NC0088838_Engineering Alternatives Analysis_20090519

ENGINEERING ALTERNATIVES ANALYSIS (EAA)
Submitted In Support of
National Pollutant Discharge Elimination System (NPDES) Permit
for
Radiator Specialty Company
Groundwater Remediation
600 Radiator Road
Indian Trail, Union County, North Carolina
May 19, 2009
Prepared for:
Mr. Richard Harmon, P.G.
Harmon Environmental, PA
615 Bruce Thomas Road
Monroe, North Carolina 28112
On Behalf of:
Radiator Specialty Company
600 Radiator Road
Indian Trail, Union County, North Carolina 28079
Prepared by:
NESCO
A Professional Limited Liability Company
PO Box 78222
Charlotte, North Carolina 28271
[phone]

ENGINEERING ALTERNATIVES ANALYSIS (EAA)
Submitted In Support Of
National Pollutant Discharge Elimination System (NPDES) Permit
for
Radiator Specialty Company
Groundwater Remediation
600 Radiator Road
Indian Trail, Union County, North Carolina
This report was prepared by NESCO ENVIRONMENTAL, P.L.L.C.
P
Joseph P. Nestor, P.G., P.E.
President
North Carolina Licensed Engineer No. 230056
Date
EAL ' �'�
2 056
so=
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TABLE OF CONTENTS
1.0
GENERAL INFORMATION
1
2.0
OTHER CONSIDERATIONS
8
3.0
REMARKS
9
4.0
REFERENCES
10
FIGURES
Figure 1 Topographic Location Map
TABLES
Table 1 Air Stripper Influent Concentrations
/001N Table 2 Air Stripper Effluent Concentrations
Table 3 Recent Influent and Effluent Concentrations
and Calculated Removal Efficiencies

I
6A
APPENDICES
Appendix A Description of Low -Flow Characteristics for South Fork Crooked Creek
near Indian Trail Prepared by J. Curtis Weaver of the United States
Geological Survey — February 19, 2009
Appendix B Records of Communication
Appendix C Review of Union County Soil Survey Information for Potential Land
Application of Treated Groundwater Radiator Specialty Company, Inc. -
February 6, 2009 — Prepared by Septic Environmental Solutions, Inc.
Appendix D Evaluation of On -Site Soils and Bedrock for Potential Subsurface
Discharge of Treated Groundwater from the Existing Remediation
System, Radiator Specialty Company, Inc. - February 26, 2009 —
Prepared by Harmon Environmental, P.A.
Appendix E Treated Groundwater Reuse Synopsis - February 26, 2009 — Prepared by
Radiator Specialty Company
Appendix F Recent Influent and Effluent Analytical Results
Appendix G Present Value of Costs Analysis
Appendix H Documentation Regarding Local Government Review Forms

I
1.0 GENERAL INFORMATION
A. Project Identification
o Facility Name: Radiator Specialty Company
o Contact: Mr. Stuart Kerkhoff, Environmental Manager
o Facility County: Union
o Facility Address: 600 Radiator Road
Indian Trail, North Carolina 28079
o Facility Telephone Number: [phone]
o EAA Preparer's Name: Nesco Environmental, P.L.L.C.
o EAA Preparer's Mailing Address: PO Box 78222
Charlotte, North Carolina 28271
o EAA Preparer's Telephone Number: [phone]
o EAA Preparer's E-mail Address: nescoenv _carolina.rr.com
B. Project Description
o Radiator Specialty Company (RSC) owns and operates a
manufacturing facility at the site. A release of solvents has affected
groundwater. An onsite groundwater recovery and treatment system
designed by AWARE Environmental, Inc. (AWARE) in 1992 was
installed in 1993 and 1994 and began operation on October 24, 1994.
Since that time, the discharge has been to the publicly owned
treatment works (POTW) maintained by Union County. Groundwater
is extracted from four (4) recovery wells and is pumped to a 6,000-
gallon above -ground storage tank (AST) for flow equalization. The
extracted groundwater is then pumped to the top of a packed air
stripping tower. After passing through the air stripper, the treated
groundwater flows by gravity through a discharge port. Over 14 years
of data show that the groundwater treatment equipment has been
effectively removing volatile organic compounds (VOCs) from the
extracted groundwater. Union County recently has expressed an
unwillingness to continue to accept this wastestream. It is proposed
that the discharge be re-routed to an intermittent stream that flows
into the South Fork Crooked Creek.
1

9
STEP 1 - Determine if the proposed discharge will be allowed
o Zero flow stream restrictions (15A NCAC 2B .0206[d][(2]) apply to oxygen -
consuming waste in zero -flow streams.
➢ Although a determination has been made by the United States Geological
Survey (USGS) that the South Fork Crooked Creek is most likely a zero -
flow stream under 7Q10 conditions, this restriction is not applicable
because the wastewater is not an oxygen -consuming waste. In fact, the
wastewater will be quite the opposite, in that it will be highly oxygenated
after passing through the air stripper. A copy of the USGS report on
streamflow characteristics is attached as Appendix A.
o Receiving stream classification restrictions (e.g., ORW, WS, SA, NSW, and HQ
)class waters have various discharge restrictions or require stricter treatment
standards.
➢ Nesco Environmental determined that the stream classification for South
Fork Crooked Creek is Class C by reviewing data on NCDENR's stream
classification webpage on February 24, 2009. Therefore, this restriction is
f� not applicable.
6a
o Basinwide Water Quality Plans. These basin -specific plans list NPDES
permitting strategies that may limit wastewater discharges to particular streams
within the basin due to lack of stream assimilative capacity, etc.
➢ Nesco Environmental reviewed the basin specific water quality plan for the
Rocky River basin found through the NCDENR website at
http://h2o.enr.state.nc.us/basinwide/Neuse/2008/documents/RockyR.03040
105.pdf. This document does not contain any specific discharge
recommendations for the South Fork Crooked Creek. Nesco
Environmental contacted Ms. Heather Pratt of the NCDENR Basinwide
Planning Unit. Ms. Pratt confirmed that there are no specific discharge
recommendations for the South Fork Crooked Creek. Appendix B includes
a record of communication with Ms Pratt.
2

9
o Impaired waters and TMDLs. Certain waterbodies listed as impaired on the
303(d) list and/or subject to impending TMDLs may have wastewater discharge
restrictions.
➢ Nesco Environmental reviewed the 303(d) list found through the NCDENR
website (http://h2o.enr.state.nc.us/tmdl/documents/303d Report.pdf). This
document indicates the South Fork Crooked Creek from the source to SR
1515 (which is within the reach of the stream where the discharge is
proposed) is listed as impaired because of "impaired biological integrity".
This document lists the potential sources of this impairment as agriculture,
construction, and Urban Runoff/Storm Sewers. Nesco Environmental
contacted Ms. Kathy Stecker of the DWQ Modeling/TMDL Unit by email
regarding potential restrictions. Ms. Stecker responded by email and
indicated that her unit "only provides review and recommendations upon
request for the NPDES units". Appendix B includes a record of
communication with this individual.
o Presence of Endangered Species. If endangered species are present in the
f"1 proposed discharge location, there may be wastewater discharge restrictions.
/001N
➢ Nesco Environmental contacted Ms. Shari Bryant of the North Carolina
Wildlife Resource Commission by email. On March 11, 2009, Ms. Bryant
responded by email and indicated that several listed species were noted
within five miles of the proposed discharge in South Fork Crooked Creek.
Ms. Bryant indicated that her agency generally does not recommend against
denial of NPDES permits. Appendix B includes a record of communication
with this individual.
STEP 2 - Provide reasonable projections for population and flow
o The groundwater remediation system was originally designed and permitted for
90,000 GPD. Nesco Environmental understands that Union County verbally
requested RSC to limit the flow from the groundwater remediation system to
60,000 GPD to assist it in meeting demand without exceeding treatment capacity
at the POTW. Nesco Environmental understands that RSC has honored this
request to limit flow to less than 60,000 GPD. Nesco Environmental understands
that RSC is considering installing additional recovery wells and desires to
3

14
/IOMO1
increase the permitted flow rate of the groundwater treatment system to 75,000
GPD.
STEP 3 - Evaluate technologically feasible alternatives
o Connection to an existing wastewater treatment plant (public or private)
➢ Union County has indicated to RSC that possibly as early as December 31,
2009, it will no longer be willing to accept the waste stream from the
groundwater treatment system. A copy of draft correspondence from Union
County to RSC in regards to this matter is included in Appendix B. Nesco
Environmental reviewed information regarding facilities with NPDES or non -
discharge permits within five miles of RSC using the interactive mapping tool
found on the NCDENR Public Water Supply Section webpage
(http://swar).deh.enr.state.nc.us/Swap app/viewer.htm). Nesco
Environmental identified 24 sites with NPDES permits within five miles of the
RSC site. Nesco Environmental learned that 17 of these 24 sites hold or held
general NPDES permits for stormwater or boiler blow down discharges or its
permit had expired. Of the remaining seven sites, one was not listed as a
NPDES discharger on NCDENR or EPA databases (Pennsylvania House,
Permit No. NCGNE0169), four were operated by private utility companies,
and two were for POTWs operated by Union County. Nesco Environmental
understands that Pennsylvania House no longer operates a facility in Union
County. Nesco Environmental contacted the operators for each of the four
privately operated facilities. Three operators indicated they would be
unwilling to accept the wastestream from RSC. Nesco Environmental
contacted Aqua — North Carolina, the operator of the fourth facility (Country
Wood VWVfP located approximately 4.4 miles from the RSC facility), by
telephone and in writing to inquire if it would be willing to accept the
wastestream from RSC. Nesco Environmental has not received a response
from Aqua — North Carolina. Copies of records of communication with the
operators of these facilities may be found in Appendix B. Nesco
Environmental identified one site with a non -discharge permit within five miles
of the RSC site (Fairfield Plantation VWVTP, Permit No. WQCSD0116).
Nesco Environmental contacted the operator of this facility and was informed
it did not have the capacity to accept the wastestream from RSC. Since
la
4

9
f �N,
Union County has indicated that it will be unwilling to accept the wastestream
from RSC possibly as early as December 31, 2009, discharge to the county's
POTWs identified within five miles of the RSC facility will not be feasible.
Copies of records of communication with the operators of these facilities may
be found in Appendix B. For the aforementioned reasons, Nesco
Environmental concludes neither a private nor public wastewater facility is
within a distance that is reasonable for a connection to be made.
o Land application alternatives, such as individual/community onsite subsurface
systems, drip irrigation, spray irrigation
➢ An investigation into the feasibility of land application was conducted by
Septic Environmental Solutions under the direction of Mr. Kenneth L. Owens
(North Carolina Licensed Soil Scientist No. 1134). The findings of the
investigation are summarized in a report dated February 6, 2009 and titled
Review of Union County Soil Survey Information for Potential Land
Application of Treated Groundwater Radiator Specialty Company, Inc. A
copy of this report is attached as Appendix C. The following conclusion is
/Oftl� stated in this report:
The RSC property located on Radiator Road in Union County,
North Carolina was evaluated in a diligent manner. It is
guaranteed that the work was performed to professional
standards. However, this report represents a professional
opinion, and does not express or imply that small portions of the
RSC tract may be suitable for land application. It is our opinion
however, that insufficient acceptable soil is available to land apply
the proposed 75,000 GPD of treated waste water from the RSC
groundwater remediation system.
An investigation into the feasibility of subsurface discharge into soils and
bedrock was performed by Harmon Environmental, PA under the direction of
Mr. Richard Harmon, P.G. (North Carolina Licensed Geologist No. 649). The
findings of the investigation are summarized in a report dated February 26,
2009 and titled Evaluation of On -Site Soils and Bedrock for Potential
Subsurface Discharge of Treated Groundwater from the Existing Remediation
System, Radiator Specialty Company, Inc. A copy of this report is attached
as Appendix D. The following conclusion is stated in this report:
5

9
/00I'1
Based on the information presented in this evaluation, the shallow
soil depth and variability of the bedrock underlying the RSC
facility, the site does not appear to be conducive for subsurface
disposal of the 75, 000 gallons per day of treated water generated
from the groundwater remediation system.
Based upon the findings of the referenced reports, Nesco Environmental
concludes that land application is not a feasible alternative for the proposed
discharge.
o Wastewater reuse
➢ RSC has extensively evaluated the potential for reuse of the treated
groundwater and found that this option is not feasible. RSC's evaluation of
potential water reuse is summarized in a document dated February 26, 2009
and titled Treated Groundwater Reuse Synopsis. A copy of this document is
included as Appendix E. Based upon the findings contained in this
document, Nesco Environmental concludes that reuse of the treated
groundwater is not feasible.
o Surface water discharge through the NPDES program
➢ The existing groundwater treatment system has a demonstrated track record
with more than 14 of data showing that the system reliably and consistently
removes VOCs from the wastestream to very low or non -detectable levels.
The system was designed to handle 90,000 GPD which is more than the
75,000 GPD that is the maximum anticipated flow at this time. The system
was designed to treat the "worst case" for VOCs dissolved in groundwater
and has been effective in reducing the concentrations of VOCs in
groundwater. As such, the concentrations of VOCs in the system influent
have continually and significantly decreased since remediation began. The
total VOC concentrations for the influent were 12.47 milligrams per liter (mg/1)
on March 27, 1995 and 0.26 mg/I on December 12, 2008. The available data
indicate that the system is capable of reducing the concentrations of VOCs in
the wastestream to levels below likely NPDES permit limits for Class C
waters. Nesco Environmental concludes that surface water discharge
through the NPDES program is a feasible alternative.
0

c
/ONIIN
o Combinations of the aforementioned alternatives
➢ As discussed previously, connection to an existing wastewater facility
(excluding the Union County POTW), land application (surface and
subsurface), and water reuse are not feasible alternatives. Therefore, after
Union County prohibits discharge of the treated groundwater to the POTW, a
combination of the aforementioned alternatives will no longer be a feasible
alternative.
STEP 4 - Evaluate economic feasibility of alternatives
Appendix G includes a prevent value of costs analysis for the one feasible
alternative, discharge to surface water through the NPDES program. Nesco
Environmental followed NCDENR guidelines for the Engineering Alternatives Analysis
including an assumed 20-year project life. Mr. Bob Sledge of NCDENR indicated to
Nesco Environmental that a discount rate of 4.875 percent should be used in the
/Ow*� analysis.
N

2.0 OTHER CONSIDERATIONS
According to guidelines for the Engineering Alternatives Analysis, the
Environmental Management Commission may not act on an application for a new non -
municipal domestic wastewater discharge facility until it has received a written statement
from each city and county government having jurisdiction over any part of the lands on
which the proposed facility and its appurtenances are to be located. The guidelines
indicate that the applicant must submit requests for this information by certified mail,
return -receipt -requested. The guidelines indicate that if the applicant does not receive a
response from one or both of these local government entities within 15 days of receiving
the request, the applicant may submit an application for a new non -municipal domestic
wastewater discharge facility provided it can document that these entities received the
requests and were allowed at least 15 days to respond.
RSC has not received responses from either of the two local government entities
at this time. Appendix H includes copies the request letters and certified mail receipts.
/ORIN These documents demonstrate that RSC provided proper notification to these
government entities and responses were not received within the specified time. If RSC
receives responses from either of these entities, it will forward them to NCDENR.
The proposed discharge is necessary for the continued remediation of
groundwater at the RSC facility. Once Union County prohibits the discharge to the
POTW, there will be no reasonably feasible discharge option with the exception of
discharge to the South Fork of Crooked Creek under the NPDES program. Groundwater
remediation activities at the RSC facility are being conducted in accordance with the
RCRA permit issued for this facility.
N.

9
/0%1�
The analysis contained in this report represents Nesco Environmental's
professional opinions and are based upon the finding of its investigation and research.
These opinions were developed in accordance with currently accepted hydrogeologic
and engineering practices at this time and location. No warranties or guarantees are
intended or implied.
Certain opinions in this report are based upon the work and statements of others,
including but not limited to, laboratory reports and previous environmental investigation
reports. Nesco Environmental assumes this work and these statements to be accurate,
but accepts no responsibility for the quality or accuracy of this work and these
statements.
E

E
0Oft\
4.0 REFERENCES
Aware Environmental, Inc., May 18, 1992, Plans for 8-inch sanitary sewer, Radiator
Specialty Company, Indian Trail, North Carolina, unpublished professional work product,
1 sheet (24-inch by 36-inch).
Aware Environmental, Inc., July 1992, Interim Groundwater Remediation System,
Radiator Specialty Company, Indian Trail, North Carolina, unpublished professional work
product, 7 sheets (24-inch by 36-inch).
Harmon Environmental, P.A., February 26, 2009, Evaluation of On -Site Soils and
Bedrock for Potential Subsurface Discharge of Treated Groundwater from the Existing
Remediation System, Radiator Specialty Company, Inc., unpublished professional
consulting report, 7 pp. with attachments.
North Carolina Department of Environment, Health and Natural Resources. May 1, 1992,
Pretreatment Permit No, 698410001, Radiator Specialty Company, Indian Trail, North
Carolina, 22 pp.
North Carolina Department of Environment and Natural Resources, June 12, 2001,
Conditional Approval Groundwater Corrective Action Program, Radiator Specialty
Company, Indian Trail, North Carolina, 2 pp.
North Carolina Division of Environmental Health, Public Water Supply Section, accessed
February 24, 2009, interactive mapping program for Source Water Assessment and
Protection Program, accessed via the internet at
http://swaP.deh.enr.state.nc.us/Swap app/viewer.htm.
North Carolina Division of Water Quality, June 19, 2007, North Carolina 2006 303(d) List
accessed via the internet at http://h2o.enr.state.nc.us/tmdI/documents/303d Report.pdf
on February 24, 2009.
North Carolina Division of Water Quality, 2008, Pee Dee River Basin Plan - Rocky River
- HUC 03040105, Basinwide planning document, accessed via the internet at
http://h2o.enr.state.nc.us/basinwide/Neuse/2008/documents/RockyR.03040105.pdf on
February 24, 2009.
Radiator Specialty Company, May 27, 1992, Gravity Sewer Extension Application, Indian
Trail, North Carolina, 6 pp.
10

