WQ0039924_Permit Renewal_20180501

�<' r State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0039924
Attn: Troy Doby Facility name: von Drehle Corporation - Cordova
From: Jim Barber
Fayetteville Regional Office
Note: This form has been adapted from the non -discharge facili1y staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 1 May 2018
b. Site visit conducted by: Jim Barber and Tony Honeycutt
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Chris Fowler and their contact information: (910) 410 - 9131 ext.
e. Driving directions: From Rockingham' take US Hwy 1 South approximately_3 miles and turn right at the
intersection of US 1 and Rosalyn road Drive approximately 2 miles and the von Drehle plant is on the right.
2. Discharge Point(s): N/A (residuals storage area behind the plant)
Latitude: 34.918454 / Longitude:-79.828977
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A (Hitchcock Creek is adjacent to the von Drehle plant site)
Classification: "C"
River Basin and Subbasin No.: Yadkin -Pee Dee (YAD16) (13-39-10)
Describe receiving stream features and pertinent downstream uses: From the von Drehle plant site to the
Pee Dee River is forest/woodlands on both sides the Hitchcock Creek.
i
U. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: Residuals Land Application -
Proposed flow: N/A Wastewater from belt pressed residuals and domestic flow are discharge to the City of
Rockingham collection system/wastewater treatment plant.
Current permitted flow: N/A Facility generates approximately_20 000 Dry Tons/year of paper residuals.
2. Are the new treatment facilities adequate for the type of waste and disposal system? ® Yes or ❑ No
If no, explain: Existin �lg and application program under permit W00005135 is adequate and will be supplemented
by the proposed Class A permit.
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ® N/A
If no, please explain: Most of the Vgper residuals to be managed under the Class A permit will be managed in
South Carolina Residuals that meet the Class A standard will be marketed to farmers' in_Richmond, Scotland,
Anson and Moore counties that have sandy soil profiles as a soil amendment (i.e Candor Wagram, Wakulla, etc.)
FORM: WQROSSR 04-14 Page 1 of 6

4. Do the plans .and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ® N/A
If no, please explain: No sites have been submitted with this permit application for a Class A residual.
5. Is the proposed residuals management plan adequate? ® Yes ❑ NoEl N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ® Yes ❑ No ❑ N/A
If no, please explain: Application rates will be similar to or slightly lower than historical application rates for the
existing Class B permit (WQ0005135).
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas. TemporM storage of paper residuals off of the belt'press at the plant
site is behind the von Drehle facility and material is removed daily duringpaper production to land application
fields. See attached site map of the von Drehle plant and residuals storage, area.
' -- ---- 8-�Is the proposed or existing groundwater monitoring programadequate?"❑Yes ❑ No � NfA-I--------^---
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes Z No- ❑ N/A
If yes, attach list of sites with restrictions (Certification B) _
Describe the residuals handling and utilization scheme:
10.' Possible toxic impacts to surface waters: N/A
11. Pretreatment Program (POTWs only): N/A
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Chris Fowler Certificate #: LA-1003082 Backup ORC: Bob Branch Certificate #:LA-15676
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ❑ Yes or ❑ No
If no, please explain:
Description of existing facilities:
Proposed flow:
Current permitted flow:
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be, important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No
If no, please explain:
4. , Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ❑ No
If yes, please explain:
5. Is the residuals management plan adequate? ❑ Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g.; hydraulic, nutrient) still acceptable? ❑ Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ❑ No
. If yes, attach a map showing conflict areas.
FORM: WQROSSR 04-14 Page 2 of 6

9. Is the description of the facilities as written in the -existing permit correct? ❑ Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ❑ N/A
If no, please explain:
L
FORM: WQROSSR 04-14
Page 3 of 6

11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ❑ N/A
If no, Please complete the following (expand table if 'necessary):
Monitoring Well
Latitude
Longitude
O `11 it
O 1 11
O 1 if
_ O / If
O / it
_ O 1 If
O / It `
O 1 If `
O / 11
O I 11
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ❑ Yes or ❑ No
Please summarize any findings resulting from this review:
Provide input to help the permit writer evaluate any requests for reduced monitoring,, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ❑ No
If yes, please explain:.
7
14. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the. existing permit been satisfied? ' ❑ Yes ❑ No ❑ N/A
If no, please explain: 1 11
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ❑No❑N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14
Page 4 of 6

IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please -explain:
\ 2.. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item Reason
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
^ l
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt,of needed additional information
_ r
® Issue.
❑ Deny (Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor: - 1", ��� Fo 2_
Date:
FORM: WQROSSR 04-14 Page 5 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The Von Drehle facilfty, especially the residuals storage area of the facility is not in the 100 yr floodplain of
Hitchcock Creek based on the NC floodplain m_pping website The site elevation is approx. 150 to 155 msl and the
flood elevation for Hitchcock Creek adjacent to the plant site, ranges from 141 to 147 msl.
Von Drehle currently manages paper residuals under a Class B land application permit (W00005135). Once the
allowable dry tons of residuals are land applied under the Class B permit; von Drehle's land application contractor
transports residuals to South Carolina for land application at Belger Farms under a permit 0088889) issued by
South Carolina Department of Health and Environmental Control (SCDHEC). Under the SCDHEC permit, Beiger
Farms is required to sample for PCBs once every 60 days. Von Drehle currently performs PCB sampling as required
by the SCDHEC permit and maintains this information in their permit files (see attached copy of a representative
analytical from1ZoAeis-&-Callcoft)-"Thefef6re'ifis recominended"that PCB sampling not be duplicated in -the Class A
permit Under the Monitoring and Reporting Requirements section of the Class A permit, condition #3 (see below
from the TRS Class A permit W00037413):
3. An analysis shall be conducted on the Industrial Product residuals at the frequency specified in
Attachment A, and the Permittee shall maintain the results for a minimum of five years. The analysis
shall include the following parameters '(the.regulatory level in milligrams per liter is in parentheses):
Aluminum
Mercury
Potassium
Ammonia -Nitrogen
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Plant Available Nitrogen
(by calculation)
Sodium Adsorption Ratio
(SAR)
Calcium
Percent Total Solids
TKN
Copper
pH
Zinc
Lead
Phosphorus
Polychlorinated biphenyls
Magnesium
Nitrate -Nitrite Nitrogen
-The upper limit for polychlorinated biphenyls that can be land applied is 50 mg/kg or 50 parts per
billion (ppb) pursuant to 15A NCAC 02T .1101(8) and under no conditions can residuals with a
concentration higher be land applied.
PCB sampling would be required if SCDHEC drops their samplingreguirement or if SCDHEC permit ND008889 is not
renewed If a similar condition to the one above is included in the new von Drehle permit, that last sentence needs to be
corrected to accurately describe the PCB limit as 50 mg/kgoparts per million (ppm) verses parts per billion.
The PCB detect in the Rogers & Callcot data is somewhat typical for the von Drehle paper residual and is well below the
50 mg/kg threshol& Evidently the source of PCBs in recycled paper comes from the carbonless paper used in production
duplicate and triplicate documents The backside of underlying sheets are coated to allow for the transfer of written info to
extra sheets Evidently as entities with historical paper files (i.e. local state federal governments manufacturing
companies retailers etc) transition to electronic files/filing and recycle paper documents;, the feedstocks that von Drehle
receives (and Cascades) will contain carbonless paper and therefore will contain PCB laden coatings (see attached article).
FORM: WQROSSR 04-14 Page 6 of 6

