MO-4860_16417_CA_MRP_20230419

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B. INTRODUCTION AND EXECUTIVE SUMMARY

Buxton Environmental, Inc. (BEI) respectfully submits the methods and results of groundwater monitoring
activities conducted on March 10, 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,
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) 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. The pilot study was to be conducted to determine if ORC injection can
expedite/enhance the approved Natural Attenuation Corrective Action Plan (CAP; approved September 2014) at
the site. These activities were conducted in general accordance with North Carolina Department of
Environment Quality – Underground Storage Tank (UST) Section (NCUST) guidelines; and conversations with
Mr. Brad Newton, P.G. (project manager). 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.

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. Email correspondence is provided in Appendix A.

These activities were Pre-Approved by the NCUST Trust Fund on February 27, 2023 (Task Authorization
Number 21; for sampling and analysis only) and April 14, 2023 (Task Authorization Number 21 – Change
Order 1; for monitoring report preparation) for UST Trust Fund reimbursement purposes.

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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

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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

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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.

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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.

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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).

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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

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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.

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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 | 12

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 | 13

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.

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.

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E. GROUNDWATER MONITORING AT MW-1, MW-3, MW-5, MW-14 & MW-1D

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. Prior to
conducting the sampling activities, groundwater levels were obtained from each well (plus MW-2 and MW-4)
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-1 to 3.6 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 high oxygen levels at 9.3 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 natural
biodegradation processes from April to May each year with rising aquifer temperatures; remains DO depleted
from April/May until ~November (natural aerobic biodegradation slows); then becomes re-oxygenated in the
fall through winter with falling aquifer temperatures and slowing active biodegradation activities.

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 Pace Analytical Services, LLC (NC Certification No.:
329) in West Columbia, South Carolina. No quality control trip blanks, duplicates or field blanks were
collected.

Shallow Groundwater Flow Direction

Based on groundwater levels collected on March 10, 2023, the predominate shallow groundwater flow direction
at the subject property and immediately surrounding area is to the northwest. The shallow groundwater flow
direction at the site 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). In
addition, a southwest component of flow, which is approximately 150 degrees away from the primary
petroleum plume migration, was observed to the immediate north of the site between MW-3 and MW-14. The
shallow groundwater flow direction map is provided in Figure 4.

A moderate horizontal hydraulic gradient of 0.015 ft/ft was observed between on-site monitor wells MW-2
(groundwater high) to MW-1 (original heart of the petroleum affected plume), and transitions to a very low
gradient of 0.001 ft/ft from MW-1 to MW-4 as you move downgradient of the site, during the March 10, 2023
monitoring event. A low upward vertical hydraulic gradient of 0.002 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.

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Groundwater Analytical Results

Petroleum constituent (BTEX) groundwater analytical results collected on March 10, 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 6,900 ug/l benzene (above NCGCL), 2,300 ug/l
ethylbenzene, 3,400 ug/l toluene and 16,000 ug/l xylenes.

Groundwater sample MW-1D indicated the presence of 360 ug/l benzene, 63 ug/l ethylbenzene, 4J ug/l toluene
and 14 ug/l total xylenes, with no exceedances above NCGCLs. A J-flag indicates an estimated result (<limit of
quantitation (LOQ) and >= method detection limit (MDL)).

Groundwater sample MW-3 indicated the presence of 12,000 ug/l benzene (above NCGCL), 3,800 ug/l
ethylbenzene, 10,000 ug/l toluene and 20,000 ug/l xylenes.

Groundwater sample MW-5 indicated the presence of 3,600 ug/l benzene (below NCGCL during last 2
sampling events), 3,600 ug/l ethylbenzene, 1,400 ug/l toluene and 17,000 ug/l total xylenes.

Groundwater sample MW-14 indicated the presence of 5,300 ug/l benzene (above NCGCL), 3,400 ug/l
ethylbenzene, 20,000 ug/l toluene and 19,000 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 75’ (wide) x 195’ (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 March 10, 2023 monitoring activities, the estimated volume of
residual benzene affected groundwater above the NCGCL is 410,231 gallons (75’ (wide) x 195’ (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 | 16

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 have steadily decreased to present time (Graph
1). 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.

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 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 this March 10, 2023
sampling event.

