NC0085383_Complete File - Historical_19991210

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
December 10, 1999
EDWARD T. PERKINS
WHTTSETT TEXACO-HUFFMAN
PO BOX 730
BURLINGTON NC 27216
Subject: Rescission of NPDES & Nondischarge Permits
Permit No. NCO085383 & W00005853
WHTTSETTTEXACO-HUFFMAN
Alamance County
Dear EDWARD PERKINS:
Reference is made for rescission of the subject NPDES & Nondischarge Permits.
Staff of the Groundwater Section — Winston — Salem Regional Office have confirmed
that these Permits are no longer required. Therefore, NPDES Permit No. NCO085383 &
WQ0005853 are rescinded, effective immediately.
If in the future you wish to again operate a pump and treat wastewater facility in
North Carolina, you must first apply for and receive new Permits. Operating a facility
without a valid Permits will subject the responsible party to a civil penalty of up to
$10,000 per day.
If it would be helpful to discuss this matter further, I would suggest that you contact
the Water Quality staff, Winston-Salem Groundwater Section Regional Office at (336)
771-4600.
Sincere ,
Kerr T. Stevens
cc: Alamance County Health Department
Winston-Salem - Water Quality Regional Supervisor - w/attachments
Point Source Branch - Dave Goodrich
Non Discharge Branch — Kevin Barnett- w/attachments
Operator Training and Certification
Point Source Compliance - Robert Farmer - w/attachments
Mr. Roosevelt Childress, EPA
Fran McPherson, DWQ Budget Office
Central Files - w/attachments
Fran McPherson, DWQ Budget Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10 % post -consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
April 29, 1996
Mr. Edward Perkins
Huffman Oil Company
Post Office Box 730
Burlington, North Carolina 27216
[D FE F1
Subject: NPDES Permit Issuance
Permit No. NCO085383
Whitsett Texaco
Guilford County
Dear Mr. Perkins:
In accordance with the application for a discharge permit received on October 30, 1995, the Division is
forwarding herewith the subject NPDES permit. This permit is issued pursuant to the requirements of North
Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency dated December 6, 1983.
There is only one change to NPDES draft permit no. NCO085383. Special Condition E has been
incorporated into the Effluent Limitations and Monitoring Requirements sheet as a footnote.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of
this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447,
Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision shall be final and binding.
Please take note that this permit is not transferable. Part II, EA. addresses the requirements to be followed
in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources or any other
Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Paul B. Clark at telephone number
[phone], extension 580.
Sincerely,
Original Signed By
David it Goodrich
A. Preston Howard, Jr., P.E.
Enclosure
cc: Central Files
Winston-Salem Regional Office, Water Quality Section
Mr. Roosevelt Childress, EPA
S its and Engineering Unit
Facility Assessment Unit
Technical Assistance & Certification Group
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Permit No. NCO085383
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Huffman Oil Company
is hereby authorized to discharge wastewater from a facility located at
Whitsett Texaco
7116 Burlington Road
Whitsett
Guilford County
to receiving waters designated as an unnamed tributary to Back Creek in the Cape Fear River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III, and IV hereof.
The permit shall become effective June 1, 1996
This permit and the authorization to discharge shall expire at midnight on June 30, 2001
Signed this day April 29, 1996
Original Signed By
David A. Goodrich
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

SUPPLEMENT TO PERMIT COVER SHEET
Huffman Oil Company
is hereby authorized to:
Permit No. NC0085383
After receiving an Authorization to Construct from the Division of Environmental
Management, construct and operate a 0.01008 MGD groundwater remediation treatment
facility located at 7200 Burlington Road, Whitsett, Guilford County (See Part III of this
permit), and
2. Discharge wastewater from said treatment works at the location specified on the attached
map into an unnamed tributary to Back Creek which is classified Class C-NSW waters in the
Cape Fear River Basin.

ROAD CLASSIFICATION
PRIMARY HIVY LIGHT -DUTY ROAD. HARD OR
HARD SURFACE.--- - IMPROVED SURFACE...
SECONDARY HWY
HARD SURFACE.... =3111111111= UNIMPROVED ROAD...
Latitude 36 04 36 Longitude 79 33 49
Map # C20SE Sub -basin 03-06-02
Stream Class C-NSW
Discharge Class
Receiving Stream LIT to Back Creek
Design Q 0.01008 Permit expires
SCALE 1:24 000
0 1 MILE
0 7000 FEET
1 0 1 KILOMETER
CONTOUR INTERVAL 10 FEET
QUAD LOCATION Huffman OilMhitsett Texaco
NCO085383
Guilford County
Groundwater Remediation

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Permit No. NCO085383
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated
wastewater from an unleaded gasoline contaminated groundwater remediation system from outfall(s) serial number 001. Such discharges
shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Measurement Sample Sample
Monthly Avg. Weekly Avg, Daily Max. Frequency Type Location
Flow 1 0.01008 MGD Continuous Recording Influent or Effl
Total Suspended Solids
Oil and Grease
Benzene
Toluene
Ethylbenzene
Xylene
Methyl Ter -Butyl Ether
1,2 - Dichloroethane
30.0 mg/l
414.4 ug/1
11.0 ug/1
574.6 ug/1
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
1, 1,2 - Trichloroethane 243.8 ug/1 Monthly
Iron Monthly
Manganese Monthly
Footnotes:
I If the discharge is not continuous, flow maybe monitored weekly by an instantaneous flow estimate.
Grab
Grab 2
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
2 The grab sample for oil and grease should be skimmed from the surface in a quiescent zone, such as a holding tank, if possible.
See Special Condition, Part III, Condition E.
Effluent sampling shall be conducted prior to mixing with any other waste stream.
After one year of data have been collected, permittee can request data review and consideration of decreased monitoring.
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent

State of North Carolina IT
Department of Environment,
Health and Natural Resources CIA
Division of Environmental Management
rV�r
James B. Hunt, Jr., Governor L
Jonathan B. Howes, Secretary [D E'---i N
A. Preston Howard, Jr., P.E., Director
April 29, 1996
Mr. Edward Perkins
Huffman Oil Company
Post Office Box 730
Burlington, North Carolina 27216
Subject: Permit No. NCO085383
Authorization to Construct
Groundwater Remediation System
Whitsett Texaco
Guilford County
Dear Mr. Perkins:
A letter of request for an Authorization to Construct was received October 30, 1995 by the Division
and final plans and specifications for the subject project have been reviewed and found to be satisfactory.
Authorization is hereby granted for the construction and installation of the groundwater remediation
treatment system consisting of three recovery pumps, a stabilization tank, an oil/water separator, a transfer
pump, an air stripping tower, a holding tank, a second transfer pump, a particle filter, a carbon filtration
unit, and all necessary appurtenances with discharge of treated groundwater into an unnamed tributary to
Back Creek in the Cape Fear River basin.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of NPDES
Permit No. NCO085383 issued April 29, 1996 and shall be subject to revocation unless the groundwater
remediation treatment facilities are constructed in accordance with the conditions and limitations specified
in Permit No. NC0085383.
Any sludge generated from this treatment facility must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Environmental Management.
In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions, the Permittee shall take immediate corrective action, including those as may be required by this
Division, such as the construction of additional or replacement wastewater treatment or disposal facilities.
The Winston-Salem Regional Office, telephone number 704/663-6040, shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an in -place inspection can be
made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00
a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays.
Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC
27626-0535.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Perkins
April 29, 1996
Page 2
A copy of the approved plans and specifications shall be maintained on file by the Permittee for the
life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Environmental Management in accordance with
North Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from complying
with any and all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Paul Clark, telephone number 919/733-5083
extension 580.
Sincy,
.�+�. Preston Howard, Jr., P.E.
cc: Central Files G
Winston-Salem Regional Office, Water Quality
Training and Certification Unit
Facility Assessment Unit

the(opigroup
January 10, 2002
ITCorporntion ofNorth Carolina, Inc.
2200 Gateway Centre Boulevard, Suite 205
Morrisville, NC27560-9122
Tel. [phone]
Fier. 919. 67.2299
A Member The Group [ram II
c l z
o
Mr. Michael Myers t` 1
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
300O2
71G'2402
Subject: Request for Permit Rescission
NPDES Permit NC0086860
Sears Logistic Services, Inc. Facility
2701 Branchwood Drive
Greensboro, NC 27408
Dear Mr. Myers:
� _ED
IT Corporation of North Carolina, Inc., on behalf of Sears Logistic Services, Inc., requests that the
subject National Pollutant Discharge Elimination System (NPDES) permit be officially rescinded.
The permitted groundwater treatment system was taken off line on September 28, 2001 due to
difficulties in maintaining compliance with the permit requirements related to chronic toxicity. Due
to these difficulties and associated costs, groundwater recovery and treatment operations are to
be permanently suspended. The treatment system is scheduled to be disassembled and removed
from the site during the first calendar quarter of 2002. Remediation of the site will proceed by
other means.
Should you have any questions regarding this request, please contact Chuck or Keith at (919)
467-2227, extensions 236 and 224, respectively.
Rrati in Carolina, Inc.
�Charles A. Be. R. Keith Ogden, P.E., RSM
Project Engineer Senior Project Manager
cc: Tom Grandys — SLS, Inc.
Sherri Knight— NCDENR—Winston Salem Regional Office

@6
ff Coaporason ofNorth Carolina, InG
Y •
thev%*oup-
yr
December 1. 2000
Ms. Christie Jackson
North Carolina Department of Environment, and Natural Resources
Division of Water Quality— NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
2200 Gateway Centre Boulevard, Suite 205
Morrisville, NC 27560-9122
TeL [phone]
Fax. [phone]
A Member of The IT Croup
Subject: NPDES Authorization to Construct — Engineer's Certification
ATC Project Number: 086860ACA
W.P. Ballard Property
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
NCDENR Groundwater Incident # 6953
NPDES Draft Permit NCO086860
Dear Ms. Jackson:
IT Corporation of North Carolina, Inc., on behalf of Sears Logistics Services, Inc., is submitting the enclosed
Engineer's Certification for the completion of the construction of a groundwater recovery and treatment system
in Greensboro, North Carolina. The system has been installed to address a dissolved phase chlorinated
solvent plume. IT Corporation plans to begin operation of the installed facilities during the week of December
6-10, 2000. In accordance with the Authorization to Construct, we contacted the Water Quality Section in the
Winston-Salem Regional Office today by telephone to provide the required 48-hour advance notification.
If you have any questions, please contact Keith Ogden or Chuck Bertz at [phone].
Sincerely,
IT Corporation Of North Carolina, Inc.
�(�27
Charles A. Bert , E.
Project Engineer
Enclosures: Engineer's Certification
cc: Tom Grandys (Sears Logistics Services, Inc)
Winston-Salem Regional Office, Water Quality
file
Keith Ogdd n�SM
Senior Project Manager

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
�*A
NCDEMf
PROFESSIONAL ENGINEER'S CERTIFICATION
FOR,
ATC.PROJECT NUMBER: 086860ACA
Sears Logistic Facility - W.B. Ballard Property
NPDES Permit No. NCO086860
GOVE
DEC - 4 M
t=n i BRANCH
I, 61421,E 5 A• Se:O-T$ , am a duly registered Professional Engineer
(please print)
in the State of North Carolina and have been authorized to observe (circle one eriodically weekly, full
time) the construction of the subject project for the Permittee:
Project No.: 086860ACA
Project: Sears Logistic Services, Inc. - W.B Ballard Property
Groundwater Recovery and Remediation System
Guilford County
Location: WB Ballard Property
Greensboro
The project consists of:
Installation of a Groundwater Recovery and Remediation System consisting of the following
components:
• Influent surge tank
• Influent transfer pump
Trayed stripper
• Dual Particulate filters
Dual GAC filters
• Effluent surge tank
• Discharge transfer pump
Mw DivW= of Water Quality hereby
acknowledges receipt and aceepiance of
dds EnSWM Certification
/z s
I hereby certify that I did regularly observe this project with due care and diligence and that the
construction was completed in substantial conformance with the Authorization to Construct and with the
approved plans d specifications.
Signature Registration No. AI C Z4417-
Date /2•0l 00
Upon completion of construction and prior to operation of the modified facility, the Permittee shall provide the
Division with a certification from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct, and the approved plans and specifications_
The Certification should be submitted to:
NCDENRIDWQ, NPDES Unit, 1617Mail Service Center; Raleigh, North Carolina 27699-16/7

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
Mr. Tom Grandy
Sears Logistic Services
3333 Beverly Road
Department 824RE A3-276A
Hoffman Estates, Illinois 60179
Dear Mr. Grandy:
e�A
NCDENR
September 22, 2000
Subject: Authorization to Construct
ATC No. 086860ACA
NPDES Permit No. NCO086860
Sears Logistic Services, Inc. - W.B. Ballard Property
Guilford County
The Division of Water Quality's NPDES Unit has reviewed your request for an Authorization to Construct a
groundwater recovery and remediation system at the Sears Logistic Services - W.B. Ballard Property. The
Division finds the proposed improvements to be satisfactory and hereby grants authorization for the
following:
• Influent surge tank
• Influent transfer pump
• Trayed stripper
• Dual Particulate filters
• Dual GAC filters
• Effluent surge tank
• Discharge transfer pump
• Associated piping, valves, instrumentation, pumps and blowers
This Authorization to Construct is issued in accordance with NPDES Permit No. NC0086860, issued
September 20, 2000, and shall be subject to revocation unless the wastewater treatment facilities are
constructed in accordance with the terms and conditions of the permit.
The Permittee shall notify the Water Quality Supervisor of the Winston-Salem Regional Office, telephone
number [phone], at least forty-eight (48) hours prior to operation of the installed facilities, so that an
in -place inspection can be made. Notification shall be made during the normal office hours of 8:00 a.m. until
5:00 p.m., Monday through Friday.
Recommendations
It is recommended that the dual GAC filters be operated in series and monitored for breakthrough at a point
between the two filters. Operating the filters in this manner assures that the effluent will be filtered even
after the carbon in the lead filter is spent, allowing that filter to be removed from service and the carbon
regenerated.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Internet: http://h2o.enr.state.nc.usl

