3 lnnwood Circle, Suite 220 Little Rock, AR (5Q.1J_2_2_,5_:! :_:_~~~:~~-~~8~- AFIN:35-000/ fo PM'TIJ: I 7-52 N'f<l RECD SCAN

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1 ~ ~< Cb< ffi#( ffj ~AY water resources I environmental consultants 3 lnnwood Circle, Suite 220 Little Rock, AR (5Q.1J_2_2_,5_:! :_:_~~~:~~-~~8~- Mr. Bill Sadler, PG Geology Supervisor Solid Waste Management Division Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR AFIN:35-000/ fo PM'TIJ: I 7-52 N'f<l RECD SCAN MAY May 21,2015 RE: Submittal of First Half 2015 Semiannual Groundwater Monitoring Report Evergreen Packaging, Pine Bluff Mill Class 3N Landfill Permit No S3N-R1 AFIN: FTN No Dear Mr. Sadler: On behalf of Evergreen Packaging, Inc., FTN Associates, Ltd. is pleased to submit the First 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. DLD/tas Enclosure cc: Ms. Kelly Bryant; Evergreen Packaging, Inc. (with enclosure) R:\ WP JILES\ \CORRESPONDENCE\L-B SADLER \L-B SADLER DOCX ~ \ Regional Offices: Fayetteville, AR; Baton Rouge, LA; and Jackson, MS ftn@ftn-assoc.com

2 FIRST HALF 2015 SEMIANNUAL GROUNDWATER MONITORING REPORT EVERGREEN PACKAGING, INC. PINE BLUFF MILL CLASS 3N LANDFILL PINE BLUFF, ARKANSAS PERMIT NO S3N-R1 AFIN: MAY 21, 2015

3 FIRST 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 May 21, 2015

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5 May 21, 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 May 21, 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 May 21, 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, April 2, Table 4.1 Groundwater quality results, first 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, April 2, Figure 5.1 Power curve for the 2015 monitoring periods iv

8 May 21, 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 first 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 discusses the statistical approach and analyses of the first 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 May 21, GROUNDWATER MONITORING PROGRAM 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 on a semiannual basis 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 reporting period. 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 fitted with a flow through cell. 2-1

10 Figure 2.1. Groundwater monitoring network. 2-2

11 May 21, 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 May 21, WATER LEVEL DATA This section presents water level data for the first half 2015 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 sampling on April 2, 2015, to determine the level to maintain during purging, to contour the potentiometric surface and to determine the hydraulic gradient. 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, April 2, 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, April 2,

14 May 21, Hydraulic Gradient and Rate of Groundwater Flow The hydraulic gradient across the site from MW-1 to MW-2 during the first half 2015 was calculated at 1.2 x 10-3 ft/ft. The average hydraulic conductivity 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). The rate of groundwater flow was calculated using the measured gradient, an average hydraulic conductivity of 0.02 cm/sec, and an effective porosity of 20% (assumed based on lithology and consistent with previous reports). These values were applied to 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. Average linear groundwater velocity is estimated at 1.2 x 10-4 cm/sec (0.3 ft/day), which is generally consistent with previously reported values. 3-3

15 May 21, GROUNDWATER QUALITY DATA This section presents analytical results for detection monitoring during the first 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 first 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 first 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 May 21, 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 except for iron, manganese, and zinc. While the turbidity level at MW-1 was less than 10 NTUs, the disparity on the metals data may have been due to an entrained solid in the duplicate. Overall, results were similar between the duplicate pair, 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, labeled as MW-9, had detections for zinc above the laboratory PQL. This detection does not appear to have affected the quality of the samples collected. 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 (1986) recommends that detections in quality control blanks not be used to correct groundwater data. 4.3 Summary of Groundwater Quality Results Field-measured parameters and laboratory results detected above the PQL in groundwater samples from the first half 2015 monitoring period 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 its secondary drinking water standard (SDWS) of 0.3 mg/l at all wells; Manganese exceeded the SDWS of 0.05 mg/l at all wells; 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-2. The exceedances of SDWSs during the current monitoring period are consistent with historical groundwater quality at this facility. 4-2

17 May 21, 2015 Table 4.1. Groundwater quality results, first half of

18 May 21, STATISTICAL EVALUATION This section describes the statistical approach and the statistical analyses of the analytical data for the first 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), and 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 May 21, 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 May 21, 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 (SSIs). 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 facility's power curve indicates that any single test will detect exceedances above background approximately 95% of the time at 3σ, approximately 100% of the time at 4σ, and exceed 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 May 21, 2015 Figure 5.1. Power curve for the 2015 monitoring periods. 5.2 Statistical Evaluation Detected constituents during the first 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). 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 Background was updated prior to the first half 2014 reporting period and a summary of the 5-4