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 March 10, 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 two sampling events conducted on June 4, 2022 and March 10, 2023.

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 seven (7) 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. However, benzene
concentrations were only detected slightly above the NCGCL during this March 10, 2023 sampling event,
which is the lowest benzene concentration detected since the historic low in October 2018.

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I. CONCLUSIONS AND RECOMMENDATIONS

Conclusions:

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 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, 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) 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. The pilot study was to
be conducted to determine if ORC injection can expedite/enhance the approved Natural Attenuation Corrective
Action Plan (CAP; approved September 2014) at the site. These activities were conducted in general
accordance with North Carolina Department of Environment Quality – Underground Storage Tank (UST)
Section (NCUST) guidelines; and conversations with Mr. Brad Newton, P.G. (project manager). 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.

• 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.

• 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.

• 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-1 to 3.6 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
high oxygen levels at 9.3 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

Page | 18

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 slows); then becomes re-oxygenated in the fall through winter with falling aquifer
temperatures and slowing active biodegradation activities.

• Based on groundwater levels collected on March 10, 2023, the predominate shallow groundwater flow
direction at the subject property and immediately surrounding area is to the northwest. The shallow
groundwater flow direction at the site 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). In addition, a southwest component of flow, which is approximately 150
degrees away from the primary petroleum plume migration, was observed to the immediate north of the
site between MW-3 and MW-14.

• A moderate horizontal hydraulic gradient of 0.015 ft/ft was observed between on-site monitor wells
MW-2 (groundwater high) to MW-1 (original heart of the petroleum affected plume), and transitions to
a very low gradient of 0.001 ft/ft from MW-1 to MW-4 as you move downgradient of the site, during the
March 10, 2023 monitoring event. A low upward vertical hydraulic gradient of 0.002 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.

• 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 6,900 ug/l benzene (above NCGCL), 2,300 ug/l ethylbenzene, 3,400 ug/l
toluene and 16,000 ug/l xylenes. Groundwater sample MW-1D indicated the presence of 360 ug/l
benzene, 63 ug/l ethylbenzene, 4J ug/l toluene and 14 ug/l total xylenes, with no exceedances above
NCGCLs. Groundwater sample MW-3 indicated the presence of 12,000 ug/l benzene (above NCGCL),
3,800 ug/l ethylbenzene, 10,000 ug/l toluene and 20,000 ug/l xylenes. Groundwater sample MW-5
indicated the presence of 3,600 ug/l benzene (below NCGCL during last 2 sampling events), 3,600 ug/l
ethylbenzene, 1,400 ug/l toluene and 17,000 ug/l total xylenes. Groundwater sample MW-14 indicated
the presence of 5,300 ug/l benzene (above NCGCL), 3,400 ug/l ethylbenzene, 20,000 ug/l toluene and
19,000 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 75’ (wide) x 195’ (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. Based on the March 10,
2023 monitoring activities, the estimated volume of residual benzene affected groundwater above the
NCGCL is 410,231 gallons (75’ (wide) x 195’ (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.

• Petroleum concentrations at MW-1 peaked on July 19, 2012 and have steadily decreased to present time.
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.

Page | 19

• 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 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 this March 10, 2023 sampling event.

• 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 March 10, 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 two sampling events conducted on
June 4, 2022 and March 10, 2023.

• 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 seven (7) 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.
However, benzene concentrations were only detected slightly above the NCGCL during this March 10,
2023 sampling event, which is the lowest benzene concentration detected since the historic low in
October 2018.

Page | 20

Recommendations:

• Based on the findings of this investigation, BEI recommends 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. The next semi-annual MNA sampling event will be conducted in September 2023.