5
/'MN
Radiator Specialty Company, February 26, 2009, Treated Groundwater Reuse Synopsis,
internal corporate document, 2 pp.
Resolve Environmental Services, P.A., January 20, 1997, Groundwater Corrective
Action Program, Radiator Specialty Company, Indian Trail, North Carolina, unpublished
professional report, 10 pp. with attachments.
Resolve Environmental Services, P.A., July 19, 2001, Response to Conditional
Approval, Radiator Specialty Company, Indian Trail, North Carolina, unpublished work
product, 1 pp. with attachments.
Septic Environmental Solutions, February 6, 2009, Review of Union County Soil Survey
Information for Potential Land Application of Treated Groundwater Radiator Specialty
Company, Inc., unpublished professional consulting report, 10 pp. with attachments.
Union County Public Works Department, November 21, 1994, Industrial User Permit No.
UC-1, Radiator Specialty Company, Indian Trail, North Carolina, 14 pp. with
attachments.
/Oft*� Weaver, J. Curtis, February 19, 2009, Low -flow characteristics for South Fork Crooked
Creek near Indian Trail, email correspondence from hydrologist at The United States
Geological Survey, 4 pp.
Weaver, J. Curtis and Jason M. Fine, 2003, Low -Flow Characteristics and Profiles for
the Rocky River in the Yadkin -Pee Dee River Basin, North Carolina, through 2002,
USGS Water -Resources Investigations Report 03-4147, USGS, Raleigh, North
Carolina, 50 pp.
11

FIGURES

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TABLES

TABLE 1
w
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters
03/27/96
04/12/96
06/16/95
07112/96
09/20/96
10/26/95
11/21/95
12/14/96
02/20/96
04/16/96
06/16/96
Acetone
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.22
<0.01
0.47
<0.01
<0.01
Benzene
0.19
0.17
0.15
0.13
<0.005
<0.005
0.11
<0.005
0.11
0.1
<0.005
Carbon tetrachloride
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Chloroethane
<0.01
<0.01
<0.01
<0.01
<0.01
0.32
0.5
0.2
0.34
0.032
0.3
Chloromethane
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2-Chlorotoluene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4-Chlorotoluene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1, 1-Dichloroethane
3.3
2.9
3
2.7
3
2.9
2.4
2.6
2.7
2.5
2.2
1, 2-Dichloroethane
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
1, 1-Dichloroethene
1.1
1.3
1.2
0.91
0.97
0.98
1
0.99
1.1
0.99
1.5
1, 2-Dichloroethene (total)
2
1.7
1.5
1.4
1.4
1.4
1.4
1.4
1.4
1.3
1.1
cis-1, 2-Dichlroethene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
trans-1, 2-Dichloroethene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Dichlorodifluoromethane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Ethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Methylene chloride
3.6
2.8
2.8
2.7
3
2.2
2
3.1
3.2
3
2.6
4-Methyl-2-pentanone
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Naphthalene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Tetrachloroethene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Toluene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
1, 1, 1 Trichooroethane
2.1
2.2
1.8
1.5
1.5
0.72
0.81
2
1.8
1.4
1.3
Trichloroethene
0.18
0.22
0.14
<0.005
0.13
<0.005
<0.005
0.14
0.14
0.12
<0.005
Trichlorofluoromethane
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,2,4-Tdmethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
1,3,5-Timethylbenzene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Vinyl chloride
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Xylenes (total)
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
TOTAL:
12.47
11.29
10.69
9.34
10.00
8.62
8.44
10.43
11.26
9.44
9.00
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 1 of 6 PARTBIINFLUENT.XLS

TABLE 1
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters
06/27/96
07/23/96
08/12/96
09/09/96
10/16/96
11/19/96
12/18/96
01/21/97
02/26/97
03/24/97
04/21/97
Acetone
<0.01
<0.01
<0.01
<0.01
0.18
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Benzene
<0.005
<0.005
<0.005
<0.005
0.06
<0.005
0.052
0.04
<0.005
0.05
<0.005
Carbon tetrachloride
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Chloroethane
0.3
0.39
0.27
0.4
0.44
0.41
0.47
0.3
0.6
0.82
0.74
Chloromethane
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2-Chlorotoluene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4-Chlorotoluene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1, 1-Dichloroethane
2.7
2.6
2.1
2.1
1.9
1.6
1.6
0.94
1.4
1.1
0.98
1, 2-Dichloroethane
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
1, 1-Dichloroethene
0.84
0.75
0.57
0.6
0.65
0.5
0.51
0.33
0.45
0.51
0.52
1, 2-Dichloroethene (total)
1.2
1.1
0.98
1
0.97
0.9
0.87
0.52
0.73
0.74
0.67
cis-1, 2-Dichlroethene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
trans-1, 2-Dichloroethene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Dichlorodifluoromethane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Ethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Methylene chloride
2.6
2.2
1.9
1.8
1.5
1.2
1.3
0.78
1.2
<0.005
0.92
4-Methyl-2-pentanone
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Naphthalene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Tetrachloroethene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Toluene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
1, 1, 1-Trichloroethane
0.84
0.59
0.38
0.25
0.16
0.098
0.091
0.1
0.16
0.099
0.079
Trichloroethene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.036
<0.005
<0.005
<0.005
Trichlorofluoromethane
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,2,4-Trimethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
1,3,5-Trimethylbenzene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Vinyl chloride
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.11
0.077
0.18
0.23
0.32
Xylenes (total)
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
TOTAL:
8.48
7.63
6.20
6.15
6.86
4.71
6.00
3.12
4.72
3.65
4.23
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 2 of 6 PARTBIINFLUENT.XLS

TABLE 1
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters
05/22/97
06/26/97
07/28/97
08/19/97
09/16197
10/30/97
11/26/97
12/08/97
01/13/98
02118/98
03/23/98
Acetone
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.05
Benzene
0.036
<0.005
0.046
<0.005
0.03
0.039
0.037
0.032
0.027
0.034
0.044
Carbon tetrachloride
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Chloroethane
0.47
1
1.5
1.1
0.29
0.55
0.46
0.55
0.34
0.53
0.86
Chloromethane
NA
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
2-Chlorotoluene
NA
0.18
0.14
0.12
NA
0.1
0.096
0.087
0.071
0.11
0.099
4-Chlorotoluene
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.002
1, 1-Dichloroethane
0.66
0.88
0.73
0.54
0.41
0.5
0.49
0.39
0.31
0.44
0.52
1, 2-Dichloroethane
<0.005
<0.005
<0.005
<0.005
<0.005
0.009
0.008
0.007
<0.005
0.008
0.009
1, 1-Dichloroethene
0.32
0.42
0.36
0.24
0.17
0.31
0.3
0.24
0.22
0.26
0.26
1, 2-Dichloroethene (total)
0.47
NA
NA
0.39
0.31
NA
NA
NA
NA
NA
NA
cis-1, 2-Dichlroethene
NA
0.58
0.51
0.37
0.28
0.35
0.34
0.27
0.2
0.34
0.39
trans-1, 2-Dichloroethene
NA
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
NA
<0.005
0.005
0.006
Dichlorodifluoromethane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
Ethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Methylene chloride
0.69
0.82
0.62
0.47
0.39
0.48
0.41
0.32
0.34
0.44
0.56
4-Methyl-2-pentanone
<0.01
<0.01
<0.01
<0.01
<0.01
0.017
0.017
<0.01
<0.01
<0.01
0.016
Naphthalene
NA
<0.005
<0.005
NA
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Tetrachloroethene
<0.005
<0.005
<0.005
<0.005
<0.005
0.011
0.012
0.011
0.009
0.015
0.022
Toluene
<0.005
<0.005
<0.005
<0.005
0.018
0.029
0.028
0.024
0.018
0.026
0.032
1, 1, 1-Trichooroethane
0.049
<0.005
<0.005
<0.005
0.019
0.033
0.033
0.03
0.02
0.031
0.04
Trcchooroethene
<0.005
<0.005
<0.005
<0.005
<0.005
0.02
0.02
0.018
0.015
0.021
0.027
Trichlorofluoromethane
NA
<0.005
<0.005
NA
NA
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
1,2,4-Trimethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
1,3,5-Trimethylbenzene
NA
<0.005
<0.005
NA
NA
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Vinyl chloride
0.28
0.48
0.41
0.32
0.16
0.32
0.29
0.31
0.2
0.36
0.45
Xylenes (total)
<0.005
<0.005
<0.005
<0.005
<0.005
0.021
0.02
0.016
0.012
0.019
0.023
TOTAL:
2.98
4.36
4.32
3.66
2.08
2.79
2.66
2.31
1.78
2.64
3.37
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 3 of 6 PARTBIINFLUENT.XLS

TABLE 1
-
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters
04120/98
05/14/98
06/24/98
12/17/98
06/30199
12/07/99
12/29/99
06/28/00
12/20/00
06/21/01
12/20/01
Acetone
<0.05
<0.05
<0.05
<0.05
0.057
0.1
0.54
<0.05
0.035
<0.05
<0.05
Benzene
0.047
0.043
0.039
0.033
0.055
0.091
0.058
0.045
0.022
0.021
0.018
Carbon tetrachloride
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Chloroethane
0.51
0.73
0.55
0.7
1.2
2.0
2.1
0.86
0.48
0.36
0.68
Chloromethane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
<0.01
<0.01
<0.01
<0.01
2-Chlorotoluene
0.18
0.18
0.099
0.072
0.13
0.29
0.093
0.15
0.054
0.045
0.049
4-Chlorotoluene
0.006
<0.002
<0.002
<0.002
0.007
0.011
0.008
0.008
<0.005
<0.005
<0.005
1, 1-Dichloroethane
0.44
0.44
0.34
0.25
0.39
0.41
0.7
0.26
0.085
0.076
0.085
1, 2-Dichloroethane
0.011
0.01
0.006
0.006
0.011
0.014
0.011
0.009
<0.005
<0.005
<0.005
1, 1-Dichloroethene
0.23
0.26
0.18
0.16
0.25
0.19
0.41
0.24
0.084
0.055
0.048
1, 2-Dichloroethene (total)
NA
NA
0.28
NA
NA
NA
NA
NA
NA
NA
NA
cis-1,2-Dichloroethene
0.33
0.4
NA
0.19
0.27
0.22
0.45
0.29
0.097
0.073
0.054
trans-1, 2-Dichloroethene
0.007
0.007
NA
<0.005
0.008
0.011
0.008
0.006
<0.005
<0.005
<0.005
Dichlorodifluoromethane
<0.01
0.01
<0.01
<0.01
0.015
<0.01
0.022
<0.01
<0.01
<0.01
<0.01
Ethylbenzene
<0.005
<0.005
<0.005
<0.005
0.007
0.012
0.008
0.006
<0.005
<0.005
<0.005
Methylene chloride
0.49
0.61
0.62
0.57
0.62
0.59
1.6
0.78
0.34
0.16
0.26
4-Methyl-2-pentanone
0.028
0.033
0.02
0.019
0.03
0.065
0.03
0.028
0.017
0.014
<0.01
Naphthalene
<0.005
<0.005
<0.005
<0.005
<0.005
0.007
<0.005
<0.005
<0.005
<0.005
<0.005
Tetrachloroethene
0.016
0.019
0.018
0.013
0.022
0.024
0.034
0.016
0.011
0.013
0.0093
Toluene
0.037
0.034
0.03
0.031
0.047
0.064
0.045
0.041
0.021
0.019
0.02
1, 1, 1-Trichloroethane
0.041
0.041
0.022
0.02
0.062
0.028
0.32
0.017
0.008
0.0054
<0.005
Trichloroethene
0.028
0.026
0.021
0.014
0.025
0.021
0.058
0.017
0.01
0.01
0.0067
Trichlorofluoromethane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.015
<0.01
<0.01
<0.01
<0.01
1,2,4-Trimethylbenzene
<0.005
<0.005
<0.005
<0.005
0.007
0.01
0.008
0.006
<0.005
<0.005
<0.005
1,3,5-Trimethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
0.008
0.007
0.007
<0.005
<0.005
<0.005
Vinyl chloride
0.29
0.54
0.29
0.31
0.45
0.67
0.73
0.58
0.29
0.22
0.47
Xylenes (total)
0.024
0.017
0.018
0.019
0.03
0.052
0.034
0.024
0.013
0.013
<0.005
TOTAL:
2.72
3.40
2.63
2.41
3.69
4.89
7.31
3.39
1.67
1.08
1.70
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 4 of 6 PARTBIINFLUENT.XLS

TABLE 1
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters
06/25/02
12/20/02
06/25/03
12/18/03
07/12/04
12/20/04
06/27/06
02/14/06
06/22/06
12/12/06
06/28/07
Acetone
<0.05
<0.05
<0.05
<0.05
<0.05
0.02
<0.01
<0.01
<0.01
<0.01
0.011
Benzene
0.016
0.025
0.0096
<0.005
0.022
0.025
0.012
0.02
0.0072
0.0081
0.016
Carbon tetrachloride
<0.005
<0.005
<0.005
<0.005
<0.005
<0.002
0.0032
<0.002
<0.002
<0.002
<0.002
Chloroethane
0.50
0.360
0.240
0.082
0.29
0.5
0.18
0.27
0.12
0.13
0.26
Chloromethane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.002
<0.002
<0.002
<0.002
<0.002
<0.002
2-Chlorotoluene
0.048
0.053
<0.005
<0.005
0.024
0.035
0.013
0.015
0.006
0.0054
0.013
4-Chlorotoluene
<0.005
<0.005
<0.005
<0.005
<0.005
0.0014
0.00083.1
<0.001
<0.001
<0.001
<0.001
1, 1-Dichloroethane
0.059
0.073
0.046
0.038
0.063
0.09
0.073
0.08
0.059
0.063
0.15
1, 2-Dichloroethane
<0.005
<0.005
<0.005
<0.005
0.003.1
0.0041
0.0022
0.0031
0.0015
0.0013
0.0034
1, 1-Dichloroethene
0.041
0.046
0.035
0.05
0.038
0.055
0.042
0.043
0.029
0.034
0.089
1, 2-Dichloroethene (total)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
cis-1,2-Dichloroethene
0.034
0.037
0.020
0.02
0.05
0.059
0.048
0.049
0.03
0.043
0.11
trans-1, 2-Dichloroethene
<0.005
<0.005
<0.005
<0.005
0.0037.1
0.0044
0.0031
0.0045
0.0025
0.0031
0.0055
Dichlorodifluoromethane
<0.01
<0.01
<0.01
<0.01
0.0049.1
0.011
0.0059
0.0081
0.0049
0.0077
0.0066
Ethylbenzene
<0.005
<0.005
<0.005
<0.005
0.00118.1
0.0017
0.0011
0.0023
0.00056 J
<0.001
0.0011
Methylene chloride
0.081
0.130
0.023
0.0094
0.043
0.058
0.015
0.017
0.0094
0.0079
0.019
4-Methyl-2-pentanone
<0.01
<0.01
<0.01
<0.01
0.0054J
0.0057
0.0044J
0.01
0.002 J
<0.005
0.0044J
Naphthalene
<0.005
<0.005
<0.005
<0.005
0.0028.1
<0.001
0.0016
0.0056
<0.001
0.0019
0.0015
Tetrachloroethene
0.012
0.013
0.015
0.02
0.021
0.018
0.014
0.029
0.017
0.025
0.018
Toluene
0.016
0.022
0.010
<0.005
0.018
0.021
0.011
0.013
0.0045
0.0071
0.014
1, 1, 1-Trichloroethane
<0.005
0.0054
0.0051
<0.005
0.0074
0.0079
0.0055
0.0073
0.0054
0.0053
0.018
Trichloroethene
0.0056
0.0068
0.0063
0.0056
0.01
0.01
0.0084
0.014
0.0072
0.0096
0.0093
Trichlorofluoromethane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.002
0.0016J
<0.002
<0.002
<0.002
0.00071J
1,2,4-Trimethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
0.0012
0.0014
0.0013
<0.001
<0.001
0.00075J
1,3,5-Trimethylbenzene
<0.005
<0.005
<0.005
<0.005
<0.005
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
Vinyl chloride
0.41
0.170
0.060
<0.01
0.12
0.16
0.07
0.06
0.03
0.039
0.11
Xylenes (total)
<0.005
<0.005
0.0075
<0.005
0.008
0.0079
0.0049
0.0083
0.0024
0.0014
0.005
TOTAL:
1.22
0.94
0.48
0.23
0.74
1.10
0.62
0.66
0.34
0.40
0.87
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
J: The analyte was positively identified but the value is estimated below the reporting limit.
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 5 of 6 PARTBIINFLUENT.XLS

TABLE 1 -
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters 12/272007 06/26/08 12/12/08
Acetone
0.0052J
<0.01
<0.01
Benzene
0.011
<0.001
0.0047
Carbon tetrachloride
<0.002
<0.002
<0.002
Chloroethane
0.2
<0.005
0.062
Chloromethane
<0.002
<0.002
<0.002
2-Chlorotoluene
0.0077
<0.001
0.0023
4-Chlorotoluene
<0.001
<0.001
<0.001
1, 1-Dichloroethane
0.13
0.026
0.044
1, 2-Dichloroethane
0.0024
<0.001
0.001
1, 1-Dichloroethene
0.084
0.074
0.037
1, 2-Dichloroethene (total)
NA
NA
NA
cis-1,2-Dichloroethene
0.12
0.0086
0.031
trans-1, 2-Dichloroethene
0.004
0.00058.1
0.0027
Dichlorodifluoromethane
0.0076
0.0064
0.0059
Ethylbenzene
0.00092J
<0.001
<0.001
Methylene chloride
0.01
<0.002
0.0019
4-Methyl-2-pentanone
<0.005
<0.005
<0.005
Naphthalene
<0.001
<0.001
<0.001
Tetrachloroethene
0.02
0.02
0.027
Toluene
0.012
<0.001
0.0028
1, 1, 1-Trichloroethane
0.016
0.0023
0.0031
Trichloroethene
0.0086
0.0045
0.0063
Trichlorofluoromethane
0.00077J
<0.002
<0.002
1,2,4-Trimethylbenzene
0.0011
<0.001
<0.001
1,3,5-Trimethylbenzene
<0.001
<0.001
<0.001
Vinyl chloride
0.11
<0.002
0.022
Xylenes (total)
0.0044
<0.002
<0.002
TOTAL: 0.76 0.14 0.26
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
J: The analyte was positively identified but the value is estimated below the reporting limit.
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 6 of 6 PARTBIINFLUENT.XLS

