WI0100106_Permit_20101216

f � 5 - (Vab Z'
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
December 16, 2010
TO: Debra Watts C� j "1
FROM: Michael Rogers Al I
THROUGH: Thomas Slusser
1: Z/
RE: Issuance of permit to inject 1 % milk solution (Permit #WI0100106)
Milkco, Inc. - Former Andrei Industries Corp. Facility
I recommend that Permit Number WI0100106 be issued to Milkco Inc. to inject the above referenced injectant(s) to remediate
groundwater (GW) contaminated with volatile organic compounds (VOCs).
SITE DESCRIPTION: The site is a former textile manufacturing and dry cleaning facility located at 180 Deverview Rd.,
Asheville, Buncombe County, North Carolina 28806. Due to past use, the GW is contaminated with VOCs (primarily
PCE). Much of the property has been demolished, and has been accepted into the Brownfields Program by the DWM.
Milkco, Inc. has acquired the property and is planning to build on the site. The site has undergone groundwater
remediation in the past through pump and treat. The Applicant is now looking at an alternative remediation process
(Figure 1).
HYDROGEOLOGIC DESCRIPTION: The site is located within the Blue Ridge Belt geologic province. In the area of the site,
the overburden consists primarily of saprolite and partially weathered rock, with gneiss bedrock at approximately'30 feet
BLS. However, the property is very large and is situated on a topographic high. Therefore, thickness of the overburden
and depth to groundwater varies throughout the site. The injection for this project will be in the saprolite, PWR, and
bedrock. Since the site is on a topographic high, GW flow is generally radial. The highest velocity is approximately 750
feet/year (Figure 2).
EXTENT OF CONTAMINATION: The VOC plume is huge, and extends off -site approximately 2500 feet north to south (Figure
3). According to the information provided in the Additional Information request letter, there are no known water supply wells
within 1/4 mile.
PROPOSED INJECTION: The proposed injection will be in the plume and will consist of a total of 5 injection events (2
events per year for the first 2 years, then one event in the 3rd year). The information for the injection is below.
Injection
Well
Total AMT of
Injectant (gal)
Approximate
Days for
Injection
Appx. AMT
of Injectant
Per Well Per
Da al
Estimated
AMT of Fluid
Displacement
Potential
Displacement
of Plume
RW-1
15,816
19
832
5%
Low
RW-3
8852
23
385
5%
Low
RW-5
23,764
19
1251
5%
Low
RW-7
15,261
28
545
5%
Low
TOTAL
63,693
89
-
-
The Applicant is designing this injection to displace only approximately 5% of fluid displacement within a radius of 50 feet
of each injection well. The injection wells are highlighted in yellow on Figure 3.

c � ,reCeiWJ dOcvrnen
AA
�' 1-
s
_ 1milk; d f v,5. k P( N/V!.'lS e,
HOW IT WORKS: The Applicant is proposing to use a solution of % and 99% water. The will come from
Milkco Inc.'s facility after -dairy products are processed. The solution will come from the holding tanks after they are rinsed
with tap water from the city of Asheville. A bench study in the application seems to indicate this 1 % milk solution will
remediate groundwater contaminated with volatile organic compounds by stimulation of the biologic community
(bioremediation) and dechlorination of the contaminants.
MONITORING: The wells to be monitored are highlighted in blue on Figure 3. I have requested they modify the monitoring
plan as originally submitted to include sampling surface water locations BC-1, BC-2, SM-2, SM-3, SM-5, and possibly JW-1 if
the location is accessible. Additionally, field parameters are to be added to the parameter list. Surface water locations will also
be analyzed for TOC in addition to VOCs. The monitoring plan containing the parameters and sampling frequency is on Table
7. BLE, Inc. conducted annual assessment sampling for this site in October., Therefore', data from this sampling event will
fulfill the need to have a pre -injection, baseline sampling event.
EPIDEMIOLOGY: The DHHS has approved this solution as an injectant. Further, the NCDEH and the US Food and Drug
Administration have classified this product as"other ingredient" from the dairy plant's milk processing "recovery system" (refer
to the letters attached to the e-mail from Andrew Alexander, dated October 21, 2010).
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
Item #1-Submit a revised water supply well survey. The applicant provided this as part of the Additional Information request
(refer to spiral bound document dated November 23, 2010).
Item #2-Surface water impacts from more toxic (hazardous PCE degradation compounds produced by dechlorination. I have
requested that surface water sampling locations be added to the monitoring plan. EPA Method 8260 will include potential
daughter products.
Landon Davidson, and Brett Laverty of the Asheville RO, recommends. issuance of this permit.
a

