R:\WP_FILES\ \CORRESPONDENCE\L-B SADLER \DRAFT L-B SADLER 20I DOCX ~

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1 - water resources I environmental consultants 31nnwood Circle. Suite 220 Little Rock, AR (501) Fax (501) Mr. Bill Sadler, PG Geology Supervisor Solid Waste Management Division Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR December 22, 2015 AFIN:~/r; PMlW:~IY-lfFDSCAN DEC ~~S\WD RE: Submittal of Second Half 2015 Semiannual Groundwater Monitoring Report Evergreen Packaging, Pine Bluff Mill Class 3N Landfill Permit No S3N-Rl AFIN: FTN No Dear Mr. Sadler: On behalf of Evergreen Packaging, Inc., FTN Associates, Ltd. is pleased to submit the Second Half 2015 Semiannual Groundwater Monitoring Report for the Pine Bluff Mill Class 3N Landfill. As you have requested~ we are submitting the entire report on a CD in Adobe PDF format. If you have any questions regarding the submittal of this report, please do not hesitate to contact me at (501) or Paul Crawford, PE, PG, at (501) Respectfully submitted, FTN ASSOCIATES, LTD. ~~ Dana Derrington, PE, PG Project Manager DLD/dlc Enclosure cc: Ms. Stanza Donald; Evergreen Packaging, Inc. (with enclosure) R:\WP_FILES\ \CORRESPONDENCE\L-B SADLER \DRAFT L-B SADLER 20I DOCX ~ Corporate Office: 3 lnnwood Circle, Suite 220 Little Rock, AR (501) Fax (501) Regional Offices: Fayetteville, AR; Baton Rouge, LA; Jackson, MS ftn@ftn-assoc.. com

2 SECOND HALF 2015 SEMIANNUAL GROUNDWATER MONITORING REPORT EVERGREEN PACKAGING, INC. PINE BLUFF MILL CLASS 3N LANDFILL PINE BLUFF, ARKANSAS PERMIT NO S3N-R1 AFIN: DECEMBER 22, 2015

3 SECOND HALF 2015 SEMIANNUAL GROUNDWATER MONITORING REPORT EVERGREEN PACKAGING, INC. PINE BLUFF MILL CLASS 3N LANDFILL PINE BLUFF, ARKANSAS PERMIT NO S3N-R1 AFIN: Prepared for Evergreen Packaging Pine Bluff Mill 5201 Fairfield Road Pine Bluff, AR Prepared by FTN Associates, Ltd. 3 Innwood Circle, Suite 220 Little Rock, AR FTN No. R December 22, 2015

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5 December 22, 2015 TABLE OF CONTENTS PROFESSIONAL GEOLOGIST S CERTIFICATION... i 1.0 INTRODUCTION GROUNDWATER MONITORING PROGRAM Current Monitoring Network Sampling Methodology Laboratory Analyses WATER LEVEL DATA Water Level Measurements and Groundwater Flow Direction Hydraulic Gradient and Rate of Groundwater Flow GROUNDWATER QUALITY DATA Review of Field Documentation Quality Control Data Evaluation Summary of Groundwater Quality Results STATISTICAL EVALUATION Statistical Program Design Detection Monitoring Statistics Site-Wide False Positive Rate and Power Statistical Evaluation Outlier Identification Prediction Limits Mann-Kendall Test/Sen s Estimate of Slope CONCLUSIONS AND RECOMMENDATIONS SELECTED REFERENCES ii

6 December 22, 2015 TABLE OF CONTENTS (CONTINUED) LIST OF APPENDICES APPENDIX A: APPENDIX B: APPENDIX C: APPENDIX D: APPENDIX E: APPENDIX F: Field Sampling Forms Laboratory Data Sheets Historical Database Distributional Plots Background Used for Statistics Statistical Evaluation Results iii

7 December 22, 2015 LIST OF TABLES Table 2.1 Monitoring well construction data Table 2.2 Constituents for detection monitoring Table 3.1 Water level data and potentiometric surface elevations, September 15, Table 4.1 Groundwater quality results, second half Table 5.1 Well-parameter pairs analyzed by intrawell prediction limits Table 5.2 Well-parameter pairs analyzed by Sen's Slope/Mann Kendall trend test Table 5.3 Test α and power curve criteria, 2015 semiannual reporting periods LIST OF FIGURES Figure 2.1 Groundwater monitoring network Figure 3.1 Potentiometric surface map, September 15, Figure 5.1 Power curve for the 2015 monitoring periods iv

8 December 22, INTRODUCTION Evergreen Packaging, Inc. (EPI) owns and operates a Class 3N Landfill (the Landfill) at their Pine Bluff Mill located near Pine Bluff, Arkansas, in Jefferson County. The Landfill operates under Permit No S3N-R1, which was issued by the Arkansas Department of Environmental Quality (ADEQ) on July 8, Groundwater detection monitoring is conducted semiannually at the site in accordance with the permit and Arkansas Pollution Control and Ecology Commission Regulation No. 22 requirements. This document presents the results of semiannual detection monitoring during the second half of 2015 and fulfills the requirements of of Regulation No. 22. Section 2.0 describes the facility s current groundwater monitoring network and sampling approach; Section 3.0 presents water level data; Section 4.0 presents groundwater quality data; Section 5.0 presents the statistical analysis of the second half of 2015 data with a discussion of results; Section 6.0 includes conclusions and recommendations for the program; and Section 7.0 provides selected references for the report. 1-1

