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HomeMy WebLinkAboutMO-4860_16417_CA_MRP_20231115 Page | 1 Buxton Environmental, Inc. P.O. Box 11550 ~ Charlotte, North Carolina 28220 Phone (704) 906-4994 ~ e-mail: buxtonenv@bellsouth.net October 25, 2023 Mrs. Jan Yandle Southland Oil Company 2325 Summerlake Road Charlotte, North Carolina 28226 Subject: Second Semi-Annual 2023 - Groundwater Monitoring Event Report (October 2023) Former Big Bill’s Place; 601 Gastonia Highway; Bessemer City, North Carolina Incident No.: 16417; Ranking I140D Dear Mrs. Yandle, A. SITE INFORMATION 1. Site Identification Date of Report: _____October 25, 2023_____________ Facility I.D.: __NA_________Incident Number: __16417______Site Risk/Priority Rank: __I140D____ Site Name: ___Former Big Bill’s Place____________________________________________________ Site Street Address: ___601 Gastonia Highway_____________________________________________ City/Town: __Bessemer City, NC_____Zip Code: _28016___County: ___Gaston__________________ Description of Geographical Data Point (e.g., dispenser): __Former UST Basin_____________________ Location Method (GPS, topographical map, other):___Topo Map_______________________________ Latitude (decimal degrees): _35o 17’ 00” ________ Longitude (decimal degrees): _81o 16” 24” ______ 2. Information about Contacts Associated with the Release (Addresses must include street, city, state, zip code and mailing address, if different) UST/AST Owner: ____Southland Oil Company_____________________________________________ Address: ____2325 Summerlake Rd., Charlotte, NC 28226________Tel: __704-451-7849___________ UST/AST Operator: ______As Above____________________________________________________ Address: __________________________________________________Tel: _______________________ Other Person Associated with Release: ____Mrs. Jan Yandle (with Southland Oil Co.)______________ Address: ___As Above______________________________________Tel: __704-451-7849_________ Property Owner: __The Phone Center (during 2013 CSA)___________________________________ Address: ___601 Gastonia Highway; Bessemer City, NC 28016_____Tel: __704-629-5200_________ Property Occupant: ___The Phone Center; Eaves Farm Supply and The Car Lot_________ Address: ____601 Gastonia Highway_______________Tel: __704-629-5200, 704-913-1139_________ Consultant/Contractor: __Ross Klingman, P.G. w/Buxton Environmental, Inc._____________________ Address: ___P.O. Box 11550; Charlotte, NC 28220______________Tel: ___704-906-4994__________ Analytical Laboratory: ___Waypoint Analytical Carolina, Inc.______State Certification No.___402_____ Address: __449 Springbrook Rd., Charlotte, NC 28217_____Tel: __704-529-6364_____________ 3. Information about Release Date Discovered: __September 1996 and March 1998_______________________________________ Estimated Quantity of Release: _____Unknown_____________________________________________ Cause of Release: ____2-4,000 and 1-3,000 gallon gasoline USTs (closed in-place)______________ Source of Release: ____as above____________________________________________________ Sizes and Contents of Tank or Other Containment from which the Release Occurred:________________ 4. Certification (The title page must display the seal and signature of the certifying P.E. or L.G. and the name and certification number of the company or corporation [See 15A NCAC 2L .0103(e).]) I, ___Ross Klingman, P.G.__________, a Professional Engineer/Licensed Geologist (circle one) for (firm or company of employment), do certify that the information contained in this report is correct and accurate to the best of my knowledge. (Please Affix Seal and Signature) Buxton Environmental, Inc._(Name of company or corporation) is licensed to practice geology/engineering (circle one or both) in North Carolina. The certification number of the company or corporation is C-278. Page | 2 B. INTRODUCTION AND EXECUTIVE SUMMARY Buxton Environmental, Inc. (BEI) respectfully submits the methods and results of the second semi-annual 2023 - groundwater monitoring event report activities conducted on October 8, 2023 at the former Big Bill’s Place located at 601 Gastonia Highway in Bessemer City, North Carolina. These activities were conducted to determine current groundwater quality, and determine the effectiveness of continuation of the approved Natural Attenuation Corrective Action Plan (CAP; approved September 2014) at the site to treat up to approximately 1,000,000 gallons of residual petroleum affected groundwater (currently only benzene) historically detected above the North Carolina Gross Contamination Levels in Groundwater (NCGCL) at on-site monitor wells MW- 1, MW-3 and MW-5, and off-site well MW-14. These activities were conducted in general accordance with North Carolina Department of Environment Quality – Underground Storage Tank (UST) Section (NCUST) guidelines, conversations with Mr. Brad Newton, P.G. (NCUST project manager) and the May 3, 2023 Notice of Regulatory Requirements (NORR) from the NCUST requesting the resumption of the approved Natural Attenuation CAP and previously established semi-annual groundwater monitoring at the site (Appendix A). The incident at the site is associated with releases from three closed in-place gasoline UST systems including one 3,000-gallon gasoline UST, two 4,000-gallon gasoline UST’s, associated piping and three dispensers. The site is located at 81o 16” 24” longitude and 35o 17’ 00” latitude. A site location map is provided in Figure 1; a site layout map (zoom-out) is provided in Figure 2, and a site layout map (zoom-in) is provided in Figure 3. These activities were Pre-Approved by the NCUST Trust Fund on September 29, 2023 (Task Authorization Number 22) for UST Trust Fund reimbursement purposes. Page | 3 D. SITE HISTORY AND CHARACTERIZATION According to a UST Closure Report prepared by Kimbrell & Associates, one approximately 4,000-gallon gasoline tank (tank 1) was closed in-place on September 4, 1996 at the site. During the closure activities, a total of three confirmation soil samples (#1, #2 and #4) were collected from the base of the UST and one confirmation soil sample (#3) was collected at the base of the gasoline dispenser and were analyzed by SW-846 Methods 5030 (gasoline range, total petroleum hydrocarbons (TPH)) and 3550 (diesel range TPH). Confirmation soil sample #3, which was collected at the base of the dispenser, indicated the presence of 192 milligrams per kilogram (mg/kg) gasoline range TPH, which is above the North Carolina General Action Level (NCGAL) of 10 mg/kg. The remaining soil samples did not indicate the presence of gasoline or diesel range hydrocarbons above method detection limits. A March 16, 1998 UST Closure Report prepared by Kimbrell & Associates indicated that one approximately 4,000-gallon gasoline tank (tank 2) and one approximately 3,000-gallon gasoline tank (tank 3) were closed-in- place in March 1998 at the site. During the closure activities, a total of three confirmation soil samples (#1, #2 and #3) were collected from the base of the 4,000-gallon gasoline tank and two confirmation soil samples (#4 and #5) were collected from the base of the 3,000-gallon gasoline tank. In addition, one confirmation soil sample (#6) was collected at the base of the shared piping run and two confirmation soil samples (#7 and #8) were collected at the base of two shared dispenser islands. The soil samples were analyzed by EPA Method 8260 (including isopropyl ether (IPE) and MTBE) and SW-846 Method 5030 (gasoline range TPH). Confirmation soil samples #3, #4 and #5 indicated the presence of petroleum constituents above the North Carolina standards. The remaining soil samples did not indicate the presence of petroleum constituents above North Carolina standards. Based on these findings, the North Carolina Department of Environment and Natural Resources (NCDENR) Mooresville Regional office (currently NCDEQ-UST) issued two NORR letters on February 16, 1998 and April 28, 1998 to Southland Oil Company for the reported petroleum releases. The NORR letters requested that Limited Site Assessment (LSA) activities be conducted at the site. Mr. Dan Graham with the NCDENR, indicated during a June 9, 1998 telephone conversation, that the gasoline releases detected at the site could be evaluated in a single stand-alone LSA report. A Phase I and II Limited Site Assessment and Free Product Recovery Activities report dated September 29, 1998 was prepared for the site by Carolina Environmental, Inc and Buxton Environmental, Inc. The LSA was conducted to determine soil and groundwater quality in the area of reported gasoline releases, determine potential receptors in the area of the site and determine the risk of the release. Gasoline free product recovery activities were also conducted as initial remediation. During the LSA, four shallow groundwater monitor wells (MW-1, MW-2, MW-3 and MW-4), one deep groundwater monitor well (MW-1D) and one soil boring (SB-2) were advanced at the site. Monitor well MW-1 was installed at soil boring SB-1. During the receptor survey, one water supply well was identified 1,300 feet from the site, and five places of public assembly were identified from 500 to 1,200 feet from the site. A total thickness of 0.67 feet of gasoline free product was observed at monitor well MW-1 and 0.75 gallons of gasoline were removed during free product recovery activities. Soil samples SB-1 (8-10’) and SB-1 (13-15’) indicated the presence of petroleum constituents above the lesser of the North Carolina Maximum Soil Contaminant Concentration, Soil-to-Groundwater standards (NCMSCC-STG) or NCMSCC, Residential standards (R), and above the NCMSCC-R. Soil samples SB-2 (9-11’), SB-2 (19-21’) and SB-2 (29-31’) indicated the presence of petroleum constituents above the lesser of the NCMSCC-STG or R and above the NCMSCC-R. Soil samples SB-2 (19-21’) and SB-2 (29-31’) also indicated the presence of petroleum constituents above the NCMSCC, Industrial/Commercial standards (I/C). The groundwater samples collected at monitor wells MW-1, MW-1D, MW-2, MW-3 and MW-4 indicated the presence of target constituents above NCGQS’s. Groundwater samples collected at monitor wells MW-1 and MW-3 indicated benzene and ethylene dibromide (EDB) above the NCGCLs. Groundwater samples MW-2, MW-3, MW-4 and Page | 4 MW-1D also indicated the presence of chlorinated solvents including but not limited to 1,2-dichloroethane, tetrachloroethene and/or trichloroethene, which are common degreasers. Tetrachloroethene and trichloroethene are not typically associated with gasoline UST releases. 1,2-dichloroethane is also a common gasoline additive. It is difficult to discern if the 1,2-dichloroethane is associated with the gasoline UST’s or not, due to the presence of other chlorinated solvents. The source of the chlorinated solvents is currently unknown. Due to the presence of groundwater constituents above NCGCLs and gasoline free product, the site was classified as intermediate risk. Based on review of the Phase I and II Limited Site Assessment and Free Product Recovery Activities report, the NCDENR requested in a NORR letter dated October 23, 1998 that a Comprehensive Site Assessment (CSA) be conducted. The CSA was originally due for submittal to the NCDENR by February 2, 1999. On July 19, 2012, Mr. Brad Newton, P.G. with the NCDENR indicated that the CSA requested on October 23, 1998 had not been prepared for the site. On July 31, 2000, groundwater sampling was conducted at monitor wells MW-1D, MW-2 and MW-4 and the samples were analyzed for volatile organic compounds (VOCs). Groundwater sampling was not conducted at monitor wells MW-1 and MW-3, due to the presence of 0.68 feet and 0.42 feet of gasoline free product, respectively. The groundwater samples collected at monitor wells MW-1D, MW-2 and MW-4 indicated the presence of target constituents above NCGQS’s; and groundwater samples collected at monitor well MW-1D indicated benzene above NCGCLs. On May 11, 2012, the NCDENR issued a NORR letter requesting that groundwater monitoring activities be conducted at LSA monitor wells MW-1, MW-1D, MW-2, MW-3 and MW-4. Mr. Brad Newton, P.G. with the NCDENR requested that groundwater samples be analyzed for Risk-Based gasoline parameters, excluding lead (Pb). On July 19, 2012, Mr. Brad Newton, P.G. with the NCDENR was notified that two additional shallow monitor wells MW-5 (60 feet, installed December 2001) and MW-7 (53 feet, installed December 2001), and one additional deep well DW-1 (91 feet, installed December 2001) were observed at the site during preliminary groundwater sampling activities. Mr. Newton indicated that additional on-site wells were not required to be monitored as part of the May 11, 2012 NORR letter. An additional shallow monitor well, MW-6 (60 feet, installed December 2001), was also discovered during the CSA activities. Mr. Newton indicated that these wells could be utilized for the CSA investigation. On July 19, 2012, BEI conducted groundwater monitoring activities at MW-1, MW-1D, MW-2, MW-3 and MW-4. The groundwater samples were analyzed by EPA Method 6200B (VOCs) and Massachusetts Department of Environmental Protection – Volatile Petroleum Hydrocarbons (MADEP-VPH). The groundwater samples collected at MW-1, MW-1D, MW-2, MW-3 and MW-4 indicated the presence of target constituents above NCGQS’s. Groundwater samples collected at MW-1 (benzene and MTBE), MW-1D (benzene) and MW-3 (benzene) indicated the presence of petroleum constituents above established NCGCLs. The shallow groundwater flow direction was determined to be to southwest across the site. Free product was not detected at any of the sampled monitor wells. The Groundwater Monitoring Report Activities dated August 9, 2012, which was prepared by BEI, was submitted to the NCDENR. Following review of the August 9, 2012 Groundwater Monitoring Report Activities, the NCDENR issued a NORR letter on September 7, 2012 requesting that a CSA be prepared at the site. Following review of the original May 3, 2013 Comprehensive Site Assessment report, Mr. Brad Newton, P.G. with the NCDENR indicated in a May 28, 2013 letter that additional monitor wells were required to delineate the horizontal extent of the petroleum affected groundwater plume associated with the gasoline UST releases at the site. Mr. Newton indicated during a May 30, 2013 telephone conversation that three additional shallow Page | 5 monitor wells should be installed for delineation purposes. A total of three wells were requested to be installed at the following