TABLE 2
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters
Permit
Limits
11/16/94
12/14/94
01/23195
02/15/95
03/27/95
04/11/95
05/15/95
06/28/95
07/12/95
08/09/95
Flow (MGD)
0.09
0.0599
0.0587
0.0311
0.0063
0.0532
0.0571
0.0551
0.01542
0.0561
0.0505
1, 1-Dichloroethane
0.46
<0.001
0.045
<0.001
<0.001
0.014
0.026
0.038
0.006
0.0091
0.01
1, 1-Dichloroethene
0.135
0.02
0.01
<0.001
<0.001
<0.005
0.0039
0.008
<0.005
<0.001
0.0014
1, 2-Dichloroethene (total)
1.382
0.066
0.029
<0.001
<0.001
0.012
0.015
<0.001
<0.005
<0.001
0.0053
Tetrachloroethene
0.044
0.0011
<0.005
0.014
0.007
<0.005
<0.001
0.002
<0.005
<0.001
<0.001
1,1,1-Trichloroethane
1.525
0.065
0.03
0.01
0.004
0.013
0.024
0.03
<0.005
0.0061
0.0068
Trichloroethene
0.085
0.006
<0.005
<0.001
<0.001
<0.005
0.0022
0.0019
<0.005
<0.001
<0.001
Benzene
---
NA
<0.005
NA
NA
<0.005
NA
NA
<0.005
NA
NA
Chloroethane
---
NA
<0.01
NA
NA
<0.01
NA
NA
<0.01
NA
NA
Chloroform
---
NA
<0.005
NA
NA
<0.005
NA
NA
<0.005
NA
NA
Methylene chloride
---
NA
0.064
NA
NA
0.03
NA
NA
0.006
NA
NA
Xylenes (total)
---
NA
<0.005
NA
NA
<0.005
NA
NA
<0.005
NA
NA
Naphthalene
---
NA
<0.01
NA
NA
<0.01
NA
NA
<0.01
NA
NA
1,2-Dichloroethane
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Toluene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Vinyl chloride
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,3,5-Trimethlybenzene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2-Chlorotoluene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Comments:
5/5/92: NCDEM issued Pretreatment Permit 698410001.
10/25/94: Groundwater Recovery System brought On-line. Operates 24 hrs. a day, 7 days a week unless otherwise noted.
1124/95: Pretreatment Permit 698410001 void. Union County Pretreatment Permit UCA effective.
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 1 of 7 PARTBIEFFLUENT.XLS

TABLE 2
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Permit
Parameters
Limits
09/18/95
10/25/95
11/21/95
12/13/95
01/26/96
02/20/96
04/16/96
05/16/96
06/26/96
07123/96
Flow (MGD)
0.09
0.0454
0.0158
0.0564
0.0537
0.009
0.0598
0.06
0.0506
0.0521
0.0487
1, 1-Dichloroethane
1.58
0.0063
0.0023
0.013
<0.005
0.012
0.024
0.014
0.0069
0.0057
0.0097
1, 1-Dichloroethene
0.139
<0.005
0.0021
<0.001
<0.005
NA
NA
NA
NA
<0.005
NA
1, 2-Dichloroethene (total)
0.28
<0.005
0.0011
0.009
0.016
NA
NA
NA
NA
<0.005
NA
Tetrachloroethene
0.096
<0.005
<0.001
<0.001
<0.005
0.0013
<0.001
<0.001
<0.001
<0.005
<0.001
1,1,1-Trichloroethane
1.191
<0.005
0.0033
0.0066
0.009
NA
NA
NA
NA
<0.005
NA
Trichloroethene
1.42
<0.005
<0.001
<0.001
<0.005
0.0025
<0.001
<0.001
<0.001
<0.005
<0.001
Benzene
---
<0.005
NA
NA
<0.005
NA
NA
NA
NA
<0.005
NA
Chloroethane
---
<0.01
NA
NA
<0.01
NA
NA
NA
NA
<0.01
NA
Chloroform
---
<0.005
NA
NA
<0.005
NA
NA
NA
NA
<0.005
NA
Methylene chloride
---
0.0075
NA
NA
0.054
NA
NA
NA
NA
0.0064
NA
Xylenes (total)
---
<0.005
NA
NA
<0.005
NA
NA
NA
NA
<0.005
NA
Naphthalene
--
<0.01
NA
NA
<0.01
NA
NA
NA
NA
<0.01
NA
1,2-Dichloroethane
--
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Toluene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Vinyl chloride
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,3,5-Tdmethlybenzene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2-Chlorotoluene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Comments:
11 /3/95: Union County Public Works reduced frequency of sampling.
March '96: Groundwater Recovery System down due to a request by Union County Public Works.
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 2 of 7 PARTBIEFFLUENT.XLS

TABLE 2
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Permit
Parameters
Limits
08/12/96
09/09/96
10/16/96
11/19/96
12/18/96
01/21/97
02/25/97
03/24/97
04/21197
05/22/97
Flow (MGD)
0.09
0.0473
0.0454
0.0533
0.0464
0.0426
0.0481
0.0415
0.0427
0.0434
0.0469
1, 1-Dichloroethane
1.58
NA
0.0063
0.018
0.062
0.064
0.069
0.16
0.088
0.052
0.041
1, 1-Dichloroethene
0.139
NA
<0.001
NA
NA
0.0071
NA
NA
0.014
NA
NA
1, 2-Dichloroethene (total)
0.28
NA
<0.001
NA
NA
0.046
NA
NA
<0.001
NA
NA
Tetrachloroethene
0.096
<0.001
<0.001
<0.001
<0.001
<0.005
<0.001
<0.005
<0.001
<0.001
<0.001
1, 1, 1 -Trichloroethane
1.191
NA
<0.001
NA
NA
<0.005
NA
NA
<0.001
NA
NA
Trichloroethene
1.42
<0.001
<0.001
<0.001
<0.001
<0.005
<0.001
0.005
<0.001
0.002
<0.001
Benzene
---
NA
NA
NA
NA
<0.005
NA
NA
NA
NA
NA
Chloroethane
---
NA
NA
NA
NA
0.011
NA
NA
NA
NA
NA
Chloroform
---
NA
NA
NA
NA
<0.005
NA
NA
NA
NA
NA
Methylene chloride
---
NA
NA
NA
NA
0.082
NA
NA
NA
NA
NA
Xylenes (total)
---
NA
NA
NA
NA
<0.005
NA
NA
NA
NA
NA
Naphthalene
--
NA
NA
NA
NA
<0.01
NA
NA
NA
NA
NA
1,2-Dichloroethane
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Toluene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Vinyl chloride
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,3,5-Trimethlybenzene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2-Chlorotoluene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
REVISED 02/17/09
Data provided by Radiator Specialty Company
Page 3 of 7
PARTBIEFFLUENT.XLS

TABLE 2
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters
Permit
Limits
06/26/97
07/28/97
08/19/97
09/15/97
10/30/97
11/25/97
12/08/97
01/13/98
02/18/98
03/23/98
Flow (MGD)
0.09
0.0457
0.046
0.0438
0.0496
0.0518
0.0522
0.053
0.0542
0.0502
0.0469
1, 1-Dichloroethane
1.58
0.13
0.058
0.11
0.12
0.12
0.17
0.2
0.16
0.15
0.2
1, 1-Dichloroethene
0.139
0.018
NA
NA
0.027
NA
NA
0.025
NA
NA
0.072
1, 2-Dichloroethene (total)
0.28
0.12
NA
NA
<0.001
NA
NA
0.17
NA
NA
0.21
Tetrachloroethene
0.096
<0.005
<0.001
<0.001
<0.001
0.001
0.001
<0.005
0.002
0.003
0.006
1,1,1-Trichloroethane
1.191
<0.005
NA
NA
<0.001
NA
NA
0.005
NA
NA
0.015
Trcchloroethene
1.42
<0.005
<0.001
<0.001
<0.001
0.006
0.008
0.005
0.006
0.007
0.011
Benzene
---
0.0058
NA
NA
NA
NA
NA
0.008
NA
NA
NA
Chloroethane
---
0.06
NA
NA
NA
NA
NA
0.1
NA
NA
NA
Chloroform
---
<0.005
NA
NA
NA
NA
NA
<0.005
NA
NA
NA
Methylene chloride
---
0.19
NA
NA
NA
NA
NA
0.24
NA
NA
NA
Xylenes (total)
---
<0.005
NA
NA
NA
NA
NA
<0.005
NA
NA
NA
Naphthalene
---
<0.01
NA
NA
NA
NA
NA
<0.01
NA
NA
NA
1,2-Dichloroethane
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Toluene
--
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Vinyl chloride
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,3,5-Trimethlybenzene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2-Chlorotoluene
---
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 4 of 7 PARTBIEFFLUENT.XLS

TABLE 2
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Permit
Parameters Limits 04/20/98 05/14/98 06/24/98 12/17/98 06/30/99 12/07/99 12/29/99 06/28/00 12/20/00 06/21/01
Flow (MGD)
0.09
0.0445
0.0448
0.0456
0.0475
0.0452
0.06
0.052
0.0531
0.0448
0.0405
1, 1-Dichloroethane
1.58
0.19
0.14
<0.005
0.1
0.32
<0.005
<0.005
<0.005
<0.005
<0.005
1, 1-Dichloroethene
0.139
NA
NA
0.073
0.053
<0.005
<0.005
<0.005
<0.005
<0.005
1, 2-Dichloroethene (total)
0.28
NA
NA
0.2
0.075
0.22
<0.005
<0.005
<0.005
<0.005
<0.005
Tetrachloroethene
0.096
0.007
0.007
0.009
0.005
0.008
<0.005
<0.005
<0.005
<0.005
<0.005
1,1,1-Trichloroethane
1.191
NA
NA
0.009
<0.005
0.036
<0.005
<0.005
<0.005
<0.005
<0.005
Trichloroethene
1.42
0.012
0.01
0.012
0.005
0.013
<0.005
<0.005
<0.005
<0.005
<0.005
Benzene
-
NA
NA
0.018
0.012
0.035
<0.005
<0.005
<0.005
<0.005
<0.005
Chloroethane
-
NA
NA
0.3
0.17
0.91
<0.01
<0.01
<0.01
<0.01
<0.01
Chloroform
-
NA
NA
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Methylene chloride
-
NA
NA
0.53
0.085
0.59
<0.01
<0.005
<0.005
<0.005
<0.005
Xylenes (total)
-
NA
NA
<0.005
<0.005
0.014
<0.01
<0.005
<0.005
<0.01
<0.01
Naphthalene
-
NA
NA
<0.01
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
1,2-Dichloroethane
-
NA
NA
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Toluene
--
NA
NA
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
Vinyl chloride
-
NA
NA
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
1,3,5-Trimethlybenzene
-
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2-Chlorotoluene
-
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Comments:
7/16/98: Union County Public Works reduced sampling frequency.
11116/99: Replaced Packing Media in air stripping tower.
NOTE: Concentrations are in mg/L.
NA'. Not Analyzed
LENceeded Permit Limit___
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 5 of 7 PARTB\EFFLUENT.XLS

TABLE 2
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters
Permit
Limits
12/20/01
06/26/02
12/20/02
06/25/03
12/18/03
07/12/04
12/20/04
06/27/05
02/14/06
06/22/06
Flow (MGD)
0.09
0.0488
0.0404
0.0643
0.0635
0.0604
0.058
0.0563
0.0538
0.0447
0.0635
1, 1-Dichloroethane
1.58
<0.005
<0.005
0.00081
<0.0005
0.0016
0.00061
0.0018
0.0086
0.017
0.015
1, 1-Dichloroethene
0.139
<0.005
<0.005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
0.0012
0.0028
0.0036
1, 2-Dichloroethene (total)
0.28
<0.005
<0.005
0.0012
<0.0005
0.0035
<0.0005
0.0026
0.0056
0.01152
0.011
Tetrachloroethene
0.096
<0.005
<0.005
<0.0005
<0.0005
<0.0005
0.00073
<0.0005
0.0007
0.0026
0.0031
1, 1, 1 -Trichloroethane
1.191
<0.005
<0.005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
0.0012
<0.0005
Trichloroethene
1.42
<0.005
<0.005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
0.00088
0.0017
0.0014
Benzene
---
<0.005
<0.005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
0.00076
0.0035
0.0014
Chloroethane
---
<0.01
<0.01
0.001
<0.0005
<0.0005
<0.0005
0.005
0.0091
0.025
0.016
Chloroform
---
<0.005
<0.005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
Methylene chloride
---
<0.005
<0.005
0.0044
<0.002
<0.002
0.0023
0.0035
0.0031
0.0062
0.004
Xylenes (total)
---
<0.005
<0.01
<0.0005
<0.0005
<0.0005
<0.0005
<0.001
<0.001
0.0013
<0.001
Naphthalene
---
<0.005
<0.005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
1,2-Dichloroethane
---
<0.005
<0.005
<0.005
<0.0005
<0.0005
<0.0005
<0.0005
0.00044J
<0.0005
<0.0005
Toluene
--
<0.005
<0.005
<0.005
<0.0005
<0.0005
<0.0005
<0.0005
0.00053
<0.0005
0.0011
Vinyl chloride
---
<0.01
<0.01
<0.01
<0.0005
<0.0005
<0.0005
<0.0005
0.0018
<0.0005
<0.0005
1,3,5-Trimethlybenzene
---
NA
NA
NA
<0.0005
<0.0005
<0.0005
<0.0005
0.0013
0.0021
0.00097
2-Chlorotoluene
---
NA
NA
NA
<0.0005
<0.0005
<0.0005
<0.0005
0.00065
0.0033
0.0032
Comments:
12/12/02: Union County and Radiator Specialty Company reached an agreement to not renew RSC's Pretreatment Permit because treated
groundwater does not meet the definition of "Industrial Wastewater". The Permit Limits have been changed to "Safe Concentrations".
6/27/05: Changed Analytical Method to SM6230D to report results to below the groundwater protection standard.
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 6 of 7 PARTBIEFFLUENT.XLS

i
TABLE 2
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Safe
Parameters Conc. 12/12/06 06/28/07 12/27/07 06/26/08 12/12/08
Flow (MGD)
0.09
0.0589
0.0588
0.05497
0.0606
0.0582
1, 1 -Dichloro ethane
1.58
0.018
0.044
0.029
0.0035
0.015
1, 1-Dichloroethene
0.139
0.0034
0.0075
0.0037
0.00069
0.0015
1, 2-Dichloroethene (total)
0.28
0.01261
0.0393
0.02752
0.0022
0.0074
Tetrachloroethene
0.096
0.003
0.0029
0.0018
0.0018
0.0021
1,1,1-Trichloroethane
1.191
<0.0005
0.0037
0.0012
<0.0005
<0.0005
Trichloroethene
1.42
0.0021
0.0021
0.0012
0.00071
0.00073
Benzene
---
0.00093
0.003
0.0011
<0.0005
<0.0005
Chloroethane
---
0.011
0.037
0.02
<0.0005
0.0081
Chloroform
---
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
Methylene chloride
--
0.0033
0.0077
0.0034
<0.002
0.002
Xylenes (total)
---
<0.001
<0.001
<0.001
<0.001
<0.001
Naphthalene
---
<0.0005
<0.001
<0.001
<0.001
<0.001
1,2-Dichloroethane
---
0.00097
0.00088
0.00093
<0.0005
<0.0005
1,3,5-Trimethlybenzene
---
<0.0005
<0.0005
<0.0005
<0.0005
<0.0005
2-Chlorotoluene
---
<0.0005
0.0024
0.00087
<0.0005
0.00081
Toluene
---
0.00076
0.002
0.00093
<0.0005
<0.0005
Vinyl chloride
---
0.0015
0.0082
0.0027
<0.0005
<0.0005
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
J: Estimated valaue between the Reporting Limit and the MDL
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 7 of 7 PARTBIEFFLUENT.XLS

/000�
TABLE 3
RECENT INFLUENT AND EFFLUENT CONCENTRATIONS AND CALCULATED REMOVAL EFFICIENCIES
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Target Compound
2/12/2009
Influent
03/25/2009
Effluent
Removal
Efficiency
1, 1-Dichloroethane
0.065
<0.005
> or = 92.31 %
1, 1-Dichloroethene
0.042
<0.005
> or = 88.10%
Tetrachloroethene
0.027
<0.005
> or = 81.48%
Trichloroethene
0.0063
<0.005
> or = 20.63%
Benzene
0.0067
<0.005
> or = 25.37%
Chloroethane
0.110
<0.005
> or = 95.45%
Vinyl chloride
0.030
<0.005
> or = 83.33%
Totals
0.287
<0.035
> or = 87.80%
Values reported as "less than" were assumed to be zero for the purpose of
calculating totals.
Concentrations reported as milligrams per liter.
Data provided by Radiator Specialty Company.
Page 1 of 1

APPENDICES

APPENDIX A
DESCRIPTION OF LOW -FLOW CHARACTERISTICS FOR SOUTH FORK
CROOKED CREEK NEAR INDIAN TRAIL PREPARED BY J. CURTIS WEAVER
OF THE UNITED STATES GEOLOGICAL SURVEY - FEBRUARY 19, 2009

Page I of
n
Joseph P. Nestor
From: John C Weaver [e-mail]]
Sent: Thursday, February 19, 2009 9:27 AM
To: Joseph P. Nestor
Cc: Richard Harmon; Curtis Weaver; Jeanne C Robbins
Subject: Low -flow characteristics for South Fork Crooked Creek near Indian Trail... Re: Stream Flow
Statistics - South Fork Crooked Creek
I
imUSGS
science for a changing world
U.S. Geological Survey North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, North Carolina 27607
00%k Date: February 18, 2009
To: Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
P.O. Box 78222
Charlotte, North Carolina 28271
Dear Mr. Nestor,
In response to your inquiry for low -flow characteristics (7Q10, 30Q2) at a location on South Fork Crooked Creek
near Indian Trail in Union County, the following information is provided:
A check of the low -flow files here at the USGS North Carolina Water Science Center indicates a previous
determination of low -flow characteristics for your point of interest based on the location coordinates provided via
your email dated January 28, 2009 (station id 0212475140, drainage area 2.20 sgmi). Determined in October
1985, the 7Q10 discharge was estimated at zero flow. However, no estimate of 30Q2 discharge was provided.
No USGS records of discharge are known to exist for your point of interest. The only known USGS records of
discharge for South Fork Crooked Creek is at a partial -record site (station id 02124761, drainage area 18.4 sgmi,
located at Secondary Road 1004, 0.6 mile upstream from mouth) consisting of 2 miscellaneous measurements
(both at zero flow) obtained in the 1961-62 water years.
Where no or insufficient data is available for a low -flow analysis, a determination of low -flow characteristics is
based on assessment of low -flow yields (expressed as flow per square mile drainage area, or cfsm) at nearby
locations where such statistics have previously been determined. The low -flow characteristics that are provided
.� have been computed by correlating the runoff characteristics of a nearby stream in vicinity of the request site.
Please note that the flow estimates do not account for the presence of any diversions or regulation, present or
2/19/2009