9 2.0 GROUNDWATER MONITORING PROGRAM December 22, 2015 This section describes the current groundwater detection monitoring program at the Landfill. Included is a discussion of the monitoring well network, sampling methodology, and laboratory analyses. 2.1 Current Monitoring Network The current monitoring well network consists of the three wells shown on Figure 2.1. Water level measurements and groundwater samples are collected at each of the three monitoring wells. Based on the historical groundwater flow direction, MW-1 is an upgradient well, MW-3 is upgradient/sidegradient, and MW-2 is downgradient of the waste mass. According to well installation records, each monitoring well is constructed with a 20-ft screen and has a total depth of 30 ft below ground surface (bgs). Well construction details are summarized in Table 2.1. Table 2.1. Monitoring well construction data. Ground Surface Elevation* (ft, NGVD) Top of Casing (TOC) Elevation* (ft, NGVD) Total Depth (ft bgs) Screen Interval (ft bgs) Well Installation Well No. Date MW-1 1 st Quarter to 30 MW-2 1 st Quarter to 30 MW-3 1 st Quarter to 30 *Survey conducted by Harmon Surveying, Inc., of Conway, Arkansas, in March Sampling Methodology Groundwater sampling is conducted using low flow methods in accordance with United States Environmental Protection Agency (EPA 1996) guidelines. FTN Associates, Ltd. (FTN) of Little Rock, Arkansas, provided sampling services during this monitoring period on September 30, Each well was sampled using a Geopump Peristaltic Series II Pump and linear low-density natural polyethylene tubing. Field parameters were measured during purging and sampling using a HACH 2100P portable turbidity meter and YSI 556 multiparameter instrument and flow through cell. 2-1

10 Figure 2.1. Groundwater monitoring network. 2-2

11 December 22, Laboratory Analyses The current analytical parameter list is shown in Table 2.2. American Interplex Corporation (AIC) of Little Rock, Arkansas, provided laboratory services. Laboratory analyses adhered to methods described in EPA s Test Methods for Evaluating Solid Waste Physical/Chemical Methods SW-846, or equivalent. Table 2.2. Constituents for detection monitoring. *Field parameters Cadmium Chloride Hardness Iron Lead Manganese Zinc Parameters Chemical Oxygen Demand (COD) Total Dissolved Solids (TDS) ph* Conductance* Turbidity* Temperature* 2-3

12 December 22, WATER LEVEL DATA This section presents water level data for the second half 2015 groundwater detection monitoring period and discusses groundwater flow direction and rate of groundwater flow. 3.1 Water Level Measurements and Groundwater Flow Direction Static water levels were measured in the three monitoring wells before purging and sampling activities on September 15, Depths to water were measured to the nearest 0.01 ft from the top of casing and are tabulated in Table 3.1. These measurements were converted to potentiometric surface elevations [feet National Geodetic Vertical Datum of 1929 (ft NGVD)] and contoured to construct the potentiometric surface map shown as Figure 3.1. As shown by the map, groundwater flow is to the southeast, which is consistent with the historical groundwater flow direction. Table 3.1. Water level data and potentiometric surface elevations, September 15, Well No. TOC Elevation (ft NGVD) Depth to Water (ft below TOC) Groundwater Elevation (ft NGVD) MW MW MW

13 Figure 3.1. Potentiometric surface, September 30,

14 December 22, Hydraulic Gradient and Rate of Groundwater Flow The hydraulic gradient across the site from MW-1 to MW-2 during the second half 2015 was calculated at 1.2 x 10-3 ft/ft. The linear groundwater velocity, or rate of flow, was calculated using the following equation: V x = K/n e (dh/dl) Where: V x = linear velocity, K = hydraulic conductivity, n e = effective porosity, and dh/dl = hydraulic gradient. The average hydraulic conductivity (K) of the aquifer beneath the site is estimated to be 400 gpd/ft 2, or 0.02 cm/sec (James L. Grant & Associates, Inc. 1991). An effective porosity (n e ) of 20% is assumed based on lithology and is consistent with previous reports. Using these values, the average linear groundwater velocity is calculated to be 1.2 x 10-4 cm/sec (0.3 ft/day). This flow rate is consistent with previously reported flow rates. 3-3

