WQ0036881_Permit Application_20130919

State of North Carolina
Department of Environment and Natural Resources - Division of Water Quality
Non -Discharge Groundwater Remediation Permit Application Form
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED UNLESS ALL APPLICABLE ITEMS ARE INCLUDED
APPLICATION INFORMATION '
Application Date:
9/19/2013
Application Type:
New Project
* New Projects — DWQ to assign application #
�?p
k/ Q
** Renewals/Modifications — Enter Permit #
Clid< here to enter text.
Fee Sub.mitted: (refer to fee schedule at
http://p6rtal.ncdenr.org/web/wq/­apsLiau Lfees)
$1,310 (major)
* For new projects: complete this page, signature page, and supply all attachments.
** For renewals: complete this page and signature page.
For modifications: complete this page, signature page, and supply relevant attachments.
Applicant's Name (specify the name of the
municipality, corporation, individual, etc.):
Northrop Grumman Guidance and Electronics
Company, Inc.
Owner or Signing Official's Name and Title
(person legally responsible for the facility
and its compliance):
Joseph P. Kwan, Corporate Director,
Environmental Remediation
Mailing Address:
2980 Fairview Park Drive, Falls Church, VA 22042
a
Telephone Number:
[phone]
Email Address:
[e-mail]
Facility Name (name of the project site; be
consistent throughout application package):
Former Clifton Precision Site
Physical Address:
1995 NC Highway 141, Murphy, NC 28906
County:
Cherokee
Geographic Coordinates:
Lat: 35.09539 Long:-83.94756
Contact Person (who can answer
questions about application):
Andrew Romanek, CDM Smith
Telephone Number:
[phone]
Email.Address:
[e-mail]
Non -Discharge Groundwater Remediation Permit Application Revised January 30, 2013

i
ATTACHMENTS
The following shall be included as separate attachments to this application form. Failure to
include the following information as part of the application package will result in the
application package being returned as incomplete.
A. Site Description and Incident Information. As specified in 15A NCAC 02T .1604(a). the
applicant must briefly.describe the site, noting pertinent site information including:
(1) Contaminant(s) of concern,
(2) Source(s) and date(s) of the contaminant release,
(3) Remedial actions to date,
(4) Current land use,
(5) Potential receptors, and
(6) Incident number and name of oversight agency.
B. Soils Evaluation. As specified in 15A NCAC 02T .1604(b), for systems with proposed
discharge within seven feet of land surface and above the seasonal high water table, a soil
evaluation of the disposal site shall be provided to the Division by the applicant. If required by
G.S. 89F, a soil scientist shall submit this evaluation. This evaluation shall be presented in a
report that includes the following components:
(1) Field description of soil profile. Based on examinations of excavation pits or
auger borings, the following parameters shall be described by individual
diagnostic horizons to a depth of seven feet below land surface or to bedrock:
(A) Thickness of the horizon;
(B) Texture;
(C) Color and other diagnostic features;
(D) Structure;
(E) Internal drainage;
(F) Depth, thickness, and type of restrictive horizon(s);
(G) pH;
(H) Cation exchange capacity; and
(1) Presence or absence and depth of evidence of any seasonal high water
table.
(2) Recommendations concerning annual and instantaneous loading rates of
liquids, solids, other wastewater constituents and amendments. Annual
hydraulic loading rates shall be based on in -situ measurement of saturated
hydraulic conductivity in the most restrictive horizon.
Non -Discharge Groundwater Remediation Permit Application Revised January 30, 2013

