NC0087874_Complete File - Historical_20070412

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NCDENR
306 D2,
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
April 12, 2007
Mr. Frank C. Brown
REXAM, Inc.
4201 Congress Street
Charlotte, N.C. 28209
Subject: Rescission of NPDES Permit NCO087874
REXAM Flexible Packaging site
Guilford County
Dear Mr. Brown:
Division staff has confirmed that the subject permit is no longer required. Therefore, in
accordance with the request submitted by your Authorized Representative [Envision Geological
Services], NPDES Permit NCO087874 is rescinded, effective immediately.
If in the future your firm wishes to discharge wastewater to the State's surface waters, they must
first apply for and receive a new NPDES permit. Discharge of wastewater without a valid
NPDES permit will subject the responsible party to a civil penalty of up to $25,000 per day.
If you have questions about this matter, please contact Charles Weaver of my staff at the
telephone number or address listed below.
Sin ely,
fi(Al an W. ek
cc: Central Files
Winston-Salem Regional Office / Corey Basinger
NPDES Permit file '
Fran McPherson, DWQ Budget Office
James Gonsiewski / Envision Geological Services [4800 Adams Ridge Drive, Greensboro, NC 274071
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 North Salisbury Street, Raleigh, North Carolina 27604
Internet: h2o.enr.statem.us
Phone: 91 9-733M, extension 511 / FAX [phone]
charles weaver0mcmailmet
Nne
oithCarolina
Natmallff
An Equal Opportunity/Affirmative Action Employer —50% Recycled/10% Post Consumer Paper

4
ENJI ISION
GEOLOGICAL SERVICES
OF NORTH CAROLINA, LLC
April 3, 2007
Mr. Joseph Corporon
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Aquifer Protection Section, NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Request to Rescind NPDES Permit
Former REXAM FLEXIBLE PACKAGING
2600 Phoenix Drive
Greensboro, Guilford County
NCDENR Incident Number 17427
NPDES Permit No. NCO087874
Dear Mr. Corporon:
I APR 4 .
On behalf of REXAM Industries Corp. (REXAM), ENVISION GEOLOGICAL SERVICES of NC,
LLC (ENVISION GEO) is requesting that the NPDES Permit, NC0087874, for the former REXAM
FLEXIBLE PACKAGING (currently NORTH STATE FLEXIBLES) facility located at 2600 Phoenix
Drive, Greensboro, Guilford County be rescinded. This request is being made based on the North
Carolina Department of Environment and Natural Resources (NCDENR) August 18, 2006 letter to
Mr. Frank C. Brown of REXAM. A copy of this letter is attached for your convenience.
The NCDENR's request to rescind the permit was made due to the impaired condition of the
proposed receiving stream (Buffalo Creek), the "zero flow condition" of the stormwater system,
and the realization by the NCDENR that the effluent for the permitted groundwater remediation
system proposed to be installed at the Site would have a BOD component that would not be
appropriate for discharge to the impaired stream. This realization came from reviewing the results
of a groundwater remediation pilot test conducted by ENVISION GEO. The results of the pilot test
were submitted to the NCDENR in April 2006 in ENVISION GEO's Pilot Test Evaluation Report.
Please be aware that at no time in the permitting process did REXAM or ENVISION GEO indicate
that the effluent would not have a BOD component. It was stated in the Corrective Action Plan
(CAP) that the recovered groundwater would be mixed with molasses and that the excess treated
groundwater would have to be discharged.
As a reminder, the pilot test was conducted as a requirement of the NCDENR in order to receive
the final CAP approval for the remediation of this Site. Final CAP approval was received in May
2006. The purpose of the pilot test was to demonstrate that the enhanced biodegradation system
proposed for the Site will contain and control the chlorinated VOC plume found in the groundwater
at the Site; that the horizontal injection wells will provide for sufficient infiltration to allow for the
introduction of the carbon substrate (molasses solution) that will be used to enhance the biological
activities at the Site; and that the addition of the carbon substrate will promote the geochemical
changes that will speed the degradation of the contamination at the Site.
11 Sleepy Hollow Court, Allentown, NJ 08501 4800 Adams Ridge Drive, Greensboro, NC 27407
[phone] Fax: [phone] [phone]

E N I$ I O N Mr. Joseph Corporon
NCDENR
NPDES Permit
April 3, 2007
Page 2 of 2
The other purposes of the pilot study were to determine the approximate volume of water that
would necessarily be discharged to the stormwater sewer; and to determine the BOD that this
effluent would have.
The fact that the Site's soil will not accept, through the horizontal wells, the same volume of water
that is being recovered by the down -stream recovery well (with a recovery rate established to
create a cone of depression), requires that excess treated groundwater to which molasses has
been added must be discharged. Please note that this was pointed out in the October 13, 2003
cover letter for the NPDES Discharge Permit application package. Alternatively, we will be
pursuing an amendment to the CAP with a proposed modification to the biodegradation remedial
technology. The pilot test clearly demonstrated that the injection of a molasses and water
mixture would enhance the degradation of the CVOC groundwater contamination. Based upon
the BOD component of the groundwater, discharging any recovered groundwater is not allowed
and, based upon the costs associated with the offsite disposal of the recovered water
generated during the pilot test, offsite transportation and disposal of any recovered groundwater
is not cost effective. As a result, we will propose to revise the CAP by eliminating the active
groundwater recovery portion from the proposed treatment system since the groundwater
monitoring conducted to date shows that the plume appears to be stable. The molasses
solution will be added to the aquifer via gravity feed through the two (2) horizontal wells and any
of the onsite monitoring wells that exhibit CVOC contamination at a rate at which the solution
could infiltrate without the application of any mechanical force. Under this approach, the noted
NPDES Discharge Permit would not be needed.
Please be aware that the referenced NPDES Discharge Permit has never been used as there was
no discharge from the groundwater treatment pilot test system to either the surface water or to the
local publicly owned treatment works (POTW). Wastewater generated while conducting the pilot
test was containerized and shipped offsite for treatment and disposal.
Please also note that NCDENR's suggestion on reapplying to the local POTW for permission to
discharge to the POTW's sanitary wastewater treatment system was met with a negative
response from the City of Greensboro's Industrial Waste Section in their letter dated January 12,
2007. A copy of this letter is attached for your convenience.
We appreciate your consideration and cooperation in the submission of this letter. If you have any
questions or need additional information, please contact the undersigned at [phone] or
[phone].
Sinceft
James J. onsiews i, .G.
Senior Geologist
cc: Mr. Frank Brown — REXAM
Appro y
Mark P. Ro n
Operations Manager

January 12, 2007
[via ema....... _ __ .,,
Mr. Abraham Platt, Senior Engineer
ENVISION ENVIRONMENTAL, INC.
11 Sleepy Hollow Court
Allentown, NJ 08501
RE: Groundwater Discharge Permit Request for REXAM Flexible Packaging
2600 Phoenix Drive
Greensboro, NC 27406
Dear Mr. Platt,
As I indicated in several telephone conversations with you, representatives from REXHAM
Flexible Packaging and staff from the State of North Carolina Division of Water Quality NDPES
Permits Section, the City of Greensboro Industrial Waste Section is no longer issuing new
Groundwater Remediation Discharge Permits and has not issued a new permit in over 6 years.
The City of Greensboro is under no legal obligation to accept groundwater remediation
discharges and discontinued the program several years ago. We encourage all facilities with new
groundwater remediation discharges to pursue an NPDES permit from the State of North
Carolina for direct discharge to the surfaces waters of North Carolina.
I regret we are unable to assist REXHAM in their current situation.
If you have any questions or feel that my office can be of any assistance in exploring other
alternatives for REXHAM, please feel free to contact me at 336-433-7229 or via email at
[e-mail]
�Sincerely,
� J
M ' Martha
r omeu Q� �
Martha Groome
Laboratory and Industrial Waste Section Supervisor
cc: Sharon Miller, Pretreatment Coordinator
640 P.O. Box 3136 • Greensboro, NC 27402-3136 • www.d.greensboro.nc.us • [phone] • TTY # 333-6930