• 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 [phone].
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
MARCH 10, 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 40.40 NP 59.60
MW-1D 99.50 99.79 61.63 2 5 39.87 NP 59.63
MW-2 100.57 101.07 48.47 2 15 40.54 --60.03
MW-3 97.99 98.40 42.35 2 15 38.41 NP 59.58
MW-4 96.58 97.00 42.3 2 15 37.04 --59.54
MW-5 99.24 99.59 60 2 20 39.63 NP 59.61
MW-14 98.50 98.85 50 2 20 38.82 NP 59.68
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 March 10, 2023
TABLE 2
MONITORED NATURAL ATTENUATION - GROUNDWATER PARAMETER DATA
FORMER BIG BILL'S PLACE
601 GASTONIA HIGHWAY
BESSEMER CITY, NORTH CAROLINA
INCIDENT NO.: 16417
MARCH 10, 2023
Well ID MW-1 MW-1D MW-3 MW-5 MW-14
Field Parameters
pH (standard units)6.23 6.88 6.28 6.44 6.20
Conductivity (uS/cm)530 210 360 340 310
Temperature (Celsius)16.2 17.0 16.1 16.4 15.6
Dissolved Oxygen (DO) (mg/l)2.6 9.3 3.2 3.4 3.6

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
MARCH 10, 2023

Well ID MW-1 MW-1D MW-3 MW-5 MW-14 NCGQS NCGCL
EPA Method 8260D (BTEX)(ug/l)
Benzene 6,900 360 12,000 3,600 5,300 1 5,000
Ethylbenzene 2,300 63 3,800 3,600 3,400 600 84,500
Toluene 3,400 4J 10,000 1,400 20,000 600 260,000
Xylenes (total)16,000 14 20,000 17,000 19,000 500 85,500
Notes:
Groundwater sample collected at MW-1, MW-1D, MW-3, MW-5 and MW-14 on March 10, 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
VOC's (ug/l)Acetone NT BDL 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 1 5,000BromodichloromethaneNTBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.6 600**
2-Butanone NT BDL 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 70 6,900sec-Butylbenzene NT 6,800 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 70 70,0001,2-Dichloroethane BDL BDL 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 70 70,000
1,2-Dichloropropane BDL BDL 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 2,300 600 84,500
EDB 72 BDL BDL 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 40 40,000Isopropyl Ether (IPE)290 BDL 170J NT NT NT NT 220J 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 70 25,000
p-Isopropyltoluene NT BDL 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 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 20 20,000NaphthaleneNT920NT760NTNTNT8601,000 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 70 30,000
Styrene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 70,000TetrachloroetheneBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.7 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 3,400 600 260,000
Trichloroethene BDL BDL 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 0.005 5**
1,2,4-Trimethylbenzene NT 4,000 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 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 16,000 500 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 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 400 400,000**C9-C12 Aliphatics 46,100 6,200 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 200 200,000**
EPA 3030C Lead (ug/l)5 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
VOC's (ug/l)Acetone NT BDL BDL 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 1 5,000BromodichloromethaneNTBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.6 600**
2-Butanone NT BDL BDL 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 70 6,900sec-Butylbenzene 12.2 7.1 BDL 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 70 70,0001,2-Dichloroethane 26.5 25.2 BDL 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 70 70,000
1,2-Dichloropropane BDL BDL BDL 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 63 600 84,500
EDB 1.36 BDL BDL BDL 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 40 40,000Isopropyl Ether (IPE)46.8 44 BDL 55J NT NT NT NT 27J 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 70 25,000
p-Isopropyltoluene 7.27 3.5 BDL 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 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 20 20,000Naphthalene196124500NT180J50032040038J36JNTNTNTNTNTNTNT66,000n-Propylbenzene 194 79 BDL 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 70 70,000Tetrachloroethene6.9 1.8 BDL 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 600 260,000
Trichloroethene 13.7 17 BDL 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 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 400 28,500
1,3,5-Trimethylbenzene 295 94 360 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 14 500 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 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 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 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 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-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