22 May 21, 2015 updated datasets are included in Appendix E. Statistical plots for prediction limit and trend analyses are included in Appendix F Outlier Identification For small data populations, containing generally less than 25 data, Dixon's outlier test is applied to period of record data to identify possible outliers. For larger populations, at least 20 or more data, the Rosner's test is applied. Sanitas TM did not identify any statistical outliers in the first half 2015 data Prediction Limits Detected data for well-parameter combinations identified in Table 5.1 were tested using intrawell prediction limits to determine if the first half of 2015 data are representative of background data. Statistical analyses are included in Appendix F and results indicated that all analyzed well-parameter combinations were within estimated prediction limits 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. Trend tests indicated one significant increasing trend for the first half 2015 monitoring period; a statistically significant increasing trend is indicated in the manganese data at upgradient MW-1. This well-parameter has been previously indicated as an SSI and while it is considered a "confirmed" SSI, the trend is indicated for 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 a natural variation in groundwater quality and not the result of landfilling activities. 5-5

23 May 21, CONCLUSIONS AND RECOMMENDATIONS 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 first half 2015, groundwater flow across the landfill is to the southeast, consistent with the historical groundwater flow direction. 2. Prediction limit analyses did not indicate any SSIs during the first half 2015 monitoring period. 3. Trend tests indicated a significantly increasing trend for manganese at upgradient well MW-1 during the first half 2015 monitoring period. While this trend is considered a confirmed SSI, the well is located approximately 2,100 ft upgradient of the waste mass and the trend is considered a natural variation in groundwater quality and not the result of landfilling activities. 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 first half 2015 sampling event are generally consistent with historical data observed at the facility. 6-1

24 May 21, 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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33 APPENDIX B Laboratory Data Sheets

34 April 10, 2015 Control No Page 1 of 7 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 April 2, 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: Mr. Bill Sadler sadler@adeq.state.ar.us 8600 Kanis Road Little Rock, AR Phone FAX

35 April 10, 2015 Control No Page 2 of 7 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR SAMPLE INFORMATION Project Description: Six (6) water sample(s) received on April 2, 2015 Evergreen Packaging LF GW Permit No S3N-R1, AFIN: R P.O. No. S Line 2 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 02-Apr MW-2 02-Apr MW-3 02-Apr MW-8 02-Apr MW-9 02-Apr Leachate 02-Apr Notes: 1. Sample was received unpreserved Qualifiers: D Result is from a secondary dilution factor 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

36 April 10, 2015 Control No Page 3 of 7 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR ANALYTICAL RESULTS AIC No Sample Identification: MW-1 02-Apr Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 07-Apr by 271 Analyzed: 07-Apr by 271 Batch: W51482 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: 08-Apr by 271 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 03-Apr by Analyzed: 09-Apr by 271 Batch: W51508 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S38639 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 04-Apr by 07 Batch: C17589 AIC No Sample Identification: MW-2 02-Apr Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 07-Apr by 271 Analyzed: 07-Apr by 271 Batch: W51482 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: 08-Apr by 271 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 03-Apr by Analyzed: 09-Apr by 271 Batch: W51508 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S38639 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 04-Apr by 07 Batch: C Kanis Road Little Rock, AR Phone FAX

37 April 10, 2015 Control No Page 4 of 7 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR ANALYTICAL RESULTS AIC No Sample Identification: MW-3 02-Apr Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 07-Apr by 271 Analyzed: 07-Apr by 271 Batch: W51482 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: 08-Apr by 271 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 03-Apr by Analyzed: 09-Apr by 271 Batch: W51508 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S38639 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 04-Apr by 07 Batch: C17589 AIC No Sample Identification: MW-8 02-Apr Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 07-Apr by 271 Analyzed: 07-Apr by 271 Batch: W51482 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: 08-Apr by 271 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 03-Apr by Analyzed: 09-Apr by 271 Batch: W51508 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S38639 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 04-Apr by 07 Batch: C Kanis Road Little Rock, AR Phone FAX

38 April 10, 2015 Control No Page 5 of 7 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR ANALYTICAL RESULTS AIC No Sample Identification: MW-9 02-Apr Analyte Result RL Units Qualifier COD < HACH 8000 Prep: 07-Apr by 271 Analyzed: 07-Apr by 271 Batch: W51482 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: 08-Apr by 271 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 03-Apr by 07 < Analyzed: 09-Apr by 271 Batch: W51508 < Analyzed: 06-Apr by 235 Batch: S38639 < Analyzed: 06-Apr by 235 Batch: S38639 < Analyzed: 06-Apr by 235 Batch: S38639 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S38639 < 1 1 Analyzed: 06-Apr by 235 Batch: S38639 < Analyzed: 04-Apr by 07 Batch: C17589 AIC No Sample Identification: Leachate 02-Apr Analyte Result RL Units Qualifier COD D HACH 8000 Prep: 07-Apr by 271 Analyzed: 07-Apr by 271 Batch: W51482 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: 08-Apr by 271 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 06-Apr by 235 Prep: 03-Apr by Analyzed: 09-Apr by 271 Batch: W51508 < Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 06-Apr by 235 Batch: S Analyzed: 04-Apr by 07 Batch: C17589 D Dil: Kanis Road Little Rock, AR Phone FAX