15 December 22, GROUNDWATER QUALITY DATA This section presents analytical results for detection monitoring during the second half of 2015 and reviews field and laboratory quality assurance (QA) and quality control (QC) measures. Data quality was evaluated by reviewing the chain-of-custody (COC) documents, field documentation, laboratory QC results, and conformance of QC sample results. 4.1 Review of Field Documentation Field sampling forms for the current monitoring period are included in Appendix A. Based on a review of these records, the following observations were made: Criteria for low-flow minimal drawdown purging and sampling were met for all samples collected during the second half 2015 event [i.e., drawdown was less than 0.3 ft during purging and sample collection which conforms with low-flow sampling requirements (EPA 1996)]. Field-measured turbidity was below 10 NTU for all samples, as required by Reg (a). 4.2 Quality Control Data Evaluation The laboratory report provided by AIC detailing the analytical results for second half 2015 monitoring is included in Appendix B. Based on a review of the data quality documentation provided by AIC, the overall quality of the data relative to the contaminants of concern was acceptable and generally met method-specific requirements for precision and accuracy. Field QA/QC included the collection of one field duplicate and one equipment rinsate blank. These samples were collected in conjunction with groundwater sampling activities and were handled in the same manner as groundwater samples with respect to packaging, shipping, sample preservation and COC procedures. The field duplicate, labeled as MW-8, was taken at monitoring well MW-1 during this sampling event. To verify that results for these two samples showed reasonable precision for analyzed parameters, the relative percent difference (RPD) was calculated for detected parameters where the detected level was at least five times the laboratory practical quantitation 4-1

16 December 22, 2015 limit (PQL) and where neither result was qualified or suspected of blank contamination. Calculated RPDs were below the quality control limit of 20% for all results, indicating that sampling methods produced samples with an acceptable level of reproducibility. The equipment rinsate blank was taken to assess the effectiveness of field decontamination procedures. Analytical results for this sample were non-detect for all analyzed parameters. When detections above the PQL occur in a quality control blank, groundwater data for the detected parameter(s) are flagged with a B in the historical database. EPA guidance recommends that detections in quality control blanks not be used to correct groundwater data. 4.3 Summary of Groundwater Quality Results Laboratory results detected above the PQL in groundwater samples from the second half 2015 monitoring period and field-measured ph and turbidity are summarized in Table 4.1. Water quality standards promulgated by EPA are included for comparison purposes, where applicable, on Table 4.1. Summarized below are well-parameter pairs that exceeded water quality standards during the current monitoring period: Iron exceeded the secondary drinking water standard (SDWS) of 0.3 mg/l at MW-2 and MW-3; Manganese exceeded the SDWS of 0.05 mg/l at MW-2 and MW-3; TDS exceeded the SDWS of 500 mg/l at MW-2; and The lower SDWS limit of 6.5 su for ph was exceeded at MW-1 and MW-3. The exceedances of SDWSs during the current monitoring period are consistent with historical groundwater quality at this facility. 4-2

17 December 22, 2015 Table 4.1. Groundwater quality results, second half of Hardness as CaCO3 () Parameter/ Chloride Iron Manganese TDS Zinc ph Well ID (mg/l) () () () () (su) MW MW MW MW < MW-9 <0.2 <0.02 <1 <0.002 <10 < EPA Standard 250 * 0.3 * * 500 * 5 * * --- Notes: Bold values exceeded the applicable EPA standards. MW-8 is a duplicate sample of MW-1. MW-9 is an equipment rinsate blank. * Secondary Drinking Water Standard (SDWS). Turbidity (NTU) 4-3

18 5.0 STATISTICAL EVALUATION December 22, 2015 This section describes the statistical approach and the statistical analyses of the analytical data for the second half 2015 monitoring. 5.1 Statistical Program Design This section outlines the statistical program design which adheres to recommendations in EPA's Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities Unified Guidance (Unified Guidance), released in March Detection Monitoring Statistics Intrawell statistical comparisons are used at this facility because spatial variability in groundwater quality had previously been identified (James L. Grant & Associates, Inc. 1991). Detected well-parameter pairs are tested for compliance using either prediction limits or formal trend tests. As recommended by the Unified Guidance, prediction limits are run only on well-parameter combinations where the background population is free of significant increasing or decreasing trends. If trends are detected in the background, the assumption of a steady state condition in background (required by the test) is not met and can lead to prediction limits being biased on the high side, resulting in a less powerful test. Under these circumstances, a formal trend test is recommended by the Unified Guidance in lieu of a prediction limit test. If a statistically significant increasing trend is indicated by a formal trend test, it would indicate deteriorating groundwater quality, as evidenced by rising concentration levels (EPA Unified Guidance; communication from Dr. Kirk Cameron, Statistical Scientist MacStat Consulting, Ltd.; and Kristina Rayner, Sanitas Technologies, April 5, 2011). Table 5.1 identifies well-parameter pairs that have background populations free of significant trends and are tested for compliance using prediction limits. Well-parameter pairs that have either significantly increasing or decreasing trends in background are summarized in Table 5.2 and are tested for compliance using a formal trend test. If a well-parameter pair has two consecutive statistically significant increases (SSIs) (or a statistically significant decrease [SSD] in the case of ph) from a 5-1