Frank C. Brown, Esq., President
REXAM, Inc.
4201 Congress Street
Charlotte, North Carolina 28209
Dear Mr. Brown:
Michael F. Easley, Governor
Sate of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Plan W. Klimek, P.E., Director
Division of Water Quality
August 18, 2006
Subject: Review of Pilot Study — Request for Letter to
Rescind NPDES Permit NCO087874
Proposed Discharge to Surface Waters
from former REXAM Flexible Packaging,
Greensboro, North Carolina
Guilford County
The Division of Water Quality (the Division) has received and reviewed your Pilot Test Evaluation Report
(April 2006) provided for the subject site by your consultant, Envision Geological Services of North Carolina,
LLC. We must disagree with certain conclusions in this report and ask for your further correspondence.
The Division issued this permit considering a discharge of remediated groundwater with volatile organic
compounds (VOCs) treated to surface water -quality standards. According to the above report, you intend to
remediate groundwater using molasses producing an oxygen -consuming waste. You also expect to discharge
approximately 880 gpd, and you estimate resulting concentrations of biochemical oxygen demand (BODS) to
range from 27.6 to 83.4 mg/L. This effluent is significantly different in character from the effluent on which
we based the original permit issuance.
The proposed receiving stream, Buffalo Creek, is formally impaired for ammonia. The Division may not permit
new discharges, or expand existing discharges containing oxygen -consuming wastes, to waterbodies impaired for
ammonia. Therefore, this discharge as newly characterized is strictly forbidden. Please realize that any detectable
component of DOD in your effluent is unacceptable.
Please consider reapplying to the local publicly owned treatment works (POTW) for disposal of this waste. Now
that you have committed to a viable groundwater treatment alternative and documented an oxygen -consuming
waste, the municipality may be more receptive to accepting this discharge as compatible with other influent.
In conclusion, the Division requests that you send us a letter asking us to rescind NPDES permit NC0087874.
Your cooperation and understanding are greatly appreciated.
If you have questions, or if we can be of further service, please contact Joe Corporon at
[Joe.Corooron(aa-)ncmail.netl or call [phone], extension 597.
Resp tfully,
,4y, ; Alan W. Klimck,"P.E.
cc: Central Files
Winston-Salem Regional Office, Water Quality Section
NPDES Unit
EnVision Geological Services, LLC, 480OAdams Ridge Dr., Greensboro, NC 27407
ern
NCDENR
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

[Fwd: REXAM Inc. NCO087874]
Subject: [Fwd: REXAM Inc. NC0087874]
From: Mark McIntire <[e-mail]>
Date: Mon, 21 Feb 2005 09:35:17 -0500
To: Joe Corporon <[e-mail]>
hey joe. hope you're doing well. I'm playing catch up...
looks like you issued this permit. could you look into this issue and make the appropriate changes, if necessary? sounds like the facility is using
molasses to bioremediate... which means they probably do have a substantial effluent bod. we may need to have them provide us with some
samples to determine if a limit is appropriate.
thanks!
mark
------- Original Message--------
Subject:REXAM Inc. NCO087874
Date:Wed, 16 Feb 2005 10:08:19 -0500
From:Cecil G. Madden <Cecil.Madden(cr),ncmail.net>
Organization:DENR/DWQ/Construction Grants and Loans
To:Dave Goodrich <Dave.Goodrichnancmail.net>
CC:Mark McIntire <mark.mcintire(a)ncmail.net>, "Kenneth O. Pohlig, PhD., P.E." <Ken.POhligPncmail.net>
Hello Dave,
An NPDES Permit was issued to REXAM, Inc. associated with a groundwater
remediation project. As the project was presented to NPDES, it may not
have been clear what the nature of the waste will be. They will be
pumping groundwater, sending it through two bag filters, sending it
through two activated carbon filters, adding molasses and sending the
flow back to two horizontal wells. The remaining treated water (mixed
with molasses) (likely high in BOD) will go to the permitted discharge
location. It would appear that the NPDES Permit needs a BOD Limit.
Please advise if the permit needs to be modified, and advise if doing so
will be initiated by the Division or if it needs to be initiated by the
owner.
Regards,
Cecil G. Madden, Jr., P.E.
1 of 2 2/22/2005 3:09 PM

AT,c9
Q
0 Y
February 16, 2005
Mr. Frank C. Brown, President
REXAM, Inc.
4201 Congress Street
Charlotte, North Carolina 28209
SUBJECT:
Dear Mr. Brown:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Acknowledgement of Request for
Authorization to Construct
REXAM, Inc. Groundwater Treatment System
NPDES Permit No. NCO087874
Thank you for your January 28, 2005 letter regarding your request for Authorization to
Construct. We received your request on January 21, 2005 and acknowledged that request on the
same day. The application and supplemental information are currently under review.
However, when the NPDES Permit No. NCO087874 was issued, the Division was
unaware of the wastewater characteristics resulting from the proposed addition of molasses to the
waste treatment stream. Thus, the NPDES permit may require modification, and we are working
with the NPDES staff to determine any necessary changes. Currently there is no mechanism
proposed for the removal of BOD5 from the waste stream prior to discharge to the storm drain.
Please identify a range of anticipated BOD5 concentrations and provide a design for reducing the
concentration prior to discharge.
It is our understanding that you think you need an Authorization to Construct facilities
associated with the pilot project which was permitted through an Insitu Remediation Injection
Well Permit. That permit only authorized the injection of potable water mixed with molasses as
a pilot study. If a discharge will not be required associated with running the pilot study, then an
Authorization to Construct will not be required at this time, since the discharge facilities will not
need to be constructed. If a discharge is essential to the pilot study then plans and specifications
must be generated for the facility using potable water, molasses, horizontal well injection, BOD5
reduction, and discharge.
If you have the capability to obtain results from the pilot study without a discharge to the
waters of the state, we would prefer to receive the results prior to issuance of the Authorization
to Construct. These results would further help to characterize the quality of the water that must
be treated and ultimately discharged.
Plans and specifications that were provided do not indicate the injection of potable water
mixed with molasses. They indicate the recovery of groundwater, the treatment of groundwater
with two bag filters and two activated carbon filters, the addition of molasses, and injection of
Construction Grants and Loans Section
1633 Mail Service Center Raleigh NC 27699-1633 One
Phone: [phone] / FAX: [phone] / Internet: www.nccgi.net North iCa+roliina
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/l0% Post Consumer Paper NatA( Q1`b(

Mr. Frank C. Brown, President
Page 2
February 16, 2005
the solution into two horizontal wells, with the discharge of excess molasses laden water to the
storm drain. Typically we would expect that the Non Discharge Permit and our Authorization to
Construct would have to be issued on or about the same time. We understand that Tom
Cadwallader in the Aquifer Protection Section is reviewing the Non -Discharge Permit Section.
We are currently coordinating our reviews with the Aquifer Protection Section.
In the meantime, we will continue our review of the proposed project. However, until the
above -mentioned issues are resolved, an Authorization to Construct cannot be issued.
If you have any questions concerning this matter, please call me at [phone].
Sincerely 4 4ssistan;oiefDaniel . Blaisdell, P.��
Engineering Branch
DMB/dr
cc: Blue Ridge Geological Services, Inc. - Attention: Jeffrey Gerlock, L.G.
DWQ Winston-Salem Regional Office SWP Section
DWQ Winston-Salem Regional Office Aquifer Protection Section
Water Quality Central Files
Dave Goodrich, Surface Water Protection Section
Tom Cadwallader, P.E., Aquifer Protection Section
Kenneth O. Pohlig, Ph.D., P.E.
Mark Hubbard
ATC Files

Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
November 2, 2004
Frank C. Brown, Esq., President
REXAM, Inc.
4201 Congress Street
Charlotte, North Carolina 28209
Subject: Issuance of NPDES Permit NCO087874
for Contaminated Groundwater Treatment System
located at the former REXAM Flexible Packaging
Guilford County
Dear Mr. Brown:
The Division of Water Quality (the Division)'hereby is"sues this permit final for the subject facility.
This permit is issued to REXAM, Inc. pursuant to'ihe'requiiements 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.
The Division has received comments on the draft permit (dated Junel4, 2004) from your authorized
consultant, Envision Environmental, Inc. and provides the following responses:
Items 3 and 4. Your request to supply a non-resettable totalizing mechanical flow meter is
acceptable. Regular field verification of instrument calibration within 10% of
factory specifications is acceptable. An additional chart recorder is not required.
Item 5 Parameters 1,1, Dichloroethene and Tetrachloroethene will not be limited initially, but all
effluent limitations and monitoring conditions are subject to subsequent analytical data to
be provided according to the permit after treatment system startup.
Items 6 and 7 Discussion and limits governing the use of biocides and TRC remain in the permit,
but apply only if these parameters are used at the facility.
Item 8 Please submit any petition to relax parameter monitoring or limits only after one full year
of documented discharge (not withstanding treatment system down time). This minimum
time frame is necessary to evaluate discharge consistency.
Item 9 Pending confirmation of system design (to be established during Authorization to
Construct permit review), this contaminated groundwater treatment system is expected to
be classified Class I.
ern
NCDENR
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