5I Calculations Worksheet
Applicant/Facility: /lrll�r�cc� , E�i C
Permit No. WI �?,(//�
Date: 8Ah 0
Reviewer: �2b 6��IL�
Depth to groundwater (GW): V BLS
GW flow direction: AaA
MWs installed in same aquifer as injection?
(Y or N); Inj zone:
Nearest water supply well: O
Groundwater Flow Rate
�MW zone:
-HQ X„ _. 1 3 ,Z gradient(FT?) = flow rate/DAY(?) X 365 = FT/YR
SY or porosity (-.30)
[FYI- 60 min/day X 24 hrs X 365 days = 525,600]
culations for Potential Contaminate Plume Displacement
i .142 (7c) X _r2 X °/. height = a 3 Sr CF
a S'� CF X W -oS SY or porosity (i.e. -.30) _ `/ / -,7- CF of available void
space
CF of available void space X 7.48 gallons _gallons of water in void sp
fir,{, gallons of injectant = , �8 % of fluid displaced by injectant (move decimal)
3 j �� gallons of water in void space -31-70 /Vvo r'l-e-0 �y � f � T
Potential displacement of plume by injection:(q
'ection Volume and Pumping Rate Per Well Per Day + SAO-7a
total amt. of injectant / _number of wells / 1�number of days of injection event =
e 3 )- amount of injectant per well per day (average gallons per day)
S:UIC/Applications and forms/ 5I Calculations worksheet version 9/10/10

5I Calculations Worksheet
Notes
S:UIC/Applications and forms/ 5I Calculations worksheet version 9/10/10

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Milkco, Inc.
FOR THE CONSTRUCTION AND/OR OPERATION OF 4 TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject 1 % milk solution for
the enhanced bioremediation of volatile organic compounds. These injection wells/points will be
located at the Former Andrex Industries Corp. Facility located at 180 Deaverview Road, Asheville,
Buncombe County, NC 28806, and will be operated in accordance with the application submitted
June 30, 2010, and inconformity with the specifications and supporting data submitted, August 17,
2010, and December 3, 2010, all of which are filed with the Department of Environment and Natural
Resources and are considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the Water
Use Actor any other applicable Laws, Rules, or Regulations. Operation and use of an injection well
shall be in compliance with Title 15A North Carolina Administrative Code 2C .0100 and .0200, and
any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from the date of its issuance until November 30, 2013,
and shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 22nd day of December, 2010.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0100106 PAGE 1 OF 6
ver. Oct.2010 AP/UIC-6

PART I -WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and criteria
specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C .0200). Any
noncompliance with conditions of this permit constitutes a violation of the North Carolina Well
Construction Act and is grounds for enforcement action as provided for in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only for construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Aquifer Protection Section.
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during construction
and use.
8. Each injection well shall have permanently affixed an identification plate.
9. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify the
Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff, telephone
number [phone] and the Asheville Regional Office Aquifer Protection Section Staff,
telephone number [phone].
Permit No. WI0100106 PAGE 2 OF 6
ver. Oct.2010 AP/UIC-6