C. Hydrogeologic Evaluation. As specified in 15A NCAC 02T .1604(c), a hydrogeologic
evaluation of the disposal site shall be provided to the Division by the applicant. This
evaluation shall be conducted to a depth that includes the depth of existing contamination and
the total depth of the injection well(s) or infiltration gallery(ies). This evaluation shall be based
on borings for which the numbers, locations, and depths are sufficient to define the
components of the hydrogeologic evaluation. In addition to borings, other techniques may be
used to investigate the subsurface conditions at the site. These techniques may include
geophysical well logs, surface geophysical surveys, and tracer studies. This evaluation shall be
presented in a report that includes the following components:
(1) A description of the regional and local geology and hydrogeology;
(2) A description, based on field observations of the site, of the site topographic
setting, streams, springs and other groundwater discharge features, drainage
features, existing and abandoned wells, rock outcrops, and other features that
may affect the movement of the contaminant plume and treated wastewater;
(3) Changes in lithology underlying the site;
(4) Depth to bedrock and occurrence of any rock outcrops;
(5) The hydraulic conductivity, transmissivity, and storativity (specific yield if
unconfined aquifer) of the affected aquifer(s);
(6) Depth to the seasonal high water table;
(7) A discussion of the relationship between the affected aquifers of the site to
local and regional geologic and hydrogeologic features; and
(8) A discussion of the groundwater flow regime of the site focusing on the
relationship of the plume and remediation system to groundwater receptors,
groundwater discharge features, and groundwater flow media.
D. Demonstration of Hydraulic Control. As specified in 15A NCAC 02T .1604(d), computer
modeling or predictive calculations based on site -specific conditions shall be provided to the
Division by the applicant to demonstrate that operation of the system will not cause or
contribute to:
(1) The migration of contaminants into previously uncontaminated areas, and
(2) A violation of the groundwater standards specified in 15A NCAC 02L .0202 at
the compliance boundary as described in 15A NCAC 02L .0107.
Non -Discharge Groundwater Remediation Permit Application Revised January 30, 2013

E. Maps and Cross -Sections. As specified in 15A NCAC 02T .1604(e), site plans or maps shall be
provided to the Division by the applicant depicting the location, orientation, and relationship of
facility components including:
(1) A scaled map of the site, with site -specific topographic contour intervals and
showing all facility -related structures and fences within the treatment, storage
and disposal areas;
(2) Locations of all test auger borings or inspection pits;
(3) The location of all wells (including usage and construction details if available),
designated wellhead protection areas, streams (ephemeral, intermittent, and
perennial), springs, lakes, ponds, other surface drainage features, and any other
site activities or features that may involve possible exposure to contamination
within 500 feet of all waste treatment, storage, and disposal sites;
(4) Setbacks specified in 15A NCAC 02T .1606;
(5) Delineation of property boundaries, review boundaries, and compliance
boundaryies;
(6) The horizontal and vertical extent of the contaminant plume for each of the
contaminants of concern, including isoconcentration lines and plume cross -
sections;
(7) Cross -sections depicting soil and rock layers and features to a depth including
the depth of existing contamination and the total depth of the injection wells or
infiltration galleries; and
(8) Hydrologic features such as potentiometric surface / water table contours and
the direction of groundwater flow.
F. Engineering Design Documents. As specified in 15A NCAC 02T .1604(f), the following
documents shall be provided to the Division by the applicant:
(1) Engineering plans for the entire system, including treatment, storage,
application, and disposal facilities and equipment except those previously
permitted unless they are directly tied into the new units or are critical to the
understanding of the complete process;
(2) Specifications describing materials to be used, methods of construction, and
means for ensuring quality and integrity of the finished product; and
(3) Plans that include construction details of recovery, injection, and monitoring
wells and infiltration galleries.
NOTE: Recovery and monitoring wells shall be constructed in accordance with
the requirements of 15A NCAC 02C .0108. Injection wells shall be constructed
in accordance with the requirements of 15A NCAC 02C .0225(g).
Non -Discharge Groundwater Remediation Permit Application Revised January 30, 2013