REXAM, Inc.
Issuance of final NPDES Permit NCO087874
Guilford County
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing upon written request within thirty (30) days
after receiving this letter. Your request must be in the form of a written petition conforming to Chapter
150B of the North Carolina General Statutes, and must be filed with the office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is
made, this permit shall be final and binding.
This permit is not transferable except after notifying the Division of Water Quality. The Division may
require modification, or revocation and re -issuance of this permit. Please notice that this permit does not
affect your legal obligation to obtain other permits required by the Division of Water Quality, the
Division of Land Resources, the Coastal Area Management Act, or other federal or local governments.
If you have questions, or if we can be of further service, please contact Joe Corporon at
[Joe.CorporonQncmail.netl or call [phone], extension 597.
Sincerely,
ORIGINAL SIGNED BY
Mark McIntire
Alan W. Klimek, P.E.
cc: Central Files
Winston-Salem Regional Office, Water Quality Section
NPDES Unit
Aquatic Toxicology Unit
Technical Assistance & Certification Unit
James J. Gonsiewski / Envision Environmental, Inc.

Permit NCO087874
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
(NPDES)
In compliance with the provisions 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,
REXAM, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Former REXAM Flexible Packaging
2600 Phoenix Drive
Greensboro
Guilford County
to receiving waters designated as South Buffalo Creek within 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, 2004.
This permit and authorization to discharge shall expire at midnight on June 30, 2006.
Signed this day November 2, 2004.
ORIGINAL SIGNED BY
Mark McIntire
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Pemtit NCO087874
SUPPLEMENT TO PERMIT COVER SHEET
REXAM, Inc. is hereby authorized to:
After receiving an Authorization to Construct permit from the Division,
construct and operate a system to treat contaminated groundwater.
This treatment system will be located at the former REXAM Flexible
Packaging facility off Phoenix Drive in Greensboro, Guilford County.
2. Discharge from said treatment facility through Outfall 001, via a storm
sewer, at the location specified on the attached map, into South Buffalo
Creek, a waterbody classified as C-NSW waters within the Cape Fear
River Basin.

Permit NC0087874
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
For the period beginning December 1, 2004 and lasting until expiration, the Permittee is authorized to discharge
treated wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
PARAMETER
'LIMITS
MONITORING REQUIREMENTS "'.
Monthly
Daily 1 ; ;
Measurement `
'Sample
Sample
y
• '"' a
•,. „
Avera e`
Maximum
Frequency_ ;
T ` e_'_
Location
Flow
0.001 MGD
Instantaneous
Recording
Influent or
Effluent
1,1 Dichloroethene (1,1 DCE)
Monthly
Grab
Effluent
Tetrachloroethene (PCE)
Monthly
Grab
Effluent
Trichloroethene TCE
92.4 g/L
2/Month
Grab
Effluent
Carbon Tetrachloride
4A2 µg/L
2/Month
Grab
Effluent
Total Residual Chlorine
17 µg/I,
Weekly
Grab
Effluent
pH
> 6.0 and < 9.0 Standard Units
Weekly
Grab
Effluent
Chronic Toxicity2
Quarterly
Composite
Effluent
Footnotes:
1. Total Residual Chlorine —limits and monitoring shall apply only if chlorine is used by the facility.
2. Chronic Toxicity (Ceriodaphnia) P/F @ 90 %; February, May, August, November [See A. (3.)].
Units: MGD = million gallons per day µg/L = micrograms per liter
Discharge shall contain no floating solids or foam visible in other than trace amounts.
A. (2.) USE OF BIOCIDES — SPECIAL CONDITION
There shall be no chromium, zinc or copper added to the treatment system extent as pre -approved
additives to biocidal compounds.
The permittee shall obtain approval from the Division's Aquatic Toxicology Unit prior to the use of any biocide
(not previously approved by the Division) in the effluent discharged under this permit. Approval for use of any
biocide not previously approved should be requested at least 90 days in advance of any planned usage.
Contact the Aquatic Toxicology Unit for detailed instructions on requesting approval of biocides:
NC DENR / DWQ / Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621

Permit NCO087874
A. (3.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia
dubia at an effluent concentration of 90 %.
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 11 Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of February, May, August, and 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 H 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 peanut 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 THP3B
for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: NC DENR / DWQ / 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 perrittee
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.

NPDES PERMIT
DRAFT /FINAL
FILE CONTENTS:
Left
New Tracking Slip.
❑ Old Tracking Slip.
CHECK LIST
Permit No.
NPDES Permit Writer:
4-JX .
Right side:
❑ Streamline Package Sheet
ed)
(to region, only/ity
L�Draft Permit Cover Letter.
(add new policarize major ch ges to permit)
19�Draft Permit
(order: cover, smap, effluent eets, special conditions)
13" Facility Map
(E-Map: includutfalls; U and sample locations)
I�Fact Sheet.
(document perissues and re -issue logic)
Erb Permit Writer's Notes
(if not in Factsronology, strategy, DMR Review, RPA, etc.)
--I}' Staff Report from Region
(as appropriate - not needed if streamlined)
--ElOld Permit
(Text, Effluent Sheets and Special Conditions)
Permit Application.
(New Permit or Renewal; any additional permittee correspondence)
B- Acknowledgement Letter
(NPDES Unit written response to Renewal Application)
❑ Permittee Responses
(to acknowledgement letter, if any)
❑ Waste Load Allocation
(reference date; notes if recalculated for current action)
Note: Italics indicate special
conditions not always required or applicable.
❑Submitted to • 1kY-C iW' &I Pc for Peer Review: Date . Admin cutoff /
17/Peer Review completed by ' `� C 1f- Date
S / Public Notice System Update W�21- �C BIMS Update: Events Limits
❑ Pe milt Mailed / E-Mailed to I"V J —(Regional Staff) by ��+ Date ���
Regional Office Review
�,�S�t � t F-- l 1 l� Date 9-6
❑ Submitted to V_P ' ��%.,., `\Wt- t `� U� ( for Public Winitiated
i Z j- notice Date
❑ Additional Review by CY)b\'N �l.�lk%� Iv� by `^'" Date �y
❑ Additional Review completed by _ ,c on: Date!4L
❑ FINAL to Dave /Mike /Susan om r signature on l t Letter Dated `
❑ Additional Review
❑ Additional Review
❑ Final Files transferred to Server (Permits Folder)
_. B1MS Update: Events Limits
2CaAo W�_rl —
(� tsb otr�5 -�-) 3 t K ;
-,C63iP-11s,Lk.• >

Fact Sheet Addkndum
27Oct04 — Joe Corporon
Corrected Text:
Verifying Existing Strea Conditions. The Division has verified that the Permittee proposes to
discharge treated wastew ter to an unnamed tributary (storm drain) to South Buffalo Creek [stream
segment 16-11-14-2), a lass C-NSW stream located within Subbasin 03-06-02, Cape Fear River
Basin. Segment 16-11- -2c is described as an "impaired waterbody" due to ammonia, i.e., it is listed
in NCDENR / DWQ 3 3(d) list of impaired streams. However, this facility is not proposed to discharge
ammonia or oxygen -consuming wastes. Considering proposed flow to a storm drain, this discharge will
occur under "zero -flow" stream conditions (7Q10 = 0.0 cfs; 30Q2 = 0.0 cis) and is therefore subject to
appropriately stringent permitting policies. It follows that the instream waste concentration (IWC) is
100 %, i.e., treated wastes receive little or no benefit from dilution by natural surface waters.