VOCs (ug/l)Acetone NT 6,400 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 1 5,000BromodichloromethaneNTBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.6 600*2-Butanone NT 2,500 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 70 6,900sec-Butylbenzene BDL BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 8,500ChloroformBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000
1,2-Dichloroethane 125 BDL 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 70 70,0001,2-Dichloropropane BDL BDL 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 3,800 600 84,500EDB62BDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNT0.02 50
2-Hexanone NT 680 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 70 70,000Isopropylbenzene91BDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT7025,000
p-Isopropyltoluene BDL BDL 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 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 20 20,000
Naphthalene 3,100 360J NT 730 650 1,000 860 720 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 70 30,000StyreneBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000
Tetrachloroethene BDL BDL 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 10,000 600 260,000
Trichloroethene BDL BDL 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 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 400 28,500
1,3,5-Trimethylbenzene 465 340 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 20,000 500 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 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 400 400,000*
C9-C12 Aliphatics 19,100 15,000 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 200 200,000*
EPA 3030C Lead (ug/l)BDL 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
VOCs (ug/l)Acetone BDL 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 1 5,000BromodichloromethaneBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT0.6 600**2-Butanone BDL 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 70 6,900sec-Butylbenzene BDL NT NT NT NT NT NT NT NT NT NT NT NT NT NT 70 8,500ChloroformBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000
1,2-Dichloroethane BDL 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 70 70,0001,2-Dichloropropane BDL 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 3,600 600 84,500EDBBDLBDLNTNTNTNTNTNTNTNTNTNTNTNTNT0.02 50
2-Hexanone 55J 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 70 70,000Isopropylbenzene220NTNTNTNTNTNTNTNTNTNTNTNTNTNT7025,000
p-Isopropyltoluene BDL 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 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 20 20,000
Naphthalene 1,200 NT 720 660 520 710 410 850 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 70 30,000StyreneBDLNTNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000
Tetrachloroethene BDL 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 1,400 600 260,000
Trichloroethene BDL 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 0.005 5**1,2,4-Trimethylbenzene 4,300 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 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 17,000 500 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 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 400 400,000**
C9-C12 Aliphatics 7,100 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 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)
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
VOCs (ug/l)
Acetone BDL 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 1 5,000
Bromodichloromethane BDL 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 4,000 4,000,000n-Butylbenzene 60 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 70 8,500ChloroformBDLNTNTNTNTNTNTNTNTNTNTNTNTNT7070,0001,2-Dichloroethane 17 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 70 70,0001,2-Dichloropropane BDL 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 3,400 600 84,500
EDB BDL 85J 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 40 40,000
Isopropyl Ether (IPE)45 BDL NT NT NT 46J 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 70 25,000p-Isopropyltoluene 36 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 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 20 20,000Naphthalene910NT980860790670770NTNTNTNTNTNTNT66,000
n-Propylbenzene 550 NT NT NT NT NT NT NT NT NT NT NT NT NT 70 30,000StyreneBDLNTNTNTNTNTNTNTNTNTNTNTNTNT7070,000TetrachloroetheneBDLNTNTNTNTNTNTNTNTNTNTNTNTNT0.7 700
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 20,000 600 260,000Trichloroethene9JNTNTNTNTNTNTNTNTNTNTNTNTNT33,000
1,2,3-Trichloropropane BDL 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 400 28,5001,3,5-Trimethylbenzene 950 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 19,000 500 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 NS NS
MADEP - VPH (ug/l)C5-C8 Aliphatics 32,000 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 700 700,000*
C9-C10 Aromatics 12,000 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 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