G. Operating and Monitoring Plans. As specified in 15A NCAC 02T .1604(g), an operation and
monitoring plan shall be provided to the Division by the applicant. These documents shall be
specific to the site and include:
(1) The operating plan shall include:
(A) The operating schedule including any periodic shut -down times,
(B) Required maintenance activities for all structural and mechanical
elements,
(C) All consumable and waste materials with their intended source and
disposal locations,
(D) Restrictions on access to the site and equipment, and
(E) Provisions to ensure the quality of the treated effluent and hydraulic
control of the system at all times when any portion of the system ceases
to function.
(2) If injection wells are to be used then the operating plan shall also include:
(A) The proposed average and maximum daily rate and quantity of injectant;
(B) The average maximum injection pressure expressed in units of pounds per
square inch (psi); and
(C) The total or estimated total volume to be injected.
(3) The monitoring plan shall be prepared in accordance with 15A NCAC 02T .1607
and include:
(A) The monitoring well(s) that will be sampled,
(B) The constituent(s) for which those samples will be analyzed, and
(C) The schedule for sampling.
H. In Situ Remediation Additives. The following shall be provided to the Division by the
applicant if the remediation system includes additives to promote remediation in situ:
NOTE: Approved injectants can be found online at http://i)ortaLncdenr.orglweblwglapslqwpro. All other
substances must be reviewed by the Division of Public Health, Department of Health and Human Services as
required by 15A NCAC 02C .0225(a). Contact the UIC Program for more information (Ph# 919-807-6464).
(1) MSDS, concentration at the point of injection, and percentage if present in a mixture
with other injectants;
(2) A description of the rationale for selecting the injectants and concentrations proposed
for injection, including an explanation or calculations of how the proposed injectant
volumes and concentrations were determined;
(3) A description of the reactions between the injectants and the contaminants present
including specific breakdown products or intermediate compounds that may be formed
by the injection;
(4) A summary of results if modeling or testing was performed to investigate the injectant's
potential or susceptibility for biological, chemical, or physical change in the subsurface;
and
(5) An evaluation concerning the development of byproducts of the injection process,
including increases in the concentrations of naturally occurring substances. Such an
evaluation shall include the identification of the specific byproducts of the injection
process, projected concentrations of byproducts, and areas of migration as determined
through modeling or other predictive calculations.
Non -Discharge Groundwater Remediation Permit Application Revised January 30, 2013

Professional Engineer's Certification:
Name and Complete Address of Engineering Firm:
City: Long Beach
Telephone Number: ( 562 ) 988-2755
r Jeffrey P Gwinn
non -discharge groundwater remediation permit
Orion Engineering, dba Arctos Engineering
State: CA
Zip:
Fax Number: ( 562
•1:1.
) 988-2759
, attest that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I further attest
that to the best of my knowledge the proposed design has been prepared in accordance with the
applicable regulations. Although certain portions of this submittal package may have been developed
by other professionals, inclusion of these materials under my signature and seal signifies that I have
reviewed this material and have judged it to be consistent with the proposed design. N ICAR /!///
'C O
North Carolina Professional Engineer's Seal Signature, and Date: O OFESS/O liy
SEAL
036053 =
GINE��'�a� .
\\�
12/5/13, P-1277 �'�,,RFIYP. G
Applicant's Certification (signing authority must be in compliance with 15A NCAC 2T .0106(b)
and c :
Joseph P. Kwan
attest that this application for
non-discharee eroundwater remediation oermit
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand
that if all required parts of this application are not completed and that if all required supporting
information and attachments are not included, this application package will be returned to me as
incomplete.
Signature Date 9/19/2013
SEND TWO COPIES OF THE COMPLETE APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION AND MATERIALS, TO THE FOLLOWING ADDRESS:
DWQ - AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636
TELEPHONE NUMBER: [phone]
Non -Discharge Groundwater Remediation Permit Application Revised January 30, 2013

Attachment A
Site Description and Incident Information
The information requested in this attachment is primarily presented in the RCRA Facility Investigation
(RFI) Report (CDM Smith, July 2013), which is included on the enclosed CD-ROM. Additional details
are provided here along with where to find specific information in the RFI Report:
1. Contaminant(s) of concern
The contaminants of concern are volatile organic compounds (VOCs), and specifically
chlorinated ethene and ethane VOCs. Soil and groundwater VOC results from multiple
investigations are presented in Section 4 of the RFI Report, and Section 5.3 of the RFI Report
contains conclusions regarding the extent of VOCs in groundwater. A complete profile of VOC
influent and predicted effluent concentrations for the groundwater treatment system that will
be upgraded as part of this project are provided in Appendix C-1 of the Final Design Report for
Offsite Groundwater Interim Measure (Orion, September 2013). This report is also included on
the enclosed CD-ROM.
In addition to VOCs, 1,4-dioxane has been detected in groundwater at levels up to 40
micrograms per liter (µg/L). The design basis for 1,4-dioxane is presented in Appendix C-4 of
the design report.
2. Source(s) and date(s) of the contaminant release
Section 1.1 of the RFI Report provides a site history, and Section 1.2 describes each identified
waste management unit (WMU). As described in the report, the majority of the VOCs in
groundwater are believed to have originated from WMU-B (Underground Storage Tank) based
on the investigation results and site history.
3. Remedial actions to date
See Sections 1.3 and 6 of the RFI Report.
4. Current land use
The site is currently owned and operated by Moog Components Group. Moog designs and
manufactures brush and brushless DC motors, synchros, resolvers, solenoids, and air moving
solutions for both commercial and military markets at this facility. Details regarding
surrounding land use are provided in Section 2.1 of the RFI Report.
S. Potential receptors
Current potential receptors include construction workers, outdoor workers, indoor workers,
and offsite residents. A portion of the residents living near the site previously used private
wells to meet domestic water supply needs. These residential properties are currently
connected to the Town of Murphy water supply, and private wells located on these properties
have been locked out from use per executed agreements with the property owners. The results
from a risk assessment submitted to the U.S. Environmental Protection Agency (EPA) and
smith a-1
2013-D919-Murphy-Non-Discharge GW Remediation Perm it Application Attachments.doa