Data Comparison
Maximum Detected vs. Water Quality Standards and Criteria
Summary of Analytical Results -- based on groundwater data collected between 1997 and 2003
(see Maximum Detected)
REXAM, Inc -- former REXAM Flexable Packaging -- GW REM
NPDES Permit NCOO87874
VOLATILE ORGANCS
Acetone
i54
500
350
No
Yes
C
1-Butanol
1,400
X
No
No
C
2-Butanol
5,700
X
No
No
C
2-Pentanol
100
X
No
No
C
2-Butanone MEK
69
26,355
2,090
7.000,000
No
No
C
1,1-Dichloroethene
280
19,500
0.057
3.2
No
Yes
M
cis-1,2-Dichloroethene
1,080
X
No
No
C
Ethanol
17
440K
No
No
C
Hexane, 2-2-dimeth I
8.5
1 X
11
No
No
C
2-Meth I-1- ro anol
13
X
No
No
C
3-Pentanone
7.3
X
No
No
C
Pro enolic acid, methyl ester
43
X
No
No
C
Pro enolic acid, Propyl ester
217
X
No
No
C
1-Pro anol
832
X
No
No
C
n-Propyl acetate
16
X
No
No
C
Tetrachloroethene
579
0.8
8.85
Yes
Yes
L
Trichloroethene
352
3.08
92.4
Yes
Yes
L
11,1-Trichlorcethene
63
2,460
No
No
C
Carbon Tetrachloride
12
1
0.254
4.42
Yes
Yes
L
Trans-1,3-Dichoro ro ene
6
X
No
No
C
Acetaldehyde
72
X
No
No
C
MTBE
180
X
No
No
C
Trans 1,2-Dichloroethene
13
I1,000
1 26,000
No
No
C
4-Meth I-2-Pentanone
43
18,410
276
180k
No
No
C
Toluene
13
II
1
1390
1
No
No
C
Total X lenes
13
780
1
1 6,000
1 431,
No
No
C
C = cut — no monitoring required
M = monitor only -- no permit limit
L = add permit limit

News & Record
North Carolina, Guilford County
Published by
News & Record, Inc.
Greensboro, North Carolina
Affidavit of Publication
5/13/2004
Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by law to
administer oaths, personally appeared the Publisher's Representative who being first duly sworn, deposed and says:
1. That he/she is the Publisher's 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 he/she is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement,
a copy of which is attached hereto, was published in the News & Record on the dates listed below.
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.
Name
Publisher's Representative h. Ir/ 1j" /.1 CG%t� "a
Sworn to and subscribed before me, this day of 2004.
�G4ul�
Notary Public
My commission expires: August 23, 2005
Adf Date EdlOon Class PO
Ad Coov
VALERIE McNEIL
NOTARY PUBLIC
GUILFORD COUNTY, NC
Commission Expires 8.23.2005
NCDENR DWO NPDES 6451647 05/14/04 News & Record 400 NCO087874 PUBLIC NOTICESTATE O

Ad # 16451647 Date 05/13/2004 Time 9:49 AM
PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION/NPD ES UNIT
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
NOTIFICATION OF INTENT
TO ISSUE A
NPDES WASTEWATER PERMIT
On the basis of thorough staff
review and application of NC
General Statute 143.21, Pub-
lic law 92-500 and other law-
ful standards and regulations,
the North Carolina Environ-
mental Management Commis-
sion proposes to issue a Na-
tional Pollutant Discharge
Elimination System (NPDES)
wastewater discharge permit to
the persons) listed below ef-
fective 45 days from the pub-
lish date of this notice.
Written comments regarding the
proposed permit will be ac-
cepted until 30 days after the
publish date of this notice. All
comments received prior to
that date are considered in the
final determinations regarding
the proposed permit. The Di-
rector of the NC Division of
Water Quality may decide to
hold a public meeting for the
proposed permit should the
Division receive a significant
degree of public interest.
Copies of the draft permit and
other supporting information
on file used to determine con-
ditions present in the draft
permit area available upon re-
quest and payment of the
costs of reproduction. Mail
comments and/or requests for
Information to the NC Division
of Water Quality at the above
address or call Ms. Valery
Stephens at(919) 733-5083,
extension 520. Please include
the NPDES permit number
(attached) In any communica-
tion. Interested persons may
also visit the Division of Water
Quality at 512 N. Salisbury
Street, Raleigh, NC
27604-1148 between the
hours of 8:00 a.m. and 5:00
p.m, to review information on
file.
REXAM, Inc.. (NC0087874) has
applied for a permit to dis-
charge treated groundwater at
the former REXAM Flexible
Packaging site located at
2600 Phoenix Drive in Greens-
boro, Guilford County with dis-
charge into South Buffalo
Creek within the Cape Fear
River Basin. The parameters
trichloroethene and carbon
tetrachloride and Total Re-
sidual Chlorine area water
quality limited. This discharge
may affect future allocations to
the receiving stream.
Ad shown is not actual print size

Public
Notice
c^
AVIT OF INSERTION OF
The Times -News Publishing
Burlington, NC
Alamance County
State of North
Carolina
Environmental
Management
Commission/
NPDES Unit
"� j 7']
• �+ RTI 1 1617 Mail Service Center
Raleigh, NC 27699-1617
Notification Of Intent
Company To Issue A NPDES
Wastewater Permit
On the basis of thorough
staff review and application
of NC General Statute
143.21. Public law 92-500
and other lawful standards
and regulations. the North
Carolina Environmental
Management Commission
proposes to issue a Nation-
al Pollutant Discharge
Elimination System
(NPDES) wastewater dis-
charge permit to the per-
sons) listed below effec-
tive UNDA GIBSON Legal Advertising Manager of the The Times. -News Pn i sn dattdays ns notice. pub -
Co., do certify that the advertisement of NCDENR/DWQ/NPDES
Written comments regard-
ing the proposed permit will
Entitled Public be accepted until 30 days
Notice alter the publish date of this
notice. All comments re -
State of North Carolina calved prior to that date are
considered in the final de-
terminations regarding the
Measuring 97 lines appeared in The Times -News, a newspaper published in, recto, of the Cat DivThe sion°of
County, Burlington, NC, in issues of May 1 6 , 2004 Water Quality may decide
to hold a public meeting for
the proposed pennit should
the Division receive a slg-
nifcant degree of Public in-
terest.
Copies of the draft permit
and other supporting infor-
ma" im file used to de-
termine oonddions present
in the drakperim, are avml-
able upon request and pay-
,f1
ment of the costs of repro,
auction. Mail comments
and/or requests for infor-
Legal Adverismg M
of Wate the Q arty at Isthe
above address or call Ms.
Valery Stephens at
919-733-5083, extension
520. Please include the
NPDES permit number
(attached) In any commum-
Sworn to and subscribed before me thus day
cation. Interest persons
may also visit the Division
Of
W Water Qualify at 512 N
Salisbury Street, Raleigh,
My commission expires
^ 1 I NC ours of
between
' \Jh Me hours of 14800 a . and
5:00 p_m. to review infor-
mation on file,
IL/ �� 1_\ ' 1 _ p REXAM, Inc. (NG087874)
=—�--t-- �--5� has applied for a permit to
I Notary h6ho water t t treated REXA -
""'^? �"u� water at the loner REXAM
Flexible Packaging site lo-
cated
Drive at Greensboro
Phoenix
Drive in Greensboro, Guil-
ford County with discharge
into South Bufalo Creek
within the Cape Fear River
Basinthe parameters td-
chlorcethene and carbon
tetrachloride and Total Re-
sidual Chlorine are water
quality limited. This dis-
c charge may affect future
alllocations to the receiving
stream.
March 16, 2004
�� aa�DBJ��-

June 13, 2004
ENVISION ENVIRONMENTAL, INC
Mr. Joe Corporon, P.G.
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Draft NPDES Permit NCO087874
Groundwater Treatment System
Former REXAM Flexible Packaging
Greensboro, Guilford County, NC
ENVISION Project ID: 297.REX
Dear Mr. Corporon:
JUN 1 5 2004
wxlFR 811AI ITf
On behalf of our client, REXAM INC. (REXAM), we would like to offer the following comments
regarding the referenced draft NPDES permit:
All correspondence and monitoring report forms pertaining to this permit should be sent
to the following location:
Frank C. Brown, Esq.
REXAM INC.
4201 Congress Street
Charlotte, NC 28209
2. REXAM is preparing an Authorization to Construct (ATC) permit application for the
groundwater treatment system covered by the referenced NPDES permit. The ATC
permit application will be submitted to the Department upon completion.
Section A. (1.) Effluent Limitations And Monitoring Requirements identifies the need for a
recording flowmeter to provide an instantaneous measurement of the water flow
discharged through the permitted outfall or the water flow into the groundwater treatment
system. Will a non-resettable totalizing mechanical flowmeter satisfy this requirement?
The non-resettable totalizing mechanical flowmeter provides a gallon per minute
readout, as well as a cumulative total gallons readout (which is non-resettable). REXAM
can provide a specification sheet on the flowmeter if desired. Also is a chart recorder
required as part of the flow measurement requirement?
Section D. Monitoring and Records Item 3. Flow Measurements requires (at a minimum)
the annual calibration of the groundwater treatment system's flow measurement device.
21 Priscilla Lane, Howell, NJ 07731 • Phone: [phone] Fax: [phone]