PART III - OPERATION AND USE GENERAL CONDITIONS
This permit is effective only with respect to the nature, volume of materials, rate of injection, and
number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to change
ownership, or there is a name change of the Permittee, a formal permit amendment request must
be submitted to the Director, including any supporting materials as may be appropriate, at least
30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying with
any and all statutes, rules, regulations, or ordinances which may be imposed by other local, state,
and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not
imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
The injection facility shall be effectively maintained and operated at all times so that there is no
contamination of groundwater which will render it unsatisfactory for normal use. In the event
that the facility fails to perform satisfactorily, including the creation of nuisance conditions or
failure of the injection zone to adequately assimilate the injected fluid, the Permittee shall take
immediate corrective actions including those actions that may be required by the Division of
Water Quality such as the repair, modification, or abandonment of the injection facility.
2. The Permittee shall be required to comply with the terms and conditions of this permit even if
compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director of
any planned alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
At least forty-eight (48) hours prior to the initiation of the operation of the facility for injection,
the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central Office staff,
telephone number [phone]. Notification is required so that Division staff can inspect or
otherwise review the injection facility and determine if it is in compliance with permit
conditions.
Permit No. WI0100-106 PAGE 3 OF 6
ver. Oct.2010 AP/UIC-6

PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality may,
upon presentation of credentials, enter and inspect any property, premises, or place on or related
to the injection facility at any reasonable time for the purpose of determining compliance with
this permit, may inspect or copy any records that must be maintained under the terms and
conditions of this permit, and may obtain samples of groundwater, surface water, or injection
fluids.
2. Department representatives shall have reasonable access for purposes of inspection, observation,
and sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
The proposed monitoring plan included in the application has been modified to include obtaining
field parameters during sampling, and to add surface water locations BC-1, BC-2, SM-2, SM-3, SM-5,
and JW-1, if the location is accessible, to the annual monitoring event. All sample results shall be
submitted to the Aquifer Protection Section's Asheville Regional Office and the Raleigh Central
Office. Any monitoring (including groundwater, surface water, or soil sampling) deemed
necessary by the Division of Water Quality to ensure surface and ground water protection, will
be established and an acceptable sampling reporting schedule shall be followed.
2. The Permittee shall submit an Injection Event Record within 30 days of completing.each
injection.
The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the injection
projects findings in a written summary. The final project evaluation' shall also contain,
monitoring well sampling data, contaminant plume maps and potentiometric surface maps.
4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Program
DENR-Division of Water.Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Permit No. WI0100106, PAGE 4 OF 6
ver. Oct.2010 AP/-JIC-6

5. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
the occurrence, to the Asheville Regional Office, telephone number [phone], any of the
following:
(A)Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
6. Where the Permittee becomes aware of an omission of any relevant facts in a permit application,
or of any incorrect information submitted in said application or in any report to the Director, the
relevant and correct facts or information shall be promptly submitted to the Director by the
Permittee.
7. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take such
immediate action as may be required by the Director.
PART VIII - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal. If a
well is not to be used for any purpose that well must be permanently abandoned according to
15A NCAC 2C .0214; Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .0214, including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom from
obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines that
failure to do so could lead to the contamination of an underground source of drinking
water.
Permit No. WI01 00 i 06 PAGE 5 OF 6
ver. Oct.2010 AP/UIC-6

(D) Drilled wells shalfbe completely filled -with cement grout or bentonite grout, which shall
be introduced into the well through a pipe which extends to the bottom of the well and is
raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely filling
it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has been
created, each well shall be abandoned in such a manner that will prevent the movement
of fluids into or between underground sources of drinking water and in accordance with
the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified in
15A NCAC 2C .0213(h)(1) within 30 days of completion of abandonment.
3. The written documentation required in Part IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows: eye,
skin, nose, throat, and lung irritation. If the product is released into the environment in a way
that could result in a suspension of fine solid or liquid particles (e.g., grinding, blending,
vigorous shaking or mixing), then proper personal protective equipment should be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
2. Persons working with these products should wear goggles or a face shield, gloves, .and protective
clothing. Face and body protection should be used for anticipated splashes or sprays.
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse reactions
and injuries.
Pen -nit No. WI01 CIO 106 PAGE 6 OF 6
ver. Oct.20 ] 0 AP/UIC-6 .

