
Monitor the extent of VOCs off site to the north but
switch to annual considering the relatively stable VOC
concentrations. Well results reported to Truett Baptist.
MW-48
Offsite
Regolith Well
Not historically monitored. Access issues.
MW-49
Ofsite
Regolith Well
X
X
Limited VOC detections. Near upgradient boundary.
MW-SO
Ofsite
Bedrock Well
X
X
Limited VOC detections. Near upgradient boundary.
MW-51
Offsite
Bedrock Well
X
X
X
Not recommended for continued sampling as no VOCs
detections since 2008
MW-52
Offsite
Regolith Well
X
X
Historically monitored for water level only as shallow well
far downgradient of site
MW-53
Offsite
Bedrock Well
X
X
X
Not recommended for continued sampling as no VOCs
detections since 2008
MW-54
Offsite
Regolith Well
X
X
X
This well cluster not recommended for continued
sampling since very limited VOCs. Few times that TCE was
detected, it was well below the MCL.
MW-55
Offsite
Bedrock Well
X
X
X
Page 7 of 10

Table 2
CAMP Summary and Proposed Modifications
Corrective Action Monitoring Plan
Former Clifton Precision Site
Murphy, North Carolina
Onsite or
Current CAMP
Proposed
Well ..
Offsite?
Sampling Sampling
Sampling Sampling
MW-S6
Onsite
Transition Well
"g
Per offsite report (CDM Smith, March 2012), these wells
MW-57
Onsite
Transition Well
do not appear to be in the migration path for VOCs from
the site to residential wells to the southwest
MW-60
Offsite
Regolith / Transition Well
^ ` X " "'
ssX- Per offsite report (CDM Smith, March 2012), these wells
MW-61
Offsite
Bedrock Well
;X
appear to be in a highly transmissive zone north of Slow
'I..
Creek
MW-62
Offsite
Regolith / Transition Well�X'�,,
r Monitor VOC concentrations between the site and
MW-63
Offsite
Bedrock Well
°X 1S
a%(" monitoring wells further to the north:
GW-1B
Onsite
BedrockWell
Sampling covered by RW-iD, GW-SB, GW-78, and GW-8B
GW-6S
Onsite
Regolith (Shallow) Well
Limited and immediately upgradient of former
GW-6D
Onsite
Regolith (Deep) Well
source areas
GW-6B
Onsite
Bedrock Well
GW-7
Onsite
Regolith Well
X Monitor VOCs in deep regolith near former source areas
GW-7B
Onsite
Bedrock Well
t " X 101 W:"�'
,. '..
w t Monitor VOCs in bedrock near former source areas
.A',.x
GW-8
Onsite
Regolith Well
E W
;�0' Monitor VOCs in deep regolith near former source areas
5
GW-8B
Onsite
Bedrock WellgX$Z?�
€X MonitorVOCs in bedrock near formersource areas
GW-5D*
Onsite
Regolith (Deep)Well"'
j(' Sampling covered by other "GW"-wells
GW-SB*
Onsite
Bedrock Well
X Sampling covered by other former source area wells
GW-1S
Onsite
Regolith (Shallow) Well
X. VOC concentrations in shallow groundwater nearsource
area not as much of a concern
GW-1D
Onsite
Regolith (Deep) Well
X Sampling covered by other former source area wells
GW-2S
Onsite
Regolith (Shallow) Well
X- VOC concentrations in shallow groundwater near source
area not as much of a concern
GW-2D
Onsite
Regolith (Deep) Well
g s
MonitorVOCs in deep regolith near former source areas
GW-3S
Onsite
Regolith (Shallow) Well
"t°;;, X VOC concentrations in shallow groundwater near source
area not as much of a concern
GW-3D
Onsite
Regolith (Deep) Well
X
, j( - Monitor VOCs in deep regolith near former source areas
GW 4
Onsite
Regolith Well
Sampling covered by other "GW" wells
Page 8 of 10

f and Proposed Modifications
Corrective Action Monitoring Plan
Former Clifton Precision Site
Murphy, North Carolina
Current CAMP
Proposed
Onsite or
Well .. .Rationale
Level
Sampling Sampling
Sampling
I Sampling
IWater
RW-IS Onsite Regolith Recovery Well
X X
X
X
X
X Monitor groundwater extraction performance
RW-1D
Onsite
Bedrock Recovery Well
X
X
X
RW-2
Onsite
Regolith Recovery Well
X
X
X
RW-3
Onsite
Regolith Recovery Well
X
X
X
X
FIWXm
MIXAM
RW-4
Onsite
Regolith Recovery Well
MMAM
RW-5
Onsite
Bedrock Recovery Well
PW-16
Offsite
Bedrock Supply Well
X
X
X '
X Monitor extent of VOCs to the west. Evidence of site -
related VOCs.
PW-18A
Offsite
Bedrock Supply Well
X
X
Recommend well be abandoned based on observed
construction and integrity issues.
PW-22A
Offsite
Bedrock Supply Well
X
X
Recommend well be abandoned as it could be a source of
Minsideeper
migration for compounds from shallower depths into
bedrock.
PW-23
Offsite
Bedrock Supply Well
X
X
Not recommended for sampling due to shallow depth and
limited evidence of site -related VOCs. However, this well.
may need to be sampled to appease the homeowner.
Offsite
Bedrock Supply Well
X
X
recommended for continued sampling as limited
JPW-39'
evidence of site -related VOCs in this well.
MINot
r
Page 9 of 10

Table 2
CAMP Summary and Proposed Modifications
Corrective Action Monitoring Plan
Former Clifton Precision Site
Murphy, North Carolina
Well .d
CMP-1
Onsite or
Upstream
Description
Creek Monitoring Point
Current CAMP
Sampling Sampling
X
Proposed
Sampling Sampling
X
No recommended changes to surface water and spring
CMP-3
Adjacent Creek Monitoring Point
X X
CMP-4
Downstream Creek Monitoring Point
X X
SW-3
Downstream
Surface Water Station
X
X
sampling program. Samples are easy to collect from these
locations and provide useful data regarding impacts to
Slow Creek and the downgradient spring.
SW-6
Downstream Surface Water Station
X X
SW-10
Downstream Surface Water Station
X X
SP-26
Offsite Spring
X
X
Notes:
BGS - Below Ground Surface
TOC - Top of casing
PW R - Partially Weathered Rock
Highlighted boxes under "Proposed CAMP" indicate changes from the current CAMP.
This table includes all monitoring wells but onlv those residential wells and surface water samoline points that have historically been monitored
Sampling proposed for wells in the immediate vicinity of the former source_areas is short-term (likely October 2012 only) as additional interim measures are planned to address groundwater.in these areas: A
specific source zone monitoring plan will be develop ed.to support monitoring,VOC concentrations in the former.source areas during the additional planned interim measures. This will likely -be separate4rom
monitoring dbnducted.under the CAM P.The associated wells in these areas are MW-4, MW-5; MW-S; and all 'GW" wells.
Page 10 of 10

Messer
MW-44 I
b MW-47
0
®V
NONNI
IL U 1-ii
' �0
MW-50
MW-11
MW43 t�i�� RW 5
t MW 14R MW-36 GW 8B
r
O-MW 37 MW-6
GW-7B GW-1B
o �o RW-1
r MW-38 of .0 I
1 MW�-39 GW-6B
i GW-5B
Q i
MW-56 ?
PW-22A 6-MW-57 Former Clifton /
O Precision Site
o O-MW-45
°r
MW-2 `t�,�_.
PW-23 MW-19R-�
Parcel Lines
Facility -Owned
MW-19 / Properties
F
PW- 9/ O
Coarse —Grained Data Point •
PW-37 PW-38A
/ spring ®-
10.005— Total VOCs in mg/L
��... >-=�.J�_!� • Total VOCs include 1,1,1-Trichloroethane,
"•�-...�� • �- ' • 1,1-Dichloroethene, Tetrachloroethene,
-� and Trichloroethene
N
Scale in Feet
0 350 700 1,050 1,400
Figure 5-8: Bedrock Zone Total VOCs
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, Cherokee County, North Carolina

Smith
Messer
Q
PW-87
MW-46
Y
PW-8":'sMW34���h�� r (t >>
.. 0.01 _
MW 24 I
MW 62
MW-49
MW 29 RW 3
k 7 W 2 � MW-21
MW10 4 MW 20
x10� s ?; MW31
13 MW-28 MW 32 I
MW 15 O MW 5
O V-1
1 +l GW-8
GW-2D
RW 4 MW 12 GW-4S
f
Q GW-7
MW-8 G -1 GW-ID
O GW-6D .
t �oos o.ol
4
MW-27
Former Clifton
Precision Site P -
MW-17 l/ PW-58
MW-16
•
Parcel Lines Facility -Owned
Properties
/
— - - —
0
Coarse -Grained Data Point •
Alluvium
/.`7
. ,
Spring
0.005— Total VOCs in mg/L
•
Total VOCs include 1,1,1-Trichloroethane,
- .� _ •
1,1-Dichloroethene, Tetrachlorcethene,
--�,,
and Trichloroethene
Figure 5-7: Regolith/Transition Zone Total VOCs
RCRA Facility Investigation
Scale in Feet Former Clifton Precision Site
0 350 boo 1,050 1,400
Murphy, Cherokee County, North Carolina