Page 2 of 4
/'w"\ future, which may occur upstream of the request site.
Previously published low -flow information for streams in your area of interest...
The most recent low -flow information published for most streams in Union County is in a basinwide low -flow
report completed in 2003. It is USGS Water -Resources Investigations Report 03-4147, "Low -Flow Characteristics
and Profiles for the Rocky River in the Yadkin -Pee Dee River Basin, North Carolina, through 2002" (Weaver and
Fine, 2003). An online version of the report is available through http;H )ubs.usas.aov/wri/wri034.147/. The report
provides the low -flow characteristics (based on data through 2002) for continuous -record gaging stations and
partial -record sites within the Rocky River basin. The report also provides low -flow discharge profiles (7Q10,
30Q2, winter 7Q10, and 7Q2) for the Rocky River from its headwaters in Mecklenburg County to its mouth.
Determination of low -flow characteristics...
(1) In Tables 5 and 6 of the above -referenced report, there are two nearby USGS sites for which low -flow
characteristics were published:
• partial -record site on North Fork Crooked Creek near Fairview (station id 02124745, drainage area 16
sgmi), record of 16 miscellaneous measurements (including 1 at zero flow) obtained during the 1961-62,
1965-69, and 1971 water years
• continuous -record station on Goose Creek at Fairview (02124692, drainage area 24.0 sgmi), period of
record since November 1999
Expressing these estimates as low -flow yields (again, flow per square mile of drainage area, or cfsm) provides
some indication of the yield ranges that potentially could be applicable to your location. Based on consideration
/Ok,N of the published values, the 7Q10 low -flow yields are 0 and 0.0125 cfsm, and the 30Q2 low -flow yields are 0.03
and 0.06 cfsm.
(2) Considering the above information, please be aware of the following: The data provided in the above
referenced report are based on periods of record ending during or in advance of the drought conditions that have
occurred since publication of the report. In some North Carolina basins, the low -flow conditions observed during
the 1998-2002 and current (2007-09) droughts have resulted in lower low -flow statistics. No formal statewide
investigation has been completed to document the changes in low -flow statistics since the drought. However,
where updated analyses have been completed for selected stations, the changes in pre -drought versus updated
7Q10 discharges have shown varying percentage changes of decline.
(3) At the nearby continuous -record station on Goose Creek at Fairview (operated since November 1999), an
update of the low -flow analyses for this site indicates the 7Q10 is zero flow and the 30Q2 discharge is now about
0.8 cfs (compared to the previously published value of 1.4 cfs). The updated 30Q2 discharge is equivalent to a
low -flow yield of about 0.03 cfsm, which is consistent with the 30Q2 yield noted above for the North Fork Crooked
Creek site. This updated analysis is based on records in the 2000-07 climatic years, which is considered short-
term record for the purposes of determining low -flow characteristics at continuous -record gaging stations.
However, the results of the updated analysis for this gage confirm observation of declining low -flow
characteristics in response to the low flow conditions that have been observed since the late 1990's.
Notes:
(a) The climatic year is the standard annual period used for low -flow analyses at continuous -record gaging
stations. It runs from April 1 through March 31 and is designated by the year in which the period begins. For
example, the 2007 climatic year is from April 1, 2007, through March 31, 2008.
(b) The water year is the standard annual period used for collection and publication of streamflow records. It runs
from October 1 through September 30 and is designated by the year in which the period ends. For example, the
2007 climatic year is from October 1, 2006, through September 30, 2007.
Putting together the above pieces of information...
2/19/2009

Page 3 of 4
/1001\ Applying the drainage area at your point of interest (2.20 sgmi) to the above yield values (in items #1 and #3)
results in a 7Q10 discharge that is zero flow. The 30Q2 discharge is estimated to be about 0.07 cfs.
A charge of $250.00 for accessing and processing information has been assessed to partially offset these costs.
An electronic invoice covering processing costs for these data is attached to this email as a .PDF file.
Instructions for sending your payment are shown on the invoice.
This information is considered preliminary and subject to revision pending further analysis as further data were to
become available, and is made available through our cooperative program of water -resources investigations with
the North Carolina Department of Environment and Natural Resources.
Hope this information is helpful. If you have any questions regarding this information, please contact me at the
phone number listed below.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Telephone: [phone] Fax: [phone]
E-mail address -- [e-mail]
Internet address -- httpalnc.water..usgs...go_v._/
"Joseph P. Nestor" <[e-mail]>
To <[e-mail]>
01/28/2009 10:10 AM
cc "Richard Harmon" <[e-mail]>
Subject Stream Flow Statistics - South Fork Crooked Creek
Mr. Weaver:
Thank you for returning my telephone call.
As we discussed, my firm, Nesco Environmental, PLLC, has been requested by another consulting firm to prepare
a proposal to assist it in obtaining an NPDES permit for Radiator Specialty Company in Indian Trail. Guidance
from the NCDENR indicates that as part of the process, the applicant must obtain stream flow statistics from the
f USGS. From our conversation, I understand that the USGS normally charges $250.00 for providing such stream
flow statistics.
2/19/2009

Page 4 of 4
From our conversation, I understand that there is a published report regarding stream flow data in the Rocky
River Basin from which I might obtain the necessary data without incurring the $250 fee. I understand that you
will forward me the link. Please note that at this time, I do not have the authorization to expend funds. I expect to
have authorization within the next several days.
The approximate location of the proposed discharge into the South Fork Crooked Creek is 35 03' 58" N 80 39'
16" W. A map is also attached which shows the facility and South Fork Crooked Creek.
Thank you for your help on this matter
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]..rr..com
[attachment "EDITEDPERMITMAP2007 for Joe.pdf'deleted by John C Weaver/WRD/USGS/DOI]
2/19/2009

APPENDIX B
RECORDS OF COMMUNICATION

UNION COUNTY PUBLIC WORKS
Scott Huneycutt, Interim Director
March 18, 2009
Mr. Stewart A. Kerkhoff
Environmental Supervisor
Radiator Specialty Company
600 Radiator Road
Indian Trail, NC 28079
Subject: Discontinuance of Remediated Groundwater Discharge Order
Radiator Specialty Company
Dear Mr. Kerkhoff:
Union County Public Works (UCPW) has allowed Radiator Specialty to discharge up to 90,000
gallons per day of remediated groundwater into the sanitary sewer. The water is ultimately
handled at the Crooked Creek Wastewater Treatment Plant (WWTP). Over the past years
demand for sewer capacity in the Crooked Creek WWTP service area has started to tax the
rated capacity of the WWTP. Removal of Radiator's discharge from the WWTP would provide a
00*41 fairly significant decreased "base flow" which in turn may allow for new and/or expanded
industrial commercial flow within the service area. Expansion of the WWTP is not an option at
this time. Please accept this letter as notice that, effective December 31, 2009, Radiator
Specialty Company must find and alternate disposal option for the remediated groundwater and
cease discharge of the same to the sanitary sewer system. This discontinuance order is for
remediated groundwater only and does not apply to process or domestic wastewater.
UCPW is aware that Radiator Specialty has been investigating alternate disposal options for the
past several years. These options include internal uses as well as off -site options. It is
understood that these options are not viable either due to cost or due to the high the volume of
water needing to be disposed of; or a combination of the two. If UCPW can assist Radiator in
anyway with an alternate disposal method other than discharge to the sanitary sewer, please do
not hesitate to contact me and I will be glad to discuss it with you.
I think you will agree that UCPW and Radiator Specialty have enjoyed a good working
relationship over the past years. UCPW very much wants to continue this relationship. As
stated above if UCPW can assist with evaluating options, just let me know. If additional
discussion is required on these matters, please feel free to contact me at 704 296-4215 or
mtve(&co.union.nc.us .
Respectfully,
Mark E. Tye
Assistant Public Works Director
CC: Scott Huneycutt, UCPW Interim Director
Mike Garbark, Assistant Director for Engineering
500 North Main St., Suite 500 • Monroe, NC 28112-4730 • Phone: [phone] • Fax: [phone]

Pagel of 2
Ila
Joseph P. Nestor
From: Joseph P. Nestor [[e-mail]]
Sent: Tuesday, February 24, 2009 4:02 PM
To:'[e-mail]. nc.us'; '[e-mail]'
Subject: Engineering Alternatives Evaluation for NPDES Permitting
Ms. Reid:
I am trying to contact the Dianne Reid who works in basinwide planning at NCDENR. Two Dianne
Reids were list on the NC GOV webpage. I apologize if I have sent this email to you and you are not
that person.
I am assisting a client in obtaining a NPDES permit for the discharge of treated ground water as part of
a RCRA cleanup. The NPDES permitting process requires that an Engineering Alternatives Evaluation
(EAA) be performed. NCDENR guidance indicates that the proponent must first determine if the
discharge may be allowed. The guidance indicates that the proponent should determine if there are
any limitations as a result of basinwide planning that would prohibit a proposed discharge. Specifically
the guidance states:
Basinwide Water Quality Plans. These basin -specific plans list NPDES permitting strategies that
may limit wastewater discharges to particular streams within the basin due to lack of stream
assimilative capacity, etc. Basin plans are available on the DWQ website, or you may contact the
DWQ Basinwide Planning Unit at 919-807-6300.
The proposed discharge is into the South Fork Crooked Creek at approximately 35 03' 58" N 80 39'
16" W. This is in Indian Trail in Union County. The discharge point lies within the Rocky River Basin
within the Yadkin River Basin.
I have downloaded the 2008 Rocky River Basinwide Plan Report from
http. //h2o.._enr.state._nc. us/basi.nw de..Neu..se/2008ldocu.merits/.R.oc_ky..R.030401„05,. d.1
The South Fork Crooked Creek is listed as impaired in this document, but I did not find anything in the
document to indicate that the proposed discharge would be prohibited as a result of basinwide
planning. I am certainly not an expert on the basinwide planning process, and would appreciate a
knowledgeable person from NCDENR confirming my understanding. Would you or another member
of your staff help me on this matter, please?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
2/24/2009

Page 2 of 2
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
nescoenv a�carolina.rr.com
2/24/2009

Page 1 of 2
?OWN
Joseph P. Nestor
From: Joseph P. Nestor [[e-mail]]
Sent: Tuesday, February 24, 2009 3:42 PM
To: '[e-mail]'
Subject: Engineering Alternatives Evaluation for NPDES Permitting
Ms. Stecker:
I am assisting a client in obtaining a NPDES permit for the discharge of treated ground water as part of
a RCRA cleanup. The NPDES permitting process requires that an Engineering Alternatives Evaluation
(EAA) be performed. NCDENR guidance indicates that the proponent must first determine if the
discharge may be allowed. The guidance indicates that the proponent should determine if there are
any limitations as a result of impaired waters and TMDLs that would prohibit a proposed discharge.
Specifically the guidance states:
Impaired waters and TMDLs. Certain waterbodies listed as impaired on the 303(d) list and/or
subject to impending TMDLs may have wastewater discharge restrictions. The list of 303(d)
impaired waters is located on the DWQ website, or you may contact the DWQ Modeling/TMDL
Unit at 919-807-6300.
The proposed discharge is into the South Fork Crooked Creek at approximately 35 03' 58" N 80 39'
16" W. This is in Indian Trail in Union County. The discharge point lies within the Rocky River Basin
within the Yadkin River Basin.
I have downloaded the a document from NCDENR which lists impaired waters
(http://h2o.enr.state.nc.us/tmdI/­`documents/"303d_Repp.q,pdo.
As I read this document, I understand that South Fork Crooked Creek from the source to SR 1515
(which is within the reach of the stream where the discharge is proposed) is listed as impaired
because of "Impaired biological integrity". I further understand that the potential sources of this
impairment are listed as Agriculture, construction, and Urban Runoff/Storm Sewers.
Can you please let me know if the DWQ Modeling/TMDL Unit would prohibit the proposed discharge
as a result of Impaired waters and TMDLs?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
nescoenv@carol i n.a._rr. com
Joseph P. Nestor, P.G., P.E.
2/24/2009

Page 2 of 2
(jwst� Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
nescoenv@carolina._rr.com
2/24/2009

Page 1 of 1
,IMN
Joseph P. Nestor
From: Joseph P. Nestor [[e-mail]]
Sent: Tuesday, February 24, 2009 3:56 PM
To: '[e-mail]'
Subject: Engineering Alternatives Evaluation for NPDES Permitting
Ms. Deaton:
I am assisting a client in obtaining a NPDES permit for the discharge of treated ground water as part of
a RCRA cleanup. The NPDES permitting process requires that an Engineering Alternatives Evaluation
(EAA) be performed. NCDENR guidance indicates that the proponent must first determine if the
discharge may be allowed. The guidance indicates that the proponent should determine if there are
any limitations as a result of the presence of endangered species. Specifically the guidance states:
Presence of Endangered Species. If endangered species are present in the proposed
discharge location, there may be wastewater discharge restrictions. Endangered species
information may be included in the Basinwide Water Quality Plan, or you may contact the U. S.
Fish and Wildlife Service (919-856-4520), N. C. Wildlife Resources Commission (919-733-
3633), or the N.C. Natural Heritage Program (919-733-7701).
The proposed discharge is into the South Fork Crooked Creek at approximately 35 03' 58" N 80 39'
16" W. This is in Indian Trail in Union County. The discharge point lies within the Rocky River Basin
within the Yadkin River Basin.
I have downloaded the NCDENR 2008 Rocky River Basinwide Plan Report from
bttpalh2o..enr.state_nc..us/basinwide/.Neuse/20081documents/RocKyR -O04Q105.pdf.
I did not see any reference to endangered species for the South Fork Crooked Creek in this document
and presume that your agency would not prohibit or restrict he discharge as a result of endangered
species. I am certainly not an expert on endangered species, and would appreciate a knowledgeable
person from your agency confirming my understanding. Would you or another member of your staff
help me on this matter, please?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]...rr.com
2/24/2009

Page 1 of 2
Joseph P. Nestor
From: Rick Harmon [[e-mail]]
Sent: Thursday, February 26, 2009 1:05 PM
To: Joseph P. Nestor
Subject: Re: NPDES Permit No. NCO087858 - Equipment and Supply
Mr. Nestor:
The NPDES Permit for the Equipment & Supply, Inc. facility does not have the capacity to support the
additional volume of wastewater discussed in your attached e-mail. As a result we must respectfully
decline accepting your waste stream into this permited outfall.
Richard L. Harmon, P.G.
Harmon Environmental, PA
ORC for Equipment @ Supply, Inc.
From: Joseph P. Nestor <[e-mail]>
To: Rick Harmon <[e-mail]>
Sent: Thursday, February 26, 2009 12:39:47 PM
Subject: NPDES Permit No. NCO087858 - Equipment and Supply
Dear Mr. Harmon:
I am assisting a client in obtaining a (National Pollutant Discharge Elimination System) NPDES permit for the
discharge of treated ground water as part of cleanup project involving solvent -impacted ground water. The
NPDES permitting process requires that an Engineering Alternatives Evaluation (EAA) be performed. Guidance
from the North Carolina Department of Environment and Natural Resources (NCDENR) indicates that the
proponent must determine if other existing wastewater facilities within 5 miles of the proposed discharge have the
capacity and would be willing to accept the discharge.
Nesco Environmental has identified the Union County remediation site (AKA Equipment & Supply company)
(NPDES Permit No. NC0087858) as being within 5 miles of the proposed discharge. Nesco Environmental
understands that you are the operator of responsible charge for this facility.
The flow from the proposed discharge is anticipated to be up to 75,000 GPD. The expected concentrations of
solvents remaining in the treated discharge are as follows:
Dichloroethane
0.015
1, 1-
Dichloroethene
0.0015
1, 2-Dichloroethene (total)
0.0074
Tetrachloroethene
0.0021
Trichloroethene
0.00073
Chloroethane
0.0081
Chloroform
0.002
1,3,5-Trimethlybenzene
0.00081
Vinyl chloride
0.039
Units are
milligrams per liter
2/26/2009

Page 2 of 2
Does this facility have the capacity to accept this wastestream?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte , North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
nescoenv carolina.rr.
2/26/2009

Page 1 of 2
Joseph P. Nestor
From: Martin Lashua [[e-mail]]
Sent: Thursday, February 26, 2009 12:03 PM
To: [e-mail]
Cc: Linda Matthews; Tony Konsul; Mark Haver
Subject: RE: HEMBY ACRES WWTP, IDLEWILD RD, INDIAN TRAIL, NC
Dear Mr. Nestor,
I am in receipt of the below email.
Regrettably we do not have any uncommitted capacity remaining in our Hemby Acres facility and would be unable
to accommodate either the flow or the industrial nature of this wastestream.
Thank you for contacting us and I regret we could not be of service.
Utilities. Inc
--
Martin Lashua
Regional Director
Phone [phone] x 216
Fax [phone]
email mjlashua@uiwatercom
`Please consider the environment before printing this email
From: Joseph P. Nestor [mailto:[e-mail]]
Sent: Thursday, February 26, 2009 11:29 AM
To: CSR Charlotte
Subject: HEMBY ACRES WWTP, IDLEWILD RD, INDIAN TRAIL, NC
Dear Sir/Madame:
I am assisting a client in obtaining a (National Pollutant Discharge Elimination System) NPDES permit for the
discharge of treated ground water as part of cleanup project involving solvent -impacted ground water. The
NPDES permitting process requires that an Engineering Alternatives Evaluation (EAA) be performed. Guidance
from the North Carolina Department of Environment and Natural Resources (NCDENR) indicates that the
proponent must determine if other existing wastewater facilities within 5 miles of the proposed discharge would be
willing to accept the discharge.
Nesco Environmental has identified the HEMBY ACRES WWTP, (NPDES Permit No. NC0035041) as being
within 5 miles of the proposed discharge. Nesco Environmental has identified your company as the operator of
this facility through public records.
The flow from the proposed discharge is anticipated to be up to 75,000 GPD. The expected concentrations of
solvents remaining in the treated discharge are as follows:
14M� 1, 1-
Dichloroethane 0.015
2/26/2009

Page 2 of 2
1-
Dichloroethene
0.0015
1, 2-Dichloroethene (total)
0.0074
Tetrachloroethene
0.0021
Trichloroethene
0.00073
Chloroethane
0.0081
Chloroform
0.002
1,3,5-Trimethlybenzene
0.00081
Vinyl chloride
0.039
Units are
milligrams per liter
Would your company be willing to accept this additional wastestrearn at the HEMBY ACRES WWTP?
Also for your information, I left a telephone message with your operations department regards to this inquiry at
[phone] ext 504. If there is another contact to which I should address this inquiry, please let me know.
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
nescoen_v_aOca_rolina.. rr.
2/26/2009

,a� Joseph P. Nestor
Subject: Hemby Acres VW TP
Entry Type: Phone call
Start: Thu 2/26/2009 11:21 AM
End: Thu 2/26/2009 11:26 AM
Duration: 5 minutes
I called Carolina Water Services (Now Utilities, Inc) at 704- 525-7990. 1 left a mssg in operations dept voice mail
requesting that they call me about Hemby Acres VW TP
la

/041� Joseph P. Nestor
Subject: Fairfield Plantation WVVrP
Entry Type: Phone call
Start: Thu 2/26/2009 12:21 PM
End: Thu 2/26/2009 12:26 PM
Duration: 5 minutes
I called Jerry Sulivan of the Goose Creek Utility Company at 704-882-2319 regarding the Fairfield Plantation
WWTP (NC0034762) and whetehrr it would be willing to accept another waste stream. I told him it was a
ground water cleanup project invloving solvents and the estimated flow rate was 75,000 GPD. He said his
facility could not accept this waste stream for NPDES discharge or spray irrigation (Permit No. WQCSD0116)
due to capacity limitations.