Telephone Record/Log
DATE: 5/5/15
Telephone Record/Log Completed By: Mike R.
Telephone Call ❑ Made To: Andrew Moore w/ARO
❑ Received From:
Telephone No.:828-296-4500
Permit or Well No.: 10100106
RE: Exceedances seen in surface water samples in lab report dated April 30, 2015
COMMENTS/NOTES: Andrew said that the region is aware of these exceedances. There is a
history of exceedances in the sw at this site, even prior to the infection activities. The DWM
also is aware as they have a Brownfields agreement with the

Rogers, Michael
From: Andrew W. Alexander <[e-mail]>
Sent: , Thursday, April 30, 2015 11:42 AM
To: Rogers, Michael
Cc: 4Moe'�'"`re,�A�ndr v�i W; Wahl, Tracy; Collins, Keith (Milkco); Gottdiener, Stephen (Andrex)
Subject: UIC Permit No. W10100106 Semi -Annual SW Submittal
Attachments: Transmittal UIC-rm-i?Wo- VV)N s& °6 emi-Annual SW 2015.pdf
Hello Michael,
I have attached the subject document. A hard copy will not be mailed unless
requested. Please contact me with any questions or comments. Thanks, --Andy
Andrew W. Alexander, P.G., RSM
Bunnell-Lammons Engineering, Inc. (BLE)
6004 Ponders Court
Greenville, South Carolina 29615
[phone] (voice)
[phone] (fax)
[phone] (cell)
andy(JWecorp.com
www.blecorp.com
This electronic transmission contains information from the consulting firm of Bunnell-Lammons Engineering, Inc., that may -be confidential or privileged.
The information is intended solely for the recipient. Use by any other party is not authorized. If you are not the intended recipient, be aware that any
disclosure, copying, distribution, or use of the contents of this information is prohibited. If you received this transmission in error, please notify us
immediately by telephone [phone]) or by email (info(a)blecorp.com). Thank you for your cooperation.

Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL
TO: Underground Injection Control Program
DWR — WQROS
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
ATTENTION: Mr. Michael Rogers
CC: Mr. Keith Collins — Milkco, Inc.
Ms. Tracy Wahl — NCDENR—Brownfields
Mr. Andrew Moore —DWR — WQROS (ARO)
Mr. Stephen Gottdiener — Andrex
DATE: April 30, 2015
RE: Andrex Industries Corp.
2015 Semi -Annual Surface Water Lab Data
UIC Permit No. WI0100106
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL.
® Lab Data ❑ Prints ❑ Change order ❑ Letter
❑ Other ❑ W.A.S. ❑ Plans ❑ Samples
❑ Proposal ❑ Preliminary Data:
THESE ARE TRANSMITTED AS CHECKED BELOW:
❑ For approval ❑ For your use ® As required ❑ Other
Number of copies: One
REMARKS: Michael,
❑ Copy of report
❑ Specifications
❑ For review and comment
The subject UIC permit requires that surface water sampling points BC-1 and JW-1 be sampled semi-
annually. The points were sampled on a c 7—,Xfff5 as art of h pre -injection lmselininampling
f, 15. The surface water laboratory results are attached. The second semi-annual sampling event
for these locations will be performed as part of the site -wide annual event which will be conducted in
September 2015 and reported under separate cover.
a
Andrew W. Alex4nder, P.G.
Senior Hydrogeologist
e:\awa projects\andrex milkco\phase42 injection and monitoring 2015\1022-42 semi-annual sw submittal\transmittal 2015 sw
transmittal rogers.doex