Attachment A
North Carolina Department of Health and Environmental Control (NCDENR) calculated that all
risks to current receptors are within the range of risks that EPA considers acceptable.
6. Incident number and name of oversight agency
EPA Region 4 is the lead regulatory agency on this project with support provided by NCDENR.
The EPA ID number for this site is NCD 044 438 406.
Smith A-z
202-0919-Murphy-Non-Discharge GW Rem ediation Permit Application Attachments.dea

Attachment B
Soils Evaluation
Reinjection of treated groundwater is not planned above the seasonal high water level or within seven
feet of land surface. As such, attachment soil evaluation is not required. Details regarding the site
geology are presented in Section 5.1 of the RFI Report.
Smith s-1
2013-093-Murphy-Non-Discharge GW Remediation Permit Application Attachmenh.dom

Attachment C
Hydrogeologic Evaluation
The information requested in this attachment is primarily presented in the RFI Report (CDM Smith,
July 2013), which is included on the enclosed CD-ROM. Additional details are provided here along with
where to find specific information in the RFI Report:
1. A description of the regional and local geology and hydrogeology
Regional geology and hydrogeology are discussed in Sections 2.3 and 2.4, respectively, of the
RFI Report. Summaries of the local geology and hydrogeology are presented in Sections 5.1 and
5.2, respectively, of the RFI Report.
2. A description, based on field observations of the site, of the site topographic setting,
streams, springs and other groundwater discharge features, drainage features, existing
and abandoned wells, rock outcrops, and other features that may affect the movement of
the contaminant plume and treated wastewater
Section 2.2 of the RFI Report includes information on topography and drainage. Detailed
descriptions of groundwater movement and VOC migration in groundwater are presented in
Sections 5.2 (Hydrogeology) and 5.6 (Conceptual Hydrogeologic Model) of the RFI Report.
3. Changes in lithology underlying the site
Sections 5.1 (Geology) and 5.2 (Hydrogeology) of the RFI Report discuss changes in lithology
on site and off site. Figures 5-1 through 5-4 provide surface elevation maps for the transition
zone and bedrock zone as well as a map of transition zone thickness. Figures 4-19 through 4-21
show geologic cross -sections for the WMU-B area.
4. Depth to bedrock and occurrence of any rock outcrops
See response to Item #3.
S. The hydraulic conductivity, transmissivity, and storativity (specific yield if unconfined
aquifer) of the affected aquifer(s)
Estimated values for hydraulic conductivity (k), transmissivity (T), and storativity/specific
yield (S/Sy) in the proposed area of reinjection are as follows:
Layer K ft da T ftz da S/& (dimensionless)
Fine -Grained Alluvium 0.014 —0.4 0.15
Coarse -Grained Alluvium 30 —500 OAS
Transition Zone 100 —2,750 0.005
Bedrock (1) 0.005 —1 5 x 10-7
(1) —The bedrock transmissivity is highly variable because of location -specific fractures.
Smith c-1
2013-0919-Murphy-Non-Discharge GW Remediation Permit Application Attachments.dam