Environmental
February 28, 2009
Mr. Thomas Roberts
President
Aqua — North Carolina
202 Mackenan Court
Cary, North Carolina 27811
Re: Country Wood WWfP
NPDES Permit No. NCO065684
Radiator Specialty Company
Union County, North Carolina
Dear Mr. Roberts:
Nesco Environmental, P.L.L.C. (Nesco Environmental) is assisting a client in
obtaining a (National Pollutant Discharge Elimination System) NPDES permit for the
discharge of treated ground water as part of cleanup project involving solvent -
impacted ground water. The NPDES permitting process requires that an Engineering
Alternatives Evaluation (EAA) be performed. Guidance from the North Carolina
Department of Environment and Natural Resources (NCDENR) indicates that the
proponent must determine if other existing wastewater facilities within 5 miles of the
proposed discharge would be willing to accept the discharge.
Nesco Environmental has identified the Country Wood WWTP (NPDES Permit
No. NC0065684) as being within 5 miles of the proposed discharge. Nesco
Environmental has identified your company as the operator of this facility through
public records.
The flow from the proposed discharge is anticipated to be up to 75,000 GPD.
The expected concentrations (in milligrams per liter) of solvents remaining in the
treated discharge are as follows:
/OWN Environmental and Geologic Services
?O Box 78222 Charlotte, NC 28271 + 2416 River Oaks Drive Waxhaw, NC 28173
Phone [phone] + Fax [phone]
Email [e-mail]

Mr. Thomas Roberts.
Aqua — North Carolina
February 28, 2009
Page 2
1, 1-Dichloroethane
1, 1-Dichloroethene
1, 2-Dichloroethene (total)
Tetrachloroethene
Trichloroethene
Chloroethane
Methylene chloride
0.015
0.0015
0.0074
0.0021
0.00073
0.0081
0.002
Would your company be willing to accept this wastestream at the Country
Wood WWTP?
Please respond to this inquiry as soon as your schedule allows. You may
respond by telephone, mail, or by email (nescoenva-carolina.rr.com).
Thank you for your help in this matter. If you have questions, please contact
me at [phone].
Sincerely,
/001� NESCO ENVIRONMENTAL, P.L.L.C.
Y0101 P. A* fj
Joseph P. Nestor, P.G., P.E.
President
JPNypn120090228
r

EPA I Envirofacts Warehouse I FII Page I of 2
http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?
o �fv pgm_sys_idL6"r' �f �A ll}d51j5-F@45FlI@r 952009.
U
'Facility Reg
istry System (FR�I You are here: EPA Home Envirofacts FRS Report
34 Facility Detail Report
r 1a
Facility Name:
ICOUNTRY WOOD WWTP
Location Address:
I NCSR 1004
Supplemental Address:
City Name.,
MONROE
State
NC
County Name:
UNION
ZIP/Postal Code:
28110
EPA Region:
04
Congressional District Number:
08
Legislative District Number:
HUC Code:
03040105
Federal Facility:
US Mexico Border Indicator:
NO
Tribal Land :
NO
Latitude:
35.122778
Longitude:
-80.620556
Method:
INTERPOLATION -MAP
Reference Point Description:
FACILITY CENTROID
Duns Number:
Registry ID:
110006708429
Map this facility
Environmental Interests
Information
Information
Environmental
Data
Source
Last
Updated
Date
Supplemental
Environmental
System
System ID
Interest Type
Interests•
PCS
NC0065684
NPDES MAJOR N
NPDES
PERM T
03/25/2003
Facility Mailing Addresses
http://oaspub.cpa.gov/enviro/ft i_query_dtl.disp_program_facility?pgm_sys_id_in=NC006... 2/28/2009

,
EPA ( Envirofacts Warehouse I FII
Page 2 of 2
6a
Affiliation Type Delivery Point 11Cft SiPosta l Information
Name Code S stem
PRIMARY MAILING 202 MACKENAN IC
ARY NC 27511 PCs
ADDRESS CT
NAICS Codes
No NAICS Codes returned.
SIC Codes
Data Source SIC Codell Description Primar
PCs 4952 SEWERAGE SYSTEMS Q
Contacts
Affiliation Type Full Name Office Information Mailing
Phone S stem11
Address
COGNIZANT THOMAS ROBERTS,
OFFICIAL PRESIDENT
919467871211PCS
Organizations
No Organizations returned.
Alternative Names
Alternative Name 11source of Data
HEATER UTIL/COUNTRY WOOD WWTP NPDES PERMIT
Query executed on: FEB-28-2009
http://oaspub.epa.gov/enviro/fii_query_dtl.disp�rogram_facility?pgm_sys_id_in=NC006... 2/28/2009

Page 1 of 3
Joseph P. Nestor
From: Bryant, Shari L. [[e-mail]]
Sent: Wednesday, March 11, 2009 9:41 AM
To: Joseph P. Nestor
Subject: RE: Engineering Alternatives Evaluation for NPDES Permitting
Mr. Nestor,
I have reviewed our GIS database and there are records for several listed species in South Fork Crooked Creek
within 5 miles of the site. These include:
Savannah lilliput (Toxolasma pullus) - federal species of concern, state endangered freshwater mussel
Carolina creekshell (�illosa vaughaniana) - federal species of concern, state endangered freshwater mussel
Carolina darter (Etheostoma collis) - federal species of concern, state special concern freshwater fish
Eastern creekshell ( �illosa delumbis) - state significantly rare freshwater mussel
You indicated there is a proposal for an NPDES permit for discharging treated wastewater. Typically, we have not
recommended denial for these types of permit; however, we have recommended specific conditions to be included
in the issuance of any permit. The conditions would depend on proposed discharge volume (e.g., daily discharge),
parameters of concern (e.g, ammonia or organic compounds), and instream waste concentration (particularly
during low flow periods). Recommendations have included use of best available technology, instream sampling
for the parameters of concern upstream and downstream of the discharge particularly during low flow months
(July, August, September and October), a remedial action plan if concentrations of the parameters of concern in
instream sampling are found to be sigrificantly higher during low flow periods, and installation of stand-by power
systems.
Please note the above information is intended for informational purposes only since specific details regarding the
proposed discharge were not provided. I would need more specific details on the proposed discharge prior to
providing definitive recommendations.
If you have any questions, please contact me at 336.449.7625.
Shari Bryant
N.C. Wildlife Resource Commission
P.O. Box 129
Sedalia, NC 27342-0129
336.449.7625
sharibryant@ncwildlfe,org
From: Joseph P. Nestor [[e-mail]]
Sent: Tuesday, March 10, 2009 11:11 AM
To: Bryant, Shari L.
Subject: FW: Engineering Alternatives Evaluation for NPDES Permitting
Ms. Bryant:
I am following up on an email which was forwarded to you yesterday by Shannon Deaton. The text of
/40'� the email is below. I realize that your time is valuable and you may not be able to address our inquiry
immediately. However, in the meantime, can you forward me a reply indicating that you have received
3/11/2009

Page 2 of 3
/"E1 the email and are the correct person to whom we should be making this inquiry?
If you need additional information, please contact me at your earliest convenience.
Thanks.
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
nescoenv@carolina. rr.,com
From: Deaton, Shannon L. [mailto:[e-mail]]
Sent: Monday, March 09, 2009 10:02 AM
To: [e-mail]
Cc: Bryant, Shari L.
Subject: FW: Engineering Alternatives Evaluation for NPDES Permitting
1 apologize for my delayed response. I am glad you followed up with another phone call as I missed your first
email.
/%ftN You do need to get in touch with Shari Bryant to evaluate Union county habitats and species. She is cc'd to this
email and her phone number is 336-449-762-5.
From: Joseph P. Nestor [mailto:[e-mail]]
Sent: Tuesday, February 24, 2009 3:56 PM
To: Deaton, Shannon L.
Subject: Engineering Alternatives Evaluation for NPDES Permitting
Ms. Deaton:
I am assisting a client in obtaining a NPDES permit for the discharge of treated ground water as part of a
RCRA cleanup. The NPDES permitting process requires that an Engineering Alternatives Evaluation
(EAA) be performed. NCDENR guidance indicates that the proponent must first determine if the
discharge may be allowed. The guidance indicates that the proponent should determine if there are any
limitations as a result of the presence of endangered species. Specifically the guidance states:
Presence of Endangered Species. If endangered species are present in the proposed
discharge location, there may be wastewater discharge restrictions. Endangered species
information may be included in the Basinwide Water Quality Plan, or you may contact the U.S.
Fish and Wildlife Service (919-856-4520), N.C. Wildlife Resources Commission (919-733-
3633), or the N. C. Natural Heritage Program (9 1 9-733-7701).
The proposed discharge is into the South Fork Crooked Creek at approximately 35 03' 58" N 80 39' 16"
W. This is in Indian Trail in Union County. The discharge point lies within the Rocky River Basin within
the Yadkin River Basin.
I have downloaded the NCDENR 2008 Rocky River Basinwide Plan Report from
3/11/2009

Page 3 of 3
14MI\
fO'
http_//h2o.enr.state. nc_us/basinwide/Neuse/2008/documents/RockyR.03040105_.pdf.
I did not see any reference to endangered species for the South Fork Crooked Creek in this document
and presume that your agency would not prohibit or restrict he discharge as a result of endangered
species. I am certainly not an expert on endangered species, and would appreciate a knowledgeable
person from your agency confirming my understanding. Would you or another member of your staff
help me on this matter, please?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
nescoenvea carolina..rrcom
3/11/2009

/dft\
eosl1
06 February AD, 2009
Richard L. I-larmon, N.G.
Harmon Environmental, PA
615 Bruce Thomas Road
Monroe, North Carolina 28112
:� ;OPTIC
OO LUTI� rONf:
SUBJECT: REVIEW OF UNION COUNTY SOIL SURVEY INFORMATION FOR
POTENTIAL LAND APPLICATION OF TREATED GROUNDWATER
RADIATOR SPECIALTY COMPANY, INC.
600 RADIATOR ROAD
INDIAN TRAIL, NORTH CAROLINA
Dear Mr. Harmon:
Introduction
Septic Environmental Solutions, Inc. has completed Part 1, Alternative B. of the Engineering
Alternative Analysis (EAA) Guidance Document for North Carolina Division of Water
Quality/National Polluted Discharge Elimination System (NPDES) Unit on the Radiator Specialty
Company (RSC) property in Indian Trail, North Carolina. One of the application requirements is
for a North Carolina Soil Scientist to estimate the best case hydraulic loading rate based on
County Soil Surveys. 'Therefore, the objective of this scope of services is to provide information
for a best case estimate of the hydraulic loading rate based on information presented in the Soil
Survey of Union County, North Carolina published by the United States Department of
Agriculture.
Interpretations regarding the suitability of these soils in reference to hydraulic loading rates for
various land uses are based on a combination of factors, including but not limited to detailed
understanding of topography, soil characteristics, soil depths, restrictive horizons, soil wetness,
slope, drainage patterns, available space, local climate, including rainfall amounts and
evaporation rates, buffer restrictions and impact of watertable, and local field experience. Other
important site selection criteria factors include, but are not limited to feasibility of design and
installation, operation and maintenance requirements and cost, and consultation with local
landowners and other experts located in the county and state. Generally, some of these
conditions, which may limit the site use, can be compensated for by changing the system design.
5522 Whispering Wind Lane- Indian Trail, North Carolina 28079
Office [phone] • Mobile [phone] • Fax [phone]

fIMN
However, some factors cannot be remedied. It is with this philosophy that this report was
prepared.
This summary report addresses the requirements of Part 1, Alternative B. Land Application
requirements for an Engineering Alternatives Analyses (EAA) and is intended to be incorporated
into a National Pollution Discharge Elimination System (NPDES) Permit application being
prepared by Harmon Eanvironmental, PA and NESCO Environmental, P.L.L.C. on behalf of
Radiator Specialty Company.
Background Information
The total acreage for the subject properties is approximately 127tacres. Currently RSC is
treating approximately 37-gallons per minute (GPM) or 53,280 gallons per day (GPD). This
treated wastewater is currently discharged to the Union County Publicly Owned Treatment Works
(POTW). RSC's current agreement allows for the discharge of up to 60,000 GPD. The
groundwater treatment system is capable of treating up to approximately 100,000 GPD and the
groundwater recovery system is capable of capturing approximately 75,000 GPD. For this scope
of service 75, 000 GPD was used for the EEA Land Application disposal waste flow to determine
the best estimate of the hydraulic loading rate based on the County Soil Surveys. Land
application disposal alternatives include individual/community onsite subsurface, drip irrigation,
and spray irrigation systems.
It is understood that the groundwater remediation system was in operation October 1994. The
groundwater recovery system consists of four wells, (R-1, RW-2, RW-3 and RW4) ranging in
depth for 110 feet below grade to 500 feet below grade. These wells are currently pumped at a
combined flow of approximately 37 GPM. The collected groundwater is transferred via sub -
grade piping to a 6,000-gallon above ground equalization tank.. Recovered groundwater is
transferred from the 6,000-gallon equalization tank via a feed pump to the air stripping tower for
treatment. In the stripping tower, VOCs are stripped from the water and transferred to an air
stream which exits through the top of the treatment unit. The treated groundwater is subsequently
discharged to the Union County Publicly Owned Treatment Works (POTW) in accordance with
the conditions of Industrial Users Permit UC-1.
2

Site Location
The RSC facility is located on Radiator Road in Indian Trail, Union County, North Carolina
(Figure 1). The RSC tract is bisected by the CSX Railroad. The northeastern portion of the
property is bound to the northeast by Goose Creek Golf Course, to the northwest by the
Ridgefield Subdivision and to the southeast by Harris Teeter Distribution Center. The
southwestern portion of the property is bound to the northwest, south and the southeast by
wooded undeveloped property and east by a developed subdivision. (Figure 2)
Soil Survey Map Description
Soil series maps prepared by the United States Department of Agriculture (USDA) and Natural
Resource Conservation Service (MRCS) and previously known as the Soil Conservation Service
(SCS) for Union County indicates six soil map units present on the site (Figure 3). However, the
site consists primarily of two soil map units the BdB2- Badin channery silty clay loam, 2 to 8
percent slopes, eroded and the CmB- Cid Channery silt loam with 1 to 5 percent slopes that make
/Oft� up approximately 75% of the total soil map units located on the site (See Attachment A). The
BuB- Badin —Urban land complex, 2 to 8 percent slopes, the ChA- Chewacla silt loam with 0 to 2
percent slopes, frequently floods, the BaB- Badin channery silt loam, 2 to 8 percent slopes and
the ZnB-Zion gravelly loam with 2 to 8 percent slopes makes up the remaining 25%.
The BdB2- Badin channery silty clay loam, 2 to 8 percent slopes, eroded. This map unit consists
of moderately deep, well -drained, undulating Badin and similar soils on convex ridges that are
dissected by intermittent drainageways in the uplands. individual areas are irregular in shape and
mostly range from 5 to more than 100 acres in size. Typically, the surface layer is reddish brown
channery silty clay loam 6 inches thick. The subsoil is 23 inches thick. 1n the upper part, it is red
silty clay and in the lower part it is red channery silty clay loam that has yellow and strong brown
mottles. Weathered, fractured slate bedrock is at a depth of about 29 inches. Hard fracture slate
bedrock is at a depth of 41 inches. In some small uneroded areas, the surface soil is brown
channery silt loam. In some other areas, the surface layer is silt loam.
Permeability, available water holding capacity and shrink -swell potential is typically described as
moderate. This soil is typically described as strongly to extremely acid in the subsoil and
underlying material.
3

?4ft1
The unit includes the Cid Channery silt loam (CmB) with 1 to 5 percent slopes. The Cid soil is
moderately deep over bedrock. It is moderately well -drained and somewhat poorly drained
nearly level and gently sloping Cid and similar soils on flats, on ridges in the uplands, in
depressions, and at the head of intermittent drainageways. Typically, the surface layer is light
brownish gray channery silt loam 4 inches thick. The subsurface layer is pale yellow channery silt
loam 5 inches thick. The subsoil is 18 inches thick. In the upper part it is brownish yellow silty
clay loam that has pale yellow mottles. In the lower part it is mottled grayish brown and light
olive brown channery silty clay. Weathered, fractured slate bedrock is at a depth of approximately
27 inches. I -lard, fracture, slate bedrock is at a depth of 32 inches.
Permeability is slow in the Cid soil. Available water holding capacity is low or moderate. The
shrink -swell potential is moderate. This soil is typically described as strongly to extremely acid.
/Oft� The BuB-Badin—Urban land complex, 2 to 8 percent slopes. This map unit occurs mainly as areas
of moderately deep, well -drained, undulating Badin soil and areas of Urban land. It is about 60
percent Badin soil and 25 percent Urban land. Individual areas are irregular in shape and range
from 25 to 500 acres in size. Typically, the surface layer is reddish brown channery silty clay
loam 6 inches thick. The subsoil is 23 inches thick. In the upper part, it is red silty clay and in the
lower part it is red channery silty clay loam that has yellow and strong brown mottles.
Weathered, fractured slate bedrock is at a depth of about 29 inches. Hard fracture slate bedrock is
at a depth of 41 inches.
Permeability and shrink -swell potential is typically described as moderate. Available water
capacity is low or moderate. `Phis soil is typically described as strongly to extremely acid.
The ChA- Cliewacla silt loam with 0 to 2 percent slopes, frequently floods. This map unit consists
mainly of very deep, nearly level, somewhat poorly drained Chewacla and similar soils on flood
plains. It is mostly on broad flats along the major streams and on narrow flats along minor creeks
and drainageways. Individual areas are generally long and narrow and range from 25 to more
than 200 acres in size. Typically, the surface layer is brown silt loam 7 inches thick. The subsoil
is 45 inches thick. In the upper part, it is light yellowish brown silt loam that has yellowish
4