12065 Lebanon Rd.
Mt. Juliet, TN 37122
(615) 758-5$58
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
Est. 1970
Mr. Andy Alexander
Bunnell - Lammons Engineering, Inc.
6004 Ponders Court
Greenville, SC 29615
Report Summary
Wednesday April 08, 2015
Report Number: L756288
Samples Received: 03/28/15
Client Project: J15.-1022-42
Description: Andrex Industries
The analytical results in this report are based upon information supplied
by you, the client, and are for your exclusive use. If you have an
questions regarding this data package, please do not hesitate to caly
l.
Entire Report Reviewed By:
Ji4 Hunt , ESC Representative
Laboratory Certification Numbers
A2LA - 1461-01, AIHA - 100789, AL - 40660, CA - 01157CA, CT - PH-0197,
FL - E87487, GA - 923, IN - C-TN-01., KY - 90010, KYUST - 0016,
NC - ENV375/DW21704/BIO041, ND - R-140. NJ - TN002, NJ NELAP - TN002,
SC - 84004, TN - 2006, VA - 460132, WV - 233, AZ - 0612,
MN - 047-999-395, NY - 11742, WI - 998093910, NV - TN000032011-1,
TX - T104704245-11-3, OK - 9915', PA - 68-02979, IA Lab #364, EPA - TNO02
Accreditation is only applicable to the test methods specified on each scope of accreditation held
by ESC Lab Sciences.
This report may not be reproduced, except in full, without written approval from ESC Lab Sciences.
Where applicable, sampling conducted by ESC is performed per guidance provided
in laboratory standard operating procedures: 060302, 060303, and 060304.
R
Page 1 of 21

OESC
I
REPORT OF ANALYSIS
Mr. Andy Alexander
Bunnell - Lammons Engineering, Inc.
6004 Ponders Court
Greenville, SC 29615
Date Received March 28, 2015
Description Andrex Industries
Sample ID BC-1
Collected By Benjamin P. Nisbeth
Collection Date 03/27/15 13:45
12065 Lebanon Rd.
Mt. Juliet, TN 37122
[phone]
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
Est. 1970
April 08,2015
ESC Sample # L756288-08
Site ID ASHEVILLE, NC
Project # J15-1022-42
Parameter
Result
Det. Limit
Units
Method
Date
Dil.
TOC (Total Organic Carbon)
BDL
1000
ug/l
9060A
03/31/15
1
Volatile Organics
Acetone
BDL
50.
ug/l
8260B
04/08/15
1
Acrolein
BDL
50.
ug/1'
8260B
04/08/15
1
Acrylonitrile
BDL
10.
ug/l
8260B
04/08/15
1
Benzene
BDL
1.0
ug/l
8260B
04/08/15
1
Bromobenzene
BDL
1.0
ug/l
8260B
04/08/15
1
Bromodichloromethane
BDL
1.0
ug/l
8260B
04/08/15
1
Bromoform
BDL
1.0
ug/l
8260B
04/08/15
1
Bromomethane
BDL
5.0
ug/l
8260B
04/08/15
1
n-Butylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
sec-Butylbenzene
BDL
1.0
ug/1
8260B
04/08/15
1
tert-Butylbenzene
BDL
1.0
ug/1
8260B
04/08/15
1
Carbon tetrachloride
BDL
1.0
ug/l
8260B
04/08/15
1
Chlorobenzene
BDL
1.0
ug/1
8260B
04/08/15
1
Chlorodibromomethane
BDL
1.0
ug/l
8260B
04/08/15
1
Chloroethane
BDL
5.0
ug/l
8260B
04/08/15
1
2-Chloroethyl vinyl ether
BDL
50.
ug/l
8260B
04/08/15
1
Chloroform
BDL
5.0
ug/1
8260B
04/08/15
1
Chloromethane
BDL
2.5
ug/l
8260B
04/08/15
1
2-Chlorotoluene
BDL
1.0
ug/l
8260B
04/08/15
1
4-Chlorotoluene
BDL
1.0
ug/l
8260B
04/08/15
1
1,2-Dibromo-3-Chloropropane
BDL
5.0
ug/l
8260B
04/08/15
1
1,2-Dibromoethane
BDL
1.0
ug/l
8260B
04/08/15
1
Dibromomethane
BDL
1.0
ug/l
8260B�
04/08/15
1
1,2-Dichlorobenzene
BDL
1.0
ug/1
8260B
04/08/15
1
1,3-Dichlorobenzene
BDL
1.0
ug/l
8260B
04/08/15
1
1,4-Dichlorobenzene
BDL
1.0
ug/l
8260B
04/08/15
1
Dichlorodifluoromethane
BDL
5.0
ug/1
8260B
04/08/15
1
1,1-Dichloroethane
BDL
1.0
ug/l
8260B
04/08/15
1
1,2-Dichloroethane
BDL
1.0
ug/l
8260B
04/08/15
1
1,1-Dichloroethene
BDL
1.0
ug/1
8260B
04/08/15
1
cis-1,2-Dichloroethene
5.3
1.0
ug/l
8260B
04/08/15
1
trans-1,2-Dichloroethene
BDL
1.0
ug/l
8260B
04/08/15
1
1,2-Dichloropropane
BDL
1.0
ug/l
8260B
04/08/15
1
1,1-Dichloropropene
BDL
1.0
ug/l
8260B
04/08/15
1
1,3-Dichloropropane
BDL
1.0
ug/l
8260B
04/08/15
1
cis-1,3-Dichloropropene
BDL
1.0
ug/l
8260B
04/08/15
1
trans-1,3-Dichloropropene
BDL
1.0
ug/l
8260B
04/08/15
1
2,2-Dichloropropane
BDL
1.0
ug/1
8260B
04/08/15
1
Di -isopropyl ether
BDL
1.0
ug/l
8260B
04/08/15
1
Ethylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
Hexachloro-1,3-butadiene
BDL
1.0
ug/l
8260B
04/08/15
1
BDL - Below Detection Limit
Det. Limit - Practical Quantitation
Limit(PQL)
Page 16 of 21