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

The electronic signature above is the equivalent of a handwritten signature.
This report shall not be reproduced,except in its entirety,without the written approval of Pace Analytical Services,LLC.
Pace Analytical Services,LLC (formerly Shealy Environmental Services,Inc.)
106 Vantage Point Drive West Columbia,SC 29172
Tel:[phone] Fax:[phone] www.pacelabs.com
Report of Analysis
Buxton Environmental
PO Box 11550
Charlotte,NC 28220
Attention:Ross Klingman
Project Name:Big Bill's Place
Project Number:16417
Lot Number:YC13028
Date Completed:03/24/2023
04/02/2023 2:47 PM
Approved and released by:
Project Manager II:Cathy S.Dover
Page 1 of 19
PACE ANALYTICAL SERVICES,LLC
SC DHEC No:32010001 NELAC No:E87653 NC DENR No:329 NC Field Parameters No:5639
Pace Analytical Services,LLC (formerly Shealy Environmetal Services,Inc.)
106 Vantage Point Drive West Columbia,SC 29172 [phone] Fax [phone] www.pacelabs.com
Case Narrative
Buxton Environmental
Lot Number:YC13028
This Report of Analysis contains the analytical result(s)for the sample(s)listed on the Sample Summary
following this Case Narrative.The sample receiving date is documented in the header information
associated with each sample.
All results listed in this report relate only to the samples that are contained within this report.Where
sampling is conducted by the client,results relate to the accuracy of the information provided,and as the
samples are received.
Sample receipt,sample analysis,and data review have been performed in accordance with the most
current approved The NELAC Institute (TNI)standards,the Pace Analytical Services,LLC ("Pace")
Laboratory Quality Manual,standard operating procedures (SOPs),and Pace policies.Any exceptions to
the TNI standards,the Laboratory Quality Manual,SOPs or policies are qualified on the results page or
discussed below.
Pace is a TNI accredited laboratory;however,the following analyses are currently not listed on our TNI
scope of accreditation:Drinking Water:VOC (excluding BTEX,MTBE,Naphthalene,&1,2-
dichloroethane)EPA 524.2,E.coli and Total coliforms SM 9223 B-2004,Solid Chemical Material:TOC
Walkley-Black,Biological Tissue:All,Non-Potable Water:SGT-HEM EPA 1664B,Silica EPA 200.7,
Boron,Calcium,Silicon,Strontium EPA 200.8,Bicarbonate,Carbonate,and Hydroxide Alkalinity SM 2320
B-2011,SM 9221 C E-2006 &SM 9222D-2006,Strontium SW-846 6010D,VOC SM 6200 B-2011,Fecal
Coliform Colilert-18.
If you have any questions regarding this report,please contact the Pace Project Manager listed on the
cover page.
Page 2 of 19
PACE ANALYTICAL SERVICES, LLC
Sample Summary
Buxton Environmental
Lot Number: YC13028

Project Name: Big Bill's Place
Project Number: 16417
Sample Number Sample ID Matrix Date Sampled Date Received
001 03/10/2023 0930MW-1 Aqueous 03/13/2023
002 03/10/2023 0945MW-1D Aqueous 03/13/2023
003 03/10/2023 1015MW-3 Aqueous 03/13/2023
004 03/10/2023 1045MW-5 Aqueous 03/13/2023
005 03/10/2023 1115MW-14 Aqueous 03/13/2023
(5 samples)
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Page 3 of 19
PACE ANALYTICAL SERVICES, LLC
Detection Summary
Buxton Environmental
Lot Number: YC13028