3.4.2 Extraction and Injection Flow Rates
The existing GWTS includes extraction wells RW-1 S, RW-3, RW-4, and RW-5 and is
operating at total flow rate of 20 to 25 gpm. CDM Smith conducted a well capacity test at
extraction well RW-4 and has indicated that the long-term sustainable pumping rate for
this well is estimated at about 50 gpm.
The new GWTS will include the same four extraction wells and, with an increased flow
rate from well RW-4, the anticipated operating flow rate will be 56 gpm. The maximum
design flow rate for the new system will be 100 gpm, which includes additional capacity
for potential future groundwater extraction and injection wells. The anticipated initial
operating and maximum groundwater extraction and injection flow rates are summarized
in the table below:
Well Type
Well ID
Hydrogeologic
Zone
Current Flow
Rates
(gpm)
Operating
Flow Rates
(gpm)
Maximum
Flow Rates
(gpm)
RW-1 S
Re olith
1.0
1.0
1.0
RW-3
Re olith
1.5
1.5
1.5
Extraction
Wells
RW-4
Re olith
17.5
50.0
50.0
RW-5
Bedrock
3.0
3.5
3.5
Future Well(s)
TBD
N/A
N/A
44.0
Total Flow Rates
22.0
56.0
100.0
INJ-01
Bedrock
N/A
1.5
3.0
INJ-02
Re olith
N/A
15
22
INJ-03
Bedrock
N/A
1.5
3.0
Injection
INJ-04
Re olith
N/A
15
22
Wells
INJ-05
Bedrock
N/A
1.5
3.0
INJ-06
Re olith
N/A
15
22
INJ-07
Bedrock
N/A
1.5
3.0
INJ-08
Re olith
N/A
15
22
Total Flow Rates
N/A
S6.0
100 Q
i ou —to oe aeterminea; N/A - not appncaote.
3.4.3 Conveyance System for Groundwater Extraction
Extracted groundwater will be transferred to the treatment plant through (1) an existing
single -wall pipeline from well RW-1S and the WMU-B SVE system and (2) an existing
2013-0812-Murphy-Offsite GW Design Report.docx 3-5
() !-,,1` G-w-Ts oel,,), �p���

".I MW-47 t1Q7&32} r
"� M:So (90 td.8t_e7
OMY
1\
11R
k 1 ti M14W f?C1i�1k—r— 9„��1, 1 1 i W
•_ jj�4Y54
IF
. � a
� r a. a�.'� t , .. ��saV '" /) _ .. ' �rq"tl'�'N =d.1 J � C:MW:45 (96if h �W+w,i,n;,, ,-. t ipi,• •. �';.. " � .Y r.�
4,1
LMWY btx t rzs.,,51Are ti }
x. ., ii ,� `*s":.'. •:.... ', V. .. .�,�`�' 1 -�i. tlq• i3q'{",x„5;,. ..'�
r
+
d.
t�Ws zs.zsf
Properties
.",
t Parcel Lines Alluvium
Xq, Spring 0—
Bedrock Zone Potentiameble Surface
r je 1
��.
x t North American Vertical Datum 1988
411
V 4
a � „

+ Regolith Monitor Well O Proposed Semi -Annual VOC Sampling Scale in Feet
* Bedrock Monitor Well D Proposed Annual VOC Sampling 32.5 0 65
+ Transition Monitor Well
® Regolith Recovery Well
® Bedrock Recovery Well
O Proposed Water Level Only
Water levels will also be collected
from all well sampling locations.
Figure 2
Onsite Well Locations
Corrective Action Monitoring Plan Revisions
Former Clifton Precision Site
Murphy, North Carolina

9rq0s=.I
SDK' �l°11w.1
scu- e-)
fwfosert
AAIW Il
544(11^)
+ Regolith Monitor Well ® Regolith Recovery Well A Creek Monitoring Point 0 Proposed Semi -Annual VOC Sampling
Figure 1
i1E Bedrock Monitor Well ® Bedrock Recovery Well 0 RE Surface Water Station ■ Proposed Annual VOC Sampling Scale in Feet Well and Surface Water Locations
4 Transition Monitor Well -A Bedrock Supply Well * Spring O Proposed Water Level Only Corrective Action Monitoring Plan Revisions
CDM
Smith Water levels will also be collected from all well sampling locations. 125 0 250 Former Clifton Precision Site
All monitoring wells are shown but only those surface water stations and residential wells that have historically been sampled are shown. Murohv. North Carolina
C ftm f La k—A- rev Si ' ti

WATER QUALITY REGIONAL OPERATIONS - AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: January 7, 2014
To: M-Lando TM aeon, _ ._ SAPS
❑Art Barnhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
❑ Rick Bolich, RRO-APS
From: Thomas Slusser, , Groundwater Protection Unit
Telephone: [phone]
E Mail. [e-mail]
A. Permit Number: WQ_Q0-6&8 -
B. Owner: Northrup Grummon
C. Facility/Operation:
❑ Proposed ® Existing
D. Application:
❑ David May, WaRO-APS
❑ Morella Sanchez -King, WiRO-APS
❑ Sherri Knight, WSRO-APS
Fax: [phone]
JAN 0 9 2013
Water Quality Regional Operations .
Asheville Regional Office
® Facility Operation
L Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H,R Infiltration
❑ Recycle ❑ I/E Lagoon ®�W Rediation-(I�
❑ UIC - (51) in -situ groundwater remediation
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
vet ly -71 s le6r s e,4 +tbe ge? 1; c O"fr®ol w." -aU, it JS'LiK C40 14734--�M40#11-4- Led- vw- k-a w14 :4ppv need A w da le,
s •� v
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
® Return a Completed Form APSARR.
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO*.
* Remember that you will be responsible for coordinating site visits, reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above. J
RO-APS Reviewer: i�i�✓1/4't.J j (,Z�c� Date:
FORM: APSARR 02/06 1 Page 1 of 1

Table 4-25
Reinjection Well Aquifer Test Results
RCRA Facility Investigation
Former Clifton Precision Site
Murphy, North Carolina
Aquifer Testing Data
Preliminary UIC Permit
Application Data
Xgpm
5 gpm
20 gpm
Specific
Specific
Static Water
Aquifer Test Aquifer
Test
Wellhead
Wellhead
Wellhead
Well Code
Level Depth
Pumping Rate Drawdown
Pumping
Reinjection
Reinjection
Reinjection
Reinjection
(feet)
(gpm)
(feet)
Capacity
(gpm/foot)
Capacity
(psi/gpm)
pressure
Pressure
Pressure
(psi*)
(psi*)
(psi*)
®
1
1
1
®
1
1 1
1
1
1 1
1
1 1
UIC - Underground Injection Control
NA - Not applicable
gpm - gallons per minute
psi* - pounds per square inch, positive values indicate positive pressure, negative values
indicate flow under gravity.

PRELIMINARY MAINTENANCE SCHEDULE
OFFSITE GROUNDWATER TREATMENT SYSTEM
FORMER CLIFTON PRECISION FACILITY
Task January February March
_ . ,• -. ,. • F - ,. ..�,. ..
_GroundwaterE.�dractfonSystem :,.,.,.,, • :.:_ r .-
Service submersible um s if a realer than 10% decrease in flow is observed
Check duplex filter housingpressure and replace fillers when the inlet pressure exceeds 6 psi
Airripper
-
YInspect
air stripper and associated equipment blower, sump pump, etc, for abnormal o eration
m
Advanced
Ins act the UV reactor and associated equipment for abnormal operation
Oxidation
System
.,:
Empty the UV reactor drain line
Inspect the H2O2 pump components for leaking, swelling, cracking, discoloration, or corrosion
Groundwater
Injection
Pstem
Inspect flow sensors for build-up and abnormal operation
Groundwater Extraction System
Inspect and dean interior, exterior, and perimeter of wellhead shelters
Inspect the level switch in the air stripper sump for build-up and abnormal operation
. . "I , .-
Air Stripper
„
Collect field measurements of temperature, pH, and conductivity from SP-3 and SP-6
Advanced Oxidation S stem
y
Clean the exterior of the UV reactor with a mild soap and water solution
i
Clean quartz sleeves and UV sensor
p
Electrical
Panels
and Contra, System
-
Open and inspect the control panel for moisture intrusion
Remove debris and other materials from panel vicinities
Inspect the touchscreen for proper operation
;. . General
Site
Maintenance
• -
Ins eclwell vaults and remove debris and water
'
Inspect pump house and shipping containers for damage, record observations, and repair as needed
Remove debris in the vicinity of all equipment
-
Analytical Program
Collect samples for chemical analysis from SP-3, SP-6, and SP-7
:Air Stripper
Inspect aeration trays through cleanout ports
Check the alignment of the blower shaft
�.,
Check the tightness of all bolls and set screws on the blower
=
m
Lubricate the blower fan and motor bearing as needed
Inspect the blower inlet and outlet duct work for obstructions and remove as needed
cc
Ins ec the blower wheel blades for accumulation of dust and dirt and clean as needed
CY
Advanced
Oxidation
System
Collect field measurements for residual hydrogen peroxide from the AIDS discharge
Inspect UV lamps for a change in color and replace per manufacturer's literature
-'
Inspect vacuum and pressure relief valves for leaks
°
Inspect water level sensor cap for build-up and damage and replace as needed
Ins act UV lam ins for overheating, corrosion, or bending
- Air Stripper - -
Clean the interior and exterior of the air stripper
Advanced Oxidation System
- -
De ressurive, drain, and clean the UV reactor
Inspect the UV lamp socket
Inspect the quartz lamp sleeves for cleanliness '
`C
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Q
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Ins ect rod seal for leakage at the drive screw
Ins ect the stop late flange and drive screw for build-up and wear
Ins ect drive nuts of thrust bushing for UV decay
linseed
bearing, limit switch compression spring, switch rod seals and roof fans for abnormal operation
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LTIFAA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder
Governor Director
December 11, 2013
Joseph P. Kwan — Corporate Director, Environmental Remediation
Northrop Grumman Guidance and Electronics Company, Inc.
2980 Fairview Park Dr.
Falls Church, VA 22042
Dear Mr. Kwan:
John E. Skvarla, III
Secretary
Subject: Acknowledgement of Application
No. WQ0036881
Former Clifton Precision Site
Groundwater Remediation System
Cherokee County
The Water Quality Regional Operations Section (WQROS) acknowledges receipt of your permit
application and supporting documentation received on December 9, 2013. Your application package has been
assigned the number listed above, and the primary reviewer is Thomas Slusser.
Central and Asheville Regional Office staff will perform a detailed review of the provided application, and
may contact you with a request for additional information. To ensure maximum efficiency in processing permit
applications, the Water Quality Regional Operations Section (WQROS) requests your assistance in providing a
timely and complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days after
receipt of a complete application. If you have any questions, please contact Thomas Slusser at [phone] or
[e-mail].
Sincerely,
for Debra J. Watts
Groundwater Protection Unit Supervisor
cc: hevilleRegionaLOific—e;._W_QROS)
Andrew Romanek — CDM Smith, Inc., 651 E. 41h St., Ste. 100, Chattanooga, TN 37403
Jeffrey P. Gwinn — Orion Engineering, dba Arctos Engineering, 3450 E. Spring St., # 212, Long Beach,
CA 90806
Kurt Batsel — The Dextra Group, Inc., # 446 1205 Johnson Ferry Rd., Ste. 136, Marietta, GA 30068
Permit File WQ0036881
WATER QUALITY REGIONAL OPERATIONS SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Salisbury St., Raleigh, North Carolina 27604
Phone: [phone] l FAX: [phone]
Internet: hfto://Portal.ncdenr.ora/webiwa/aos
DEC 1 D 2013
An Equal Opportunity 1 Affirmative Action Employer
DWQ/Surface Vlater±'rotection Section
Asheville Regional office