Sears Logistic Services, Inc - W.B. Ballard Property
NPDES Permit No. NCO086860
ATC No. 086860ACA
Page 2
Engineer's Certification
Upon completion of construction and prior to operation of the modified facility, the Permittee shall provide
the Division with a certification (copy enclosed) from a professional engineer registered in North Carolina
certifying that the permitted facility has been installed in accordance with the NPDES Permit, this
Authorization to Construct, and the approved plans and specifications. The Certification should be submitted
to: NCDENR / DWQ, NPDES Unit, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Additional Reauirements
The Operational Agreement between the Permittee and the Environmental Management Commission is
incorporated herein by reference and is a condition of this Permit. Noncompliance with the terms of the
Operational Agreement shall subject the Permittee to all sanctions provided by G. S. 143-215.6 for violation
of or failure to act in accordance with the terms and conditions of this Permit.
Failure to abide by the requirements contained in this Authorization to Construct may subject the Permittee
to an enforcement action by the Division of Water Quality in accordance with North Carolina General Statute
143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (local,
state, and federal) which have jurisdiction.
The Permittee shall maintain a copy of the approved plans and specifications on file for the life of the
facility. One (1) copy of the approved plans and specifications is enclosed for your records.
If you have any questions about this Authorization to Construct, please contact Mike Myers, at (919) 733-
5083, extension 508.
Sincerely,
' 1
,&31 __�
Kerr T. Stevens
Director
Enclosures: Project Plans and Specifications (approved)
Engineer's Certification Form
cc: Winston-Salem Regional Office, Water Quality
Technical Assistance and Certification Unit
Central Files
NPDES Unit Files
Mr. Charles Benz, P.E. - IT Corporation
2200 Gateway Centre Boulevard, Suite 205
Morrisville, North Carolina 27560-9122

%► State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
November 15, 2000
Mr. Tom Grandvs
Logistic Real Estate Manager
3333 Beverly Road
Department 824RE A3-276A
Hoffman Estates, Illinois 60179
©
r' � ' '
�A
�� � M
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL REsouRCE5
Subject: Issuance of NPDES Permit NCO086860
Sears Logistic Services, Inc.
Guilford County
Dear Mr. Grandys:
Division personnel have reviewed and approved your application for the subject permit. Accordingly, we are
forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North
Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency dated May 9, 1994 (or as subsequently amended).
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of
this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh,
North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management .Act or any other Federal or Local governmental permit that may be
required.
If you have any questions concerning this permit, please contact Michael Myers at telephone number (919)
733-5083, extension 508.
Sincerely,
Original Signed By
David A Goodrich
Kerr T. Stevens
cc: Central Files
Winston-Salem Regional Office/Water Quality Section
VS Unit
Point Source Compliance Enforcement Unit
Aquatic Toxicology Unit
Charles Bertz — IT Corporation
2200 Gateway Centre Boulevard, Suite 205
Morrisville, North Carolina 27560-9122
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer VISITUSONTHEINTERNET@hftp:/lh2o.enr,state.nc.us/NPDES

Permit Number: NCO086860
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and
the Federal Water Pollution Control Act, as amended,
Sears Logistics Services, Inc.
is hereby authorized to discharge wastewater from a facility located at
Sears Logistic Services, Inc.
2701 Branchwood Drive
Greensboro
Guilford County
to receiving waters designated as an unnamed tributary to Philadelphia Lake in the Cape Fear
River Basin in accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, II, III and IV hereof.
This permit shall become effective December 1, 2000.
This permit and authorization to discharge shall expire at midnight on October 31, 2005.
Signed this day November 15, 2000.
original Signed BY
pavid A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number: NCO086860
y
SUPPLEMENT TO PERMIT COVER SHEET
Sears Logistic Services, Inc.
is hereby authorized to:
1. After receiving an Authorization to Construct from the Division of Water Quality, construct and
operate a groundwater remediation facility with an ultimate design capacity of 0.072 MGD, and
2. Discharge treated groundwater from said treatment works at the location specified on the attached
map through outfall(s) 001, into an unnamed tributary to Philadelphia Lake, which is classified
C-NSW waters in the Cape Fear River Basin.

Permit NC0086860.
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge treated groundwater from outfall(s) 001. Such discharges shall
be limited and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Locationl
Flow'
0.072 MGD
Continuous
Recording
E or I
Total Suspended Solids
30.0 m /L
Monthly
Grab
E
Oil and Grease2
Monthly
Grab
E
Lead3
Monthly
Grab
E
Iron
Monthly
Grab
E
Manganese
Monthly
Grab
E
Benzene
71.4 /L
Monthly
Grab
E
Toluene
11.0 /L
Monthly
Grab
E
Carbon Tetrachloride
4.4 /L
Monthly
Grab
E
1,1 —Dichloroethene
3.2 /L
Monthly
Grab
E
1,2 — Dichloropropane
39.0 /L
Monthly
Grab
E
Trichloroethene
81.0 /L
Monthly
Grab
E
Tetrachloroethene
8.85 /L
Monthly
Grab
E
1,1,2—Trichloroelhane
42.0 /L
Monthly
Grab
E
Vinyl Chloride
Monthly
Grab
E
Eth (benzene
Monthly
Grab
E
X lenes (Total)
Monthly
Grab
E
1,2-Dichloroethane
Monthly
Grab
E
1,2-Dichlorobenzene4
Monthly
Grab
E
1,3-Dichlorobenzene4
Monthly
Grab
E
Methylene Chloride4
Monthly
Grab
E
Chloroform4
Monthly
Grab
E
1,2-Dibromomethane4
Monthly
Grab
E
1,1-Dichloroethane
Monthly
Grab
E
1,2-Dichloroethane
Monthly
Grab
E
cis-1,2-Dichloroethene
Monthly
Grab
E
Trans-1,2-Dichlorothene
Monthly
Grab
E
Na lhalene4
Monthly
Grab
E
1,1,2,2-Tetrachloroethene
Monthly
Grab
E
1,1,1-Trichloroelhane
Monthly
Grab
E
1,3,5-Trimeth Ibenzene4
Monthly
Grab
E
1,2,4-Trimeth Ibenzene4
Monthly
Grab
E
Bromoform4
Monthly
Grab
E
Methyl tert-but I ether MTBE
Monthly
Grab
E
EPA Method 624/625 Full Suite)
Annually
Grab
E
Total Nitrogen
Monthly
Grab
E
Chronic Toxicit s
Quarterly
Composite
E

Permit NC0086860
ti
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — Continued.
Footnotes:
1. Sample Location: E — Effluent, I — Influent
2. The grab sample for oil and grease should be skimmed from the surface in a quiescent cone, such
as a holding tank, if possible.
3. If after one year of sampling (12 sampling events) lead has not been detected above 25.0 µg/L, the
may request that the Division evaluate removing lead as a condition for the permit.
4. If after one year of sampling (12 sampling events) this analtye has not been detected above the
quantitation limit, the permittee may request that the Division evaluate removing that parameter
as a condition for the permit.
5. Chronic P/F (Cerriodaphnia) ® 90%, February, May, August, November.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCOO8686O-.,_..
A.(2.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia
duhia at an effluent concentration of 9017b.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina
Phase Il Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of February, May, August, November. Effluent sampling for this testing shall be performed at
the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter' results in a failure or ChV below the permit limit, then
multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure' (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration
having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable
impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and
further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure'
(Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and T7P313
for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the
end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the
effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee
will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit
number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the
form. The report shall be submitted to the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required
during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality
indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring
requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival,
minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial
monitoring.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0086860
Facility Information
Applicant/Facility Name:
Sears Logistic Services, Inc.
Applicant Address:
3333 Beverly Road Department 824RE A3-276A
Facility Address:
2701 Branchwood Road, Greensboro, NC 27408
Permitted Flow
0.072 MGD
Type of Waste:
Groundwater remediation
Facility/Permit Status:
New
County:
Guilford
Miscellaneous
Receiving Stream:
UT to
Philadelphia Lake
Regional Office:
Winston-Salem
Stream Classification:_
C NSW
USGS Topo Quad:
C 19 SE
303(d) Listed?:
No
Permit Writer:
Michael Myers
Subbasin:
03-06-02
Date:
May 20, 2000
Drainage Area (mi2):
<0.1 mil
4*�
Summer 7Q10 (cfs)
0.0
Winter 7Q10 (cfs):
0.0
Average Flow (cfs):
<0.1
IWC (%):
100%
Primary SIC Code:
SUMMARY
Sears Logistic Services has applied for an NPDES permit to discharge treated groundwater to an
Unnamed Tributary to Philadelphia Creek. The proposed system would require a permitted flow of 72,
000 gpd.
The discharge location is located above the Jordan Lake watershed in subbasin 03-06-02 of the Cape Fear
River Basin. The receiving water is not listed on the state's 303(d) list and has been evaluated as
meeting its designated uses. As noted the discharge location is above the Jordan Lake watershed and is
considered a nutrient sensitive water. Since the permitted flow is greater than 50, 000 gpd and the
discharge is into NSW waters the permit is subject to House Bill 515.
Limit Development:
Flow — The flow limit was developed based on information provided by the permittee on the anticipated
flow from the facility.
Total Suspended Solids — The limit for TSS was based on the fact that groundwater remediation system
are subject to elevated solids content and as such are a condition for the general permit for petroleum
contaminated groundwater remediation system general permits. Since this facility has the potential for
solids and additionally is partially contaminated with petroleum products this parameter was included as
a condition for the permit. The monitoring frequencies was based on BPJ and the sample type was based
on current Division policy.
Oil and Grease — Due to the nature of the contamination and the fact the oil and grease may be
introduced into the wastewater through normal maintenance activities. Oil and Grease shall be
monitored. Since petroleum products are one of the sources of contamination oil and grease monitoring
was included as stipulated in the general permit for petroleum based groundwater remediation systems.
The monitoring frequencies was based on BPJ and the sample type was based on current Division policy.
Pact"ilwct
\1'DES Renewal
Paee I

Lead — Since the contamination is petroleum based, the monitoring of lead has been incorporated as
stipulated in the general permit for petroleum based groundwater remediation systems. The monitoring
frequencies was based on BPJ and the sample type was based on current Division policy.
Iron and Manganese — Groundwater in the Piedmont is subject to elevated levels of iron and manganese.
Therefore monitoring has been included as a condition for the permit. Additionally, iron and manganese
monitoring is useful for Division personnel in assessing when the carbon in the GAC filter has been
spent. The monitoring frequencies was based on BPJ and the sample type was based on current Division
policy.
Individual Volatile Organic Compounds — Using the data supplied by the permittee, individual
compounds that have been detectedfr
part of the site assessment have monitoring requirements as part of
the permit. For those parameters water quality criteria exist, the more strigent of the chronic or
acute criteria were used to set the lit assuming zero dilution. The monitoring frequencies � based on
BPJ and the sample type was based on current Division policy. w"Y-
EPA method 6241625 — Annual monitoring of the full suite of volatile and semi -volatile organic
compounds shall be required in to assess possible degradation byproducts that have not been detected to
date. The monitoring frequencies was based on BPJ and the sample type was based on current Division
policy.
Total Nitrogen monitoring — TN monitoring has been included per House Bill 515. The monitoring
frequencies was based on BPJ and the sample type was based on current Division policy.
Total Phosphorus — The TP limit and monitoring has been incorporated according to House Bill 515. The
monitoring frequencies yms based on BPJ and the sample type was based on current Division policy.
Chronic Toxicity — The toxicity test is included per the Division's Toxicity Policy to assess the possible
synergistic affects of the numerous toxicants. Since the facility discharges to a zero flow stream toxicity
test shall be perform a concentration of 90%. The monitoring frequencies was based on BPJ and the
sample type was based on current Division policy.
TOXICITY TESTING:
Recommended Requirement: Chronic using Cerriodaphnia P/F @ 90%
INSTREAM MONITORING:
None proposed.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: July 26, 2000
Permit Scheduled to Issue: September 11, 2000
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact Michael Myers
at [phone] ext. 508.
p4m1�Jsvif -W UA/)t ► "AIL-r—� 173s A- Pe" .
NPDES SUPERVISOR:
Pact Sheet
NPDFS Renewal
Page 2

REGIONAL OFFICE COMMENT:
NAME: DATE:
Pact Shccl
NPDES Renewal
Pa,e 3

cc: Permits and Engineering
Guilford County Health Dept.
Central Files
WSRO
SOC PRIORITY PROJECT: Yes _ No x
If Yes, SOC No.
To: Permits and Engineering Unit
Water Quality Section
Attention: Michael Myers
Date: August 31, 2000
NPDES STAFF REPORT AND RECOMMENDATION
County: Guilford
Permit No. NCO086860
ATC Number 086860ACA
PART I - GENERAL INFORMATION
1. Facility and Address: W.P. Ballard property
2701 Branchwood Drive
Greensboro, NC
••ll� 4i1�
DENR - WATER DUALITY
PAINT SOURCE BRANCH
Facility contact: Mr. Charles Bertz, P.E.
IT Corporation of North Carolina, Inc.
2200 Gateway Centre Blvd, Suite 205
Morrisville, NC 27560-9122
[phone]
2. Date of Investigation: August 29, 2000
3. Report Prepared by: Jenny Rankin
4. Persons Contacted and Telephone Number: Charles Bertz, IT Corporation of North Carolina, Inc. (919)
467-2227
5. Directions to Site: From Winston-Salem take I-40 East to Wendover Ave. Take the second exit for
Wendover and turn right at the top of the ramp so you are heading east on Wendover. Turn left on
Battleground Ave. (Hwy 220). Turn right on Rollins Road Branchwood Drive.
6. Discharge Points(s), List for all discharge points:
Latitude:36°06'29" Longitude:79°49'27"
U.S.G.S. Quad No.D19SE U.S.G.S. Quad Name Greensboro
7. Site size and expansion area consistent with application? X Yes —No If No, explain:
S. Topography (relationship to flood plain included): The site is located in Greensboro in a very urban setting.
The facility is located above the headwaters of the U.T. to Philadelphia Lake.
9. Location of nearest dwelling: <200 feet

0. Receiving stream or affected surface waters: Unnamed tributary to Philadelphia Lake
a. Classification: C NSW
b. River Basin and Subbasin No.: 03-06-02
C. Describe receiving stream features and pertinent downstream uses: The treatment system will
discharge into a storm drain about 250 feet away. The storm drain discharges into UT to
Philadelphia Lake. Philadelphia Lake flows into Buffalo Lake which drains into White Oak Lake.
Part H - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
a. Volume of Wastewater to be permitted: 0.072 MGD (Ultimate Design Capacity)
b. What is the current permitted capacity of the Waste Water Treatment facility? N/A
C. Actual treatment capacity of the current facility (current design capacity)?
N/A
d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the
previous two years. N/A
e. Please provide a description of existing or substantially constructed wastewater treatment facilities.
N/A
f. Please provide a description of proposed wastewater treatment facilities. The proposed
groundwater treatment system will consist of a deep high vacuum dual phase (HVDP) extraction
system (recovering groundwater and soil vapors from 29 wells) and a shallow low vacuum soil
vapor extraction (SVE) system (recovering soil vapors from 14 wells). Groundwater recovery and
recovered soil vapors will be done using downhole submersible pneumatic pumps and the
recovered groundwater will be conveyed from the individual recovery wells to the treatment
system through a network of subsurface process pipe. Recovered groundwater will be conveyed to
an influent surge tank prior to being processed by the treatment system. Recovered soil vapors will
be processed through a moisture separation vessel prior to treatment. The treatment system will
consist of an air stripper, particulate filters and granular activated carbon. The discharge from the
treatment system will be conveyed to an,effluent surge tank. Treated water will be discharged to
an existing storm sewer catch basin located down gradient of the W.P. Ballard property on the
former Sears Logistics Services property.
g. Possible toxic impacts to surface waters: The following contaminants have been detected in the
groundwater: PCE, TCE, 1,1-DCE, cis-1,2-DCE, trans-1,2-DCE, Methylene chloride, 1,1,1-TCA,
1,1,2-TCA, 1,1-DCA, Chloroform, 1,2-Dichloropropane, Benzene, Toluene, Napthalene,
Carbontetrachloride.
h. Pretreatment Program (POTWs only): N/A
in development _ approved
should be required _ not needed _
2. Residuals handling and utilization/disposal scheme: All residuals will be bound in the filters.
3. Treatment plant classification (attach completed rating sheet). N/A
4. SIC Code(s): 5541
Primary 66 Secondary
Page 2