locations: to the north of monitor well MW-3 and MW-6 across E. Washington Ave. on the northern side of the site, to the south of MW-2 and MW-5 across Gastonia Highway on the southern side of the site, and to the west of MW-7 on the western side of the site. On June 10, 2013, Mr. Newton met Mr. Ross Klingman, P.G. with BEI at the site to discuss the additional assessment and confirm the locations of the additional monitor wells. On August 9, 2013, BEI submitted the final Comprehensive Site Assessment – Revision 1 report to the NCDENR. The primary objectives of the CSA activities were to determine the risk to potential receptors, characterize the vertical and horizontal extent of petroleum affected soil and groundwater associated with releases from the closed in-place gasoline UST system and determine geologic and hydrogeologic characteristics at the site. During the CSA, a receptor survey update was conducted, nine (9) GeoprobeTM soil borings (GP-1, GP-2, GP-3, GP-4, GP-5, GP-6, GP-7, GP-8 and GP-9) were advanced, previously installed groundwater monitor wells (MW-5, MW-6, MW-7 and DW-1) were sampled for Risk-Based petroleum constituents, and eight (8) shallow groundwater monitor wells (MW-8, MW-9, MW-10, MW-11, MW-12, MW- 13, MW-14 and MW-15) were installed and sampled for Risk-Based petroleum constituents. During the receptor survey, no water supply wells were identified within a 1,000 foot radius of the subject site. A total of five (5) potential receptors, including a water supply well located 1,300 feet from the site and four places of public assembly were identified within a 1,500 foot radius of the site. The subject site is currently owned by The Phone Center and operates as The Phone Center (mobile phone sales and service) and Eaves Farm Supply. Municipal water is available within a 1,500 foot radius of the site and municipal water use is required within the city limits of Bessemer City. No surface water bodies were identified within a 1,500 foot radius of the site. The land use of the site is industrial/commercial. The vertical and horizontal extent of petroleum affected soil above the lesser of the NCMSCC-STG or R appears to have been effectively defined and is primarily located on-site in an area of 35 feet by 70 feet down to approximately 46.5 feet below grade (approximately 40 feet below grade during CAP groundwater sampling in January 2014). Based on groundwater analytical results obtained from July 19, 2012 to July 12, 2013, the vertical and horizontal extent of petroleum affected groundwater above the NCGQS’s and the NCGCLs (for benzene and MTBE) appears to have been effectively defined, with the exception of the area to the northeast of monitor well MW-14. The petroleum affected groundwater plume above NCGQS’s was determined to have migrated off-site and is a minimum of 225 feet by 550 feet in area and extends downward from approximately 40 feet below grade (top of water table) to approximately 100 feet below grade (60 foot thickness). The benzene affected groundwater plume above NCGCLs is a minimum of 65 feet by 225 feet in area and extends downward from approximately 40 feet below grade (top of water table) to approximately 75 feet below grade (35 foot thickness), and is located at the subject property and extends off-site to the northeast. The MTBE affected groundwater plume above NCGCLs appeared to be contained on the subject property. The presence of gasoline free product was not encountered in any monitor wells during groundwater monitoring conducted from July 19, 2012 through July 12, 2013. Petroleum affected groundwater associated with releases from the closed in-place gasoline UST systems was determined to be preferentially migrating to the southwest and northeast along strike of the near vertical metamorphic foliation dip, which is sidegradient (up to approximately 90o) to the predominant shallow groundwater flow direction to the northwest and west northwest. Based historical assessment activities and the findings of the CSA investigation, the site was determined to be classified as an intermediate risk, due to the presence of petroleum affected groundwater above NCGCLs. NCDENR Appendix B – Reporting Tables (B-1 and B-2), including information concerning the three closed in- place gasoline UST’s and UST owner/operator and other responsible party information are provided in Appendix B. Based on review of the CSA, the NCDENR issued a NORR letter on September 4, 2013 requesting that a Corrective Action Plan (CAP) be prepared for the site. On June 25, 2014, BEI submitted the Corrective Action Plan to the NCDENR, which recommended natural attenuation as the preferred remedial option for the site. Page | 6 Following review of the CAP, the NCDENR issued a NORR letter on September 9, 2014 approving natural attenuation as an acceptable remedial approach for the site. The NORR letter requested that groundwater monitoring be conducted semi-annually (twice) during the first year, then the sampling schedule could be re- evaluated. On March 18, 2015, BEI conducted the first semi-annual post CAP groundwater monitoring event at seventeen (17) monitor wells including MW-1, MW-1D, DW-1, MW-2, MW-3, MW-4, MW-5, MW-6, MW-7, MW-8, MW-9, MW-10, MW-11, MW-12, MW-13, MW-14 and MW-15. On October 6, 2015, BEI conducted the second semi-annual post CAP groundwater monitoring event at sixteen (16) monitor wells including MW-1D, DW-1, MW-2, MW-3, MW-4, MW-5, MW-6, MW-7, MW-8, MW-9, MW-10, MW-11, MW-12, MW-13, MW-14 and MW-15. Monitor well MW-1 was dry, therefore, was unable to be sampled. The annual groundwater monitoring activities were requested at monitor wells MW-1D, MW-3, MW-5 and MW-14 in a December 8, 2015 letter from the NCDEQ-UST. On September 6, 2016, BEI conducted annual groundwater sampling at monitor wells MW-1D, MW-3, MW-5 and MW-14 at the subject site as requested in the December 8, 2015 letter from the NCDEQ-UST. On September 28, 2017, BEI conducted annual groundwater monitoring at monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14 located at the subject site, as requested in the December 8, 2015 letter from the NCDEQ-UST. Monitor well MW-1 was dry, therefore, was unable to be sampled. The original copy of Groundwater Monitoring Report – Annual 2017 dated October 23, 2017 was submitted to the NCDEQ-UST. Based on their review, the NCDEQ-UST requested that the report be revised and formatted in general accordance with new NCDEQ-UST guidelines. A subsequent Groundwater Monitoring Report (Revised) – Annual 2017 dated January 16, 2018 was submitted to the NCDEQ-UST. Based on review of the October 23, 2017 report, the NCUST requested that groundwater monitoring be conducted on a semi-annual basis (twice a year) and replace the annual monitoring schedule at monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14; and that monitor well MW-1 be re-installed to a greater depth (due to recent dry conditions). On March 15, 2018, Mr. Ross Klingman, P.G. with BEI contacted Mr. Brad Newton P.G. with the NCDEQ-UST to request that the installation of MW-1 be delayed, since the existing well has historically intercepted the water table during the late spring and early summer (historical groundwater high in Gaston County; however; was dry during site checks conducted on March 6, April 17, April 27 and May 7, 2018); and the current property owner expressed concerns with the requested well installation and damage to his asphalt parking lot. Based on this information, BEI proposed to proceed with semi-annual sampling only (knowing that MW-1 is expected to intercept the water table during the late spring and early summer); and to re-install MW-1 only if needed in the future. The first semi-annual 2018 sampling event was to be conducted once MW-1 contains water or by May 31, 2018 (whichever came first). On May 18, 2018, BEI conducted the First Semi-Annual 2018 groundwater monitoring event (this event) at monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14 located at the subject site, as requested in the November 9, 2017 letter from the NCUST. This report was submitted to the NCUST on June 15, 2018. Based on review of the June 15, 2018 report, the NCUST requested in a July 10, 2018 letter that routine semi- annual groundwater monitoring along with MMPE vacuum truck remediation be conducted by the end of September 2018. On August 21, 2018, Mr. Ross Klingman, P.G. with BEI contacted Mr. Brad Newton P.G. with the NCDEQ-UST to request that the MMPE event be delayed, since key on-site monitor wells MW-1 and MW-3, which have historically indicated elevated petroleum affected groundwater constituents above the NCGCLs, contained less than 1-foot of water and was dry, respectively, during an August 20, 2018 site visit. Page | 7 Limited water and dry monitor well conditions would limit the effectiveness of the requested MMPE at this time. Additional factors considered for not conducting the MMPE event include: 1) the current property owner has expressed concerns of potential further damage to his asphalt parking lot by heavy equipment; 2) the vertical geologic foliation at the site would prevent lateral remediation effectiveness (perpendicular to the foliation); 3) the potential for pulling the affected groundwater plume vertically downward; 4) off-site monitor well MW-14 also contains petroleum constituents above the NCGCLs, and conducting MMPE at this location could pull petroleum affected groundwater further off-site; and 5) the approved MNA CAP appears to be working, based on generally decreasing petroleum constituent concentrations with time. Based on this information, BEI proposed to proceed with groundwater sampling only. On October 31, 2018, BEI conducted Second Semi-Annual 2018 groundwater monitoring activities at four (4) monitor wells including MW-1, MW-1D, MW-5 and MW-14. Groundwater sampling was unable to conducted at monitor well MW-3, due to dry conditions. Historical groundwater analytical results for monitor wells MW- 1, MW-1D, MW-3, MW-5 and MW-14 are provided in Tables 4, 5 and 6. A copy of the November 19, 2018 Second Semi-Annual 2018, Groundwater Monitoring Report was submitted to the NCUST on December 5, 2018. Following review of the November 19, 2018 Second Semi-Annual 2018, Groundwater Monitoring Report prepared by BEI, the NCDEQ-UST issued a Notice of Regulatory Requirements (NORR) letter to Southland Oil Company on December 20, 2018. The NCUST letter requested abandonment and replacement of monitor wells MW-1 and MW-3 (due to recently low/insufficient water levels for sampling/remediation), a mobile multi-phase event (MMPE)(long-term AFVR event lasting 1 week or more), and subsequent groundwater monitoring at MW-1, MW-1D, MW-3, MW-5 (on-site wells) and MW-14 (off-site well)). These activities were requested to be conducted in March 2019. On January 15, 2019, Mr. Ross Klingman, P.G. with BEI contacted Mr. Brad Newton, P.G. with NCUST to discuss the requests made in the December 20, 2018 letter. During the conversation Mr. Newton was informed that due to recent rain events, monitor wells MW-1 and MW-3 (which can contain little or no water during extreme dry seasons) contained approximately 6 feet and 4 feet of standing water, respectively, during a January 2019 site visit, which would be more than sufficient for sampling. Mr. Newton was also informed that Mrs. Jan Yandle with Southland Oil Company had agreed to conduct one (1) AFVR pilot event, even though it is not part of the NCUST approved natural attenuation CAP, in order to attempt to expedite/enhance the natural attenuation remediation time (estimated at 17 years in the CAP). As presented in the Second Semi-Annual 2018, Groundwater Monitoring Report, petroleum affected groundwater constituents have generally decreased over time; and annual groundwater monitoring was recommended in the spring of each year due to historically high water level conditions and historical data has shown little intra-seasonal trends in petroleum concentrations. In addition, gasoline free-product, which was present at MW-1 and MW-3 in the late 1990s and early 2000s, has dissipated and is no longer present in these wells. Based on this information, the approved natural attenuation CAP appears to be working, based on generally decreasing petroleum constituent concentrations with time, and the absence of gasoline free-product. The current property owners (Eaves Farm Supply and The Car Lot) indicated during a recent site visit that they would potentially allow the AFVR event, if it would expedite the remediation process. The current owners have historically been concerned about the degraded condition of the asphalt parking lot in the immediate area of the closed in-place gasoline underground (for aesthetics and liability reasons) and the use heavy drilling/remediation equipment at their property has been discouraged during recent conversations, due to potential further asphalt damage. On March 20, 2019, BEI obtained a right-of-access agreement to enter on to the subject property to conduct NCDEQ-UST requested assessment and/or remediation activities (including the NCDEQ-UST requested AFVR event) from Mr. Howard Eaves and Mrs. Howard Shannon Eaves (current property owners). Page | 8 From March 28, 2019 (19:00) to March 29, 2019 (03:00), an 8-hour AFVR pilot test event #1 was conducted at on-site monitor wells MW-1, MW-3 and MW-5. During these activities, 2,475 gallons of petroleum affected groundwater were recovered. The recovered groundwater was appropriately transported and disposed at an off- site facility. The approximate area of groundwater table draw-down influence during the 8-hour AFVR event, appears to be 95 feet x 250 feet+, with a minimum vertical influence of 32 feet below the water table at MW- 1D. The area of AFVR influence appears to follow the northeast-southwest strike of the near vertical metamorphic rock foliation. Based on groundwater levels collected on March 28 and 31, 2019, the predominate shallow groundwater flow direction at the subject property and immediately surrounding area is to the west northwest and southwest; approximately 45-degrees counter to the primary petroleum plume migration (which follows the near vertical northeast to southwest striking metamorphic rock foliation). Post-AFVR groundwater samples collected on March 31, 2019 at shallow monitor wells MW-1, MW-3, MW-5 and MW-14 indicated the presence of benzene, ethylbenzene, MTBE, toluene and xylenes above NCGQSs. The groundwater sample collected at deep monitor well MW-1D indicated the presence of benzene and MTBE