Project Name: Big Bill's Place
Project Number: 16417
Sample Sample ID Matrix Parameter Method Result Q Units Page
001 MW-1 Aqueous Benzene 8260D 6900 ug/L 5
001 MW-1 Aqueous Ethylbenzene 8260D 2300 ug/L 5
001 MW-1 Aqueous Toluene 8260D 3400 ug/L 5
001 MW-1 Aqueous Xylenes (total)8260D 16000 ug/L 5
002 MW-1D Aqueous Benzene 8260D 360 ug/L 6
002 MW-1D Aqueous Ethylbenzene 8260D 63 ug/L 6
002 MW-1D Aqueous Toluene 8260D 4.0 J ug/L 6
002 MW-1D Aqueous Xylenes (total)8260D 14 ug/L 6
003 MW-3 Aqueous Benzene 8260D 12000 ug/L 7
003 MW-3 Aqueous Ethylbenzene 8260D 3800 ug/L 7
003 MW-3 Aqueous Toluene 8260D 10000 ug/L 7
003 MW-3 Aqueous Xylenes (total)8260D 20000 ug/L 7
004 MW-5 Aqueous Benzene 8260D 3600 ug/L 8
004 MW-5 Aqueous Ethylbenzene 8260D 3600 ug/L 8
004 MW-5 Aqueous Toluene 8260D 1400 ug/L 8
004 MW-5 Aqueous Xylenes (total)8260D 17000 ug/L 8
005 MW-14 Aqueous Benzene 8260D 5300 ug/L 9
005 MW-14 Aqueous Ethylbenzene 8260D 3400 ug/L 9
005 MW-14 Aqueous Toluene 8260D 20000 ug/L 9
005 MW-14 Aqueous Xylenes (total)8260D 19000 ug/L 9
(20 detections)
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Page 4 of 19
Volatile Organic Compounds by GC/MS
Description:Matrix:
Date Received:
Client:Laboratory ID:
Date Sampled:
Buxton Environmental
MW-1
YC13028-001
03/10/2023 0930
03/13/2023
Aqueous
Project Name: Big Bill's Place
Project Number: 16417
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 5030B 8260D 100 03/15/2023 1726 JWO 70177
AnalyticalCAS
Parameter Number Method Result Q LOQ Units Run DL
Benzene 71-43-2 8260D 6900 1ug/L40100
Ethylbenzene 100-41-4 8260D 2300 1ug/L40100
Toluene 108-88-3 8260D 3400 1ug/L40100
Xylenes (total)1330-20-7 8260D 16000 1ug/L40100
AcceptanceRun 1
Surrogate Q % Recovery Limits
Bromofluorobenzene 104 70-130
1,2-Dichloroethane-d4 112 70-130
Toluene-d8 91 70-130
J = Estimated result < LOQ and > DL_
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
P = The RPD between two GC columns exceeds 40%ND = Not detected at or above the DL N = Recovery is out of criteria
H = Out of holding time
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
DL = Detection Limit
W = Reported on wet weight basis
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Page 5 of 19
Volatile Organic Compounds by GC/MS
Description:Matrix:
Date Received:
Client:Laboratory ID:
Date Sampled:
Buxton Environmental
MW-1D
YC13028-002
03/10/2023 0945
03/13/2023
Aqueous
Project Name: Big Bill's Place
Project Number: 16417
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
2 5030B 8260D 5 03/20/2023 0328 JMM2 70463
AnalyticalCAS
Parameter Number Method Result Q LOQ Units Run DL
Benzene 71-43-2 8260D 360 2ug/L2.05.0
Ethylbenzene 100-41-4 8260D 63 2ug/L2.05.0
Toluene 108-88-3 8260D 4.0 J 2ug/L2.05.0
Xylenes (total)1330-20-7 8260D 14 2ug/L2.05.0
AcceptanceRun 2
Surrogate Q % Recovery Limits
Bromofluorobenzene 89 70-130
1,2-Dichloroethane-d4 113 70-130
Toluene-d8 94 70-130
J = Estimated result < LOQ and > DL_
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
P = The RPD between two GC columns exceeds 40%ND = Not detected at or above the DL N = Recovery is out of criteria
H = Out of holding time
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
DL = Detection Limit
W = Reported on wet weight basis
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Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)

Page 6 of 19
Volatile Organic Compounds by GC/MS
Description:Matrix:
Date Received:
Client:Laboratory ID:
Date Sampled:
Buxton Environmental
MW-3
YC13028-003
03/10/2023 1015
03/13/2023
Aqueous
Project Name: Big Bill's Place
Project Number: 16417
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 5030B 8260D 500 03/15/2023 1906 JWO 70177
AnalyticalCAS
Parameter Number Method Result Q LOQ Units Run DL
Benzene 71-43-2 8260D 12000 1ug/L200500
Ethylbenzene 100-41-4 8260D 3800 1ug/L200500
Toluene 108-88-3 8260D 10000 1ug/L200500
Xylenes (total)1330-20-7 8260D 20000 1ug/L200500
AcceptanceRun 1
Surrogate Q % Recovery Limits
Bromofluorobenzene 100 70-130
1,2-Dichloroethane-d4 116 70-130
Toluene-d8 90 70-130
J = Estimated result < LOQ and > DL_
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
P = The RPD between two GC columns exceeds 40%ND = Not detected at or above the DL N = Recovery is out of criteria
H = Out of holding time
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
DL = Detection Limit
W = Reported on wet weight basis
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Page 7 of 19
Volatile Organic Compounds by GC/MS
Description:Matrix:
Date Received:
Client:Laboratory ID:
Date Sampled:
Buxton Environmental
MW-5
YC13028-004
03/10/2023 1045
03/13/2023
Aqueous
Project Name: Big Bill's Place
Project Number: 16417
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 5030B 8260D 200 03/15/2023 1816 JWO 70177
AnalyticalCAS
Parameter Number Method Result Q LOQ Units Run DL
Benzene 71-43-2 8260D 3600 1ug/L80200
Ethylbenzene 100-41-4 8260D 3600 1ug/L80200
Toluene 108-88-3 8260D 1400 1ug/L80200
Xylenes (total)1330-20-7 8260D 17000 1ug/L80200
AcceptanceRun 1
Surrogate Q % Recovery Limits
Bromofluorobenzene 98 70-130
1,2-Dichloroethane-d4 111 70-130
Toluene-d8 89 70-130
J = Estimated result < LOQ and > DL_
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
P = The RPD between two GC columns exceeds 40%ND = Not detected at or above the DL N = Recovery is out of criteria
H = Out of holding time
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
DL = Detection Limit
W = Reported on wet weight basis
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Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)