19 December 22, 2015 prediction limit test or formal trend test, then the data will be further examined by a qualified groundwater scientist. If a confirmed 1 SSI is declared, the facility will initiate the procedures required by (c) of Regulation No. 22. However, some flexibility is necessary in evaluating confirmed SSIs, primarily when there is uncertainty that the SSIs are the result of landfilling activities. Table 5.1. Well-parameter pairs analyzed by intrawell prediction limits. Parameter Cadmium Chloride Hardness as CaCO 3 Iron Manganese ph Total Dissolved Solids Well MW-1, MW-2, MW-3 MW-1, MW-2 MW-1, MW-2 MW-1 MW-2 MW-1, MW-2, MW-3 MW-1, MW-2 Table 5.2. Well-parameter pairs analyzed by Sen's Slope/Mann Kendall trend test. Parameter Chloride COD Hardness as CaCO 3 Iron Lead Manganese Total Dissolved Solids Zinc Well MW-3 MW-1, MW-2, MW-3 MW-3 MW-2, MW-3 MW-1, MW-2, MW-3 MW-1, MW-3 MW-3 MW-1, MW-2, MW-3 1 An SSI is considered "confirmed" if a statistical test (prediction limit or trend test) indicates an SSI for a well-parameter pair for two consecutive monitoring events (personal communication, Kristina Rayner, Sanitas Technologies, April 12, 2011). 5-2

20 December 22, Site-Wide False Positive Rate and Power The Unified Guidance recommends that detection monitoring programs have adequate statistical power and a site-wide false positive rate (SWFPR) value of 10% over a year period of testing. Intrawell prediction limits were applied where applicable and input criteria for test alpha (α) calculations are included in Table 5.3. Using Unified Guidance standards, the yearly SWFPR is fixed at 10% and, therefore, the per evaluation SWFPR is fixed at 0.05 (5%) for semiannual statistical evaluations. The magnitude of the per test alpha varies, depending on how many statistical tests are required. To gauge statistical power, the Unified Guidance recommends the use of EPA reference power curves to estimate the cumulative, annual ability of any individual test to identify real increases in concentration levels above background. Over the course of a single year, assuming normally distributed background data, any single test performed at the site should have the ability to detect three and four standard deviation increases above background at specific power levels at least as high as the reference curves. Input criteria used to construct the power curve for the 2015 statistical program are included in Table 5.3. Figure 5.1 depicts the facility's power curve plotted against the EPA reference power curve (ERPC). The facility's power curve crosses the ERPC at <2σ, which is an indicator of very good statistical power. The power curve indicates that any single test will detect exceedances above background approximately 95% of the time at 3σ and approximately 100% of the time at 4σ, exceeding EPA targets for detection. Table 5.3. Test α and power curve criteria, 2015 semiannual reporting periods. Criteria for Test α and Power Curve Generation Statistical Test Intrawell Prediction Limit Number of Downgradient Monitoring Wells 2 Background Sample Size (n) 34 Number of Parameters 7* Re-sample Strategy 1 of 2 Per-Evaluation Site-Wide False Positive Rate 0.05 *Includes only parameters that are expected to be detected in groundwater samples based on historical evidence. 5-3

21 December 22, 2015 Figure 5.1. Power curve for the 2015 monitoring periods. 5.2 Statistical Evaluation Detected constituents during the second half of 2015 were evaluated using the Sanitas TM software program. No statistical evaluations were conducted for non-detect results or those detected below the practical quantitation limit (PQL), per (h) (5) of Regulation No. 22. Distributional analyses including time-series plots, box and whiskers diagrams, and outlier tests were applied to period of record data on currently detected parameters to identify apparent trends or excursions from normal ranges. Results from these analyses are included in Appendix D, and outliers identified in the current dataset are summarized in Section A summary of the datasets used for statistical analyses are included in Appendix E. Statistical plots for prediction limit and trend analyses are included in Appendix F. 5-4

22 December 22, Outlier Identification Data were screened for outliers using Dixon's, Rosner's, or Tukey's outlier tests. None of these tests indicated statistical outliers in the second half 2015 dataset Prediction Limits Detected data for well-parameter combinations identified in Table 5.1 were tested using intrawell prediction limits to determine if the second half of 2015 data were representative of background data. Statistical analyses are included in Appendix F. Results indicated three SSIs at MW-2 for chloride (91 mg/l), hardness as CaCO3 (510 mg/l), and TDS (780 mg/l). At this time, these SSIs are considered unconfirmed and will be re-evaluated based on sampling results from the next monitoring period. However, the levels which triggered the SSIs at downgradient MW-2 are well within levels detected at upgradient/sidegradient well MW-3. For example, MW-3 had measured levels for chloride and hardness as CaCO3 of 100 mg/l and 520 mg/l, respectively, in July Similarly, MW-3 had a measured TDS level of 868 mg/l in June Mann-Kendall Test/Sen s Estimate of Slope The Sen's Slope/Mann Kendall trend analysis test for temporal trends was applied to detected well-parameter pairs where significant trends in background were identified (Table 5.2). Period of record data for each well-parameter combination were analyzed and test plots are included in Appendix F. Results from the trend analyses indicated a statistically significant increasing trend in the manganese data at upgradient MW-1. This well-parameter has been previously indicated as an SSI and is therefore considered a "confirmed" SSI. However, this trend is indicated for data from an upgradient well located approximately 2,100 ft from the waste mass. In consideration of the distance between the well and the disposal area, the trend is considered the result of offsite influences or natural variation in groundwater quality. 5-5