A
Attachment C
6. Depth to the seasonal high water table
Figures 3 and 4 of the most recent semi-annual groundwater monitoring report (April 2013
event), which is provided on the enclosed CD-ROM, show potentiometric surface maps for the
regolith / transition zone and bedrock zone. This report also includes tabulated measurements
for the depths to groundwater. Considering the unusually high amount of precipitation in 2013,
these maps are expected to represent high water table conditions.
7. A discussion of the relationship between the affected aquifers of the site to local and
regional geologic and hydrogeologic features
Similar to the above items, this is covered by Sections 2.2 (Topography and Drainage), 2.3
(Regional Geology), 2.4 (Hydrogeology), 5.1 (Geology), and 5.2 (Hydrogeology) of the RFI
Report.
B. A discussion of the groundwater flow regime of the site focusing on the relationship of
the plume and remediation system to groundwater receptors, groundwater discharge
features, and groundwater flow media
See Section 5.6 (Conceptual Hydrogeologic Model) of the RFI Report.
Smith C-Z
2013-0919-Murphy-Non-Discharge GW Rem ediation Permit Appl lotion Attachments.dou

Attachment D
Demonstration of Hydraulic Control
The purpose of Attachment D is twofold and includes demonstrations that operation of the
groundwater remediation system will not cause or contribute to:
■ Migration of contaminants into previously uncontaminated areas; and
■ A violation of the NC2L groundwater standards at and beyond the Compliance Boundary.
Compliance Boundary and Waste Boundary Definition
Figure D-1 includes the Compliance Boundary and Waste Boundaries, and delineates the areas where
the applicant has controlled access. The Waste Boundary was initially drawn as a 30-foot radius
around each of the eight reinjection wells, and the radial areas were joined as one area on the Truett
Baptist property and as one area on the Former Smith property. These two areas were selected to
minimize the number of properties containing waste boundaries while complying with NCDENR's
guidance for constructing the Waste Boundaries. The Waste Boundary on Truett Baptist encompasses
approximately 8,230 square feet (ft2), and the deepest reinjection well, INJ-1, within this boundary is
180 feet deep. The Waste Boundary on the Former Smith property encompasses approximately
77,500 ftz, and the deepest reinjection wells within this boundary are also 180 feet deep.
The Compliance Boundary was constructed by drawing a 280-foot radius around each reinjection well
to show the area that is 250 feet beyond the 30-foot Waste Boundaries. This initial area extended to an
additional six properties without controlled access. The proposed Compliance Boundary was redrawn
to exclude these six additional properties by establishing the boundary within 50 feet of the property
lines with controlled access, which is consistent with the NCDENR guidance. While this boundary does
establish an irregular area, the resulting area does allow sufficient access for monitoring the
groundwater plume and the effects of reinjection on the plume. The Compliance Boundary has an area
of approximately 541,500 W.
Groundwater Modeling
The DYNFLOW modeling code was used to develop a project groundwater flow model. DYNFLOW is a
fully three-dimensional, finite element groundwater flow model. This model has been developed over
the past 25 years by CDM Smith engineering staff, and is in general used for large scale basin modeling
projects and site specific remedial design investigations. It has been applied to hundreds of
groundwater modeling studies in the United States and has been reviewed and tested by the
International Ground Water Modeling Center (IGWMC) (van der Heijde 1985, 2000).
DYNFLOW uses a finite -element grid mesh built with a large number of elements. The elements are
triangular in plan view and three -sided prisms in three dimensions, and give a wide flexibility in grid
variation over the area of study. An identical grid is used for each level (surface) of the model, but the
thickness of each model layer (the vertical distance between levels in the model) may vary at each
nodal point in the grid. Linear interpolation functions are applied in all hydraulic computations within
elements, such that each node is computationally linked to each of the nodes of the elements of which
it is a part.
Smith D-1
2013-0919-Murphy-Nan-Discharge GW Remediatlun Permit Applimtlon Attachments,daa