ENVISION
ENVIRONMENTAL, INC.
Mr. Joe Corporon, P.G.
State of North Carolina
Division of Water Quality
June 13, 2004
Page 2 of 3
The non-resettable totalizing mechanical flowmeter (referenced in Item 3 above) is
factory calibrated. The device cannot be calibrated in the field. However, the calibration
can be verified in the field. If the calibration verification indicates that the flowmeter
device is measuring flows with a maximum deviation of less than 10% from the true
discharge rates through the treatment system, the flowmeter will be considered to be
properly calibrated. If the maximum flow deviation is greater than 10%, then the flow
measurement device will be removed and returned to the manufacturer for repair/re-
calibration and/or replaced with another meter of similar construction. At no time will the
treatment system be operated without a Department -approved flow measurement device
in place. Will this approach satisfy the Department's annual flowmeter calibration
requirement?
5. Section A. (1.) Effluent Limitations And Monitoring Requirements identifies the
requirement to sample the groundwater treatment system's effluent for 1,1-
Dichloroethene and Tetrachloroethene on a monthly basis. However, no permit limits
are referenced for these compounds. Will permit limits be listed for these compounds in
the final form of the permit?
6. Section A. (1.) Effluent Limitations And Monitoring Requirements identifies the need to
conduct weekly analysis for Total Residual Chlorine only if chlorine is used by the
facility. The groundwater treatment system does not use chlorine in its operations.
Therefore, Total Residual Chlorine will not be monitored.
7. Section A. (1.) Effluent Limitations And Monitoring Requirements Footnote 4 identifies a
Special Condition concerning the use of biocides in cooling water. The special condition
is reviewed in Section A. (2.) Use of Biocides — Special Condition in the permit. The
groundwater treatment system does not utilize any cooling water or biocides. Therefore,
this special condition does not apply.
8. Section A. (1.) Effluent Limitations And Monitoring Requirements identifies the
measurement frequency for effluent characteristic permit limits. The proposed
measurement frequencies range from weekly to quarterly. Typically, NPDES permits
allow for reductions in monitoring frequency after at least two (2) quarters of monitoring.
Will the Department allow for the filing of a petition to reduce monitoring frequencies of
select parameters after at least two (2) quarters of conducting the monitoring outlined in
the draft permit (providing the data supports the proposed reduction)? Typically, such a
petition would request the reduction of quarterly monitoring to semi-annual, 2
samples/month monitoring to monthly, monthly monitoring to quarterly, and weekly
monitoring to monthly.
9. Section C. Operation and Maintenance of Pollution Controls requires the use of a
certified operator to manage the groundwater treatment system. Based upon the system
design, the groundwater treatment system should be considered a Class I facility.
On behalf of REXAM, thank you for the opportunity to comment on the draft permit.

ENVISION
ENVIRONMENTAL, INC.
Mr. Joe Corporon, P.G.
State of North Carolina
Division of Water Quality
June 13, 2004
Page 3 of 3
Should you have any questions pertaining to this information, please feel free to contact me at
any time.
Very truly you
J
Mark P. Roman
President
Cc: Frank Brown — REXAM INC.

Draft Permit review
Subject: Draft Permit review
From: John Giorgino <[e-mail]
Date: Tue, 25 May 2004 11:13:08 -0400
To: Joe Corporon <[e-mail]
Hi Joe, I reviewed NCO087874 (REXAM Inc.) and have no comments
to us.
John Giorgino
Environmental Biologist
North Carolina Division of Water Quality
Aquatic Toxicology Unit
Mailing Address:
1621 MSC
Raleigh, NC 27699-1621
office: 919 733-2136
Fax: [phone]
Email: [e-mail]
Web Page: http://www.esb.enr.state.nc.us
Thank you for forwarding it
IofI
6/7/2004 8:16 AM

DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit NCO087874
INTRODUCTION
REXAM, Inc. (herein referred to as REXAM or the Permittee) requires a National Pollutant Discharge
Elimination System (NPDES) permit to dispose treated groundwater to the surface waters of the state. The
Permittee has requested this permit from the Division of Water Quality (the Division) for its former
REXAM Flexible Packaging facility in Greensboro, North Carolina and the Division has assigned an
NPDES number. This Fact Sheet summarizes background information and rationale used by the Division's
NPDES Unit to determine permit limits and monitoring conditions.
FACILITY RECORDS REVIEW
Facility Description. REXAM's Corrective Action Plan (CAP) currently in review by NCDENR
includes a groundwater recovery system consisting of an array of recovery wells for site remediation. This
permit addresses wastewater effluent limits and monitoring conditions required to protect waters of the
state. REXAM (Table 1) proposes to discharge 0.001 million gallons per day (MGD) of treated
wastewater to an equalization (EQ) tank followed by carbon filtration. Final treatment system design must
be approved by an Authorization to Construct (ATC) permit issued by the Division.
Table 1. REXAM — Treatment of Contaminated Groundwater
Facility Information
Applicant/Facility Name
REXAM, Inc. / formerly REXAM Flexible Packaging (currently North
State Flexibles
Applicant Address
Envision Environmental, Inc., 21 Priscilla Lane, Howell, NJ 07731
Facility Address
2600 Phoenix Drive, Greensboro, NC 27406
Permitted Flow (MGD)
0.001 MGD
Type of Waste
Treated Groundwater (chlorinated hydrocarbons, VOCs )
Facility/Permit Status
Class I, Minor / New
Drain a Basin / County
Cape Fear / Guilford
Miscellaneous
Receiving Stream
South Buffalo Creek
Regional Office
Winston-Salem
Stream Classification
C-NSW
rj
State Grid /
USGS To o Quad
C 19 SE /
Greensboro, NC
303(d) Listed?
N
Permit Writer
Joe R. Corporon
Subbasin
03-06-02 i
Date:
29A r04
Drainage Area (sq. mi.)
Lat. 36° 00' 38" Long. 79° 50' 09"
Summer 7QI0 (cfs)
0
Winter 7QI0 (cfs)
0
30Q2 (cfs)
0
Average Flow (cfs)
0
IWC m
100
Fact Sheet
Renewal -- NPDES Permit NC0057874
Page 1