1. Additional information and detail regarding startup plan monitoring
o Attachment D of the permit application states that reinjection water will be treated to
below the 2L standards.
o Sample location and sample analyses during startup
2. 15A NCAC 2L .0107(d) prohibits the use of supply wells within a compliance boundary. PW-9
appears to be within the compliance boundary. Please verify compliance with .0107(d). Please
provide additional information regarding the use and control of PW-9.
o TCE detected post -treatment on 2/6/2008
3. A separate map indicating water supply well status and monitoring frequency. Additionally,
please provide.this office with a copy of the risk assessment document submitted to
EPA/NCDENR and referenced in the application.
o It appears PW-16 is the only actively monitored wsw
© "Inactive" wells locked out per executed agreement with property owners
0 6 private wsws have historically contained a detection of at least on VOC
4. The application of a compliance boundary to this site is problematic as groundwater
contamination already extends beyond the compliance boundary to the southwest, injection will
be occurring in bedrock wells in the complex hydrogeologic setting, and groundwater
monitoring is very limited to the west and southwest of the injection site. Please provide further
discussion on how groundwater migration will be monitored at the compliance boundary.
5. We need a separate, individualized monitoring plan for the groundwater remediation permit.
We have reviewed the reports referenced in the application but wish to review a single plan
designed for the project meeting .1607.
6. Based on the simulated groundwater flow in the regolith, the closest down -gradient regolith
monitoring point is greater than 600 ft. downgradient (SW). Please provide additional
information addressing this issue which relates to compliance with .1607.
© Monitoring wells MW-33 and MW-60 do not appear directly downgradient of INJ-4, INJ-
6, INJ-8.

Q \JOC kc;,F ec1 0-7ifOS'
i 08 Aerial Photograph, Cherokee county, O Inactive Water Supply * Regolith Monitoring Well Figure 1-3: RFI Phases 1- 3
rn NC, Mapping/GIS Depar4nt. Creek Monitoring Point
Scale in Feet
(PW -Well)
Bedrock Monitoring Well Q RCRA Facility Investigation Investigation Location Map
Active Water Supply 200 0 400 RCRA Facility Investigation
(PW - Well, SP- Spring) O Exploratory Boring Surface Water Station
CDM Former Clifton Precision Site
Smith Murphy, North Carolina

Permit No. WQ0036881
Northrop Grumman Guidance and Electronics Company, Inc.
ENGINEER'S CERTIFICATION,
Partial. :Final
I,
�� �� �vri ,.as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of
the project,
't'O�('YiA2Y' C`�''�'tI7V` \ rf•ti"GCCst`a'I� �C-l`LI_��1�r. 1 'V.�j.'t,Sd►�;�_�,��(i�tC.E� �VV�,���.1" ,
Project Name Location_; and County
for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of this permit, the approved plans and specifications, and other supporting
materials.
Signature ._ ".. Registration No,_ 036053
Date 3 l
_.. _ ...
CARP
=O oFE•ssip�Gj,9%
SEAL 9"
036053
WQ0036881 permit.docx Page 8 of 8

Department of Environmental Quality - Division of Water Resources
STATUS OF INJECTION WELL(S)/PERMIT RESCISSION REQUEST FORM
Permit Number: W00036881
Permittee Name(s): Northrop Grumman Guidance and Electronics Company, Inc.
Mailing Address: 101 Continental Boulevard, MailStop: D12/YE6D21, El Segundo, CA 90245
Physical Address of Well(s) (if different than mailing address): 200 Clifton Lane
City: Murphy County: Cherokee Zip Code: 28906
Daytime Telephone No.: 310-332-5915 Cell No.:
Email Address: Michael. Shannonna,nge.com
Please check the selection which most closely describes the current status of your system:
1) ❑✓ Well(s) still used for injection activities
2) ❑ Well(s) not used for injection but used for other purposes: a) ❑ Water Suppll000tiiw-1'�rRa�uar
b) ❑ Recovery
c) ❑ Irrigation .J A N 2 7 2017"
d) ❑ Monitoring
3) ❑ Injection discontinued and: a) ❑ Well(s) temporarily abandoned WawQuaMyRegkrAOPWad",
b) ❑ Well(s) permanently abandoned Asheville Regional Oidce
c) ❑ Well(s) not abandoned
4) ❑ Injection well(s) never constructed ❑ N/A injection well(s) never proposed
Well(s) Abandonment/Comments:
If you checked (3)(a) or (b), attach a copy of the GW-30 (Well Abandonment Record). If not applicable, then describe
the method used (or to be used) to abandon the well(s), including a description of how the well were sealed and material
used. If the work below is proposed, a GW-30 will need to be submitted to the UIC Program 30 days after abandonment.
Per previous discussions with NC DEQ (Andrew Moore & Michael Rogers) injection well INJ-8 has been replaced by
INJ-8R. INJ-8R was installed on 5 October 2016 and put into service on 11 January 2017. INJ-8 has not been abandoned
and will continue to be used for monitoring purposes.
Permit Rescission:
If you checked (2), (3), or (4) and will not use a well for injection on this site in the future, you should request rescission
of the permit. Do you wish to rescind the permit?
❑ Yes ❑ No
Certification:
"I hereby certify, under penalty of law, which I have personally examined and am familiar with the information submitted
in this document, and that to the best of my knowledge the information is true, accurate, and complete."
lWhad J ShaW1011 16 January 2017
Signature Date
Manager, Corporate
Michael D. Shannon Environmental Remediation
Print or Type Name Title
GW-68 Injection Well Status Form Rev. 3-1-2016 Page 1 of 1

Moore, Andrew W
From:
Fuller, Nicholas D. <FullerND@cdmsmith:com>
Sent:
Wednesday, January 11, 2017 3:36 PM
To:
Moore, Andrew W
Cc:
Rogers, Michael _
Subject:
Murphy Reinjection System, (WQ0036881).
Andrew,
Injection well INJ-8R was officially put into service today at the Former Clifton Precision Site in Murphy, NC. Injection
well ]NJ-8R was installed on October 5, 2016 to replace injection well INJ-8. INJ-8 was not abandoned and will be used
for site monitoring purposes in the future. CDM Smith has prepared the Injection Well Status Form and it is currently
being reviewed -by the client. As soon as we have the client's signature on the form a hard copy will be mailed to you and
Michael Rogers.
If you should have any questions or concerns please feel free to contact me by phone or email.
Thank you,
Nicholas Fuller I Environmental Scientist I CDM Smith 13200 Windy Hill Road, Suite 210 West, Atlanta, GA 30339
Desk/Fax: [phone] Cell: [phone] 1 Email: [e-mail]

WQ0036881-Former Clifton Precision site
Note to File
Jeffrey Weeber (404-720-1369) with CDM Smith called me September 28, 2016 to provide notification
that replacement injection well INJ-8R will be installed October 4-5, 2016.
Andrew Moore

i
roore,rew W
From: Moore, Andrew W
Sent: Tuesday, September 06, 2016 2:26 PM
To: 'Weeber, Jeffrey'; Rogers, Michael
Subject: RE: Murphy Reinjection System (WQ0036881)
Jeffrey,
Thank you for the supporting information. Based on the additional information provided, the proposed re -injection
replacement well (INJ-8R) location, as depicted on the map provided with your August 29, 2016 email, is approved.
Please refer back to my August 17, 2016 email for additional notification requirements.
If you have any questions, feel free to contact me.
Andrew W. Moore, P.G.
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
<..--"Nothing Compares,,_.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Weeber, Jeffrey [mailto:[e-mail]]
Sent: Monday, August 29, 2016 11:09 AM
To: Rogers, Michael <[e-mail]>; Moore, Andrew W <[e-mail]>
Subject: RE: Murphy Reinjection System (WQ0036881)
Michael and Andrew,
Thank you for your review of CDM Smith's proposed reinjection replacement well (NJ-8R) for the Former Clifton
Precision Site groundwater reinjection system. This email addresses your request for additional information regarding
access authorization with Truett Baptist and a demonstration that the proposed INJ-8R well location will not result in the
migration of contaminants into previously uncontaminated areas.
1. The attached "Truett Authorizations" PDF provides documentation that J. Mitchell Shields, authorized
representative for the property, has approved access to the property for monitoring purposes. This PDF contains
the access authorization and conditions for installation and ongoing sampling of wells at the property. Truett