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Water Resources
ENVIRON14ENTAL GUALITr
IN ROY COOPER
GDYBIitOF
11ZiCHAEL S. REGAN
Serraims
LINDA CULPEPPER
Idaran Dirattor
May 08, 2018
Justin Dawkins - -- - - - -
Von Drehle Corporation _
126 1st St
Cordova, NC 28330
SUBJECT: Compliance Inspection Report
Von Drehle Corporation RLAP
Non -discharge -Permit No. WQ0005135
Richmond County
Dear Permittee:
The North Carolina Division of Water. Resources conducted an inspection of the von Drehle
Corporation RLAP on 5/01/2018. This inspection was conducted to verify that the facility is
operating in compliance with the conditions and limitations specified in Non -discharge Permit
No. WQ0005135. The findings and comments noted during this inspection are provided in the
enclosed copy of the inspection report entitled "Compliance Inspection Report".
If you should have any questions, please do not hesitate to contact Tony Honeycutt with
the Water Quality Regional Operations Section in the Fayetteville Regional Office at
910-433-3300 or via email at [e-mail].
J Sincerely,
- J.-Trent Allen,- Regional- Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division.of Water Resources, NCDEQ
Cc: Chris Fowler, ORC
s WQS Fayettevl[le Regional Office :-=(T
Central`Files
State of North Carolina i Environmental Quality I Water Resources
225 Green Street, Suite 714, Fayetteville, NC 28301-5043
910-433-3300

Comoliance Inspection Report
Permit: WQ0005135 Effective: 10/06/17 Expiration:. 09/30/22 Owner:
Von Drehle Corporation
SOC: Effective: Expiration: Facility:
von Drehle Corporation RLAP
County: Richmond
126 First St
Region: Fayetteville
Cordova NC 28330
Contact Person: Ken Downing Title:
i
Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Christopher C Fowler Certification: 1003082
Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/01/2018 Ei t Time: 10- OAM Exit Time:
01:OOPM
Primary Inspector: Tony W Hon
Phone: [phone]
Secondary Inspector(s)-
Reason for Inspection: Routine Inspection Type:
Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503 Exempt)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
Land Application Site
(See attachment summary)
Page: 1

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WATER POLLUTION CONTROL SYSTEM OPERATOR DESIGNATION FORM (WPCSOCC)
NCAC 15A 8G .0201
Press TAB to enter information (�
Perm€ttee Owner/Officer Name: T6 C -1'A j Mz , V c� MAWN,-FAoLw 18-;,tq
Malling Address: 12 t.- r; ivf,4 :1-(ae-,' Phone: g7LA "Ar, -?/3t
City: Cc e,dt ud State: !N14C Zip: 243 j &
Email Address: ee.:pjg4ygA4zLOAWdrek•ir -CQ.-
Signature: Date:
Facility Name: VejJ jNZai, B ,a q,a i Permit # k �` Dae 5-/.iS •.
County: Achmc
YOU MUST SUBMIT A SEPARATE FORM FOR EACH TYPE AND CLASSiF€CATION OF SYSTEM:
Facili Type: Select L- A'ja I : :0„ 1 ............
...:..
Facility Grade: Select ........:....::::
OPERATOR IN RESPONSIBLE CHARGE (ORC)
PrintFuIl Name: Work Phone: Mvo) c/l b- 13 /.3
Certificate Type: Select L /f Certificate Grade: SelectCertificate M /0 �� 0 g 2
Email Address: _'111Zi5 , Fn w [ E/t: ( (� [J�/ piZ.6 14 6,6 �C O/V -
Sgnature:Date: .
'7 certify that.l agree.to my designation as the operator In Responsible Charge for the facility noted. i understand and wUl abide by the
rules and regulations pertaining to the responsibilities of the ORC as set forth In 15A NCW 08G .0204 and falling to do so can result in '
DisciplinaryActions by the Water Pollution Control System operators Certification Commission."
Print Full Name: Ke &1 -7
Certificate Type: Select t
Small Address:
BACKUP ORC
Certificate Grade: Select
s ._ Work Phone: 3f,..- 1"/t-o s*
1 Certificate #: J -T6 74
Signature: �� �, Date:t/2o�%
"1 certify that I agree to my designation as a Back-up Operator in Responsible Charge for the fad ity noted, l understand and will abide by
the rules and regulations pertaining to the responsibllftles of the ORC ns set forth In 15A NC4C 08G .0204 and falling to do -so can result In
DisciplinoryActions by the Water Pollution Control system Operators Certification Commission."
Mail, fax or email WPCSOCC,1618 Mail Service Center, Fax: [phone] Email: certadmin@ncdeiir..gov
RIII61NAI, to: Raleigh, NC 27699.1618
Mail or Fax Asheville
a C- OPY to: 2090 US Hwy 70
Swanoanoa, NC28778
Fax:[phone]
Phone. [phone]
Washington
943 Washington 5q. Mall
Washington, NC 27899
Faw 252-946-9215
Phone: [phone]
Fayetteville
225 Green St., Suite 714
Fayetteville, NC 28301-SO43
Fax. [phone]
Phone: [phone]
Wilmington
127 Cardinal Dr.
Wilmington, NC 28405-2845
Fax,910-350-2004
Phone: 910-79&-7215
Mooresville
610 E. Center Ave., Suite 301
Mooresville, NC 28115
Fax,704-663-6040
Phone:[phone]
L
w1h3ton-$alem
45 W. Hanes Mall Rd.
Winston-Salem, NC27105
Fax!336-776-9797
Phone,336-776-9800
Raleigh
3800 Barrett Dr.
Raleigh, NC 27609
Fax:[phone]
Phone:[phone]
RWwW.rnote