above NCGQSs. The groundwater samples collected MW-1, MW-3, MW-5 and MW-14 also indicated benzene above NCGCLs. Following the March 2019 AFVR event, a decrease in target petroleum constituents was observed in groundwater samples collected monitor wells MW-1, MW-3 and MW-1D (as compared to the last several groundwater sampling events). However, an increase in target petroleum constituents was observed in groundwater samples collected monitor wells MW-5 and MW-14 following the March 2019 AFVR event (as compared to the last several groundwater sampling events). The long-term positive effects of AFVR (via: volatilization of residual source area petroleum VOC affected soil and groundwater; increased oxygenation of the aquifer and resulting increase in bioremediation potential (as observed in affected wells following the AFVR event, as compared to the October 2018 sampling event); and the observed radius of AFVR influence (along the preferred petroleum plume pathway and strike of the near vertical metamorphic foliation)) are expected to expedite/enhance the existing natural attenuation remedial approach at the site. BEI recommended that annual 8-hour AFVR events be conducted to attempt to expedite/enhance the natural attenuation remediation time at the site; followed by annual groundwater sampling to monitor the effectiveness of a dual remedial approach at the site. A summary of these activities was presented in the April 30, 2019 AFVR Pilot Test and Groundwater Monitoring Report prepared by BEI, which was submitted to the NCUST. Following review of the April 30, 2019 AFVR Pilot Test and Groundwater Monitoring Report prepared by BEI, the NCUST issued a letter on May 16, 2019 requesting groundwater sampling in September 2019, and tentatively agreed with BEI’s recommendation to conduct an additional AFVR event in March 2020 (dependent on the results of the requested September 2019 groundwater sampling results). On September 23, 2019, BEI conducted post AFVR groundwater monitoring activities at four (4) shallow monitor wells including MW-1, MW-3, MW-5 and MW-14; and one (1) intermediate depth monitor well MW- 1D. The groundwater samples were analyzed for target petroleum constituents including benzene, toluene, ethylbenzene and xylenes (BTEX); plus methyl-tert-butyl-ether (MTBE) by EPA Method 8260D. A groundwater depression with a northeast-southwest axis-of-orientation is present in the immediate area of the closed-in-place UST system, with shallow groundwater flow to the north, south, east and west toward the center of the depression. This groundwater depression may be the result of residual effects of the AFVR pilot test event conducted in March 2019 at on-site monitor wells MW-1, MW-3 and MW-5, which are located along the same axis-of-orientation as the groundwater depression and along the northeast-southwest strike of the near vertical metamorphic rock foliation across the site. The predominate shallow groundwater flow direction outside of the groundwater depression is westward, which is approximately 45-degrees counter to the primary petroleum plume migration (which follows the near vertical northeast to southwest striking metamorphic rock foliation). Groundwater samples collected at shallow monitor wells MW-1, MW-3, MW-5 and MW-14 indicated the presence of benzene, ethylbenzene, MTBE, toluene and xylenes above NCGQSs. The groundwater sample collected at deep monitor well MW-1D indicated the presence of benzene, ethylbenzene, MTBE, toluene and xylenes above NCGQSs. The groundwater samples collected MW-1, MW-3, MW-5 and MW-14 also indicated benzene above NCGCLs. Due to both vertical (MW-1D) and horizontal (MW-5 and Page | 9 MW-14) increases/expansion in petroleum constituents following the March 2019 AFVR pilot test event, we recommended groundwater monitoring only during the next event anticipated to occur in March 2020, in order to determine the continued effects of the AFVR pilot test on groundwater quality and plume migration at the site. The Post AFVR Groundwater Monitoring Report prepared by BEI on October 8, 2019 was submitted to the NCUST. From April 23 (19:00) until April 24 (03:00), 2020, an 8-hour AFVR (AFVR event #2) was conducted at on-site monitor wells MW-1, MW-3 and MW-5 (extraction wells). The AFVR event was conducted after regular store hours, as requested by the Eaves, in order to not interfere with their business operations. During these activities, 3,000 gallons of petroleum affected groundwater were recovered. The AFVR activities were conducted by Zebra Environmental and Industrial Services, Inc. (Zebra) of High Point, North Carolina, with oversight by Mr. Ross Klingman, P.G. with BEI. The recovered groundwater was appropriately transported and disposed at an off-site facility by Zebra. The approximate area of groundwater table drawdown influence during the 8-hour AFVR event #2, appears to be approximately 115’ x 250’+, with a minimum vertical influence of 58.68’ below the water table at deep monitor well DW-1 (TD BTOC 91’ - static depth-to-water BTOC 32.32’ = 58.68’ standing water). The area of AFVR influence appears to follow the northeast-southwest strike of the near vertical metamorphic rock foliation. On May 7, 2020, post AFVR event #2 groundwater monitoring activities were conducted at four (4) shallow monitor wells including MW-1, MW-3, MW-5 and MW-14; and one (1) intermediate depth monitor well MW-1D were conducted. The predominate shallow groundwater flow direction at the subject property and immediately surrounding area is to the northwest and southwest, which is approximately 45 to 90 degrees counter to the primary petroleum plume migration (which follows the near vertical northeast to southwest striking metamorphic rock foliation). The groundwater samples collected on May 7, 2020 at shallow monitor wells MW-1, MW-3, MW-5 and MW-14 indicated the presence of benzene, ethylbenzene, MTBE, toluene and xylenes above NCGQSs. The groundwater sample collected at intermediate depth monitor well MW-1D indicated the presence of benzene, ethylbenzene, MTBE, toluene and xylenes above NCGQSs. The groundwater samples collected MW-1, MW-3, MW-5 and MW-14 also indicated benzene above NCGCLs. AFVR appears to oxygenate the aquifer which becomes depleted over time, which appears to indicate enhanced natural attenuation processes are occurring at the site. Following the March 2019 AFVR pilot-test event and the April 2020 AFVR event #2, decreases in target petroleum constituents have been observed in groundwater samples collected at monitor wells MW-1 and MW-3. However, lateral/horizontal increases/expansion in target petroleum constituents have been observed in groundwater samples collected at shallow monitor wells MW-5 (substantial increase) and MW-14 following the two (2) AFVR events. A vertical increase/expansion in target petroleum constituents have been observed in groundwater samples collected at intermediate depth monitor well MW-1D following the two (2) AFVR events. The long-term positive effects of AFVR (via: volatilization of residual source area petroleum VOC affected soil and groundwater; increased oxygenation of the aquifer and resulting increase in bioremediation potential (as observed in affected wells following the AFVR events); and the observed radius of AFVR influence (along the preferred petroleum plume pathway and strike of the near vertical metamorphic foliation)) are expected to expedite/enhance the existing natural attenuation remedial approach at the site. However, negative impacts of continued AFVR at the site include increases in petroleum constituents and plume expansion, both vertically (MW-1D) and horizontally (MW-5 and MW-14). Based on the above findings, Buxton Environmental, Inc. recommended that future 8- hour AFVR events be conducted only at monitor well MW-1 to attempt to expedite/enhance the natural attenuation remediation time at the site and pull the petroleum affected ground plume towards the center of the site and source area; and not away from the source area as indicated at MW-5 and MW-14. AFVR was recommended to be conducted annually in the spring of each year (around the month of March) during historical groundwater highs encountered in the Gaston County area (would reduce further potential downward vertical migration of the petroleum affected groundwater plume); and for cost saving purposes. Semi-annual groundwater monitoring should continue to be conducted at monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14, in order to monitor the effectiveness of a dual remedial approach (natural attenuation with annual AFVR) at the site. Page | 10 Based on review of the May 26, 2020 8-Hour AFVR Event #2 and Post AFVR Groundwater Monitoring Report, the NCDEQ-UST requested in a June 16, 2020 NORR letter that a Mobile Multi-Phase (MMPE) event be conducted at monitor wells MW-1 and MW-3, then followed by groundwater sampling (MW-1, MW-1D, MW- 3, MW-5 and MW-14) at least two weeks after the MMPE. In the event that the MMPE was unable to be conducted, then an AFVR event should be conducted prior to the next sampling event. From September 14 (09:30 am) until September 15 (03:30 am), 2020, an 18-hour AFVR event (AFVR event #3) was conducted at on-site monitor wells MW-1 and MW-3 (groundwater monitor wells used as extraction wells). During these activities, 2,477-gallons of petroleum affected groundwater were recovered. The AFVR activities were conducted by Zebra Environmental and Industrial Services, Inc. (Zebra) of High Point, North Carolina, with oversight by Mr. Ross Klingman, P.G. with BEI. The recovered groundwater was appropriately transported and disposed at an off-site facility by Zebra. The approximate area of groundwater table draw- down influence during the 18-hour AFVR event #3, appears to be approximately 113’ x 320’+, with a minimum vertical influence of 54.29’ below the water table at deep monitor well DW-1 (total depth (TD) below top-of- casing (BTOC) 91’ - static depth-to-water BTOC 33.71’ = 54.29’ standing water). The area of AFVR influence appears to follow the northeast-southwest strike of the near vertical metamorphic rock foliation. On September 29, 2020, Buxton Environmental, Inc. conducted post 18-hour AFVR #3 groundwater monitoring activities at four (4) shallow monitor wells including MW-1, MW-3, MW-5 and MW-14; and one (1) intermediate depth monitor well MW-1D. The groundwater samples collected at shallow monitor wells MW-1, MW-3, MW-5 and MW-14 indicated the presence of benzene, ethylbenzene, MTBE, toluene and xylenes above NCGQSs. The groundwater sample collected at intermediate depth monitor well MW-1D indicated the presence of benzene, ethylbenzene, MTBE, toluene and xylenes above NCGQSs. The groundwater samples collected MW-1, MW-3, MW-5 and MW-14 also indicated benzene above NCGCLs. The long-term positive effects of AFVR (via: volatilization of residual source area petroleum VOC affected soil and groundwater; increased oxygenation of the aquifer and resulting increase in bioremediation potential (as observed in affected wells following the AFVR events); and the observed radius of AFVR influence (along the preferred petroleum plume pathway and strike of the near vertical metamorphic foliation)) are expected to expedite/enhance the existing natural attenuation remedial approach at the site. However, negative impacts of continued AFVR at the site include recent increases (post AFVR event #1) in petroleum constituents and plume expansion, both vertically at MW- 1D and horizontally at MW-5 and MW-14. Future AFVR events were recommended to be conducted only at monitor well MW-1 to attempt to expedite/enhance the natural attenuation remediation time at the site and pull the petroleum affected ground plume towards the center of the site and source area; and not away from the source area as recently (post-AFVR event #1) indicated at MW-5 and MW-14. From July 28 to August 19, 2021, BEI conducted the installation of monitor well MW-16 and pre- bioaugmentation remediation groundwater monitoring at the former Big Bill’s Place located at 601 Gastonia Highway in Bessemer City, North Carolina. The purposes for conducting these activities were to attempt to delineate the horizontal extent of the northeast side of the petroleum impacted groundwater plume, and to determine current groundwater quality/bio-chemical/physical conditions necessary to properly evaluate, design and implement a bioaugmentation remedial plan to expedite/enhance the approved Natural Attenuation Corrective Action Plan (CAP; approved September 2014) for the site to remediate the residual petroleum affected groundwater constituent benzene historically detected above NCGCLs at on-site monitor wells MW-1, MW-1D, MW-3 and MW-5, and off-site well MW-14. Shallow Type II monitor well MW-16 was installed in the grass right-of-way along the north side of East Maryland Avenue, which is located approximately 465’ north northeast of monitor well MW-1 and along strike of the metamorphic rock foliation and preferred plume migration oriented ~N 15o E. Groundwater sample MW-16 indicated the presence of 230 ug/l benzene and 200 ug/l MTBE, with no exceedances above NCGCLs. Based on these findings, the horizontal extent of petroleum affected groundwater above NCGCL’s appears to now be adequately defined by MW-16. Based on this sampling event and historical data at other monitor wells through October 6, 2015 (Appendix C), the horizontal extent of the BTEX + MTBE affected groundwater plume above NCGQSs is approximately 245’ x 810’ in area and extends from the water table (~40’ below grade +/-) to approximately 90’ below grade (DW-1). Page | 11 The horizontal extent of the benzene affected groundwater plume above NCGCLs is approximately 80’ x 345’ in area and extends from the water table (~40’ below grade +/-) to approximately 60’ below grade (MW-1D). The estimated volume of residual benzene affected groundwater above the NCGCL, which will require remediation, is 1,032,240 gallons (80’ (wide) x 345’ (long) x 20’ (thickness) x 0.25 (estimated porosity of the aquifer) x 7.48 gallons/ft3). According to Monitored Natural Attenuation of BTEX and Other Hydrocarbon Compounds provided in Module Three from www.HowToMNA.com prepared by Land Quality Management, Ltd., conditions within a sites petroleum affected groundwater plume indicate that natural attenuation is occurring based on expected trends in dissolved oxygen (DO decreasing) and ferrous iron (Fe+2 increasing) over time. In addition, a predominate level of DO at or above 1 mg/l within