WQ0000965_Final Permit_20071105

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen R. Sullins Director
Division of Water Quality
November 5, 2007
Ernest Holley
Oracle Flexible Packaging, Inc.
220 East Polo Road
Winston-Salem, NC 27105
Subject- Permit Number WQ0000965
Oracle FIexible Packaging, Inc./Plant 200
Groundwater Remediation Facility
Forsyth County
Dear Mr. Holley:
In accordance with your request for renewal received October 12, 2006, we are forwarding herewith Permit No,
WQ0000965, dated November 5, 2007, to Oracle Flexible Packaging, Inc./Plant 200 for the continued operation of the
subject groundwater rernediation facility.
This permit shall be effective from the date of issuance until October 31, 2012, shall void Permit No. WQ0000965
issued June 13, 2005, and shall be subject to the conditions and limitations as specified therein. Please pay particular
attention to the monitoring requirements in this permit, Failure to establish an adequate system for collecting and
-maintaining the required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request
an adjudicatory hearing upon written request within thirty (30) days following receipt of this permit. This request must be
in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with th4e
Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made
this permit shall be final and binding,
If you need any additional information concerning this matter, please contact Peter Pozzo at [phone].
Sincerely,
4,,.j,L"JA-:;'
n H- SulIins
cc: Forsyth County Health Department
Winston-Salem Regional Office, Aquifer Protection Section
David Yount, Oracle Flexible Packaging, Inc.
Technical Assistance and Certification Unit
APS -- Central Files
APS Files
One
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone: [phone]
Internet: www,nowaterguality.org Location: 2728 Capital Boulevard Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
Are Equal QpportunilylAHirmative Action Employer— 50% Recycled170% Post Consumer Paper Customer Service: [phone]

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
GROUNDWATER REMEDIATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended,
and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Oracle Flexible Packaging, Inc.IPlant 200
Forsyth County
FOR THE
continued operation of a 10,000 GPD groundwater remediation facility consisting of thirteen (13) recovery wells
(plus the continued operation of two (2) existing recovery wells) of which five (5) will be vacuum enhanced
including a blower; a 1,200 gallon biocide tank chamber with hydrogen peroxide feed; a 270 gallon oil/water
separator; a 550 gallon pH adjustment and aeration tank with caustic feed; a 1,400 gallon sludge settling tank, two
sets of backwashing filters; a deep bed filtration unit; one filter press; two (2) PetroClean 4000 fixed film
bioreactors with nutrient feed; a 550 gallon effluent aerated dosing tank for the injection wells; a 2,100 gallon
effluent aerated dosing tank for the infiltration galleries; four (4) 1,200 f12 infiltration galleries; and four (4) 0.25
GPM injection wells to serve Oracle Flexible Packaging, Inc.— Plant 200 located on Cunningham Avenue, with no
discharge of wastes to the surface waters, pursuant to the application received August 27, 2003, and subsequent
additional information received by the Division of Water Quality (Division), and in conformity with the project
plan, specifications, and other supporting data subsequently filed and approved by the Division and considered a
part of this permit.
This permit shall be effective from the date of issuance until October 31, 2012, shall void Permit No.
WQ0000965 issued June, 13, 2005, and shall be subject to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
The groundwater treatment system shall consistently achieve at least 95% removal of the influent
contaminants or 15A NCAC 2L Section .0202(g) Class GA Standards (whichever is higher) prior to
discharge to the infiltration gallery. The treated water discharged into the infiltration gallery must not
cause a violation of Class GA Standards for any constituent beyond the Compliance Boundary, nor cause
the migration of the contamination into unaffected areas. If the treatment system fails to consistently
achieve this standard, additional treatment units or changes in operational needs may be required.
2. This permit shall become voidable if the soils fail to adequately assimilate the remaining wastes and may
be rescinded unless the facilities are installed, maintained, and operated in a manner, which will protect
the assigned water quality standards of the surface and groundwaters.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface or
groundwaters resulting from the operation of this facility.
WQ0000965 Page 1 of 10

