NC0088838_Headworks Analysis_20090519

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

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

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

t
1.0 GENERAL INFORMATION
A. Project Identification
o Facility Name: Radiator Specialty Company
o Contact: Mr. Stuart Kerkhoff, Environmental Manager
o Facility County: Union
o Facility Address: 600 Radiator Road
Indian Trail, North Carolina 28079
o Facility Telephone Number: [phone]
o EAA Preparer's Name: Nesco Environmental, P.L.L.C.
o EAA Preparer's Mailing Address:PO Box 78222
Charlotte, North Carolina 28271
o EAA Preparer's Telephone Number: [phone]
o EAA Preparer's E-mail Address: nescoenv(u�carolina.rr.com
B. Project Description
o Radiator Specialty Company (RSC) owns and operates a
manufacturing facility at the site. A release of solvents has affected
groundwater. An onsite groundwater recovery and treatment system
designed by AWARE Environmental, Inc. (AWARE) in 1992 was
installed in 1993 and 1994 and began operation on October 24, 1994.
Since that time, the discharge has been to the publicly owned
treatment works (POTW) maintained by Union County. Groundwater
is extracted from four (4) recovery wells and is pumped to a 6,000-
gallon above-ground storage tank (AST) for flow equalization. The
extracted groundwater is then pumped to the top of a packed air
stripping tower. After passing through the air stripper, the treated
groundwater flows by gravity through a discharge port. Over 14 years
of data show that the groundwater treatment equipment has been
effectively removing volatile organic compounds (VOCs) from the
extracted groundwater. Union County recently has expressed an
unwillingness to continue to accept this wastestream. It is proposed
that the discharge be re-routed to an intermittent stream that flows
into the South Fork Crooked Creek.
1

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

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

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

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

Based on the information presented in this evaluation, the shallow
soil depth and variability of the bedrock underlying the RSC
facility, the site does not appear to be conducive for subsurface
disposal of the 75,000 gallons per day of treated water generated
from the groundwater remediation system.
Based upon the findings of the referenced reports, Nesco Environmental
concludes that land application is not a feasible alternative for the proposed
discharge.
o Wastewater reuse
➢ RSC has extensively evaluated the potential for reuse of the treated
groundwater and found that this option is not feasible. RSC's evaluation of
potential water reuse is summarized in a document dated February 26, 2009
and titled Treated Groundwater Reuse Synopsis. A copy of this document is
included as Appendix E. Based upon the findings contained in this
document, Nesco Environmental concludes that reuse of the treated
groundwater is not feasible.
o Surface water discharge through the NPDES program
➢ The existing groundwater treatment system has a demonstrated track record
with more than 14 of data showing that the system reliably and consistently
removes VOCs from the wastestream to very low or non-detectable levels.
The system was designed to handle 90,000 GPD which is more than the
75,000 GPD that is the maximum anticipated flow at this time. The system
was designed to treat the "worst case" for VOCs dissolved in groundwater
and has been effective in reducing the concentrations of VOCs in
groundwater. As such, the concentrations of VOCs in the system influent
have continually and significantly decreased since remediation began. The
total VOC concentrations for the influent were 12.47 milligrams per liter (mg/I)
on March 27, 1995 and 0.26 mg/I on December 12, 2008. The available data
indicate that the system is capable of reducing the concentrations of VOCs in
the wastestream to levels below likely NPDES permit limits for Class C
waters. Nesco Environmental concludes that surface water discharge
through the NPDES program is a feasible alternative.
6

o Combinations of the aforementioned alternatives
➢ As discussed previously, connection to an existing wastewater facility
(excluding the Union County POTW), land application (surface and
subsurface), and water reuse are not feasible alternatives. Therefore, after
Union County prohibits discharge of the treated groundwater to the POTW, a
combination of the aforementioned alternatives will no longer be a feasible
alternative.
STEP 4 - Evaluate economic feasibility of alternatives
Appendix G includes a prevent value of costs analysis for the one feasible
alternative, discharge to surface water through the NPDES program. Nesco
Environmental followed NCDENR guidelines for the Engineering Alternatives Analysis
including an assumed 20-year project life. Mr. Bob Sledge of NCDENR indicated to
Nesco Environmental that a discount rate of 4.875 percent should be used in the
analysis.
7

2.0 OTHER CONSIDERATIONS
According to guidelines for the Engineering Alternatives Analysis, the
Environmental Management Commission may not act on an application for a new non-
municipal domestic wastewater discharge facility until it has received a written statement
from each city and county government having jurisdiction over any part of the lands on
which the proposed facility and its appurtenances are to be located. The guidelines
indicate that the applicant must submit requests for this information by certified mail,
return-receipt-requested. The guidelines indicate that if the applicant does not receive a
response from one or both of these local government entities within 15 days of receiving
the request, the applicant may submit an application for a new non-municipal domestic
wastewater discharge facility provided it can document that these entities received the
requests and were allowed at least 15 days to respond.
RSC has not received responses from either of the two local government entities
at this time. Appendix H includes copies the request letters and certified mail receipts.
These documents demonstrate that RSC provided proper notification to these
government entities and responses were not received within the specified time. If RSC
receives responses from either of these entities, it will forward them to NCDENR.
The proposed discharge is necessary for the continued remediation of
groundwater at the RSC facility. Once Union County prohibits the discharge to the
POTW, there will be no reasonably feasible discharge option with the exception of
discharge to the South Fork of Crooked Creek under the NPDES program. Groundwater
remediation activities at the RSC facility are being conducted in accordance with the
RCRA permit issued for this facility.
•
8

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

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

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

FIGURES

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FIGURE 1
APPROXIMATE SCALE
TOPOGRAPHIC LOCATION MAP
SCALE 1.24000
I
— 0 1 MILE
1000 0 1000 2000 3000 4000 5000 6000 7000 FEET
1 .5 0 1 KILOMETER RADIATOR SPECIALTY COMPANY
CONTOUR INTERVAL 10 FEET INDIAN TRAIL, NORTH CAROLINA
NATIONAL GEODETIC VERTICAL DATUM OF 1929

TABLES

TABLE 1
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL,NORTH CAROLINA
Parameters 03/27/95 04/12/95 05/16/95 07/12/95 09/20/95 10/26/95 11/21/95 12/14/95 02/20/96 04/16/96 05/15/96
Acetone <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.22 <0.01 0.47 <0.01 <0.01
Benzene 0.19 0.17 0.15 0.13 <0.005 <0.005 0.11 <0.005 0.11 0.1 <0.005
Carbon tetrachloride <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Chloroethane <0.01 <0.01 <0.01 <0.01 <0.01 0.32 0.5 0.2 0.34 0.032 0.3
Chloromethane NA NA NA NA NA NA NA NA NA NA NA
2-Chlorotoluene NA NA NA NA NA NA NA NA NA NA NA
4-Chlorotoluene NA NA NA NA NA NA NA NA NA NA NA
1, 1-Dichloroethane 3.3 2.9 3 2.7 3 2.9 2.4 2.6 2.7 2.5 2.2
1, 2-Dichloroethane <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
1, 1-Dichloroethene 1.1 1.3 1.2 0.91 0.97 0.98 1 0.99 1.1 0.99 1.5
1, 2-Dichloroethene(total) 2 1.7 1.5 1.4 1.4 1.4 1.4 1.4 1.4 1.3 1.1
cis-1, 2-Dichlroethene NA NA NA NA NA NA NA NA NA NA NA
trans-1, 2-Dichloroethene NA NA NA NA NA NA NA NA NA NA NA
Dichlorodifluoromethane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Ethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Methylene chloride 3.6 2.8 2.8 2.7 3 2.2 2 3.1 3.2 3 2.6
4-Methyl-2-pentanone <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Naphthalene NA NA NA NA NA NA NA NA NA NA NA
Tetrachloroethene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Toluene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
1, 1, 1-Trichloroethane 2.1 2.2 1.8 1.5 1.5 0.72 0.81 2 1.8 1.4 1.3
Trichloroethene 0.18 0.22 0.14 <0.005 0.13 <0.005 <0.005 0.14 0.14 0.12 <0.005
Trichlorofluoromethane NA NA NA NA NA NA NA NA NA NA NA
1,2,4-Trimethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
1,3,5-Timethylbenzene NA NA NA NA NA NA NA NA NA NA NA
Vinyl chloride <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Xylenes(total) <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
TOTAL: 12.47 11.29 10.59 9.34 10.00 8.52 8.44 10.43 11.26 9.44 9.00
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 1 of 6 PARTB\INFLUENT.XLS