the groundwater plume indicates aerobic conditions, which is most conducive to encourage natural attenuation processes. Low DO and elevated ferrous iron (Fe+2) levels encountered at the site during the July and August 2021 sampling activities indicates evidence of exhausted active natural attenuation, due to anaerobic conditions and elevated Fe+2 that were observed at monitor wells MW-1 (DO=0.48 mg/l; Fe+2=44H mg/l), MW-1D (DO=0.42 mg/l; Fe+2=21H mg/l), MW-3 (DO=0.49 mg/l; Fe+2=18H mg/l), MW-5 (DO=0.45 mg/l; Fe+2=31H mg/l), and MW-14 (DO=0.46 mg/l; Fe+2=5.9H mg/l). However, aerobic conditions and absent Fe+2 levels were encountered at newly installed monitor well MW-16 located on the northeast edge of the petroleum affected groundwater plume (DO=4.48 mg/l; Fe+2=BDL (H)). The H-flag indicates that samples were analyzed by the laboratory outside of the recommended EPA holding time. Based on this and historical data, it appears that elevated petroleum concentrations (which serves as an energy source:food) within the heart of the groundwater plume results in exuberant natural aerobic biologic activity that quickly depletes DO to the point that anaerobic conditions arise and continual aerobic biodegradation becomes stalled (appears to occur at some point in late spring or early summer at the site); however, biodegradation transitions to more favorable aerobic conditions as petroleum concentrations decrease away from the source area, as observed at MW-16. According to a technical protocol concerning MNA of petroleum constituents published by the Florida Department of Environmental Protection (FLDEP), optimum biodegradation of petroleum affected groundwater occurs above 15o Celsius. Therefore, it appears reasonable to expect cyclical seasonal conditions where: DO levels increase/rebound (aerobic conditions return) during cool fall and winter months when aquifer temperature induced biologic activity declines; biologic activity becomes active again with rebounded/renewed DO levels and rising aquifer temperatures in the late winter into spring; DO becomes depleted again (return to anaerobic conditions) following optimum biological conditions in late spring into early summer. The exact time-frames of these cyclical events are currently unknown for the site, and it may be necessary to determine when these transitions occur to optimize bioaugmentation efforts. From May 27 to June 4, 2022, BEI conducted pre-ORC bio-enhancement injection – groundwater monitoring activities at the former Big Bill’s Place located at 601 Gastonia Highway in Bessemer City, North Carolina. These activities were conducted to determine groundwater quality, prior to commencing with the ORC injection pilot study to treat up to approximately 1,000,000 gallons of residual petroleum affected groundwater (currently only benzene) historically detected above the NCGCL at on-site monitor wells MW-1, MW-3 and MW-5, and off-site well MW-14. During this assessment, the aquifer appears to become DO depleted as a result of natural biodegradation processes from April to May each year with rising aquifer temperatures; remains DO depleted from April/May until ~November (natural aerobic biodegradation stifled); then becomes re-oxygenated in the fall through winter with falling aquifer temperatures and slowing active biodegradation activities. Based on this sampling event and historical data at other monitor wells, the horizontal extent of the BTEX + MTBE affected groundwater plume above NCGQSs is approximately 245’ x 810’ in area and extends from the water table (~42’ below grade +/-) to approximately 90’ below grade at DW-1. The horizontal extent of the benzene affected groundwater plume above NCGCLs was approximately 80’ x 280’ in area and extends from the water table (~42’ below grade +/- at MW-1) to approximately 55’ below grade at MW-1D. Each of these plumes are oriented along the near vertical metamorphic rock foliation trending N 15o E. Based on the June 4, 2022 monitoring activities, the estimated volume of residual benzene affected groundwater above the NCGCL is 544,544 gallons (80’ (wide) x 280’ (long) x 13’ (thickness) x 0.25 (estimated porosity of the aquifer) x 7.48 gallons/ft3), which was a 47% reduction from the above NCGCL benzene affected plume estimated at Page | 12 1,032,240 gallons in July/August 2021. The methods, results, conclusions and recommendations of these activities are presented in the June 30, 2022 Pre-ORC Bio-Enhancement Injection – Groundwater Monitoring Activities (May/June 2022) report, which was submitted by BEI to the NCUST for review. On February 6, 2023, BEI collected water levels at monitor wells MW-1 and MW-3, in order to determine current standing water heights for the anticipated ORC injection pilot study. During these activities, monitor wells MW-1 contained 3.25-feet of standing water and MW-3 contained 1.15’. This information was emailed to Mr. Newton, P.G. with the NCUST on February 14, 2023, along with the recommendation to first conduct groundwater sampling for petroleum constituents benzene, ethylbenzene, toluene and xylene (BTEX) at affected monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14 (sample and analysis only), in order to determine current groundwater quality before commencing with the ORC injection pilot study or other remedial options. Mr. Newton and BEI agreed to discuss appropriate steps following receipt of the analytical data. Email correspondence is provided in Appendix A. On April 6, 2023, BEI submitted an email to the NCUST including BTEX groundwater results collected at MW-1, MW-1D, MW-3, MW-5 and MW-14 on March 10, 2023, along with historical groundwater quality data and corresponding BTEX concentration graphs. The BEI email contained several observations, including: 1) benzene is the only remaining petroleum constituent above NCGCLs (the site will be subject for site closure and No Further Action once levels fall below NCGCLs); 2) BTEX concentrations have steadily declined to below NCGCLs at MW-1D and MW-5; 3) BTEX concentrations have steadily declined to just above NCGCLs at MW-1 and MW-14; and 3) MW-3 is the only remaining well with elevated benzene above NCGCLs, however, concentrations are declining. The email proposed several remedial options, including: 1) continue with the approved Monitored Natural Attenuation (MNA) Corrective Action Plan (CAP) (8 years into the projected 17 year clean-up model); 2) install ORC socks at affected wells; and 3) conduct the on-site ORC pilot test, as planned. Based on this information, the NCUST requested that we re-instate the MNA groundwater monitoring approach, unless petroleum constituents begin the rebound significantly in the future. In addition, the NCUST requested that a groundwater monitoring report be prepared and submitted documenting the March 10, 2023 sampling activities. On March 10, 2023, BEI conducted groundwater monitoring activities at four (4) shallow monitor wells including MW-1, MW-3, MW-5 and MW-14; and one (1) intermediate depth monitor well MW-1D at site to determine current groundwater quality, prior to commencing with the planned ORC injection pilot study to treat up to approximately 1,000,000 gallons of residual petroleum affected groundwater (currently only benzene). Based on the findings of this investigation, BEI recommended that semi-annual monitored natural attenuation (MNA) be reinstated and continue to be the preferred remedial approach at the former Big Bill’s Place site, since MNA along with previous AFVR events appear to have and continue to efficiently and cost effectively reduced/reduce residual petroleum affected groundwater at the site. The only petroleum constituent remaining above NCGCLs at the site is benzene, which is steadily decreasing in concentrations at three (3) remaining monitor wells MW-1, MW-3 and MW-14 (off-site well). Site Closure and No Further Action will be requested once the residual petroleum constituents fall below NCGCLs. A copy of the April 19, 2023 Groundwater Monitoring Report (March 2023) was submitted to the NCUST for review. Historical groundwater analytical results for monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14 are provided in Tables 4, 5, 6, 7 and 8, respectively. Page | 13 E. GROUNDWATER MONITORING AT MW-1, MW-3, MW-5, MW-14 & MW-1D On October 8, 2023, BEI conducted groundwater monitoring activities at four (4) shallow monitor wells including MW-1, MW-3, MW-5 and MW-14; and one (1) intermediate depth monitor well MW-1D. Prior to conducting the sampling activities, groundwater levels were obtained from each of these wells (plus MW-4 and MW-6) with a depth-to-water electrode to the nearest 0.01 foot. Following the gauging activities, each well was purged of three well bore volumes of water or until dryness with a disposable PVC bailer attached to new nylon rope. Purge water was poured on the ground surface at the site. Following sampling, field parameters including pH, conductivity, temperature and dissolved oxygen (DO) were determined with appropriately calibrated HANNA-HI 9812-5 and ExTech DO 210 meters (Table 1). DO concentrations at all shallow groundwater monitor wells located within the petroleum plume contained moderate oxygen levels ranging from 2.6 mg/l at MW-3 to 4.8 mg/l at MW-14; which were above the depleted oxygen levels (< 1 mg/l) observed in May and June 2022 (warmer aquifer temperatures). DO concentrations at intermediate depth groundwater monitor well MW-1D contained DO levels at 5.3 mg/l, and were well above the depleted oxygen levels (< 1 mg/l) observed in May and June 2022 (warmer aquifer temperatures). Based on this and historical data, the aquifer appears to become DO depleted as a result of active natural biodegradation processes from April to May each year with rising aquifer temperatures; DO levels remain depleted from April/May until ~September/October; then the aquifer becomes re-oxygenated in the fall through winter as a result of slowing active biodegradation activities caused by falling aquifer temperatures. Optimal aerobic biodegradation conditions (temperature and DO) for natural attenuation of the petroleum affected groundwater plume occurs at the site in the early spring and fall of each year. The groundwater samples were analyzed for target petroleum constituents including benzene, toluene, ethylbenzene and xylenes (BTEX) by EPA Method 8260D. The samples were collected in general accordance with accepted protocol, immediately placed in laboratory supplied containers, appropriately labeled (with sample identification, sample depth, date and time), placed in a cooler with wet ice, transferred to the laboratory with chain-of-custody documentation, and analyzed by Waypoint Analytical Carolina, Inc. (NC Certification No.: 402) in Charlotte, North Carolina. No quality control trip blanks, duplicates or field blanks were collected. Shallow Groundwater Flow Direction Based on groundwater levels collected on October 8, 2023, an oblong low gradient groundwater flow depression (oriented northeast to southwest) was observed within the heart of the on-site petroleum groundwater impacted area, rendering the most impacted portion of the plume immobile. The on-site groundwater flow depression may be the result of recent drought conditions that have persisted for several months prior to the sampling event. Historically, shallow groundwater flow at the site is to the northwest, which is approximately 90 degrees counter to the primary petroleum plume migration (which follows the near vertical northeast to southwest striking metamorphic rock foliation trending N 15o E). The oblong groundwater flow depression observed on October 8, 2023 parallels the vertical metamorphic rock foliation and the primary petroleum plume migration pathway. According to the NOAA drought.gov website, the subject site is currently in a moderate drought. The shallow groundwater flow direction map is provided in Figure 4. A very low horizontal hydraulic gradient of 0.0011 ft/ft was observed between on-site monitor wells MW-6 (groundwater high) to MW-3 (groundwater low and heart of the petroleum affected plume). A low upward vertical hydraulic gradient of 0.0019 ft/ft was observed between shallow monitor well MW-1 and intermediate depth monitor well MW-1D. This upward vertical hydraulic gradient would generally be expected to inhibit downward plume migration. Page | 14 Groundwater Analytical Results Petroleum constituent (BTEX) groundwater analytical results collected on October 8, 2023 at monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14 are presented in Table 3 and are illustrated in Figure 5. The horizontal extent of BTEX + MTBE affected groundwater above NCGQSs (based on this sampling event; and historical data collected at shallow monitor wells MW-1 through MW-16, intermediate depth well MW-1D and deep well DW-1 provided in Appendix C); and the approximate horizontal extent of residual benzene affected groundwater above the NCGCL (based on this sampling event; and historical data as mentioned for the above monitor wells provided in Appendix C) are also illustrated in Figure 5. Historical petroleum constituent groundwater analytical results at monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14 are provided in Tables 4, 5, 6, 7 and 8, respectively. Laboratory data sheets are provided in Appendix D. A summary of petroleum constituent groundwater analytical results, which were detected above NCGQSs (with NCGCL exceedances noted), are summarized below. Groundwater sample MW-1 indicated the presence of 7,830 ug/l benzene (above NCGCL), 3,440 ug/l ethylbenzene, 10,900 ug/l toluene and 20,400 ug/l xylenes. Groundwater sample MW-1D indicated the presence of 3,060 ug/l benzene, 1,660 ug/l ethylbenzene and 4,950 ug/l total xylenes, with no exceedances above NCGCLs. Groundwater sample MW-3 indicated the presence of 12,100 ug/l benzene (above NCGCL), 4,360 ug/l ethylbenzene, 8,560 ug/l toluene and 22,400 ug/l xylenes. Groundwater sample MW-5 indicated the presence of 4,840 ug/l benzene (below NCGCL during last 3 sampling events), 4,480 ug/l ethylbenzene, 1,160 ug/l toluene and 16,800 ug/l total xylenes. Groundwater sample MW-14 indicated the presence of 6,960 ug/l benzene (above NCGCL), 3,800 ug/l ethylbenzene, 18,200 ug/l toluene and 19,300 ug/l xylenes. Based on this sampling event and historical data at other monitor wells, the horizontal extent of the BTEX + MTBE affected groundwater plume above NCGQSs is approximately 245’ (wide) x 810’ (long) in area and extends from the water table (~40’ below