Permitting Approach
Evaluation of Alternatives to Discharge. Situat96 amid the City of Greensbobo's commercial and
industrial development, REXAM has limited alterKatives for viable land application alternatives for
wastewater disposal. Connection to the City of Vreensboro W WTP has been denied by the city, however
the City of Greensboro Stormwater Managemeo Division has granted through city "...Ordinance 27-
31(b)(4), the discharge of uncontaminated non Corm water from the above named facility to the City's
storm drain system" (see letter from CGSMD fo Jim Gonsiewski, Law Engineering, May 18, 2001). The
Division concurs with the Permittee that surf a disposal 's a best viable dischargealternative fgr I
wastewater dispo _� S tr 1 Wt �e4Cw` C� � J� 'jam
Verifying xisting Stream Conditions. The Division has verified that$3(d)
ttee propos s to
discharge treated wastewater to an unnamed tributary (storm drain) to Soalo Creek [stream
segment 16-11-14-2), a Class C-NSW stream located within Subbasin 0, Cape Fear River Basin.
This is4ytan "impaired waterbody," i.e., &*listed in NCDENR / DWQist of impaired streams.
However, considering proposed flow and receiving stream, this discharge will occur under "zero -flow"
stream conditions (7Q10 = 0.0 cfs; 30Q2 = 0.0 cfs) and is therefore subject to appropriately stringent
permitting policies. It follows that the instream waste concentration (IWC) is 100 %, i.e., treated wastes
receive little or no benefit from dilution by natural surface waters.
Waste Load Allocation (WLA). This is a new permit for a groundwater remediation wastewater treatment
system. There is no sanitary sewer influent to the treatment system. The Division has prepared a WLA and
developed effluent limits and monitoring requirements based on the Permittee's proposed discharge of
0.001 MGD.
Establishing Parameters of Concern (POCs) and Permit Limits. In the absence of effluent data from
this as yet un-built treatment system, the Division established a list of potential POCs from analytical results
collected during groundwater contaminant plume characterization. Site -characterization analytes date from
year 1997 through 2003 and include volatile organic compounds detected in an array of 11 groundwater -
monitoring wells. The laboratory did not detect all parameters at each sampling. The Division compared the
maximum detected value of each analyte to its respective instream water quality standard or criteria, if any
(see database summary, Table 2 Analytes). To establish the permit's Effluent Limitations and Monitoring
Requirements, the Division conducted a 4-step evaluation (Table 3).
Table 3 Establishing POCs -- Startup Monitoring and Limits
Parameter:
ACTION:
STEP 1
If not detected during the 10-year
Disregard as POC/ no
site characterization
additional monitoring required
STEP 2
If detected during the 10-year period
Compare maximum level to
existing standard or criteria.
STEP 3
If parameter is detected, and if maximum
Monitor only -- no permit limit
level exceeds federal criteria but not a state
standard
STEP 4
If parameter levels exceed state standard.
Monitor -- add permit limit /no dilution. Limits
or if it is a known carcinogen
calculated using stream flows associated with
carcinogenic compounds (average flow), aesthet
criteria (30Q2 flow), and standards (7Q10 flow).
Fart Sheet
Renewal -- NFUES \C(H)S_-MA
face_

Data Comparison
Maximum Detected vs. Water Quality Standards and Criteria
Summary of Analytical Results -- based on groundwater data collected between 1997 and 2003
(see Maximum Detected)
REXAM, Inc — former REXAM Flexable Packaging -- GW REM
NPDES Permit NCO087874
All analytes reported in ug/L unless noted
°fie r,
^dpo, S',(• ^fit
P^n ,}o!e / �'r r r!t !j�° `Opd,
d�
o�
d° ^s �S
fP7 Pad O'
� S °djA fd7 /d7
I
• .
'SJ °od adr adi
-
VOLA TILE ORGANCS
Acetone
3s4
SOU
1�0
No
Yes
C
1-Butanol
1,400
x
No
No
C
2-Butanol
5,700
X
No
No
C
2-Pentanol
too
X
No
No
C
2-Bulanone MEK
69
26,355
2,090
7,000,000
No
No
C
1,1-Dichloroethene
280
19,500
0.057
3.2
No
Yes
M
cis-1,2-Dichloroethene
1,080
X
No
No
C
Ethanol
17
440K
I
No
No
C
Hexane, 2-2-dimeth I
8.5
X
I
No
No
C
2-Meth I-1- ro anol
13
X
I
No
No
C
3-Pentanone
7.3
X
No
No
C
Pro enolic acid, methyl ester
43
X
No
No
C
Pro enolic acid, Propyl ester
217
X
No
No
C
1-Pro anol
832
X
No
No
C
n-Propyl acetate
16
X
No
No
C
Tetrachloroethene
579
0.8
8.85
Yes
Yes
L
Tichooroethene
352
3.08
92.4
Yes
Yes
L
1,1,1-Trichloroethane
63
2,460
No
No
C
Carbon Tetrachloride
12
0254
4.42
Yes
Yes
L
Trans-1,3-Dichoro ro ene
6
X
No
No
C
Acetaldehyde
72
X
No
No
C
MTBE
190
X
No
No
C
Trans 1,2-Dichloroethene
13
11,000
26,000
No
No
C
4-Meth-2-Pentamne
43
1ii 0
276
1801,
No
No
C
Toluene
13
11
390
No
No
C
Total X lens
13
780
6,000
43k
No
No
C
C = cut -- no monitoring required
M = monitor only -- no permit limit
IF
L = add permit limit

A
Following logic presented in Table 2, the Division short-listed POCs and calculated permit limits and
monitoring condition (Table 4). POCs include 1,1 Dichloroethene (1,1 DCE), Tetrachloroethene (PCE),
Trichloroethene (TCE), and Carbon Tetrachloride. Parameters not requiring limits will be monitored
Monthly; parameters requiring limits will be monitored 2/Month.
Table 4. Stream Flows Used for Limits Calculations
Parameter of
Standard
Standard
Stream Flow
Comments
Concern
Used
T
Used
1,1 Dichloroethene (1,1 DCE)
3.2 µg/L
toxic
Not WS waters.
Monitor only — no limit
Tetrachloroethene(PCE)
10.8 µg/L
carcinogen
Not WS waters.
Monitor only — no limit
Trichloroethene (TCE)
92.4
carcinogen
verage "
Zero flow stream —
1100 cfs)
Included standard as limit
Carbon Tetrachloride
4.42
carcinogen I
Average
Zero flow stream —
(1100 cfs)
Included standard as limit
Whole Effluent Toxicity (WET) Test. This facility shall be required to conduct quarterly Whole
Effluent Toxicity (WET) testing using an IWC of 90 %.
Total Nitrogen and Total Phosphorus. By policy, the Division requires Total Nitrogen and Total
Phosphorus for discharges to NSW waters. However, this facility does not treat domestic sanitary
sewer, and by its nature, the discharge has virtually no potential to contain oxygen -consuming wastes.
Therefore, Total Nitrogen (NO2-N + NO3-N + TKN) and Total Phosphorus will not be added to the
permit.
Use of Biocide. The facility may have potential to need biocides to curb organic growth within the
treatment system. Therefore, a Special Condition — Use Of Biocides will be added to the permit as
follows: q
The Permittee uthorization from the Division prior to using any
biocide in the ooling wate that may be toxic to aquatic life. The Permittee shall
notify the Dire g no later than 90 days prior to using any biocide not
already approved for this facility. The Permittee shall provide such notification by
completing a Biocide Worksheet, Form 101 to include a map indicating the
receiving stream and the effluent discharge point. Concentrations of additives to
biocides such as chromium, copper, or zinc shall not exceed applicable water
quality standards or action levels in the receiving stream, as determined by
calculations using the biocide Work Sheet, Form 101 and the Supplemental
Analysis Worksheet.
km SlIc"t
Renewal — APDIS M ig)S%871
Pu^_c

SUMMATION
The Division considers the above -described approach to be environmentally conservative and reasonable in
the absence of an established effluent database. To establish this database, monitoring frequencies for
toxicants will be set at Monthly for POCs -- 2/Month if limited, in keeping with similar sites across the
state. An effluent page footnote will stipulate that the Division may consider the Permittee's petition to
relax monitoring conditions, should data warrant, after a minimum of twelve analytical events (one year).
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
May 12, 2004.
June 6, 2004
NPDES UN T CON CT
If you ha ques'ons rega any of the above information or on the attached permit, please
contact J Co ron at 3- ex .
NAME' DATE' �
REG NAL CO MEN S
D NAME' F ATE'
/vL
REGIONAL
TE:
NPDES SUPERVISOR: DATE:
Fact Shed
Renewal -- NPDIS M WS7874
Park 4