•
TABLE 1 •
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL,NORTH CAROLINA
Parameters 06/27/96 07/23/96 08/12/96 09/09/96 10/16/96 11/19/96 12/18/96 01/21/97 02/25/97 03/24/97 04/21/97
Acetone <0.01 <0.01 <0.01 <0.01 0.18 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Benzene <0.005 <0.005 <0.005 <0.005 0.06 <0.005 0.052 0.04 <0.005 0.05 <0.005
Carbon tetrachloride <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Chloroethane 0.3 0.39 0.27 0.4 0.44 0.41 0.47 0.3 0.6 0.82 0.74
Chloromethane NA NA NA NA NA NA NA NA NA NA NA
2-Chlorotoluene NA NA NA NA NA NA NA NA NA NA NA
4-Chlorotoluene NA NA NA NA NA NA NA NA NA NA NA
1, 1-Dichloroethane 2.7 2.6 2.1 2.1 1.9 1.6 1.6 0.94 1.4 1.1 0.98
1, 2-Dichloroethane <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
1, 1-Dichloroethene 0.84 0.75 0.57 0.6 0.65 0.5 0.51 0.33 0.45 0.51 0.52
1, 2-Dichloroethene(total) 1.2 1.1 0.98 1 0.97 0.9 0.87 0.52 0.73 0.74 0.67
cis-1, 2-Dichlroethene NA NA NA NA NA NA NA NA NA NA NA
trans-1, 2-Dichloroethene NA NA NA NA NA NA NA NA NA NA NA
Dichlorodifluoromethane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Ethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Methylene chloride 2.6 2.2 1.9 1.8 1.5 1.2 1.3 0.78 1.2 <0.005 0.92
4-Methyl-2-pentanone <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Naphthalene NA NA NA NA NA NA NA NA NA NA NA
Tetrachloroethene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Toluene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
1, 1, 1-Trichloroethane 0.84 0.59 0.38 0.25 0.16 0.098 0.091 0.1 0.16 0.099 0.079
Trichloroethene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 0.036 <0.005 <0.005 <0.005
Trichlorofluoromethane NA NA NA NA NA NA NA NA NA NA NA
1,2,4-Trimethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
1,3,5-Trimethylbenzene NA NA NA NA NA NA NA NA NA NA NA
Vinyl chloride <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.11 0.077 0.18 0.23 0.32
Xylenes(total) <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
TOTAL: 8.48 7.63 6.20 6.15 5.86 4.71 5.00 3.12 4.72 3.55 4.23
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 2 of 6 PARTB\INFLUENT.XLS

TABLE 1 •
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters 05/22/97 06/26/97 07/28/97 08/19/97 09/15/97 10/30/97 11/25/97 12/08/97 01/13/98 02/18/98 03/23/98
Acetone <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.05
Benzene 0.036 <0.005 0.046 <0.005 0.03 0.039 0.037 0.032 0.027 0.034 0.044
Carbon tetrachloride <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Chloroethane 0.47 1 1.5 1.1 0.29 0.55 0.46 0.55 0.34 0.53 0.86
Chloromethane NA <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
2-Chlorotoluene NA 0.18 0.14 0.12 NA 0.1 0.096 0.087 0.071 0.11 0.099
4-Chlorotoluene NA NA NA NA NA NA NA NA NA NA <0.002
1, 1-Dichloroethane 0.66 0.88 0.73 0.54 0.41 0.5 0.49 0.39 0.31 0.44 0.52
1, 2-Dichloroethane <0.005 <0.005 <0.005 <0.005 <0.005 0.009 0.008 0.007 <0.005 0.008 0.009
1, 1-Dichloroethene 0.32 0.42 0.36 0.24 0.17 0.31 0.3 0.24 0.22 0.26 0.26
1, 2-Dichloroethene(total) 0.47 NA NA 0.39 0.31 NA NA NA NA NA NA
cis-1,2-Dichlroethene NA 0.58 0.51 0.37 0.28 0.35 0.34 0.27 0.2 0.34 0.39
trans-1, 2-Dichloroethene NA <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 NA <0.005 0.005 0.006
Dichlorodifluoromethane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01
Ethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Methylene chloride 0.69 0.82 0.62 0.47 0.39 0.48 0.41 0.32 0.34 0.44 0.56
4-Methyl-2-pentanone <0.01 <0.01 <0.01 <0.01 <0.01 0.017 0.017 <0.01 <0.01 <0.01 0.016
Naphthalene NA <0.005 <0.005 NA <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Tetrachloroethene <0.005 <0.005 <0.005 <0.005 <0.005 0.011 0.012 0.011 0.009 0.015 0.022
Toluene <0.005 <0.005 <0.005 <0.005 0.018 0.029 0.028 0.024 0.018 0.026 0.032
1, 1, 1-Trichloroethane 0.049 <0.005 <0.005 <0.005 0.019 0.033 0.033 0.03 0.02 0.031 0.04
Trichloroethene <0.005 <0.005 <0.005 <0.005 <0.005 0.02 0.02 0.018 0.015 0.021 0.027
Trichlorofluoromethane NA <0.005 <0.005 NA NA <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
1,2,4-Trimethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
1,3,5-Trimethylbenzene NA <0.005 <0.005 NA NA <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Vinyl chloride 0.28 0.48 0.41 0.32 0.16 0.32 0.29 0.31 0.2 0.36 0.45
Xylenes(total) <0.005 <0.005 <0.005 <0.005 <0.005 0.021 0.02 0.016 0.012 0.019 0.023
TOTAL: 2.98 4.36 4.32 3.55 2.08 2.79 2.56 2.31 1.78 2.64 3.37
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 3 of 6 PARTB\INFLUENT.XLS

TABLE 1 •
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL,NORTH CAROLINA
Parameters 04/20/98 05/14/98 06/24/98 12/17/98 06/30/99 12/07/99 12/29/99 06/28/00 12/20/00 06/21/01 12/20/01
Acetone <0.05 <0.05 <0.05 <0.05 0.057 0.1 0.54 <0.05 0.035 <0.05 <0.05
Benzene 0.047 0.043 0.039 0.033 0.055 0.091 0.058 0.045 0.022 0.021 0.018
Carbon tetrachloride <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Chloroethane 0.51 0.73 0.55 0.7 1.2 2.0 2.1 0.86 0.48 0.36 0.68
Chloromethane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 <0.01 <0.01 <0.01
2-Chlorotoluene 0.18 0.18 0.099 0.072 0.13 0.29 0.093 0.15 0.054 0.045 0.049
4-Chlorotoluene 0.006 <0.002 <0.002 <0.002 0.007 0.011 0.008 0.008 <0.005 <0.005 <0.005
1, 1-Dichloroethane 0.44 0.44 0.34 0.25 0.39 0.41 0.7 0.26 0.085 0.076 0.085
1,2-Dichloroethane 0.011 0.01 0.006 0.006 0.011 0.014 0.011 0.009 <0.005 <0.005 <0.005
1, 1-Dichloroethene 0.23 0.26 0.18 0.16 0.25 0.19 0.41 0.24 0.084 0.055 0.048
1, 2-Dichloroethene(total) NA NA 0.28 NA NA NA NA NA NA NA NA
cis-1,2-Dichloroethene 0.33 0.4 NA 0.19 0.27 0.22 0.45 0.29 0.097 0.073 0.054
trans-1, 2-Dichloroethene 0.007 0.007 NA <0.005 0.008 0.011 0.008 0.006 <0.005 <0.005 <0.005
Dichlorodifluoromethane <0.01 0.01 <0.01 <0.01 0.015 <0.01 0.022 <0.01 <0.01 <0.01 <0.01
Ethylbenzene <0.005 <0.005 <0.005 <0.005 0.007 0.012 0.008 0.006 <0.005 <0.005 <0.005
Methylene chloride 0.49 0.61 0.62 0.57 0.62 0.59 1.6 0.78 0.34 0.16 0.26
4-Methyl-2-pentanone 0.028 0.033 0.02 0.019 0.03 0.065 0.03 0.028 0.017 0.014 <0.01
Naphthalene <0.005 <0.005 <0.005 <0.005 <0.005 0.007 <0.005 <0.005 <0.005 <0.005 <0.005
Tetrachloroethene 0.016 0.019 0.018 0.013 0.022 0.024 0.034 0.016 0.011 0.013 0.0093
Toluene 0.037 0.034 0.03 0.031 0.047 0.064 0.045 0.041 0.021 0.019 0.02
1, 1, 1-Trichloroethane 0.041 0.041 0.022 0.02 0.062 0.028 0.32 0.017 0.008 0.0054 <0.005
Trichloroethene 0.028 0.026 0.021 0.014 0.025 0.021 0.058 0.017 0.01 0.01 0.0067
Trichlorofluoromethane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.015 <0.01 <0.01 <0.01 <0.01
1,2,4-Trimethylbenzene <0.005 <0.005 <0.005 <0.005 0.007 0.01 0.008 0.006 <0.005 <0.005 <0.005
1,3,5-Trimethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 0.008 0.007 0.007 <0.005 <0.005 <0.005
Vinyl chloride 0.29 0.54 0.29 0.31 0.45 0.67 0.73 0.58 0.29 0.22 0.47
Xylenes(total) 0.024 0.017 0.018 0.019 0.03 0.052 0.034 0.024 0.013 0.013 <0.005
TOTAL: 2.72 3.40 2.53 2.41 3.69 4.89 7.31 3.39 1.57 1.08 1.70
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 4 of 6 PARTB\INFLUENT.XLS