Attachment D
A summary evaluation of reinjecting treated groundwater into the regolith and bedrock zones is
summarized in a March 2011 memo prepared by CDM Smith. This memo is included on the enclosed
CD-ROM. The reinjection evaluation predates installation and testing of the eight injection wells, as
summarized at the end of Section 1.5.4 and in Section 4.9 of the RFI Report. The groundwater model
was updated based on the additional work performed, and further simulation yielded consistent
results with those documented in the March 2011 memo. Specifically, the model confirms that the
transmissivity of the shallow aquifer is high enough to receive the projected quantity of injected water
without producing large -magnitude mounding of the water table and that reinjection into fractured
bedrock will enhance hydraulic containment in that zone.
Hydraulic Control
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 Section 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.
The reinjection water will be treated to below the NC2L standards and reinjected. A portion of the
reinjected water will be captured by the existing extraction well system. However, the extent of this
capture will not be fully known until the system is placed in full operation. The remainder of the
reinjected water will migrate downgradient to the west, and the residual VOCs that may currently
exist in the downgradient area will be diluted and attenuated. The ultimate fate of the downgradient
groundwater is to discharge to Slow Creek. Figure D-2 summarizes the regolith groundwater
modeling results based on an extreme groundwater extraction and reinjection scenario. This scenario
minimizes groundwater extraction rates to a total of 19.5 gpm while maximizing the reinjection rates
at 20 gpm per reinjection, well. This scenario is designed to evaluate the sensitivity of the groundwater
migration paths under reinjection. As shown in Figure D-2, the regolith groundwater migration paths
are essentially undisturbed by the reinjection. The groundwater continues to migrate primarily to the
west-southwest and ultimately into Slow Creek.
Similar to Figure D-2, Figure D-3 summarizes the bedrock groundwater modeling results when I
minimizing the groundwater extraction rate to 0.86 gpm while maximizing the reinjection rate at 45.5
gpm. Figure D-3 shows that the bedrock groundwater migration paths show very little disturbance by
the reinjection in bedrock.
smith D-2
2013-0919-Murphy-Non-Diuharge GW Remediation Permit Application Attachmentt.dom

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_ Facility -Owned Accessible
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Figure D-1: Compliance &
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Former Clifton Precision Site
Murphy, Cherokee County, North Carolina

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(D Regolith Recovery Well Properties Properties
® Regolith/Transition Recovery Well Compliance Boundary
N Simulated Regolith Groundwater Flow Direction Scale in Feet
0 Zoo 400
Reinjection Simulation Parameters Figure D-2' Simulated Regolith
RW-1S: No extraction INJ-Z: Reinjection at Zo gpm
RW-Z: No extraction INJ-4: Reinjection at Zo gpm Reinjection Groundwater Flow
COMRW-3: Extraction at o.18 gpm INJ-6: Reinjection at Zo gpm Former Clifton Precision Site
Smith RW-4: Extraction at 19.5 gpm INJ-8: Reinjection at 20 gpm Murphy, Cherokee County, North Carolina

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Simulated Bedrock Groundwater Flow Direction Scale in Feet
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Reinjection Simulation Parameters Figure D-3• Simulated Bedrock
RW-iD: No extraction INJ-i: Reinjection at ao gpm
C� RW-5: Extraction at o.86 gpm INJ-3: Reinjection at 2.5 gpm Reinjection Groundwater Flow
��7�th INJ-5: Reinjection at 20 gpm Former Clifton Precision Site
INJ-7: Reinjection at 3 gpm Murphy, Cherokee County, North Carolina

Attachment E
Maps and Cross -Sections
The information requested in this attachment is primarily presented in the RFI Report (CDM Smith,
July 2013), which is included on the enclosed CD-ROM. Additional details are provided here along with
where to find specific information in the RFI Report:
1. A scaled map of the site, with site -specific topographic contour intervals and showing all
facility -related structures and fences within the treatment, storage and disposal areas
See Figure 1-7 of the RFI Report.
2. Locations of all test auger borings or inspection pits
See Figures 1-3 through 1-9 of the RFI Report. Figure 1-9 shows the reinjection wells proposed
for use via this request for a remediation permit.
3. The location of all wells (including usage and construction details if available),
designated wellhead protection areas, streams (ephemeral, intermittent, and
perennial), springs, lakes, ponds, other surface drainage features, and any other site
activities or features that may involve possible exposure to contamination within 500
feet of all waste treatment, storage, and disposal sites
All onsite and offsite wells are shown on Figures 1-2, 1-3, 1-7, 1-8, 1-9, and 4-2 of the RFI
Report. Figure 1-9 is the most relevant to this application as it shows the groundwater
extraction, reinjection wells, and surrounding site features. Well construction details for all RFI
installed wells are provided in Table 3-1.
4. Setbacks specified in 15A NCAC 02T .1606
See Figure 1-9 of the RFI Report and the attached Figure E-1 and Figure E-2. The Former
Smith parcel located northwest of the Moog property across Slow Creek is owned by Northrop
Grumman Guidance and Electronics Company, Inc. (NGGECI), who is the Permit Applicant and
Potentially Responsible Party. Nobody lives on this property and the only remaining structure
is a barn. The Truett Baptist parcel and the Fleming parcel have access agreements with
NGGECI. All setbacks are in place except for bedrock reinjection well INJ-7, which is located
approximately 90 feet from Slow Creek.
The eight reinjection locations are believed to be critical to the success of the reinjection and
groundwater capture system. VOCs have been detected in Slow Creek and on both neighboring
properties to INJ-3 and INJ-4. All reinjected water will be treated to below NC2L standards, and
use of these injection wells will not result in migration of contaminants to previously
uncontaminated areas.
Note that some groundwater wells installed by NGGECI are within 100 feet of the injection
wells and will be used for monitoring.
Smith E-1
2013-0919-Murphy-Non-Discharge GW Remediation Permit Application Attachments.doa