ENVISION ENVIRONMENTAL, IN
4DFNRwATEnOUlUTY �I
01T4T SOU/nCE B"Jf'N H
O P (,v{10P✓P✓ �� J
October 13, 2003
Mr. Dave Goodrich
North Carolina Department of Environment and
Division of Water Quality, NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
1/p1At14, SPC 7,dA &1111(Ir-
Natural Resources
I've 0f m'4 -'l'-d JA"
Subject: NPDES Permit Submittal
Former REXAM FLEXIBLE PACKAGING
2600 Phoenix Drive
Greensboro, Guilford County, North Carolina 27406
NCDENR Incident Number 17427
Envision Project ID: 297.REX
Dear Mr. Goodrich:
n✓o-)ec } Vvi do A, -
On behalf of REXAM INC. (REXAM), ENVISION ENVIRONMENTAL, INC. (ENVISION) is
submitting the attached NPDES Permit application and supporting information for the former
REXAM FLEXIBLE PACKAGING (currently NORTH STATE FLEXIBLES) facility located at 2600
Phoenix Drive, Greensboro, Guilford County, North Carolina, 27406. This application is being
submitted in conjunction with the implementation of a Corrective Action Plan (CAP) at the facility.
As part of the CAP, impacted groundwater will be recovered and treated using activated carbon to
remove low levels of chlorinated hydrocarbons found in the groundwater. The treated groundwater
will have food grade molasses added and will be routed through two (2) infiltration galleries into
the soil to introduce a carbon source to stimulate the growth of anaerobic bacteria at the Site. The
activity of these bacteria will reduce the levels of chlorinated solvents in the soil and groundwater
at the Site. The volume of treated water (if any) in excess of what can be reintroduced to the soil
will be discharged to the City of Greensboro stormwater system.
The site is located in a commercial/residential area of Greensboro which is zoned light industrial.
The location of the site is shown on the attached Figure 1. Figure 1 also shows the location of the
proposed outfall to the storm sewer (labeled 1) and the location of the end of the storm sewer
(labeled A) at an unnamed tributary of South Buffalo Creek.
Stormwater discharge was selected as a backup after an inquiry was made to Ms. Marty Groome,
Supervisor of the City of Greensboro Wastewater Treatment Plant. According to Ms. Groome, the
City of Greensboro is no longer accepting applications to discharge treated groundwater to the
city sanitary wastewater system. Therefore, the only backup to discharge to groundwater available
21 Priscilla Lane, Howell, NJ 07731 • Phone: [phone] Fax: [phone]

ENVISION
ENVIRONMENTAL, INC.
Mr. Dave Goodrich
NCDENR
October 13, 2003
Page 2 of 2
for excess recovered groundwater disposal is into the site stormwater drain system. Permission
for disposal into the City of Greensboro stormwater system has been obtained from Mr. David
Phlegar, Water Quality Supervisor for the City of Greensboro (letter attached). Since these are
the only two (2) options available for this site, a report of alternatives to surface water discharge
was not completed.
Currently a pilot test is planned at the Site for early November. During a previous pump test
conducted using recovery well RW-1 at the Site, an effective pump rate of approximately 1,000
gallons of groundwater per day was determined. The pilot test of the infiltration wells will
determine the volume of this treated groundwater that can effectively be re -injected into the soil
and groundwater using the two (2) infiltration wells already installed onsite. After completion of
this test, the information will be forwarded to you.
No base/neutral or acid extractable compounds were used in processes at this facility. Therefore,
no groundwater samples from the site have been analyzed using USEPA Method 625. A
summary table listing all groundwater constituents detected at the site and a complete sampling
history is attached as Table 1. Monitoring wells MW-2, MW-3, MW-4, MW-6, MW-7, MW-10, and
RW-1 are located in the permit area of concern at the site. The other wells are located
hydraulically upgradient.
We appreciate your consideration and cooperation in the submission of this permit application. If
you have any questions or need additional information, please contact the undersigned at (336)
855-0034 or [phone].
Sincerely,
y9 'S
mes J. Go ' wski, L`. SEAL
t•
Senior Geologist : c. 1371
Licensed NC 1371 i y Y
Attachments
cc: REXAM INC.
Mr. Danny Crump, North State Flexibles
Mark P. Roman, CHMM O8-
President

V
City of Greensboro
North Carolina
May 18, 2001
Mr. Jim Gonsiewski
Law Engineering & Environmental Services, Inc.
7347-E West Friendly Ave.
Greensboro, NC 27410
RE: Non -storm water discharge from North State Flexibles (formerly Rexam Flexible Packaging)
Dear Mr. Gonsiewski:
This letter is being written upon request and as a requirement of the NC NPDES Permit
Application — Short Form C-GW for North State Flexibles (formerly Rexam Flexible Packaging)
located at 2600 Phoenix Dr. in Greensboro, NC to discharge wastewater from an on -site
groundwater remediation system to the City of Greensboro storm drain system. Pursuant to NC
NPDES Permit guidelines and ensuring that no NC surface water quality standards are violated,
the City of Greensboro Stormwater Management Division allows, through City of Greensboro
Ordinance 27-31(b)(4), the discharge of uncontaminated non -storm water from the above named
facility to the City's storm drain system. This City reserves the right to revoke this permission in
the event that NC surface water standards are violated as a result of the facilities discharge, or it is
shown that the receiving stream is otherwise impaired as a result of the facilities discharge. In the
event that NC surface water standards are violated, or it is shown that the receiving stream is
impaired as a result of the facilities discharge, the above named facility would be found in non-
compliance with City ordinances and subject to civil penalties of up to $5000 per day.
If you have any questions or need any further clarification, feel free to contact me at (336) 373-
2707.
Sincerely,
David Phlegar, Water Quality Supervisor
City of Greensboro Stormwater Management Division
640 P.O. Box 3136 • Greensboro, NC 27402-3136 • www.ci.greensboro.nc.us • [phone] • TTY# 333-6930

Oki ql ilL1GpO: •VL. •
p sibo ;
04 DC li P J11:
it
Jv
APPROXIMATE SCALE
APPROXMIATE SITE LOCATION i0oo 500 0 1000
O PROPOSED NPDES STORM SEWER OUTFALL� 4: QO" ST "A.AT (ot gar )
END OF STORM SEWER
0
— — STORM SEWER UNE '
7 -7 0 tro « c,�:1c,
REF.: U.S.G.S. TOPOGRAPHIC MAP, GREENSBORO, N.C. QUADRANGLE, DATED 1951, PHOTOREVISED 1994.
NnYlwr p•Ad NA
SITE LOCATION MAP 297.RO(
n•t. 05/14/03
FORMER REXAM So,• ArSb•
FLEXIBLE PACKAGING am"° "'
Envision Environmental, Inc. 2600 PHOENIX DRIVE
Yt A*cN" La"a t/0'"4 NJ °nJt GREENSBORO, NORTH CAROl1NA FIGURE 1
7J2-, )s-/ss+ r= 7.tt-8W-2V25
(> tq E

T
NC DENR - DIVISON OF WATER QUALITY
.0311 CAPE FEAR RIVER BASIN
2B .0300
Classification
Name of Stream Description Class Date Index No.
Unnamed Tributary at Camp
From dam at Lake Herman to
C;NSW
12/01/83
16-11-10-(2)
Herman
Reedy Fork
Smith Branch
From source
to Reedy Fork
C;NSW
12/01/83
16-11-11
Rocky Branch
From source
to Reedy Fork
C;NSW
12/01/83
16-11-12
Katie Branch
From source
to Reedy Fork
C;NSW
12/01/83
16-11-13
Buffalo Creek
From junction of North
C;NSW
12/01/83
16-11-14
Buffalo Creek and South
Buffalo Creek to Reedy Fork
North Buffalo Creek
From source
to Buffalo Creek
C;NSW
08/01/85
16-11-14-1
Lake Hamilton, Lake Euphemia
Entire lakes
and
C;NSW
12/01/83
16-11-14-1-1
connecting streams
to
North Buffalo
Creek
Philadephia Lake, Buffalo
Entire lakes
and
C;NSW
08/03/92
16-11-14-1-2
Lake, and White Oak Lake)
connecting stream
to North
Buffalo Creek
Muddy Creek
From source
to North Buffalo
C;NSW
08/01/85
16-11-14-1-3
Creek
Jordan Branch
From source
to North Buffalo
C;NSW
12/01/83
16-11-14-1-4
Creek
South Buffalo Creek
From source
to Buffalo Creek
C;NSW
08/01/85
16-11-14-2
Piedmont Creek
From source
to South Buffalo
C;NSW
12/01/83
16-11-14-2-1
Creek
Glenwood Creek
From source
to South Buffalo
C;NSW
12/01/83
16-11-14-2-2
Creek
Ryan Creek
From source
to South Buffalo
C;NSW
12/01/83
16-11-14-2-3
Creek
Mile Run Creek
From source
to South Buffalo
C;NSW
12/01/83
16-11-14-2-4
Creek
Blackwood Creek
From source
to Buffalo Creek
C;NSW
12/01/83
16-11-14-3
Parks Creek
From source
to Reedy Fork
C;NSW
12/01/83
16-11-15
Travis Creek
From source
to Raw River
C;NSW
01/01/85
16-12
Tickle Creek (Trickle Creek)
From source
to Travis Creek
C;NSW
12/01/83
16-12-1
Dry Creek
From source
to Haw River
C;NSW
12/01/83
16-13
Stony Creek (Lake
From source
to Buttermilk
WS-II;HQW,NSW
08/03/92
16-14-(1)
Burlington)
Creek
Grays Branch
From source
to Stony Creek
WS-II;HQW,NSW
08/03/92
16-14-2
Benton Branch
From source
to Stony Creek
WS-II;HQW,NSW
08/03/92
16-14-3
Toms Creek
From source
to Lake
WS-II;HQW,NSW
08/03/92
16-14-4
Burlington,
Stony Creek
Buttermilk Creek
From source
to Stony Creek
WS-II;HQW,NSW
08/03/92
16-14-5
Jones Creek
From source
to Buttermilk
WS-II;HQW,NSW
08/03/92
16-14-5-1
Creek
Laughin Creek
From source
to Buttermilk
WS-II;HQW,NSW
08/03/92
16-14-5-2
Creek
3