23 6.0 CONCLUSIONS AND RECOMMENDATIONS December 22, 2015 The following conclusions and recommendations are based on a review of data for the Landfill from the current monitoring period: 1. Based on water level measurements taken during the second half 2015, groundwater flow across the landfill is to the southeast, consistent with the historical groundwater flow direction. 2. Prediction limit analyses indicated three SSIs at MW-2 for chloride, hardness as CaCO3, and TDS. The levels that trigged these SSIs are within levels previously measured at upgradient/sidegradient MW-3. These SSIs are considered unconfirmed at this time and will be re-evaluated based on results from the next monitoring period. 3. Trend analyses indicated a statistically significant increasing trend in the manganese data at upgradient well MW-1. While this trend is considered a confirmed SSI, the well is located approximately 2,100 ft upgradient of the waste mass. As such, this trend is considered to be the result of offsite influences or natural variations in groundwater quality. 4. Exceedances of SDWSs for iron, manganese, TDS, and ph detected at upgradient and downgradient wells are consistent with historical data collected at the site. 5. Results of the second half 2015 sampling event are generally consistent with historical data observed at the facility. 6-1

24 December 22, SELECTED REFERENCES EPA Low-Flow (Minimal Drawdown) Ground-Water Sampling Procedures. Office of Solid Waste and Emergency Response, April EPA Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities, Unified Guidance (EPA 530-R ). Office of Resource Conservation and Recovery, Program Implementation and Information Division, U.S. Environmental Protection Agency, Washington, D.C., March FTN Associates, Ltd First half 2006 Semi-annual Groundwater Monitoring Report. Pine Bluff Mill Class 3N Landfill. Prepared for International Paper Company. GEC Second half 2005 Groundwater Monitoring Report, International Paper Company Pine Bluff Mill, Pine Bluff, Arkansas. Gibbons, Robert D Statistical Methods for Groundwater Monitoring. John Wiley & Sons, Inc., New York. Intelligent Decision Technologies, Inc., an NIC Company Sanitas TM for Groundwater Version 8 User s Guide. Intelligent Decision Technologies, Inc., an NIC Company. Longmont, Colorado. James L. Grant & Associates, Inc Background Hydrogeological Report, New Solid Waste Landfill, International Paper Mill, Pine Bluff, Arkansas. Rayner, Kristina L. communication. April 5, (As an NIC Environmental Division Project Manager, Rayner directs development and testing of Sanitas TM groundwater statistical software.) Rayner, Kristina L. communication. April 12, (As an NIC Environmental Division Project Manager, Rayner directs development and testing of Sanitas TM groundwater statistical software.) 7-1

25 APPENDIX A Field Sampling Forms

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32 APPENDIX B Laboratory Data Sheets

33 October 8, 2015 Control No Page 1 of 8 Evergreen Packaging Inc. ATTN: Ms. Kelly Bryant 5201 Fairfield Road Pine Bluff, AR This report contains the analytical results and supporting information for samples submitted on September 30, Attached please find a copy of the Chain of Custody and/or other documents received. Note that any remaining sample will be discarded two weeks from the original report date unless other arrangements are made. This report is intended for the sole use of the client listed above. Assessment of the data requires access to the entire document. This report has been reviewed by the Laboratory Director or a qualified designee. John Overbey Laboratory Director This document has been distributed to the following: PDF cc: FTN Associates, Ltd. ATTN: Ms. Dana Derrington dld@ftn-assoc.com Evergreen Packaging Inc. ATTN: Ms. Kelly Bryant kelly.bryant@everpack.com Arkansas Department of Environmental Quality ATTN: Ms. Barbara Mathews mathews@adeq.state.ar.us 8600 Kanis Road Little Rock, AR Phone FAX

34 October 8, 2015 Control No Page 2 of 8 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR SAMPLE INFORMATION Project Description: Six (6) water sample(s) received on September 30, 2015 Evergreen Packaging LF Permit No S3N-R1, AFIN: R P.O. No. S line 002 Receipt Details: A Chain of Custody was provided. The samples were delivered in one (1) ice chest. Each sample container was checked for proper labeling, including date and time sampled. Sample containers were reviewed for proper type, adequate volume, integrity, temperature, preservation, and holding times. Any exceptions are noted below: Sample Identification: Laboratory ID Client Sample ID Sampled Date/Time Notes MW-1 30-Sep MW-2 30-Sep MW-3 30-Sep MW-8 30-Sep MW-9 30-Sep Leachate 30-Sep Notes: 1. Sample was received unpreserved Qualifiers: D Result is from a secondary dilution factor X Spiking level is invalid due to the high concentration of analyte in the spiked sample References: "Methods for Chemical Analysis of Water and Wastes", EPA/600/ (Mar 1983) with updates and supplements EPA/600/ (Jun 1991), EPA/600/R (Aug 1992) and EPA/600/R (Aug 1993). "Test Methods for Evaluating Solid Waste Physical/Chemical Methods (SW846)", Third Edition. "Standard Methods for the Examination of Water and Wastewaters", (SM). "American Society for Testing and Materials" (ASTM). "Association of Analytical Chemists" (AOAC) Kanis Road Little Rock, AR Phone FAX