TABLE 1 •
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters 06/25/02 12/20/02 06/25/03 12/18/03 07/12/04 12/20/04 06/27/05 02/14/06 06/22/06 12/12/06 06/28/07
Acetone <0.05 <0.05 <0.05 <0.05 <0.05 0.02 <0.01 <0.01 <0.01 <0.01 0.011
Benzene 0.016 0.025 0.0096 <0.005 0.022 0.025 0.012 0.02 0.0072 0.0081 0.016
Carbon tetrachloride <0.005 <0.005 <0.005 <0.005 <0.005 <0.002 0.0032 <0.002 <0.002 <0.002 <0.002
Chloroethane 0.50 0.360 0.240 0.082 0.29 0.5 0.18 0.27 0.12 0.13 0.26
Chloromethane <0.01 <0.01 <0.01 <0.01 <0.01 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002
2-Chlorotoluene 0.048 0.053 <0.005 <0.005 0.024 0.035 0.013 0.015 0.006 0.0054 0.013
4-Chlorotoluene <0.005 <0.005 <0.005 <0.005 <0.005 0.0014 0.00083J <0.001 <0.001 <0.001 <0.001
1, 1-Dichloroethane 0.059 0.073 0.046 0.038 0.063 0.09 0.073 0.08 0.059 0.063 0.15
1, 2-Dichloroethane <0.005 <0.005 <0.005 <0.005 0.003J 0.0041 0.0022 0.0031 0.0015 0.0013 0.0034
1, 1-Dichloroethene 0.041 0.046 0.035 0.05 0.038 0.055 0.042 0.043 0.029 0.034 0.089
1, 2-Dichloroethene(total) NA NA NA NA NA NA NA NA NA NA NA
cis-1,2-Dichloroethene 0.034 0.037 0.020 0.02 0.05 0.059 0.048 0.049 0.03 0.043 0.11
trans-1, 2-Dichloroethene <0.005 <0.005 <0.005 <0.005 0.0037J 0.0044 0.0031 0.0045 0.0025 0.0031 0.0055 1
Dichlorodifluoromethane <0.01 <0.01 <0.01 <0.01 0.0049J 0.011 0.0059 0.0081 0.0049 0.0077 0.0066
Ethylbenzene <0.005 <0.005 <0.005 <0.005 0.0018J 0.0017 0.0011 0.0023 0.00056 J <0.001 0.0011
Methylene chloride 0.081 0.130 0.023 0.0094 0.043 0.058 0.015 0.017 0.0094 0.0079 0.019
4-Methyl-2-pentanone <0.01 <0.01 <0.01 <0.01 0.0054J 0.0057 0.0044J 0.01 0.002 J <0.005 0.0044J
Naphthalene <0.005 <0.005 <0.005 <0.005 0.0028J <0.001 0.0016 0.0056 <0.001 0.0019 0.0015
Tetrachloroethene 0.012 0.013 0.015 0.02 0.021 0.018 0.014 0.029 0.017 0.025 0.018
Toluene 0.016 0.022 0.010 <0.005 0.018 0.021 0.011 0.013 0.0045 0.0071 0.014
1, 1, 1-Trichloroethane <0.005 0.0054 0.0051 <0.005 0.0074 0.0079 0.0055 0.0073 0.0054 0.0053 0.018
Trichloroethene 0.0056 0.0068 0.0063 0.0056 0.01 0.01 0.0084 0.014 0.0072 0.0096 0.0093
Trichlorofluoromethane <0.01 <0.01 <0.01 <0.01 <0.01 <0.002 0.0016J <0.002 <0.002 <0.002 0.00071J
1,2,4-Trimethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 0.0012 0.0014 0.0013 <0.001 <0.001 0.00075J
1,3,5-Trimethylbenzene <0.005 <0.005 <0.005 <0.005 <0.005 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001
Vinyl chloride 0.41 0.170 0.060 <0.01 0.12 0.16 0.07 0.06 0.03 0.039 0.11
Xylenes(total) <0.005 <0.005 0.0075 <0.005 0.008 0.0079 0.0049 0.0083 0.0024 0.0014 0.005
TOTAL: 1.22 0.94 0.48 0.23 0.74 1.10 0.52 0.66 0.34 0.40 0.87
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
J: The analyte was positively identified but the value is estimated below the reporting limit.
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 5 of 6 PARTB\INFLUENT.XLS

TABLE 1
AIR STRIPPER INFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Parameters 12/272007 06/26/08 12/12/08
Acetone 0.0052J <0.01 <0.01
Benzene 0.011 <0.001 0.0047
Carbon tetrachloride <0.002 <0.002 <0.002
Chloroethane 0.2 <0.005 0.062
Chloromethane <0.002 <0.002 <0.002
2-Chlorotoluene 0.0077 <0.001 0.0023
4-Chlorotoluene <0.001 <0.001 <0.001
1, 1-Dichloroethane 0.13 0.026 0.044
1, 2-Dichloroethane 0.0024 <0.001 0.001
1, 1-Dichloroethene 0.084 0.074 0.037
1, 2-Dichloroethene(total) NA NA NA
cis-1,2-Dichloroethene 0.12 0.0086 0.031
trans-1, 2-Dichloroethene 0.004 0.00058J 0.0027
Dichlorodifluoromethane 0.0076 0.0064 0.0059
Ethylbenzene 0.00092J <0.001 <0.001
Methylene chloride 0.01 <0.002 0.0019
4-Methyl-2-pentanone <0.005 <0.005 <0.005
Naphthalene <0.001 <0.001 <0.001
Tetrachloroethene 0.02 0.02 0.027
Toluene 0.012 <0.001 0.0028
1, 1, 1-Trichloroethane 0.016 0.0023 0.0031
Trichloroethene 0.0086 0.0045 0.0063
Trichlorofluoromethane 0.00077J <0.002 <0.002
1,2,4-Trimethylbenzene 0.0011 <0.001 <0.001
1,3,5-Trimethylbenzene <0.001 <0.001 <0.001
Vinyl chloride 0.11 <0.002 0.022
Xylenes(total) 0.0044 <0.002 <0.002
TOTAL: 0.75 0.14 0.26
Comments:
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
J: The analyte was positively identified but the value is estimated below the reporting limit.
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 6 of 6 PARTB\INFLUENT.XLS

TABLE 2 •
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Permit
Parameters Limits 11/16/94 12/14/94 01/23/95 02/15/95 03/27/95 04/11/95 05/15/95 06/28/95 07/12/95 08/09/95
Flow (MGD) 0.09 0.0599 0.0587 0.0311 0.0063 0.0532 0,0571 0.0551 0.01542 0.0561 0.0505
1, 1-Dichloroethane 0.46 <0.001 0.045 <0.001 <0.001 0.014 0.026 0.038 0.006 0.0091 0.01
1, 1-Dichloroethene 0.135 0.02 0.01 <0.001 <0.001 <0.005 0.0039 0.008 <0.005 <0.001 0.0014
1, 2-Dichloroethene (total) 1.382 0.066 0.029 <0.001 <0.001 0.012 0.015 <0.001 <0.005 <0.001 0.0053
Tetrachloroethene 0.044 0.0011 <0.005 0.014 0.007 <0.005 <0.001 0.002 <0.005 <0.001 <0.001
1,1,1-Trichloroethane 1.525 0.065 0.03 0.01 0.004 0.013 0.024 0.03 <0.005 0.0061 0.0068
Trichloroethene 0.085 0.006 <0.005 <0.001 <0.001 <0.005 0.0022 0.0019 <0.005 <0.001 <0.001
Benzene --- NA <0.005 NA NA <0.005 NA NA <0.005 NA NA
Chloroethane --- NA <0.01 NA NA <0.01 NA NA <0.01 NA NA
Chloroform --- NA <0.005 NA NA <0.005 NA NA <0.005 NA NA
Methylene chloride --- NA 0.064 NA NA 0.03 NA NA 0.006 NA NA
Xylenes (total) --- NA <0.005 NA NA <0.005 NA NA <0.005 NA NA
Naphthalene --- NA <0.01 NA NA <0.01 NA NA <0.01 NA NA
1,2-Dichloroethane --- NA NA NA NA NA NA NA NA NA NA
Toluene --- NA NA NA NA NA NA NA NA NA NA
Vinyl chloride --- NA NA NA NA NA NA NA NA NA NA
1,3,5-Trimethlybenzene --- NA NA NA NA NA NA NA NA NA NA
2-Chlorotoluene --- NA NA NA NA NA NA NA NA NA NA
Comments:
5/5/92: NCDEM issued Pretreatment Permit 698410001.
10/25/94: Groundwater Recovery System brought On-line. Operates 24 hrs. a day, 7 days a week unless otherwise noted.
1/24/95: Pretreatment Permit 698410001 void. Union County Pretreatment Permit UC-1 effective.
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 1 of 7 PARTB\EFFLUENT.XLS