grade at MW-1) to ~90’ below grade at DW-1. The horizontal extent of the benzene affected groundwater plume above NCGCLs is approximately 70’ (wide) x 210’ (long) in area and extends from the water table (~40’ below grade at MW-1) to ~55’ below grade at MW-1D (~15’ plume thickness). Each of these plumes are oriented and migrating along the near vertical metamorphic rock foliation trending N 15o E (Figure 5). Based on the October 8, 2023 monitoring activities, the estimated volume of residual benzene affected groundwater above the NCGCL is 412,335 gallons (70’ (wide) x 210’ (long) x 15’ (thickness) x 0.25 (estimated porosity of the aquifer) x 7.48 gallons/ft3)., which is a 25% reduction from the above NCGCL benzene affected plume estimated at 544,544 gallons on June 4, 2022; and a 60% reduction from the above NCGCL benzene affected plume estimated at 1,032,240 gallons in July/August 2021. Page | 15 Historical Trends in Total BTEX A visual evaluation of historical trends in petroleum constituent concentrations of benzene, toluene, ethylbenzene and xylenes (BTEX) and total BTEX was conducted at monitor wells MW-1 (Graph 1), MW-1D (Graph 2), MW-3 (Graph 3), MW-5 (Graph 4) and MW-14 (Graph 5), in order to determine long-term trends and the impacts of remedial activities (monitored natural attenuation (MNA), and AFVR Events #1, #2 & #3) at the site. For reference: AFVR event #1 was conducted March 28-29, 2019; AFVR event #2 was conducted April 23-24, 2020; and AFVR event #3 was conducted September 14-15, 2020. Petroleum concentrations at MW-1 peaked on July 19, 2012 and steadily decreased to an all-time low in July 2021, then began increasing again to present time (Graph 1). The recent increases in petroleum concentrations may be the result of falling water levels caused by recent drought conditions. The AFVR activities which were initiated on March 28-29, 2019 appear to have contributed to a steady improvement in groundwater quality at MW-1. The recent increases in petroleum concentrations may be the result of falling water levels caused by recent drought conditions, which created the oblong low gradient groundwater flow depression (oriented northeast to southwest) observed within the heart of the petroleum affected groundwater plume, rendering this portion of the plume immobile and thus concentrating petroleum affected groundwater levels. Petroleum concentrations at MW-1D peaked on October 6, 2015 and decreased in an erratic fashion to near all- time lows from May 18, 2018 to March 31, 2019 (AFVR event #1 conducted March 28 and 29, 2019), then petroleum concentrations steadily began to increase in an erratic fashion following subsequent AFVR events #2 and #3 (Graph 2). These recent increases in petroleum concentrations at intermediate depth monitor well MW- 1D appear to have been the result of downward petroleum plume migration caused by downward vertical gradients created during AFVR activities. Petroleum concentrations at MW-1D declined to all-time lows during the March 10, 2023 sampling event, then rebounded upward again during this October 8, 2023 sampling event (which may be the result of falling water levels caused by recent drought conditions, creation of the immobile groundwater flow depression and concentration of petroleum affected groundwater. Petroleum concentrations at MW-3 peaked on September 6, 2016 and steadily decreased to all-time lows on May 7, 2020 (following AFVR event #2), then petroleum concentrations slowly began increasing again following AFVR event #3 to until June 4, 2022 (Graph 3). An overall gradual decline in petroleum concentrations have occurred at MW-3 since the September 2016 peak until this October 8, 2023 sampling event. Petroleum concentrations at monitor well MW-5 initially peaked in March 2014 and steadily declined until May 2018 (historic low), then steadily began to increase to an all-time high on May 7, 2020 (following AFVR event #2) (Graph 4). As a result of this increase, monitor well MW-5 was not utilized as an extraction well during AFVR event #3 due to suspected lateral/horizontal plume migration away from the source area caused by previous AFVR activities at the well. Petroleum concentrations subsequently began to decline from their all- time peak on May 7, 2020 until this March 10, 2023 event, following the caseation of extraction from MW-5 during AFVR event #3. No petroleum constituents (namely benzene) were detected above the NCGCL at MW- 5 during the last three (3) sampling events conducted on June 4, 2022, March 10, 2023 and this October 8, 2023 sampling event. Petroleum concentrations at monitor well MW-14 peaked September 6, 2016 and steadily declined until October 31, 2018 (historic low; no BTEX above NCGCLs); then they suddenly increased to stable plateaued concentrations during the last eight (8) sampling events (benzene remained above NCGCL), which followed AFVR events #1, #2 and #3 (Graph 5). The subsequent increases in petroleum concentrations at MW-14 appear to be the result of downward gradients generated at MW-14 during the AFVR events, which are suspected to have resulted in lateral/horizontal plume expansion away from the source area. Page | 16 I. CONCLUSIONS AND RECOMMENDATIONS Conclusions: On October 8, 2023, BEI conducted second semi-annual 2023 groundwater monitoring activities at four (4) shallow monitor wells including MW-1, MW-3, MW-5 and MW-14; and one (1) intermediate depth monitor well MW-1D at the former Big Bill’s Place located at 601 Gastonia Highway in Bessemer City, North Carolina. These activities were conducted to determine current groundwater quality, and determine the effectiveness of continuation of the approved Natural Attenuation CAP (approved September 2014) at the site to treat up to approximately 1,000,000 gallons of residual petroleum affected groundwater (currently only benzene) historically detected above the NCGCL at on-site monitor wells MW-1, MW-3 and MW-5, and off-site well MW-14. These activities were conducted in general accordance with NCUST guidelines, conversations with Mr. Brad Newton, P.G. (NCUST project manager), and the May 3, 2023 NORR from the NCUST requesting the resumption of the approved Natural Attenuation CAP and previously established semi-annual groundwater monitoring at the site. The incident at the site is associated with releases from three closed in-place gasoline UST systems including one 3,000-gallon gasoline UST, two 4,000-gallon gasoline UST’s, associated piping and three dispensers. • DO concentrations at all shallow groundwater monitor wells located within the petroleum plume contained moderate oxygen levels ranging from 2.6 mg/l at MW-3 to 4.8 mg/l at MW-14; which were above the depleted oxygen levels (< 1 mg/l) observed in May and June 2022 (warmer aquifer temperatures). DO concentrations at intermediate depth groundwater monitor well MW-1D contained DO levels at 5.3 mg/l, and were well above the depleted oxygen levels (< 1 mg/l) observed in May and June 2022 (warmer aquifer temperatures). Based on this and historical data, the aquifer appears to become DO depleted as a result of active natural biodegradation processes from April to May each year with rising aquifer temperatures; DO levels remain depleted from April/May until ~September/October; then the aquifer becomes re-oxygenated in the fall through winter as a result of slowing active biodegradation activities caused by falling aquifer temperatures. Optimal aerobic biodegradation conditions (temperature and DO) for natural attenuation of the petroleum affected groundwater plume occurs at the site in the early spring and fall of each year. • Based on groundwater levels collected on October 8, 2023, an oblong low gradient groundwater flow depression (oriented northeast to southwest) was observed within the heart of the on-site petroleum groundwater impacted area, rendering the most impacted portion of the plume immobile. The groundwater flow depression may be the result of recent drought conditions that have persisted for several months prior to the sampling event. According to the NOAA drought.gov website, the subject site is currently in a moderate drought. Historically, shallow groundwater flow at the site is to the northwest, which is approximately 90 degrees counter to the primary petroleum plume migration (which follows the near vertical northeast to southwest striking metamorphic rock foliation trending N 15o E). The oblong groundwater flow depression observed on October 8, 2023 parallels the vertical metamorphic rock foliation and the primary petroleum plume migration pathway. • A very low horizontal hydraulic gradient of 0.0011 ft/ft was observed between on-site monitor wells MW-6 (groundwater high) to MW-3 (groundwater low and heart of the petroleum affected plume). A low upward vertical hydraulic gradient of 0.0019 ft/ft was observed between shallow monitor well MW- 1 and intermediate depth monitor well MW-1D. This upward vertical hydraulic gradient would generally be expected to inhibit downward plume migration. Page | 17 • A summary of petroleum constituent groundwater analytical results, which were detected above NCGQSs (with NCGCL exceedances noted), are summarized below. Groundwater sample MW-1 indicated the presence of 7,830 ug/l benzene (above NCGCL), 3,440 ug/l ethylbenzene, 10,900 ug/l toluene and 20,400 ug/l xylenes. Groundwater sample MW-1D indicated the presence of 3,060 ug/l benzene, 1,660 ug/l ethylbenzene and 4,950 ug/l total xylenes, with no exceedances above NCGCLs. Groundwater sample MW-3 indicated the presence of 12,100 ug/l benzene (above NCGCL), 4,360 ug/l ethylbenzene, 8,560 ug/l toluene and 22,400 ug/l xylenes. Groundwater sample MW-5 indicated the presence of 4,840 ug/l benzene (below NCGCL during last 3 sampling events), 4,480 ug/l ethylbenzene, 1,160 ug/l toluene and 16,800 ug/l total xylenes. Groundwater sample MW-14 indicated the presence of 6,960 ug/l benzene (above NCGCL), 3,800 ug/l ethylbenzene, 18,200 ug/l toluene and 19,300 ug/l xylenes. • Based on this sampling event and historical data at other monitor wells, the horizontal extent of the BTEX + MTBE affected groundwater plume above NCGQSs is approximately 245’ (wide) x 810’ (long) in area and extends from the water table (~40’ below grade at MW-1) to ~90’ below grade at DW-1. The horizontal extent of the benzene affected groundwater plume above NCGCLs is approximately 70’ (wide) x 210’ (long) in area and extends from the water table (~40’ below grade at MW-1) to ~55’ below grade at MW-1D (~15’ plume thickness). Each of these plumes are oriented and migrating along the near vertical metamorphic rock foliation trending N 15o E (Figure 5). Based on the October 8, 2023 monitoring activities, the estimated volume of residual benzene affected groundwater above the NCGCL is 412,335 gallons (70’ (wide) x 210’ (long) x 15’ (thickness) x 0.25 (estimated porosity of the aquifer) x 7.48 gallons/ft3)., which is a 25% reduction from the above NCGCL benzene affected plume estimated at 544,544 gallons on June 4, 2022; and a 60% reduction from the above NCGCL benzene affected plume estimated at 1,032,240 gallons in July/August 2021. • A visual evaluation of historical trends in petroleum constituent concentrations of benzene, toluene, ethylbenzene and xylenes (BTEX) and total BTEX was conducted at monitor wells MW-1, MW-1D, MW-3, MW-5 and MW-14. • Petroleum concentrations at MW-1 peaked on July 19, 2012 and steadily decreased to an all-time low in July 2021, then began increasing again to present time. The recent increases in petroleum concentrations may be the result of falling water levels caused by recent drought conditions. The AFVR activities which were initiated on March 28-29, 2019 appear to have contributed to a steady improvement in groundwater quality at MW-1. The recent increases in petroleum concentrations may be the result of falling water levels caused by recent drought conditions, which created the oblong low gradient groundwater flow depression (oriented northeast to southwest) observed within the heart of the petroleum affected groundwater plume, rendering this portion of the plume immobile and thus concentrating petroleum affected groundwater levels. • Petroleum concentrations at MW-1D peaked on October 6, 2015 and decreased in an erratic fashion to near all-time lows from May 18, 2018 to March 31, 2019 (AFVR event #1 conducted March 28 and 29, 2019), then petroleum concentrations steadily began to increase in an erratic fashion following subsequent AFVR events #2 and #3. These recent increases in petroleum concentrations at intermediate depth monitor well MW-1D appear to have been the result of downward petroleum plume migration caused by downward vertical gradients created during AFVR activities. Petroleum concentrations at MW-1D declined to all-time lows during the March 10, 2023 sampling event, then rebounded upward again during this October 8, 2023 sampling event (which may be the result of falling water levels caused by recent drought conditions, creation of the immobile groundwater flow depression and concentration of petroleum affected groundwater. Page | 18 • Petroleum concentrations at MW-3 peaked on September 6, 2016 and steadily decreased to all-time lows on May 7, 2020 (following AFVR event #2), then petroleum concentrations slowly began increasing again following AFVR event #3 to until June 4, 2022. An overall gradual decline in petroleum concentrations have occurred at MW-3 since the September 2016 peak until this October 8, 2023 sampling event. • Petroleum concentrations at monitor well MW-5 initially peaked in March 2014 and steadily declined until May 2018 (historic low), then steadily began to increase to an all-time high on May 7, 2020 (following AFVR event #2). As a result of this increase, monitor well MW-5 was not utilized as an extraction well during AFVR event #3 due to suspected lateral/horizontal plume migration away from the source area caused by previous AFVR activities at the well. Petroleum concentrations subsequently began to decline from their all-time peak on May 7, 2020 until this March 10, 2023 event, following the caseation of extraction from MW-5 during AFVR event #3. No petroleum constituents (namely benzene) were detected above the NCGCL at MW-5 during the last three (3) sampling events conducted on June 4, 2022, March 10, 2023 and this October 8, 2023 sampling event. • Petroleum concentrations at monitor well MW-14 peaked September 6, 2016 and steadily declined until October 31, 2018 (historic low; no BTEX above NCGCLs); then they