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Well Replacement Work Plan
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Former BASF Landfill Site (Brownfields Project # 15011 -11 - 011)
164 Jacob Holm Way
Candler, North Carolina
Headwater Project # A19-107A-01
Prepared for:
Enka Youth Sports Organization
1091 Hendersonville Rd # 201
Asheville, North Carolina 28803
September 2, 2020

Well Replacement Work Plan
Former BASF Landfill Site (Brownfields Project # 15011 -11 - 011)
164 Jacob Holm Way
Candler, North Carolina
Headwater Project # A19-107A-01
September 2, 2020
Prepared for
Enka Youth Sports Organization
164 Jacob Holm Way
Candler, North Carolina 28715
Prepared by
Headwater Geology, PLLC
43 College Place, Suite 212
Asheville, North Carolina 28801
Adam M. Tripp, PG
Senior Geologist
Firm License # C-566

Former BASF Landfill Site (Brownfields Project # 15011-11- 011)—Well Replacement Work Plan
TABLE OF CONTENTS
1 Introduction............................................................................................................... 1
1.1 Background and Purpose...................................................................................................
1
1.2 Site History.........................................................................................................................
2
1.3 Landfill Information.............................................................................................................2
2 Proposed Well Replacement Activities..................................................................... 4
2.1 Monitoring Well Decommissioning.....................................................................................
4
2.2 Monitoring Well Installation................................................................................................
4
2.2.1 Well Development..................................................................................................
5
2.2.2 Investigative Derived Waste Management.............................................................
5
2.3 Well Survey........................................................................................................................
5
2.4 Deliverables.......................................................................................................................
5
2.5 Schedule............................................................................................................................
6
3 References............................................................................................................... 7
FIGURES
Figure 1
Figure 2
APPENDICES
Appendix A
Location Map
Site Layout Map
Well Replacement Evaluation (Anchor QEA 2018)—Figure 3 - Water Column
Trends and Table 1 — Well Construction Characteristics
Headwater Geology

Former BASF Landfill Site (Brownfields Project # 15011 -11 - 011)—Well Replacement Work Plan
1 Introduction
Headwater Geology, PLLC. (Headwater), on behalf of Enka Youth Sports Organization (Enka
Youth), prepared this Well Replacement Work Plan for the Former BASF Landfill Brownfields
Property (Brownfields Project # 15011-11-11) located at 164 Jacob Holm Way, Candler,
Buncombe County, North Carolina (the Site). The Site is a closed, permitted, landfill (#1102-
INDUS-1980) for the former American Enka Company. BASF Corporation (BASF) is the permit
holder for the landfill. A Site Location Map and Site Layout Map are included as Figures 1 and 2,
respectively.
1.1 Background and Purpose
During Site redevelopment and grading activities performed in early 2017 by Enka Partners of
Asheville, LLC (the entity that owned the Site during development), two groundwater monitoring
wells were altered. Specifically, the casing for monitoring well MW-6 was cut and shortened and
the casing for monitoring well MW-3 was lengthened by coupling an additional section of PVC to
the well casing. Based on well construction information in ELM Site Solutions' (ELM) 2015 Semi -
Annual Monitoring Report, and well gauging performed by Anchor QEA of North Carolina, PLLC
(Anchor QEA) on May 19, 2017, groundwater monitoring well MW-3 had been extended from a
total depth of approximately 30 feet below ground surface (bgs) to approximately 40 feet bgs.
Groundwater monitoring well MW-6 appears to have been reduced in total depth from
approximately 41 feet bgs to approximately 22 feet bgs. In short, the casing for MW-3 was raised
approximately 10 feet and the casing for MW-6 was lowered approximately 19 feet. The change
in well casing corresponded to a change in grade in these areas (Anchor QEA 2018).
In a letter dated September 20, 2017, from the Department of Environmental Quality (DEQ) Solid
Waste Section to the DEQ Brownfields Program, the Solid Waste Section stated that "due to the
public perception of the project, the validity of analytical results from the monitoring wells MW-3
and MW-6, and the validity of the well construction of the current monitoring wells MW-3 and
MW-6, it is necessary that prospective developer replace both monitoring wells".
In response, Anchor QEA prepared a Well Replacement Evaluation, dated June 2018. The results
of that evaluation indicated that neither well had been functioning to its intended purpose prior to
being modified during redevelopment and therefore should be replaced by the permit holder.
Specifically, the top of the well screen for monitoring well MW-3 has been consistently submerged
by approximately 12 feet of groundwater, and therefore may not detect volatile organic
compounds (VOCs) that are lighter than water. Monitoring well MW-6 began to go dry in mid-
2014, corresponding with the construction of the neighboring New Belgium Distribution Center
and associated paved parking and roadway (approximately 300,000 square feet of additional
impervious surface in the groundwater recharge area for MW-6). Prior to the off -Site construction,
the water column thickness in MW-6 averaged approximately 7 feet. After construction, water
levels averaged approximately 1.75 feet, with water column as short as 1.09 feet in October 2015.
A corresponding reduction in water levels was not observed in any other well, indicating that this
Headwater Geology