later approved the installation of existing injection wells INJ-1 and INJ-2, and the permit application and
corresponding permit are attached.
2. Reinjection system performance collected over the past year demonstrates that migration of contaminants into
previously uncontaminated areas is not a concern for this system.
a. As provided to NCDEQ in the 2016 Annual Report for Groundwater Remediation Permit Number
WQ0036881 (CDM Smith, April 2016), analytical results from the treatment system effluent (water that
is reinjected) show that all volatile organic compounds, in particular trichloroethene (TCE), are below
the NC 2L groundwater standards.
b. The regolith TCE plume has been significantly mitigated due to the effects of the reinjection system.
Figure 3-2 in the 2016 Annual Report shows the TCE plume prior to reinjection operation. In contrast,
Figure 3-3 shows the TCE plume since reinjection activities: The footprint of the plume has been reduced
due to the combined groundwater extraction and reinjection, and there has been no migration to areas
that were previously uncontaminated. Both of these figures are provided in the attached "Nonmigration
Support" PDF, and the proposed [NJ-8R location is shown on Figure 3-3.
c. Provided to NCDEQ in the Non -Discharge Groundwater Remediation Permit Application (Northrop
Grumman, September 2013), the Demonstration of Hydraulic Control (Attachment D) states:
"As evidenced by Figures 5-7 and 5-8 of the RFI Report, the eight injection wells (INJ-1 through INJ-8) are
located within, but near the edges of, the VOC plume extents. As noted in 5.6.3 of the RFI Report,
groundwater in both the regolith and bedrock zones off site migrates into the coarse -grained alluvium
and ultimately discharges into Slow Creek. VOCs have been detected in Slow Creek as far downstream as
location SW-10 (see Figure 1-3). VOC concentrations are expected to improve in Slow Creek as the result
of reinjection and will continue to be monitored semi-annually to evaluate any changes"
INJ-8R will be relocated to a position as close to the current plume edge as possible and is considered an
improvement over the original location. The groundwater plume has been reduced in size and TCE
concentrations in offsite groundwater and Slow Creek have been reduced. CDM Smith would prefer to
maintain the injection well configuration as close as possible to the original to continue this
performance.
In summary, CDM Smith selected the proposed INJ-8R location to improve plume mitigation in this area. The proposed
location of INJ-8R is approximately 65-feet to the northwest of the existing location, as shown on Figure 3-3. Based on
the information provided above, the fact that the treatment system has consistently maintained effluent VOC
concentrations below the NC 2L groundwater standards, and the information provided in the original permit application,
CDM Smith believes that migration to previously uncontaminated areas will not occur.
Thank you for your consideration in this matter. If you have any questions, please contact me at 404-720-1369.
From: Rogers, Michael [mailto:[e-mail]]
Sent: Friday, August 26, 2016 3:32 PM
To: Moore, Andrew W <[e-mail]>; Weeber, Jeffrey <[e-mail]>
Subject: RE: Murphy Reinjection System (WQ0036881)
Keep me in the loop on this. Thanks.
From: Moore, Andrew W
Sent: Monday, August 22, 2016 12:39 PM

P!uV.Vreeber.,,Jeffrey <[e-mail]>'
ogers, ichael <[e-mail]>
ct: REMurphy Reinjection System (WQ0036881)
Jeffrey,
Please provide me a copy of the access agreement with the Truett Baptist property.
As your proposed injection well location will not meet the requirements in 15A NCAC 02T .1606
(http://reports.oah.state.nc.us/ncac/title%2015a%20-%20environmental%20guality/chapter%2002%20-
%20environmental%20management/subchapter%20t/15a%20ncac%2002t%20.1606.pdf), in accordance with 15A NCAC
02T .1606 please demonstrate that the proposed injection well location and subsequent injection will not result in the
migration of contaminants into previously uncontaminated areas.
Thanks,
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: Andrew.W.Moore(�ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
¢a` �".,,, Nothing Compar-es.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Weeber, Jeffrey [mailto:[e-mail]
Sent: Friday, August 19, 2016 11:33 AM
To: Moore, Andrew W <[e-mail]>
Cc: Rogers, Michael <[e-mail]>
Subject: RE: Murphy Reinjection System (WQ0036881)
Andrew and Michael,
I've attached two figures for your review. The proposed location of the replacement well is shown on the "Regolith
Wells" figure, since INJ-8R will be a regolith well. The "Bedrock Wells" figure is provided for reference. Please not both
these figures originated from the annual UIC report. Please also note the following about this proposed location:
The proposed location is less than 50' from the property boundary between the subject property and the Truett
Baptist property. However, there are currently two injection wells on Truett Baptist property: INJ-1 (bedrock)
and INJ-2 (regolith). And the proposed location will be approximately 60' from the property line that separates
Truett Baptist from the adjacent property.

• Although the proposed location is not on Truett property, we have an access agreement with them regarding
well installation and monitoring.
• As noted in our application (and shown on the figures), we are injecting into an area that is already impacted.
Please let me know if you have any questions or comments, and I'll provide whatever additional details that I can.
Thanks for your help,
Jeffrey Weeber, P.E. I Environmental Engineer I CDM Smith
3715 Northside Pkwy NW #300/400 1 Atlanta, GA 30327 1 404-720-1369 1 [e-mail]
From: Moore, Andrew W [mailto:[e-mail]
Sent: Wednesday, August 17, 2016 3:52 PM
To: Weeber, Jeffrey <[e-mail]>
Cc: Rogers, Michael <[e-mail]>
Subject: RE: Murphy Reinjection System (WQ0036881)
Jeffrey,
Can you send me a map with the proposed injection well location? I need to make sure that the proposed injection well
system and associated monitoring network will meet the requirements of 15A NCAC 02C .0225 (e)(9). An existing map
with hand -drawn location will suffice.
When the proposed location is approved, a new application form will not be needed. We will simply modify the existing
permit. We will require 48 hour notification prior to the construction of the well as described in part III. (4) of the subject
permit.
When the proposed well location is approved, the injection well must meet the construction requirements found in 15A
NCAC 02C .0225. You should pay particular attention to 15A NCAC 02C .0225 (g)(20) and (21). From my recollection,
when I conducted a reconnaissance inspection of the facility prior to permit issuance, none of the injection wells had
well identification plates or sampling taps. If/when a compliance inspection is conducted, these are items that I would
consider non -compliant.
After the new injection well is drilled and constructed, you will need to submit a copy of the Well Construction Record to
the Underground Injection Control (UIC) Program in Raleigh. You will also need to complete a well change of status form
(attached) for INJ-8 and submit to UIC.
Once I receive the map with the proposed location, I will review it and let you know if the location is approved or if we
have any concerns with the monitoring network.
Feel free to call me if you have any questions.
Andrew W. Moore, P.G.
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: Andrew.W.Moore(o)ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778

—�Nothing Compares.-- .
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Weeber, Jeffrey [mailto:[e-mail]]
Sent: Friday, August 12, 2016 2:14 PM
To: Moore, Andrew W <[e-mail]>
Subject: Murphy Reinjection System (WQ0036881)
Andrew,
I have a question regarding installation of a replacement injection well for the Murphy groundwater treatment
reinjection system (Permit # WQ0036881). Injection well INJ-8 is no longer a viable injection well because
surfacing was observed during its operation. After evaluation, we have determined that it is not possible to
correct and we'd like to replace this well with a "new" INJ-8 (call it INJ-8R). It appears that INJ-8 failed due to
its construction because other residuum wells have been operational without issue. We're currently in the
preliminary planning stages for installation of [NJ-8R and our permit states that "Construction of additional
injection wells must be approved in advance", so I'd like to make sure I'm clear on the procedures for
performing this installation, from a regulatory standpoint. I can provide additional details as you need, but
generally:
1. INJ-8R will be of similar construction to INJ-8. It will be a residuum well and will go no deeper than 75'.
2. INJ-8R will be located approximately 65' further west than INJ-8. Plume analysis since reinjection began
indicates that hydraulic control can be further improved by locating INJ-8R further to the west, and this
will place it on the western boundary of the property.
3. The flow rate to INJ-8R is expected to be similar to the other residuum wells, and a pressure switch will
ensure that,pressure in the well does not exceed 10-psi.
To install INJ-811, what notification does NCDNR require?
Does a "Non -Discharge Groundwater Permit Application Form" need to be submitted for modification of the
existing permit?
How far in advance should notification be provided?
If you have any further questions or would like additional details, feel free to call me at 404-720-1369 to
discuss. This is still in the planning stages, but I'll provide any additional details I can at this point.
Thanks for your help,
Jeffrey Weeber, P.E. I Environmental Engineer I CDM Smith
3715 Northside Pkwy NW #300/400 1 Atlanta, GA 30327 1 404-720-1369 1 [e-mail]

Proposed INJ-8R
Location
=1
,(D Regolith Recovery Well Regolith /Transition Zohe Monitoring, Well A Surface Water Location
Regblith MonitorihgVell Repplith /Trb6sitior-Whe Recdveyil Permit ompWWI
inactive s6pply Well; V, R-e9blith /Transiti-On2bbe Reinjection Well
Fi--R - bilthl
Coarse -Grained 4 R6�&ty Lines g M-3-3f 2016/2616 .09
Al�uvlurrtTran'sJudin- Groundwater
Permift'ge Properties, TCE Distribution
CDM.
Cross Section Location Former Clifton Precision Site
.............. #.-
Cherokee County,, North Carolina
Smith Murp ky,

1 �
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r Precision Site
.' r.
_
ontours are trichloroethene (TCE) in groundwater
1,0(?0 mIcrog( amsftiter. Posted values + ' re the highest TCE duriAg 201312014 pnor to
reatment system operation. J values are estimated
nd below the quantif" on level
S - No sample. ' - Sarrt4e collected prior to 2013.
Regolith Recovery Well Regolith /Transition Zone Monitoring Well A Surface Water Location
r Regolith Monitoring Well Regolith /Transition Zone Recovery Well Permit Compliance Well
Inactive Supply Well Regolith /Transition Zone Reinjection Well
•--TTTTT7' �Figure 3-2: 2013/2014 Re olith/ ' Coarse -Grained ,) Proper -Lines - g g
Alluvium Transition Groundwater
F�--L--A--'—yy� Permittee Properties
CD M Thermal Treatment TCE Distribution
Smith Area (WMU-B} Cross•Section Location Former Clifton Precision Site
............... .
Murphy, Cherokee County, North Carolina

Truett Baptist Association of Churches, Inc.
2235 North Carolina Hwy. 141
Marble, North Carolina 28905
828.837.5401
Fax [phone]
FEIN — 20-1183600
February 13, 2006
Mr. Joe Kwan
% CDM
9100 Shelbyville Road
Suite 150
Louisville, Kentucky 40222
FEB 1 6 2006
CDIW
RE: Request for Truett Property Access off of Hendrix Road in Murphy, NC
Dear Mr. Kwan:
This correspondence is in response to your letter dated January 271h, 2006,
The Truett Baptist Association Board of Directors met on Monday, February 13,
2006 and recommended approval to Litton Systems for the purpose of conducting
environmental investigative activities on Truett Property.
You will find attached the original letter dated and signed.
Sincerely yours,
J. Mitchell Shields
Association Missionary