Main Treatment Unit Code: 5 6 0 0
PART IH - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies involved.
(municipals only)? N/A
2. Special monitoring or limitations (including toxicity) requests: N/A
3. Important SOC, IOC or Compliance Schedule dates: (Please indicate) N/A
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available.
Please provide regional perspective for each option evaluated.
Spray Irrigation: The continuous production of effluent by the treatment system as well as the
residential/commercial nature of the adjacent properties does not facilitate this option.
Connection to Regional Sewer System: Connection to sewer is not an option.
Subsurface: Land was not deemed suitable to reintroduce remediated groundwater to the
impacted aquifer through injection wells or infiltration galleries.
PART IV - EVALUATION AND RECOMMENDATIONS
The Winston-Salem Regional Office recommends issuance of permit and Authorization to Construction for
the Sears Logistic Services, Inc. Groundwater Remediation System.
tmu �WUK' 9-1-00
Signature of report preparer
D
Water Qu ' Regional Supervisor
S-00
Date
Page 3

s cvri,ki2 CQ l
26144
News & Record
Published by
News & Record, Inc. ( 5
Greensboro, North Carolina i llU .} J z, ao
North Carolina, Guilford County
AFFIDAVIT OF PUBLICATION [`
Before the undersigned, a Notary Public of said County and State, duly
commissioned, qualified and authorized by law to administer oaths,
personally appeared Lolita Cousin who being first duly sworn, deposes
and says:
1. That she is the Publishers Representative of the Greensboro News &
Record, Inc. a corporation, engaged in the publication of newspapers
known as "News & Record", published, issued and entered as second
class mail in the City of Greensboro in said County and State;
2. That she is authorized to make this affidavit and sworn statement; that
the notice or other legal advertisement, a true copy of which is
attached hereto, was published in the News & Record on the
following dates: July 21, 2000 for Notification of Intent to Issue a
NPDES Wastewater Permit and placed through NCDENR
Div. of Water Quality
3. That the said newspaper (or newspapers) in which such notice, paper,
document, or legal advertisement was published was, at the time of
each and every such publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of the General
Statutes of North Carolina and was a qualified newspaper within the
meaning of Section 1-597 of the General Statutes of North Carolina.
This 21 day of July, 2000
Publishers Representative
Sworn to and subscribed before me, this 21
Notary Public
My commission expires: April 10, 2001
T- PARRISH
NOTARY PUBLIC
ALAMANCE COUNTY, No
Commission Expires 4-10.20011

the(49roup
January 19, 2000
Ms. Christie Jackson
North Carolina Department of Environment, and Natural Resources
Division of Water Quality — NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NPDES Permit Application
W.P. Ballard Property
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
NCDENR Groundwater Incident # 6953
Dear Ms. Jackson:
►TCo-ponwon eivorfh
1000 Perimeter Park Drive, Suite 1
Morrisville, NC 27560-9291
Tel. [phone]
Fax. [phone]
d Member of The IT Croup
L.
i
r .
IT Corporation of North Carolina, Inc., on behalf of Sears Logistics Services, Inc., is submitting three (3)
copies of a NPDES Permit Application for the operation of a groundwater recovery and treatment system in
Greensboro, North Carolina. The system is proposed to be installed to address a dissolved phase chlorinated
solvent plume. This permit application has been prepared pursuant to North Carolina Administrative Code 2H
.0105. Additionally, Mr. Michael Myer of the NPDES Unit has been consulted in the preparation of this
application.
If you have any questions or concerns regarding the permit application or the proposed remediation
system, please contact Keith Ogden at [phone].
Sincerely,
IT CORPORATION OF NORTH CAROLINA
Charles A. Bartz, E. R. Keith Ogden, P. E., RSM
Project Engineer Senior Project Manager
Enclosures: NPDES Permit Application — Short Form C-GW (3 copies)
Engineering Alternative Analysis (3 copies)
cc: Tom Grandys (Sears Logistics Services, Inc)
file

ff Corporation ofNorfb QuwHmy hie.
thev1*0up
April 26, 2000
Mr. Michael Myer.
North Carolina Department of Environment, and Natural Resources
Division of Water Quality — NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NPDES Permit Application
W.P. Ballard Property
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
NCDENR Groundwater Incident # 6953
Dear Mr. Myers:
1000 Perimeter Park Drive, Suite I
Morrisville, NC 27560-9291
Tel. [phone]
Fax. [phone]
A Member of The IT Croup
P
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In response to your telephone call with our Mr. Charles Bertz today, I am writing to clarify several aspects
of our NPDES permit application, submitted on January 19, 2000.
• A Non -Discharge permit application is not being prepared for subsurface re -injection of treated
groundwater.
• For the present value cost analysis of alternatives included in Appendix C, an interest rate of 3% and
a period of 3 years were used.
If you have any additional questions regarding the permit application, please contact Keith Ogden at (919)
467-2227, ext 224 or Charles Bertz at ext. 236
Sincerely,
IT CORP(
Charles A. Begz, P
Project Engineer
NORTH CAROLINA
cc: Tom Grandys (Sears Logistics Services, Inc)
file
R. Keith Ogden, P. E., RSM
Senior Project Manager

® REMITTANCE ADVICE
DETACH AND RETAIN THIS PORTION FOR
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NC DEPARTMENT OF THE ENVIRONMENT
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1.
2.
NPDES PERMIT APPLICATION - SHORT FORM C-GW
To be filed by persons engaged in groundwater remediation projects
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit NCOO f� & i0
Please print or type
Applicant and facility producing discharge
A. Name Sears Logistics Services, Inc.
B. Mailing address of applicant:
1. Street address 3333 Beverly Road: Department 824RE A3-276A
2. City Hoffman Estates
3. County Not Applicable
4. State Illinois
5. Zip Code 60179
Telephone Number ( 847
) 645-5324 (Tom Grandys)
Fax Number ( 847
) 645-4264 (Tom Grandvs)
e-mail address: tgrandys hotmail.com
C. Location of facility:
1. Street 2701 Branchwood Drive
2. City Greensboro
3. County Guilford
4. State North Carolina
5. Zip Code 27408
Telephone Number (
) currently not available
Fax Number (
) currently not available
Standard Industrial Classification (SIC) code(s) (if known
3. This application is for a: ® New Permit ❑ Permit Renewal ❑ Permit Modification
4.
5.
E
If this application is for a permit renewal, record the permit number: NC00
Product(s) recovered (circle all that apply): Gasoline Diesel fuel Solvents
Other (describe) tetrachloroethene and its reductive dechlorination by-products
(a) Check here if discharge occurs all year ® , or
(b) Circle the month(s) in which discharge occurs: January February March April
May June July August September October November December
(c) Days per week discharge
Volume of wastewater discharged to receiving stream(s): 72,000 GPD*
*Gallons per operating day
7. Check here if wastewater is discharged directly to the receiving stream(s) ❑
If not, state the specific discharge location: Stormwater catchbasin, see location on attached Site Map
Mark the path taken by the wastewater to the receiving stream(s) on the site map. If a storm sewer is the only viable
means of discharge, trace the route of the storm sewer to its discharge point(s).
Short Form C-GW
Version 6-99

NPDES PERMIT APPLICATION - SHORT FORM C-GW
To be filed by persons engaged in groundwater remediation projects
8. Number of separate discharge points: One
NOTE: If the facility has separate discharge points (outfalls), include a schematic diagram of
wastewater flow at the facility.
9. Name of receiving water(s): Unnamed tributary of Philadelphia and Buffalo Lakes
This application package must include the items listed below. This application will be returned if the
reguired items are not included.
o A USGS topographical map (or copy of the relevant portion) which shows all outfalls
❑ A report of altematives to surface water discharge as outlined by the Division's "Guidance for Evaluation of Wastewater Disposal
Alternatives" (required by 15A NCAC 2H.0105 (c))
❑ A summary of the most recent analytical results containing the maximum values for each chemical detected
Applications for new fun -permitted) discharges must also include the items listed below. This
❑ An engineering proposal describing the remediation project in detail (required by 15A NCAC 21-1.0105 (c))
❑ A list of any chemicals found in detectable amounts at the site, with the maximum observed concentration reported for each chemical
(the most recent sample must be collected less than one year prior to the date of this application)
❑ A summary of analytical results containing the maximum values for each chemical detected
❑ The removal efficiency of each compound detected (if known)
For fuel remediation oroiectsanalyses for volatile organic compounds (VOCs) should be performed. Analyses for any fuel additives likely
to be present at the site should also be performed. At minimum, analyses should be performed for the following compounds:
benzene' toluene' ethylbenzene' xylene' lead methyl tert-butylether (MTBE) dibromoethane (EDB)
1,2-dichloroethane isopropyl ether napthalene phenol
('an EPA -approved method capable of detection levels to 1 ppb should be used to detect these compounds).
For solvents or unidentified oroiects, an EPA Method 624/625 analysis should be performed. The data submitted with this application
should include the ten largest peaks not identified as targeted compounds and not present in the procedural blank. These peaks should be
identified and approximately quantitated (as per the same restrictions found on the NC DENR/DWQ Annual Pollutant Analysis
Monitoring (APAM) Requirement— Reporting Form A).
If metals or pesticides are suspected to be present these compounds should be analyzed to the same detection level as presented in the
NC APAM.
I certify that I am familiar with the information contained in the application and that to the best of
my knowledge and belief such information is true, complete, and accurate.
Tom Grandys, Sears Logistics Services, Inc. G oar s t s /2 - A, F_ S TA rr W q n7 A Gf/(
Printed name of Person Signing Title
Signature of Applicant
Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in
any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management
Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method
required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Adide, shall be
guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprisonment not to exceed six months, or by both.
(18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or imprisonment for not more than 5 years, or both, for a similar
offense.)
Short Form C-GW Version 6-99

fT Corporation ofNorih Carolina, Inc.
A Akroher of The IT Croup
NPDES Permit Application — Supplemental Information
W.P. Ballard Property
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
NCDENR Groundwater Incident # 6953
ITEM 7.0
Treated groundwater is proposed to be discharged to an existing storm sewer catch basin located
downgradient of the W.P. Ballard property on the former Sears Logistics Services (SLS) property. The
ultimate outfall of the storm sewer system is an unnamed tributary of of Philadelphia and Buffalo Lakes.
Attached Figure 1 is a portion of the Greensboro, North Carolina Quadrangle USGS topographic map
showing the approximate location of the storm sewer outfall to the unnamed tributary. Please note that the
USGS topographic map was most recently photo -revised in 1968, as such it does not accurately depict
the current area conditions. A portion of a City of Greensboro stormsewer map which provides a clearer
picture of the current area configuration is attached as Figure 2. A site map of the former SLS property
showing the proposed treatment system discharge location, a storm sewer catch basin, is included as
Figure 3.
This application package must include the items listed below. Other Required Information:
❑ A USGS topographical map (or copy of relevant portion) which shows all outfalls.
Treated groundwater from the proposed groundwater remediation system is proposed to be discharged tc
the storm water collection system located on the former SLS property. The ultimate outfall of the storm
sewer system is located hydraulically downgradient of the former SLS property, to the east. The outfall is
a 66-inch line which discharges to an unnamed tributary of Buffalo Lake. The ouffall is located adjacent to
the intersection of West Cone Boulevard and Cone Drive. A portion of the Greensboro, North Carolina
Quadrangle USGS topographic map showing the approximate location of the storm sewer outfall to the
unnamed tributary is included as Figure 1.
❑ A report of alternatives to surface water discharges outlined in the Division's `Guidance for the
evaluation of Wastewater Disposal Alternatives" (required by 15A NCAC 2H .0105 (c)).
A comprehensive Engineering Alternatives Analysis for the proposed discharge is included as
Attachment A.
❑ A summary of the most recent groundwater analytical results containing the maximum values
for each chemical detected.
A summary of the laboratory analytical data from the October 1999 groundwater sampling event is
included as Table 1. The maximum detected concentration for each chemical detected is listed along the
bottom of the table. A site map showing the location of the groundwater monitoring wells and other
pertinent site features is included as Figure 3.