12065 Lebanon Rd.
Mt. Juliet, TN 37122
[phone]
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
Est. 1970
REPORT
OF ANALYSIS
Mr. Andy Alexander
April
08,2015
Bunnell - Lammons Engineering, Inc.
6004 Ponders Court
Greenville, SC 29615
ESC
Sample #
L756288-08
Date Received March 28, 2015
Description Andrex Industries
Site
ID ASHEVILLE, NC
Sample ID BC-1
Project
#
J15-1022-42
Collected By Benjamin P. Nisbeth
Collection Date 03/27/15 13:45
Parameter
Result
Det. Limit
Units
Method
Date
Dil.
Isopropylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
p-Isopropyltoluene
BDL
1.0
ug/1
8260B
04/08/15
1
2-Butanone.(MEK)
BDL
10.
ug/l
8260B
04/08/15
1
Methylene Chloride
BDL
5.0
ug/1
8260B
04/08/15
1
4-Methyl-2-pentanone (MIBK)
BDL
10.
ug/l
8260B
04/08/15
1
Methyl tert-butyl ether
BDL
1.0
ug/1
8260B
04/08/15
1
Naphthalene
BDL
5.0
ug/1
8260B
04/08/15
1
n-Propylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
Styrene
BDL
'1.0
ug/l
8260B
04/08/15
1
1,1,1,2-Tetrachloroethane
BDL
1.0
ug/l
8260B
04/08/15
1
1,1,2,2-Tetrachloroethane
BDL
1.0
ug/l
8260B
04/08/15
1
1,1,2-Trichlorotrifluoroethane
BDL
1.0
ug/1
8260B
04/08/15
1
Tetrachloroethene
19.
1.0
ug/1
8260B
04./08/15
1
Toluene
BDL
5.0
ug/1
8260B
04/08/15
1
1,2,3-Trichlorobenzene
BDL
1.0
ug/1
8260B
04/08/15
1
1,2,4-Trichlorobenzene
BDL
1.0
ug/1
8260B
04/08/15
1
1,1,1-Trichloroethane
BDL
1.0
ug/1
8260B
04/08/15
1
1,1,2-Trichloroethane
BDL
1.0
ug/l
8260B
04/08/15
1
Trichloroethene
1.7
1.0
ug/l
8260B
04/08/15
1
Trichlorofluoromethane
BDL
5.0
ug/l
8260B
04/08/15
1
1,2,3-Trichloropropane
BDL
2.5
ug/l
8260B
04/08/15
1
1,2,4-Trimethylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
1,2,3-Trimethylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
1,3,5-Trimethylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
Vinyl chloride
BDL
1.0
ug/l
8260B
04/08/15
1
Xylenes, Total
BDL
3.0
ug/l
8260B
04/08/15
1
Surrogate Recovery
Toluene-d8
110.
% Rec.
8260B
04/08/15
1
Dibromofluoromethane
109.
o Rec.
8260B
04/08'/15
1
4-Bromofluorobenzene
101.
% Rec.
8260B
04/08/15
1
BDL - Below Detection Limit
Det. Limit - Practical Quantitation Limit(PQL)
Note:
The reported analytical results relate only to the sample submitted.
This report shall not be reproduced, except in full, without the written approval from ESC.
Reported: 04/08/15 14:01 Printed: 04/08/15 14:02
Page 17 of 21
r