Page 8 of 19
Volatile Organic Compounds by GC/MS
Description:Matrix:
Date Received:
Client:Laboratory ID:
Date Sampled:
Buxton Environmental
MW-14
YC13028-005
03/10/2023 1115
03/13/2023
Aqueous
Project Name: Big Bill's Place
Project Number: 16417
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 5030B 8260D 200 03/15/2023 1841 JWO 70177
AnalyticalCAS
Parameter Number Method Result Q LOQ Units Run DL
Benzene 71-43-2 8260D 5300 1ug/L80200
Ethylbenzene 100-41-4 8260D 3400 1ug/L80200
Toluene 108-88-3 8260D 20000 1ug/L80200
Xylenes (total)1330-20-7 8260D 19000 1ug/L80200
AcceptanceRun 1
Surrogate Q % Recovery Limits
Bromofluorobenzene 104 70-130
1,2-Dichloroethane-d4 113 70-130
Toluene-d8 90 70-130
J = Estimated result < LOQ and > DL_
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
P = The RPD between two GC columns exceeds 40%ND = Not detected at or above the DL N = Recovery is out of criteria
H = Out of holding time
Q = Surrogate failure
L = LCS/LCSD failure
S = MS/MSD failure
DL = Detection Limit
W = Reported on wet weight basis
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Page 9 of 19
QC Summary
QC Data for Lot Number: YC13028
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Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)