TABLE 2
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Permit
Parameters Limits 09/18/95 10/25/95 11/21/95 12/13/95 01/26/96 02/20/96 04/16/96 05/15/96 06/26/96 07/23/96
Flow (MGD) 0.09 0.0454 0.0158 0.0564 0.0537 0.009 0.0598 0.06 0.0506 0.0521 0.0487
1, 1-Dichloroethane 1.58 0.0063 0.0023 0.013 <0.005 0.012 0.024 0.014 0.0069 0.0057 0.0097
1, 1-Dichloroethene 0.139 <0.005 0.0021 <0.001 <0.005 NA NA NA NA <0.005 NA
1, 2-Dichloroethene (total) 0.28 <0.005 0.0011 0.009 0.016 NA NA NA NA <0.005 NA
Tetrachloroethene 0.096 <0.005 <0.001 <0.001 <0.005 0.0013 <0.001 <0.001 <0.001 <0.005 <0.001
1,1,1-Trichloroethane 1.191 <0.005 0.0033 0.0066 0.009 NA NA NA NA <0.005 NA
Trichloroethene 1.42 <0.005 <0.001 <0.001 <0.005 0.0025 <0.001 <0.001 <0.001 <0.005 <0.001
Benzene --- <0.005 NA NA <0.005 NA NA NA NA <0.005 NA
Chloroethane --- <0.01 NA NA <0.01 NA NA NA NA <0.01 NA
Chloroform --- <0.005 NA NA <0.005 NA NA NA NA <0.005 NA
Methylene chloride --- 0.0075 NA NA 0.054 NA NA NA NA 0.0064 NA
Xylenes (total) --- <0.005 NA NA <0.005 NA NA NA NA <0.005 NA
Naphthalene --- <0.01 NA NA <0.01 NA NA NA NA <0.01 NA
1,2-Dichloroethane --- NA NA NA NA NA NA NA NA NA NA
Toluene --- NA NA NA NA NA NA NA NA NA NA
Vinyl chloride --- NA NA NA NA NA NA NA NA NA NA
1,3,5-Trimethlybenzene --- NA NA NA NA NA NA NA NA NA NA
2-Chlorotoluene --- NA NA NA NA NA NA NA NA NA NA
Comments:
11/3/95: Union County Public Works reduced frequency of sampling.
March '96: Groundwater Recovery System down due to a request by Union County Public Works.
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 2 of 7 PARTB\EFFLUENT.XLS

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

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

TABLE 2 •
AIR STRIPPER EFFLUENT CONCENTRATIONS
VOLATILE ORGANIC COMPOUNDS
RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
Permit
Parameters Limits 04/20/98 05/14/98 06/24/98 12/17/98 06/30/99 12/07/99 12/29/99 06/28/00 12/20/00 06/21/01
Flow (MGD) 0.09 0.0445 0.0448 0.0456 0.0475 0.0452 0.06 0.052 0.0531 0.0448 0.0405
1, 1-Dichloroethane 1.58 0.19 0.14 <0.005 0.1 0.32 <0.005 <0.005 <0.005 <0.005 <0.005
1, 1-Dichloroethene 0.139 NA NA 0.073 0.053 I. _ <0.005 <0.005 <0.005 <0.005 <0.005
1, 2-Dichloroethene (total) 0.28 NA NA 0.2 0.075 0.22 <0.005 <0.005 <0.005 <0.005 <0.005
Tetrachloroethene 0.096 0.007 0.007 0.009 0.005 0.008 <0.005 <0.005 <0.005 <0.005 <0.005
1,1,1-Trichloroethane 1.191 NA NA 0.009 <0.005 0.036 <0.005 <0.005 <0.005 <0.005 <0.005
Trichloroethene 1.42 0.012 0.01 0.012 0.005 0.013 <0.005 <0.005 <0.005 <0.005 <0.005
Benzene --- NA NA 0.018 0.012 0.035 <0.005 <0.005 <0.005 <0.005 <0.005
Chloroethane --- NA NA 0.3 0.17 0.91 <0.01 <0.01 <0.01 <0.01 <0.01
Chloroform --- NA NA <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Methylene chloride --- NA NA 0.53 0.085 0.59 <0.01 <0.005 <0.005 <0.005 <0.005
Xylenes (total) --- NA NA <0.005 <0.005 0.014 <0.01 <0.005 <0.005 <0.01 <0.01
Naphthalene --- NA NA <0.01 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
1,2-Dichloroethane --- NA NA <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Toluene --- NA NA <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Vinyl chloride --- NA NA <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
1,3,5-Trimethlybenzene --- NA NA NA NA NA NA NA NA NA NA
2-Chlorotoluene --- NA NA NA NA NA NA NA NA NA NA
Comments:
7/16/98: Union County Public Works reduced sampling frequency.
11/16/99: Replaced Packing Media in air stripping tower.
NOTE: Concentrations are in mg/L.
NA: Not Analyzed
;Exceeded Permit Limit _®=
Data provided by Radiator Specialty Company
REVISED 02/17/09 Page 5 of 7 PARTB\EFFLUENT.XLS

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

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

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

APPENDICES

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

Page 1 of 4
Joseph P. Nestor
From: John C Weaver[[e-mail]]
Sent: Thursday, February 19, 2009 9:27 AM
To: Joseph P. Nestor
Cc: Richard Harmon; Curtis Weaver; Jeanne C Robbins
Subject: Low-flow characteristics for South Fork Crooked Creek near Indian Trail...Re: Stream Flow
Statistics- South Fork Crooked Creek
usG
science for a changing world
U.S. Geological Survey North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, North Carolina 27607
Date: February 18, 2009
To: Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
P.O. Box 78222
Charlotte, North Carolina 28271
Dear Mr. Nestor,
In response to your inquiry for low-flow characteristics (7Q10, 30Q2) at a location on South Fork Crooked Creek
near Indian Trail in Union County, the following information is provided:
A check of the low-flow files here at the USGS North Carolina Water Science Center indicates a previous
determination of low-flow characteristics for your point of interest based on the location coordinates provided via
your email dated January 28, 2009 (station id 0212475140, drainage area 2.20 sqmi). Determined in October
1985, the 7Q10 discharge was estimated at zero flow. However, no estimate of 30Q2 discharge was provided.
No USGS records of discharge are known to exist for your point of interest. The only known USGS records of
discharge for South Fork Crooked Creek is at a partial-record site (station id 02124761, drainage area 18.4 sqmi,
located at Secondary Road 1004, 0.6 mile upstream from mouth)consisting of 2 miscellaneous measurements
(both at zero flow) obtained in the 1961-62 water years.
Where no or insufficient data is available for a low-flow analysis, a determination of low-flow characteristics is
based on assessment of low-flow yields (expressed as flow per square mile drainage area, or cfsm) at nearby
locations where such statistics have previously been determined. The low-flow characteristics that are provided
have been computed by correlating the runoff characteristics of a nearby stream in vicinity of the request site.
Please note that the flow estimates do not account for the presence of any diversions or regulation, present or
2/19/2009

Page 2 of 4
future, which may occur upstream of the request site.
Previously published low-flow information for streams in your area of interest...
The most recent low-flow information published for most streams in Union County is in a basinwide low-flow
report completed in 2003. It is USGS Water-Resources Investigations Report 03-4147, "Low-Flow Characteristics
and Profiles for the Rocky River in the Yadkin-Pee Dee River Basin, North Carolina, through 2002" (Weaver and
Fine, 2003). An online version of the report is available through http://pubs.usgs.gov/wri/wri034147/. The report
provides the low-flow characteristics (based on data through 2002)for continuous-record gaging stations and
partial-record sites within the Rocky River basin. The report also provides low-flow discharge profiles (7Q10,
30Q2, winter 7Q10, and 7Q2)for the Rocky River from its headwaters in Mecklenburg County to its mouth.
Determination of low-flow characteristics...
(1) In Tables 5 and 6 of the above-referenced report, there are two nearby USGS sites for which low-flow
characteristics were published:
• partial-record site on North Fork Crooked Creek near Fairview(station id 02124745, drainage area 16
sqmi), record of 16 miscellaneous measurements(including 1 at zero flow) obtained during the 1961-62,
1965-69, and 1971 water years
• continuous-record station on Goose Creek at Fairview(02124692, drainage area 24.0 sqmi), period of
record since November 1999
Expressing these estimates as low-flow yields (again, flow per square mile of drainage area, or cfsm) provides
some indication of the yield ranges that potentially could be applicable to your location. Based on consideration
of the published values, the 7Q10 low-flow yields are 0 and 0.0125 cfsm, and the 30Q2 low-flow yields are 0.03
and 0.06 cfsm.
(2) Considering the above information, please be aware of the following: The data provided in the above
referenced report are based on periods of record ending during or in advance of the drought conditions that have
occurred since publication of the report. In some North Carolina basins, the low-flow conditions observed during
the 1998-2002 and current (2007-09) droughts have resulted in lower low-flow statistics. No formal statewide
investigation has been completed to document the changes in low-flow statistics since the drought. However,
where updated analyses have been completed for selected stations, the changes in pre-drought versus updated
7Q10 discharges have shown varying percentage changes of decline.
(3)At the nearby continuous-record station on Goose Creek at Fairview(operated since November 1999), an
update of the low-flow analyses for this site indicates the 7Q10 is zero flow and the 30Q2 discharge is now about
0.8 cfs (compared to the previously published value of 1.4 cfs). The updated 30Q2 discharge is equivalent to a
low-flow yield of about 0.03 cfsm, which is consistent with the 30Q2 yield noted above for the North Fork Crooked
Creek site. This updated analysis is based on records in the 2000-07 climatic years, which is considered short-
term record for the purposes of determining low-flow characteristics at continuous-record gaging stations.
However, the results of the updated analysis for this gage confirm observation of declining low-flow
characteristics in response to the low flow conditions that have been observed since the late 1990's.
Notes:
(a) The climatic year is the standard annual period used for low-flow analyses at continuous-record gaging
stations. It runs from April 1 through March 31 and is designated by the year in which the period begins. For
example, the 2007 climatic year is from April 1, 2007, through March 31, 2008.
(b) The water year is the standard annual period used for collection and publication of streamflow records. It runs
from October 1 through September 30 and is designated by the year in which the period ends. For example, the
2007 climatic year is from October 1, 2006, through September 30, 2007.
Putting together the above pieces of information...
2/19/2009