Former BASF Landfill Site (Brownfields Project # 15011 -11 - 011)—Well Replacement Work Plan
well went dry as a result of neighboring construction. Therefore, this well was compromised before
it was modified during development in early 2017. A graph showing water column trends and a
well construction characteristics table from Anchor QEA's report is included in Appendix A. Anchor
QEA provided a description of proposed well abandonment procedures to be conducted on behalf
of Enka Youth and provided recommendations for BASF's consultant to replace these wells
(Anchor QEA 2018).
Neither the DEQ Brownfields Program nor Solid Waste Section provided a response to the Well
Replacement Evaluation. However, in an email sent on May 13, 2020, Tracy Wahl with the DEQ
Brownfields Program again requested a work plan to decommission and replace these monitoring
wells.
In order to discuss the plan to decommission the wells, Adam Tripp with Headwater, participated
in a conference call with Tracy Wahl, Adam Ulishney (DEQ-SWS), Jackie Drummond (DEQ-
SWS), and Jason Watkins (DEQ-SWS) on May 19, 2020. Headwater offered to redevelop the
modified wells, a common technique used to refurbish a well, but DEQ-SWS insisted that the
wells must be replaced. DEQ-SWS did not address the monitoring well's compromised conditions
that existed before the well casings were modified during Site construction.
The purpose of this work plan is to describe proposed well decommissioning and replacement
activities as directed by the DEQ.
1.2 Site History
The Site is a 41-acre property that contains an approximately 28-acre closed, permitted, industrial
landfill. Material from an adjacent textile manufacturing facility was disposed of in the landfill. The
textile facility primarily manufactured various types of yarns, including continuous filament rayon
yarn, nylon textile yarn, and carpet yarn. American Enka Company operated the landfill until BASF
Corporation (BASF) acquired American Enka in 1985. BASF continued to operate the landfill until
it was closed in 2002. BASF is required to meet post -closure conditions for a 30-year period
(Anchor QEA 2019).
A Brownfields Agreement for the Site was finalized in April 2016. Multiple assessments were
performed on the Site and neighboring property, where the textile facility was located. Following
review of assessment data and coordination with the Brownfields Program, redevelopment of the
Site into a ballfield began in late 2016 and was completed in general accordance with the
Redevelopment Plan (Altamont 2016).
1.3 Landfill Information
The landfill operated under permit No. 11-02 from the North Carolina Department of Environment
and Natural Resources, which is now the DEQ-SWS. Various wastes generated from the textile
manufacturing facility were disposed of in the landfill. The wastes included fly ash (a coal
combustion byproduct), caprolactam (a precursor to nylon) reactor bottoms, waste activated
Headwater Geology 2

Former BASF Landfill Site (Brownfields Project # 15011 -11 - 011)—Well Replacement Work Plan
sludge (excess biological material produced during wastewater treatment), alum sludge (material
produced from treating wastewater with aluminum sulfate), viscose pit bottoms (a byproduct of
the production of viscose rayon), and household and construction wastes. Wastes were deposited
from 1929 to 1975 in a 10-acre swale that was located in the northeast corner of the current landfill
footprint. That section of the landfill was closed in 1975. The remaining landfill area received
waste from 1975 to 2002.
The closed landfill is 28-acres in size and was covered with a minimum 2-foot-thick soil cap as
part of closure conditions. The approximate edge of waste boundary is shown on Figure 2. Note
that additional fill, in some areas as much as 30 feet, was placed on the existing landfill cap to
grade the Site for construction (Anchor QEA 2019).
Headwater Geology 3