Northrop Grumman Corporation
1840 Century Park East
Los Angeles. California 90067-2199
Joseph P. Kwan
310556-4514
[e-mail]
January 27, 2006
Truett Baptist Association
2235 NC Hwy, 141
Marble, NC 28905
Attn: Mitchell Shields
Re: Request for Property Access at Your Property off of Hendrix Road in
Murphy, NC
Dear Mr. Shields:
Litton Systems, Inc. (Litton) is conducting investigative and remedial activities at its
former facility located on Slow Creek Road, Hwy. 141 in Murphy, North Carolina
(former Litton facility), which facility is now owned and operated by Moog Components
Group, Inc. The investigation and remediation activities are being conducted pursuant
to a work plan approved by the United States Environmental Protection- Agency
(USEPA). As part of this investigation, Litton has been directed by the USEPA to
conduct an investigation on property adjacent to the former Litton facility. So that it
can continue to perform required environmental work, Litton requests permission from
you as the property owner to conduct these investigation activities on your property
located at the above -referenced address (Truett Property).
The required work proposed to be performed at the Truett Property includes direct -
push groundwater sampling; possible groundwater monitoring well installation with
ongoing sampling; and possible temporary road installation (Required Work). The
actual time to be spent on the Truett Property in the performance of the Required
Work will consist of approximately two weeks for direct -push sampling and new well
installation(s) (if required). If a permanent groundwater monitoring well(s) is installed,
Litton will then require periodic access for sampling the well(s). Well sampling will
typically take half a day to complete and will occur two to four times per year.
To satisfy its obligations under the work plan, Litton respectfully requests access to
the Truett Property for purposes of performing the Required Work. Litton will perform
the Required Work in accordance with the following:
1. Litton will take precautions to minimize damage to the Truett Property that may
result from its performance of the Required Work. Although the Required Work

Mr. Mitchell Shields
January 27, 2006
Page 2
is not expected to be destructive in any way, Litton will restore that portion of
the Truett Property affected by the Required Work to its pre-existing condition,
to the extent reasonably practicable and upon completion of the Required
Work.
2. Litton will provide you with advance notice of the date on which it plans to enter
the Truett Property for purposes of conducting the Required Work,
3. Litton will provide you with a Summary Report on monitoring results obtained
from the wells on the Truett Property for each sampling event.
4. This Access Agreement will continue from year to year as long as the
investigation is necessary according to the USEPA.
5. In return for this Agreement, Litton will pay you a one-time access fee of
$100.00 (one hundred dollars). If Litton installs a groundwater monitoring
well(s) that will require periodic access,.Litton will pay you a yearly access fee
of $250.00 (two hundred fifty dollars) instead of the one-time fee of $100.00
(one hundred dollars).
If you have any questions on the above, please do not hesitate to contact Kurt Batsel
at [phone]. To indicate your approval of the above, please sign below and
return the signed letter to me in the enclosed envelope. Thank you in advance for
your cooperation and assistance with this matter.
Sincerely,
Joseph P. Kwan
Director, Environmental Remediation
Northrop Grumman Corporation
ACCEPTED AND AGREED TO:
Truett Baptist Association
Date:

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT & NATURAL RESOURCES
DIVISION OF WATER QUALITY — AQUIFER PROTECTION SECTION
APPLICATION FOR PERMIT TO CONSTRUCT A MONITORING OR RECOVERY WELL SYSTEM
PLEASE TYPE OR PRINT CLEARLY
In accordance with the provisions of Article 7, Chapter 87, General Statutes of North Carolina and regulations pursuant thereto,
application is hereby made for a permit to construct monitorinq or recovery wells.
1. Date: October 6, 2011-
2. county: Cherokee
3
4
5
Ia
7
8.
FOR OFFICE USE ONLY
PERMIT NO. ISSUED DATE
What type of well are you applying for? (monitoring or recovery): Monitoring
Applicant:
Northrop Grumman Guidance and Electronics Company, Inc.
Telephone: [phone]
Applicant's Mailing Address: 2980 Fairview Park Dr., Falls Church, VA 22042
Applicant's Email Address (if available):
Contact Person (if different than Applicant): Tom Duffey Telephone: [phone]
Contact Person's Mailing Address: 3715 Northside Pky., NW, Bldg 300 Suite 400, Atlanta, GA 30327
Contact Person's Email Address (if available): [e-mail]
Property Owner (if different than Applicant): Truett Baptist Assoc. of Churches, Inc.
Property Owner's Mailing Address: 2235 North Carolina Hwy. 141
Property Owner's Email Address (if available):
Marble, NC 28905
Telephone:
828-837-5401
Property Physical Address (including zip code) and PIN Number Royal Oaks Lane, Marble, NC 28905 PIN 552201077466000
Reason for Well(s): Groundwater contamination assessment
(ex: non -discharge permit requirements, suspected contamination, assessment, groundwater contamination, remediation, etc.)
9. Type of facility or site for which the well(s) is(are) needed: RCRA Corrective Action for U.S. EPA Region 4
(ex: non -discharge facility, waste disposal site, landfill, UST, etc.)
10. Are there any current water quality permits or incidents associated with this facility or site? If so, list permit and/or incident no(s).
No
11. Type of contaminants being monitored or recovered
(ex: organics, nutrients, heavy metals, etc.)
12.
Volatile Organic Compounds
Are there any existing wells associated with the proposed well(s)? If yes, how many? —60
Existing Monitoring or Recovery Well Construction Permit No(s): WM0100158, WM0100159
13. Distance from proposed well(s) to nearest known waste or pollution source (in feet):
•11
14. Are there any water supply wells located less than 500 feet from the proposed well(s)? Yes
If yes give distance(s): —150' to 225', applicant routinely monitors the supply well and provides whole -house water treatment
15.
Well Contractor: M&W Drilling Certification No.
Well Contractor Address: 8321 Oak Ridge Hwy., Knoxville, TN 37931
2336
PROPOSED WELL CONSTRUCTION INFORMATION
As required by 15A NCAC 02C .0105(f)(7), attach a well construction diagram of each well showing the following:
a. Borehole and well diameter e. Type of casing material and thickness
b. Estimated well depth f. Grout horizons
C. Screen intervals g. Well head completion details
d. Sand/gravel pack intervals
Continued on Reverse

PROPOSED WELL CONSTRUCTION INFORMATION (Continued)
2. Number of wells to be constructed in unconsolidated 5. How will the well(s) be secured? BOIL -down
material: 1
3. Number of wells to be constructed in bedrock:
4. Total Number of wells to be constructed: 2
(add answers from 2 and 3)
Flush -mount covers with locking caps
Estimated beginning construction date: 10-10-2011
Estimated construction completion date: 11-10-2011
ADDITIONAL INFORMATION
As required by 15A NCAC 02C .0105(f)(5), attach a scaled map of the site showing the locations of the following:
a. All property boundaries, at least one of which Is referenced to a minimum of two landmarks such as identified roads,
intersections, streams,,or lakes within 500 feet of the proposed well or well system.
b. All existing wells, identified by type of use, within 500 feet of the proposed well or well system.
C. The proposed well or well system.
d. Any test borings within 500 feet of proposed well or well system.
e. All sources of known or potential groundwater contamination (such -as septic tank systems, pesticide, chemical or fuel
storage areas, animal feedlots as defined in G.S. 143-215.10B(5), landfills, or other waste disposal areas) within 500 feet
of the proposed well orwell system.
SIGNATURES
The Applicant hereby agrees that the proposed well(s) will be constructed in accordance with approved specifications and conditions of
this Well Construction Permit as regulated under the Well Construction Standards (Title 15A of the North Carolina Administrative Code,
r� s Subchapter 2C) and accepts full responsibility for compliance with these rules
ti., -
`" Corporate Director, Environmental Remediation
Signatuii'D ` icant or *Agent Title of Applicant or *Agent
Joseph P. Kwan . If signing as Agent, attach authorization agreement stating
Printed name of Applicant or 'Agent that you have the authority to act as the Agent.
If the property is owned by someone other than the applicant, the property owner hereby consents to allow the applicant to construct
wel Is as outlined in this Well Construction Permit application and that it shall be the responsibility of the applicant to ensure that the
w s) nform to the Well Construction Standards (Title 15A of the North Carolina Administrative Code, Subchapter 2C).
J. Mitchell Shields
e of Property Owner (if different than Applicant) Printed name of Property Owner (if different than Applicant)
DIRECTIONS
Please send the completed application to the appropriate Division of Water Quality's Aquifer Protection Section Regional Office:
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Phone: [phone]
Fax: [phone]
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 26301-5094
Phone: [phone]
Fax: [phone]
Mooresville Regional Office
610 East Center Avenue
Mooresville, NC 28115
Phone: [phone]
Fax: [phone]
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Phone: [phone]
Fax: (919) 571A718
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
Fax: [phone]
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Phone: [phone]
Fax: [phone]
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
Fax: (336) 771AB30
GW-22MR (Rev. 7/11)

FA
Royal Oaks Lane ► 41
r` r n Marble, NC 28905 rt..
PIN 552201077466000
MW-44
MW-46 ( ►
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Offsite Wells AIW-64
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ti
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RegolithMonitorij4.V%el w `,' '�. A.� � ► -__
Regolith Recovery VYtefl � ► t $ � �� i r '.
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M

on

0
-10
-20
-30
-40
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-60
-70
-80
-90
-100
-110
-120
-130
-140
-150
-160
1-170
-180
-190
200
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'
JJ
6" Diameter Carbon
Steel Surface Casing
Cement/Bentonite Grout
4" Diameter :��'
PVC Well Riser
�;✓'�
Nominal io"
Diameter Borehole;
Bentonite Sealy
,
Diameter
PVC Well Screen`
--
Sand Pacl
_—
Nominal 6"
Diameter Borehole
0 50 100 150 200 250 300
Figure 3: Proposed;
Well Construction:
10/06/2011 Monitoring
,., 11 ., • 1.