Pa f4
Page
Applying the drainage area at your point of interest(2.20 sqmi) to the above yield values (in items#1 and#3)
results in a 7010 discharge that is zero flow. The 3002 discharge is estimated to be about 0.07 cfs.
A charge of$250.00 for accessing and processing information has been assessed to partially offset these costs.
An electronic invoice covering processing costs for these data is attached to this email as a .PDF file.
Instructions for sending your payment are shown on the invoice.
This information is considered preliminary and subject to revision pending further analysis as further data were to
become available, and is made available through our cooperative program of water-resources investigations with
the North Carolina Department of Environment and Natural Resources.
Hope this information is helpful. If you have any questions regarding this information, please contact me at the
phone number listed below.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Telephone: [phone] II Fax: [phone]
E-mail [e-mail]
Internet address--http://nc.water,usgs.gov/
"Joseph P.Nestor"<[e-mail]>
To<[e-mail]>
01/28/2009 10:10 AM cc
"Richard Harmon"<[e-mail]>
Subject Stream Flow Statistics-South Fork Crooked Creek
Mr. Weaver:
Thank you for returning my telephone call.
As we discussed, my firm, Nesco Environmental, PLLC, has been requested by another consulting firm to prepare
a proposal to assist it in obtaining an NPDES permit for Radiator Specialty Company in Indian Trail. Guidance
from the NCDENR indicates that as part of the process, the applicant must obtain stream flow statistics from the
USGS. From our conversation, I understand that the USGS normally charges$250.00 for providing such stream
flow statistics.
2/19/2009

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

APPENDIX B
RECORDS OF COMMUNICATION
I -

• r e. UNION COUNTY PUBLIC WORKS
. Huneycutt,cutt, Interim Director
v
7.
March 18, 2009
Mr. Stewart A. Kerkhoff
Environmental Supervisor
Radiator Specialty Company
600 Radiator Road
Indian Trail, NC 28079
Subject: Discontinuance of Remediated Groundwater Discharge Order
Radiator Specialty Company
Dear Mr. Kerkhoff:
Union County Public Works (UCPW) has allowed Radiator Specialty to discharge up to 90,000
gallons per day of remediated groundwater into the sanitary sewer. The water is ultimately
handled at the Crooked Creek Wastewater Treatment Plant (WWTP). Over the past years
demand for sewer capacity in the Crooked Creek WWTP service area has started to tax the
rated capacity of the VW TP. Removal of Radiator's discharge from the WWTP would provide a
fairly significant decreased "base flow" which in turn may allow for new and/or expanded
industrial commercial flow within the service area. Expansion of the WWTP is not an option at
this time. Please accept this letter as notice that, effective December 31, 2009, Radiator
Specialty Company must find and alternate disposal option for the remediated groundwater and
cease discharge of the same to the sanitary sewer system. This discontinuance order is for
remediated groundwater only and does not apply to process or domestic wastewater.
UCPW is aware that Radiator Specialty has been investigating alternate disposal options for the
past several years. These options include internal uses as well as off-site options. It is
understood that these options are not viable either due to cost or due to the high the volume of
water needing to be disposed of; or a combination of the two. If UCPW can assist Radiator in
anyway with an alternate disposal method other than discharge to the sanitary sewer, please do
not hesitate to contact me and I will be glad to discuss it with you.
I think you will agree that UCPW and Radiator Specialty have enjoyed a good working
relationship over the past years. UCPW very much wants to continue this relationship. As
stated above if UCPW can assist with evaluating options, just let me know. If additional
discussion is required on these matters, please feel free to contact me at 704 296-4215 or
mtve(a co.union.nc.us
Respectfully,
Mark E. Tye
Assistant Public Works Director
CC: Scott Huneycutt, UCPW Interim Director
Mike Garbark, Assistant Director for Engineering
500 North Main St.,Suite 500 • Monroe,NC 28112-4730 • Phone: [phone] • Fax: [phone]

Page 1 of 2
Joseph P. Nestor
From: Joseph P. Nestor[[e-mail]]
Sent: Tuesday, February 24, 2009 4:02 PM
To: '[e-mail]'; '[e-mail]
Subject: Engineering Alternatives Evaluation for NPDES Permitting
Ms. Reid:
I am trying to contact the Dianne Reid who works in basinwide planning at NCDENR. Two Dianne
Reids were list on the NC GOV webpage. I apologize if I have sent this email to you and you are not
that person.
I am assisting a client in obtaining a NPDES permit for the discharge of treated ground water as part of
a RCRA cleanup. The NPDES permitting process requires that an Engineering Alternatives Evaluation
(EAA) be performed. NCDENR guidance indicates that the proponent must first determine if the
discharge may be allowed. The guidance indicates that the proponent should determine if there are
any limitations as a result of basinwide planning that would prohibit a proposed discharge. Specifically
the guidance states:
Basinwide Water Quality Plans. These basin-specific plans list NPDES permitting strategies that
may limit wastewater discharges to particular streams within the basin due to lack of stream
assimilative capacity, etc. Basin plans are available on the DWQ website, or you may contact the
DWQ Basinwide Planning Unit at 919-807-6300.
The proposed discharge is into the South Fork Crooked Creek at approximately 35 03' 58" N 80 39'
16" W. This is in Indian Trail in Union County. The discharge point lies within the Rocky River Basin
within the Yadkin River Basin.
I have downloaded the 2008 Rocky River Basinwide Plan Report from
http://h2o.enr.state.nc.us/basinwide/Neuse/2008/documents/RockyR.03040105.pdf.
The South Fork Crooked Creek is listed as impaired in this document, but I did not find anything in the
document to indicate that the proposed discharge would be prohibited as a result of basinwide
planning. I am certainly not an expert on the basinwide planning process, and would appreciate a
knowledgeable person from NCDENR confirming my understanding. Would you or another member
of your staff help me on this matter, please?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
2/24/2009

Page 2 of 2
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]
2/24/2009

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

Page 2 of 2
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]
2/24/2009

Page 1 of 1
Joseph P. Nestor
From: Joseph P. Nestor[[e-mail]]
Sent: Tuesday, February 24, 2009 3:56 PM
To: '[e-mail]'
Subject: Engineering Alternatives Evaluation for NPDES Permitting
Ms. Deaton:
I am assisting a client in obtaining a NPDES permit for the discharge of treated ground water as part of
a RCRA cleanup. The NPDES permitting process requires that an Engineering Alternatives Evaluation
(EAA) be performed. NCDENR guidance indicates that the proponent must first determine if the
discharge may be allowed. The guidance indicates that the proponent should determine if there are
any limitations as a result of the presence of endangered species. Specifically the guidance states:
Presence of Endangered Species. If endangered species are present in the proposed
discharge location, there may be wastewater discharge restrictions. Endangered species
information may be included in the Basinwide Water Quality Plan, or you may contact the U.S.
Fish and Wildlife Service (919-856-4520), N.C. Wildlife Resources Commission (919-733-
3633), or the N.C. Natural Heritage Program (919-733-7701).
The proposed discharge is into the South Fork Crooked Creek at approximately 35 03' 58" N 80 39'
16" W. This is in Indian Trail in Union County. The discharge point lies within the Rocky River Basin
within the Yadkin River Basin.
I have downloaded the NCDENR 2008 Rocky River Basinwide Plan Report from
http;//h2o.enr.state.nc.us/basinwide/Neuse/2008/documents/RockyR.03040105.pdf.
I did not see any reference to endangered species for the South Fork Crooked Creek in this document
and presume that your agency would not prohibit or restrict he discharge as a result of endangered
species. I am certainly not an expert on endangered species, and would appreciate a knowledgeable
person from your agency confirming my understanding. Would you or another member of your staff
help me on this matter, please?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]
2/24/2009

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

Page 2 of 2
Does this facility have the capacity to accept this wastestream?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte , North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
nescoenv( carolina.11.
2/26/2009

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

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

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

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

WESSokirm,,ffiod
Environmental
A Professorial Limited Liab,bt1 Company
February 28, 2009
Mr. Thomas Roberts
President
Aqua— North Carolina
202 Mackenan Court
Cary, North Carolina 27811
Re: Country Wood WWTP
NPDES Permit No. NC0065684
Radiator Specialty Company
Union County, North Carolina
Dear Mr. Roberts:
Nesco Environmental, P.L.L.C. (Nesco Environmental) is assisting a client in
obtaining a (National Pollutant Discharge Elimination System) NPDES permit for the
discharge of treated ground water as part of cleanup project involving solvent-
impacted ground water. The NPDES permitting process requires that an Engineering
Alternatives Evaluation (EAA) be performed. Guidance from the North Carolina
Department of Environment and Natural Resources (NCDENR) indicates that the
proponent must determine if other existing wastewater facilities within 5 miles of the
proposed discharge would be willing to accept the discharge.
Nesco Environmental has identified the Country Wood WWTP (NPDES Permit
No. NC0065684) as being within 5 miles of the proposed discharge. Nesco
Environmental has identified your company as the operator of this facility through
public records.
The flow from the proposed discharge is anticipated to be up to 75,000 GPD.
The expected concentrations (in milligrams per liter) of solvents remaining in the
treated discharge are as follows:
Environmental and Geologic Services
_ 'O Box 78222 Charlotte, NC 28271 -I- 2416 River Oaks Drive Waxhaw, NC 28173
Phone [phone] -I- Fax [phone]
Email [e-mail]