Former BASF Landfill Site (Brownfields Project # 15011-11- 011)—Well Replacement Work Plan
2 Proaosed We' Replacement Activities
Monitoring wells MW-3 and MW-6 will be properly decommissioned and replaced as described in
the following sub -sections.
2.1 Monitoring Well Decommissioning
Monitoring wells MW-3 and MW-6 will be properly decommissioned by a North Carolina licensed
driller in accordance with 15A North Carolina Administrative Code (NCAC) 2C .0113. Specifically,
the protective surface casing for each well will be removed and the polyvinyl chloride (PVC) well
casing will be cut off at a depth approximately 1 foot below ground surface (bgs). The remaining
well casing will then be willed with a bentonite-grout mixture to the surface and ground surface
will be returned to the condition of the surrounding area (i.e. seeded and strawed). Well
abandonment records will be provided to DEQ-SWS.
2.2 Monitoring Well Installation
Replacement monitoring wells will be installed in the locations proposed on Figure 2. Note that
the actual well location may be adjusted slightly to account for Site conditions.
The monitoring well installation procedures will be in general accordance with the 15A NCAC 2C
.0100 Well Construction Rules and the Design and Installation of Monitoring Wells, guidance
document, prepared by the US Environmental Protection Agency (EPA) Science and Ecosystem
Support Division (SESD), dated February 18, 2008. The monitoring wells will be installed using
hollow stem auger (HSA) drilling technology by a North Carolina licensed driller. Drilling tools will
be decontaminated using pressurized water before and after each boring. Borings will be
advanced to a depth of approximately 5 feet into the water table such that the well screen can be
set to bracket the water table. Based on topography and historical water level information
Headwater anticipates that monitoring well MW-3R will be installed to a terminal depth of 15 to 20
feet below ground surface (feet bgs) and well MW-6R will be installed to approximately 40 feet
bgs.
The monitoring wells will be constructed in the annulus created by the drilling tools and will be
composed of 2-inch nominal inside -diameter Schedule 40 PVC riser with a 10-foot-long
0.010-inch machine -slotted PVC screen. A #2 filter sand will then be used to fill the annular space
between the well screen and the borehole from the base of the borehole to a depth of
approximately 2 feet above the top of the well screen. Hydrated bentonite pellets will then be set
above the filter sand at a thickness of approximately 2 feet. Grout will be used to fill the annular
space from the top of the bentonite to ground surface. A locking steel stickup -up surface
completion will be used to protect the well casing and an expandable well plug will be used to
seal the well riser. The monitoring well casing will be set in a concrete pad. Well construction
records and boring logs will be submitted to the DEQ-SWS.
Headwater Geology 4

Former BASF Landfill Site (Brownfields Project # 15011 -11 - 011)—Well Replacement Work Plan
2.2.1 Well Development
After installation, the monitoring wells will be developed in general accordance with the Design
and Installation of Monitoring Wells, using a submersible pump to remove sediment from the well
and to set the sand filter pack. Well development is anticipated to be performed for less than an
hour for each well. During development, the pH, specific conductivity, turbidity, and temperature
will be measured and recorded. Well development will be complete when these parameters have
stabilized (three successive readings in which pH ± 0.1 unit; specific conductivity ± 3 percent;
temperature, and turbidity ± 10 percent; and the water is visually clear of sediment) or until
development has progressed for an hour. Note that well development will be performed prior to
setting the protective casing and pouring the well pad.
2.2.2 Investigative Derived Waste Management
Investigative derived waste (IDW), including drilling cuttings, decontamination fluid, and well
development water will be managed in accordance with h 15A NCAC 02T.1503 and 15A NCAC
02H. 0106. Review of historical assessment and operations at the Site has not indicated that
impacted media is present in the vicinity of MW-6R. Soil sampling in the vicinity of MW-3R
indicates that surface soils are impacted by low concentrations of polychlorinated biphenyls
(PCBs). Historical soil analysis of composite soil samples collected in this area indicate that PCB
congeners are present at concentrations in excess of the Residential Preliminary Soil
Remediation Goals (SRGs) but below the Industrial/Commercial SRGs (Anchor QEA 2017). All
concentrations of PCB congeners were below 1 part per million (ppm) and were well below the
50 ppm threshold to be considered a Toxic Substances Control Act (TSCA) regulated waste.
Because hazardous waste is not expected to present and IDW spreading is not expected to
contravene water quality standards, the IDW will be thin -spread onsite in the vicinity of the well
from which they originated. If impacted media (determined by visual or olfactory observations) is
encountered, it will be containerized, characterized, and, if necessary, disposed of in a permitted
facility.
2.3 Well Survey
The top of casing and ground surface of each well will be surveyed by a North Carolina licensed
well surveyor. The horizontal and vertical position of each well will be measured. One additional
monitoring well (MW-4 or MW-5) will also be surveyed to provide reference to the existing
monitoring well network
2.4 Deliverables
Headwater will provide to the Brownfields Program and DEQ-SWS GW-30 DWR well
abandonment records, GW-1 DWR well construction records, boring logs, well development logs,
NC licensed well survey data for each well, and a table showing well construction information.
Well lock keys will be mailed to the DEQ Asheville Regional Office. If during well installation there
Headwater Geology 5