Pr
MW-65
Bolt -Down Protective Cover',-,,
Grade Line
Concrete Pa.f.,:._414:._'* 49,,,
oaov
(3 x 3'x 4") ..� '.. _. V4
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Concrete, 3' Deep
Ea
Nominal to" Diameter Borehole I'm
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L
CDM 1
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Expansion Cap/Lock Bolt -Down Protective Cover'.
Grade Li
114 Concrete Pad 4
(3'x3'x4") A.
AV
o•n
A
AV
4 "Diameter PVC Well Risel.
•
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..nv
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nE
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Nominal io" Diameter Borehole "A'A
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I--- Expansion Cap/Lock
14 A
Figure 4: Propos
Wellhead Construed
io/ob
/zon Monito-
Well Permit Applical
Former Clifton Precision

NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY — AQUIFER PROTECTION SECTION
PERMIT FOR THE CONSTRUCTION OF MONITORING WELL(S)
In accordance with the provisions of Article 7, Chapter 87, North Carolina General Statutes, and other applicable Laws, Rules
and Regulations.
PERMISSION IS HEREBY GRANTED TO .
Northrop Grumman Guidance and Electronics Company, Inc.
FOR THE CONSTRUCTION OF A MONITORING WELL SYSTEM consisting of two wells owned byNorthrop Grumman
Guidance and Electronics Company, Inc. located at 2980 Fairview Park Dr., Falls Church, VA 22042. The well will be located
on the property owned by Truett Baptist Assoc. of Churches, Inc. located on Royal Oaks Lane., Marble, NC in Cherokee County
(PIN # 552201077466000). This Permit is issued in accordance with the application received on October 27, 2011 in
conformity with specifications and supporting data, all of which are filed with the Department of Environment and Natural
Resources and are considered integral parts of this Permit.
This Permit is for well construction only, and does not waive any provision or requirement of any other applicable law or
regulation. Construction of any well under this Permit shall be in strict compliance with the North Carolina Well Construction
Regulations and Standards (15A NCAC 02C .0100), and other State and Local Laws and regulations pert4ining to well
construction.
If any requirements or limitations specified in this Permit are unacceptable, you have a right to an adjudicatory hearing upon
written request within 30 days of receipt of this Permit. The request must be in the form of a written petition conforming to
Chapter 150B of the North Carolina General Statutes and filed with the Office ofAdministrative Hearings, 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this Permit is final and binding..
This Permit will be effective for one year from the date of its issuance and shall be subject to other specified conditions,
limitations, or exceptions as follows:
1. Issuance of this Permit does not supersede any other agreement, permit, or requirement issued by another
agency.
3. The well(s) shall be located and constructed as shown on the attachments submitted as part of the Permit
application.
4. You are required to provide a copy of this permit to the property owner(s).
5. You are required to provide notification to the property owner upon well completion and upon termination of
monitoring.
6. Each well shall have a Well Contractor Identification Plate in accordance with 15A NCAC 02C .0108(o).
7. The monitoring well shall be maintained in accordance with 15A NCAC 2C .0108.
8. Well construction records (GW-1) for each well shall be submitted to the Division of Water Quality's
Information Processing Unit within 30 days of the well completion.
9. When the well is discontinued or abandoned, it shall be abandoned in accordance with 15A NCAC 02C .0113
and a well abandonment record (GW-30) shall be submitted to the Division of Water Quality's Information
Processing Unit and property owner within 30 days of the well abandonment.
Permit issued the 27 h day of October, 2011
FOR THE NORTH CAROLINA 6N NTAL MANAGEMENT COMMISSION
Landon Davidson, Regional Supervisor
Division of Water Quality
By Authority of the Environmental Management Commission
Permit No. # WM0100276
Revised July 2011

4\ .:
NCDENR :
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen.H. Sullins Dee Freeman
Governor Director Secretary
October 27, 2011
Joseph P. Kwan
Northrop Gruman Guidance and Electronics Company, Inc.
2980 Fairview Park Dr.
Falls Church, Virginia 22042
Subject: Well Construction Permit No. WM0100276
Truett Baptist Assoc. of Churches, Inc.
Royal Oaks Lane, Marble, NC
PIN# 552201077466000
Cherokee County, North Carolina
Dear Mr. Kwan,
In accordance with the application you submitted on October 21, 2011 and received on October 27, 2011
we are forwarding herewith Well Construction Permit numbered WM0100276, dated October 27, 2011
issued for the construction of two monitoring wells as described in'the application and attached permit.
These monitoring well wills be drilled on property owned by Truett Baptist Assoc. of Churches, Inc. (NCPIN
# 552201077466000).
This permit will be effective from the date of issuance and shall be subject to the conditions and
limitations as specified therein. A well Construction Record (GW-1a) shall be completed and signed"by the
certified drilling contractor. This form shall be submitted to the Department upon completion of the well.
Please note the attached permit conditions.
Sincerely,
G. Landon Davidson, L.G.
Aquifer Protection Section Regional Supervisor
Asheville Regional Office
ec: Tom Duffey (CMD)
- North Carolina Division of Water Quality — Asheville Regional Office .
2090 U.S. Highway 70, Swannanoa, N.C. 28778 Phone [phone] FAX [phone]
Customer Service 1-877-623-6748 Internet; h2o.ennstatemc.us
An Equal Opportunity/.Affirmative Action Employer
ne •
O Karo ina
atura�lr�

Moore, Andrew W
From: Steve Hash <[e-mail]>
Sent: Friday, September 05, 2014 5:14 PM
To: Moore, Andrew W
Cc: [e-mail]; Jeff Gwinn; Miguel Tseng
Subject: 02NC: Former Clifton Precision Facility Noncompliance Notification (Permit #
WQ0036881)
Good Afternoon Andrew,
I spoke with Landon Davidson this afternoon regarding noncompliance with groundwater remediation permit
WQ0036881 issued for the former Clifton Precision Facility in Murphy, North Carolina. Orion was on site during the
week of August 25th for startup testing of the remediation system. During that time; the system was configured to
discharge to a frac tank in order to collect verification samples to confirm compliance with the North Carolina 02L
Standards.
On Wednesday August 27th, Orion collected an effluent frac tank sample and the results indicated the system was in
compliance. Based on those results, the system.was connected to the injection wells on Friday August 29th and we
began injecting water back into the aquifer. Additional effluent samples were collected on Friday August 29th as part of
our startup testing. We received the results of those samples today, Friday September 5th, and the results indicated a
trichloroethene (TCE) concentration of 19 micrograms per liter (ug/1), which is greater than the 02L Standard of 3
ug/l. Orion immediately shut down the remediation system and notified the State as required in the permit. Between
August 29th and September 5th, approximately 37,000 gallons of water were injected.
The remediation system will once again be configured to discharge to a frac tank while we troubleshoot the treatment
issue, which we believe can be attributed to the air -water ratio of the air stripping tower. After addressing the air -water
ratio issue, we will collect multiple verification samples over the course of several hours to confirm compliance with the
02L Standards. Per my conversation with Mr. Davidson, we will contact you via email or phone to provide notification
that the system has been repaired and in compliance with the 02L Standards before resuming injection. In addition, no
other reporting will be required unless we are notified otherwise by you. Please let me know if you have any questions
and we will be in touch in the near future.
Thank you -
Steve Hash
Project Engineer
Orion Environmental Inc.
2955 Redondo Avenue
Long Beach, California 90806
Phone: [phone]
Fax: [phone]

Moore, Andrew W
From: Moore, Andrew W
Sent: Monday, April 13, 2015 4:47 PM
To: Davidson, Landon ([e-mail])
Subject: FW: GW remediation/injection permit violation
Landon,
Steve Hash called to notify me today that they plan to begin injections again at the former Clifton Precision facility: Orion
has been working to optimize the system since their TCE 2L groundwater exceedance in the groundwater remediation
effluent in August (see email below). They have six weeks of influent/effluent data that indicates they are treating their
effluent to 2L standards. They plan to begin injecting again on April 20, 2015.
I'm going to review their permit, but I do not believe there are any additional notification requirements.
Andrew
From: Davidson, Landon
Sent: Monday, September 08, 2014 11:35 AM
To: Moore, Andrew W
Subject: RE: GW remediation/injection permit violation
I agree.please add to bims as vindicate.
Sent from my Windows Phone
From: Moore. Andrew W
Sent: 9/8/201410:20 AM
To: Davidson, Landon
Subject: RE: GW remediation/injection permit violation
Landon,
There does not appear to be any additional reporting required in the permit beyond what they have already done.
It seems like this should be recorded in BIMS in some way., Perhaps "Non -Compliance Reporting" in the BIMS Public
Portal? Let me know if you think that is the appropriate way of documenting this incident,
Andrew
From: Davidson, Landon
Sent: Friday, September 05, 2014 4:56 PM
To: Moore, Andrew W
Subject: GW remediation/injection permit violation
Andrew -
We can talk next week but you will likely be getting an email from Steve Hash for the Clifton Precision/Murphy GW
reinjection permit. They had a sample fail for PCE after some testing and are required to notify us. He asked if there
were additional conditions and I told him this would suffice but that we could contact them after looking at the permit

again. He will send you an email with some information as well. Perhaps have a look atAhe permit and then we can talk
and notify him if there are other conditions. Thanks
Landon
GW remediation for treatment system doing startup testing aug 25th, discharging to frack tank, wed 8/22 confirmation
sample collected and it passed, 29th started injecting. in aquifer but during testing continued testing and 8/29 exceeded
for PCE 19ppb received results today, shutdown system, believe it was caused by air/water ratio of stripping tower, no
more injection for now, going to frac tank and resume — injected 37,000 gallons during. Notification in permit. Once we
confirm to 2L treatment, asked they he let us know when beginning reinjection
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources'
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwatercivality.org
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law
and may be disclosed to third parties.