4. Any residuals generated from these treatment facilities must be disposed in accordance with General
Statute 143-215.1 and in a manner approved by the Division.
5. Diversion or bypassing of the untreated groundwater from the treatment facilities is prohibited.
H. OPERATION ,AND MAINTENANCE RE LT REMENTS
The facilities shall be properly maintained and operated as a non -discharge system to prevent the
discharge of any wastewater resulting from the operation of this facility. The groundwater recovery,
treatment and disposal system shall be inspected weekly. If it is determined that the system is
malfunctioning or leading to the release of wastes to the environment, a threat to human health, or a
nuisance, all repairs should be made as soon as possible and reported to the Winston-Salem Regional
Office at [phone](see Section V. NONCOMPLIANCE NOTIFICATION). All components of
the groundwater recovery, treatment, and disposal system shall be properly weatherproofed to prevent
freezing and failure of the system.
The Water Pollution Control System Operators Certification Commission (WPCSOCC) has classified
these wastewater treatment and remediation facilities as Grade I Physical Chemical Pollution Control
Treatment System., the Permittee shall designate and employ a certified operator to be in responsible
charge (ORQ and one or more certified operator(s) to be back-up ORC(s) of the facilities in accordance
with 15A NCAC 8G .0201. The ORC shall visit the facilities in accordance with 15A NCAC 8G .0204 or
as specified in this permit and shall comply with all other conditions specified in these rules.
I The infiltration gallery shall be operated above the water table at all times.
4. If requested by the owner, the Division will consider remote monitoring in lieu of (frequency) physical
inspections, on a case -by -case basis, following at least two years of successful operation.
5. The Permittee shall maintain an inspection log or summary including at least the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken by the Permittee.
This log of inspections shall be maintained by the Permittee for a period of three years from the date of
the inspection and shall be made available to the Division or other permitting authority, upon request.
Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the disposal site or facility at
any reasonable time for the purpose of determining compliance with this permit, may inspect or copy any
records that must be maintained under the terms and conditions of this permit, and may obtain samples of
groundwater, surface water, or leachate.
III. MONITORING REQUIREMENTS
1. The influent and effluent from the treatment system shall be sampled every (February, May, August and
November) for the parameters specified below:
Total Phosphorous (effluent only)
Nitrate Nitrogen (NO3-N)
EPA Method 624 Modified: Analysis for Acetone, MEK, Isopropyl Acetate, normal Propyl
Acetate, Toluene, and Heptane.
EPA Method 8015: Analysis for Isopropanol and normal Propanol.
2. Monitor wells (MW-1, MW-2, MW-6, MW-8, MW-16, MW-17, MW-19, and MW-21 S) shall be
sampled every (May and November) for the parameters listed below:
WQ0000965 Page 2 of 5

IR
PH Water Level Total Phosphorous
Total Ammonia Nitrate Nitrogen (NO3-N)
EPA Method 624 Modified: Analysis for Acetone. MEK, Isopropyl Acetate, normal Propyl
Acetate, Toluene, and Heptane.
EPA Method 8015: Analysis for Isopropanol and normal Propanol.
3. Prior to sampling the parameters, the measurement of water levels must be taken. The depth to water in
each well shall be measured from the surveyed point on the top of the casing. The measuring points (top
of well casing) of all monitoring wells shall be surveyed relative to a common datum.
4. Any laboratory selected to analyze parameters must be Division of Water Quality certified for those
parameters required.
5. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
REPORTING REQUIREMENTS
1. Two (2) copies of the following forms shall be mailed to the address below:
a. GW-59 Groundwater Quality Monitoring: Compliance Report Form
b. GW-59A Compliance Report Form
Mail these documents to the following address: Division of Water Quality
1617 Mail Service Center
Information Processing Unit
Raleigh, NC 27699-1617
Updated blank forms (GW-59, GW-59A) may be downloaded from the Division of Water Quality
website at http://h2o.enr:state.nc.us/ or requested from the address mentioned above.
2. The results of the sampling and analysis must be received on forms GW-59 and GW-59A on or before the
last working day of the month following the sampling month. The data of all groundwater sampling
analyses required by the permit conditions must be reported using the most recent GW-59 and GW-59A
forms along with attached copies of the laboratory analyses.
3. The permittee shall retain records of all monitoring information, including calibration and maintenance
records, continuous monitoring data and reports required by this permit, for at least 3 years from the date
of the sample measurement, report or application. Records of this monitoring information shall include,
but not be limited to, the following:
a. the date, exact place, and time of sampling or measurements,
b. the individual who performed the sampling or measurements,
c. the date the analyses were performed,
d. the analytical techniques or methods used, and
e. the results of such sampling, measurements, and analyses.
The permittee shall report to the Winston-Salem Regional Office (see Section V. NONCOMPLIANCE
NOTIFICATION) any monitoring or other information which indicates:
a. any contaminant may cause an endangerment to an underground source of drinking water,
b. any noncompliance with a permit condition due to a malfunction of the system, or
c. any cause of fluid migration outside the injection zone or area.
WQ0000965 Page 3 of 5