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Data Comparison
Maximum Detected vs. Water Quality Standards and Criteria
Summary of Analytical Results -- Based on groundwater data collected between 1998 and 2003
(see Maximum Detected)
REXAM Flexable Packaging -- GW REM
NPDES Permit NCO087874
All analytes reported in ug/L unless noted
e!P
oIp
�r /!!.
�Ir,
o,y. p
•P� pry
/p
OS, .P D
/d0 /do
'!I
A
/,2
.
VOLATILE ORGANCS
Acetone
I54
No
Yes
C
1-Butanol
1.400
x
No
No
C
2-Butanol
5,700
X
No
No
C
2-Pentanol
100
%
No
No
C
2-Butanone MEK
69
1 26,355 1
2,090
7,000,000
No
No
C
1,1-Dichloroethene
280
1 19.5001
0.057
3,2
No
Yes
M
cis-1,2-Dichloroethene
1,090
X
I
No
No
C
Ethanol
17
440K I
No
No
C
Hexane, 2-2-dimeth I
8.5
%
1
No
No
C
2-Methyl-l-propanol
13
%
I
No
No
C
3-Pentanone
7.3
X
I
No
No
C
Pro enolic acid, methyl ester
43
X
No
No
C
Pro enolic acid, Propyl ester
217
X
No
No
C
1-Propanol
832
X
No
No
C
n-Propyl acetate
16
X
No
No
C
Tetrachloroethene
579
0.8
8.85
Yes
Yes
L
Trichloroethene
352
3.09
92.4
Yes
Yes
1,1,1.Tdchloroethane
63
2,460
No
No
Carbon Tetrachloride
12
0.254
4.42
Yes
Yes
L
Trans-1,3-Dichoro ro ene
6
%
No
No
C
Acetaldehyde
72
%
No
No
c
MTBE
180
x
No
No
C
Trans 1,2-Dichloroethene
13
11,000
26,000
No
No
C
4-Meth I-2-Pentanone
43
18%0
276
I80k
No
No
C
Toluene
13
II
390
No
No
C
Total X lens
13
780
6,000
43k
No
No
C
C = cut -- no monitoring required
M = monitor only -- no permit limit
IF
L = add permit limit

l
grMnOwater remediation package
.
Subject: groundwater remediation package
From: Charles Weaver <[e-mail]>
Date: Tue, 02 Dec 2003 07:48:03 -0500
To: Tom Belnick <[e-mail]>, Valery Stephens
<Valery.Stephens @ ncmail.net>
Jim Gonsiewski ed last week asking about a groundwater
reme cat/abases,
ect. He said it had been reviewed by Tom but that
it was gbe returned. Valery sent him to me.
I can't record of a GW project in the Assignments or Return
Numbers so ... someone please e-mail Jim
(jimgonsnvisionenvironmental.com) and let him know what the
status 's (returned, being reviewed, etc.).
I of 1 12/2/2003 9:35 Ara

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TABLE 1
DETECTED GROUNDWATER ANALYTICAL RESULTS
�DOmmmmmmm0�mmmmmmmmmmmmm�mm�
"
mm�m�
mmmmmOmm�mm
0�
mmm�mmm
�000000�00000m0000
,
o
, ,.
o000000m
mom0000
o00000000m
o
, ,
o0000000
"
o00000
, ,
m000000000
, ,
o
, .:
0000mmom
�000000
�00000m000
o
, , :
m000000m
�oom000
:
�000000000m00000m000m
�omomommmom000m000
,,,
ommmommmom
�000mommmoo
' ' '
o0000000mmmoom000
moomm0000000000000000�om0000m
"
om000000000000000000�000000m
�000moom0000000000000momoomom
�00000000m000000000000000000m
m
, , :
omm
' '
0000momm
, :
m000moom0000�
��o
, ,
o
. ,. •
momo�
, , :
mmmm
mom000
omoom
�oommommmmmmmmmmm©mmmom000mo®
�ommmomo
,:
m
,:
mmmomoo��moom0000®
�om00000�omo
,'
moomm
�m0000moo�
m0000000�0000000mo
,
�00000000m
"
o000000
o00000000
.
, :
o0000
�oo�
�000m000
:
000c�00000
.
00000�oom
�o
oom
o00000000
000000moo
�emm�aaaeaaaeaamaaaaaaaaaaeaa
�mmmom
' '
mmmmmommmmmm
,
o000000mm
�oomoommoom■�mmoommomoom00000m
"
oom000mmomoomoommmo■m00000mmo
m000000m00000000m0000000r�oomo
�000000mmomm0000m000000000000
„
, , •
o0000000000000moo■000000amom
�m00000000mm00000m0000000mm
'
m
�ommommoomov0000mmoom0000m
o0
•
�ommmommoommomoomo
�ramor�n■�ommoo
„
ommmoomoom�0000000mmoom
"•
mmmm
�ommmoomoomv0000000mmoom
, :,
■�amom
�oom0000000y00000000mm
,,
m
.
omoo

TABLE 1
DETECTED GROUNDWATER ANALYTICAL RESULTS
Volatile Organlc Compounds (Method 8240 or 8260)
L
Yy
Y
°
�yy
d
5
5
CL
6
Ij
m
p
F
Well Identification
Date
d
,py
e0.5
'�
m
5
r5
a
a
c
F
21, Groundwater
QualityStandard**
0.70
MDL
MDL
MDL
0.17 1
0.00019
0 07
0.07
MDL
MDL
MDL
MDL
MDL
MDL
MDL
MDL
MDL
0,0007
0.0028
MW-10
5199
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4/00
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0,011
ND
8/01
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.0092
ND
8103
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.0320
ND
MW-11
5/99
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.016
ND
ND
4/00
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
8/01
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
8103
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
RW-1
4/00
ND
ND
ND
I ND
ND
0.0073'
0.013
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.110
ND
8/01
ND
ND
ND
ND
ND
0.0078'
0.010
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.120
ND
8/03
ND
ND
ND
ND
ND
0.0076'
0.031
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.150MND
Duplicate
8/03
ND
ND
ND
ND
ND
0.013'
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.130
Equip. Blank
8/03
0.028
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Duplicate 2
8103
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Equip. Blank 2
8/03
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Trip Blank
7/97
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1198
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
5199
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4/00
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
8/01
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
8/03
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Trip Blank 2
8/03
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MAXIMUM
CONCENTRATION
0.354
1.400
5.700
0.100
0.069
0.031
0.280
1.080
0.017
0.0085
0.019
0.013
0,0073
0.043
0.217
0.832
0.016
0.579
0.352
DATE
1#####
#####
#####
#####
#####
1/0/1900
8/03
1 7/97
1 1/98
1 7/97
1 1198
1 1/98
1/98
7/97
1/98
1/98
5199
7/97
7/97
NOTES:
All parameters reported in milligrams per liter (mgll)
ND - Not Detected
MDL- Method Detection Limit (No NC Groundwater Standard established)
•• North Carolina Groundwater Standards ***Well dry - unable to be sampled from 5199 to 8/03.
(1) NCAC Title 15A 2L.020(g) dated Octobar 24 ,1994, last revised April 14, 1998.
a - Common field contaminant (1) Type III deep monitoring well
Bold Values exceed NC Groundwater Standards.
Bold Values exceed NC Groundwater Standards.
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ND
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ND
ND
I ND
I ND
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I ND
I ND
i.063
0,012
0.006
0.072
0.180
0.013
0.043
0.013
0.013
1/98
1 4100
5/99
5/99
8/01
1 5199
8/03
8/01
5/99