/dmb�
brown mottles. In the next part, it is yellowish brown loam that has light brownish bray mottles.
In the lower part, it is light brownish gray silty clay loam that has yellowish brown mottles. The
underlying material to a depth of 72 inches is light gray loamy fine sand that has yellowish brown
and dark yellowish brown mottles.
Permeability is moderate in the Chewacla soil. Available water capacity is high. The soil is
typically described as very strongly acid to slightly alkaline in the lower part of the subsoil and in
the underlying material. The shrink -swell potential is low.
The BaB- Badin channery silt loam, 2 to 8 percent slopes. This map unit consists of moderately
deep, well -drained soils. Typically, the surface layer is brown channery silt loam 7 inches thick.
The subsoil is 21 inches thick. In the upper part, it is red silty clay and in the lower part it is red
channery silty clay loam that has yellow and strong brown mottles. Weathered, fractured slate
bedrock is at a depth of about 28 inches. Vlard fracture slate bedrock is at a depth of 41 inches.
Permeability and shrink -swell potential is typically described as moderate. Available water
capacity is low or moderate. This soil is typically described as strongly to extremely acid.
The ZnB- Zion gravelly loam with 2 to 8 percent slopes. This map unit consists mainly of
moderately deep, well drained, gently sloping Zion and similar soils on ridges in the uplands.
Individual areas are oval and range from 4 to more than 200 acres. Typically, the surface layer is
brown gravelly loam 8 inches thick. The subsoil is 18 inches thick. In the upper part, it is
yellowish brown gravelly clay loam. In the next part, it is dark yellowish brown clay that has
yellowish brown mottles. In the lower part, it is mottled yellowish brown and brown clay loam.
The underlying material extends to a depth of 30 inches.
Permeability is slow in the Zion soil. Available water capacity is low. This soil is typically
described as strongly acid to neutral in the subsoil and underlying material. The shrink -swell
potential is high.
E

/4 1
On -Site Field Check
On January 26, 2009 Septic Environmental Solutions, Inc. verified that the published soil series
in the Union County Soil Survey Manual were located on the subject property by conducting a
field check. The landscape positions were verified in reference to soils located on the subject
property by collecting soil data. This is known as soil landscape mapping. Soil landscape
mapping is natural areas of land that have similar topography and soils, which can be specifically
and concisely described, and shown on maps. Since soil landscape mapping recognizes that soils
are naturally occurring entities they can be used to distinguish mappable areas of soils because
the formation of landscapes and soils is interrelated; both have been subject to the same processes
and influences over time.
The soil data was collected by advancing hand auger borings across specific landscape positions
in reference to soil series maps published in the Union County Soil Survey Manual. Note: The
scope of this service is not to delineate soil map unit boundaries but only to verify that the soil
/IM1 map unit described in the Union County Soil Survey Manual is in fact on the subject property.
The USDAJNRCS Field Book for Describing and Sampling Soils, Version 2.0 was used as a
supplement in order to complete this scope of service. The topography is nearly level to gently
sloping with a smooth linear linear to smooth linear -convex slope between 3 to 10 percent.
Evidence of ponding and erosion was noted during the time of the walkover.
During the walkover, 9 closed bucket auger borings (BA) were advanced across all sites to a
maximum depth of 48 inches or until unsuitable characteristics were encountered such as a
shallow water table, bedrock, restrictive soil horizons, poor drainage mottles, expansive clay or
saprolite (Figure 4). Tenninating soil boring depths were typically due to shallow soil depths
such as weathered bedrock, poor drainage mottles and unsuitable clay mineralogy (expansive clay
mineralogy) that ranged from 6 to 16-inches in depth. The most limiting soil evaluation factors
were shallow soil depths to weathered fractured bedrock, poor drainage mottles (grey soil color)
and clay mineralogy (expansive clay) (Photographs I and 2).
6

/'=N
ejmkl�
Summary of Site Recommendations
Not all sites are appropriate for land application. Facilities wishing to dispose of treated
groundwater through irrigation sometimes must purchase or lease suitable land for disposal or
enter into cooperative arrangements with local farmers or landowners. Sites near surface water or
high groundwater often are restricted, especially when these are used as drinking water sources.
Regulations typically require minimum separation distance or buffer zone from ground and
surface water resources and public areas to minimize contact with wastewater.
To guard against the possibility that drifting aerosols and runoff created by land application
(spray irrigation) systems will reach and contaminate nearby public areas and water resources,
regulations typically require considerable minimum setback distances or buffer zones to nearby
residences, property lines, public areas, wells, streams, rivers, lakes, and wetlands. Minimum
setbacks of as much as 150 to 500 feet from neighboring residenccs and water sources are not
unusual, depending on local regulations. Buffers also may be required from water lines,
embankments, drains, drainage ditches, and public rights of way. A minimum vertical separation
distance to the water table also applies. Because of these setback requirements, spray systems
tend to be mainly practical for irrigating crops, fields, and larger land areas.
During the field check and based on aerial maps, several areas were noted to have existing
structures such as paved or gravel parking, several industrial buildings, storage tanks and sheds,
loading pads and stations etc. In addition, many areas had surface ponding, seasonal drainage
swales and previous indication of surface water ponding from possible seasonal flooding
(Figure 5).
According to the USDA and NRCS previously known as the SCS of Union County, the soil
survey maps indicate six soil map units present of on the site. Based on the field check and the
soil data collected on -site, the soils appeared to match the soil series that were published in the
Union County Soil Survey Manual.
Based on the two primary soil series, the soil survey maps indicated in the "Physical and
Chemical Properties of the Soils" that the permeability of the most restrictive soil horizon for
these soil types ranged from 0.06 to 2.0-inches per hour (in/hr) which equates to 0.8976 to 89.76-
7

e4o1
gallons per square foot per day (gal/W/day). This permeability data is of relevance. However
these estimates are based on samples collected from the field and tested in laboratory conditions
including but not limited to soil characteristics, particularly structure, porosity, and texture. In
addition, these County Soil Surveys are not site specific and the information relates to only the
upper three feet of the soil profile and for this reason this data should be used qualitatively and
not quantitatively.
Septic Environmental Solutions, Inc. has performed numerous Soil and Site Evaluations on
similar soil types throughout Union County. Many of these soil types were unsuitable for land
application due to severe limitations, topography and shallow soil depths to restrictive soil
conditions such as shallow bedrock, shallow soil wetness, shallow water table and unsuitable clay
mineralogy (expansive clay). For these reasons, hydraulic conductivity (Ksat) tests typically
were not warranted.
Depending on the type of land disposal, the disposal flow and State Rules and Regulation
requirements only a few sites with these soil types warrant Ksat testing. Most of these sites were
evaluated for small amounts of residential waste flow, typically less than 600-GPD or larger
facilities such as Day Care Facilities with waste flow < 3,000-GPD. These Ksat tests were
performed on similar soil types and landscape positions by using an advanced field instrument,
the Compact Constant Head Permeameter (CCHP) designed by Dr. Amoozegar (1989).
Measurements were continuously taken in dry to moist soil conditions up to twenty-four hours or
until the meters were near empty in the most restrictive soil horizons. These field tests, typically
reported much lower test results then what was reported in the (MRCS) Union County Soil
Survey Manual. A few test results reported slightly higher Ksat measurements. It was believed
that the higher Ksat results were contributed to the shallow fractured bedrock that underlies the
soil and other unconsolidated material.
These soil types typically have shallow depth to bedrock, long duration of seasonal high water table
as described for December to May, surface ponding, slow permeability and erosion potential. The
remaining soil types have slow to moderate permeability, shallow depth to bedrock, surface
ponding, erosion potential, and moderate to high shrink -swell potential. Other limited factors for
8

r
these soil types are depth to water for drainage, depth to rock and slope for irrigation and soil
wetness and flooding.
The slow permeability of these soils is one of the most limiting factors. This factor can not be
altered to increase the soils permeability. In addition the depth to weathered bedrock limits the
volume of water the soil can store and transmit. For these limitations but not limited to, there is
nothing that can be done to alter them. Based on the 75,000-GP1) proposed treated groundwater
disposal flow and the published data in the Union County Soil Survey Manual and our experience
with these soil types, these soils types would typically be considered unsuitable for land
application.
Note: Other factors such as hydrogeological characteristics and groundwater mounding analysis
of the site must be used to determine the final loading rate in the final design of the land
application.
Closing
This opinion report may be relied upon in connection with and for the purposes set forth herein to
the degree allowed by the Terms and Conditions agreed to on January 29, 2009. Independent
conclusions, opinions and recommendations made by others based on the field data are not the
responsibility of the undersigned.
The RSC property located on Radiator Road in Union County, North Carolina was evaluated in a
diligent manner. It is guaranteed that the work was performed to professional standards.
However, this report represents a professional opinion, and does not express or imply that small
portions of the RSC tract may be suitable for land application. It is our opinion however, that
insufficient acceptable soil is available to land apply the proposed 75,000 GPD of treated waste
water from the RSC groundwater remediation system.
This document does not guarantee government approval or denial. North Carolina Division of
Water Quality (DWQ), Department of Environmental Health and Natural Resource, and NPDES
must approve all proposed land application and their installation locations.
iJ

If you should have any questions concerning this report, or need further assistance, call (704)
502-5588.
Sincerely,
Kenneth L. Owens, L.S.S.
North Carolina Licensed Soil Scientist # 1134
Radiator Specialty.doc
10
SOIL SCI�
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Source: ADC The Map People 21
FIGURE 1. Site Location Map
Radiator Specialty Company
600 Radiator Drive
Union County, North Carolina
Dag Dole- January 29. 2009
DViG BY: I(LO MVG NO. 1 REVISED: NA
SCALE: NTS I SHEET'. 1 /4

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FIGURE 3. Soil Survey Map
Radiator Specialty Company
600 Radiator Drive
Union County, North Carolina
D.v9 Dole: Jonvary 29, 2009
DWG BY: KLO DWG N0. 3 REV;0: NA
SCALE:NIS SHEET: 3/4

r.
Source: Union County GIS
LEGEND
T APPROXIMATE SOIL BORING LOCATIONS
/ftk
FIGURE 4. Approximate Soil Boring
Locations
Radiator Specialty Company
600 Radiator Drive
Union County, North Carolina
Dwy Dole: January 29. 2009
OWG BY: KL0 I DWG NO. 4 1 RE"SEO: NA
SCAEE:NTS I SHEET: 4/5

.^
Source: Union County GIS
.. Brittany Du wns ^"''
FIGURE S. Approximate Site
Limitation Map
Radiator Specialty Company
600 Radiator Drive
Union County, North Carolina
Dw9 Dn1e: Jomwy 29, 2009
DWG BY: KLO DWC NO. 5 REVISED: NA
SCALE:NTS SHEET: 5/5
Po

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Photograph 1: View of a soil sample taken from SB-l.
IRad end grn� soil cnior'.
pn+c ilrainaec biw�6s;
Photograph 2: View of a soil sample taken from 513-2. I

ATTACHMENT A
(WEB SOIL SURVEYII FORM4TIOA9

/M%l
OV"�
Wa'1g
353'2T
Soil Map —Union County, North Carolina
Mep Saele: 11,90o a p.MW mA 4m (& W z tl') sheet
b
Meters
�� S A so oo mo 300
N rOer e
a aa,o IiJO tsoo 1.810
USDA Natural Resources Web Soil Survey 2.1
"" Conservation Service National Cooperative Soil Survey
—I W 3'21'
R
n
1/28/2009
Page 1 of 3

E
Soil Map —Union County, North Carolina
MAP LEGEND
MAP INFORMATION
Area of Interest (AOI)
1Z Very Stony Spot
Map Scale: 1:7,900 if printed on A size (8.5" x 11 ") sheet.
C
Area of Interest (AOI)
Wet Spot
The soil surveys that comprise your AOI were mapped at 1:24,000.
Solis
A Other
Please rely on the bar scale on each map sheet for accurate map
Soil Map Units
measurements.
Spacial Line Features
Special
Point Features
Ginty
Source of Map: Natural Resources Conservation Service
�s
Blowout
Web Soil Survey URL: http:/fwebsoilsurvey.nres.usda.gov
®
Barrow Pit
.. Short Steep Slope
Coordinate System: UTM Zone 17N NAD83
X
Clay Spot
�• . Other
This product is generated from the USDA-NRCS certified data as of
Political Features
the version date(s) listed below.
0
Closed Depression
O Cities
Soil Survey Area: Union County, North Carolina
X
Gravel Pit
water Features
Survey Area Data: Version 10, Oct 19, 2007
Gravely Spot
� Oceans
Date(s) aerial images were photographed: 6/20/2006
®
Landfill
_.- Streams and Canals
The orthophoto or other base map on which the soil lines were
A
Lava Flow
Transportation
compiled and digitized probably differs from the background
Rails
imagery displayed on these maps. As a result, some minor shifting
�y
Marsh or swamp
of map unit boundaries may be evident.
x
Mine or Quarry
Interstate Highways
p
Miscellaneous Water
US Routes
Q
Perennial Water
Major Roads
v
Rock Outcrop
Local Roads
+
Saline Spot
Sandy Spot
_
Severely Eroded Spot
Q
Sinkhole
i�
Slide or Slip
g
Sodic Spot
Spoil Area
Q
Stony Spot
USDA Natural Resources Web Soil Survey 2.1 1 /28/2009
Conservation Service National Cooperative Soil Survey Page 2 of 3

/Owt\ Soil Map —Union County, North Carolina
Map Unit Legend
Union County, North Carolina (NC179)
Map Unit Symbol
Map Unit Name
Acres in AOI
Percent of AOI
BaB
Badin channery silt loam, 2 to 8 percent slopes ,
6.7
5.0%
BdB2
Badin channery silty clay loam, 2 to 8 percent
30.8
23.2%
slopes, eroded
BuB
Badin-Urban land complex, 2 to 8 percent
14.5
10.9%
slopes
ChA
I Chewacla silt loam, 0 to 2 percent slopes,
6.9
5.2 /o
frequently flooded
CmB
'Cid channery silt loam, 1 to 5 percent slopes I
67.8
51.1 %
GOC
Goldston very channery silt loam, 4 to 15
0.8
0.6% j
percent slopes
GsB
Goldston-Badin complex, 2 to 8 percent slopes E
:
0.0
0.0°%
Zn6
Zion gravelly loam, 2 to 8 percent slopes i
5.2 ,
3.9%
f Totals for Area of Interest
132.8 '
100.0 /o
/,M\
r� ISM Natural Resources Web Soil Survey 2.1 1/28/2009
Conservation Service National Cooperative Soil Survey Page 3 of 3

Marmon ]Environmental, PA
615 Bruce Thomas Road Phone and Fax: [phone]
Monroe, North Carolina 28112 %v%%-%v.harmonenvironmental.com
February 26, 2009
Mr. Stuart Kerkhoff
Radiator Specialty Company, Inc.
600 Radiator Road
Indian Trail, North Carolina 28079
Re: Evaluation of On -Site Soils and Bedrock for Potential
Subsurface Discharge of Treated Ground)vater front
The Existing Remediation System
Radiator Special1j) Company, Inc.
600 Radiator Road, Indian Trail, North Carolina
Project 303-10
Dear Mr. Kerkhoff:
To comply with the requirements of the National Pollution Discharge Elimination System (NPDES)
Permit Application, Harmon Envirorunental, PA respectfully submits this letter summarizing the
subsurface conditions at the referenced site. Based on the information presented in this evaluation,
the soil and bedrock underlying the Radiator Specialty Company (RSC) facility does not appear to be
conducive for subsurface disposal of the 75,000 gallons per day of treated water generated from the
existing groundwater remediation system. Figure 1 presents the location of the site as depicted on
an excerpt of a United States Geologic Survey (USGS) 7.5 minute quadrangle topographic map of
the region.
The RSC facility is located near the western edge of the Carolina Slate Belt within the Piedmont
Physiographic Province. The Carolina Slate Belt consists of low-grade metamorphosed volcanic and
sedimentary rocks situated in the east -central portion of the Piedmont Province of North Carolina.
Coastal Plain sediments overlap the Carolina Slate Belt to the east. The Charlotte Belt, which
consists of higher -grade metamorphic and igneous rocks, borders the Carolina Slate Belt to the west.
Investigations at the RSC facility indicate the site is located near the contact between the Carolina
Slate Belt and the Charlotte Belt. As a result, the site is underlain by rock types normally associated
with the Carolina Slate Belt and rock types normally associated with the Charlotte Belt.
Rocks comprising the Carolina Slate Belt consist of laminated and non -laminated metamorphosed
peltic rocks. Rock color varies from bluish -grey when fresh to brown and reddish -orange when
weathered. When present, laminated bedding planes are typically well developed and exhibit
bedding plane cleavage. Igneous intrusions have been observed throughout the Carolina Slate Belt.
Theses intrusions are typically comprised of diabase and metagabbro. The diabase occurs most
commonly as dikes with a general mineralogy of plagioclase, clinopyroxene and chlorite with biotite