The written submission shall contain a description of the noncompliance and its cause, the period of
noncompliance, including exact dates and times, If the noncompliance is not corrected and is expected to
continue, steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance
shall be provided to the Regional Office in a timely manner.
5. The permittee shall submit an annual report summarizing the volume of effluent discharged into
the infiltration gallery and the summary results of related groundwater, influent, and effluent
monitoring. Iso concentrations (horizontal and vertical direction) and water level contour snaps
shall be prepared on an annual basis and submitted with this report. If an annual report
containing this information (e.g. corrective action plan) is required by a regulatory agency, the
permittee may submit two (2) copies of that report in lieu of the preceding information within
thirty days of its publication. The permittee shall submit this report to the following address:
Aquifer Protection Section,
Groundwater Protection Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
V. NONCOMPLL4NCE NOTIFICATION
The Perrmittee shall report by telephone to the Winston-Salem. Regional Office, telephone number (336)
771-5000, as soon as possible, but in no case more than 24 hours or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the groundwater remediation facility which results in the treatment of significant
amounts of contaminated groundwaters which are abnormal in quantity or characteristic, such as the
dumping of the contents of a basin or tank, the known passage of a slug of hazardous substance
through the facility, or any other unusual circumstances;
b. Any process unit failure, due to known or unknown reasons; that renders the groundwater treatment
and disposal system incapable of adequate treatment and disposal, such as mechanical or electrical
failures of pumps, aerators, compressors, etc.;
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion of the influent to such station or facility; or
d. Any time that self -monitoring information indicates that the groundwater treatment and disposal
system is not in compliance with any specified permit limitations.
2. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at telephone number [phone] or to the Emergency Management's switchboard at (919)
733-3300. Also, persons reporting such occurrences by telephone shall file a written report within five
(5) days following first knowledge of the occurrence. This report must outline the actions taken or
proposed to be taken to ensure that the problem does not recur.
VI. APPLICABLE BOUNDARIES
1. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC 2L,
Groundwater Classifications and Standards. The Compliance Boundary for the disposal system
individually permitted on or after December 30, 1983 is established at either (1) 250 feet from the waste
disposal area, or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area.
An exceedance of Class GA Standards at or beyond the Compliance Boundary is subject to remediation
action according to 15A NCAC 2L .0106(d)(2).
2. The REVIEW BOUNDARY is established around the disposal systems midway between the Compliance
Boundary and the perimeter of the waste disposal area. Any exceedance of Class GA Standards at the
Review Boundary may require action in accordance with 15A NCAC 2L A106(d)(1).
WQ0000965 Page 4 of 5

VH- GENERAL CONDITIONS
Issuance of this permit does not constitute approval for reimbursement from the Leaking Petroleum
Underground Storage Tank Cleanup Fund (I5A NCAC 2P) or any other fund. Additionally, the issuance
of this permit does not remove the permittee's responsibility to comply with the corrective action
requirements of the Division of Waste Management. Furthermore, the permitter should notify and report
all changes concerning the remedial system to the Division of Waste Management. It is the permittee's
responsibility to comply with the requirements of all involved agencies.
2. This permit shall become voidable unless the facilities are constructed in accordance with the conditions
of this permit, the approved plans and specifications, and other supporting data.
3. This permit is effective only with respect to the nature and volume of wastes described in the application
and other supporting data.
4. This permit is not transferable. In the event there is a desire for the facilities to change ownership, or
there is a name change of the Permittee, a formal permit request must be submitted to the Division
accompanied by an application fee, documentation from the parties involved, and other supporting
materials as may be appropriate. The approval of this request will be considered on its merits and may or
may not be approved.
5. A set of approved plans and specifications for the subject project must be retained by the Permitter for the
life of this project.
6. Failure to abide by the conditions and limitations contained in this permit may subject the Permitter to an
enforcement action by the Division in accordance with North Carolina General Statute 143-215.6A to
143-215.6C.
7. The annual administering and compliance fee must be paid by the Permittee within thirty (30) days after
being billed by the Division. Failure to pay tiie fee accordingly may cause the Division to initiate action
to revoke this permit as specified by 15A NCAC 2T .0105 (e)(3).
The issuance of this permit does not preclude the Permitter from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other government agencies (local, state, and
federal), which have jurisdiction.
9. Sixty (60) days prior to closure of the infiltration gallery, the permitter must request a rescission of the
permit from the Division of Water Quality. Guidelines for the closure of the infiltration gallery may be
obtained from http://h2o.em.state.nc.us or requested from the Division of Water Quality.
10. If the permitter wants to continue operation of this system, at least six (6) months prior to the expiration
of this permit, the permitter, shall request its extension. Upon receipt of the request, the Commission will
review the adequacy of the facilities described therein, and if warranted, will extend the permit for such
period of time and under such conditions and limitations as it may deem appropriate.
Permit issued this the fifth day of November 2007
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
a), ' �, UZ-4
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0000965
WQ0000965 Page 5 of 5