35 October 8, 2015 Control No Page 3 of 8 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR ANALYTICAL RESULTS AIC No Sample Identification: MW-1 30-Sep Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 05-Oct by 271 Analyzed: 05-Oct by 271 Batch: W53434 Total Dissolved Solids SM 2540 C 1997 Cadmium EPA 3010A, 6020A Iron EPA 3010A, 6020A Lead EPA 3010A, 6020A Manganese EPA 3010A, 6020A Zinc EPA 3010A, 6020A Hardness as CaCO3 SM 2340 B 1997 Chloride EPA 9056A Prep: 06-Oct by 271 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by Analyzed: 07-Oct by 271 Batch: W53455 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 07 Batch: C18128 D Dil: 2 AIC No Sample Identification: MW-2 30-Sep Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 05-Oct by 271 Analyzed: 05-Oct by 271 Batch: W53434 Total Dissolved Solids SM 2540 C 1997 Manganese EPA Cadmium EPA 3010A, 6020A Iron EPA 3010A, 6020A Lead EPA 3010A, 6020A Zinc EPA 3010A, 6020A Hardness as CaCO3 SM 2340 B 1997 Chloride EPA 9056A Prep: 06-Oct by 271 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by Analyzed: 07-Oct by 271 Batch: W Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 07 Batch: C18128 D Dil: 2 D Dil: 2 D Dil: Kanis Road Little Rock, AR Phone FAX

36 October 8, 2015 Control No Page 4 of 8 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR ANALYTICAL RESULTS AIC No Sample Identification: MW-3 30-Sep Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 05-Oct by 271 Analyzed: 05-Oct by 271 Batch: W53434 Total Dissolved Solids SM 2540 C 1997 Manganese EPA Cadmium EPA 3010A, 6020A Iron EPA 3010A, 6020A Lead EPA 3010A, 6020A Zinc EPA 3010A, 6020A Hardness as CaCO3 SM 2340 B 1997 Chloride EPA 9056A Prep: 06-Oct by 271 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by Analyzed: 07-Oct by 271 Batch: W Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 07 Batch: C18128 D Dil: 2 D Dil: 2 AIC No Sample Identification: MW-8 30-Sep Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 05-Oct by 271 Analyzed: 05-Oct by 271 Batch: W53434 Total Dissolved Solids SM 2540 C 1997 Cadmium EPA 3010A, 6020A Iron EPA 3010A, 6020A Lead EPA 3010A, 6020A Manganese EPA 3010A, 6020A Zinc EPA 3010A, 6020A Hardness as CaCO3 SM 2340 B 1997 Chloride EPA 9056A Prep: 06-Oct by 271 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by Analyzed: 07-Oct by 271 Batch: W53455 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 317 Batch: S Analyzed: 01-Oct by 07 Batch: C18128 D Dil: Kanis Road Little Rock, AR Phone FAX

37 October 8, 2015 Control No Page 5 of 8 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR ANALYTICAL RESULTS AIC No Sample Identification: MW-9 30-Sep Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 05-Oct by 271 Analyzed: 05-Oct by 271 Batch: W53434 Total Dissolved Solids SM 2540 C 1997 Cadmium EPA 3010A, 6020A Iron EPA 3010A, 6020A Lead EPA 3010A, 6020A Manganese EPA 3010A, 6020A Zinc EPA 3010A, 6020A Hardness as CaCO3 SM 2340 B 1997 Chloride EPA 9056A Prep: 06-Oct by 271 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 235 Prep: 01-Oct by 07 < Analyzed: 07-Oct by 271 Batch: W53455 < Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 317 Batch: S39847 < 2 2 Analyzed: 01-Oct by 317 Batch: S39847 < Analyzed: 01-Oct by 07 Batch: C18128 D Dil: 2 AIC No Sample Identification: Leachate 30-Sep Analyte Result RL Units Qualifier COD D HACH 8000 Prep: 05-Oct by 271 Analyzed: 05-Oct by 271 Batch: W53434 Dil: 2 Total Dissolved Solids SM 2540 C 1997 Cadmium EPA 3010A, 6020A Iron EPA 3010A, 6020A Lead EPA 3010A, 6020A Manganese EPA 3010A, 6020A Zinc EPA 3010A, 6020A Hardness as CaCO3 SM 2340 B 1997 Chloride EPA 9056A Prep: 06-Oct by 271 Prep: 02-Oct by 235 Prep: 02-Oct by 235 Prep: 02-Oct by 235 Prep: 02-Oct by 235 Prep: 02-Oct by 235 Prep: 02-Oct by 235 Prep: 01-Oct by Analyzed: 07-Oct by 271 Batch: W53455 < Analyzed: 02-Oct by 235 Batch: S Analyzed: 02-Oct by 235 Batch: S39855 < Analyzed: 02-Oct by 235 Batch: S Analyzed: 02-Oct by 235 Batch: S39855 < Analyzed: 02-Oct by 235 Batch: S Analyzed: 02-Oct by 235 Batch: S Analyzed: 01-Oct by 07 Batch: C18128 D Dil: 10 D Dil: 10 D Dil: 10 D Dil: 10 D Dil: 10 D Dil: 10 D Dil: Kanis Road Little Rock, AR Phone FAX