Mr. Stuart Kerkhoff
February 26, 2009
Page 2
and quartz filling voids. The metagabbro is generally xenoblastic, but abundant sericite and epidote
obscure structure and mineralogy (Randazzo, 1972).
Quartz veins are present throughout the Carolina Slate Belt. These veins (i.e. dikes and sills) are
typically intruded into fractures in the country rock. Large muscovite flakes are commonly seen
along these intrusions, possibly indicating recrystalization of the country rock at the time of
intrusion. The quartz is usually milky in appearance (Randazzo, 1972).
The Gold Hill Shear Zone is a major structural feature present along the western boundary of the
Carolina Slate Belt. The Gold Hill Shear Zone is thought to be a thrust fault generally trending
approximately north 15 degrees east and extending southward from near Southmont in Davidson
County, North Carolina to the eastern side of Indian Trail. Previous investigations indicate the rocks
along the western margin of the shear zone are characterized by higher ranking metamorphism
including the occurrence of slate and phyllite. Local fault planes, quartz veins and minor joints are
also commonly associated with this major shear zone trend (Randazzo, 1972; The Geologic Map of
North Carolina, 1985).
/081N The Charlotte Belt is generally described as a granite/diorite complex. Relationships of the granite
and diorite in complexes of this nature are obscure. Many areas of the Charlotte Belt suggest the
granite intruded into the diorite, while at other locations in the diorite appears to have intruded into
the granite. The mineralogy components of granite and diorite are essentially the same (Stuckey and
Steel, 1953).
Rocks that comprise the Charlotte Belt are commonly described as metamorphosed diorite,
granodiorite and tonolite intruded by gabbro, granite, diabase, syenite, and quartz batholiths, dikes
and sills. Each rock unit is generally massive with weak foliation. Most units grade from one rock
type to another over distances of ten feet to a few miles. Sharp contacts are rare, except along the
perimeters of intrusions where banding and contact metamorphism may be observed (Randazzo,
1972).
The United States Department of Agriculture, Natural Resources Conservation Service defines the
soils in the immediate vicinity of the RSC facility as a Badin-Urban land complex primarily bounded
by Badin channery silty clay loam. The Badin soils are typically described as areas of moderately
deep, well drained soils associated with convex ridges that are dissected by intermittent drainage
ways in the uplands. Typically, the surface layers of these soils consist of approximately six inches
of reddish brown channety silty clay loam. The sub -soils are typically 23-inches thick comprised of
a red silty clay overlying red chaiuiery silty clay loam that exhibits yellow and strong brown mottles.
Weather -fractured slate bedrock is typically encountered at a depth of approximately 29-inches.
Hard -fractured slate bedrock is typically encountered at a depth of approximately 41-inches. The
permeability of the Badin soils is moderate with a moderate shrink swell potential. (Soil Survey,
r4ftN

/40kN
Mr. Stuart Kerkhoff
February 26, 2009
Page 3
Union County, North Carolina, 1996) The urban designation indicates this area of the site to have
been disturbed or covered by structures and pavement.
Soil overlying the phyllite bedrock on site consisted of a channery loam. This mantle ranged in
thickness across the site from non-existent to 20 feet thick. As indicated in the geologic cross -
sections, no soil mantle was observed in many disturbed areas of the site including the ridge
immediately south of the facility and the vicinity of the railroad spur line.
Based on boring logs associated with monitor wells advanced on the RSC property, a partially
weathered rock (PWR) material is present underlying the soil mantle at the site. For the purposes of
this report PWR is defined as material which can be bored with conventional hollow -stem augers and
exhibits penetration resistance values greater than 100 blows per foot, using the Standard Penetration
Resistance Test as described in ASTM D- 1586. The phyllite PWR on site is typically approximately
10 feet thick. The contact between the soil mantle and the phyllite PWR is generally gradational,
representing varying degrees of weathering of the same phyllite parent material.
The phyllite bedrock underlying the PWR at the site is represented by a gradational contact with a
hard, slightly weathered to fresh laminated phyllite typically exhibiting bedding planes of
approximately 0.125-inches in thickness with a dip of approximately 75°. Phyllite is typically
defined as argillaccous rock intermediate with a metamorphic grade between the slate and schist.
Phyllite is typically differentiated from other argillites in the field by its silky sheen observed along
the cleavage planes imparted by the mica crystals.
A fracture trace investigation previously conducted at the site indicates this unit exhibits two
predominant joint sets consisting of a sub -vertical set dipping at approximately 60° to 75' and a sub -
horizontal set dipping at approximately 0° to 20°. Field measurements indicated the sub -vertical
fracture set appears to parallel the bedding planes of the formation.
The soil mantle weathered in -place from the diorite bedrock on -site ranges in thickness from non-
existent to 25 feet thick. Diorite PWR underlies the soil mantle with a gradational contact. 1'he
PWR observed in the borings advanced within the diorite on -site ranges in thickness from non-
existent to 15 feet thick.
Diorite parent rock was observed both underlying the PWR and exposed at the surface in portions of
the site. Rock cores indicate this diorite to be hard, slightly weathered aphanitic to phaneritic diorite
typically possessing three poorly developed fracture joint sets. These fracture sets consist of a
closely spaced, sub -horizontal fracture set with dip angles of approximately 10" to 20°, a sub -
vertical fracture set with dip angles ranging from approximately 30° to 60' and a less predominant
vertical fracture set with dip angles of approximately 80°.

Mr. Stuart Kerkhoff
February 26, 2009
Page 4
The aquifer underlying the RSC facility is typical of the composite -weathered residuum -crystalline
fractured rock aquifers located in the piedmont region of North Carolina. The aquifer is unconfined,
existing under phreatic or water table conditions. Under such conditions, the water table surface is in
equilibrium with the atmospheric pressure and is not confined by low -permeable layers between the
surface of the water table and the surface of the ground.
Groundwater under water table conditions is typically replenished through direct infiltration from
precipitation. Water flows through pore spaces in geologic media to its ultimate discharge in
topographic low regions where the water table surface intersects the surface of the ground. As a
result of these typical flow patterns, the potentiometric (water table) surface expressed by water
table aquifers typically appears as a subdued replica of the topography. Prior to initiating the
groundwater recovery program, shallow groundwater flowed from the RSC facility to the northwest
and southeast. The calculated velocity of the groundwater flowing to the northwest was
approximately 0.005 feet per day (ft/d) and the calculated velocity of the groundwater flowing to the
southeast was 0.03 ft/d.
In 1994, to assess the aquifer characteristics and evaluate the effect the fracture set may have on the
/ORIN recovery of groundwater for on -site pretreatment, RSC conducted step-down tests in three of the
individual recovery wells and a constant discharge test pumping from the entire recovery well
network. The results of the constant discharge test were interpreted using Theis, Cooper -Jacob and
Neuman Methods. The results of these interpretations indicated the geometric mean of the
hydraulic conductivity results at the site ranged from 0.17 ft/d to 0.23 ft/d.
Based on wager level measurements collected on April 29, 2008, the water table surface exhibits the
influence of the on -going groundwater remediation system. The calculated groundwater flow
velocities depicted on this figure ranged from 0.05 ft/d to 0.23 ft/d in the vicinity of the recovery
wells.
The vertical component of the groundwater flow calculated based on the April 29, 2008 water level
measurements indicate the recovery wells are influencing the flow of the deeper portion of the
aquifer, effectively drawing deeper water toward the recovery wells. The vertical component of the
groundwater flow velocity calculated from the groundwater elevations collected from an on -site
well cluster is 0.01 ft/d upward.
North Carolina General Statue, Article 21 5143-215.IA. allows for injection of treated groundwater
in a "closed -loop groundwater remediation system". A closed -loop system is considered a system in
which the injected groundwater is captured by the recovery system. Based on the variability of the
bedrock the RSC facility, this site is not considered to be conducive for this form of subsurface
disposal. As a result, Harmon Environmental, PA recommends RSC pursue other options for
discharging for this water.

Mr. Stuart Kerkhoff
February 26, 2009
Page 5
Please call if you have any questions or require any additional information.
Sincerely,
Harmon Environmental, PA
i.�•.' =ter_
Richard L. Harmon, P.G
President " Attachment.
w
l20%�

/00111\
Mr. Stuart Kerkhof f
February 26, 2009
Page 6
References
Geology and Hinercrl Resources ol'N'orth Carolina, Jasper J. Stuckey and Warren G. Steel, 1953
Geologic hlap oftVorth Carolina, North Carolina Department of Natural Resources and Community
Development, 1985
Petrology and Stratigraphy, of the Carolina Slate Belt, Union County, 1Vor•th Carolina, Anthony F.
Randazzo, 1972
.Soil SIIITey gf'Uniar7 C011171y, United States Department of Agriculture, January, 1996
Groundwaler, R.A. Freeze and J.A. Cherry, 1979
Groundwater and Wells, Second Edition, F.G. Driscoll, PhD, 1986
The Geology of the Carolinas, J. W. Horton and V. A Zullo, 1991

a
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All Risrhts Reserved ! Not For 14-avcaa#ion { _ 'AIN:
SOURCE: MAPTECH.COM
APPROXIMATE SCALE IN FEET
0 2000 4000
HARMON ENVIRONMENTAL, PA
FIGURE 1
W
a
W
SITE LOCATION MAP
o
615 BRUCE THOMAS ROAD
NPDES PERMIT APPLICATION
o
MONROE, NORTH CAROLINA 28112
RADIATOR SPECIALTY COMPANY
[phone] PHONE & FAX
INDIAN TRAIL, NORTH CAROLINA

�0
Radiator Specialty Company
Indian Trail, North Carolina
EPA ID No. NCD 091245 969
Treated Groundwater Reuse Synopsis
Radiator Specialty Company (RSC) has been operating a Groundwater Recovery
and Treatment System since October 1994. The system operates twenty-four (24) hours a
day, seven (7) days a week, three hundred and sixty-five (365) days a year. The system
treats and discharges to the Union County Publicly Owned Treatment Works (POTW) up
to sixty thousand (60,000) gallons of treated groundwater a day.
On June 6, 2003 RSC requested and was granted a "Contained -In Determination"
for its treated groundwater. RSC has been investigating alternatives to the Union County
POTW for its treated groundwater since receiving the "Contained -In Determination".
Listed below is a brief synopsis of the alternatives RSC has investigated for its treated
groundwater/gray water.
A. Waterbaths - RSC has three (3) aerosol manufacturing lines that utilize
waterbaths for pressure testing the aerosol cans. Each waterbath utilizes
five hundred (500) gallons of water per day.
B. Toilets — Based on the assumption that each RSC associate, one hundred
and fifty-two in total, uses twelve and a half (12.5) gallons of water per
/Oft\ day for sanitary wastewater disposal, 2,900 gallons of water would be
used per day.
These two options combined were assumed to consume approximately 3,400
gallons of wastewater per day. Due to the limited volume of gray water
consumed by these options relative to the costs associated with reconfiguring the
plumbing to utilize this limited volume of wastewater deemed these options
infeasible.
C. Process Water — RSC reviewed utilizing the wastewater as makeup water
in the production of chemical products. This option is infeasible because
the costs associated with the further treatment required to render this water
usable as process water far outweighs the savings realized in reduced
sewer costs.
D. Evaporative Cooling - RSC reviewed installing swamp coolers on the
plant roof to cool the production building. The swamp coolers would be a
seasonal item utilizing gray water six (6) months out of the year.
Installing and plumbing swamp coolers would provide use for a minimum
volume of wastewater. This option was not considered to be cost-effective
based on the limited volume of water consumed by these systems.
E. Process and Comfort Heat - RSC reviewed using the wastewater in the
boilers on -site to provide process and comfort heat. The boilers are used

}
seasonally, no more than six (6) months out of the year. The cost to
plumb and pretreat the wastewater so it can be used in the boilers far
outweighs the savings realized in reduced sewer costs.
F. Reuse through Other Entities - RSC considered installing a six thousand
(6,000) gallon aboveground storage tank (AST) at the edge of the property
and keeping the tank full of treated groundwater for use by other entities
as gray water. However, RSC is located in Indian Trail, NC surrounded
by residential neighborhoods. RSC is not located on a major highway. In
addition, the volume of water RSC could store for off -site reuse,
approximately six thousand (6,000) gallons a day, was determined to be
insignificant relative to the daily volume of water discharged.
G. Reuse by a Neighboring Industry - RSC negotiated with a neighboring
industry to utilize the treated groundwater in their process. While the
neighbor could have used approximately thirty thousand (30,000) gallons
a day, the water quality of the treated groundwater would require
additional pretreatment before they could use it in their process. The
neighboring Industry decided that the cost to transport the water,
approximately one mile, combined with further treatment of the water
upon receipt was not cost effective.
PARTB/REUSESYN.DOC
00M14
2
2/26/09

,.
AO\
Present -Value -of -Costs Analysis
Discharge to existing tributary to South Fork Crooked Creek (Zero 7QI0 flow)
Capital Costs
o Land acquisition costs $NA
o Equipment costs $NA
o Labor costs $Included with installation costs
o Installation costs $23,000
o Design costs $ 3,200
Co = $26,200
Recurring Costs
o Operation and maintenance costs (with replacement costs) $ 3,300
o Laboratory costs assuming a weekly monitoring regime for
discharge systems and a monthly regime for non -discharge systems $15,158
o Operator and support staff costs $ 9,240
o Residual disposal costs (included in operation and maintenance costs) $ 0
o Connection and subsequent user fees $ 0
o Permit and compliance fees (included in operation and maintenance costs) $ 0
o Utility costs (power, water, etc.) $ 5,032
C, _ $32,730
Present Value of Costs Calculation
Present value standard formula:
n C,
PV = Co+
Where:
PV = Present value of costs.
Co = Costs incurred in the present year.
C, = Costs incurred in time 1.
t = Time period after the present year (The present year is t = 0)
n = Ending year of the life of the facility.
r = Discount rate. For these calculations, the applicant shall use an interest rate quoted by the
lending institution. The loan interest rate quote shall be provided with this analysis.
However, if costs are the same in every time period from year one through year n (i.e., C, = C, a
constant for t = 1,2,..., n), then the formula reduces to:
PV = Co+ C (1+r)"-1
r(1 + r)"
Co = $26,200
C = $32,730
r = 4.875 % (Rate provide by Bob Sledge of NCDENR on May 18, 2009))
n = 20 years
/'** PV= $409,331 (assuming equal yearly costs)

/IMN
DeBruhl Environmental Exc., Inc. PROPOSAL
4921 Hoover Drive
Charlotte, NC 28269
I NAMEIADDRESS I
Harmon Environmental
615 Bruce Thomas Road
Monroe, NC 28112
DATE
ai2212na9
TERMS
PROJECT
Due on receipt
Radiator Specialty
DESCRIPTION
COST
PER TON
Advance approximately 1 300 It. of 2 foot trench.
18.370.00
Cut and remove asphalt from parking lot in trench area.
Install approximately 1300 It. of4" PVC pipe.
--Pipe will be bedded with 4"sand under pipe and 4"sand above pipe.
--Pipe will be buried 24" deep and installed in accordance with specifications provided by NESCO
Environmental.
Backfill trench with native soil and compact. Replace asphalt in parking lot area.
All material is guaranteed to be as specified. The work above to be performed and completed in
substantial workmanlike manner with payments to be made upon receipt of invoice. Invoices over 30
days old will be charged 18% interest per year. hiterest will be added monthly.
Please note: This proposal may be withdrawn by DeBruhl hnviromncrttal Excavating, Inc., if not accepted
within 30 days. Any alteration or variation from above listed specifications that involve additional costs
shall be executed only alter being submitted in writing and will become new charges over and above the
estimate. All agreements are contingent upon strikes, accidents, or delays beyond our contml. Owner is
to carry lire, tornado, and other necessary insurance upon above work. Workmen's compensation and
public liability insurance on above work shall be underwritten by The Hanover Insurance Group.
Acceptance of Proposal:
"ihe above prices, specifications and conditions are satisfactory and are hereby accepted. You are
authorized to do the work as specified. Payment will be made as outlined above. Note: A faxed copy of
acceptance and signature is same as original signature and shall be treated as such.
Acceptance Date: Signature:
Title: Company:
Phone #
Fax #
E-mail
704-598-2681
704-598-2988
rdcbruhl(c carolina.rr.com

Print Page 1 of I
Froin: John H. Ross (}
To: 'Rick Hannon'
Date: Wednesday,, April 15, 2009 9:20:02 AM
Cc: 'John 13arnard'
Subject: Radiator Specialties -Materials Testing
Rick,
Thank you for the opportunity to provide you with this "place holder" budget number for materials testing
services.
Based on our conversations, it is our understanding that the project is the installation of approximately 2000
linear feet of 4 gravity drain line. Our services will include testing of sand backfill around the pipe and soils
above the sand to grade. It is anticipated that the project will span a 1 to 2 week period.
For the proposal, we have assumed 10 trips to the project site at 3-4 hours per trip. I have included two
proctors (one sand and one soil) and engineering oversight in preparing a summary letter of test results. With
these assumptions, we suggest a project budget of $2600.
Once the details of the project have been defined and a contractor schedule has been developed, we will be
able to provide a more formal proposal for the requested testing services.
Thank you for your consideration,
JOHN H. Ross, P.E.
EAGLE ENGINEERING, INC.
2013 VAN BUREN AVENUE
INDIAN TRAIL, NC 28079
VOICE [phone]
TOLL FREE 866-EAGLENC
FAX [phone]
[e-mail]!„(NE.N1-!"
WWW.EAGLEONLINE.NET
Any attached files are for information use only. EEI assumes no responsibility for the accuracy
or the validity of any electronic data. All construction should follow signed and sealed
construction documents. The content of this email is the confidential property of EEI and
should not be copied, modified, retransmitted, or used for any purpose except with EEI's
written authorization. If you are not the intended recipient, please delete all copies and notify us
immediately.
http://us.mg l .mail.yalioo.com/dc/launch?.gx=0&.rand=9rpj7aa616n2d 4/17/2009

Preliminary
NPDE-S Permit Cost Estimate*
Operation and Maintenance
Radiator Specialty Company
Indian Trail, North Carolina
EPA I.D. NO. NCD091245969
Assumptions:
I ) No additional groundwater pretreatment will he required. in excess ofesisting air stripping system.
2) No air emissions controls will be required.
3) Pretreated groundwater will be discharged to the South Fork of Crooked Creek.
4) System will be operational for a 30-year period.
.9 No additional groundwater remcdialion wells will he required
Ire» a
E.slrnluted Cost (S)
I. 17.Iectricit% rii 3.0 1.11, x 0.7,16 Kwil IP x S0.07 / Kwh x 8760 hr. x 1 pumps
Llectricit',r 2.0 E 11' x 0.746 Kw/l IP x $0.07 / Kwh x 8760 hr. x 1 blower
Clectricil%- (W 1. q Hl" x 0.7.16 Kw/l IP.,, $0.07 / Kwh x 8760 hr. x 3 punip
Electricity u; M 1111 x 0.7d6 Kw/HP x $0.07 ; Kwh x 8761) hr. x I pump
2. Wastewater Monitoring
S 325.01) i sample " 4 events per year (Quarterly) -- Chronic 'Toxicity
S85.00 i sample " 2 events per rnonlh ' 2 samplcs (Influent & E:Ttlueru) - 62.1 analy%is
S 175.00 / sample 0 2 events per month • 2 samples (Influent & Effluent) w 625 analysis
i, Lalvr - Sampling and Reporting
3 hours 1 event ` 24 sampling events " I Horn (3 hrs • 555.001 hr. ' I person)
3 hours : report ` 12 reports ' 1 man (3 hrs • $90.00 ! hr • I person)
Miscellaneous: S 100.00 1 sampling ctvcnl " 12 events
4. h4iscellancous Maintenance on groundwater recovery system
Sublowl
10 % Contingenc.i
Total (:faurartrl)
Towl Estimated Cast j6 0 Years
*Cost estimate based on 2009 dollars
NPI)I S\COS'I'S.I)OC
lcf
C.(,
S 1.372.34
S 914.8x I,r;�Y i�
9
S 2.058.51
S 228.72
S 1.3.780.00
�4
S s.400.00 I
u-
3,000,0(
S 29.754.46 r�
S 2.975A
1-f 32.729.91
S 654.598.20