i
_E KOY^ers &Callcott
ENVIRONMENTAL
Laboratory Report
Client von Drehle Corporation
Chris Fowler
PO -Box 36103
Charlotte, NC 28236
Dear Client:
Project:
Work Order:
Received:
Sludge
8011324 _
01/31/2018 07:50
Rogers and Callcott appreciates the opportunity to be of service to you. The attached laboratory services report includes analytical results and chain of
custody for samples that were received on January 31, 2018. Rogers and Callcott maintains a formal QA/QC program. Unless otherwise noted, all
analyses performed under NELAP certification have complied with all the requirements for the TNI standard The analyses met the QA/QC confidence
interval for each test method unless otherwise qualified. Estimated uncertainty is available upon request.
Privileged / Confidential information may be contained in this report and is intended only for the use of the addressee. If you are not the addressee, or the
person responsible for delivering to the person addressed, you may not copy or deliver this message to anyone else. If you receive this message by
mistake, please notify Rogers and Callcott immediately.
We strive to provide excellent service to our clients. Please contact Emily Howard, your Project Manager, at [e-mail] or
(864)-232-1556 if you have any questions about this report.
CC: Penny Wallace, Bob Branch (Branch Residuals)
Report Approved By:
Emily Howard
Project Manager
PO Box 5655 ' Greenville, SC 29606 426 FairforeSE Way ; Greenville, SC 29607 ' main 864.232J556 fax [phone] rogersandcallcott.com
- - — an employee -owned company
This report may not be reproduced, except in full, witbout written permission from Rogers & Callcott, Inc.
Page 1 of 10

Rogers &Cailcott_.
tq
if-----J ENVIRONMENTAL BO
South Carolina Greenville Laboratory Identification 23105
South Carolina Columbia Laboratory Identification 40572
Certificate of Analysis N6rth-_CaivlinaLaboratoryCerdficatiorilVwn--- '
'Norih Carolina Drinking WatefLab Number 45710
NELAP Utah Certificate Number SC000042014-1
Georgia Drtnling Water Lab ID 880
Client von Drehle Corporation Project: Sludge
Chris Fowler Work Order: 8011324
PO Box 36103 Received: 01/31/2018 07:50
Charlotte, NC 28236 -
Sample Number Sample Description Matrix Sampled
8011324-01 1 Sludge 01/30/18 14:00
8011324-02 2 Sludge 01/30/18 14:01
8011324-03 3 Sludge 01/30/18 14:01
8011324-04 4 Sludge 01/30/18 14:03
8011324-05 5 Sludge 01/30/18 14:04
8011324-06 6 Sludge 01/30/18 14:04
8011324-07 7 Sludge 01/30/18 14:06
8011324-08 8 Sludge 01/30/18 14:07
Type
PO Box 5655 Greenville, SC 29606 426 Fairforesc Way Greenville, SC 29607 main 864.232.1556 fax [phone] rogersandcallcott.com
-- - -- - an employee -owned company
0212712018 07:48 This report may not be reproduced, except in fuU, without written permission from Rogers & Callcott, Inc.
Page 2 of 10

s Rogers &Callcott
--; ENVIRONMENTAL
von Drehle Corporation Project: Sludge
PO Box 36103 Work Order: 8011324
Charlotte, NC 28236 Reported: 02/27/18 07:48
Case Narrative
Per client, South Carolina laboratory certification required for analysis of samples.
The sample was extracted and analyzed in accordance with SC DHEC Regulation 4444 concerning PCBs. The reporting limit
is less than or equal to the required limit of 1.0 mg/kg dry weight.
PCB 1242 was detected in sample 8011324.
i
1
PO Box 5655 Greenville, SC 29606 426 Fairforest Way Greenville, SC 29607 main 864.232.1556 fax 864.232.614o rogersandcallcott.corn
an employee -owned company
0212712018 07:48 This report may not be reproduced, except inf dl, without written permission from'Rogers & Callcott, Inc.
Page 3 of 10

Rogers &Callcott
- _b= ENVIRONMENTAL
von Drehle Corporation Project: , Sludge
PO Box 36103 Work Order: 8011324
Charlotte, NC 28236 Reported: 02/27/18 07:48
Sample Data
Sample Number 8011324-01.
Sample Description I collected on 01/30/18 14:00
Reporting
Parameter Result
Limit
Units DF Analyzed Method Flag Analyst Batch
Microbiological Parameters
Fecal Coliform, MPN 4960
4470
WN/g dry 1.00 01/31/18 10:35 SM 92210E-2006 SGM 138B0447
Wt
General Chemistry Parameters
-
Total Solids 40.3
0.100
% 1.00 01/31/18 12:00 Dry Weight RDA B8A1360
Sample Number 8011324-02
Sample Description 2 collected on 01/30/18 14:01
Reporting
Parameter Result Limit Units DF Analyzed Method Flag Analyst Batch
Microbiological Parameters
Fecal Coliform, NUN 5170 4650 WN/g dry 1.00- 01/31/18 10:35 SM 92210E-2006 SGM 138B0447
Wt
General Chemistry Parameters
Total Solids 38.7 0.100 % 1.00 01/31/18 12:00 Dry Weight RDA B8A1360
Sample Number 8011324-03
Sample Description 3 collected on 01/30/18 14:01
Reporting
Parameter Result Limit Units DF Analyzed Method Flag Analyst Batch
Microbiological Parameters
Fecal Coliform, MPN ND 4590 MPN/g dry 1.00 01/31/18 10:35 SM 92210E-2006 SGM B8130447
Wt
General Chemistry Parameters
Total Solids 39.2 0.100 % 1.00 01/31/18 12:00 Dry Weight RDA 138A1360
PO Box 5655 Greenville, SC 29606 426 Fait, orestWay Greenville. SC 29607 main 864,232.1556 fax [phone] rogersaildcallcott.com
an employee -owned company
- 0212712018 07.48 This report may not be reproduced, except infull, without written permission from Rogers & Callcott, Inc.
Page 4 of i 0