IT Corporation offbilh Carolina, Inc.
A Afember of The IT Croup
-. NPDES Permit Application Page 2
W.P. Ballard Property, Greensboro, Guilford County, North Carolina January 19, 2000
Applications for new (un-permitted) discharges must include the items listed below. Other
information for New Discharges:
❑ An engineering proposal describing the remediation project in detail (required by 15A NCAC
2H.0105(c)):
The following remedial system description is a conceptual design of the groundwater recovery and
treatment portion of the turnkey system, as submitted to the NCDENR in a Corrective Action Plan dated
May 20, 1999. Once the NPDES permit has been issued, the engineered design of the groundwater
treatment system will be finalized and submitted for review with the application for the authorization to
construct. This application will include detailed plans and specifications.
Groundwater and Soil Vapor Recovery and Treatment Design Summary
The proposed sail and groundwater remedial system will consist of a deep high vacuum dual phase
(HVDP) extraction system and a shallow low vacuum soil vapor extraction (SVE) system. The purpose of
the HVDP and SVE systems will be to reduce the residual adsorbed and dissolved phase chlorinated
solvent concentrations. The HVDP/SVE system will use a two -level system to address adsorbed and
dissolved phase concentrations in areas of varying permeability. Shallow soils, located from the surface
to approximately 35 to 40 feet bgs exhibit a relatively low permeability with increased permeability at
greater depths. To address the adsorbed phase contaminants in the shallow soils and those created in
the deeper zone during dewatering activities, a multi -level system will be required.
To dewater the formation and remove adsorbed phase contaminants from the created vadose zone, a
combination groundwater recovery system and high vacuum soil vapor recovery system will be employed.
Groundwater recovery will be performed using downhole submersible pumps set at depths ranging from
60 to 75 feet bgs. Soil vapor recovery will be performed using high vacuum positive displacement
blowers. Remediation of the shallow adsorbed phase contamination will be performed using soil vapor
extraction. Extraction will be performed from shallow wells installed at depths ranging from 30 to 40 feet
bgs using a regenerative -type blower. The shallow soil vapor extraction points are anticipated to be used
exclusively in the vicinity of the Ballard property source area and immediately downgradient, adjacent to
the former SLS Axton -Cross building.
Based on the current groundwater analytical data, a conceptual layout of the dual phase extraction system
was prepared. The layout uses 28 deep dual -phase extraction wells, 12 shallow soil vapor extraction
wells, and 9 air injection points.
For the purposes of this permit application, only the groundwater recovery and treatment portions of the
I;
system design will be discussed further.
Groundwater Recovery and Treatment System Components
Based on the pilot testing activities performed in September 1997, the following recovery rates were
determined for use in preparing this conceptual design. Groundwater recovery from the deep high
vacuum dual phase recovery points will be performed at a constant rate of 0.5 to 1.0 gallons per minute
\\MORRFP7\COMMON1ProjectFiles\SLS-Greensboro\Permits\NPDESWPDES SLS Greensboro, NC.doc

ff Corporation ofNorlh Cerolina� Inc.
A Dfemher of The IT Croup
NPDES Permit Application Page 3
W.P. Ballard Property, Greensboro, Guilford County, North Carolina January 19, 2000
(gpm), per recovery point. Higher initial recovery rates are attainable, but will not be overly beneficial to
the long term performance of the remediation system. Therefore, the HVDP system will be designed to
recover a minimum of 28 gpm from the 28 deep wells. To accommodate potential future expansion of the
recovery well network, the treatment system will be designed for an operating flowrate of 50 gallons per
minute.
Dual Phase Extraction Wells
Based on the aerial extent of the total dissolved phase plume, as determined during the recent
groundwater sampling events, a total of 28 deep high vacuum dual phase recovery wells are proposed to
be installed. The deep dual phase extraction wells will be installed will be installed as Type II wells,
advanced to an approximate depth of 60 to 75 feet below ground surface (bgs). The wells will be
constructed of 20 to 35 feet of 4-inch diameter schedule 40 PVC riser and 40 feet of 4-inch diameter 0.020
slot schedule 304 stainless steel screen. Washed sand will be installed in the annulus of the well boring
from the bottom of the well to a point approximately one foot above the top of screen elevation. The well
annulus will then be completed to grade with 2 - 3 foot bentonite seal and cement grout to the surface.
The dual phase extraction wells will be secured inside steel vaults. The steel vaults will be flush mounted
with the existing grade and secured with concrete. The steel vault will be designed to be traffic -bearing.
Dual Phase Extraction Groundwater Recovery Pumps
Groundwater extraction will be performed from the 28 deep HVDP recovery points using CEE AP-3'
pneumatic submersible pumps or equivalent. CEE AP-3 pumps are capable of recovering up to 3 gallons
per minute of fluids from depths of 70 feet below ground surface with 2 feet of submergence at the pump
fluid inlet. Higher flow rates are attainable with greater elevations of submergence. Groundwater will be
conveyed from the pump into the well vault using 3/4-inch diameter flex -hose. The fluid recovery lines frorr
the individual recovery pumps will be manifolded into a single 2-inch SDR 11 HDPE chase pipe for gravity
feed into the treatment compound, where it will be discharged into the treatment system. Air will be
supplied to drive the pumps using a reciprocating compressor capable of 30 scfm at 70 psi. Air
conveyance lines will be constructed of 1-inch diameter schedule 80 PVC.
Groundwater Treatment Components
Recovered groundwater will be processed by an ex situ treatment system prior to being discharged. The
treatment system will consist of a two phase process. Recovered groundwater will be pumped directly
- into a surge tank and subsequently to a shallow tray air stripper. Water recovered by the vapor extraction
separation vessels associated with the soil vapor recovery operations will be intermittently pumped into
the influent surge tank as needed. Three sensor -driven direct drive transfer pumps will convey the
recovered groundwater from the vapor extraction separation vessels to the influent surge tank. A third
sensor -driven direct drive transfer pump will be used to convey recovered groundwater from the surge
" tank to the air stripper. The air stripper will be sized to handle a minimum influent flow of 50 gpm, and will
utilize, at a minimum, a 900 cfm blower for air injection. Final sizing of the air stripper will be based on the
required effluent limitations specified in the NPDES permit. A fourth sensor driven direct drive transfer
pump will convey the treated groundwater from the air stripper sump through a series of bag pre -filters,
into two 50-gpm granular activated carbon (GAC) vessels placed in series. The treated groundwater
i
\\MORRFP1\COMMON\ProjectFiles\SLS-Greensboro\Permits\NPDES\NPDES SLS Greensboro, NC.doc

IT Corporation ofNorih Carolinas Inc.
A Memher of The IT Croup
NPDES Permit Application Page 4
W.P. Ballard Property, Greensboro, Guilford County, North Carolina January 19, 2000
_ exiting the GAC vessels will gravity feed to the discharge point. It is proposed that the discharge line from
the treatment system be tied into the existing stormwater sewer system located on the former SLS
property.
System Controls
One main electric control panel will control the remediation system. A licensed electrical contractor will
follow guidelines in the National Electric Code and the local municipal code during electrical installation.
System controls are summarized as follows:
■ High-level control switch in the air/moisture separation vessels will shut down the
respective HVDP vacuum pump or low vacuum SVE blower.
■ High-level control switch in the air stripper sump will shut down the pneumatic pump air
supply compressor and both the HVDP vacuum pump and low vacuum SVE blower.
■ Low-pressure interlock sensor in the air stripper will shut down the pneumatic pump air
supply compressor and both the high vacuum pump and low vacuum blower.
■ High-pressure interlock sensor in the bag/cartridge filters will shut down the pneumatic
pump air supply compressor and both the high vacuum pump and low vacuum blower.
■ A shut down of any portion of the catalytic oxidizer system will shut down the entire
HVDP/SVE system.
The remediation system will include a programmable logic controller (PLC) and computer -based man -
machine interface (MMI) with remote monitoring capability using dial -up modem communications. Real-
time computer operating screens and graphical data will be used to interface to the system for the purpose
of controlling and monitoring the system either locally or remotely. All critical system operational
parameters will be continuously monitored and recorded in data logs residing on the hard drive of the site
MMI computer. This data will be used for process evaluations by the project team. The data files will be
maintained for the duration of the project for the historical record. In addition, the system will include a
remote alarm system consisting of an autodialer that accepts PLC alarm outputs and sends voice
descriptions of any alarm condition to a list of phone numbers for site technicians and project support
personnel. The remote alarm system will also notify select personnel via pagers.
Environmental Piping, Fittings and Valves
Groundwater recovered by the HVDP system will be transferred to the treatment compound in lines
constructed of 2-inch diameter SDR 11 HDPE piping and fittings. Groundwater recovery from the dual
phase wells will be performed using 5 individual trunk lines. Four trunk lines will manifold 5-wells and one
will manifold 8-wells.
\\MORRFPI\COMMON1ProjectFiles\SLS-GreensborolPermits\NPDES\NPDES SLS Greensboro, NC.doc

ff Corporation ofNorth Carolina, Ine.
A Alemher of The IT Croup
NPDES Permit Application Page 5
W.P. Ballard Property, Greensboro, Guilford County, North Carolina January 19, 2000
_ Electrical
Electrical work shall be conducted in accordance with the National Electrical Code (NEC) and other
applicable Federal, State or local codes. Equipment installed in the treatment system building will be UL
listed and approved. The control panel shall be mounted outside the hazardous area and shall be NEMA
IV (weatherproof) rated.
❑ A List of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical
A summary of chemicals detected, and the maximum concentrations observed is included as Table 2.
Please note that several of the maximum concentrations detected are from as early as May 1992. As
such these concentrations may not accurately reflect current site conditions. A summary of the
anticipated system influent concentrations is included as Table 3. The estimated influent groundwater
concentrations were calculated based on the current groundwater analytical data for the existing
monitoring wells, distance from the existing wells to the proposed recovery wells and the anticipated
groundwater recovery rates using the following calculation:
Cr / d, + C2/d2 + ... C /d,
C AVG =
1/dt + 1/d2 + ... 1/d,
where,
C AVG = concentration of a constituent in a single recovery well based on concentrations
_ of the constituent in nearby monitoring wells, taking into account the distance from the
recovery well to each monitoring well.
C AVG was calculated for each constituent in each of the 28 recovery wells. Then using simple averaging,
the combined influent concentration for each constituent was calculated. For this calculation, the recovery
flow rate from each recovery point was assumed to be the same. A 25-percent safety factor was added to
the estimated influent concentrations.
❑ A summary of analytical results containing the maximum values for each chemical detected.
A summary of historical groundwater analytical data from the groundwater sampling events is included as
Tables 4 and 5. Table 4 is a summary of the shallow groundwater analytical results and Table 5 is a
summary of the deep groundwater laboratory analytical results.
❑ The removal efficiency of each compound detected (if known).
A detailed description of each component proposed for the treatment train will be included in the
application for the authorization to construct. The removal efficiencies for each compound for the
respective components will be outlined along with the estimated concentration reductions throughout the
system based on the anticipated groundwater influent concentrations.
UMORRFPt\COMMON1ProjectFiles\SLS-Greensboro\PermitsWPDESWPDES SLS Greensboro, NC.doc

• IT Corporation oFNorth Cmwlma� Inc.
-" A Afemher of The IT Croup
TABLES

r
Sampling
Location
05-C8
Aliphatics
(pg/L)
C9-C12
Aliphatics
(pglL)
Benzene
(pglL)
1,2-
Dichloro-
benzene
(pglL)
1,3-Dichlora
benzene
(pglL)
MW - 1
1,600
NO
NO
NO
NO
MW-2
670
NO
NO
ND
NO
MW-3
26,100
NO
NO
NO
NO
MW-4
8,740
700
NO
NO
NO
MW-5
3,420
NO
NO
NO
NO
MW-6
NO
ND
I NO
NO
NO
MW-7
NO
ND
NO
•ND
NO
MW-8
NO
ND
NO
NO
NO
MW-9
NO
NO
NO
NO
NO
MW-10
3,580
ND
NO
NO
NO
MW-11
ND
ND
NO
NO
NO
MW-12
NO
ND
NO
NO
NO
MW-13
NO
NO
NO
NO
NO
MW-15
NO
ND
NO
NO
NO
MW-17
ND
NO
NO
'ND
ND
MW - 18
ND
NO
NO
ND
ND
MW-20
ND
ND
ND
ND
ND
MW-21
ND
NO
ND
ND
NO
MW-22
ND
NO
ND
ND
ND
MW-23
ND
NO
1.1
ND
ND
MW-27
9,820
NO
ND
ND
ND
MW-28
270
ND
ND
ND
ND
LMP-1
ND
ND
ND
ND
ND
LMP-2
ND
ND
ND
ND
ND
DW-1
NO
ND
ND
ND
NO
DW-2
NO
ND
ND
ND
NO
DW-3
65,800
ND
ND
ND
NO
DW-4
9,700
ND
ND
ND
NO
DW-5
NO
ND
ND
ND
NO
DW-7
NO
ND
ND
NO
NO
DW-8
NO
ND
ND
ND
NO
DW-12
ND
ND
ND
ND
NO
DW-13
ND
ND
ND
NO
NO
DW-14
ND
ND
ND
ND
NO
DW-15
ND
ND
NO
ND
NO
DMP-1
ND
ND
1.6
4
1.1
DMP-2
ND
NO
ND
ND
NO
DMP-3
ND
ND
ND
ND
NO
DMP-4
ND
ND
NO
ND
ND
BMW-1
DRY
DRY
DRY
DRY
DRY
BMW-2
19,600
ND
NO
ND
NO
BMW-3
ND
ND
ND
ND
ND
BMW-4
ND
NO
NO
ND
NO
Maximum
Concentration
65,800
700
1.6
4
1.1
Table 1
Summary of Groundwater Analytical Data - October 1999
W.P. Ballard and Downgradient Properties
Greensboro, North Carolina
Ethyl-
benzene
(pglL)
Bromoform
(pglL)
Carbon
tetra-
chloride
(pg/L)
2-Chloro-
ethly-
vinyl-
ether
(pglL)
Chloro-
form
(PglL)
Dibromo-
chloro-
methane
(p9/L)
Vinyl
chloride
(pglL)
1,2-DCA
(pglL)
1,1-DCE
(pglL)
cis-1,2-DCE
(pglL)
trans-1,2-
DCE
(pglL)
1,2-Dichloro
propane
(pg/L)
Methylene
chloride
(pglL)
PCE
(pglL)
1,1,1-TCE
(pglL)
TCE
(pglL)
MTBE
(pglL)
NO
NO
NO
NO
NO
NO
ND
NO
ND
NO
NO
NO
NO
3,880
ND
ND
NO
NO
NO
NO
NO
NO
NO
ND
NO
ND
1,070
14.4
NO
NO
56
ND
156
19.3
NO
NO
NO
NO
ND
NO
ND
NO
ND
ND
NO
NO
NO
60,500
NO
ND
NO
NO
NO
NO
NO
NO
NO
ND
NO
ND
ND
NO
NO
NO
1 22,200
NO
I NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
NO
NO
NO
7,590
ND
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
199
NO
NO
NO
ND
37
ND
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
1.2
NO
ND
NO
ND
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
ND
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
NO
NO
ND
NO
ND
ND
NO
NO
NO
NO
NO
NO
NO
NO
NO
2.4
4
ND
1.7
ND
3.5
NO
NO
NO
8,090
8.3
13.0
NO
NO
NO
NO
NO
ND
NO
ND
NO
ND
NO
NO
NO
NO
NO
NO
ND
NO
NO
NO
NO
NO
ND
NO
ND
NO
ND
NO
NO
240.0
NO
NO
NO
ND
NO
NO
ND
NO
NO
ND
NO
NO
NO
ND
NO
NO
NO
NO
NO
ND
NO
NO
NO
NO
7.7
1.5
16.4
NO
ND
NO
NO
18.9
NO
NO
NO
20.8
ND
280
NO
NO
NO
12.6
NO
1.6
NO
ND
NO
ND
95
NO
6.0
NO
4,880
ND
960
NO
NO
ND
NO
NO
ND
NO
ND
NO
NO
15.6
NO
12:0
NO
2,100
NO
730
ND
NO
ND
NO
NO
ND
NO
ND
NO
NO
NO
NO
ND
NO
NO
NO
NO
ND
NO
NO
NO
NO
ND
NO
NO
NO
NO
NO
NO
NO
NO
252
NO
40.9
ND
NO
ND
2.5
NO
ND
NO
ND
NO
NO
50.3
NO
NO
ND
1,680
NO
146.0
ND
2.5
ND
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
ND
NO
NO
ND
NO
ND
NO
NO
3,700
NO
NO
NO
NO
NO
15,900
NO
NO
NO
NO
NO
NO
NO
ND
NO
ND
323
NO
NO
NO
NO
NO
192
NO
NO
NO
NO
NO
ND
NO
NO
NO
ND
21.2
ND
1,560
NO
145
NO
NO
NO
NO
ND
NO
NO
1.4
NO
NO
NO
ND
10.9
NO
316
NO
46
NO
NO
NO
NO
1
NO
NO
1.2
NO
NO
NO
9.4
10.5
ND
NO
NO
170
4.8
8.6
NO
NO
ND
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
NO
150
NO
ND
ND
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
NO
NO
NO
174,000
NO
NO
NO
NO
NO
NO
ND
NO
NO
NO
NO
ND
NO
NO
NO
NO
23,900
NO
ND
NO
NO
NO
73.2
NO
23.1
NO
NO
NO
ND
22.1
NO
NO
NO
52.3
NO
261
NO
NO
NO
NO
NO
NO
NO
ND
NO
ND
NO
NO
15.0
NO
221.0
NO
NO
NO
NO
NO
19.7
NO
5.6
NO
ND
NO
NO
530
2.1
1.1
NO
4,290
NO
1,300
NO
NO
NO
NO
NO
NO
ND
NO
NO
ND
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
5
NO
NO
ND
421
NO
21.7
NO
NO
NO
NO
NO
NO
NO
1.1
NO
NO
3.1
NO
NO
ND
304
NO
84.5
NO
NO
NO
NO
NO
ND
NO
1.3
NO
NO
2.7
NO
NO
NO
398
NO
71.7
NO
NO
NO
NO
ND
NO
NO
3.6
8.4
3.5
3,440
16.9
28.0
8.0
60.0
NO
355
NO
NO
NO
8.2
NO
3.5
ND
NO
2.8
NO
6.8
NO
NO
NO
329
NO
505
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
10.4
NO
ND
NO
562
NO
90
NO
NO
NO
17.1
NO
5.7
2
NO
1
1.2
375
2.8
NO
NO
4,500
NO
1,180
NO
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
DRY
NO
NO
NO
NO
ND
NO
NO
NO
NO
ND
NO
NO
NO
48,800
NO
NO
NO
NO
NO
NO
NO
ND
NO
NO
NO
NO
ND
NO
18.0
NO
260.0
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
5.5
NO
NO
NO
607.0
NO
118
NO
2.5
1
73.2
1.5
23.1
3.7
3.6
8.4
199
3,700
16.9
1,660
8
174,000
8.3
15,900
19.3