suddenly increased to stable plateaued concentrations during the last eight (8) sampling events (benzene remained above NCGCL), which followed AFVR events #1, #2 and #3. The subsequent increases in petroleum concentrations at MW-14 appear to be the result of downward gradients generated at MW-14 during the AFVR events, which are suspected to have resulted in lateral/horizontal plume expansion away from the source area. Page | 19 Recommendations: • Based on the findings of this investigation, BEI recommends that semi-annual monitored natural attenuation (MNA) groundwater sampling continue be conducted as the remedial approach at the former Big Bill’s Place site. Site Closure and No Further Action will be requested once the residual petroleum constituents fall below NCGCLs. The next semi-annual MNA sampling event will be conducted in March 2024. • A copy of this report should be submitted to the NCUST for their review. If you have any further questions concerning these matters, please call me at (704) 906-4994. Sincerely, Buxton Environmental, Inc. Ross Klingman, P.G. FIGURES TABLES TABLE 1 MONITOR WELL AND GROUNDWATER GAUGING INFORMATION FORMER BIG BILL'S PLACE 601 GASTONIA HIGHWAY BESSEMER CITY, NORTH CAROLINA INCIDENT NO.: 16417 OCTOBER 8, 2023 Well ID TOC Elevation Ground Elevation TD BTOC Well Diamater Screen Length DTW BTOC Product Thickness Groundwater Elevation (feet) (feet)(feet)(inches)(feet)(feet)(feet)(feet) MW-1 100.00 100.31 46.45 2 15 42.68 NP 57.32 MW-1D 99.50 99.79 61.63 2 5 42.15 NP 57.35 MW-3 97.99 98.40 42.35 2 15 40.69 NP 57.30 MW-4 96.58 97.00 42.3 2 15 39.19 --57.39 MW-5 99.24 99.59 60 2 20 41.93 NP 57.31 MW-6 99.90 100.25 60 2 20 42.41 --57.49 MW-14 98.50 98.85 50 2 20 41.11 NP 57.39 Notes: Monitor well MW-1 installed on May 7, 1998 by ECS, Inc. of Charlotte, NC. Monitor wells MW-1D, MW-2, MW-3 and MW-4 were installed on August 11 and 12, 1998 by SAEDACCO, Inc. of Fort Mill, SC. Monitor wells DW-1, MW-5, MW-6 and MW-7 installed in December 2001 by SAEDACCO, Inc. of Fort Mill, SC. Monitor wells MW-8, MW-9 and MW-10 installed on January 2 and 3, 2013 by SAEDACCO, Inc. of Fort Mill, SC. Monitor well MW-14 installed July 10 and 11, 2013 by SAEDACCO, Inc. of Fort Mill, SC. Monitor well MW-16 installed August 17, 2021 by IET of Concord, NC. Depth to groundwater measurments collected by Buxton Environmental, Inc. on June 4, 2022 with depth-to-water meter. Top of casing and ground surface elevations surveyed by Buxton Environmental, Inc., using monitor well MW-1 TOC as 100.00' datum. TOC = top of casing BTOC = below top of casing DTW = depth to water TD = total depthNP = no measurable gasoline free product observed during well purging/sampling activities on October 8, 2023 TABLE 2 MONITORED NATURAL ATTENUATION - GROUNDWATER PARAMETER DATA FORMER BIG BILL'S PLACE 601 GASTONIA HIGHWAY BESSEMER CITY, NORTH CAROLINA INCIDENT NO.: 16417 OCTOBER 8, 2023 Well ID MW-1 MW-1D MW-3 MW-5 MW-14 Field Parameters pH (standard units)6.43 6.48 6.15 6.60 6.55 Conductivity (uS/cm)470 240 440 410 500 Temperature (Celsius)20.5 23.6 22.3 20.7 20.1 Dissolved Oxygen (DO) (mg/l)2.8 5.3 2.6 3.9 4.8 Notes: Field parameters pH, conductivity & temperature obtained with a calibrated HANNA Instuments-HI 9812-5 meter; and DO obtained with an ExTech DO 210 meter. uS/cm = microsiemens per centimeter mg/l = milligrams per liter TABLE 3 PETROLEUM CONSTITUENTS - GROUNDWATER ANALYTICAL RESULTS FORMER BIG BILL'S PLACE 601 GASTONIA HIGHWAY BESSEMER CITY, NORTH CAROLINA INCIDENT NO.: 16417 OCTOBER 8, 2023 Well ID MW-1 MW-1D MW-3 MW-5 MW-14 NCGQS NCGCL EPA Method 8260D (BTEX)(ug/l) Benzene 7,830 3,060 12,100 4,840 6,960 1 5,000 Ethylbenzene 3,440 1,660 4,360 4,480 3,800 600 84,500 Toluene 10,900 462 8,560 1,160 18,200 600 260,000 Xylenes (total)20,400 4,950 22,400 16,800 19,300 500 85,500 Notes: Groundwater sample collected at MW-1, MW-1D, MW-3, MW-5 and MW-14 on October 8, 2023 and analyzed for benzene, ethylbenzene, toluene & xylenes (BTEX) by EPA Method 8260D by Pace Analytical Services, Inc. (NC Certification No.: 329) Prior to sampling, wells purged of 3 well volumes of water with a bailer BDL = below detection limit; NS = no standard all data presented in ug/l = micrograms per liter NCGQS = 2L North Carolina Groundwater Quality Standard NCGCL = North Carolina Gross Contamination Levels in Groundwater; * = estimated NCGCL (no established NCGCL) (1,000 x NCGQS) Bold denotes above NCGQS Shade denotes above NCGCL (only shaded if NCGCL has been established)J = estimated result <LOQ or PQL and >=MDL TABLE 4 HISTORICAL PETROLEUM CONSTITUENT GROUNDWATER ANALYTICAL RESULTS, MONITOR WELL MW-1 FORMER BIG BILL'S PLACE 601 GASTONIA HIGHWAY BESSEMER CITY, NORTH CAROLINA INCIDENT NO.: 16417 Well ID NCGQS NCGCLSample Date 5/11/98 7/19/12 1/28/14 3/18/15 10/16/15 9/6/16 9/28/17 5/18/18 10/31/18 3/31/19*9/23/19 5/7/20*9/29/20*7/28/21 6/4/22 3/10/23 10/8/23 VOC's (ug/l)Acetone NT BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 6,000 6,000,000 Benzene 9,900 15,000 13,000 12,000 NT NT NT 17,000 14,000 8,700 9,000 9,100 6,100 5,100 5,900 6,900 7,830 1 5,000BromodichloromethaneNTBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.6 600** 2-Butanone NT BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 4,000 4,000,000n-Butylbenzene NT BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 6,900sec-Butylbenzene NT 6,800 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 8,500 Chloroform BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,0001,2-Dichloroethane BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.4 400cis-1,2-Dichloroethene NT BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,000 1,2-Dichloropropane BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.6 600Ethylbenzene2,900 4,400 3,600 3,600 NT NT NT 4,300 4,300 2,900 3,600 3,500 2,800 2,000 2,500 2,300 3,440 600 84,500 EDB 72 BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.02 50 2-Hexanone NT 620 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 40 40,000Isopropyl Ether (IPE)290 BDL 170J NT NT NT NT 220J NT NT NT NT NT NT NT NT NT 70 70,000 Isopropylbenzene NT BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 25,000 p-Isopropyltoluene NT BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 25 11,700Methyl Isobutyl Ketone NT BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 100 100,000 Methyl-Tert-Butyl-Ether 7,600 35,000 16,000 16,000 NT NT NT 25,000 22,000 5,300 5,700 6,100 2,500 1,100 3,500 NT NT 20 20,000NaphthaleneNT920NT760NTNTNT8601,000 NT NT NT NT NT NT NT NT 6 6,000n-Propylbenzene NT 630 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 30,000 Styrene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,000TetrachloroetheneBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.7 700Toluene22,000 9,400 11,000 6,800 NT NT NT 9,200 8,500 18,000 6,400 6,300 6,300 6,100 3,100 3,400 10,900 600 260,000 Trichloroethene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 3 3,0001,2,3-Trichloropropane BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.005 5** 1,2,4-Trimethylbenzene NT 4,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 28,500 1,3,5-Trimethylbenzene NT 1,100 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 20400 400 25,000Xylenes (total)15,000 25,000 22,000 20,000 NT NT NT 23,000 24,000 16,000 20,000 21,000 16,000 12,000 15,000 16,000 20,400 500 85,500 Total BTEX 49,800 53,800 49,600 42,400 NT NT NT 53,500 50,800 45,600 39,000 39,900 31,200 25,200 26,500 28,600 42,570 NS NS MADEP - VPH (ug/l) C5-C8 Aliphatics 70,000 73,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 400,000**C9-C12 Aliphatics 46,100 6,200 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 700 700,000** C9-C10 Aromatics 12,400 15,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 200 200,000** EPA 3030C Lead (ug/l)5 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 15 15,000 Notes: VOCs = volatile organic compounds; BDL = below detection limit; NS = no standard; NT = not tested; EDB = ethylene dibromide all data presented in ug/l = micrograms per liter NCGQS = North Carolina Groundwater Quality Standard NCGCL = North Carolina Gross Contamination Levels in Groundwater; ** = estimated NCGCL (no established NCGCL) (1,000 x NCGQS) J = estimated result (<Reporting Limit and >=Method Detection Limit; J-flagged groundwater data exceeding the NCGQS does not constitute an exceedance. * = sampling on 3/31/19, 5/7/20 and 9/29/20 were conducted post AFVR, which occurred on 3/28-29/19 (MW-1, 3 & 5), 4/24-25/20 (MW-1, 3 & 5) and 9/14-15/20 (MW-1 & 3), respectively. Bold denotes above NCGQS Shade denotes above NCGCL (only shaded if NCGCL has been established) MW-1 Well ID NCGQS NCGCLSample Date 8/18/98 7/31/00 7/19/12 1/28/14 3/18/15 10/6/15 9/6/16 9/28/17 5/18/18 10/31/18 3/31/19*9/23/19 5/7/20*9/29/20*7/28/21 6/4/22 3/10/23 10/8/23 VOC's (ug/l)Acetone NT BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 6,000 6,000,000 Benzene 4,920 5,120 7,100 3,400 3,200 6,800 3,600 4,800 510 960 330 3,700 1,900 3,400 2,600 610 360 3,060 1 5,000BromodichloromethaneNTBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.6 600** 2-Butanone NT BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 4,000 4,000,000n-Butylbenzene 12.3 BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 6,900sec-Butylbenzene 12.2 7.1 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 8,500 Chloroform 1.32 BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,0001,2-Dichloroethane 26.5 25.2 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.4 400cis-1,2-Dichloroethene 5.07 5.9 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,000 1,2-Dichloropropane BDL BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.6 600Ethylbenzene6855701,800 670 630 2,100 1,300 1,700 110 180 41 1,300 370 1,500 1,100 110 63 1,660 600 84,500 EDB 1.36 BDL BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.02 50 2-Hexanone NT BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 40 40,000Isopropyl Ether (IPE)46.8 44 BDL 55J NT NT NT NT 27J NT NT NT NT NT NT NT NT NT 70 70,000 Isopropylbenzene 59.5 54 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 25,000 p-Isopropyltoluene 7.27 3.5 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 25 11,700Methyl Isobutyl Ketone NT BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 100 100,000 Methyl-Tert-Butyl-Ether 2,470 2,300 5,000 6,200 4,200 4,200 3,400 3,000 2,100 1,900 800 2,600 2,400 2,000 1,000 860 S NT NT 20 20,000Naphthalene196124500NT180J50032040038J36JNTNTNTNTNTNTNTNT66,000n-Propylbenzene 194 79 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 30,000 Styrene BDL 0.5 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,000Tetrachloroethene6.9 1.8 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.7 700Toluene1,920 700 1,600 110 120 1,600 960 560 7.8J 31 15 1,400 150 1,000 730 9.9 4J 462 600 260,000 Trichloroethene 13.7 17 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 3 3,0001,2,3-Trichloropropane BDL 7 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.005 5** 1,2,4-Trimethylbenzene 450 282 1,300 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 28,500 1,3,5-Trimethylbenzene 295 94 360 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 25,000Xylenes (total)2,470 663 6,600 1,600 1,300 7,300 6,800 5,000 100 310 79 4,500 800 5,200 3,900 90 14 4,950 500 85,500 Total BTEX 9,995 7,053 17,100 5,780 5,250 17,800 12,660 12,060 727.8 1,481 465 10,900 3,220 11,100 8,330 820 441 10,132 NS NS MADEP - VPH (ug/l) C5-C8 Aliphatics 6,400 NT 22,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 400,000**C9-C12 Aliphatics 8,190 NT 9,400 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 700 700,000** C9-C10 Aromatics 1,320 NT 4,200 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 200 200,000** EPA 3030C Lead (ug/l)BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 15 15,000 Notes: VOCs = volatile organic compounds; BDL = below detection limit; NS = no standard; NT = not tested; EDB = ethylene dibromide all data presented in ug/l = micrograms per liter NCGQS = North Carolina Groundwater Quality Standard NCGCL = North Carolina Gross Contamination Levels in Groundwater; ** = estimated NCGCL (no established NCGCL) (1,000 x NCGQS) J = estimated result (<Reporting Limit and >=Method Detection Limit; J-flagged groundwater data exceeding the NCGQS does not constitute an exceedance. * = sampling on 3/31/19, 5/7/20 and 9/29/20 were conducted post AFVR, which occurred on 3/28-29/19 (MW-1, 3 & 5), 4/24-25/20 (MW-1, 3 & 5) and 9/14-15/20 (MW-1 & 3), respectively. Bold denotes above NCGQS Shade denotes above NCGCL (only shaded if NCGCL has been established) MW-1D TABLE 5 HISTORICAL PETROLEUM CONSTITUENT GROUNDWATER ANALYTICAL RESULTS, MONITOR WELL MW-1D FORMER BIG BILL'S PLACE 601 GASTONIA HIGHWAY BESSEMER CITY, NORTH CAROLINA INCIDENT NO.: 16417 TABLE 6 HISTORICAL PETROLEUM CONSTITUENT GROUNDWATER ANALYTICAL RESULTS, MONITOR WELL MW-3 FORMER BIG BILL'S PLACE 601 GASTONIA HIGHWAY BESSEMER CITY, NORTH CAROLINA INCIDENT NO.: 16417 Well ID NCGQS NCGCL Sample Date 8/18/98 7/19/12 1/28/14 3/18/15 10/6/15 9/6/16 9/28/17 5/18/18 10/31/18 3/31/19*9/23/19 5/7/20*9/29/20*7/28/21 6/4/22 3/10/23 10/8/23 VOCs (ug/l)Acetone NT 6,400 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 6,000 6,000,000 Benzene 16,400 10,000 22,000 22,000 21,000 16,000 17,000 17,000 NT 8,800 12,000 6,600 11,000 10,000 15,000 12,000 12,100 1 5,000BromodichloromethaneNTBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.6 600*2-Butanone NT 2,500 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 4,000 4,000,000 n-Butylbenzene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 6,900sec-Butylbenzene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 8,500ChloroformBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000 1,2-Dichloroethane 125 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.4 400cis-1,2-Dichloroethene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,0001,2-Dichloropropane BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.6 600 Ethylbenzene 2,190 1,600 4,400 4,500 4,000 3,200 4,400 4,440 NT 3,400 4,500 3,200 4,100 3,500 4,100 3,800 4,360 600 84,500EDB62BDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.02 50 2-Hexanone NT 680 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 40 40,000 Isopropyl Ether (IPE)142 BDL 230J NT NT NT NT 130J NT NT NT NT NT NT NT NT NT 70 70,000Isopropylbenzene91BDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT7025,000 p-Isopropyltoluene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 25 