Mr. Thomas Roberts.
Aqua— North Carolina
February 28, 2009
Page 2
1, 1-Dichloroethane 0.015
1, 1-Dichloroethene 0.0015
1, 2-Dichloroethene (total) 0.0074
Tetrachloroethene 0.0021
Trichloroethene 0.00073
Chloroethane 0.0081
Methylene chloride 0.002
Would your company be willing to accept this wastestream at the Country
Wood WWTP?
Please respond to this inquiry as soon as your schedule allows. You may
respond by telephone, mail, or by email (nescoenv(carolina.rr.com).
Thank you for your help in this matter. If you have questions, please contact
me at [phone].
Sincerely,
NESCO ENVIRONMENTAL, P.L.L.C.
P. A*/
Joseph P. Nestor, P.G., P.E.
President
JPN1jpn120090228

•
1
I
I
1

EPA I Envirofacts Warehouse I FII Page 1 of 2
http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?
.y- ?"s pqm—sys---idiAtr W8f} 0+A� -fk(15 fir Y X52009.
Facility Registry System (FRS)
ar
3��r4t anottc You are here: EPA Home Envirofacts FRS Report
Facility Detail Report
ert
an
Error
FRS
Facility Name: COUNTRY WOOD WWTP
Location Address: NCSR 1004
Supplemental Address:
City Name: MONROE
State NC
County Name: UNION
ZIP/Postal Code: 28110
EPA Region: 04
Congressional District Number: 08
Legislative District Number:
HUC Code: 03040105
Federal Facility:
US Mexico Border Indicator: NO
Tribal Land : NO
Latitude: 35.122778
Longitude: -80.620556
Method: INTERPOLATION-MAP
Reference Point Description: FACILITY CENTROID
Duns Number:
Registry ID: 110006708429
Map this facility
Environmental Interests
Information Information Environmental Data Last Supplemental
System System ID Interest Type Source Updated Environmental
Date Interests:
PCS NC0065684 NPDES NON- NPDES 03/25/2003
MAJOR PERMIT
Facility Mailing Addresses
http://oaspub.epa.gov/enviro/fii_query_dtl.disp program_facility?pgm_sys_id_in=NC006... 2/28/2009

EPA I Envirofacts Warehouse I FII Page 2 of 2
Affiliation Type Delivery Point City State Postal Information
Name Code System
PRIMARY MAILING 202 MACKENAN CARY NC 27511 PCS
ADDRESS CT
NAICS Codes
No NAICS Codes returned.
SIC Codes
Data Source SIC Code Description Primary
PCS 4952 SEWERAGE SYSTEMS
Contacts
Affiliation Type Full Name office Information Mailing
Phone System Address
COGNIZANT THOMAS ROBERTS, 9194678712 PCS
OFFICIAL PRESIDENT
Organizations
No Organizations returned.
Alternative Names
Alternative Name Source of Data
HEATER UTIL/COUNTRY WOOD WWTP NPDES PERMIT
Query executed on: FEB-28-2009
http://oaspub.epa.gov/enviro/fii_query_dtl.disp program_facility?pgm_sys_id_in=NC006... 2/28/2009

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

Page 2 of 3
the email and are the correct person to whom we should be making this inquiry?
If you need additional information, please contact me at your earliest convenience.
Thanks.
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]
From: Deaton, Shannon L. [mailto:[e-mail]]
Sent: Monday, March 09, 2009 10:02 AM
To: [e-mail]
Cc: Bryant, Shari L.
Subject: FW: Engineering Alternatives Evaluation for NPDES Permitting
I apologize for my delayed response. I am glad you followed up with another phone call as I missed your first
email.
You do need to get in touch with Shari Bryant to evaluate Union county habitats and species. She is cc'd to this
email and her phone number is 336-449-7625.
From: Nestor P.Joseph mailto:[e-mail]
P [ ]
Sent: Tuesday, February 24, 2009 3:56 PM
To: Deaton, Shannon L.
Subject: Engineering Alternatives Evaluation for NPDES Permitting
Ms. Deaton:
I am assisting a client in obtaining a NPDES permit for the discharge of treated ground water as part of a
RCRA cleanup. The NPDES permitting process requires that an Engineering Alternatives Evaluation
(EAA) be performed. NCDENR guidance indicates that the proponent must first determine if the
discharge may be allowed. The guidance indicates that the proponent should determine if there are any
limitations as a result of the presence of endangered species. Specifically the guidance states:
Presence of Endangered Species. If endangered species are present in the proposed
discharge location, there may be wastewater discharge restrictions. Endangered species
information may be included in the Basinwide Water Quality Plan, or you may contact the U.S.
Fish and Wildlife Service (919-856-4520), N.C. Wildlife Resources Commission (919-733-
3633), or the N.C. Natural Heritage Program (919-733-7701).
The proposed discharge is into the South Fork Crooked Creek at approximately 35 03' 58" N 80 39' 16"
W. This is in Indian Trail in Union County. The discharge point lies within the Rocky River Basin within
the Yadkin River Basin.
I have downloaded the NCDENR 2008 Rocky River Basinwide Plan Report from
3/11/2009

Page 3 of 3
http://h2o.enr.state.nc us.../basinwde/Neuse/2008/documents/RockyR03040105.pdf.
I did not see any reference to endangered species for the South Fork Crooked Creek in this document
and presume that your agency would not prohibit or restrict he discharge as a result of endangered
species. I am certainly not an expert on endangered species, and would appreciate a knowledgeable
person from your agency confirming my understanding. Would you or another member of your staff
help me on this matter, please?
Thanks
Joseph P. Nestor, P.G., P.E.
Nesco Environmental, P.L.L.C.
PO Box 78222
Charlotte, North Carolina 28271
704-442-1365 (office)
704-243-5024 (fax)
[e-mail]
3/11/2009

F

Ltima2C1 M '
06 February AD,2009
Richard L. Harmon, P.G.
Harmon Environmental, PA
615 Bruce Thomas Road
Monroe,North Carolina 28112
SUBJECT: REVIEW OF UNION COUNTY SOIL SURVEY INFORMATION FOR
POTENTIAL LAND APPLICATION OF TREATED GROUNDWATER
RADIATOR SPECIALTY COMPANY,INC.
600 RADIATOR ROAD
INDIAN TRAIL,NORTH CAROLINA
Dear Mr. Harmon:
Introduction
Septic Environmental Solutions, Inc. has completed Part 1, Alternative 13. of the Engineering
Alternative Analysis (EAA) Guidance Document for North Carolina Division of Water
Quality/National Polluted Discharge Elimination System(NPDES)Unit on the Radiator Specialty
Company(RSC)property in Indian Trail,North Carolina. One of the application requirements is
for a North Carolina Soil Scientist to estimate the best case hydraulic loading rate based on
County Soil Surveys. Therefore, the objective of this scope of services is to provide information
for a best case estimate of the hydraulic loading rate based on information presented in the Soil
Survey of Union County, North Carolina published by the United States Department of
Agriculture.
Interpretations regarding the suitability of these soils in reference to hydraulic loading rates for
various land uses are based on a combination of factors, including but not limited to detailed
understanding of topography, soil characteristics, soil depths, restrictive horizons, soil wetness,
slope, drainage patterns, available space, local climate, including rainfall amounts and
evaporation rates, buffer restrictions and impact of watertable, and local field experience. Other
important site selection criteria factors include, but are not limited to feasibility of design and
installation, operation and maintenance requirements and cost, and consultation with local
landowners and other experts located in the county and state. Generally, some of these
conditions, which may limit the site use, can be compensated for by changing the system design.
5522 Whispering Wind Lane.Indian Trail,North Carolina 28079
Office(704)684.1468•Mobile[phone]•Fax[phone]