® RADIATOR SPECIALTY COMPANY
N� ® 600 Radiator Road, Indian Trail, NC 28079-5225
ATel:1.800.438.4532 FAX:[phone]
roo
May 18, 2009
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699
RE: Local Government Review Form
NPDES Permit Application
Radiator Specialty Company
Radiator Road, Indian Trail, North Carolina
Dear Sir:
As required in Section 4.0 of the Engineering Alternatives Analysis of the
National Pollutant Discharge Elimination System (NPDES) Permit Application,
Radiator Specialty Company (RSC) is submitting this notarized letter as evidence to
the Commission that the Town of Indian Trail failed to respond within fifteen (15)
days of signing the certified mail receipt stating they had received a copy of the
Application.
Please let us know if you have any questions or would like additional information.
Sincerely,
Radiator Specialty Company
&JO, I �
Stuart A. Kerkhoff, CHMM
C
Attachments
N PI)MATTAC HM ENTA. DOC
FOR MORE THAN 80 YEARS, RADIATOR SPECIALTY COMPANY HAS PRODUCED LUBRICANTS AND
CHEMICAL PRODUCTS TO HELP MAKE THINGS WORK BETTER

/oo1
Division of Water Quality
May 18, 2009
Page 2
State of � ff� D-M I OIL �, I I k.� , County of
On thisIIll
g day of ,
personally appeared before me, the said
nameLto me known and known to me to be the
person described in and o executed the foregoing document and he (or she)
acknowledged that he (or she) executed the same and being duly sworn by me, made oath
that the statements in the foregoing document are true.
My Commission expires U�,
(Signature of Notary Public
NOLI;V f' a- lic. Norfn Canocri'3
.. •'fir `��
NI'Ui:) AlH *AC IMEN I A.DOC
Public (Official Seal)

o%Q@p
• EAI.
RADIATOR SPECIALTY COMPANY
600 Radiator Road, Indian Trail, NC 28079-5225
Te1:1.800.438.4532 FAX:[phone]
VIA CERTIFIED MAIL
April 28, 2009
Ms. Peggy Piontek
Town Clerk
Town of Indian Trail
Post Office Box 2430
Indian Trail, North Carolina 28079
RE: Local Government Review Form
NPDES Permit Application
Radiator Specialty Company
Radiator Road, Indian Trail, North Carolina
Dear Ms. Piontek:
Radiator Specialty Company (RSC) is preparing to submit a National Pollutant
Discharge Elimination System (NPDES) Permit Application to the North Carolina
Department of Environment and Natural Resources (DENR) to discharge treated
groundwater to the South Fork of Crooked Creek. The Application requires a review by
local government to verify the proposed discharge complies with local ordinances.
Attached please find a Local Government Review Form to be completed by a
representative of Indian Trail. Included with this Review Form is a copy of the draft
NPDES Permit Application for your review. Upon receipt of the returned Review Form,
RSC will finalize the Permit Application for submission to the DENR.
Please complete the attached Review Form and return it to the following address.
Stuart Kerkhoff
Radiator Specialty Company
600 Radiator Road
Indian Trail, NC 28079
Please let us know if you have any questions or would like additional information.
We look forward to hearing from you.
FOR MORE THAN 80 YEARS, RADIATOR SPECIALTY COMPANY HAS PRODUCED LUBRICANTS AND
CHEMICAL PRODUCTS TO HELP MAKE THINGS WORK BETTER

Ms. Peggy Piontek
April 28, 2009
Page 2
Sincerely,
Radiator Specialty Company
1 Kj f:
Stuart A. Kerkhoff, CHMM V
Environmental Manager
Attachment
WDESNATTACHMENTA.DOC

Attachment A. Local Government Review Form
General„ Statute�yerview: North Carolina General Stahite 143-215.? (c)(6) allows input from local governments in the i<sust'ce
of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant: Prior to submitting an application for a NPDES Permit fora proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
• Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail, return receipt requested.
■ If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the certified
mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
• As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within the
15-day period.
Instructions to the Local Govemment: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Fam's
Name of local government Town of Indian Trail
(City/County)
Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes [ ] No [ ] If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ ) No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes [
No [ ]
Date Signature
(City Manager/County I4anager)
State of , County of
On this dace of -,personally appeared before me, the said
name to me known and known to me to be the person described in
and who executed the foregoing document and he (or she) acknowledged that he (or she) executed the same and being duly sworn
by me, made oath that the statements in the foregoing document are true.
My Commission expires .(Signature of Notary Public)
Notary Public (Official Seal)
EAA Guidance Document Version: June 23, 2005
Page 8 of 8

f
■ Complete items 1, 2, and 3. Also complete
Item 4 If Restricted Delivery Is deslred.
/ / / ❑ ant
X
■ Print your name and address on the reverse
ti" ❑ Addressee
so that we can return the card tdyou.
r Attach this card to the back of the mailpiece.
AeN
ELjved f pd Name) •
Ile r
C. Date of Delivery
or on the front If space permits.
I
1. Article Addressed to: '
D. la delivery adAess ditremfiom Item 1? ❑ Yes
(fin s, ?e5Sy
It YES, enter delivery address bel
owe o! T��•c� l�o: �
4 y':'.
,a
i�. $arVlCe nlpB
-�
-Fro.' o. I NC :2 r 19
' S
❑3 Registered Q
,
Retum Ra andlea
❑ Insured Mail ❑
•
4. Restricted Delivery? Ptnr Fee) ❑ Yes !
z Article Ru7009 0080
(lians/er from
rom servke laoe9
0001 4856 5474 i '
_.
PR Form 3811, February 2004 Domestic Return Receipt 10259s02Ate•164 I

RADIATOR SPECIALTY COMPANY
600 Radiator Road, Indian Trail, NC 28079-5225
Tel:[phone] FAX:[phone]
May 18, 2009
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699
RE: Local Government Review Form
NPDES Permit Application
Radiator Specialty Company
Radiator Road, Indian Trail, North Carolina
Dear Sir:
As required in Section 4.0 of the Engineering Alternatives Analysis of the
AON National Pollutant Discharge Elimination System (NPDES) Permit Application,
Radiator Specialty Company (RSC) is submitting this notarized letter as evidence to
the Commission that Union County failed to respond within fifteen (15) days of
signing the certified mail receipt stating they had received a copy of the Application.
�1
Please let us know if you have any questions or would like additional infonnation.
Sincerely,
Radiator Specialty Company
l.< ftiY 1
Stuart A. Kerkhoff, CHMIYGI V
Attachments
NPDESvaTTACHM ENTA_DOC
FOR MORE THAN 80 YEARS, RADIATOR SPECIALTY COMPANY HAS PRODUCED LUBRICANTS AND
CHEMICAL PRODUCTS TO HELP MAKE THINGS WORK BETTER

,A� Division of Water Quality
May 18, 2009
Page 2
State of , County of 11 j, Oki
On this 10 day of AU 4zq,
personally appeared before me, the said
name 8+4to me known and known to me to be the
person described in and who executed the foregoing document and he (or she)
acknowledged that he (or she) executed the same and being duly sworn by me, made oath
that the statements in the foregoing document are true.
M Commission expires JU
Y P
(Signature of Notary Public)
�► OFFICIAL SEAL
Notary Public, North Carolina
County of Cabarrvs
VICKIE L. KIMRAY
.�. res
M Canmisslon E**
%Oft` =,T)F'c n [_I ACHME\TA nOC'
Aic (Official 5 � _-

OLDV�
6a
RADIATOR SPECIALTY COMPANY
600 Radiator Road, Indian Trail, NC 28079-5225
Te1:1.800.438.4532 FAX:[phone]
VIA CERTIFIED MAIL
April 28, 2009
Ms. Lynn G. West
Clerk of County Commissioners
Union County
500 North Main Street
Monroe, North Carolina 28112
RE: Local Government Review Form
NPDES Permit Application
Radiator Specialty Company
Radiator Road, Indian Trail, North Carolina
Dear Ms. West:
Radiator Specialty Company (RSC) is preparing to submit a National Pollutant
Discharge Elimination System (NPDES) Permit Application to the North Carolina
Department of Environment and Natural Resources (DENR) to discharge treated
groundwater to the South Fork of Crooked Creek. The Application requires a review by
local government to verify the proposed discharge complies with local ordinances.
Attached please find a Local Government Review Form to be completed by a
representative of Union County. Included with this Review Form is a copy of the draft
NPDES Permit Application for your review. Upon receipt ofihe returned Review Form,
RSC will finalize the Permit Application for submission to the DENR.
Please complete the attached Review Form and return it to the following address.
Stuart Kerkhoff
Radiator Specialty Company
600 Radiator Road
Indian Trail, NC 28079
Please let us know if you have any questions or would like additional information.
We look forward to hearing from you:
FOR MORE THAN 80 YEARS, RADIATOR SPECIALTY COMPANY -HAS PRODUCED LUBRICANTS AND
CHEMICAL PRODUCTS TO HELP MAKE THINGS WORK BETTER

Ms. Lynn G. West
April 28, 2009
Page 2
Sincerely,
Radiator Specialty Company
D ,
Stuart A. Kerkhoff, CHMM
Environmental Manager
Attachment
e4w 1
WDES :ATTACHMENTA. DOC
/2"k1

11�
/WR
Attachment A. Local Government Review Form
CGenerai Statute Overview: North Carolina General Statute 143-215.1 (c)(ti) allows input from local governments in the is!Zuancc
of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental INIanagennent
Commission (EAdC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has
received a written statement from each city and counter government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
l stru tions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
■ Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail, return receipt requested.
■ If either (or both) local govemment(s) fail(s) to mail the completed form, as evidenced by the postmark on the certified
mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
• As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within the
15-day period.
Instructions to the LQcal Govemment: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government Union Counly
.(City/County)
Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes [ ] No [ ] If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ ] No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes [ ]
No[ j
Date Signature
(City Manager/County Manager)
State of , County of
On this day of , personally appeared before me, the said
name to me known and known to one to be the person described in
and ,who executed the foregoing document and he (or she) acknowledged that he (or she) executed the same and being duly sworn
by me, made oath that the statements in the foregoing document are true.
hiy Commission expires .(Signature of Notary Public)
Notary Public (Official Seal)
EAA Guidance Document Version: June 23, 2005
Page 8 of 8

f
■ Complete helms 1, 2, and 3. Also complete
Item 4If Restricted Delivery Is desired.
■ Pdnt your name and address on the reverse
so that vve can return the card to you.
■ Attacif this card to the back of the mailplece,
or an the front If space permits.
1. ANde Addressed to:
s [7.1, tie s i
�/tial COvn��(
�hA�l�se, RC a�kfr a
2. Article Number
(ri fer from service label)
Ps Form 3811. February 2004
_1p,
e.
le delivery addreee different from gem 1?
r YES, enter delivery address below.
3. Service Type
L9; bfled Mail 05press Meg
y ,episfered ❑ Return Receipt for Merchandise
ih lliaured Mail ❑ C.O.D.
-Restricted DelIVW (Gila Fee) ❑ Yes
7004 1390 0002 3308 5120
Domestic Retlan RecelPt

PIPE BURIAL DEPTH CALCULATIONS
Assume: 44nch diameter sch 40 PVC pipe to be buried 1.5 feet below grade.
Use most conservative input values from tables for depths of either 1 or 2 feet
(i.e., values that produce greatest deflection in formula)
5
W = 12.5
P = 1.81
PS = 307
E' = 0
%DEFLECTION = 3.128348
%DEFLECTION < 7.5 OK
Table 1
Medmum Reom omanded
Diametric Deflection
PVC Sewm/DreIn PI TA%
PV leoncel moults 5%
Obtain W from Table 2
TsbM 2
Live Loads on PVC Pipe
HCgm of
Live Load Transferred to Pipe, (108gtt')
Cover
Hghway
Railway
At
B
R20,
E60r
2
0.00
26.39
13.14
3
4.17
23.61
12.28
4
2.78
18.40
1127
5
1.74
16.67
10.09
6
1.39
16.03
8.79
7
1.22
12.15
7.85
8
0.69
11.11
6.93
10
7.64
6.09
12
5.58
4.70
14
4.17
3.05
is
3.47
2.29
18
2.78
1.91
20
2.08
1.53
22
1.91
1.14
24
1.74
1.05
26
1.39
28
1.06
'
3036
0.89
40
PIPE BURAIL CALCUALTIONS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Modified Iowa Equation
%DEFLECTION= 0.1(W., PI 100
0.149 (PSI +0.081E'
where:
% DEFLECTION = predicted percentage of dienwuic
deflection.
W' - Lt. Lose! (bslin'): pressure hanemlned M Me
pipe from tame on Me ground surface. Live Load values
are found in Table 2.
P- Msm Losd (Iballn'): preseum stone on the pipe
from Me weight M me sell column above Me pipe (also
called 'Dead Load'). Prism Load values ere found in
Table 3.
PS = Pipe Stiffness (lbslln'): a flexible pipe e
resistance to denectlon In an unburied state.
Pipe Some. values for WlPipe produces ere found In
Table 4.
E'= Modulus of Boll Reaction (Ibsen'): stiffness of
Me embedment sell. Values for Modulus of Sol Reaction
are found In ToW. 5.
PAGE 1 OF 2
Obtain P from Table 3
Sell Unit Weight (MAP)
1
0.69
0.76
0.83
0.87
2
1.39
1.53
1.67
1.74
1.81
3
2.08
2.29
250
2.60
4
2.78
3.08
3.33
3.47
3.61
5
3.47
3.62
4A7
4.34
4S1
6
4.17
4.68
5.00
5.21
5.42
]
4.86
6.35
5.83
6.08
5.32
6
5.56
6.11
6.67
6.94
7.22
9
6.25
6.88
7.50
7.81
8.13
10
a."
7.64
833
8.68
9.03
11
7.64
8.40
9.17
9.55
9.W
12
8.33
9.17
10.00
10A2
10.83
13
9.03
9.0
WAS
11.20
11.74
14
9.72
10.69
11.67
12.15
12.64
15
10.42
11.45
12.50
13.02
13.54
16
11.11
12.22
13.33
13.89
14.44
17
11.81
12.99
14AT
14.76
15.35
18
12.50
13.75
15.00
15.0
1625
19
1319
14.51
15.83
16.49
17.15
20
13.89
15.28
16.67
17.36
16.0e
21
14M
16.04
17.50
18.23
18.95
22
15.28
16.81
18.33
10.10
19.88
23
16.97
1].5]
1B.17
19.97
2076.
24
18.W
16.33
20.00
20.M
21.057
25
17.38
19.10
20.03
21.70
22.57
26
18.06
19.86
21.67
22.67
23A7
27
16.75
20.63
22.50
M."
24.38
28
le"
21.39
23.33
24.31
25.26
29
0.14
22.15
24.17
25.17
26.18
30
20.63
22.92
25.M
26.04
27.03
31
21.53
23.68
25.63
28.91
27.89
32
22.22
24."26.W
27.76
28.89
33
22.W
25.21
27.50
26.85
29.7E
34
23.61
25.W
28.M
]9.51
10.69
35
24.31
26.74
29.1]
30.38
3/.ad
36
25.00
27.50
30.00
31.25
32.60
37
25.69
28.26
30.83
32.12
33.d0
38
26.39
28.03
31.87
32.99
U 31
39
27-0e
29.76
32.50
33.85
35.21
40
27.78
WSW
33.33
34.72
38.11
41
28.47
31.32
34.17
35.59
37.01
42
29.17
32.08
35.00
36.46
37.92
43
29.86
32.85
35.83
37.33
38.82
44
30.56
33.61
36.67
38.19
39.72
45
31.25
34.W
37.50
39.06
40.63
46
31.94
36.14
W.33
39.93
41.53
47
32.64
35.90
39.17
40.80
42A3
48
33.33
W.67
40.00
41.07
43.33
49
34.03
37.43
ON
42.53
".24
50
34.72
38.19
41.67
43.40
45.14

Obtain PS kom Table 4
TWra
waPp eDaxx'IPa)
PM,Wtlaxk,0. e,O8q 80RWgp PpE
wCEM VkY U1M1Yn L
Resrve RSS,MI Rq Syyixr
Rpe Stlen555
(WI
1 (N7
3 64 ]
83
EB-m m
EB-2
51
m 51 N
Ea35 35
1m
OSOa1
125 25 22.5 5T
a 100 100 10
18D m 115
a6120 120
3W 21 Z24
315 13.5 BIB
W pj,.YNO GYnp. e,M Elecabrl LeD0,1b
PVC8b 113Nn E
SDRBS.waib
SauSdOh,SkSS 48
PWoplki ee
N BMnTWm,m VW CIIM1bv abPM.
(r l
sW2zenr a mWm,m PVu Bvmlxn a n5 pe.
%
% 35.1
.1M138
2.511
1% 1.0
ABTM D2IM-a.ein lax
SFx Am SSBxne
Lb'x°1 11
1% I.S08ee
3 19
2 598
a 11
2% ]Ba
9 ]
0 508
AWWA acSo w.v Plpw
a 1x
S W
� OR lent
10 18
ISO 25 1m
12 x
15U 1S 38a
200 10 815SLSI
�.
11� PyeW
% 17.O6S
AWWACWSWB Pipx
Raexlef wg Rim SDIfnxn
In m 1m
1 6.995
=5 18 3G
1% 3.83D
1% 2.811
2 1.w
204 2.141
BNW.W"S P CWWP"
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a B 8
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B 417
a mD
10 358
e m
12 w
PIPE BURAIL CALCUALTIONS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Obtain E' fmm Table 5
Table 3
AVERAGE VALUER OF MODULUS OF SOIL REACTION, E'(for Initial Flewble Pipe Deaeawn)
E' far DaB1es of
Compaction of
Pipe Bedding Materials
PI Zone Bsekilll,
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PAGE 2 OF 2

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