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IT Corporation ofNorth Carolina, Inc.
A Alemher of The IT Group
APPENDIX A
City of Greensboro POTW Letter

December 8,1999
Bill Fredrick
IT Corporation
1000 Parameter Park Drive, Suite I
Mooresville, NC 27560
RE: Groundwater Discharge for Sears Logistic Group
Branchwood Drive and Battleground Ave.
Dear Mr. Fredrick:
In response to your telephone call, I am writing this letter to inform you that the City of
Greensboro has suspended their acceptance of groundwater until further notice. We
regret our inability to assistance you at this time, but hope to be in a position in the
future to once again accept groundwater.
Sincerely,
Sharon H. Miller
Pretreatment Coordinator
640 P.O. Box 3136 • Greensboro, NC 27402-3136 • www.d.greensboro.nc.us • [phone] • TTY# 333-6930

• IT Corporation ofNorth Carolina, Inc.
• A Member of The IT Croup
APPENDIX B
Soils Analysis Report

1T Corporation of North Carolina lnc.
A Hember of The IT Croup
Soils Analysis Report
W.P. Ballard Property
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
NCDENR Groundwater Incident # 6953
The following general soil characterization, loading rate calculations and land area requirements
were prepared to evaluate the potential applicability of surface application disposal options. This
general characterization was prepared using typical values for Guilford County, not site specific
information.
Background:
Per the United States Department of Agriculture (USDA) Soil Survey of Guilford County, 1977,
the subject site is located on the Urban Land (Ur) soil map unit. This land type is described as
having more than 75 percent of the surface covered with streets, buildings, parking lots, railroad
yards, and airports. The engineering properties of this soil type are not included in the USDA soil
survey. The soil on adjacent parcels of land to the north, east, south and southwest of the
subject site are identified as the Cecil -Urban land complex (CfB). The soil on adjacent parcels of
land to the northwest are identified as the Vance -Urban land complex (VuB). The engineering
properties of the CfB and the VuB soil types are provided in the USDA soil survey.
For calculation purposes, it was assumed that the permeability values provided for the adjacent
soil types would be applicable. A summary of the permeability data acquired from the USDA soil
survey is provided below:
Depth
Permeability
Soil Name and Symbol
(Inches)
(inches/hour)
Cecil -Urban land complex (CfB)
0-6
0.6-2.0
6-52
0.6-2.0
Vance -Urban land complex (VuB)
0-6
2.0-6.0
6-40
0.06-0.2
Assumptions used to calculate the loading rate and associated land are requirements:
Design flowrate of the groundwater extraction system = 50 gal/min = 72,000 gal/day
The USDA soil permeability rates are based on natural surface soils. Areas that have been
graded or modified will have considerably lower permeability rates.
Soils Analysis Results:
If the lowest permeability for the two soils is used, at minimum of 1.84 acres of land will be
necessary to absorb the 72,000 gallons of daily effluent water. This estimate assumes a
continual movement of water through the soil with depth. Generally, as depth increases
permeability of unconsolidated sediments decreases, as such the continual movement of water
through the soil is unlikely and pooling of water and subsequent surface run off will probably
occur.
The continual addition of water would likely result in water pooling and eventual surface run off,
as such, it is recommended that several additional acres of land would likely need to be utilized to
allow proper infiltration of the 72,000 gallon/day production rate.

Soils Analysis Calculations
W.P. Ballard Property
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
Known Values and Assumptions:
Design Flowrate = 50 gal/min = 72,000 gal/day = 9626 ft3/day
Average Depth to Groundwater = 17.5 ft bgs
Soil Permeability based on typical USDA data for Guilford County, North Carolina
Soil Classification
Permeability
in/hr
in/day
Way
Cecil -Urban (CfB)
2.00
48.00
4.00
0.60
14.40
1.20
Vance -Urban (VuB)
6.00
144.00
12.00
0.06
1.44
0.12
Common Conversion Factors:
1 acre = 43,560 square feet
1 ft3 = 7.48 gallons
Using the above referenced permeability rate ranges and design treatment system flowrate,
the following land requirements were calculated:
Area Required
Area Required
Permeability
Design Flowrate
for Infiltration
for Infiltration
Soil Classification
(ft/day)
(ft3/day)
(ft2)
(acres)
Cecil -Urban (CfB)
4.00
9,626
2,407
0.055
1.20
9,626
8,022
0.184
Vance-Urban(VuB)
12.00
9,626
802
0.018
0.12
9,626
80,217
1.842
Also, based on the estimated permeability ranges, the estimated times to saturation were calculated
assuming uniform soils and saturation conditions:
Unsaturated Thickness
Estimated Time
Permeability
Storage Depth
for Saturation
Soil Classification
(f/day)
(ft)
(days)
4.00
17.5
4.38
Cecil -Urban (CfB)
1.20
17.5
14.58
12.00
17.5
1.46
Vance -Urban (VuB)
0.12
17.5
145.83

IT Corporation of North Caroline, Inc.
A Member of The IT Croup
Attachment A
Excerpts from the USDA Guilford County Soil Survey

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GUILFORD COUNTY, NORTH CAROLINA
TABLE 14.--PHYSICAL AND CHEMICAL PROPERTIES OF SOILS
(The symbol < means less than; > means greater then. The erosion tolerance factor (T) is for the entire
profile. Absence of an entry means data were not available or were not estimated]
I ; Risk of corrosion I E
Soil name and ! Depth i Perinea- i Available i Soil I Shrink- ! i
map symbol ! ; Dility I water Ireaction I swell I Uncoated i Concrete I
x. ►ppli
APB,
• Cecil:
CcB, CeC, CeD-----
CeB2, CeC2, 1CfB--
Chewacla:
Ch------
ICongaree:
Coronaca:
CrB, CrC, 1CuB----
Enon:
EnB, EnC, EnD-----
Eo82, Eo02, EOD2,
1Es, 1EuB---------
W
i
0-8 ! 2.0-6.0 ! 0.10-0.15 1 4.5-5.5 (Low ------- (Moderate ------ !Moderate ------- l0.20! 4
8-53 1 0.6-2.0 1 0.15-0.17 14.5-5.5 !Moderate !Moderate ------ !Moderate ------- 10.241
53-72 1 --- i--- 1 --- I ---------- I -------------- -------------I--- I
! 1
0-6 1 2.0-6.0 1
6-52 1 0.6-2.0
52-85 1 ---
i
0-6 1 0.6-2.0
6-52 1 0.6-2.0
52-85 1 ---
!
0-18 10.6-2.0
18-50 1 0.6-2.0
50-70 1 0.6-2.0
70-90 I ---
I
I
0-8 10.6-2.0
8-49 1 0.6-2.0
49-80 1 ---
I
0-8 1 0.6-2.0
8-95 10.6-2.0
[
0-8 1 2.0-6.0
8-33 10.06-0.2
33-75 1 0.2-0.6
!
0-8 1 0.6-2.0
8-33 10.06-0.2
33-75 1 0.2-0.6
0.12-0.14 1 4.5-6.0 1
0.13-0.15 1 4.5-5.5 !
0.13-0.15_1 4.5-6.0 1
0.13_0.15-1 4.5_5.5 1
0.10-0.15 ! 5.1-6.5
0.12-0.20 15.1-6.5
0.15-0.24 1 5.1-6.5
_-_ I ___
0.12-0.20 1 5.1-6.5
0.12-0.20 15.1-6.5
0.12-0.18 1 5.6-7.3
0.12-0.16 1 5.6-7.3
0.11-0.15 1 5.1-6.5
0.15-0.20 1 5.1-7.3
0.13-0.18 1 6.1-7.3
I !
I
10.15-0.20 15.1-6.5
1 0.15-0.20 ! 5.1-7.8
1 0.13-0.18 1 6.1-7.8
Helena:
HhB: ! I I I
Helena part ----- 1 0-7 1 2.0-6.0 1 0.10-0.12
1 7-38 10.06-0.2 1 0.13-0.15 1
1 38-80 1 --- I ---
Sedgefield part-! 0-12 1 2.0-6.0 1 0.10-0.14
1 12-16 10.06-0.2 1 0.14-0.18
1 16-33 1 0.6-2.0 1 0.12-0.15
1 33-48
! 1 I
HeC--------------- I 0-7 1 2.0-6.0 ! 0.10-0.12
1 7-38 10.06-0.2 1 0.13-0.15
1 38-80 1 --- I ---
I I I
Iredell:
IrB--------------- 1 0-7 1 2.0-6.0 1 0.12-0.15
1 7-24 10.06-0.2 1 0.16-0.22
24-27 10.06-0.6 1 0.14-0.18
27
Madison: 1 I 1
MaB, MaC, HaD, MaE1 0-5 1 2.0-6.0 1 0.11-0.15
1 5-34 1 0.6-2.0 1 0.13-0.18
1 34-80 1 --- 1 ---
See footnote at end of table.
4.5-6.5
4.5-5.5
4.5-6.5
4.5-6.5
5.6-8.�
4.5-6.5
4.5-5.`.
5.6-7.'
5.6-7.'
6.1-7.1
1 4.5-6.1
4.5-5.
'.ow-------lModerate ------ (Moderate ------- 10.321 4
Moderate ;Moderate ------ (Moderate ------- 10.281
---------- I_____________ ' ! I
_ _______________ I
Low ------- IModerate ------ IModerate------- 10.321 3
Moderate !Moderate ------ !Moderate ------- 10.281
---------- ;-------------- I --------------- 1--- I
Low ------- IHigh---------- (Moderate ------- 10.281 5
Low ------- ;High ---------- ;Moderate ------- 10.281
Low -------!High ---------- !Moderate ------- 1--- I
----------- I -------------- I--------------- ,___ ,
; I !
Low ------- iModerate ------ IModerate------- 10.281 5
Low ------- Moderate ------ !Moderate ------- 10.281
_. _I---------------!___
Low -------IModerate ------ [Moderate ------- 10.241 5
Moderate (High ---------- IModerate------- 10.241
' I !
Low ------- ;High ---------- IModerate------- 10.371 4
High ------ (High ---------- IModerate------- 10.281
Moderate ;High ---------- !Low ------------ 10.371
1 ! I !
1 [
i !
Low ----- --IHigh---------- IModerate------- 10.371 2
High ------
!High ---------- !Moderate ------- 10.281
Moderate !High ---------- !Low ------------ 10.371
1 I I
Low ------- (High ---------- !Moderate ------- 10.37
High ------ IHigh---------- ;High ----------- 10.32
---------- I -------------- --------------- I---
ILow- ------ [High-- -------- !Moderate ------- l0.37
High --- ---ILow----------- IModerate------- 10.32
IModerate ILOw----------- !Low ------------ 10.32
1---------- i-------------- I ---------------[---
I I
ILow-------[High----------IModerate-------10.37
;High ------ iHigh ---------- (High----------- 10.32
!----------
I -------------- I --------------- 1---
Low ------- IModerate------ ILow------------ 10.32
Very high IHigh---------- !Low ------------ 10.20
High ------ ;High ---------- !Low ------------ 10.28
i--------!_______________I___
Low_______
Low_______
3
7
3
3
Moderate ------- 10.281 4
Moderate ------- 10.32
---------------l--- !
! !