Attachment E
lelineation of property boundaries, review boundaries, and compliance boundaries
reefer to Figure D-1. The review boundary is proposed to be synonymous with the waste
boundary with monitoring based on testing of the reinjected water.
6. The horizontal and vertical extent of the contaminant plume for each of the
contaminants of concern, including isoconcentration lines and plume cross -sections
Figures 5-7 and 5-8 of the RFI Report present isoconcentration maps for VOCs in the
regolith/transition zone and bedrock zone, respectively. Additional concentration maps for the
source area (WMU-B) are presented in Figures 4-26 through 4-31. Cross -sections through the
source area with groundwater concentrations shown are presented in Figures 4-19 through 4-
21. Figure E-3 provides a geologic cross-section location map with corresponding cross -
sections provided on Figures"E-4 and E-5.
7. Cross -sections depicting soil and rock layers and features to a depth including the depth
of existing contamination and the total depth of the injection wells or infiltration
galleries
See Figures 4-19 through 4-21 of the RFI Report. Boring logs for the reinjection wells can be
found in Appendix A-4 of the RFI Report (starting on pdf page 495), and well construction
details for the injection wells are presented in Table 3-1. Figure E-3 provides a geologic cross-
section location map with corresponding cross -sections provided on Figures E-4 and E-5.
8. Hydrologic features such as potentiometric surface / water table contours and the
direction of groundwater flow
Refer to the potentiometric surface maps presented in the April/May 2013 Correction Action
Monitoring Report (provided on the enclosed CD-ROM). Additional maps can be found in
Figures 4-10, 4-11, 4-32, 4-33, 5-5, and 5-6 of the RFI Report.
Smith
2013d919-Murphy-Nan-Discharge GW Remediation Permit Applimtion Attachments.doa
E-2

CDM
Smith
CABLE INJECTION WELL SETBACKS
• Active Supply Well (ioo')
Q Inactive Supply Well (ioo')
Perennial Surface Water Stream (100')
Parcel Lines (50')
Former Smith Parcel
L1
LICC04110
Truett Baptist Parcel
INJ-2
rres �
:s 1
Pt .es Properties
1 Waste Boundary
Compliance Boundary
® Regolith Recovery Well
Q Regolith/Transition Reinjection Well
Scale in Feet
o 16o Sao
Figure E-1: Regolith/
Transition Setbacks
Former Clifton Precision Site
Murphy, Cherokee County, North Carolina

Smith
CABLE INJECTION WELL SETBACKS
• Active Supply Well (ioo')
Q Inactive Supply Well (ioo')
Perennial Surface Water Stream (100')
Parcel Lines (50')
Former Smith Parce
i
i
;�r�RW-5
UICC061)],
Truett Baptist Parcel
Properties Properties
6 _ e Waste Boundary
Compliance Boundary
® Bedrock Recovery Well
® Bedrock Reinjection Well
Scale in Feet
o 16o 320
Figure E-2: Bedrock
Setbacks
Former Clifton Precision Site
Murphy, Cherokee County, North Carolina