38 October 8, 2015 Control No Page 6 of 8 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR DUPLICATE RESULTS Analyte AIC No. Result RPD RPD Limit Preparation Date Analysis Date Dil Qual Total Dissolved Solids Oct by Oct by 271 Batch: W53455 Duplicate Oct by Oct by 271 Total Dissolved Solids Oct by Oct by 271 Batch: W53455 Duplicate Oct by Oct by 271 LABORATORY CONTROL SAMPLE RESULTS Spike Analyte Amount % Limits RPD Limit Batch Preparation Date Analysis Date COD W Oct by Oct by 271 Cadmium S Oct by Oct by 317 Cadmium S Oct by Oct by 317 Iron S Oct by Oct by 317 Iron S Oct by Oct by 317 Lead S Oct by Oct by 317 Lead S Oct by Oct by 317 Manganese S Oct by Oct by 317 Manganese S Oct by Oct by 317 Zinc S Oct by Oct by 317 Zinc S Oct by Oct by 317 Chloride C Oct by 07 01Oct by 07 Dil Qual 8600 Kanis Road Little Rock, AR Phone FAX

39 October 8, 2015 Control No Page 7 of 8 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR MATRIX SPIKE SAMPLE RESULTS Analyte Sample Spike Amount % Limits Batch Preparation Date COD W Oct by W Oct by 271 Relative Percent Difference: W53434 Analysis Date 05Oct by Oct by 271 Dil Qual Cadmium S39847 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 Cadmium S39855 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 Iron S39847 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 Iron S39855 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 X X Lead S39847 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 Lead S39855 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 Manganese S39847 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 Manganese S39855 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 X X Zinc S39847 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 Zinc S39855 S Oct by Oct by 235 Relative Percent Difference: S Oct by Oct by 317 X X Chloride C18128 C Oct by 07 01Oct by 07 Relative Percent Difference: C Oct by 07 01Oct by Kanis Road Little Rock, AR Phone FAX

40 October 8, 2015 Control No Page 8 of 8 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR LABORATORY BLANK RESULTS Analyte Result RL PQL QC Sample Preparation Date Analysis Date Qual COD < W Oct by Oct by 271 Total Dissolved Solids < W Oct by Oct by 271 Cadmium < S Oct by Oct by 317 Iron < S Oct by Oct by 317 Lead < S Oct by Oct by 317 Manganese < S Oct by Oct by 317 Zinc < S Oct by Oct by 317 Cadmium < S Oct by Oct by 317 Iron < S Oct by Oct by 317 Lead < S Oct by Oct by 317 Manganese < S Oct by Oct by 317 Zinc < S Oct by Oct by 317 Chloride < C Oct by 07 01Oct by Kanis Road Little Rock, AR Phone FAX

41

42 APPENDIX C Historical Database

43 Evergreen Packaging Historical Database Permit No S3N-R1 MW-1 u Chloride (mg/l) COD (mg/l) Turb (NTU) ph (su) Cadmium () 12/9/ n/a n/a n/a n/a <0.03 <1 280 n/a 3/21/ n/a n/a n/a n/a n/a 6/10/ n/a n/a n/a < n/a 0.22 <2 260 n/a 9/9/ n/a n/a n/a <0.05 n/a n/a 12/21/ n/a n/a n/a n/a n/a 6/23/ n/a n/a n/a < n/a 0.57 < n/a 9/5/ n/a n/a < /19/ n/a n/a < < /12/ n/a n/a <1E < /19/ n/a 6.6 < < /12/ n/a /12/ n/a 6.9 < < /12/ <12.5 n/a 6.4 < < /19/ n/a 6.3 < /17/ n/a /25/ <12.5 n/a 6.6 < /23/ (R) n/a 6.6 <0.004 < /25/ <10 n/a 6.5 < < /23/ <10 n/a 6.4 < < /3/ n/a 6.5 < < /9/ <10 n/a 6.4 < /24/ n/a 6.2 < < /7/ n/a < /9/ <10 n/a 6.4 < /18/ n/a 6.7 < < /21/ n/a 6.9 < Iron () Hardness as CaCO3 () Manganese () Lead (ug/l) Total Dissolved Solids () Zinc ()

44 Evergreen Packaging Historical Database Permit No S3N-R1 Chloride (mg/l) COD (mg/l) Turb (NTU) ph (su) Cadmium () MW-1 1/17/ n/a 6.4 < < (cont.) 7/13/ n/a 6.6 < /25/ <10 n/a 6.6 < < /23/ <10 n/a 6.3 < < /30/ <10 n/a 6.6 < /30/ n/a 6.5 < < /6/ <10 n/a 6.4 < /14/ <10 n/a 6.2 < /28/ n/a 6.4 < n/a 7/5/ <10 n/a 6 < < /1/ < < < /8/ < < <1 250 < /13/ < < < /24/ < < /24/ < < /5/ < <1 250 < /10/ < < /29/ < /23/ < < /14/ < < /9/ /19/ < < < /20/ < /21/ < < < /26/ < < <1 440(B) 0.013(B) 9/4/ < < < (B) 4/9/ < (B) (B) < (B) Iron () Hardness as CaCO3 () Manganese () Lead (ug/l) Total Dissolved Solids () Zinc ()