Rogers &Callcott
>•,- --._ - ENVIRONMENTAL
von Drehle Corporation Project: Sludge
PO Box 36103 - Work Order: 8011324
Charlotte, NC 28236 Reported: 02/27/18 07:48
Sample Number 8011324-04
Sample Description 4 collected on 01/30/18 14:03
Reporting
Parameter
- -- -- olt -_--Limit- -Units - DF - Analyzed ' - Method -- -Flag . - -Analyst-- - -Batch
Microbiological Parameters
Fecal Colifonn, MPN ND 4830 MPN/g dry 1.00 01/31/18 10:35 SM 92210E-2006 SGM 138B0447
Wt
General Chemistry Parameters
Total Solids 373 0.100 % 1.00 01/31/18 12:00 Dry -Weight RDA B8A1360
Sample Number 8011324-05
Sample Description 5 collected on 01/30/18 14:04
Reporting
Parameter Result Limit Units DF Analyzed Method Flag Analyst ' Batch
Microbiological Parameters
Fecal Colifonn, MPN 10200 4570 MPN/g dry 1.00 01/31/18 10:35 SM'92210E-2006 SGM 138130447
Wt
General Chemistry Parameters
Total Solids 1 39.4 0.100 % 1.00 01/31/18 12:00 Dry Weight RDA 138A1360
Sample Number 8011324-06
Sample Description 1 6 collected on 01/30/18 14:04
J
Reporting
Parameter Result Limit Units DF Analyzed Method Flag Analyst Batch
Microbiological Parameters
Fecal Colifonn, MPN 4960 4470 MPN/g dry 1.00 01/31/18 10:35 SM 92210E-2006 SGM B8B0447
Wt
General Chemistry Parameters
Total Solids 40.3 0.100 % 1.00 01/31/18 12:00 Dry Weight RDA B8A1360
Sample Number 8011324-07
Sample Description 7 collected on 01/30/18 14:06
Reporting
Parameter
Result Limit Units DF Analyzed Method Flag Analyst Batch
Microbiological Parameters
Fecal Colifotm, MPN ND 4510 WN/g dry 1.00 01/31/18 10:35 SM 92210E-2006
SGM B8B0447
Wt
General Chemistry Parameters
Total Solids 39.9 0.100 % 1.00 01/31/18 12:00 Dry Weight RDA 138A1360
i r
PO Box 5655 Greenville, SC 29606 ' 426 Fairforest Way Greenville, SC 29607 main 864.232.1556 fax [phone] rogersandcallcott.com
- -' - - - - - — -- an employee -owned company
0212712018 07.48 This report may not be reproduced, except infidt, without written permission from Rogers & Callcou, Inc.
Page 5 of—, -0

s, Rogers &Callcott
- ENVIRONMENTAL
von Drehle Corporation Project: Sludge
PO Box 36103 Work Order: 8011324
Charlotte, NC 28236 Reported: 02/27/18 07:48
Sample Number 8011324-08
Sample Description 8 collected on 01/30/18 14:07
Reporting
Parameter -- --
Result-
- -Limit
Units
DF
Analyzed
-Method
Flag
- . Analyst
-Batch
General Chemistry Parameters
Total Solids i
40.7
0.100
%
1.00
01131/1812:00
Dry Weight
RDA
B8A1360
PCBs
X
PCB-1016
ND
38.1
ug/kgdry
2.00
02/15/18 04:12
EPA 8082A
RKH
B8130288
PCB-1221
ND
38.1
ug/kgdry
2.00
02/15/18 04:12
EPA 8082A
RKH
B8B0288
PCB-1232 J
ND
38.1
ug/kgdry
2.00
02/15/18 04:12
EPA 8082A
RKH
MOM
PCB-1242 ' �D. 19fl l:r�J ?':
460,
76.3
Ug/kg drlY'l
2.00
02/23/18 04:25
EPA 8082A
Z
RKH
B8B0288
PCB-1248 l
ND
38.1
ug/kgdry
2.00
02/15/18 04:12
EPA 8082A
RICH
B8130288
PCB-1254
ND
38.1
ug/kg dry
2.00
02/15/18 04:12
EPA 8082A
RKH
B8B0288
PCB-1260
ND
38.1
ugtkg dry
2.00
02/15/18 04:12
EPA 8082A
RKH
138B0288
Surrogates
%REC
%REC Limits
Flag
2,4,5,6-Te1rach1,oro-m xylene 76 60-130
Decachlorobiphenyl 86 30-150
9
PO Box 5655 Greenville, SC 29606 426 Fairforest Way Greenville, SC 29607 main 864.232.1556 fax [phone] roge sandcallcott.Co171
- — — - -- an employee -owned company
0212712018 07.•48 This report may not be reproduced, except in full, without written permission from Rogers & Collcolt, Inc.
Page 6 of 10

_ Rogers &Callcott
ENVIRONMENTAL
von Drehle Corporation Project: Sludge
PO Box 36103 Work Order: 8011324
Charlotte, NC 28236 Reported: 02/27/18 07:48
Sample Preparation Data
Parameter Batch Sample ID Prepared Analyst
EPA 3550C Extraction
EPA 3550C - GC 138130288 8011324-08 02/07/2018 08:30 AAE
PO Box 5655 Greenville, SC 29606 426 Fairforest Way Greenville, SC 29607 main 864.232.1556 fax [phone] rogersandcallcott.com
�� --- — — ---- an employee -owned company '
0212712018 07.•48 This report may not be reproduced, except in full, without written permission from Rogers & Callcott, Inc.
Page 7 of 10

frpRogers cot
I,_;� ENVIRONMENTAL
von Drehle Corporation Project: Sludge
PO Box 36103 Work Order: 8011324
Charlotte, NC 28236 Reported: 02/27/18 07:48
Data Qualifiers and Definitions
ND Analyte NOT DETECTED at or above the reporting limit
NR Not reported
i
X Result subject to sample matrix interference. Reporting limit has been adjusted where applicable.
Z A mixture,of PCBs may be present in the sample. However, the pattern in the sample best matches PCB 1242.
l
FO Sox 5655 Greenville, SC 29606 426 Fairforest Way Greenville, SC 29607 main 864.232.1556 fax [phone] rogersalldcallcott.com
-- an employee -owned company
0212712018 07:48 This report may not be reproduced, except in full, without written permission from Rogers & Callcott, Inc.
Page 8 of 10