REPORT OF ANALYSIS
Mr. Andy Alexander
Bunnell - Lammons Engineering, Inc.
6004 Ponders Court
Greenville, SC 29615
Date Received March 28, 2015
Description Andrex Industries
Sample ID JW-1
Collected By Benjamin P. Nisbeth
Collection Date 03/27/15 14:15
Parameter Result
TOC (Total Organic Carbon) BDL
Volatile Organics
Acetone
BDL
Acrolein
BDL
Acrylonitrile
BDL
Benzene
BDL
Bromobenzene
BDL
Bromodichloromethane
BDL
Bromoform
BDL
Bromomethane
BDL
n-Butylbenzene
BDL
sec-Butylbenzene
BDL
tert-Butylbenzene
BDL
Carbon tetrachloride
BDL
Chlorobenzene
BDL
Chlorodibromomethane
BDL
Chloroethane
BDL
2-Chloroethyl vinyl ether
BDL
Chloroform
BDL
Chloromethane
BDL
2-Chlorotoluene
BDL
4-Chlorotoluene
BDL
1,2-Dibromo-3-Chloropropane
BDL
1,2-Dibromoethane
BDL
Dibromomethane
BDL
.1,2-Dichlorobenzene
BDL
1,3-Dichlorobenzene
BDL
1,4-Dichlorobenzene
BDL
Dichlorodifluoromethane
BDL
1,1-Dichloroethane
BDL
1,2-Dichloroethane
BDL
1,1-Dichloroethene
BDL
cis-1,2-Dichloroethene
BDL
trans-1,2-Dichloroethene
BDL
1,2-Dichloropropane
BDL
1,1-Dichloropropene
BDL
1,3-Dichloropropane
BDL
cis-1,3-Dichloropropene
BDL
trans-1,3-Dichloropropene
BDL
2,2-Dichloropropane
BDL
Di -isopropyl ether
BDL
Ethylbenzene
BDL
Hexachloro-1,3-butadiene
BDL
BDL - Below Detection Limit
Det. Limit - Practical Quantitation Limit(PQL)
12065 Lebanon Rd.
Mt. Juliet, TN 37122
[phone]
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
Est. 1970
April 08,2015
ESC Sample # : L756288-09
Site ID ASHEVILLE, NC
Project # J15-1022-42
Det. Limit
Units
Method
Date
Dil.
1000
ug/1
9060A
03/31/15
1
50.
ug/1
8260B
04/08/15
1
50.
ug/l
8260B
04/08/15
1
10.
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0,
ug/l
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
5.0
ug/1
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
5.0
ug/l
8260B
04/08/15
1
50.
ug/1
8260B
04/08/15
1
5.0
ug/1
8260B
04/08/15
1
2.5
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
5.0
ug/l
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
5.0
ug/1
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
1.0
ug/1
8260B
04/08/15
1
1.0
ug/l
8260B
04/08/15
1
Page 18 of 21