Moore, Andrew W
From: Moore, Andrew W
Sent: Friday, July 15, 2016 4:29 PM
To: 'Romanek, Andrew'
Cc: Rogers, Michael; [e-mail]
Subject: RE: Groundwater Remediation Permit Number WQ0036881, Former Clifton Precision
Site, Cherokee County
Andrew,
Thank you for your responses. Please send hard copies of the semiannual reports to the addresses noted in section V.6.
of the subject permit.
Based on the last part of your response to comment 3, we anticipate that the system will adjusted to bring the effluent
pH to within the 2L standard range. If this cannot be achieved, please keep us informed.
We'll look for the next annual report, as described in section V.6. of the permit, in April 2017.
Thanks again,
Andrew W. Moore, P.G.
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Low and may be disclosed to thud parties.
From: Romanek, Andrew [ma ilto:Roma [e-mail]]
Sent: Thursday, July 14, 2016 9:54 AM
To: Moore, Andrew W <[e-mail]>
Cc: Rogers, Michael <[e-mail]>; [e-mail]
Subject: RE: Groundwater Remediation Permit Number WQ0036881, Former Clifton Precision Site, Cherokee County
Andrew —

Please see our responses in red and italics below
e-mail.
Regards,
Andrew
If you have any additional questions, please do not hesitate to caq
Andrew P. Romanek, P.E., BCEE, PMP I Associate I CDM Smith
651 East 4th Street, Suite 100 1 Chattanooga, TN 37403
T:423.771.4495 1 M:423.394.9986 1 [e-mail] I cdmsmith.com
From: Moore, Andrew W [mailto:[e-mail]]
Sent: Thursday, July 07, 2016 2:41 PM
To: Romanek, Andrew <Romanel<[e-mail]>
Cc: Rogers, Michael <[e-mail]>
Subject: RE: Groundwater Remediation Permit Number WQ0036881, Former Clifton Precision Site, Cherokee County
Andrew,
The Division of Water Resources received the 2016 Annual Report for Groundwater Remediation Permit Number
WQ0036881 dated April 2016. Thank you for your submittal. Overall, the system appears to be highly effective at
removing contaminant mass from groundwater and containing plume migration.
I have a few comments regarding the report that I would like to discuss with you. Briefly, they are as follows:
1. It was my understanding that the routine semi-annual monitoring data would be provided to the DWR following
startup and that's how I read the permit as those monitoring locations and frequencies are listed in Table G-2 of
the approved monitoring plan. Perhaps those data are readily available in a monitoring report that you could
provide to us.
My apologies, Andrew. it was our intention to copy your office on these semi-annual reports but I see that was
not done for the October 2015 event (1st semi-annual event following reinjection startup). An electronic copy of
the October 2015 monitoring report is attached. The April 2016 monitoring report is in the process of being
finalized and should be ready in the next couple weeks. Please let me know if you would like a hard or electronic
copy (or both).
2. Table G-2 of the approved monitoring plan indicates all eight injection wells would be sampled monthly for the
first 12 months following startup. Perhaps I missed them, but I did not see those data in table format in the
submittal. Note that the CD enclosed with the report I received did not have anything on it. It appears that those
data were collected at least once as they are posted on Figures 3-3 and 3-5. Are those data available?
The intention for the monthly sampling of the injection wells noted in Table G-2 was to monitor what was
injected into the aquifer. Considering the water sent to each reinjection well comes from a single discharge point
off the effluent tank, data from SP-7 represents injected water concentrations. These data are presented in Table
3-2. it would be possible to temporarily shut down the system each month, verify that each well has
depressurized (and if not, relieve the pressure), and then remove a cap on the wellhead to allow traditional
sampling of each injection well. However, we feel that such data would be of limited value (i.e., basically same
result as sampling the discharge from the effluent tank) and would require interruption of system operation
during the sampling event. We believe that monitoring the nearby wells provides a more accurate representation
of changing groundwater conditions in the aquifer in response to injection.
3. The Groundwater Treatment System Monthly Water Quality Data Table in the referenced report indicates that
recovered groundwater for July 2015 to March 2016, is entering the treatment system (Sample Point SP-3) at a
pH ranging from 7.00-7.33 and leaving the system (Sample Point SP-7) at a pH ranging from 6.10-6.30. The Title

Pp
P15A NCAC 02L .0202 groundwater standard (21- standard) for pH is 6.5-8.5. Assuming the pH at SP-7 is reflective
of what is being injected, this may be considered a violation of Conditions 1.3. and/or 1.4. of the subject permit.
Title 15A NCAC 02L .0202(b)(3) allows the naturally occurring condition to be the standard when the naturally
occurring condition exceeds the standard (i.e. background pH is lower than 6.5). However, this does not appear
to be the case at the site based on the data I have. Is there any reason the measured pH at SP-3 would not be
considered reflective of background pH (e.g. historical site activities raising the pH of groundwater prior to
recovery)? Are there data available that would indicate that pH in the range of 6.10-6.30 is representative of the
background pH of groundwater at the site? If not, the treatment system may need to be adjusted to ensure
effluent pH is maintained within the standard range.
pH varies significantly at the site and in the reinjection area. For example, provided below are the most recent pH
values measured pre -injection at offsite wells in the vicinity of the injection wells that are sampled either
annually or semi-annually. In each case, the pH reported was the value at the time of sampling and after
purging.
MW-33
6.33
MW-34
5.75
MW-40
7.52
M W-41
8.15
MW-47
7.07
MW-60
6.91
MW-61
6.45
MW-62
5.08
MW-63
5.45
Our interpretation of these data is that background pH in the vicinity of the injection wells can be lower than 5.5
depending on the area. Additional data on site show some wells with a pH around 4.5. it is unlikely that the
system discharge is having any measurable effect on pH in the formation. However, the system has the capability
to control pH and limit the range of discharge pH. We are currently doing some work on the system controls and
will make the adjustments needed to keep the pH within the range of 6.5 to 8.5 going forward.
Could you provide responses to the comments above via email? Alternatively, I should be available this afternoon or
tomorrow to discuss via phone if you would like.
Thanks,
Andrew W. Moore, P.G.
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: Andrew.W.Moore ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Romanek, Andrew fmailto:[e-mail]]
Sent: Thursday, April 21, 2016 3:27 PM
To: Moore, Andrew W <[e-mail]>
Subject: RE: Groundwater Remediation Permit Number WQ0036881, Former Clifton Precision Site, Cherokee County
Andrew —
Just wanted to let you know that CDM Smith completed a draft annual report.for this permit early last week. It is
currently under client review and we have asked them to turn it around so that we can submit by the end of next week. I
recognize that this is a bit behind what. I previously relayed below, but you should have the report soon. I am pretty
confident that you will be pleased with the overall quality of the report when you see it. If you have any questions in the
meantime, let me know.
Regards,
Andrew
From: Moore, Andrew W f mailto:[e-mail]]
Sent: Friday, February 12, 2016 4:09 PM
To: Romanek, Andrew <[e-mail]>; [e-mail]
Cc: Rogers, Michael <[e-mail]>; Shrestha, Shristi R <[e-mail]>; Davidson, Landon
<[e-mail]>
Subject: RE: Groundwater Remediation Permit Number WQ0036881, Former Clifton Precision Site, Cherokee County
Andrew,
The April 2016 report is acceptable and there is no need for any additional documentation. Please be sure to include in
the report a.summary of the August/September 2014 injection related activities and associated analytical data.
Thanks and have a great weekend,
Andrew
From: Romanek, Andrew fmailto:RomanekAP�,7a cdmsmith.com]
Sent: Friday, February 12, 2016 2:03 PM
To: Moore, Andrew W <[e-mail]>; [e-mail]
Cc: Rogers, Michael <[e-mail]>; Shrestha, Shristi R <[e-mail]>; Davidson, Landon
<[e-mail]>
Subject: RE: Groundwater Remediation Permit Number WQ0036881, Former Clifton Precision Site, Cherokee County
Andrew —
It was initially anticipated that reinjection and monitoring would begin in August 2014. However, due to some startup
issues that took several months to troubleshoot, reinjection did not begin until April 2015, with the 1-month monitoring
event noted in the permit occurring in;May. 2015. Additional monitoring noted in the permit followed a similar schedule
based on an April 2015 start date.
My records indicated that you were contacted on April 13th by Orion to inform you that injection would begin on April
20th. Our intention has been to submitan annual report by April 20, 2016 to coincide with the. 1-year anniversary of the

P
reinjection. Please let us know if this will be acceptable and if you need any sort of documentation to approve
Ps proposed timing.
Regards,
Andrew
From: Moore, Andrew W [mailto:andrew.w.moore@ncdenrov]
Sent: Friday, February 12, 2016 1:37 PM
To: Romanek, Andrew <[e-mail]>; [e-mail]
Cc: Rogers, Michael <[e-mail]>; Shrestha, Shristi R <[e-mail]>; Davidson, Landon
<[e-mail]>
Subject: Groundwater Remediation Permit Number WQ0036881, Former Clifton Precision Site, Cherokee County
Mr. Romanek and Mr. Batsel,
Section V6 of the subject permit requires the submittal of an annual report summarizing injection and monitoring data
for the previous year. Correspondence from Orion Environmental indicates injection activities began in August 2014. To
date, the Asheville Regional Office has not received an annual report.
Can you provide an anticipated schedule for submittal of the annual report?
If you are no longer the correct contacts for the subject permit, will you forward this email to the correct contact and
copy me, or provide me with contact information for the appropriate contact regarding this request?
Thanks,
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Contours are trichloroethene in regolith/transition zone groundwater. Scale in Feet
Contour intervals are 3, 100, & 1,000 micrograms/liter.
Contours include data from additional wells monitored separately 0 300 600
from the Groundwater Remediation Performance Monitoring Program. Figure 2B: Regolith/Transition Zone
♦ Regolith Monitoring Well
® Regolith Recovery Well
l Spring
-Creek Monitoring Point
Smith
Permittee Properties
Property Lines
® Regolith /Transition Zone Recovery Well
Q Regolith /Transition Zone Reinjection Well
0Permit Compliance Well
4 Regolith /Transition Zone Monitoring Well
October 2015 Trichloroethene Distribution
Former Clifton Precision Site
Murphy, Cherokee County, North Carolina

N
Scale in Feet
o zoo 400
Messer
Creek
MW-5a,O
SP-z6 .
r
.•
.•
.•
I '
�,• i�i17
Slow �•.
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® Semiannual Sampling ® Regolith/Transition Reinjection Well -* Rock Monitoring Well
O Sampling
Annual Sam ® Regolith Recovery Well
g ®Regolith/Transition Recovery Well ♦Regolith Monitoring VE ell
CDM�s Regolith/Transition M onto
® Bedrock Recovery Well - Transition Monitoring Well
Smith 7 Bedrock Reinjection Well
Well
High Tr.
Alluvium/7
Coarse-Grz

Slow
Creek .
.•
MW-43
A.
Truett Baptist Parcel
a L
.1 0000
.•
-44 MW-46 .
® P INJ-i—.. MMW-47
® • • • • � INJ- a` �✓
MW- MW-34 •
v /Former Smith Parcel Fleming
® I -3� 0 Parcel •
1%
,I • INJ-4 V ®1 1
1 'INJ-5 • - • �%, MW-63
BMW 40 �4 I dos.�INJ-Cz-°�: ® MW-62 1 MW-49
. , INJ 8 MW-28
I tj MW-6o ° MW- �-3•- 9
-61►
• W-3 io MW-Z 0
u
RW-MW-
•
• • RI�V-5� ' MW-22
MW-IAR . ° M W-32
W-4 MW-u •. GW-8B
® GW-8
MW-37 GW-4°. GW-aD
GW-3D� ° GW-iB
GW-7BRW-iS
W-5D
*MW-38 GW-7 W-5B
RW-iD
GW-iS/D '°GW-6B
-- - GW-6D. GW-6S
MW-39 '
4-MW-56
MW=a7+
Former Clifton
Precision Site . —
4-MW-57
MW-45
MW-a7
MW-a9R* A '
®00,
riissivity 6 ' Waste Boundary Facility -Owned Accessible
itiio gone Properties Properties Figure E-3: Cross Section
a8o-Foot Boundary
— � Location Map
1 Alluvium Former Clifton Precision Site
Compliance Boundary Cross Section Location Murphy, Cherokee County, North Carolina
...............