Page 10 of 19
Volatile Organic Compounds by GC/MS - MB
Batch:Prep Method:
Sample ID:YQ70177-001
70177 5030B
Analytical Method:8260D
Matrix:Aqueous
Parameter Result Q LOQ DL Units Analysis DateDil
Benzene ND 03/15/2023 10581.0 0.40 ug/L1
Ethylbenzene ND 03/15/2023 10581.0 0.40 ug/L1
Toluene ND 03/15/2023 10581.0 0.40 ug/L1
Xylenes (total)ND 03/15/2023 10581.0 0.40 ug/L1
Surrogate Q % Rec
Acceptance
Limit
Bromofluorobenzene 96 70-130
1,2-Dichloroethane-d4 117 70-130
Toluene-d8 91 70-130
Note:Calculations are performed before rounding to avoid round-off errors in calculated results
LOQ = Limit of Quantitation ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
_DL = Detection Limit
* = RSD is out of criteria
QC Data for Lot Number: YC13028
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Page 11 of 19
Volatile Organic Compounds by GC/MS - LCS
Batch:Prep Method:
Sample ID:YQ70177-002
70177 5030B
Analytical Method:8260D
Matrix:Aqueous
Parameter
Result
Q % Rec
Spike
Amount
Analysis Date
%Rec
LimitDil(ug/L)(ug/L)
Benzene 47 03/15/2023 0917955070-1301
Ethylbenzene 50 03/15/2023 09171005070-1301
Toluene 50 03/15/2023 0917995070-1301
Xylenes (total)110 03/15/2023 091710910070-1301
Surrogate Q % Rec
Acceptance
Limit
Bromofluorobenzene 105 70-130
1,2-Dichloroethane-d4 111 70-130
Toluene-d8 92 70-130
Note:Calculations are performed before rounding to avoid round-off errors in calculated results
LOQ = Limit of Quantitation ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
_DL = Detection Limit
* = RSD is out of criteria
QC Data for Lot Number: YC13028
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Page 12 of 19
Volatile Organic Compounds by GC/MS - MB
Batch:Prep Method:
Sample ID:YQ70463-001
70463 5030B
Analytical Method:8260D
Matrix:Aqueous
Parameter Result Q LOQ DL Units Analysis DateDil
Benzene ND 03/19/2023 18421.0 0.40 ug/L1
Ethylbenzene ND 03/19/2023 18421.0 0.40 ug/L1
Toluene ND 03/19/2023 18421.0 0.40 ug/L1
Xylenes (total)ND 03/19/2023 18421.0 0.40 ug/L1
Surrogate Q % Rec
Acceptance
Limit
Bromofluorobenzene 93 70-130
1,2-Dichloroethane-d4 113 70-130
Toluene-d8 89 70-130
Note:Calculations are performed before rounding to avoid round-off errors in calculated results
LOQ = Limit of Quantitation ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
_DL = Detection Limit
* = RSD is out of criteria
QC Data for Lot Number: YC13028
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Page 13 of 19
Volatile Organic Compounds by GC/MS - LCS
Batch:Prep Method:
Sample ID:YQ70463-002
70463 5030B
Analytical Method:8260D
Matrix:Aqueous
Parameter
Result
Q % Rec
Spike
Amount
Analysis Date
%Rec
LimitDil(ug/L)(ug/L)
Benzene 48 03/19/2023 1738965070-1301
Ethylbenzene 50 03/19/2023 17381015070-1301
Toluene 51 03/19/2023 17381025070-1301
Xylenes (total)110 03/19/2023 173810610070-1301
Surrogate Q % Rec
Acceptance
Limit
Bromofluorobenzene 111 70-130
1,2-Dichloroethane-d4 111 70-130
Toluene-d8 97 70-130
Note:Calculations are performed before rounding to avoid round-off errors in calculated results
LOQ = Limit of Quantitation ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
_DL = Detection Limit
* = RSD is out of criteria
QC Data for Lot Number: YC13028
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Page 14 of 19
Volatile Organic Compounds by GC/MS - MS
Batch:Prep Method:
Sample ID:YC13028-002MS
70463 5030B
Analytical Method:8260D
Matrix:Aqueous
Parameter
Result
Q % Rec
Spike
Amount
Analysis Date
%Rec
Limit
Sample
Amount
Dil(ug/L)(ug/L)(ug/L)
Benzene 610 03/20/2023 04179725070-1303605
Ethylbenzene 350 03/20/2023 041711625070-130635
Toluene 290 03/20/2023 041711425070-1304.0 5
Xylenes (total)600 03/20/2023 041711650070-130145
Surrogate Q % Rec
Acceptance
Limit
Bromofluorobenzene 107 70-130
1,2-Dichloroethane-d4 109 70-130
Toluene-d8 105 70-130
Note:Calculations are performed before rounding to avoid round-off errors in calculated results
LOQ = Limit of Quantitation ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
_DL = Detection Limit
* = RSD is out of criteria
QC Data for Lot Number: YC13028
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)

Page 15 of 19
Volatile Organic Compounds by GC/MS - MSD
Batch:Prep Method:
Sample ID:YC13028-002MD
70463 5030B
Analytical Method:8260D
Matrix:Aqueous
Parameter
Result
Q % Rec
Spike
Amount
Analysis Date% RPD
%Rec
Limit
% RPD
Limit
Sample
Amount
Dil(ug/L)(ug/L)(ug/L)
Benzene 600 03/20/2023 04419425070-1301.6 203605
Ethylbenzene 340 03/20/2023 044111025070-1304.5 20635
Toluene 270 03/20/2023 044110625070-1307.0 204.0 5
Xylenes (total)560 03/20/2023 044110950070-1305.8 20145
Surrogate Q % Rec
Acceptance
Limit
Bromofluorobenzene 103 70-130
1,2-Dichloroethane-d4 103 70-130
Toluene-d8 99 70-130
Note:Calculations are performed before rounding to avoid round-off errors in calculated results
LOQ = Limit of Quantitation ND = Not detected at or above the DL
J = Estimated result < LOQ and > DL
N = Recovery is out of criteria
P = The RPD between two GC columns exceeds 40%
+ = RPD is out of criteria
_DL = Detection Limit
* = RSD is out of criteria
QC Data for Lot Number: YC13028
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)

Page 16 of 19
Chain of Custody
and
Miscellaneous Documents
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)

Page 17 of 19
PACE ANALYTICAL SERVICES, LLC

106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)

Page 18 of 19
PACE ANALYTICAL SERVICES, LLC

106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.pacelabs.com
Pace Analytical Services, LLC (formerly Shealy Environmental Services, Inc.)

Page 19 of 19