_ _ CHALN
Roger� �`���� —
k, ,_,_-__;�! ENVIRONMENTAL
° — -
Mailing PO Box 5655 Shipping 426 Fairfprest Way 2158 Stoneddge Drive
Address: Greenville,SC29606 Address: GreerMlle,SC29607 Columbia, SC29210
Phone [phone] Fax (WA) 232-6140 Phone (803) S09-M9
Client Name %A/ 010�j k6 C
Address % Z G /
Cs�n xb ti C-2
_
Report To: /fQ,C /y7✓ Llw
Par 'ouo i /.J'( ip u�/te n -/.5 ff&L Cd
Email Address S- / L- �--
Telephone # �l 6 ryr b /
PO # Project #
OF
-CUSTODY
RECORD
WORK
ORDER �bt122�
0
O
'
Z
ar
E
L°
Filtered (Yes/No)
Cooled (Yes/PIo)
Container Type(Plastic/Glass)
Container Volume (mL) -
sample Type (Grab/Composite)
Sample Source (WW, GW, DW, SW, 5, D—ther)
Preservation Codes)
A -None E-HCI I-ZnAcetate
B-HNO3 F-NaxSxOa J-HaPOa
C-1­12SO4 G-Boric Acid K-MCAA
D-NaOH H-AscorbiCAdd L-
1�
/
COMMENTS
R&C
WORK ORDER
VR /
DATE
/ 3Z)
TIME
•Z ;v1
SAMPLE DESCRIPTION
Z
z:'l
�
117,
-•�.
�/?3
L • 06
f
SAMPLER LIN UISHED BY:
DATE/TIME:
RECEIVED BY:
2. t�5
DATE/TIME:
Composite Start Date:
Composite -Start Time:
Time or .Flow (Circle one) Initials:
RE QUISHEDBY:
3. kAvS
DATE/TIME:
REC IV DBY:S
4• ' C
DATE/TINIE:
1.31.15 6}$_0
RELINQUISHED BY:
5
DATE/TIME:
RECEIVED BY:
6.
DATE/TIME:
Temperature of blank or representative sample
At time of collection 'C
At time of lab receipt 4.2 °C
Paae 9 of 10
RELINQUISHED BY:
7
)ATE/TIME:
RECEIVED BY:
B
DATEITIME:
Possible Hazards associated with samples: UNon-Hazard UFlammable (_�_Pkinirritant Drown Uummovm L_.tnu, r­..­
�--- ---

FOR LAB USE ONLY
Rogers &Callcott
ENVIRONMENTAL
Sample Receipt Verification
Date ` Work
Client: \ by\ ,� !Q Received: ` . i . Order: U uT
Carrier Name: Client FedEx UPS US lvlail Courier Field Services Other:
Tracking Number: l'�442E4y d��tallo S$Q{A
--- _
Receipt Criteria
Y
e
s
N.
o
A
-- - - -- ----
Comments
`
I Shipping container / cooler intact?
X.
Damaged Leaking Other:
Custody seals intact'?
COC included with samples?
COC signed when relinquished and received?
x
Sample bottles intact?
x
Damaged Leaking Other:
Sample ID on COC agree with label on bottle(s)?
Date / time on COC agree with label on bottle(s)?
x
Number of bottles on COC agrees with number of bottles received?
i Samplesreceived within holding time?
Sample volume sufficient for analysis?
VOA vials free of headspace (<6mm bubble)?
Samples cooled? Temp at receipt recorded on COC
p Temp measured with IR thermometer - SN: 97050067
Ice old PaC s Dry ICe None
Samples requiring pH preservation at proper pH?
Note: Samples for metals analysis may be preserved upon receipt in the lab.
Samples dechlorinated for parameters requiring chlorine removal at
the time of sample collection?
If in-house preservation used - record Lot 7
HCL
H3PO4
H2SO,
NaOH
HNO3
Other .
Comments:
0
l Were non-conformance issues noted at sample receipt? Yes or No
Non -Conformance issue other than rioted above: . -
Revised July 2014
Completed by:.
Page 10 of 10

PCBs
467
5. PRODUCTION, IMPORT/EXPORT, USE, AND DISPOSAL
5.1 PRODUCTION
Prior to the public's outcry concerning:the apparent link between PCBs and widespread environmental
problems and the discovery of their detrimental health effects, PCBs were produced commercially in the
United States from 1929 until 1977. Marketed worldwide under trade names such as Aroclor, Askarel,
and Therminol, the annual U.S. production peaked in 1970 with a total production volume of 85 million
pounds (39 million kg) of Aroclors. Between 1957 and 1971, 12 different types of Aroclors, with
chlorine contents ranging from 21 to 68% were produced in the United States. The manufacturing
process for Aroclors involved the chlorination of biphenyl with anhydrous chlorine in the presence of a
catalyst, such as iron filings or ferric chloride. The degree of chlorination, which determines the nature of
the Aroclor, was controlled by the chlorine -contact time (range, 12-36 hours) in the reactor. Late
production Aroclor 1254 (Aroclor 1254 "Late") was made by a two -stage chlorination procedure from
1974 to 1977. In the first stage, biphenyl was chlorinated to 42% chlorine content by weight as for
Aroclor 1242 production. This was then fractionated to give a distillate that was sold as Aroclor 1016 and
a residue that would have contained mostly the mono-ortho tetrachlorobiphenyls and higher homologs.
In the second stage, this residue, which contained about 49% chlorine, was further chlorinated to 54%
chlorine by weight, resulting in an Aroclor 1254 lot (Monsanto Lot KI-02-6024) with greatly increased
levels of the high TEF (i.e., 2,3,7,8-tetrachlorodibenzo p-dioxin ("dioxin") Equivalency Factor; "T" often
defined as "toxic") chlorobiphenyls. While production records suggest that Aroclor 1254 "Late"
represented <1% of.the total Aroclor 1254 production, the availability of this lot during the final years of
production resulted in the disproportionate use of Aroclor 1254 "Late" by standards suppliers and
researchers into Aroclor 1254 toxicity -(Brinkman et al. 1995; Durfee 1976; Frame 1999;.IARC 1978).
During production, Aroclor mixtures were contaminated by small amounts of polychlorinated
dibenzofurans (PCDFs) as impurities. Although PCDFs are formed during the pyrolysis of PCBs, in the
absence of fire, PCDF levels do not appear to increase during the normal use of PCBs in electrical
equipment. PCDFs have their own toxicological properties, which have been summarized in ATSDR
(1994). The concentration levels for tetra-, penta-, hexa-, and total PCDFs found in commercial PCB
mixtures are shown in Table 4-6 (de Voogt and Brinkman 1989).
Approximately 99% of the PCBs used by U.S. industry were produced by the Monsanto Chemical
Company in Sauget, Illinois, until production was stopped in August 1977. Prior to 1971, the Monsanto