However, some factors cannot be remedied. It is with this philosophy that this report was
prepared.
This summary report addresses the requirements of Part 1, Alternative B. Land Application
requirements for an Engineering Alternatives Analyses(EAA)and is intended to be incorporated
into a National Pollution Discharge Elimination System (NPDES) Permit application being
prepared by Harmon Environmental, PA and NESCO Environmental, P.L.L.C. on behalf of
Radiator Specialty Company.
Background Information
The total acreage for the subject properties is approximately 127±acres. Currently RSC is
treating approximately 37-gallons per minute (GPM) or 53,280 gallons per day (GPD). This
treated wastewater is currently discharged to the Union County Publicly Owned Treatment Works
(POTW). RSC's current agreement allows for the discharge of up to 60,000 GPD. The
groundwater treatment system is capable of treating up to approximately 100,000 GPD and the
groundwater recovery system is capable of capturing approximately 75,000 GPD. For this scope
of service 75,000 GPD was used for the EEA Land Application disposal waste flow to determine
the best estimate of the hydraulic loading rate based on the County Soil Surveys. Land
application disposal alternatives include individual/community onsite subsurface, drip irrigation,
and spray irrigation systems.
It is understood that the groundwater remediation system was in operation October 1994. The
groundwater recovery system consists of four wells, (R-1, RW-2, RW-3 and RW-4) ranging in
depth for 110 feet below grade to 500 feet below grade. These wells are currently pumped at a
combined flow of approximately 37 GPM. The collected groundwater is transferred via sub-
grade piping to a 6,000-gallon above ground equalization tank. Recovered groundwater is
transferred from the 6,000-gallon equalization tank via a feed pump to the air stripping tower for
treatment. In the stripping tower, VOCs are stripped from the water and transferred to an air
stream which exits through the top of the treatment unit.The treated groundwater is subsequently
discharged to the Union County Publicly Owned Treatment Works (POTW) in accordance with
the conditions of Industrial Users Permit UC-1.
2

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

The unit includes the Cid Channery silt loam (Cm13) with I to 5 percent slopes. The Cid soil is
moderately deep over bedrock. It is moderately well-drained and somewhat poorly drained
nearly level and gently sloping Cid and similar soils on flats, on ridges in the uplands, in
depressions, and at the head of intermittent drainageways. Typically, the surface layer is light
brownish gray channery silt loam 4 inches thick.The subsurface layer is pale yellow channery silt
loam 5 inches thick. The subsoil is 18 inches thick. In the upper part it is brownish yellow silty
clay loam that has pale yellow mottles. In the lower part it is mottled grayish brown and light
olive brown channery silty clay. Weathered,fractured slate bedrock is at a depth of approximately
27 inches. Hard,fracture,slate bedrock is at a depth of 32 inches.
Permeability is slow in the Cid soil. Available water holding capacity is low or moderate. The
shrink-swell potential is moderate. This soil is typically described as strongly to extremely acid.
The BuB-Badin—Urban land complex,2 to 8 percent slopes. This map unit occurs mainly as areas
of moderately deep, well-drained, undulating Badin soil and areas of Urban land. It is about 60
percent Badin soil and 25 percent Urban land. Individual areas are irregular in shape and range
from 25 to 500 acres in size. Typically, the surface layer is reddish brown channery silty clay
loam 6 inches thick. The subsoil is 23 inches thick. In the upper part, it is red silty clay and in the
lower part it is red channery silty clay loam that has yellow and strong brown mottles.
Weathered, fractured slate bedrock is at a depth of about 29 inches. Hard fracture slate bedrock is
ata depth of 41 inches.
Permeability and shrink-swell potential is typically described as moderate. Available water
capacity is low or moderate. This soil is typically described as strongly to extremely acid.
The ChA-Chewacla silt loam with 0 to 2 percent slopes,frequently floods.This map unit consists
mainly of very deep, nearly level, somewhat poorly drained Chewacla and similar soils on flood
plains. It is mostly on broad flats along the major streams and on narrow flats along minor creeks
and drainageways. Individual areas are generally long and narrow and range from 25 to more
than 200 acres in size. Typically,the surface layer is brown silt loam 7 inches thick. The subsoil
is 45 inches thick. In the upper part, it is light yellowish brown silt loam that has yellowish
4

brown mottles. In the next part, it is yellowish brown loam that has light brownish gray mottles.
In the lower part, it is light brownish gray silty clay loam that has yellowish brown mottles. The
underlying material to a depth of 72 inches is light gray loamy fine sand that has yellowish brown
and dark yellowish brown mottles.
Permeability is moderate in the Chewacla soil. Available water capacity is high. The soil is
typically described as very strongly acid to slightly alkaline in the lower part of the subsoil and in
the underlying material. The shrink-swell potential is low.
The BaB- Badin channery silt loam, 2 to 8 percent slopes. This map unit consists of moderately
deep, well-drained soils. Typically,the surface layer is brown channery silt loam 7 inches thick.
The subsoil is 21 inches thick. In the upper part, it is red silty clay and in the lower part it is red
channery silty clay loam that has yellow and strong brown mottles. Weathered, fractured slate
bedrock is at a depth of about 28 inches. Hard fracture slate bedrock is at a depth of 41 inches.
Permeability and shrink-swell potential is typically described as moderate. Available water
capacity is low or moderate.This soil is typically described as strongly to extremely acid.
The ZnB- Zion gravelly loam with 2 to 8 percent slopes. This map unit consists mainly of
moderately deep, well drained, gently sloping Zion and similar soils on ridges in the uplands.
Individual areas are oval and range from 4 to more than 200 acres. Typically,the surface layer is
brown gravelly loam 8 inches thick. The subsoil is 18 inches thick. In the upper part, it is
yellowish brown gravelly clay loam. In the next part, it is dark yellowish brown clay that has
yellowish brown mottles. In the lower part, it is mottled yellowish brown and brown clay loam.
The underlying material extends to a depth of 30 inches.
Permeability is slow in the Zion soil. Available water capacity is low. This soil is typically
described as strongly acid to neutral in the subsoil and underlying material. The shrink-swell
potential is high.
5

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

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

gallons per square foot per day (gal/ft2/day). This permeability data is of relevance. However
these estimates are based on samples collected from the field and tested in laboratory conditions
including but not limited to soil characteristics, particularly structure, porosity, and texture. In
addition, these County Soil Surveys are not site specific and the information relates to only the
upper three feet of the soil profile and for this reason this data should be used qualitatively and
not quantitatively.
Septic Environmental Solutions, Inc. has performed numerous Soil and Site Evaluations on
similar soil types throughout Union County. Many of these soil types were unsuitable for land
application due to severe limitations, topography and shallow soil depths to restrictive soil
conditions such as shallow bedrock,shallow soil wetness,shallow water table and unsuitable clay
mineralogy (expansive clay). For these reasons, hydraulic conductivity (Ksat) tests typically
were not warranted.
Depending on the type of land disposal, the disposal flow and State Rules and Regulation
requirements only a few sites with these soil types warrant Ksat testing. Most of these sites were
evaluated for small amounts of residential waste flow, typically less than 600-GPD or larger
facilities such as Day Care Facilities with waste flow < 3,000-GPD. These Ksat tests were
performed on similar soil types and landscape positions by using an advanced field instrument,
the Compact Constant Head Permeameter (CCHP) designed by Dr. Amoozegar (1989).
Measurements were continuously taken in dry to moist soil conditions up to twenty-four hours or
until the meters were near empty in the most restrictive soil horizons. These field tests, typically
reported much lower test results then what was reported in the (NRCS) Union County Soil
Survey Manual. A few test results reported slightly higher Ksat measurements. It was believed
that the higher Ksat results were contributed to the shallow fractured bedrock that underlies the
soil and other unconsolidated material.
These soil types typically have shallow depth to bedrock, long duration of seasonal high water table
as described for December to May, surface ponding, slow permeability and erosion potential. The
remaining soil types have slow to moderate permeability, shallow depth to bedrock, surface
ponding, erosion potential, and moderate to high shrink-swell potential. Other limited factors for
8

these soil types are depth to water for drainage, depth to rock and slope for irrigation and soil
wetness and flooding.
The slow permeability of these soils is one of the most limiting factors. This factor can not be
altered to increase the soils permeability. In addition the depth to weathered bedrock limits the
volume of water the soil can store and transmit. For these limitations but not limited to, there is
nothing that can be done to alter them. Based on the 75,000-GPD proposed treated groundwater
disposal flow and the published data in the Union County Soil Survey Manual and our experience
with these soil types, these soils types would typically be considered unsuitable for land
application.
Note: Other factors such as hydrogeological characteristics and groundwater mounding analysis
of the site must be used to determine the final loading rate in the final design of the land
application.
Closing
This opinion report may be relied upon in connection with and for the purposes set forth herein to
the degree allowed by the Terms and Conditions agreed to on January 29, 2009. independent
conclusions, opinions and recommendations made by others based on the field data are not the
responsibility of the undersigned.
The RSC property located on Radiator Road in Union County, North Carolina was evaluated in a
diligent manner. It is guaranteed that the work was performed to professional standards.
However, this report represents a professional opinion, and does not express or imply that small
portions of the RSC tract may be suitable for land application. It is our opinion however, that
insufficient acceptable soil is available to land apply the proposed 75,000 GPD of treated waste
water from the RSC groundwater remediation system.
This document does not guarantee government approval or denial. North Carolina Division of
Water Quality (DWQ), Department of Environmental Health and Natural Resource, and NPDES
must approve all proposed land application and their installation locations.
9

If you should have any questions concerning this report, or need further assistance, call (704)
502-5588.
Sincerely, so) SOIL S..
.. C
iD VC "'o(�l1..,'F
Kenneth L. Owens,L.S.S.
North Carolina Licensed Soil Scientist# 1 134 a °"
Radiator Specialty.doc �+� ,�` =Q'
91 l}3A N
F�FNORTH CPEO
10