39 April 10, 2015 Control No Page 6 of 7 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 Apr by Apr by 271 Batch: W51508 Duplicate Apr by Apr by 271 LABORATORY CONTROL SAMPLE RESULTS Spike Analyte Amount % Limits RPD Limit Batch Preparation Date Analysis Date COD W Apr by Apr by 271 Cadmium S Apr by Apr by 235 Iron S Apr by Apr by 235 Lead S Apr by Apr by 235 Manganese S Apr by Apr by 235 Zinc S Apr by Apr by 235 Chloride C Apr by 07 03Apr by 07 Dil Qual MATRIX SPIKE SAMPLE RESULTS Analyte Sample Spike Amount % Limits Batch Preparation Date COD W Apr by W Apr by 271 Relative Percent Difference: W51482 Analysis Date 07Apr by Apr by 271 Dil Qual Cadmium S38639 S Apr by Apr by 235 Relative Percent Difference: S Apr by Apr by 235 Iron S38639 S Apr by Apr by 235 Relative Percent Difference: S Apr by Apr by 235 Lead S38639 S Apr by Apr by 235 Relative Percent Difference: S Apr by Apr by 235 Manganese S38639 S Apr by Apr by 235 Relative Percent Difference: S Apr by Apr by 235 Zinc S38639 S Apr by Apr by 235 Relative Percent Difference: S Apr by Apr by 235 Chloride C17589 C Apr by 07 03Apr by 07 Relative Percent Difference: C Apr by 07 03Apr by Kanis Road Little Rock, AR Phone FAX

40 April 10, 2015 Control No Page 7 of 7 Evergreen Packaging Inc Fairfield Road Pine Bluff, AR LABORATORY BLANK RESULTS Analyte Result RL PQL QC Sample Preparation Date Analysis Date Qual COD < W Apr by Apr by 271 Total Dissolved Solids < W Apr by Apr by 271 Cadmium < S Apr by Apr by 235 Iron < S Apr by Apr by 235 Lead < S Apr by Apr by 235 Manganese < S Apr by Apr by 235 Zinc < S Apr by Apr by 235 Chloride < C Apr by 07 03Apr 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 < /17/ n/a 6.4 < < /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 < < Notes: B-flagged data indicate that parameter was detected above the PQL in a quality control sample. R (rejected), or O (outliers) are not used in statstical analyses. 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 1/6/ <10 n/a 6.4 < (cont.) 7/14/ <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) 10/16/ < (B) < (B) 4/2/ < < (B) < (B) 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 < Notes: B-flagged data indicate that parameter was detected above the PQL in a quality control sample. R (rejected), or O (outliers) are not used in statstical analyses. 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) MW-2 6/19/ n/a 6.5 < < <0.01 (cont.) 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 < < /9/ n/a /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/ < < Notes: B-flagged data indicate that parameter was detected above the PQL in a quality control sample. R (rejected), or O (outliers) are not used in statstical analyses. Cadmium () 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 8/5/ < <1 110 <0.002 (cont.) 3/10/ < < < /29/ < < /23/ < < /14/ < < < /9/ /19/ < < /20/ < < /21/ < < < /26/ < < <1 290(B) (B) 9/4/ < < < (B) 4/9/ < < (B) (B) < (B) 10/16/ < (B) < (B) 4/2/ < < (B) < (B) 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 < < Notes: B-flagged data indicate that parameter was detected above the PQL in a quality control sample. R (rejected), or O (outliers) are not used in statstical analyses. 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-3 1/23/ <10 n/a 6.4 < < (cont.) 7/3/ n/a 6.5 < < /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/ < < < /9/ /19/ < < < /20/ < /21/ < < /26/ < < <1 270(B) (B) Notes: B-flagged data indicate that parameter was detected above the PQL in a quality control sample. R (rejected), or O (outliers) are not used in statstical analyses. 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 9/4/ < < < (B) (cont.) 4/9/ < < (B) (B) < (B) 10/16/ < (B) < (B) 4/2/ < < (B) < (B) Leachate d 3/1/ n/a 4.1 < /27/ n/a /13/ n/a 8.5 < /24/ < < /24/ n/a /5/ < < /10/ n/a 9.81 < /29/ n/a 9.6 < /23/ n/a 10.1 < < /14/ <0.2 <1 160 <0.1 < <0.1 3/9/ n/a /19/ < /20/ < /21/ < < /26/ < (B) 0.026(B) 9/4/ < < (B) 4/9/ < (B) (B) (B) 10/16/ < (B) (B) 4/2/ < (B) (B) Iron () Hardness as CaCO3 () Manganese () Lead (ug/l) Total Dissolved Solids () Zinc () Notes: B-flagged data indicate that parameter was detected above the PQL in a quality control sample. R (rejected), or O (outliers) are not used in statstical analyses.