74
Soil name and
map symbol
SOIL SURVEY
TABLE 14.--PHYSICAL AND CHEMICAL PROPERTIES OF SOILS --Continued
Depth I Permea- 1 Available 1 Soil Shrink-
, bility 1 water Ireaction 1 swell Uncoated 1 Concrete
Madison: :
1
mcB2, McC2, McD2,
MCE2, 1Md, 1MeB---1 0-5 1 0.6-2.0 ! 0.12-0.16 :
1 5-34 1 0.6-2.0 1 0.13-0.18
1 34-80 1 --- i ---
Mecklenburg:
MhB2, MhC2, 1MuB--
Pits:
Pt.
Urban land:
Ur.
Vance:
VaB, VaC, VaD
1 VuB--'-----'
r
Wehadkee:
Wh------
0-7 ! 0.6-2.0 1 0.12-0.14
1 7-38 10.06-0.2 1 0.12-0.14
' 38-70 1 --- --'
! 1
' : f
4.5-6.0 :Low ------- :High ---------- :Moderate ------- 10,281 3
4.5-5.5 !Low ------- ;;High ---------- !Moderate ------- 10.321
;_______________________ I I
5.6-7.3 !Low ------- !High ---------- :Moderate ------- 10.32: 2
5.6-7.3 !Moderate :High ---------- !Moderate ------- :0.321
---------- I -------------- ! ---------------
--
--; 0-6 : 2.0-6.0 1 0.10-0.14 1 4.5-6.0 :Low ------- :High ---------- !Moderate-------:0.28: 3
: 6-40 :0.06-0.2 1 0.12-0.15 1 4.5-5.5 !Moderate :High ---------- :High ----------- 10.37:
' 40-72 ! : ' 1__________i______________ i_______________,___ i
--- --- ---
0-8 1 2.0-6.0 1 0.14-0.18 1 5.6-7.3 !Low ------- :High ---------- 1Moderate ------- 10.281 5
: 8-48 1 0.6-2.0 1 0.16-0.20 1 5.6-7.3 Mow -------
'High ----------1 Moderate ------- 10.28:
: 48-80 1 2.0-6.0 1 0.14-0.16 1 5.6-7.3 !Low-------i Nigh---------- !Moderate ------- 1--- I i
Wilkes: ! : i
WkC, WkD, WkE ----- 1 0-7 1 2.0-6.0 1 0.11-0.15 1 5.6-6.5 !Low ------- !Moderate ------ !Moderate ------- :0.281 2
1 7-18 1 0.2-0.6 1 0.15-0.20 1 5.6-6.5 !Moderate :Moderate ------ !Moderate ------- 10.321
___ ___ 1__________,______________!_______________;___ ;
1 18-52 ! --- 1 ! � , ! :
1This mapping unit is made up of two or more dominant kinds of soil. See mapping unit description for the
composition and behavior of the whole mapping unit.

10
SOIL SURVEY
helps to ensure adequate protective cover, which reduces
runoff and controls erosion.
This soil has only moderate potential for most urban
uses because of the moderate permeability, which limits
performance of septic tank absorption fields, but this
limitation generally can be overcome by modifying the
field or increasing the size of the absorption area The
potential for recreation is moderate.
This soil has moderate potential for broadleaf and
needleleaf trees. The dominant trees are shortleaf pine,
maple, loblolly pine, Virginia pine, sweetgum, red oak, and
white oak. The main understory species are dogwood,
cedar, holly, pin oak, sassafras, and black cherry. A clayey
subsoil is the main limitation in the use and management
of this soil for woodland. Capability unit IIIe-2; woodland
group 4c.
CeC2—Cecil sandy clay loam, 6 to 10 percent slopes,
eroded. This well drained soil is on narrow side slopes.
The mapped areas are 4 to 25 acres in size.
Typically, the surface layer is brown sandy clay loam
about 6 inches thick. The subsoil is 46 inches thick; it is
yellowish red sandy clay loam in the upper part, red clay
in the middle part, and mottled red clay loam in the lower
part. The underlying material, to a depth of 85 inches, is
mottled red and yellow loam.
Included with this soil in mapping are a few small areas
of soils that have a sandy loam surface layer and a few
small areas of soils that have slopes of more than 10 per-
cent. Also included are a few small areas of Appling,
Coronaca, Madison, and Mecklenburg soils.
The organic -matter content of the surface layer is low.
Permeability is moderate, available water capacity is
medium, and the shrink -swell potential is moderate. Reac-
tion of the subsoil is very strongly acid or strongly acid.
Depth to bedrock is more than 60 inches. The seasonal
high water table is at a depth of more than 6 feet.
Most areas of this soil are in woodland. The rest are
used for cultivated crops, for pasture, or for urban uses.
Slope, runoff, erosion, and permeability are the main
limitations in the use and management of this soil.
This soil has low potential _for row crops. It has
moderate potential for hay and pasture plants such as
fescue, sericea lespedeza, red clover, and white clover.
Proper pasture management helps to ensure adequate
protective cover, which reduces runoff and controls ero-
sion.
This soil has only moderate potential for most urban
uses because of moderate permeability and slope. The
limitation of slope can be reduced or modified by special
planning, design, or maintenance. Erosion is a hazard
when ground cover is removed. The moderate permeabih-
ty limits performance of septic tank absorption fields, but
this limitation generally can be overcome by modifying
the field or increasing the size of the absorption area The
potential for recreation is moderate.
This soil has moderate potential for broadleaf and
needleleaf trees. The dominant trees are shortleaf pine,
loblolly pine, Virginia pine, sweetgum, red oak, and white
oak. The main understory species are dogwood, cedar,
holly, pin oak, sassafras, and black cherry. A clayey sub-
soil is the main limitation in the use and management of
this soil for woodland. Capability unit IVe-2; woodland
group 4c.
CfB—Cecil-Urban land complex, 2 to 10 percent
slopes. This complex consists of areas of Cecil soils and
Urban land so small or so intricately mixed that it was
not practical to map them separately. The complex con-
sists of about 30 to 60 percent Cecil soils and 30 to 60
percent Urban land.
Cecil soils are well drained and are on broad ridges and
side slopes on uplands.
Typically, the surface layer is brown sandy loam about
6 inches thick. The subsoil is 46 inches thick; it is yel-
lowish red sandy clay loam in the upper part, red clay in
the middle part, and mottled red clay loam in the lower
part. The underlying material, to a depth of 85 inches, is
mottled red and yellow loam.
Urban land consists of areas where the original soil has
been cut, filled, graded, paved, or otherwise changed to
the extent that most soil properties have been so altered
that a soil series is not recognized. These areas are used
for shopping centers, factories, municipal buildings, apart-
ment complexes, parking lots, or other uses where
buildings are closely spaced or the soil is covered with
pavement. Slope is generally modified to fit the needs of
the soil. The extent of site modification varies greatly.
Many areas have had little disturbance, while many
others have been cut or filled.
Included in mapping are a few areas of Appling and
Mecklenburg soils.
Determination of use and management of these areas
generally requires onsite investigation. Not placed in in-
terpretive groups.
Ch—Chewacla sandy loam. This nearly level,
somewhat poorly drained soil is in long, flat areas parallel
to the major streams on the flood plains. The mapped
areas are 5 acres to more than 50 acres in size.
Typically, the surface layer is about 12 inches thick; it
is brown sandy loam in the upper part and pale brown silt
loam in the lower- part. The subsoil is 58 inches thick; the
upper part is mottled brown sandy loam, the middle part
is mottled light brownish gray loam and silt loam, and the
lower part is mottled light brownish gray and strong
brown clay loam The underlying material, to a depth of
90 inches, is mottled dark bluish gray clay loam
Included with this soil in mapping are a few small areas
of soils that have a silt loam or loamy sand surface layer.
Also included are a few small areas of Congaree and
Wehadkee soils.
The organic -matter content of the surface layer is low.
Permeability is moderate, available water capacity is
medium, and the shrink -swell potential is low. Reaction of
the subsoil is strongly acid to slightly acid. Depth to
bedrock is more than 60 inches. Depth to the seasonal
high water table is about 1/2 foot to 1 1/2 feet late in
winter and early in spring. This soil is commonly flooded
for brief periods.

, NORTH CAROLINA 23
trial areas. Slol 8080-899-008•I
are the main L
this soil. O
This soil ha
soybeans, and small gram. minimum
residue management help to control runoff and erosion.
Conservation practices such as maintaining sod in
drainageways, constructing terraces and diversions, strip -
cropping, establishing field borders, contour farming, and
using crop rotations that include close -growing crops also
help to conserve soil and water. The potential for hay and
pasture plants such as ladino clover, red clover, fescue,
and sericea lespedeza is moderately high. Proper pasture
management helps to ensure adequate protective cover,
which reduces runoff and controls erosion.
The potential for most urban uses is low because of
slow permeability and low strength. The potential is
moderate for recreation areas because of slow permeabili-
ty.
This soil has moderately high potential for broadleaf
and needleleaf trees. The dominant trees are white oak,
black oak, post oak, northern red oak, southern red oak,
blackjack oak, cedar, maple, hickory, loblolly pine, short -
leaf pine, and Virginia pine. The main understory species
are dogwood, holly, and sassafras. There are no major
limitations in the use and management of this soil for
woodland. Capability unit IVe3; woodland group 3o.
VaD—Vance sandy loam, 10 to 15 percent slopes.
This well drained soil is on narrow side slopes on uplands.
The mapped areas are 3 to 10 acres or more in size_
Typically, the surface layer is brown sandy loam about
6 inches thick. The subsoil is 34 inches thick; the upper
part is mottled strong brown clay, and the lower part is
mottled brownish yellow clay loam. The underlying
material, to a depth of 72 inches, is mottled brownish yel-
low, white, and red clay loam.
Included with this soil in mapping are a few small areas
of soils that have a clay loam surface layer. Also included
are a few small areas of Appling, Cecil, and Enon soils.
The organic -matter content of the surface layer is low.
Permeability is slow, available water capacity is low, and
the shrink -swell potential is moderate. Reaction of the
subsoil is strongly acid or very strongly acid. Depth to
bedrock is more than 60 inches. The seasonal high water
table is at a depth of more than 6 feet.
Most areas of the soil are forested. The rest are in
pasture. Slope, runoff, erosion, and slow permeability are
the main limitations in the use and management of this
soil.
This soil has low potential for crops because of slope
and erosion. It has low potential for hay and pasture
plants. Proper pasture management helps to ensure
adequate protective cover, which reduces runoff and con-
trols erosion.
The potential for most urban and recreation uses is low
because of slow permeability.
This soil has a moderately high potential for broadleaf
and needleleaf trees. The dominant trees are white oak,
I.
black oak, post oak, northern red oak, southern red oak,
blackjack oak, cedar, maple, hickory, loblolly pine, short -
leaf pine, and Virginia pine. The main understory species
are dogwood, holly, and sassafras. There are no major
limitations in the use and management of this soil for
woodland. Capability unit IVe-3; woodland group 3o.
VuB—Vance-Urban land complex, 2 to 10 percent
slopes. This complex consists of areas of Vance soils and
Urban land so small or so intricately mixed that it was
not practical to map them separately. The complex con-
sists of about 40 to 60 percent Vance soils and about 30 to
50 percent Urban land.
Vance soils are well drained and are on side slopes on
the uplands. Typically, the surface layer is brown sandy
loam about 6 inches thick. The subsoil is 34 inches thick;
the upper part is mottled strong brown clay, and the
lower part is mottled brownish yellow clay loam. The un-
derlying material, to a depth of 72 inches, is mottled
brownish yellow, white, and red clay loam.
Urban land consists of areas where the original soil has
been cut, filled, graded, paved, or otherwise changed to
the extent that most soil properties have been so altered
that a soil series is not recognized. These areas are used
for shopping centers, factories, municipal buildings, apart-
ment complexes, parking lots, or other uses where
buildings are closely spaced or the soil is covered writh
pavement. Slope is generally modified to fit the needs of
the site. The extent of site modification varies greatly.
Many areas have had little disturbance, and many areas
have been cut or filled.
Included in mapping are a few areas of Appling and
Cecil soils.
Determination of use and management of these areas
generally requires onsite investigation Not placed in in-
terpretive groups.
Wh—Wehadkee silt loam. This nearly level, poorly
drained soil is on broad flood plains along creeks and
streams. The mapped areas are 4 to 50 acres or more in
size.
Typically, the surface layer is brown silt loam about 8
inches thick. The subsoil is 40 inches thick; the upper part
is mottled grayish brown silt loam, the middle part is
mottled light brownish gray silt loam, and the lower part
is mottled gray silty clay loam and mottled gray loam.
The underlying material, to a depth of 80 inches, is mot-
tled gray loam.
Included with this soil in mapping are a few small areas
of soils that have a loam or fine sandy loam surface layer.
Also included are a few small areas of Chewacla soils.
The organic -matter content of the surface layer is
medium. Permeability is moderate, available water capaci-
ty is medium, and the shrink -swell potential is low. Reac-
tion of the subsoil is medium acid to neutral. Depth to
bedrock is more than 60 inches. The seasonal high water
table is at or near the surface. This soil is frequently
flooded for brief periods.
Most areas of this soil are forested. The rest are domi-
nantly in pasture. Wetness and flooding are the main
limitations in the use and management of this soil.