45 Evergreen Packaging Historical Database Permit No S3N-R1 Chloride (mg/l) COD (mg/l) Turb (NTU) ph (su) Cadmium () MW-1 10/16/ < < (cont.) 4/2/ <10 n/a n/a < < /30/ < < < MW-2 d 12/9/ n/a n/a n/a n/a 0.48 <1 504 n/a 3/21/ n/a n/a n/a n/a n/a 6/10/ n/a n/a n/a < n/a 1.44 <2 316 n/a 9/9/ n/a n/a n/a n/a 1.18 <2 560 n/a 9/30/ n/a n/a n/a <0.05 n/a 1.15 <1 16 n/a 6/23/ n/a n/a n/a < n/a 3.56 < n/a 9/5/ n/a n/a < /19/ n/a n/a < < /12/ n/a n/a <1E < /19/ n/a 6.5 < < <0.01 1/12/ (R) n/a /12/ n/a 6.7 < < /12/ n/a 6.4 < < /19/ n/a 6.7 < /17/ n/a /25/ n/a 6.8 < /23/ n/a < /25/ <10 n/a 6.8 < < /23/ n/a 6.1 < < /3/ n/a 6.5 < < /9/ n/a 6.5 < /24/ n/a 6.4 < < /7/ n/a 5.9 < < Iron () Hardness as CaCO3 () Manganese () Lead (ug/l) Total Dissolved Solids () Zinc ()

46 Evergreen Packaging Historical Database Permit No S3N-R1 Chloride (mg/l) COD (mg/l) Turb (NTU) ph (su) Cadmium () MW-2 7/9/ n/a (cont.) 1/18/ n/a 6.7 < < /21/ n/a 6.9 < /17/ n/a 6.5 < /13/ n/a 7 < /25/ n/a 6.7 < /23/ n/a 6.7 < /30/ <10 n/a 7 < < /30/ n/a 6.8 < < /6/ n/a 7 < < /14/ n/a 6.4 < /28/ n/a 6.5 < n/a 7/5/ n/a 6.6 < < /1/ < < < /8/ < < < /27/ n/a n/a n/a n/a 670 n/a 3/13/ < < /24/ < < /24/ < < /5/ < <1 110 < /10/ < < < /29/ < < /23/ < < /14/ < < < /9/ /19/ < < /20/ < < Iron () Hardness as CaCO3 () Manganese () Lead (ug/l) Total Dissolved Solids () Zinc ()

47 Evergreen Packaging Historical Database Permit No S3N-R1 Chloride (mg/l) COD (mg/l) Turb (NTU) ph (su) Cadmium () MW-2 8/21/ < < < (cont.) 3/26/ < < <1 290(B) (B) 9/4/ < < < (B) 4/9/ < < (B) (B) < (B) 10/16/ < < /2/ <10 n/a n/a < < /30/ < < < MW-3 d 12/9/ n/a n/a n/a n/a 0.79 <1 508 n/a 3/21/ n/a n/a n/a n/a 1.23 <1 522 n/a 6/10/ n/a n/a n/a < n/a 1.28 <2 492 n/a 9/9/ n/a n/a n/a < <0.05(R) n/a n/a 9/30/ n/a n/a n/a n/a 1.78 <1 380 n/a 6/23/ n/a n/a n/a < n/a 5.01(R) < n/a 9/5/ n/a n/a < /19/ n/a n/a < /12/ n/a n/a <1E < /19/ n/a 6.6 < < /12/ (R) n/a 9.5(R) /12/ n/a 7.7(R) < < /12/ n/a 6.5 < < /19/ n/a 6.6 < /17/ n/a /25/ n/a /23/ n/a /25/ <10 n/a 6.7 < < /23/ <10 n/a 6.4 < < Iron () Hardness as CaCO3 () Manganese () Lead (ug/l) Total Dissolved Solids () Zinc ()

48 Evergreen Packaging Historical Database Permit No S3N-R1 Chloride (mg/l) COD (mg/l) Turb (NTU) ph (su) Cadmium () MW-3 7/3/ n/a 6.5 < < (cont.) 1/9/ n/a 6.5 < /24/ n/a 6.4 < /7/ n/a 6.2 < /9/ n/a 6.6 < /18/ n/a 6.6 < /21/ n/a 7.3 < /17/ n/a 6.4 < /13/ n/a 6.9 < /25/ n/a 7.1 < < /23/ n/a 6.6 < /30/ <10 n/a 6.8 < /30/ n/a 6.7 < /6/ n/a 6.8 < /14/ <10 n/a 6.3 < /28/ n/a 6.5 < n/a 7/5/ n/a 6.5 < /1/ < < < /8/ < < < /13/ < < /24/ < < /24/ < < /5/ < < < /10/ < < < /29/ < /23/ < < < /14/ < < < Iron () Hardness as CaCO3 () Manganese () Lead (ug/l) Total Dissolved Solids () Zinc ()