11,700Methyl Isobutyl Ketone NT 260J NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 100 100,000Methyl-Tert-Butyl-Ether 3,920 19,000 24,000 23,000J 17,000 16,000 12,000 8,800 NT 6,100 5,600 2,100 5,100 2,200 6,300 NT NT 20 20,000 Naphthalene 3,100 360J NT 730 650 1,000 860 720 NT NT NT NT NT NT NT NT NT 6 6,000n-Propylbenzene 258 BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 30,000StyreneBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000 Tetrachloroethene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.7 700Toluene10,000 15,000 15,000 17,000 BDL 18,000 25,000 24,000 NT 24,000 26,000 7,900 18,000 23,000 10,000 10,000 8,560 600 260,000 Trichloroethene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 3 3,000 1,2,3-Trichloropropane BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.005 5*1,2,4-Trimethylbenzene 1,940 1,300 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 28,500 1,3,5-Trimethylbenzene 465 340 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 25,000 Xylenes (total)11,040 9,000 23,000 24,000 24,000 37,000 19,000 24,000 NT 18,000 23,000 14,000 22,000 20,000 21,000 20,000 22,400 500 85,500 Total BTEX 39,630 35,600 64,400 67,500 66,000 74,200 65,400 69,440 NT 54,200 65,500 31,700 55,100 56,500 50,100 45,800 47,420 NS NS MADEP - VPH (ug/l)C5-C8 Aliphatics 15,000 100,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 400,000* C9-C12 Aliphatics 19,100 15,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 700 700,000*C9-C10 Aromatics 5,870 11,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 200 200,000* EPA 3030C Lead (ug/l)BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 15 15,000 Notes: VOCs = volatile organic compounds; BDL = below detection limit; NS = no standard; NT = not tested; EDB = ethylene dibromide all data presented in ug/l = micrograms per liter NCGQS = North Carolina Groundwater Quality Standard NCGCL = North Carolina Gross Contamination Levels in Groundwater; * = estimated NCGCL (no established NCGCL) (1,000 x NCGQS) J = estimated result (<Reporting Limit and >=Method Detection Limit; J-flagged groundwater data exceeding the NCGQS does not constitute an exceedance. * = sampling on 3/31/19, 5/7/20 and 9/29/20 were conducted post AFVR, which occurred on 3/28-29/19 (MW-1, 3 & 5), 4/24-25/20 (MW-1, 3 & 5) and 9/14-15/20 (MW-1 & 3), respectively. Bold denotes above NCGQS Shade denotes above NCGCL (only shaded if NCGCL has been established) MW-3 Well ID NCGQS NCGCL Sample Date 10/19/12 1/28/14 3/18/15 10/6/15 9/6/16 9/28/17 5/18/18 10/31/18 3/31/19*9/23/19 5/7/20*9/29/20*7/28/21 6/4/22 3/10/23 10/8/23 VOCs (ug/l)Acetone BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 6,000 6,000,000 Benzene 9,900 6,800 8,700 5,800 3,800 5,900 3,000 6,600 5,200 6,200 11,000 6,000 6,000 4,800 3,600 4,840 1 5,000BromodichloromethaneBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.6 600**2-Butanone BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 4,000 4,000,000 n-Butylbenzene BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 6,900sec-Butylbenzene BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 8,500ChloroformBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000 1,2-Dichloroethane BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.4 400cis-1,2-Dichloroethene BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,0001,2-Dichloropropane BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.6 600 Ethylbenzene 4,300 3,500 4,000 2,800 2,300 3,100 1,400 3,600 3,200 4,300 4,100 4,500 4,500 3,700 3,600 4,480 600 84,500EDBBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.02 50 2-Hexanone 55J NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 40 40,000 Isopropyl Ether (IPE)BDL BDL NT NT NT NT 28J NT NT NT NT NT NT NT NT NT 70 70,000Isopropylbenzene220NTNTNTNTNTNTNTNTNTNTNTNTNTNTNT7025,000 p-Isopropyltoluene BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 25 11,700Methyl Isobutyl Ketone 96J NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 100 100,000Methyl-Tert-Butyl-Ether 1,500 1,300 2,100 1,600 2,000 1,300 1,600 1,600 2,000 1,400 4,400 1,400 1,000 1,100 NT NT 20 20,000 Naphthalene 1,200 NT 720 660 520 710 410 850 NT NT NT NT NT NT NT NT 6 6,000n-Propylbenzene 620 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 30,000StyreneBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000 Tetrachloroethene BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.7 700Toluene6,300 6,400 9,400 3,400 2,000 1,900 760 1,800 3,900 6,800 23,000 5,000 4,100 3,400 1,400 1,160 600 260,000 Trichloroethene BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 3 3,000 1,2,3-Trichloropropane BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.005 5**1,2,4-Trimethylbenzene 4,300 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 28,500 1,3,5-Trimethylbenzene 1,100 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 25,000 Xylenes (total)19,000 20,000 21,000 13,000 11,200 10,000 4,900 13,000 14,000 19,000 23,000 22,000 22,000 16,000 17,000 16,800 500 85,500 Total BTEX 39,500 36,700 43,100 25,000 19,300 20,900 10,060 25,000 26,300 36,300 61,100 37,500 36,600 27,900 25,600 27,280 NS NS MADEP - VPH (ug/l)C5-C8 Aliphatics 45,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 400,000** C9-C12 Aliphatics 7,100 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 700 700,000**C9-C10 Aromatics 17,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 200 200,000** EPA 3030C Lead (ug/l)NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 15 15,000 Notes: VOCs = volatile organic compounds; BDL = below detection limit; NS = no standard; NT = not tested; EDB = ethylene dibromide all data presented in ug/l = micrograms per liter NCGQS = North Carolina Groundwater Quality Standard NCGCL = North Carolina Gross Contamination Levels in Groundwater; ** = estimated NCGCL (no established NCGCL) (1,000 x NCGQS) J = estimated result (<Reporting Limit and >=Method Detection Limit; J-flagged groundwater data exceeding the NCGQS does not constitute an exceedance. * = sampling on 3/31/19, 5/7/20 and 9/29/20 were conducted post AFVR, which occurred on 3/28-29/19 (MW-1, 3 & 5), 4/24-25/20 (MW-1, 3 & 5) and 9/14-15/20 (MW-1 & 3), respectively. Bold denotes above NCGQS Shade denotes above NCGCL (only shaded if NCGCL has been established) MW-5 TABLE 7 HISTORICAL PETROLEUM CONSTITUENT GROUNDWATER ANALYTICAL RESULTS, MONITOR WELL MW-5 FORMER BIG BILL'S PLACE 601 GASTONIA HIGHWAY BESSEMER CITY, NORTH CAROLINA INCIDENT NO.: 16417 TABLE 8 HISTORICAL PETROLEUM CONSTITUENT GROUNDWATER ANALYTICAL RESULTS, MONITOR WELL MW-14 FORMER BIG BILL'S PLACE 601 GASTONIA HIGHWAY BESSEMER CITY, NORTH CAROLINA INCIDENT NO.: 16417 Well ID MW-14 NCGQS NCGCL Sample Date 7/12/13 1/28/14 3/18/15 9/6/16 9/28/17 5/18/18 10/31/18 3/31/19*9/23/19 5/7/20*9/29/20*7/28/21 6/4/22 3/10/23 10/8/23 VOCs (ug/l) Acetone BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 6,000 6,000,000Benzene6,700 9,300 9,400 5,300 7,100 7,800 4,500 6,800 8,400 7,100 6,700 7,000 7,800 5,300 6,960 1 5,000 Bromodichloromethane BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.6 600*2-Butanone BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 4,000 4,000,000n-Butylbenzene 60 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 6,900 sec-Butylbenzene 48 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 8,500ChloroformBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,0001,2-Dichloroethane 17 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.4 400 cis-1,2-Dichloroethene BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,0001,2-Dichloropropane BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.6 600 Ethylbenzene 3,300 3,300 3,400 2,800 3,200 3,600 1,900 3,600 3,400 3,400 3,600 3,100 3,600 3,400 3,800 600 84,500 EDB BDL 85J NT NT NT NT NT NT NT NT NT NT NT NT NT 0.02 502-Hexanone 55 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 40 40,000 Isopropyl Ether (IPE)45 BDL NT NT NT 46J NT NT NT NT NT NT NT NT NT 70 70,000 Isopropylbenzene 180 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 25,000p-Isopropyltoluene 36 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 25 11,700 Methyl Isobutyl Ketone 28 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 100 100,000Methyl-Tert-Butyl-Ether 3,300 5,300 5,400 5,300 4,400 2,300 1,800 4,600 5,100 3,000 3,400 2,900 2,600 NT NT 20 20,000Naphthalene910NT980860790670770NTNTNTNTNTNTNTNT66,000 n-Propylbenzene 550 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 30,000StyreneBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000TetrachloroetheneBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.7 700 Toluene 11,000 17,000 20,000 16,000 11,000 10,000 7,100 17,000 20,000 21,000 20,000 20,000 22,000 20,000 18,200 600 260,000Trichloroethene9JNTNTNTNTNTNTNTNTNTNTNTNTNTNT33,000 1,2,3-Trichloropropane BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 0.005 5* 1,2,4-Trimethylbenzene 3,700 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 28,5001,3,5-Trimethylbenzene 950 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 25,000 Xylenes (total)18,000 18,000 18,000 32,000 15,000 20,000 9,500 19,000 17,000 18,000 19,000 17,000 19,000 19,000 19,300 500 85,500 Total BTEX 39,000 47,600 50,800 56,100 36,300 41,400 23,000 46,400 48,800 49,500 49,300 47,100 52,400 47,700 48,260 NS NS MADEP - VPH (ug/l)C5-C8 Aliphatics 32,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 400 400,000* C9-C12 Aliphatics 16,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 700 700,000* C9-C10 Aromatics 12,000 NT NT NT NT NT NT NT NT NT NT NT NT NT NT 200 200,000* EPA 3030C Lead (ug/l)NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT 15 15,000 Notes: VOCs = volatile organic compounds; BDL = below detection limit; NS = no standard; NT = not tested; EDB = ethylene dibromide all data presented in ug/l = micrograms per liter NCGQS = North Carolina Groundwater Quality Standard NCGCL = North Carolina Gross Contamination Levels in Groundwater; ** = estimated NCGCL (no established NCGCL) (1,000 x NCGQS) J = estimated result (<Reporting Limit and >=Method Detection Limit; J-flagged groundwater data exceeding the NCGQS does not constitute an exceedance. * = sampling on 3/31/19, 5/7/20 and 9/29/20 were conducted post AFVR, which occurred on 3/28-29/19 (MW-1, 3 & 5), 4/24-25/20 (MW-1, 3 & 5) and 9/14-15/20 (MW-1 & 3), respectively. Bold denotes above NCGQS Shade denotes above NCGCL (only shaded if NCGCL has been established) GRAPHS 5/7/209/29/207/28/21Total BTEX 5/11/98 7/19/12 1/28/14 3/18/15 5/18/18 10/31/18 3/31/19*9/23/19 5/7/20 9/29/20 7/28/21 6/4/22 Benzene Ethylbenzene #REF!Toluene Xylenes (total)Total BTEX 0 10,000 20,000 30,000 40,000 50,000 60,000 7/19/121/28/143/18/155/18/1810/31/183/31/19*9/23/195/7/209/29/207/28/216/4/223/10/2310/8/23ug/lDate Graph 1. Historical BTEX and Total BTEX Concentrations MW-1 Benzene Ethylbenzene Toluene Xylenes (total)Total BTEX 9/28/175/18/1810/31/183/31/19*9/23/195/7/209/29/20Toluene Xylenes (total)Total BTEX 1/28/143/18/1510/6/159/6/169/28/175/18/1810/31/183/31/19*9/23/195/7/209/29/207/28/21Ethylbenzene #REF!Toluene Xylenes (total)Total BTEX 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 90,000 100,000 ug/lGraph 2. Historical BTEX + MTBE; and Total BTEX + MTBE Concentrations MW-1D Benzene Ethylbenzene #REF!Toluene Xylenes (total)Total BTEX 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 7/31/007/19/121/28/143/18/1510/6/159/6/169/28/175/18/1810/31/183/31/19*9/23/195/7/209/29/207/28/216/4/223/10/2310/8/23ug/lDate Graph 2. Historical BTEX and Total BTEX Concentrations MW-1D Benzene Ethylbenzene Toluene Xylenes (total)Total BTEX 9/6/169/28/175/18/183/31/19*9/23/195/7/209/29/20#REF!Toluene Xylenes (total)Total BTEX10/6/159/6/169/28/175/18/183/31/19*9/23/195/7/209/29/207/28/21Ethylbenzene #REF!Toluene Xylenes (total)Total BTEX 8/18/98 7/19/12 1/28/14 3/18/15 10/6/15 9/6/16 9/28/17 5/18/18 3/31/19*9/23/19 5/7/20 9/29/20 7/28/21 6/4/22 Benzene Ethylbenzene #REF!Toluene Xylenes (total)Total BTEX0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 7/19/121/28/143/18/1510/6/159/6/169/28/175/18/183/31/19*9/23/195/7/209/29/207/28/216/4/223/10/2310/8/23ug/lDate Graph 3. Historical BTEX and Total BTEX Concentrations MW-3 Benzene Ethylbenzene Toluene Xylenes (total)Total BTEX 0 10000 20000 30000 40000 50000 60000 70000 80000 90000 100000 8/18/987/19/121/28/143/18/1510/6/159/6/169/28/175/18/183/31/19*9/23/195/7/209/29/207/28/21ug/lBenzene Ethylbenzene Methyl-Tert-Butyl-Ether Toluene Xylenes (total)Total BTEX + MTBE9/6/169/28/175/18/1810/31/183/31/19*9/23/195/7/2099/29/207/28/21#REF!Toluene Xylenes (total)Total BTEX Ethylbenzene #REF!Toluene Xylenes (total)Total BTEX 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 1/28/143/18/1510/6/159/6/169/28/175/18/1810/31/183/31/19*9/23/195/7/2099/29/207/28/216/4/223/10/2310/8/23ug/lDate Graph 4. Historical BTEX and Total BTEX Concentrations MW-5 Benzene Ethylbenzene Toluene Xylenes (total)Total BTEX 3/31/19*Toluene Xylenes (total) Total BTEX 3/31/19*9/23/19 Total BTEX 5/7/209/28/175/18/1810/31/183/31/19*9/23/195/7/209/29/20#REF!Toluene Xylenes (total)Total BTEX 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 90,000 100,000 7/12/13 1/28/14 3/18/15 9/6/16 9/28/17 5/18/18 10/31/18 3/31/19*9/23/19 5/7/20 9/29/20 7/28/21 6/4/22 MW-14 Benzene Ethylbenzene #REF!Toluene Xylenes (total)Total BTEX 0 10,000 20,000 30,000 40,000 50,000 60,000 1/28/143/18/159/6/169/28/175/18/1810/31/183/31/19*9/23/195/7/209/29/207/28/216/4/223/10/2310/8/23ug/lDate Graph 5. Historical BTEX and Total BTEX Concentrations MW-14 Benzene Ethylbenzene Toluene Xylenes (total)Total BTEX APPENDIX A NCDEQ-UST CORRESPONDANCE APPENDIX B NCDENR APPENDIX B – REPORTING TABLES (B-1 AND B-2) APPENDIX C HISTORICAL GROUNDWATER ANALYTICAL RESULTS AT SHALLOW MONITOR WELLS MW-1 to MW-16, INTERMEDIATE WELL MW-1D & DEEP WELL DW-1 APPENDIX D LABORATORY DATA SHEETS   Laboratory's liability in any claim relating to analyses performed shall be limited to, at laboratory's option, repeating the analysis in question at laboratory's expense, or the refund of the charges paid for performance of said analysis.   