162(
160(
158(
156(
154
152
150
148
146
144
142
1400
0
Smith
A
South Waste Management
Unit B
Elevation I
in
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100 200 300 400 500 600
Posted values are trichloroethene in
groundwater in micrograms per liter.
Vertical exageration is — 4-5:1.
700 800 goo 10(
Fine -Grained Coa
Alluvium & Residuum
.........................

A'
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1100 1200
istance in Feet
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lurn Bedrock
1300 1400 1500 1600 1700 1800 1900 2000 2100
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rth
Figure E-4: Cross Section
A -A'
Former Clifton Precision Site
Murphy, Cherokee County, North Carolina

B
West
Elevation
in Feet
Spring
160(
155(
150(
145(
1400
0
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P-26
—. 2 .......:.;
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1 1
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Posted values are trichloroethene in
groundwater in micrograms per liter.
Vertical exageration is — 4.5:1.
Fine -Grained Coa
Alluvium & Residuum 1
Smith

2000
stance in Feet
2200
rained
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im
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2400
Transition
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Accessible ProPejU Boundary
2600 2800 3000 3200 3400 3600
3800
t
Figure E-5: Cross Section
B -B'
Former Clifton Precision Site
Murphy, Cherokee County, North Carolina

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la�g Befich, Calilomn UODU SECTIONS AND DETAILS
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Mon of Water Resources
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,n�ectlon Unes,
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I. The are rat sho mr and Stull ba field located
MrOtt4M* >+fth Onner'S OPPrOvvd, AIT-110, AE-110,
. Y-114 PIr04, PT-Ii4. and LW-33.
2. t'er' 5pe0irk12ttan,, T-310 stall have:
-tr:?et the nth vatvo- quackk dl;car�ect. or+d cop
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ec will be lopped
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R I �;_,t � 0_�e `?y'.s MAN �y NORTHR_ OP GRUMMAN MURPHY. NORTH CAROLINA MOIN
H ti8� t:EtnwM7 v6ortct 02NO
Orion Environmental Inc. _ a,� `•. Fyo c
3450 E. Spring St., Suite 212 ': daD EFFLUENT CONTAINER
Long Beoch, California 90806 '", �A� t;; •rr•-'.'r ,�� AS NOTED I•�
[phone] r'o;,' �6 awrz C-4
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Pull Box Details - 20llx2011x12° With Terminal Block (smith Property) _
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Orion Environmental Inc. CREEK CROSSING PROFILE AND
.... , ., 3450 E Sprmg 51., Sve 212 •!'� _
I.org Beich, Calitomin 9F180S v4t as tf„ TRENCH SECTIONS
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n
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;• eon vd.+e
r 9ch, 40 PVG- "e « "t V.
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Electron a
AtIlO100 verve
— IFS• bate Ve" .
ly gal v v,,
BYS' FW &" Tee
Datall 2
Injection Manifold
NOTE: IF THIS SCALE
BAR IS NOT I INCH
LONG, THIS DRAINING
IS N0T TD SCALE.
w CAR®
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SCALE
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02NCF10500A.D'A'G I i I/�I D11e@e ISMS POSICO _ - � 14r f_MT_�,7P6 4/30113
iiLV DESCRIPTION OF RELfiStON BY CH! REV DATE

MAY - 2 2014
Quality Regilmal Opera
choviiip Renional Office
OFFSITE GROUNDWATER
Former Clifton Precision F
- ;
Site Map
scam i°=oo•
Engineer Ov4ner
Jeffrey P. 6winn, P.E. Moog Components Group
Orion Environmental Inc. Igc15 HighHo4 141
3450 E. Spring Street, Suite 212 ' Murphy, North Garolino 28g06
Long Beach, California g0806
562--q88-2-755
a
a
i4
KOM, if THS SCALE
BAR IS NOT I WCO
n
LONG. THIS DIIAWL40
o
IS NOT TO SCALE.
PAD P E
02KCO20+000.DvrD
`
n
DSCRiPTFON OF AMON
List of Orovona5
6-1
Title Sheet
G-I
Plot Plan
G-2
Treatment 5y5tem LaL
G-3
Air Stripper Plan an
G-4
Effluent Container
G-5
Greek Grossing Profi
G-6
Trench Sections
6-1
Sections and Details
E-1 to
E-51 Electrical Dio
5-1
Concrete Slab/Found
5y5tem Layout
DATE
f OA RRO

t oiAL -
_
GaddlS JJJIIII11111
1 crubough l 1
Fleimbng 1 sr
' - `'tee .�.�' -� -+ ✓ •� r P ® . V tom-
I NoM CaroUna,68nvit antW
Commission
,
mopment
f ,• FrosE/Wallover-Eox J.'..
Dlylsion of
I gg �` 1 r�
cliEton Lane 1 ! tsetse _ t�(� I �F9
oPomdt
' -j t 7
2®
®cro551ng ..
Legend
r - ' RN-3 w3 Recovery Well
.v Put Fox e
fNJ-o1 Injection Well
/I Power Pole
Electrical Utillty
GWTS f Note. Items in blue are new
O Pad t and shall be supplied and
k In5talled.by.contrpctor
...--r ate Drawl c-? ' ' �' ..��., _ t- . - _ _.. ,_ . • ...... _f.'�i-,..,,.,_
Well Puma n-3
New Gravel L J F
Road
MOOS (iantpanent5. - �-e. _al ....•-_-.___
Group. Inc. `` E— S
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e t scnl.e
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o go wo Feer
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(r R ! IN sl,
;� r�ael Ol''' D"" ' NORTFIROP GRUMMAN MURPHY, NORTH CAROLINA
r3 �t '� aEaED PROJECT lIT 02NC
Orson Environmental Inc. o g e Ie D DAA1M
3450 E. Spring St.. Suite 212 PLOT PLAN ^ �I
Long Beach, California 90805w`f `":``' S&uE AS ROTE© C- 1
(562) %M-2765 ,'oo�'Dm . �,`;1�s'' `W DOE 30 4 73
rlu.., vi1� / /

ZEATM-ENT SYSTEM DESIGN
'Fility,
2013
Ut
'r'of i!e
Murphy, North Carolina
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F 1i9
,fire d1��
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i )g ate+
15 R\ —SITE
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N CAR®
ESS��tiA.
•n 036053
/rrrrrr111111`1`\1:
and Trenc♦? 5ection5
'am5 (51 5heet5)
ions for Treatment
Vir-initu Map
State l'= ,aoo
erQ�r _ 1 Now.
I. The Contractor and subcontractors shall verify all dimensions and condition, shown on there
drawings (see arawing list). Scale shown on the drawing, If provided, (s for guidance only.
2. No changes are to be made on there plans withovt the knowledge and consent of the Engineer.
3. Conventional Industry stwvdard detalls shall apply where no special detail Is shown, 5uch
details shall be approved by the Elgtneer.
4, L.ocation of connections to burled lines will be determined by Contractor. Locations, shown ore
for reference only.
5. Utllity Interrvptlons: the contractor shall immediately repair at its cost all utlllty service
interrupted by its work. These repairs shall Include tart not be limited to gas, water, sewoge,
telephone, and power service YKterruption.
15. The contractor shall coordhote all work and materials provided by others.
1. The contractor shall provide for fire protection (including fire extingveshers) during the onsite
work In accordance with the unlForm Fire code (UFc).
5. —me, controctor shall provide identification (signs or labels) on piping within the treatment area
and the wellheads.
9. All work shall be performed In accordance with the health once safety procedures described In
the lob spec.IFfcatlons,
ii. I 1 `4 P SH RMAD`! Q
r >�t?feecrd; °H NOR7HROP GRUTAMPN MURPHY, NORTH CAfiOLINA n
o: Z CHECKED
Orion Environmental Inc. = '� � ` ! v us ROJE`" 02NO
3450 E. Spring St., Suite 212 - `; �JPG 6 WN2
Long Beoch, California 90806 -er,t; •?,,�' TITLE SHEET
'. 1'r�e Swi AS N6TE6 ��''++ .l
(SU) 900-29s5 ry, y p C:, _e G- 1
tin, „ & Gtt 4/30/13

I
Truett BoPptl5t
Association of C hvrche5. IRc
Full Box
Gone te
Pad (20"x20"x69
I WHIM -
I iNJ-03 ~ 1
r( 1 d Frame \ Me�derfng F
Barn
i Fence
Concrete ss r
Pad c,JO
I c `\ acoa
Dr a
Diltchtr-h \/ G-5 Pull Box
1
f I
I
1 i MW-23, MW-24.
l I Ie�J-C �S• ® and MN-25
( '
Injection {Nell
5er tiom i
f Pdrd •9f_7"
f � /1t4J-015
{ `INJfob
f
INJ-0*7 //rr
S Canter o!
Slow tree
15 Property I
O MK-60
Spare 2' 5ch. 40 PVC
uwhr it (5b) Stub -Up
and Gapped at INJ-01
i 1 r f2W-5
f 1
f 1 Existing 3'x6"
Groundwater g
1 Extroctfon Line
I
f y
I �_q
Kilpatrick I
Nell RN-41k-x�
56G1,1On
I
I
I f
I
5our .e, 10/31/11 Smith Property
Survey " Southern Bounc"
Surveylnq Company.
NOTE: IF THIS SCALE
NORMHOP
w Is NOT I WXH
LONG. THIS OPAWING
IS NOT TO SCALE.
om FILE
02NCG205DOADWG
A
offolt® 6wf5 Cos
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JP6
4,50/15
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