PCBs 468
5. PRODUCTION, IMPORT/EXPORT, USE, AND DISPOSAL
Chemical Company produced Aroclors 1221, 1232,,1242, 1248; 1254, 1260, 1262, and 1268; however, in
1971, the company voluntarily restricted the uses of PCBs and subsequently produced only Aroclor 1016,
1242, 1254, and small quantities of Aroclor 1221. In 1974, the Monsanto Chemical Company produced
slightly more than 40 million pounds (18 million kg) of Aroclor'mixtures. Of the total volume of
Aroclors sold in the United States for that year, the percentages of the market for each of the Aroclors
were: Aroclor 1016, 64%; Aroclor 1242, 17.9%; Aroclor 1254, 17.9%; and Aroclor 1221, 0.1%. The
estimated, cumulative production and consumption volumes (in millions of pounds) of PCBs in the
United States from 1930 to 1975 were: total production, 1,400 (635 million kg); -imports,-3 (1.4 mi ion -- - _
kg); domestic sales, 1,253 (568 million kg); and exports, 150 (68 million kg). Section 5.3 provides
information on amounts estimated for specif c locations, as well as estimates of intermedia transfers of
PCBs (Durfee 1976; EPA 1976a; Hatton 1979; IARC 1978; Kimbrough 1987).
In 1976, the U.S. Congress charged EPA with regulating the manufacture, processing, distribution in
commerce, and use of PCBs. Currently -regulated pursuant to the Toxic Substances Control Act (TSCA)
and the Resource Conservation and Recovery Act (RCRA), the first set of effluent standards for PCBs
was issued by EPA in 1977; manufacturing and importing limitations regarding PCBs were issued in
1979. After subsequent amendments; the regulations stipulate that the production of PCBs in the United
States is generally banned, the use of PCB -containing materials still `in service is restricted, the discharge
of PCB -containing effluents is prohibited, the disposal of materials contaminated by PCBs is regulated,
and the import or export of PCBs is only permitted through an exemption granted from EPA (EPA 1977b,
1979a, 1979f, 1979g, 1988c, 1988e, 1998a).
5.2 IMPORT/EXPORT
Currently, the United States neither imports'nor exports PCBs. Section 6(e)(3)(A) of TSCA (Pub.-L.
94-969, 90 stat. 2003, 15 USC 2601 et. seq.) prohibited all manufacture and importation of PCBs after
January 1, 1979. On January 2, 1979, however, EPA announced that companies that had filed petitions
for exemptions from the PCB manufacturing/importation ban could continue manufacturing or import
activity until EPA acted on the application petition. As of July 7, 1997, the U.S. Court.of Appeals for the
Ninth Circuit overturned the Import for Disposal Rule. EPA can now only allow imports of PCBs by
'issuing exemptions to importers via the petition process under Section 6(e) of TSCA. See the
June 29, 1998 Federal Register for further discussion of EPA's PCB export and import regulations (EPA
1979a, 1998a).

PCBs 469
5. PRODUCTION, IMPORT/EXPORT, USE, AND DISPOSAL I
In 1973 and 1974, the United States imported PCBs mainly from Italy as decachlorobiphenyl (Fenclor),
and France (Phenoclor) (Durfee 1976). It is estimated that 180,000 kg (approximately 400,000 pounds)
of this compound were imported in 1974 (IARC 1978): The volume of PCBs imported through principal
U.S. custom districts from unspecified countries decreased from 132,000 kg (291,000 pounds) in 1976
(IARC 1978) and 280,867 pounds (127,400 kg) in 1977 to only 11,000 pounds (5,000 kg) in 1981
(USITC 1978, 1979, 1980; 1982). The Monsanto Chemical Company exported 5.4 million pounds
(2.45 million kg) of Aroclors 1016 and 1242 to unspecified countries in 1974 (Durfee 1976).
6.3 USE
Prior to 1974, PCBs were used both for nominally closed applications (e.g., capacitor and transformers,
and heat transfer and hydraulic fluids) and`in open=end applications (e.g., flame retardants, inks;?
Adhesives, microencapsulation:of dyes for carbonless-dupl>cating paper; paints, pesticide extenders,
plasticizers, polyolefin catalyst carriers, slide -mounting mediums for microscopes, surface coatings, wire
insulators, and metal coatings) (Durfee 1976; EPA 1976a, 1988c; IARC 1978; Orris et al. 1986; Safe
1984; Welsh 1995). Table 5-1 summarizes the former uses of the various Aroclors. Currently, under
40 CFR 761.80 (June 29, 1998), individual petitioners are granted 1-year exemptions to manufacture or
.import PCB for use solely in the manufacture or importer's own research for the development of PCB
disposal technologies. Also under 40 CFR 761.30 (June 29, 1998), individual petitioners are granted
exemptions for the use of PCBs as a mounting medium in microscopy, as an immersion oil in low
fluorescence microscopy, and as an optical liquid, as well as for analytical samples and research and
development use (EPA 1998a).
Except for the approximate 400,000 pounds (180,000 kg) of decachlorobiphenyl imported from Italy and
France used as filler for investment casting waxes (IARC 1978), most domestic use of PCBs was -
restricted to nominally closed applications by 1974 (IARC 1978). The production of capacitors and
transformers involved filling them with Aroclors through a small hole in the unit and then sealing the
hole.. While smaller capacitors contained smaller amounts, the production of large capacitors generally
required at least 2-3 pounds (1 kg) of Aroclors; many times that amount was required to produce the
transformers. By 1976, only 5% of the transformers produced in the United States were filled with PCBs,
accounting for 30% of the Monsanto Chemical Company's domestic sales; however, 95% of the
capacitors produced in the United States were filled with PCBs, accounting for 70% of the company's
domestic sales (IARC 1978). As of January 1979, Aroclors were no longer used in the production of
capacitors and transformers: Nevertheless, the life expectancy of transformers containing PCBs is greater

Table 5-1. Summary of Former End Uses for Various Aroclors
m
N
Aroclor
End use 1016 1221 1232 1242 1248 1254 1260 1262 1268
Capacitors
Transformers
Heat transfer
v
Hydraulics/lubricants 0
Hydraulic fluids C
Vacuum pumps 0
Gas -transmission turbines 3
0
o
Plasticizers: X
Rubbers x
U
0
Synthetic resins
Carbonless paper m
Miscellaneous: 'z
Adhesives o
rn
Wax extenders v
0
Dedusting agents
Inks
Cutting oils
Pesticide extenders
Sealants and caulking compounds
Source: IARC 1979
n