1
22
SOIL SURVEY
Borrow pits are areas ` Leen ex-
cavated to a depth of more than 20 feet. The more
recently excavated areas are bare and are subject to ac-
celerated erosion. The older areas are eroded, but many
of them have stabilized under pine and other vegetation.
Some of the areas are smooth, and others have a highly
irregular surface.
Quarries are areas where the regolith has been
removed and the underlying rock has been quarried for
use mainly as construction aggregate. These areas are
open excavations as deep as 100 feet or more. Water fills
the deeper cavities all year in most of the abandoned
quarries. These cavaties are almost entirely devoid of
vegetation. Some pine and cedar trees are around the top
of the quarries, where the soil is exposed.
In sanitary landfill areas the original soil has been
removed and solid waste material placed in alternating
layers with the original soils and other soil materials. A
few areas have been used as dumps for industrial and
other wastes. Soil material was mixed in some of these
dumps in low areas, and the land was then leveled. Some
of the older sanitary landfills that are closed have stands
of Virginia pine and shortleaf pine.
These areas are so diverse that onsite investigation of
each unit should be made before proceeding with any land
use practice.
Ur —Urban land. This land type consists of areas
where more than 75 percent of the surface is covered
with streets, buildings of all types, parking lots, railroad
yards, and airports. The soils between these facilities are
used for parks, lawns, playgrounds, cemeteries, and
ts
drainageways. The natural soils have been greatly altered
by cutting, filling, grading, and shaping during the
processes of urbanization. The original landscape, or
topography, and the drainage pattern has been changed.
Most of the acreage of this land type is in the business
districts of Greensboro and High Point or around the
perimeter of the cities. Isolated areas are as small as 5
acres. Slopes are 2 to 10 percent.
The major concern is the excessive runoff from roofs,
roads, and parking lots, which increases the flooding
hazard in lower lying areas. There is a very severe hazard
of waterway and reservoir siltation from areas that are
graded and not immediately stabilized.
Determination of use and treatment requires onsite in-
vestigation.
VaB—Vance sandy loam, 2 to 6 percent slopes. This
well drained soil is on narrow ridges on uplands. The
mapped areas are 3 to 15 acres or more in size.
Typically, the surface layer is brown sandy loam about
6 inches thick. The subsoil is 34 inches thick; the upper
part is mottled strong brown clay, and the lower part is
mottled brownish yellow clay loam The underlying
material, to a depth of 72 inches, is mottled brownish yel-
low, white, and red clay loam.
Included with this soil in mapping are a few small areas
of soils that have a clay loath surface layer. Also included
are small areas of Appling, Enon, and Helena soils.
The organic -matter content of the surface layer is low.
Permeability is slow, available water capacity is low, and
the shrink -swell potential is moderate. Reaction of the
subsoil is strongly acid or very strongly acid. Depth to
bedrock is more than 60 inches. The seasonal high water
table is at a depth of more than 6 feet.
Most areas of this soil are used for cultivated crops or
pasture. The rest are forested. Slope, runoff, erosion, and
slow permeability are the main limitations in the use and
management of this soil.
This soil has moderately high potential for tobacco,
corn, milo, and small grain It has high potential for hor-
ticultural crops, such as tomatoes, sweet corn, green
beans, and peas. Minimum tillage and crop residue
management help to control runoff and erosion Conserva-
tion practices such as maintaining sod in drainageways,
constructing terraces - and diversions, striperopping,
establishing field borders, contour farming, and using
crop rotations that include close -growing crops also help
conserve soil and water. The potential for hay and
pasture plants such as ladino clover, red clover, fescue,
and sericea lespedeza. Proper pasture management helps
to ensure adequate protective cover, which reduces runoff
and controls erosion.
The potential for urban uses, such as houses and
streets, is low because of slow permeability and low
strength. Potential is moderate for recreation areas
because of slow permeability.
This soil has moderately high potential for broadleaf
and needleleaf trees. The dominant trees are white oak,
black oak, post oak, northern red oak southern red oak,
blackjack oak, cedar, maple, hickory, loblolly pine, short -
leaf pine, and Virginia pine. The main understory species
are dogwood, holly, and sassafras. There are no major
limitations in the use and management of this soil for
woodland. Capability unit IIIe-3; woodland group 3o.
VaC—Vance sandy loam, 6 to 10 percent slopes. This
well drained soil is on long, narrow side slopes. The
mapped areas are 3 to 15 acres in size.
Typically, the surface layer is brown sandy loam about
6 inches thick. The subsoil is 34 inches thick; the upper
part is mottled strong brown clay, and the lower part is
mottled brownish yellow clay loam. The underlying
material, to a depth of 72 inches, is mottled brownish yel-
low, white, and red clay loam.
Included with this soil in mapping are a few small areas
of soils that have a clay loam surface layer and a few
small areas of soils that have gravel or small cobbles in
the surface layer. Also included are a few small areas of
Appling, Cecil, Enon, and Helena soils.
The organic -matter content of the surface layer is low.
Permeability is slow, available water capacity is low, and
the shink-swell potential is moderate. Reaction of the sub-
soil is strongly acid or very strongly acid. Depth to
bedrock is more than 60 inches. The seasonal high water
table is at a depth of more than 6 feet.
Most areas of this soil are forested. The rest are used
for cultivated crops, for pasture, or for urban and indus-

IT Corporation ofNorlh Carolinas Inc.
A Member of The IT Croup
APPENDIX C
Present Value Cost Analysis

Present Value of Costs
W.P. Ballard Property,
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
Capital
Costs
Recurring Costs
Option
Brief Description
Description
Cost
Description
Cost
A
Land Acquisition
$ -
O&M
$ -
Connection to a Publicly
Equipment
$ -
Lab Fees
$ -
Owned Treatment Works
Labor
$ -
Operator/Support Staff
$ -
(POTW)
Installation
$ -
Residual Disposal
$ -
Not Avallable
Design
$ -
Connection and Subsequent User fee
$ -
Permit and Compliance fees
$ -
Utility (power, water, eta)
$ -
Sub TOTAL $
Sub TOTAL
$ -
GmndTOTAL
$ -
PresentValue Costs
$ -
Option
Brief Description
Description
Cost
Description
Cost
B
Land Acquisition
$ -
O&M
$ -
Connection to a Privately
Equipment
$ -
Lab Fees
$ -
Owned Treatment Works
Labor
$ -
Operator/Support Staff
$ -
(POTW)
Installation
$ -
Residual Disposal
$ -
NotAvai/able
Design
$ -
Connection and Subsequent User fee
$ -
Permit and Compliance fees
$ -
Utility (power, water, eta)
$ -
Sub TOTAL $ -
Sub TOTAL
$
Grand TOTAL
$ -
Present Value Costs
$ -
Option
Brief Description
Ca itaI
Costs
Recurring Costs
C
Non -Discharge Permit
Land Acquisition
$ -
O&M
$ 15,000.00
Equipment
$ 10,000.00
Lab Fees
$ 3.500.00
Labor
$ 4,000.00
Operator/Support Stag
$ -
Installation
$ 18,900.00
Residual Disposal
$ -
Design
$ 6,500.00
Connection and Subsequent Userfee
$ -
Permit and Compliance fees
$ 675.00
Utility (power, water, etc.)
$ 600.00
Sub TOTAL $ 39,400.00
Sub TOTAL
S 19.775.00
Grand TOTAL
$ 59,175.00
Present Value Costs
$ 148,104.62
Cost Comparison Engineering nnemagves.sls Page 1 of 2

Present Value of Costs
W.P. Ballard Property
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
Option
Brief Description
Ca ItaI
Costs
Recurring Costs
D
Land Based Disposal
Land Acquisition
$ -
OHM
$ -
-Spmy/Ddp
Equipment
$ -
Lab Fees
$ -
Irrigation
Labor
$ -
Operator/Support Staff
$ -
NotAvallable
Installation
$ -
Residual Disposal
$ -
Design
$ -
Connection and Subsequent User fee
$ -
Permit and Compliance fees
$ -
Utility (power, water, etc.)
$
Sub TOTAL
S -
Sub TOTAL
S
Grand TOTAL
$
Present Value Costs
$
Option
Brief Description
Ca ItaI
Costs
Recurring Costs
E
Surface Water Discharge
Land Acquisition
$ -
OHM
$ 3,000.00
Equipment
$ 1.500.00
Lab Fees
$ 10,800.00
Labor
$ 2.940.00
Operator/Support Staff
$ 3,000.00
Installation
$ 3.200.00
Residual Disposal
$ -
Design
$ 4,500.00
Connection and Subsequent User fee
$ -
Pennil and Compliance fees
$ 715.00
Utility (power, water, etc.)
$ 600.00
Sub TOTAL
$ 12,140.00
Sub TOTAL
$ 18, 11530
Grand TOTAL
$ 30,255.00
Present Value Costs
$ 85,349.78
Cast Comparison Engineering Altemativess Page 2 of 2

TABLE 2
Summary of Compounds Observed to be Present in Groundwater
W.P. Ballard and Downgradient Properties
Greensboro, North Carolina
Compounds Detected
NCAC 2L
Sampling
Location
Sampling
Date
Sampling
Contractor lrl
Maximum
Concentration Detected
(ug/L)
Benzene
1.0
GP-4 (3)
9/29/99
B
3.180
Toluene
29
GP-4 (2)
9/29/99
B
14,100
Ethylbenzene
1000
GP-4 (2)
9/29/99
B
1,200
Total Xylenes
530
GP4 (2)
9/29/99
B
5.550
1,2-Dichlorobenzene
none
DMP-1
10/27/99
B
4
1.3-Dichlorobenzene
none
DMP-1
10/27/99
B
1.1
Methylene Chloride
5.0
MW-2
5/29192
A
540
Chloroform
0.19
MW-17
1OM96
B
31
Carbon Tetrachloride
0.3
MW-17
1017/96
B
140
1,2-Dibromomethane
none
EW-4 (3)
8/29/97
B
35
1,1-Dichloroethane
700
MW-7
7/22194
A
38
1,2-Dichloroethane
0.38
EW-2, EW-3 (3)
8/29/97
B
5.3
Vinyl chloride
0.015
DMP-1
10/27199
B
3.6
1,1-Dichloroethene
7.0
MW-3
7/22/94
A
2,100
cis-1,2-Dichloroethene
70
MW-27
8/26/97
B
12,000
trans-1,2-Dichloroethene
70
DMP-1
1/21/99
B
24
1,2-Dichloropropane
0.56
LMP-1
10/26/99
B
1.560
Napthalene
21
EW-4 n1
8/29/97
B
38
Trichloroethene
2.8
MW-27
8/26/97
B
64,000
Tetrachloroelhene
0.7
MW-3
5/29192
A
270,000
1,1,2,2-Tetrachloroethene
none
EW-4 tat
8/29197
B
90
1,1,1-Trichloroethane
200
MW-6
12/2/98
B
19
1,1,2-Trichloroethane
none
EW-4 (3)
8/29/97
B
120
1,3,5-Trimethylbenzene
none
EW-4 (3)
8129/97
B
38
1,2,4-Trimethylbenzene
none
EW-4 tat
8/29/97
B
38
Bromoform
0.19
DW-1
10127/99
B
1
Methyl tert-butyl ether (MTBE)
200
GP-3 jzl
9/29/99
B
66
Notes: (1) A - indicates sample collected by Mortensen Engineering, Inc.
B - indicates samples collected by IT Corporation (formerly Fluor Daniel GTI)
(2) GP samples collected as part of Geoprobe investigation to delineate small
petroleum hydrocarbon plume comingled with chlorinated solvent plume.
(3) EW samples collected during the performance of pilot testing activities.

TABLE 3
Estimated Influent Concentrations
W.P. Ballard and DownBmdlent Properties
Greensboro, North Carolina
Combined Influent Weighted Average for Treatment System Design (with 25% S.F.)
1,2-
Carbon
cis-1,2-
trans-1,2.
Methylene
Dichlam-
NapMa-
tetra-
Contaminanl
PCE
TCE
1,1-DCE
DCE
DCE
chloride
1,1,1-TCA
1,1,2-TCA
1,1-DCA
Chloroform
propane
Benzene
Toluene
lane
chloride
(uOIL)
(ue1L)
(uglL)
(uOtL)
(uglL)
(usrL)
(uOIL)
(uelL)
(ugrU
(u8/L)
(uBtL)
(un/U
(uOfL)
(uB/L)
(ue/L)
Influent
13,042
2,516
10
783
3
1
1
1
0
1
163
0
0
0
2
Concentm0on
Design Influent flow rate = 50 gpm

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REV. DRAWING DATE: ACAD FILE:
12/23/99
PORTIONS OF THE CITY OF GREENSBORO
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DESIGNED: DETAILED: PROJECT NO: FIGURE:
CAB 107535 2

IT Corporation oflVorth C wfinn, In&
A Dfember of The fT Croup
ATTACHMENT A
Engineering Alternatives Analysis

IT Corporation oPNorth Cerolinn, Inc.
thev,*Oup
1000 Perimeter Park Drive, Suite 1
Morrisville, NC 27560-9291
Tel. [phone]
Fax. [phone]
A Member of The IT Croup
Engineering Alternatives Analysis
W.P. Ballard Property
2701 Branchwood Drive
Greensboro, Guilford County, North Carolina
NCDENR Groundwater Incident # 6953
IT Corporation of North Carolina Project # 107535
January 19, 2000
Prepared for.,
Sears Logistics Services, Inc.
3333 Beverly Road
Department 824RE A3-276A
Hoffman Estates, ILL 60179
Prepared by.,
IT Corporation of North Carolina, Inc.
1000 Perimeter Drive, Suite I
Morrisville, North Carolina 27560
[phone]
IT Corporation of North Carolina
Charles A. Bertz,
Project Engineer
IT Corporation of North Carolina
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ff Corporation ofNorth Carolina, Inc.
I A Afember of The IT Croup
Engineering Alternatives Analysis Page 1
W.P. Ballard Property, 2701 Branchwood Drive, Greensboro, North Carolina January 19, 2000
I. General Information
A. Basic Identification of the Project
❑ Facility Name: W.P. Ballard Property
❑ County: Guilford County
❑ Facility Address: 2701 Branchwood Drive
❑ Facility Telephone Number: Facility currently inactive
❑ FAA Preparer: IT Corporation of North Carolina, Inc.
1000 Perimeter Park Drive
Suite I
Morrisville, NC 27560
[phone]
f The subject site is a former dry cleaning supply located at 2701 Branchwood Drive, approximately 400
feet east of Battleground Avenue in Greensboro, Guilford County, North Carolina. Currently, the site is
unoccupied. The site location is shown on a portion of the United States Geological Survey 7.5-minute
topographic map of Greensboro, North Carolina Quadrangle, included as Figure 1. A site map showing
the location of the site, downgradient properties and pertinent site features is included as Figure 2.
B. Provide a Detailed Description of the Project Which Will Require Wastewater Disposal
The proposed project is the installation and operation of a soil and groundwater remediation system to
address a chlorinated solvent plume present within the subsurface of the subject site and downgradient
properties. The main constituents of concern present include tetrachloroethene (PCE) and its reductive
dechlorination by-products (TCE, 1,1-DCE, cis-1,2-DCE, trans-1,2-DCE and vinyl chloride). Dissolved phase
petroleum hydrocarbon concentrations have also been detected, but are isolated to the location of a former
gasoline UST. A summary of groundwater analytical results from the recent October 1999 sampling event
is included as Table 1.
The following remedial system description is a conceptual design of the groundwater recovery and
treatment portion of the turnkey system, as submitted to the NCDENR in a Corrective Action Plan dated
May 20, 1999. Once the NPDES permit has been issued, the engineered design of the groundwater
treatment system will be finalized and submitted for review with the application for the authorization to
construct. This application will include detailed plans and specifications.
Groundwater and Soil Vapor Recovery and Treatment Design Summary
The proposed soil and groundwater remedial system will consist of a deep high vacuum dual phase
(HVDP) extraction system and a shallow low vacuum soil vapor extraction system. The purpose of the
HVDP and SVE systems will be to reduce the residual adsorbed and dissolved phase chlorinated solvent
concentrations. The HVDP/SVE system will use a two -level system to address adsorbed and dissolved
phase concentrations in areas of varying permeability. Shallow soils, located from the surface to
approximately 35 to 40 feet bgs exhibit a relatively low permeability with increased permeability at greater