Former BASF Landfill Site (Brownfields Project # 15011 -11 - 011)—Well Replacement Work Plan
are observations of contamination, such as the presence of waste material or odor, a summary
of those observations will be provided, and disposal manifests will be provided if applicable.
2.5 Schedule
Headwater understands that the installation of a natural gas line is planned in the vicinity of both
wells. Therefore, we recommend that well installation be performed after gas line installation is
completed. If minor well location adjustments are needed, those adjustments can be made in the
field. If the well location needs to be moved greater than 25 feet, Headwater will submit a revised
figure showing adjusted, proposed well locations.
However, because the gas line installation schedule is unknown, Headwater will perform well
installation activities within 60 days of approval of this work plan.
Headwater Geology 6

Former BASF Landfill Site (Brownfields Project # 15011 -11 - 011)—Well Replacement Work Plan
3 References
Anchor QEA, 2017. Brownfields Assessment Report. March.
Anchor QEA, 2018. Well Replacement Evaluation. June.
Anchor QEA, 2019. Methane Management Plan. January.
Altamont, 2016. Redevelopment Plan —Phase I. September 23.
ELM, 2015. Semi -Annual Monitoring Report —BASF Former Industrial Facility. July.
Headwater Geology

FIGURES

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FIGURE 1
Legend Headwater SOURCE USGS LOCATION MAP
Brownfields property boundary E N V I R O N M E N T A L I N C. 7 5-minute Topographic Quadrangle Former BASF Landfill Site
Enka, North Carolina (1998) 164 Jacob Holm Way
Note: This is not a survey. All locations Contour Interval = 20 feet Candler, Buncombe County
are approximate. Date: 4/10/2019 North Carolina
Feet Prepared b 0, 1 inch = 1,000 feet Headwater Project # A19-107A-01
0 500 1,000 2,000 p y: NJ

Brookside Cir Qat�N�y
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MW-3R
LG-4 • ®MW-3
MW-4
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LG-5
LG-11 `
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LG-13 -15
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LG-9 C`
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Legend
Sports complex outline
Brownfield property boundary
Waste boundary
O
Abandoned landfill gas wells
Landfill gas wells
®
Existing monitoring wells
•
Proposed well locations
Headwater
AOF ENVIRONMENTAL INC.
Date:
4/10/2019
Revised 7/23/20
SOURCE
NC One Map
Latest Orthoimagery
*Locations are approximate
3
at . •
LG-6 MW-6
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MW-6R
•
Feet I
0 150 300 600
FIGURE 2
SITE LAYOUT MAP
Former BASF Landfill Site
164 Jacob Holm Way
Candler, Buncombe County
North Carolina
Headwater Project # A19-107A-01
Prepared by:
NJC
'! 1 inch = 300 feet

APPENDIX A
Well Replacement Evaluation (Anchor QEA
2018)—Figure 3 -Water Column Trends
and Table 1 -Well Construction
Characteristics

25
c
15
10
0
0
Feb-09 Jun-10
Figure 3 - Water Column Trends
9MMUNT&I
+MW-4R
BMW-6
Nov-11 Mar-13 Jul-14 Dec-15 Apr-17

Table 1- Well Construction Characteristics
Former BASF Landfill Site
Monitoring
Well
Well
Diameter,
inches
Installed Total
Depth, feet bgs
Total Depth
Elevation,
feet NAVD 88
Screen
Interval,
feet bgs
Screen
Length, feet
TOC
Elevation,
feet NAVD
88
Depth to
Water*, feet
bTOC
Water Column
Thickness,
feet
Groundwater
Elevation, feet
NAVD 88
MW-3
2
30.16
2,026.28
18-28
10
2,056.44
8.49
21.67
2,047.95
MW-4R
2
34.92
2,047.75
23-33
10
2,082.67
26.87
8.05
2,055.80
MW-5
2
19.35
2,038.27
6-16
10
2,057.62
7.99
11.36
2,049.63
MW-6
2
41.35
2,073.49
28-38
10
2,114.84
39.86
1.49
2,074.98
Notes:
* * October 13, 2016
NAVD 88 North American Vertical Datum of 1988
bgs
below ground surface
bTOC
below top of casing
TBD
To Be Determined