Attachment F
Engineering Design Documents
The information requested in this attachment is presented in the Final Design Report for Offsite
Groundwater Interim Measure (Orion, September 2013), which is included on the enclosed CD-ROM.
NCDENR is encouraged to read Section 3 of the report, which provides a summary of the proposed
interim measure and design basis. Details are provided here on where to find specific information
requested by the permit application:
1. Engineering plans for the entire system, including treatment, storage, application, and
disposal facilities and equipment except those previously permitted unless they are
directly tied into the new units or are critical to the understanding of the complete
process
See Appendix A of the design report. Additionally, design details for the advanced oxidation
process are provided in Appendix F.
2. Specifications describing materials to be used, methods of construction, and means for
ensuring quality and integrity of the finished product
See Appendix E of the design report.
3. Plans that include construction details of recovery, injection, and monitoring wells and
infiltration galleries.
See Drawing C-7 in Appendix A of the design report. Note that the recovery wells (RW-1S, RW-
3, RW-4, and RW-5) are already in place and operating and that the eight injection wells (INJ-1
through INJ-8) have already been installed. Construction details for the recovery wells are
presented in Section 1.2 of the design report and construction details for the injection wells are
presented in Section 2.3 of the design report.
Smith F-1
2013-0919-Murphy-Non13Ischarge GW Remediatlon Perm it Applimtlan Attachments.dom

Attachment G
Operating and Monitoring Plans
The information requested in this attachment is primarily presented in the Final Design Report for
Offsite Groundwater Interim Measure (Orion, September 2013) and the Corrective Action Monitoring
Plan (Original = February 2008, Most Recent Revisions = August 2012, CDM Smith). These documents
are included on the enclosed CD-ROM. Additional details as well as where to find specific information
requested by the permit application are presented here:
1. The operating plan shall include:
a. The operating schedule including any periodic shut -down times,
b. Required maintenance activities for all structural and mechanical elements,
c. All consumable and waste materials with their intended source and disposal locations,
d. Restrictions on access to the site and equipment, and
e. Provisions to ensure the quality of the treated effluent and hydraulic control of the system
at all times when any portion of the system ceases to function.
See Appendix G of the design report. In addition to what is shown in the design report, the
following reinjection startup plan will be implemented to ensure reinjected water meets the
NC21, standards and confirm initial reinjection setup:
■ Step 1— Initiate treatment system operation at 25 gpm with discharge to the public
operated treatment works (POTW) via an existing permit. Collect a sample after 12 and 24
hours to verify treatment to NC2L standards.
■ Step 2 — If treatment is being achieved, divert flow to the reinjection wells at 25 gpm and
verify reinjection performance (wellhead pressures/water level rise) over a 24-hour
period.
! Step 3 — Ramp up the flow while monitoring the water level response in RW-4, adjusting
'! RW-4 settings as appropriate. As a conservative measure, the flow to the POTW will be
1,
maintained at 25 gpm (permit limit) with the remainder reinjected during this period.
Collect RW-4 influent samples and treatment system samples after 12 and 24 hours of
operation at the high flow rate.
■ Step 4 - If treatment is still being achieved, divert all of the higher flow to reinjection wells
and verify reinjection performance (wellhead pressures/water level rise) over a 24-hour
period.
■ Step 5 — Sample weekly for next 3 weeks of operation.
After the initial three week startup period, routine monitoring will occur as noted in the design
report.
CSm Smith G-1
2013-0919-Murphy-Nan-Discharge GW Remediation Permit Applimtion Attachments.dou

a.
)n wells are to be used then the operating plan shall also include:
The proposed average and maximum daily rate and quantity of injectant;
Attachment G
b. The average maximum injection pressure expressed in units of pounds per square inch
(psi); and
c. The total or estimated total.volume to be injected.
See Section 2.4 of the design report. Groundwater extraction, treatment, and injection are
planned to operate continuously.
3. 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.
See Section 4 of the design report and the Corrective Action Monitoring Plan (CAMP). The
original CAMP contains details on the sampling procedures while the latest revisions document
which monitoring wells are sampled on a semi-annual basis. This plan will be modified as
needed to support continuing evaluations of groundwater conditions and submitted to EPA and
NCDENR for approval.
Smith
2013-0919-Murphy-Non-Discharge GW Remediation Permit Applimtion Attachments.doa
G-2

he proposed reinjection.
Smith H-1
2013-0919-Murphy-Non-Discharge GW Remediation Permlt Applimtion Attachments,doa