10/17/2023 Buxton Environmental, Inc. Ross Klingman 1101 South Blvd Charlotte, NC, 28203 Ref: Analytical Testing Lab Report Number: 23-282-0002 Client Project Description: Big Bills Place NC Incident #: 16417 Dear Ross Klingman: Waypoint Analytical, LLC (Charlotte) received sample(s) on 10/9/2023 for the analyses presented in the following report. The above referenced project has been analyzed per your instructions. The analyses were performed in accordance with the applicable analytical method. The analytical data has been validated using standard quality control measures performed as required by the analytical method. Quality Assurance, method validations, instrumentation maintenance and calibration for all parameters were performed in accordance with guidelines established by the USEPA (including 40 CFR 136 Method Update Rule May 2021) unless otherwise indicated. Certain parameters (chlorine, pH, dissolved oxygen, sulfite...) are required to be analyzed within 15 minutes of sampling. Usually, but not always, any field parameter analyzed at the laboratory is outside of this holding time. Refer to sample analysis time for confirmation of holding time compliance. The results are shown on the attached Report of Analysis(s). Results for solid matrices are reported on an as- received basis unless otherwise indicated. This report shall not be reproduced except in full and relates only to the samples included in this report. Please do not hesitate to contact me or client services if you have any questions or need additional information. Sincerely, Angela D Overcash Senior Project Manager Page 1 of 13 Certification Summary Laboratory ID: WP CNC: Waypoint Analytical Carolina, Inc. (C), Charlotte, NC State Program Lab ID Expiration Date 07/31/202437735State ProgramNorth Carolina 12/31/2023402State ProgramNorth Carolina 07/31/202499012State ProgramSouth Carolina 12/31/202399012State ProgramSouth Carolina Page 1 of 1 00016/23-282-0002 Page 2 of 13 Report Number: Sample Summary Table Client Project Description: 23-282-0002 Big Bills Place NC Incident #: 16417 Lab No Client Sample ID Matrix Date Collected Date Received 10/08/2023 12:30Aqueous 97122 MW-1 10/09/2023 11:00 10/08/2023 14:15Aqueous 97123 MW-1D 10/09/2023 11:00 10/08/2023 13:45Aqueous 97124 MW-3 10/09/2023 11:00 10/08/2023 14:30Aqueous 97125 MW-5 10/09/2023 11:00 10/08/2023 13:00Aqueous 97126 MW-14 10/09/2023 11:00 Page 3 of 13 Summary of Detected Analytes QualifiersAnalyzedUnitsResult Report Number: Client Sample ID Method Parameters Lab Sample ID 23-282-0002 Report Limit Project:Big Bills Place V 97122MW-1 7830 10/12/2023 07:466200BBenzeneµg/L 18.0 3440 10/12/2023 07:466200BEthylbenzeneµg/L 17.0 10900 10/13/2023 05:346200BTolueneµg/L 220 5820 10/12/2023 07:466200Bo-Xylene µg/L 21.0 14600 10/12/2023 07:466200Bm,p-Xylene µg/L 42.0 20400 10/12/2023 07:466200BXylene (Total)µg/L 21.0 V 97123MW-1D 3060 10/12/2023 08:116200BBenzeneµg/L 18.0 1660 10/12/2023 08:116200BEthylbenzeneµg/L 17.0 462 10/12/2023 08:116200BTolueneµg/L 22.0 125 10/12/2023 08:116200Bo-Xylene µg/L 21.0 4820 10/12/2023 08:116200Bm,p-Xylene µg/L 42.0 4950 10/12/2023 08:116200BXylene (Total)µg/L 21.0 V 97124MW-3 12100 10/13/2023 05:596200BBenzeneµg/L 180 4360 10/12/2023 08:356200BEthylbenzeneµg/L 17.0 8560 10/13/2023 05:596200BTolueneµg/L 220 6160 10/12/2023 08:356200Bo-Xylene µg/L 21.0 16200 10/12/2023 08:356200Bm,p-Xylene µg/L 42.0 22400 10/12/2023 08:356200BXylene (Total)µg/L 21.0 V 97125MW-5 4840 10/12/2023 09:006200BBenzeneµg/L 18.0 4480 10/12/2023 09:006200BEthylbenzeneµg/L 17.0 1160 10/12/2023 09:006200BTolueneµg/L 22.0 2050 10/12/2023 09:006200Bo-Xylene µg/L 21.0 14700 10/12/2023 09:006200Bm,p-Xylene µg/L 42.0 16800 10/12/2023 09:006200BXylene (Total)µg/L 21.0 V 97126MW-14 6960 10/12/2023 09:246200BBenzeneµg/L 18.0 3800 10/12/2023 09:246200BEthylbenzeneµg/L 17.0 18200 10/13/2023 06:236200BTolueneµg/L 220 5850 10/12/2023 09:246200Bo-Xylene µg/L 21.0 13400 10/12/2023 09:246200Bm,p-Xylene µg/L 42.0 19300 10/12/2023 09:246200BXylene (Total)µg/L 21.0 Page 4 of 13 , REPORT OF ANALYSISReport Number : Project Information : NC 28203 23-282-0002 00456 Buxton Environmental, Inc. 1101 South Blvd Ross Klingman Charlotte NC Incident #: 16417 Received : 10/09/2023 Big Bills Place Report Date : 10/17/2023 Sample ID : Lab No : Sampled:MW-1 97122 Matrix: 10/8/2023 12:30 Aqueous Analytical Method: Prep Method: Test Results Units MDL MQL By Analytical Batch Date / Time Analyzed DF 6200 PT 6200B Prep Batch(es):V38961 10/11/23 14:00 V39055 10/12/23 09:00 7830 µg/L 18.0 50.0Benzene 100 10/12/23 07:46 V38962MSA 3440 µg/L 17.0 50.0Ethylbenzene 100 10/12/23 07:46 V38962MSA 10900 µg/L 220 500Toluene 1000 10/13/23 05:34 V39056MSA 5820 µg/L 21.0 50.0o-Xylene 100 10/12/23 07:46 V38962MSA 14600 µg/L 42.0 100m,p-Xylene 100 10/12/23 07:46 V38962MSA 20400 µg/L 21.0 50.0Xylene (Total)100 10/12/23 07:46 V38962 Surrogate: 4-Bromofluorobenzene 100 Limits: 70-130%10/12/23 07:46100 MSA V38962 Surrogate: Dibromofluoromethane 99.8 Limits: 70-130%10/12/23 07:46100 MSA V38962 Surrogate: 1,2-Dichloroethane - d4 96.8 Limits: 70-130%10/12/23 07:46100 MSA V38962 Surrogate: Toluene-d8 103 Limits: 70-130%10/12/23 07:46100 MSA V38962 Surrogate: 4-Bromofluorobenzene 99.0 Limits: 70-130%10/13/23 05:341000 MSA V39056 Surrogate: Dibromofluoromethane 99.4 Limits: 70-130%10/13/23 05:341000 MSA V39056 Surrogate: 1,2-Dichloroethane - d4 99.4 Limits: 70-130%10/13/23 05:341000 MSA V39056 Surrogate: Toluene-d8 100 Limits: 70-130%10/13/23 05:341000 MSA V39056 Qualifiers/ Definitions Method Quantitation LimitMQLDilution FactorDF Page 5 of 13 , REPORT OF ANALYSISReport Number : Project Information : NC 28203 23-282-0002 00456 Buxton Environmental, Inc. 1101 South Blvd Ross Klingman Charlotte NC Incident #: 16417 Received : 10/09/2023 Big Bills Place Report Date : 10/17/2023 Sample ID : Lab No : Sampled:MW-1D 97123 Matrix: 10/8/2023 14:15 Aqueous Analytical Method: Prep Method: Test Results Units MDL MQL By Analytical Batch Date / Time Analyzed DF 6200 PT 6200B Prep Batch(es):V38961 10/11/23 14:00 3060 µg/L 18.0 50.0Benzene 100 10/12/23 08:11 V38962MSA 1660 µg/L 17.0 50.0Ethylbenzene 100 10/12/23 08:11 V38962MSA 462 µg/L 22.0 50.0Toluene 100 10/12/23 08:11 V38962MSA 125 µg/L 21.0 50.0o-Xylene 100 10/12/23 08:11 V38962MSA 4820 µg/L 42.0 100m,p-Xylene 100 10/12/23 08:11 V38962MSA 4950 µg/L 21.0 50.0Xylene (Total)100 10/12/23 08:11 V38962 Surrogate: 4-Bromofluorobenzene 99.4 Limits: 70-130%10/12/23 08:11100 MSA V38962 Surrogate: Dibromofluoromethane 99.2 Limits: 70-130%10/12/23 08:11100 MSA V38962 Surrogate: 1,2-Dichloroethane - d4 93.0 Limits: 70-130%10/12/23 08:11100 MSA V38962 Surrogate: Toluene-d8 103 Limits: 70-130%10/12/23 08:11100 MSA V38962 Qualifiers/ Definitions Method Quantitation LimitMQLDilution FactorDF Page 6 of 13 , REPORT OF ANALYSISReport Number : Project Information : NC 28203 23-282-0002 00456 Buxton Environmental, Inc. 1101 South Blvd Ross Klingman Charlotte NC Incident #: 16417 Received : 10/09/2023 Big Bills Place Report Date : 10/17/2023 Sample ID : Lab No : Sampled:MW-3 97124 Matrix: 10/8/2023 13:45 Aqueous Analytical Method: Prep Method: Test Results Units MDL MQL By Analytical Batch Date / Time Analyzed DF 6200 PT 6200B Prep Batch(es):V38961 10/11/23 14:00 V39055 10/12/23 09:00 12100 µg/L 180 500Benzene 1000 10/13/23 05:59 V39056MSA 4360 µg/L 17.0 50.0Ethylbenzene 100 10/12/23 08:35 V38962MSA 8560 µg/L 220 500Toluene 1000 10/13/23 05:59 V39056MSA 6160 µg/L 21.0 50.0o-Xylene 100 10/12/23 08:35 V38962MSA 16200 µg/L 42.0 100m,p-Xylene 100 10/12/23 08:35 V38962MSA 22400 µg/L 21.0 50.0Xylene (Total)100 10/12/23 08:35 V38962 Surrogate: 4-Bromofluorobenzene 98.4 Limits: 70-130%10/12/23 08:35100 MSA V38962 Surrogate: Dibromofluoromethane 97.8 Limits: 70-130%10/12/23 08:35100 MSA V38962 Surrogate: 1,2-Dichloroethane - d4 96.0 Limits: 70-130%10/12/23 08:35100 MSA V38962 Surrogate: Toluene-d8 103 Limits: 70-130%10/12/23 08:35100 MSA V38962 Surrogate: 4-Bromofluorobenzene 101 Limits: 70-130%10/13/23 05:591000 MSA V39056 Surrogate: Dibromofluoromethane 99.0 Limits: 70-130%10/13/23 05:591000 MSA V39056 Surrogate: 1,2-Dichloroethane - d4 100 Limits: 70-130%10/13/23 05:591000 MSA V39056 Surrogate: Toluene-d8 102 Limits: 70-130%10/13/23 05:591000 MSA V39056 Qualifiers/ Definitions Method Quantitation LimitMQLDilution FactorDF Page 7 of 13 , REPORT OF ANALYSISReport Number : Project Information : NC 28203 23-282-0002 00456 Buxton Environmental, Inc. 1101 South Blvd Ross Klingman Charlotte NC Incident #: 16417 Received : 10/09/2023 Big Bills Place Report Date : 10/17/2023 Sample ID : Lab No : Sampled:MW-5 97125 Matrix: 10/8/2023 14:30 Aqueous Analytical Method: Prep Method: Test Results Units MDL MQL By Analytical Batch Date / Time Analyzed DF 6200 PT 6200B Prep Batch(es):V38961 10/11/23 14:00 4840 µg/L 18.0 50.0Benzene 100 10/12/23 09:00 V38962MSA 4480 µg/L 17.0 50.0Ethylbenzene 100 10/12/23 09:00 V38962MSA 1160 µg/L 22.0 50.0Toluene 100 10/12/23 09:00 V38962MSA 2050 µg/L 21.0 50.0o-Xylene 100 10/12/23 09:00 V38962MSA 14700 µg/L 42.0 100m,p-Xylene 100 10/12/23 09:00 V38962MSA 16800 µg/L 21.0 50.0Xylene (Total)100 10/12/23 09:00 V38962 Surrogate: 4-Bromofluorobenzene 102 Limits: 70-130%10/12/23 09:00100 MSA V38962 Surrogate: Dibromofluoromethane 101 Limits: 70-130%10/12/23 09:00100 MSA V38962 Surrogate: 1,2-Dichloroethane - d4 97.8 Limits: 70-130%10/12/23 09:00100 MSA V38962 Surrogate: Toluene-d8 103 Limits: 70-130%10/12/23 09:00100 MSA V38962 Qualifiers/ Definitions Method Quantitation LimitMQLDilution FactorDF Page 8 of 13 , REPORT OF ANALYSISReport Number : Project Information : NC 28203 23-282-0002 00456 Buxton Environmental, Inc. 1101 South Blvd Ross Klingman Charlotte NC Incident #: 16417 Received : 10/09/2023 Big Bills Place Report Date : 10/17/2023 Sample ID : Lab No : Sampled:MW-14 97126 Matrix: 10/8/2023 13:00 Aqueous Analytical Method: Prep Method: Test Results Units MDL MQL By Analytical Batch Date / Time Analyzed DF 6200 PT 6200B Prep Batch(es):V38961 10/11/23 14:00 V39055 10/12/23 09:00 6960 µg/L 18.0 50.0Benzene 100 10/12/23 09:24 V38962MSA 3800 µg/L 17.0 50.0Ethylbenzene 100 10/12/23 09:24 V38962MSA 18200 µg/L 220 500Toluene 1000 10/13/23 06:23 V39056MSA 5850 µg/L 21.0 50.0o-Xylene 100 10/12/23 09:24 V38962MSA 13400 µg/L 42.0 100m,p-Xylene 100 10/12/23 09:24 V38962MSA 19300 µg/L 21.0 50.0Xylene (Total)100 10/12/23 09:24 V38962 Surrogate: 4-Bromofluorobenzene 101 Limits: 70-130%10/12/23 09:24100 MSA V38962 Surrogate: Dibromofluoromethane 96.8 Limits: 70-130%10/12/23 09:24100 MSA V38962 Surrogate: 1,2-Dichloroethane - d4 94.8 Limits: 70-130%10/12/23 09:24100 MSA V38962 Surrogate: Toluene-d8 103 Limits: 70-130%10/12/23 09:24100 MSA V38962 Surrogate: 4-Bromofluorobenzene 98.6 Limits: 70-130%10/13/23 06:231000 MSA V39056 Surrogate: Dibromofluoromethane 98.4 Limits: 70-130%10/13/23 06:231000 MSA V39056 Surrogate: 1,2-Dichloroethane - d4 100 Limits: 70-130%10/13/23 06:231000 MSA V39056 Surrogate: Toluene-d8 99.6 Limits: 70-130%10/13/23 06:231000 MSA V39056 Qualifiers/ Definitions Method Quantitation LimitMQLDilution FactorDF Page 9 of 13 Quality Control Data 23-282-0002Report No: Project Description: Client ID:Buxton Environmental, Inc. Big Bills Place QC Prep Batch Method: Volatile Organic Compounds - GC/MS 6200B V38962QC Analytical Batch(es): Analysis Method: Analysis Description: 6200 PT QC Prep:V38961 Associated Lab Samples: 97122, 97123, 97124, 97125, 97126 LRB-V38961 Matrix: AQULab Reagent Blank Parameter AnalyzedMQLMDLBlank ResultUnits % Recovery % Rec Limits 10/12/23 02:540.5000.180<0.180µg/LBenzene 10/12/23 02:540.5000.170<0.170µg/LEthylbenzene 10/12/23 02:540.5000.220<0.220µg/LToluene 10/12/23 02:540.5000.210<0.210µg/Lo-Xylene 10/12/23 02:541.000.420<0.420µg/Lm,p-Xylene 10/12/23 02:544-Bromofluorobenzene (S)101 70-130 10/12/23 02:54Dibromofluoromethane (S)101 70-130 10/12/23 02:541,2-Dichloroethane - d4 (S)94.0 70-130 10/12/23 02:54Toluene-d8 (S)103 70-130 LCS-V38961 LCSD-V38961Laboratory Control Sample & LCSD LCSD ResultParameter Max RPD LCSD % Rec LCS %Rec LCS Result Spike Conc.Units % Rec Limits RPD 23.6 11812124.220.0µg/LBenzene 70-130 2.5 20.0 23.1 11612023.920.0µg/LEthylbenzene 70-130 3.4 20.0 23.2 11612023.920.0µg/LToluene 70-130 2.9 20.0 23.0 11511923.820.0µg/Lo-Xylene 70-130 3.4 20.0 49.1 12312750.840.0µg/Lm,p-Xylene 70-130 3.4 20.0 10199.64-Bromofluorobenzene (S)70-130 99.4101Dibromofluoromethane (S)70-130 95.692.01,2-Dichloroethane - d4 (S)70-130 102102Toluene-d8 (S)70-130 Page 1 of 2Date:10/17/2023 08:29 AM Page 10 of 13 Quality Control Data 23-282-0002Report No: Project Description: Client ID:Buxton Environmental, Inc. Big Bills Place QC Prep Batch Method: Volatile Organic Compounds - GC/MS 6200B V39056QC Analytical Batch(es): Analysis Method: Analysis Description: 6200 PT QC Prep:V39055 Associated Lab Samples: 97122, 97124, 97126 LRB-V39055 Matrix: AQULab Reagent Blank Parameter AnalyzedMQLMDLBlank ResultUnits % Recovery % Rec Limits 10/13/23 01:310.5000.180<0.180µg/LBenzene 10/13/23 01:310.5000.220<0.220µg/LToluene 10/13/23 01:314-Bromofluorobenzene (S)102 70-130 10/13/23 01:31Dibromofluoromethane (S)99.6 70-130 10/13/23 01:311,2-Dichloroethane - d4 (S)97.4 70-130 10/13/23 01:31Toluene-d8 (S)100 70-130 LCS-V39055 LCSD-V39055Laboratory Control Sample & LCSD LCSD ResultParameter Max RPD LCSD % Rec LCS %Rec LCS Result Spike Conc.Units % Rec Limits RPD 21.4 10710721.420.0µg/LBenzene 70-130 0.0 20.0 21.1 10610621.220.0µg/LToluene 70-130 0.4 20.0 99.098.24-Bromofluorobenzene (S)70-130 10198.0Dibromofluoromethane (S)70-130 10398.61,2-Dichloroethane - d4 (S)70-130 100100Toluene-d8 (S)70-130 Page 2 of 2Date:10/17/2023 08:29 AM Page 11 of 13 Fed Ex UPS US Postal Client Lab Courier Other : Shipment Receipt Form Customer Number: Customer Name: Report Number:23-282-0002 Buxton Environmental, Inc. 00456 Shipping Method Shipping container/cooler uncompromised? Thermometer ID:IRT-15 2.1C Chain of Custody (COC) present?Yes No Yes No Not Present Yes No Not Present Yes No COC agrees with sample label(s)? Yes No COC properly completed Samples in proper containers? Sample containers intact? Sufficient sample volume for indicated test(s)? All samples received within holding time? Cooler temperature in compliance? Yes No Yes No Yes No Yes No Yes No Yes NoCooler/Samples arrived at the laboratory on ice. Samples were considered acceptable as cooling process had begun. Yes No Yes No N/A Yes No N/A Yes No N/ASoil VOA method 5035 – compliance criteria met Water - Sample containers properly preserved Water - VOA vials free of headspace Yes No N/A Trip Blanks received with VOAs Low concentration EnCore samplers (48 hr) High concentration pre-weighed (methanol -14 d) Low conc pre-weighed vials (Sod Bis -14 d) High concentration container (48 hr) Custody seals intact on shipping container/cooler? Custody seals intact on sample bottles? Number of coolers/boxes received Yes No 1 Signature:Caitlyn Cummins Date & Time:10/09/2023 12:51:54 Special precautions or instructions included? Comments: Page 12 of 13 Page 13 of 13