ff Corporation ofNorth Carolinar Inc.
A Member of The IT Croup
Engineering Alternatives Analysis Page 2
W.P. Ballard Property, 2701 Branchwood Drive, Greensboro, North Carolina January 19, 2000
depths. To address the adsorbed phase contaminants in the shallow soils and those created in the
deeper smear zone during dewatering activities, a multi -level system will be required.
To dewater the formation and remove adsorbed phase contaminants from the created vadose zone, a
combination groundwater recovery system and high vacuum soil vapor recovery system will be employed.
Groundwater recovery will be performed using downhole submersible pumps set at depths ranging from
60 to 75 feet bgs. Soil vapor recovery will be performed using high vacuum positive displacement
blowers. Remediation of the shallow adsorbed phase contamination will be performed using soil vapor
extraction. Extraction will be performed from shallow wells installed at depths ranging from 30 to 40 feet
bgs using a regenerative -type blower. The shallow soil vapor extraction points are anticipated to be used
exclusively in the vicinity of the Ballard property source area and immediately downgradient, adjacent to
the former SLS Axton -Cross building.
Based on the current groundwater analytical data, a conceptual layout of the dual phase extraction system
was prepared. The layout uses 28 deep dual -phase extraction wells, 12 shallow soil vapor extraction
wells, and 9 air injection points.
For the purposes of this permit application, only the groundwater recovery and treatment portions of the
system design will be discussed further.
Groundwater Recovery and Treatment System Components
Based on the pilot testing activities performed in September 1997, the following recovery rates were
^I determined for use in preparing this conceptual design. Groundwater recovery from the deep high
vacuum dual phase recovery points will be performed at a constant rate of 0.5 to 1.0 gallons per minute
(gpm), per recovery point. Higher initial recovery rates are attainable, but will not be overly beneficial to
the long term performance of the remediation system. Therefore, the HVDP system will be designed to
recover a minimum of 28 gpm from the 28 deep wells. To accommodate potential future expansion of the
recovery well network, the treatment system will be designed for an operating flowrate of 50 gallons per
minute.
Dual Phase Extraction Wells
t- Based on the aerial extent of the total dissolved phase plume, as determined during the recent
groundwater sampling events, a total of 28 deep high vacuum dual phase recovery wells are proposed to
be installed. The deep dual phase extraction wells will be installed will be installed as Type II wells,
advanced to an approximate depth of 60 to 75 feet below ground surface (bgs). The wells will be
_ constructed of 20 to 35 feet of 4-inch diameter schedule 80 PVC riser and 40 feet of 4-inch diameter 0.020
slot schedule 304 stainless steel screen. Washed sand will be installed in the annulus of the well boring
from the bottom of the well to a point approximately one foot above the top of screen elevation. The well
annulus will then be completed to grade with 2 - 3 foot bentonite seal and cement grout to the surface.
j The dual phase extraction wells will be secured inside steel vaults. The steel vaults will be flush mounted
with the existing grade and secured with concrete. The steel vault will be designed to be traffic -bearing.

I I
ff Corporation ofNorth CRmfina� Inc.
A Alemher of The IT Group
Engineering Alternatives Analysis Page 3
W.P. Ballard Property, 2701 Branchwood Drive, Greensboro, North Carolina January 19, 2000
Dual Phase Extraction Groundwater Recovery Pumps
Groundwater extraction will be performed from the 28 deep HVDP recovery points using CEE AP-3
pneumatic submersible pumps or equivalent. CEE AP-3 pumps are capable of recovering up to 3 gallons
per minute of fluids from depths of 70 feet below ground surface with 2 feet of submergence at the pump
fluid inlet. Higher flow rates are attainable with greater elevations of submergence. Groundwater will be
conveyed from the pump into the well vault using 3/4-inch diameter flex -hose. The fluid recovery lines from
the individual recovery pumps will be manifolded into a single 2-inch SDR 11 HDPE chase pipe for gravity
feed into the treatment compound, where it will be discharged into the treatment system. Air will be
supplied to drive the pumps using a reciprocating compressor capable of 30 scfm at 70 psi. Air
conveyance lines will be constructed of 1-inch diameter schedule 80 PVC.
Groundwater Treatment Components
Recovered groundwater will be processed by an ex situ treatment system prior to being discharged. The
treatment system will consist of a two phase process. Recovered groundwater will be pumped directly
into a surge tank and subsequently to a shallow tray air stripper. Water recovered by the vapor extraction
separation vessels associated with the soil vapor recovery operations will be intermittently pumped into
the influent surge tank as needed. Three sensor driven direct drive transfer pumps will convey the
recovered groundwater from the vapor extraction separation vessels to the influent surge tank. A third
sensor driven direct drive transfer pump will be used to convey recovered groundwater from the surge
tank to the air stripper. The air stripper will be sized to handle a minimum influent flow of 50 gpm, and will
utilize, at a minimum, a 900 cfm blower for air injection. Final sizing of the air stripper will be based on the
required effluent limitations specified in the NPDES permit. A fourth sensor driven direct drive transfer
pump will convey the treated groundwater from the air stripper sump through a series of bag pre -filters,
into two 50-gpm granular activated carbon (GAC) vessels placed in series. The treated groundwater
exiting the GAC vessels will gravity feed to the discharge point. It is proposed that the discharge line from
the treatment system be tied into the existing stormwater sewer system located on the former SLS
property.
System Controls
One main electric control panel will control the remediation system. A licensed electrical contractor will
follow guidelines in the National Electric Code and the local municipal code during electrical installation.
System controls are summarized as follows:
■ High-level control switch in the air/moisture separation vessels will shut down the
respective HVDP vacuum pump or low vacuum SVE blower.
High-level control switch in the air stripper sump will shut down the pneumatic pump air
supply compressor and both the HVDP vacuum pump and low vacuum SVE blower.
Low-pressure interlock sensor in the air stripper will shut down the pneumatic pump air
supply compressor and both the high vacuum pump and low vacuum blower.

If Corporation ofNorth Carolma, Inc.
A Member of The IT Croup
Engineering Alternatives Analysis Page 4
W.P. Ballard Property, 2701 Branchwood Drive, Greensboro, North Carolina January 19, 2000
High-pressure interlock sensor in the bag/cartridge filters will shut down the pneumatic
pump air supply compressor and both the high vacuum pump and low vacuum blower.
IN A shut down of any portion of the catalytic oxidizer system will shut down the entire
HVDP/SVE system.
The remediation system will include a programmable logic controller (PLC) and computer -based man -
machine interface (MMI) with remote monitoring capability using dial -up modem communications. Real-
time computer operating screens and graphical data will be used to interface to the system for the purpose
of controlling and monitoring the system either locally or remotely. All critical system operational
parameters will be continuously monitored and recorded in data logs residing on the hard drive of the site
MMI computer. This data will be used for process evaluations by the project team. The data files will be
maintained for the duration of the project for the historical record. In addition, the system will include a
remote alarm system consisting of an autodialer that accepts PLC alarm outputs and sends voice
descriptions of any alarm condition to a list of phone numbers for site technicians and project support
personnel. The remote alarm system will also notify select personnel via pagers.
Environmental Piping, Fittings and Valves
Groundwater recovered by the HVDP system will be transferred to the treatment compound in lines
constructed of 2-inch diameter SDR 11 HDPE piping and fittings. Groundwater recovery from the dual
phase wells will be performed using 5 individual trunk lines. Four trunk lines will manifold 5-wells and one
will manifold 8-wells.
Electrical
Electrical work shall be conducted in accordance with the National Electrical Code (NEC) and other
applicable Federal, State or local codes. Equipment installed in the treatment system building will be UL
listed and approved. The control panel shall be mounted outside the hazardous area and shall be NEMA
IV (weatherproof) rated.
C. If Existing Facilities Will Be Used As Part Of An Expansion. Discuss Those Existing Units
No existing recovery or treatment facilities will be used during the proposed remediation activities.
Although, the proposed groundwater treatment system will be installed within an existing warehouse
building located on the W.P. Ballard property.
D. Indicate If The Project Will Be Constructed in Phases
The proposed recovery and treatment system described above will be installed as a turnkey system.

ff Cogoradon ofNorth Cam► ua, Ine.
A Afember of The IT Group
Engineering Altematives Analysis Page 5
W.P. Ballard Property, 2701 Branchwood Drive, Greensboro, North Carolina January 19, 2000
II. Evaluation of Disposal Alternatives
This evaluation will review the following disposal alternatives which may be capable of being implemented
at the subject site.
• Connection to a Publicly Owned Treatment Works (POTW)
• Connection to a privately owned treatment works
• Individual subsurface system
• Drip and/or Spray Irrigation
• Reuse
• Surface Water Discharge through the NPDES program
The following is a brief discussion regarding the feasibility of implementing the various treated
groundwater disposal options.
Connection to a Publicly Owned Treatment Works (POTW)
An existing sanitary sewerage system is currently in operation within the City of Greensboro and
residential, commercial and industrial service is available within the vicinity of the subject site. However,
discussions with the city wastewater treatment facility, indicated that the City of Greensboro has
suspended their acceptance of groundwater until further notice. Ms Sharon Miller, the City of Greensboro
Pretreatment Coordinator, has provided a letter stating the aforementioned. A copy of the letter is
included in Appendix A.
Connection to a Privately Owner Treatment Works
A privately owned treatment works capable of accepting the proposed treated groundwater stream was
not determined to be present within the immediate vicinity of the subject site.
Individual Subsurface System
Concurrent with the preparation and submittal of this NPDES Permit application, a Non -Discharge Permit
application is also being prepared for the subsurface re -injection of treated groundwater. Under the
proposed Non -Discharge Permit, treated groundwater would be re -injected into the subsurface
hydraulically upgradient of the dissolved phase chlorinated solvent plume through an array of vertical
injection wells. The purpose of applying for both an NPDES permit and a Non -Discharge permit are two-
fold. First, the NPDES permit will be used initially for the discharge of 100-percent of the treated
groundwater during the procurement of Non -Discharge permit and construction of the re -injection system.
Secondly, the NPDES permit would be retained in addition to the Non -Discharge permit as an alternate
disposal option. As an alternate disposal option, the NPDES permit would be used to discharge treated
groundwater during the performance of maintenance activities on the re -injection system.

ff Corporation ofNorth Carolina, /nc.
A Member of The IT Croup
Engineering Alternatives Analysis Page 6
W.P. Ballard Property, 2701 Branchwood Drive, Greensboro, North Carolina January 19, 2000
Drip and/or Spray Irrigation
Neither drip nor spray irrigation are commonly used disposal options for the discharge of treated
groundwater. Per the requirements of this EAA, a general soils analysis report has been prepared and is
included in Appendix B. However, the area being remediated is a commercial/residential area. The W.P.
Ballard property and downgradient former SLS property are both commercial lots with fixed structures and
paved lots. Neither property has a suitable area for the land application of treated groundwater.
Additionally, the subject properties on which the remediation is being performed are not currently owned
by the remediating party. Therefore, this alternative is not considered to be available.
Surface Water Discharge
As described above, the disposition of the treated groundwater is initially proposed to be performed
exclusively through an NPDES permitted discharge. Subsequently, disposition of treated groundwater is
proposed to be performed through both an NPDES permit and a Non -Discharge permit. The purpose of
applying for both an NPDES permit and a Non -Discharge permit are two -fold. First, the NPDES permit will
be used initially for the discharge of 100-percent of the treated groundwater during the procurement of
Non -Discharge permit and construction of the re -injection system. Secondly, the NPDES permit would be
retained in addition to the Non -Discharge permit as an alternate disposal option. As an alternate disposal
option, the NPDES permit would be used to discharge treated groundwater during the performance of
maintenance activities on the re -injection system.
Treated groundwater from the remediation system is proposed to be discharged to an unnamed tributary
of Philadelphia and Buffalo Lakes. The treated groundwater would be discharged to an existing
stormwater sewer located on the former Sears Logistic Services property, located immediately south of
the W.P. Ballard property. Treated groundwater would be conveyed by the stormwater sewer to the
unnamed tributary referenced above. The outfall is a 66-inch reinforced concrete pipe located northeast
_ of the intersection of Elkmart Drive and Dellwood Drive. From the oufall the treated groundwater would
travel approximately 350-feet north prior to joining the main unnamed tributary of Philadelphia and Buffalo
Lakes, which generally runs from west to east.
Preliminary discussions with personnel from the USGS indicates that the unnamed tributary may be
classified as having a zero 7Q10 and 30Q2 flows. Recent field reconnaissance of the unnamed tributary
appeared to indicate that it would be considered a flowing stream with a positive 7Q10 and 30Q2 flows.
Attached Figure 1 is a portion of the Greensboro, North Carolina Quadrangle USGS topographic map
showing the approximate location of the storm sewer outfall to the unnamed tributary. Please note that the
USGS topographic map was most recently photo -revised in 1968, as such it does not accurately depict
the current area conditions. A portion of a City of Greensboro stormsewer map which provides a clearer
picture of the current area configuration is attached as Figure 3. A site map of the former SLS property
showing the proposed treated groundwater discharge location, a storm sewer catch basin, and the path of
the storm sewer across the site is included as Figure 4.
Alternate surface water bodies were identified for the discharge of treated groundwater. The nearest
alternate surface water would be an unnamed tributary of North Buffalo Creek, located across
Battleground Avenue, approximately 2,500-feet southwest of the proposed treatment system location.

F
t IT Corporadon OPNOrth Camfina, Inc.
A 31eouber of The IT Croup
Engineering Alternatives Analysis Page 7
W.P. Ballard Property, 2701 Branchwood Drive, Greensboro, North Carolina January 19, 2000
Discharge to this unnamed tributary does not appear to be feasible disposal option.
III. Summary of Disposition Alternatives
Based on the evaluation of disposal options it appears that the only viable alternatives are surface water
discharge through an NPDES permit and subsurface re -injection through a Non -Discharge permit. As
discussed in the previous sections, it is proposed that treated groundwater be discharged using both
discharge permit options. Initially, for approximately the first year of operation, the NPDES permit would
be used exclusively for the discharge of treated groundwater to an unnamed tributary of Philadelphia and
Buffalo Lakes. Following the approval of a Non -Discharge permit, the primary discharge option would
become direct re -injection of treated groundwater into the subsurface through a network of vertical
injection wells. The NPDES permit would still be retained as an alternate disposal option, to be used
when maintenance is performed on the reinjection network.
Included as Appendix C is the Present Value Cost Analysis of the applicable disposition alternatives.

IT Corporation oPNokh Carolinas Inc.
A Member of The IT Croup
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A Afemher of The IT Croup
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REV. DRAWING DATE: ACAD FILE:
1/11/2000
QUADRANGLE LOCATION N PORTION OF THE GREENSBORO, NC
SCALE 1:24,000 USGS TOPOGRAPHIC MAP
0 2000 4000
SITE: W.P. BALLARD PROPERTY PM:
TR
SCALE IN FEET LOCATION: PEIRG:
GREENSBORO, NORTH CAROLINA
SOURCE: TOPOGRPHAY TAKEN FROM USGS 7.5 MINUTE QUADRANGLE
DESIGNED: DETAILED: PROJECT NO: FIGURE:
Greensboro, NC 1
PJB 107535

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