PCBs
5. PRODUCTION, IMPORT/EXPORT, USE, AND DISPOSAL
471
than 30 years, and the life.expectancy of capacitors ranges from 10 to 20 years, depending on the
electrical application (IARC 1978). In 1981, an estimated 131,200 transformers containing PCBs were in
service in the United States, representing approximately 1 % of all operational transformers. Currently,
the EPA maintains an up-to-date database containing the location and amount of PCBs in transformers
across the United States (EPA 1999b).
5.4 DISPOSAL
According to the Toxics Release Inventory (TRI), >99% of the"total PCB wastes produced in the United
States in 1998 were released on -site to land. About 3,742,000 pounds (1,698,000 kg) of PCB wastes were
released to land in 1998 (see Table 5-2) (TR198 2000).
The concentration of PCBs in the environment in which some action should be considered (i.e., treatment
or containment) will depend primarily on the exposure estimate determined during the baseline risk
assessment for the site and on EPA's 1996 cancer slope factor, reference dose (RfD), and exposure -
specific values (EPA 1990e, 1996c).
PCBs were included among the contaminants of concern at 500 of the 1,598 Superfund sites (29%) asof
May 11, 2000 which were listed on the Final National Priorities List (HazDat 2000). Remedial actions
taken at Superfund sites must meet the mandates of the National Contingency Plan (NCP), which
implements the requirements of the Comprehensive Environmental Response Compensation and Liability
Act (CERCLA) (EPA 1990e). CERCLA Section 121 provides specific statutory requirements (cleanup
standards) for remediation that must be addressed when evaluating proposed remedial alternatives (U.S.
Congress 1980). In order to ensure that the statutory requirements are met, the various proposed
alternatives are evaluated using nine evaluation criteria that reflect -these statutory requirements (U.S.
Congress 1980; EPA 1988j, 1989d, 1990e). The nine criteria are categorized into three groups: threshold
criteria, primary balancing criteria, and modifying criteria. The threshold criteria include the
requirements to provide overall protection of human health and the environment, and to comply with
applicable or relevant and appropriate (ARARs) federal and state laws (EPA 1988j, 1989d). The primary
balancing criteria include provisions for evaluating long-term effectiveness and permanence; the
reduction of contaminant toxicity, mobility, or volume; and short-term effectiveness for adverse health
effects from human exposure, implementability, and cost. The modifying criteria include state acceptance
and community acceptance (EPA 1988j, 1989d). While the primary balancing criteria are used to weigh
major tradeoffs among the proposed alternatives, and the modifying criteria are not taken into account
J

Table 5-2. Facilities that Manufacture'or Process Polychlorinated Biphenyls
m
N
Range of maximum
Facility
Location
amounts on -site in
Activities and uses
pounds.
Norcross Safety Prods. L.L.C.
Rock Island, Illinois
100-999
` Produce, by-product
Unison Transformer Services
Henderson, Kentucky
1,000-9,999
Ancillary/other use
Noranda Aluminum Inc.
New Madrid, Missouri
10,000-99,999
Ancillary/other use
Special Metals Corp.
New Hartford, New York
10,000-99,999
Ancillary/other use
0
0
Northwest Aluminum Co., Inc.
The Dalles, Oregon
10,000-99,999
Ancillary/other use
0
o
0
Source: TRI961998
0
\
-
M
•
m
x

PCBs
5. PRODUCTION, IMPORT/EXPORT, USE, AND DISPOSAL
473
until after public comments are received on the proposed remediation plans, an alternative must satisfy
the threshold criteria in order to be eligible for selection (EPA 1988j, 1989d).
On April 18, 1978, EPA began to regulate the storage and disposal of PCBs. These regulations specified
incineration as the`only acceptable method of PCB disposal unless, by reason of the inability to dispose of
the waste or contaminated materials in this manner, clearance was obtained from EPA to dispose of the
materials in another way. Although in March 1983 EPA issued a procedural amendment to the PCB rule
�to enable new disposal technologies to receive approval on a nationwide basis,—EPA's current-P - — - -
disposal rules generally require that PCBs at concentrations of - 50 ppm be disposed of in an incinerator
approved for that use (EPA 1998u). The recommended combustion criteria for the disposal of liquid"PCB
wastes by incineration is a 2-second dwell time at 1,200 - e (f100 - Q and 3% excess oxygen in the stack
gas; or a 1.5-second dwell time at 1,600 - C (t100 - e) and 2% excess oxygen (EPA 1979e). Since
incineration of PCBs will produce chlorine -containing products (e:g., hydrochloric acid), it is required
that water scrubbers be used to remove these products before releasing the emissions into the atmosphere
(EPA 1998u). Under TSCA (Toxic Substance and Control Act), the combustion efficiency of the
incinerator must be 99.9%, (EPA 1998u). The general acceptance of incineration as a means of disposal
for PCB -contaminated materials has declined because of concerns about incomplete incineration and the
possible formation of highly toxic dioxins and dibenzofurans if the combustion temperature is not held
sufficiently high (Arbon et al. 1994; Chuang et al. 1995). An evaluation of the applicability of oxy-fuel
technology to waste incineration conducted by Baukal et al. (1994) reported favorable results. The test
results indicated that for simulated soils containing 1% PCBs and oil containing up to 40% PCBs, more
than 99.9999% of the PCBs were destroyed. In controlled experiments conducted by Chuang et al.
(1995), significant dechlorination was noted at 300 -C and a fully dechlorinated product occurred at
400 - C when heating a mixture of PCBs (Aroclor 1221 and 1254) and iron metal powder (Fe°) in a
muffle furnace.
The regulatory requirements implemented pursuant to TSCA also provide that chemical waste landfills
and high -efficiency boilers meeting specified operating requirements are appropriate disposal facilities for
mineral oil dielectric fluid from PCB -contaminated electrical equipment containing PCBs at
concentrations - 50 ppm, but <500 ppm. Under the land disposal restrictions promulgated at 40 GFR part
268 pursuant to RCRA (Resource Conservation & Recovery Act), PCBs are regulated as halogenated
organic compounds (HOCs). Types of waste for which land disposal is prohibited include liquid
hazardous wastes containing PCBs at concentrations of - 50 ppm; nonliquid hazardous waste containing
HOCs in total concentration greater than or equal to 1,000 mg/kg (ppm); and liquid HOC -containing