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FIGURE 1 . Site Location Map
Radiator Specialty Company
600 Radiator Drive
Union County, North Carolina
Dwg Date: January 29. 2009
DWG BY: KLO DWG NO. 1 REVISED: NA
SCALE:NTS SHEET 1/4

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FIGURE 2. Site Layout Map
Radiator Specialty Company
600 Radiator. Drive
Union County, North Carolina
Dwg Dote: Jonuory 29, 2009
DWG BY: KLO DWG NO" 2 REVISED: NA
SCAI.E:NTS SHEET: 2/4
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Source: Union County Soil Survey Manual
FIGURE 3. Soil Survey Map
Radiator Specialty Company
600 Radiator Drive
Union County, North Carolina
Dwg ,�ory 29, 2009
OWG Dote:BY: KLOJanDWG NO. 3 REVISED: NA
SCALE:NTS SHEET: 3/4

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iator Drive
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600 Radiator Drive
Union County, North Carolina
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SCALENTS I SHEET: 5/5

PHOTOGRAPHS

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•
ATTACHMENT A
(WEB SOIL SURVEY INFORMATION)

Soil Map—Union County,North Carolina
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USC.)A Natural Resources Web Soil Survey 2.1 1128!2009
Conservation Service National Cooperative Soil Survey Page 1 of 3
J

Soil Map—Union County,North Carolina
MAP LEGEND MAP INFORMATION
Area of Interest(AOI) Cr! Very Stony Spot Map Scale:1:7.900 if printed on A size(8.5"a 11")sheet.
Area of Interest(A01) .f Wet Spot The soil surveys that comprise your AOI were mapped at 1:24,000.
Soils Other Please rely on the bar scale on each map sheet for accurate map
Soil Map Units measurements.
Special Line Features
Special Point Features Gully Source of Map: Natural Resources Conservation Service
Blowout Web Soil Survey URL: hltp://websoilsurvey.nres.usda.gov
. Short Steep Slope Coordinate System: UTM Zone 17N NAD83
® Borrow Pit
.., Other This product is generated from the USDA-NRCS certified data as of
x Clay Spot
Political Features the version date(s)listed below.
♦ Closed Depression
Cites
Soil Survey Area: Union County.North Carolina
Gravel Pit Water Features Survey Area Data: Version 10.Oct 19,2007
. Gravelly Soot Oceans Date(s)aerial images were photographed: 6/20/2006
J: Landfill Streams and Canals The orthophoto or other base map on which the soil lines were
Lava Flow Transportation compiled and digitized probably differs from the background
+++ Rails imagery displayed on these maps.As a result,some minor shifting
Marsh or swamp of map unit boundaries may be evident.
4s Mine or Quarry = Interstate Highways
p Miscellaneous Water US Routes
® Perennial Water Major Roads
v Rock Outcrop Local Roads
+ Saline Spot
Sandy Spot
Severely Eroded Spot
E` Sinkhole
Slide or Slip
0 Sodic Spo:
Spoil Area
Stony Spot
USDA Natural Resources Web Soil Survey 2.1 1/28/2009
atm Conservation Service National Cooperative Soil Survey Page 2 of 3

Soil Map—Union County,North Carolina
Map Unit Legend
Union County,North Carolina(NC179)
Map Unit Symbol Map Unit Name Acres in AOI Percent of AO1
BaB Badin channery silt loam,2 to 8 percent slopes 6.7 5.0%
BdB2 Badin channery silty clay loam,2 to 8 percent 30.8 23.2%
slopes,eroded
BuB Badin-Urban land complex,2 to 8 percent 14.5 10.9%
slopes
ChA Chewacla silt loam,0 to 2 percent slopes, 6.9 5.2%
frequently flooded
CmB Cid channery silt loam,1 to 5 percent slopes 67.8 51.1%
GoC Goldston very channery silt loam,4 to 15 0.8 0.6%
percent slopes
GsB Goldston-Badin complex,2 to 8 percent slopes 0.0 0.0%
ZnB Zion gravelly loam,2 to 8 percent slopes 5.2 3.9%
Totals for Area of Interest 132.8 100.0%
IJSDA Natural Resources Web Soil Survey 2.1 1/28/2009
i1� Conservation Service National Cooperative Soil Survey Page 3 of 3

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

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

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

" 1
• I
Mr. Stuart Kerkhoff
February 26, 2009
Page 4
The aquifer underlying the RSC facility is typical of the composite-weathered residuum-crystalline
fractured rock aquifers located in the piedmont region of North Carolina. The aquifer is unconfined,
existing under phreatic or water table conditions. Under such conditions,the water table surface is in
equilibrium with the atmospheric pressure and is not confined by low-permeable layers between the
surface of the water table and the surface of the ground.
Groundwater under water table conditions is typically replenished through direct infiltration from
precipitation. Water flows through pore spaces in geologic media to its ultimate discharge in
topographic low regions where the water table surface intersects the surface of the ground. As a
result of these typical flow patterns, the potentiometric (water table) surface expressed by water
table aquifers typically appears as a subdued replica of the topography. Prior to initiating the
groundwater recovery program,shallow groundwater flowed from the RSC facility to the northwest
and southeast. The calculated velocity of the groundwater flowing to the northwest was
approximately 0.005 feet per day(ft/d)and the calculated velocity of the groundwater flowing to the
southeast was 0.03 ft/d.
In 1994,to assess the aquifer characteristics and evaluate the effect the fracture set may have on the
recovery of groundwater for on-site pretreatment, RSC conducted step-down tests in three of the
individual recovery wells and a constant discharge test pumping from the entire recovery well
network. The results of the constant discharge test were interpreted using Theis,Cooper-Jacob and
Neuman Methods. The results of these interpretations indicated the geometric mean of the
hydraulic conductivity results at the site ranged from 0.17 ftld to 0.23 ft/d.
Based on water level measurements collected on April 29,2008,the water table surface exhibits the
influence of the on-going groundwater remediation system. The calculated groundwater flow
velocities depicted on this figure ranged from 0.05 ft/d to 0.23 ft/d in the vicinity of the recovery
wells.
The vertical component of the groundwater flow calculated based on the April 29,2008 water level
measurements indicate the recovery wells are influencing the flow of the deeper portion of the
aquifer,effectively drawing deeper water toward the recovery wells. The vertical component of the
groundwater flow velocity calculated from the groundwater elevations collected from an on-site
well cluster is 0.01 ft/d upward.
North Carolina General Statue,Article 21 §143-215.1A.allows for injection of treated groundwater
in a"closed-loop groundwater remediation system". A closed-loop system is considered a system in
which the injected groundwater is captured by the recovery system. Based on the variability of the
bedrock the RSC facility, this site is not considered to be conducive for this form of subsurface
disposal. As a result, Harmon Environmental, PA recommends RSC pursue other options for
discharging for this water.

•
Mr. Stuart Kerkhoff
February 26, 2009
Page 5
Please call if you have any questions or require any additional information.
Sincerely,
Harmon Environmental, PA
Richard L. Harmon,
President
6,J�Zv!
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•
Radiator Specialty Company
Indian Trail,North Carolina
EPA ID No. NCD 091 245 969
Treated Groundwater Reuse Synopsis
Radiator Specialty Company (RSC) has been operating a Groundwater Recovery
and Treatment System since October 1994. The system operates twenty-four(24) hours a
day, seven (7) days a week, three hundred and sixty-five (365) days a year. The system
treats and discharges to the Union County Publicly Owned Treatment Works (POTW) up
to sixty thousand (60,000) gallons of treated groundwater a day.
On June 6, 2003 RSC requested and was granted a"Contained-In Determination"
for its treated groundwater. RSC has been investigating alternatives to the Union County
POTW for its treated groundwater since receiving the "Contained-In Determination".
Listed below is a brief synopsis of the alternatives RSC has investigated for its treated
groundwater/gray water.
A. Waterbaths - RSC has three (3) aerosol manufacturing lines that utilize
waterbaths for pressure testing the aerosol cans. Each waterbath utilizes
five hundred(500)gallons of water per day.
B. Toilets — Based on the assumption that each RSC associate, one hundred
and fifty-two in total, uses twelve and a half(12.5) gallons of water per
day for sanitary wastewater disposal, 2,900 gallons of water would be
used per day.
These two options combined were assumed to consume approximately 3,400
gallons of wastewater per day. Due to the limited volume of gray water
consumed by these options relative to the costs associated with reconfiguring the
plumbing to utilize this limited volume of wastewater deemed these options
infeasible.
C. Process Water— RSC reviewed utilizing the wastewater as makeup water
in the production of chemical products. This option is infeasible because
the costs associated with the further treatment required to render this water
usable as process water far outweighs the savings realized in reduced
sewer costs.
D. Evaporative Cooling - RSC reviewed installing swamp coolers on the
plant roof to cool the production building. The swamp coolers would be a
seasonal item utilizing gray water six (6) months out of the year.
Installing and plumbing swamp coolers would provide use for a minimum
volume of wastewater. This option was not considered to be cost-effective
based on the limited volume of water consumed by these systems.
E. Process and Comfort Heat - RSC reviewed using the wastewater in the
boilers on-site to provide process and comfort heat. The boilers are used
I� _ I

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