PCBs
5. PRODUCTION, IMPORT/EXPORT, USE, AND DISPOSAL
474
waste that are primarily water and contain HOCs in the concentration range 1,000-10,000 mg/L (ppm)
HOCs. The treatment standards expressed as specified technologies (e.g., chemical reduction, carbon
adsorption, biodegradation) require incineration of liquid hazardous waste containing PCBs at a
concentration of 500 ppm or greater, and HOC -containing waste prohibited from land disposal (EPA
1986i, 1987c, 1987d, 1998u).
Although not widely adopted, other methods proposed for the destruction of PCBs have included wet air
oxidation, biodegradation, metal -promoted dehalbgendtion; and eldctrolytic reduction -(Chuang et -a .--_ -
1995). Timberlake and Garbaciak (1995) detailed the results of a series of bench -scale tests applying
various technologies (thermal desorption, solvent extraction, wet air oxidation, and an incineration
process known as Anaerobic Thermal Process [ATP]) to PCB -contaminated sediment. The thermal
desorption and solvent extraction technologies, though not designed to destroy the contaminants,
indirectly separate the contaminants from a solid matrix and concentrate them into smaller volumes of
treatable oily residues. The removal efficiencies of these technologies when applied to three of the river
sediments tested ranged from 96 to 99%. The wet air oxidation process, which uses elevated
temperatures and pressure to oxidize the organic constituents, was not very effective in destroying PCBs;
it achieved only a 34% removal efficiency (Timberlake and Garbaciak 1995). Zhang and Rusling (1995)
investigated electrochemical catalytic dechlorination as a method for decontaminating soils. The study
achieved a 94% dechlorination level using a lead cathode and a,micro emulsion of didodecylmethyl-
ammonium bromide, dodecane, and water for soils containing 6.5% organic matter and contaminated with
14% Aroclor 1260 (84 mg of PCB).
A chemical destruction method that has been used for the treatment of PCBs in contaminated dielectric
liquids or soil is based on the. reaction of a polyethylene glycol/potassium hydroxide mixture with PCBs
(De Filippis et al. 1997). This method can be used successfully for the destruction of higher chlorinated
PCBs with an efficiency of>99%, but was found to be unsuitable for the treatment of di- and
trichlorobiphenyls due to low destruction efficiencies (Sabata et al. 1993). Irradiation of PCBs in
isooctane and transformer oil by y-radiation resulted in degradation of PCBs to less chlorinated PCBs and
PCB -solvent adducts (Arbon et al. 1996). Supercritical fluid technology has shown promise as a method
for extraction of PCBs from soils, coupled with supercritical water oxidation of the extracted PCBs
(Tavlarides 1993, 1998a). Hofelt and Shea (1997) demonstrated the use of semipermeable membrane
devices to accumulate PCBs from New Bedford Harbor, Massachusetts water. Another method showing
some promise for the treatment of PCBs in water, soil, and sediment is titanium dioxide -catalyzed
photodecomposition with sunlight (Hong et al. 1998; Huang et al. 1996; Zhang and Rusling 1995; Zhang

PCBs 475
5. PRODUCTION, IMPORT/EXPORT, USE, AND DISPOSAL
et al. 1993). PCBs in used lubricating oils were destroyed and petroleum products, including lubricating
oils, were produced with catalytic vacuum distillation/hydrotreatment technology (Brinkman et al. 1995).
Treatment with metallic sodium has-been suggested for PCB wastes because it yields low molecular
weight polypropylene and sodium chloride which are less undesirable than products from incineration
(IRPTC 1985). Bioremediation of PCB -contaminated soil has been suggested using a combination of
anaerobic and aerobic treatments. Aerobic -treatments would metabolize the lower chlorinated homologs
(e.g., biphenyl; mono- and di-ortho chloro-substituted CBs) produced in soil from anaerobic
dechlorination prom esses.(Tiedje et al. 1993; see Section 6.3.2.3).

PUBLIC NOTICE
SC Department of Health and Environmental Control
Bureau of Water
2600 Bull Street
Columbia, South Carolina 29201
Public Notice No. 17-011-M Date: February 10, 2017
NOTICE OF PROPOSED MODIFICATION OF A
STATE'LAND APPLICATION SYSTEM PERMIT
The South Carolina Department rof Health and Environmental Control (DHEC) proposes to modify the State
Land Application System Permit (commonly called a No Discharge or ND Permit) #ND0088889, issued to
BELGER FARMS CO INC/LAND APP SITES, (SUMTER COUNTY/SUMTER EQC OFFICE) PO BOX 894, CAMDEN, SC 29021-
-0894 ---The- fa:cility--is--located-ory-mu-lt-iple---l-and- application- sites totaling. approximately-_9,-399_acres____
located in Chesterfield, Fairfield, Kershaw, Lee and Sumter counties. The facility discharge land
application of wastewater residuals from food processing and paper recycling facilities as an
agricultural resource to farm fields. The Standard Industrial Classification (SIC) Code for the
facility is 0711. A fact sheet is available.
The proposed modifications are as follows:
1. New land application sites have been added.
2. Part V.B has been updated to add the. non-food based sludge from paper recycling facility.
Persons wishing to comment on'or object to the permit modifications are invited to submit same in
writing within thirty (30) days -of the date of this notice to the attention of: Ms. Julie Song; SC
DHEC; Water Facilities Permitting Division; 2600 Bull Street, Columbia, South Carolina 29201;
Telephone: [phone]. The permit number should be placed at the top of the first page of
comments. When there is a significant degree of public interest -.in a permit or group of permits, the
Department may hold a public hearing. SC DHEC is not in in zoning, land use, or property value
issues. Please contact your local County or Municipal officials for questions or concerns on these
issues.
All comments received within the 30-day period will be considered in the formulation of final
determinations regarding the permit. All persons submitting written,comments will be notified of the
final determinations. Requests for adjudicatory hearings may be filed after the above described
determinations have been made. Additional information regarding adjudicatory hearings is available
from the Legal Office at the above Department address or by calling 803-898-3350.
Additional information on proposed permit determinations and on hearing procedures is available by
writing or calling the Department at the above address or telephone number. Copies of a specific
application or draft permit of interest to an individual, organization, or company must be requested
in writing. A fee schedule has been established for processing these requests: Reproduction of
documents - $0.25 per page. Requests must be mailed to the Freedom of Information Office at 2600
Bull Street, Columbia, SC 29201, phone number: 803-898-3882; or requests may be faxed to the Freedom
of Information Office at 803-898-3816. Arrangements can be made to review all the permit information
at the Freedom of Information Office on the third floor of the Sims Building across from Peeples
Auditorium.
Please bring the foregoing to the.attention of persons you know will be interested in this matter.
J

RFG'o -// 4olty
{
State of North Carolina
Department of Environmental Quality
Division of Water Resources
'` _ WATER QUALITY REGIONAL OPERATIONS SECTION
Dio Water Resources NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
April 16, 2018
7I- C'�6}� AIG
To: RO-VLQROS` TTrent lien /-Mark-Brantldy7 -
APR 1 8.2018
From: Troy Doby, Water Quality Permitting Section - Non -Discharge Permitting Unit
�NQ
Permit Number: wQoory Permit Type: Distribution of Residual Solids (503 Exempt)
Applicant: von Drehle Corporation
Owner Type: Organization
Facility Name: von Drehle Corporation DCAR
Signature Authority: Justin Dawkins
Address: 126 First.St., Cordova, NC 28330,
Fee Category: Non -Discharge Major
Comments/Other Information:
Project Type: New Project
Owner in.BIMS? Yes I
Facility in BIMS? Yds. N
Title: Plant Manager
County: Richmond
Fee Amount: $1,310 - New Project
Attached-, you will find, all information submitted in support of the above -referenced application for your review,
comment, and/or action. Within 45calendar days, please take the following actions:
® Return this form completed. Return a completed staff report.
❑ Attach an Attachment B for :Certification.. ❑ Issue an Attachment B Certification.
When you receive this request form; please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer: �MJm
Date: -)161
FORM: WQROSNDARR 09-15
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