OESC
I
12065 Lebanon Rd.
Mt. Juliet, TN 37122
[phone]
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
-
Est.
1970
REPORT
OF ANALYSIS
Mr. Andy Alexander
April
08,2015
Bunnell - Lammons Engineering, Inc.
6004 Ponders Court
Greenville, SC 29615
ESC
Sample
# L756288-09
Date Received March 28, 2015
Description Andrex Industries
Site
ID
ASHEVILLE, NC '
Sample ID JW-1
Project
#
J15-1022-42
Collected By Benjamin P. Nisbeth
Collection Date 03/27/15 14:15
Parameter
Result
Det. Limit
Units
Method
Date
Dil.
Isopropylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
p-Isopropyltoluene
BDL
1.0
ug/l
8260B
04/08/15
1
2-Butanone (MEK)
BDL
10.
ug/1
8260B
04/08/15
1
Methylene Chloride
BDL
5.0
ug/l
8260B
04/08/15
1
4-Methyl-2-pentanone (MIBK)
BDL
10.'
ug/l
8260B
04/08/15
1
Methyl tert-butyl ether
BDL
1.0
ug/1
8260B
04/08/15
1
Naphthalene
BDL
5.0
ug/l
8260B
04/08/15
1
n-Propylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
Styrene
BDL
1.0
ug/l
8260B
04/08/15
1
1,1,1,2-Tetrachloroethane
BDL
1.0
ug/l
8260B
04/08/15
1
1,1,2,2-Tetrachloroethane
BDL
1.0
ug/1
8260B
04/08/15
1
1,1,2-Trichlorotrifluoroethane
BDL
1.0
ug/l
8260B
04/08/15
1
Tetrachloroethene
2.7
1.0
ug/l
8260B
04/08/15
1
Toluene
BDL
5.0
ug/l
8260B
04/08/15
1
1,2,3-Trichlorobenzene
BDL
1.0
ug/1
8260B
04/08/15
1
1,2,4-Trichlorobenzene
BDL
1.0
ug/l
8260B
04/08/15
1
1,1,1-Trichloroethane
BDL
1.0
ug/l
8260B
04/08/15
1
1,1,2-Trichloroethane
BDL
1.0
ug/1
8260B
04/08/15
1
Trichloroethene
BDL
1.0
ug/l
8260B
04/08/15
1
Trichlorofluoromethane
BDL
5.0
ug/l
8260B
04/08/15
1
1,2,3-Trichloropropane
BDL
2.5
ug/1
8260B
04/08/15
1
1,2,4-Trimethylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
1,2,3-Trimethylbenzene
BDL
1.0
ug/l
8260B
04/08/15
1
1,3,5-Trimethylbenzene
BDL
1.0
ug/1
8260B
04/08/15
1
Vinyl chloride
BDL
1.0
ug/l
8260B
04/08/15
1
Xylenes, Total
BDL
3.0
ug/1
8260B
04/08/15
1
Surrogate Recovery
Toluene-d8
109.
% Rec.
8260B
04/08/15
1
Dibromofluoromethane
108.
% Rec.
8260B
04/08/15
1
4-Bromofluorobenzene
102.
% Rec.
8260B
04/08/15
1
BDL - Below Detection Limit
Det. Limit - Practical Quantitation Limit(PQL)
Note:
The reported analytical results relate only to the sample submitted.
This report shall not be reproduced, except in full, without the written approval from ESC.
Reported: 04/08/15 14:01 Printed: 04/08/15 14:02
Page 19 of 21

Attachment A
List
of Analytes with QC Qualifiers
Sample
Work
Sample
Number
Group
Type
Analyte
L756288-01
WG779515
SAMP
n-Butylbenzene
WG780646
SAMP
2-Chloroethyl vinyl ether
WG779515
SAMP
2,2-Dichloropropane
WG779515
SAMP
1,2,3-Trimethylbenzene
L756288-02
WG779515
SAMP
n-Butylbenzene
WG780646
SAMP
2-Chloroethyl vinyl ether
WG779515
SAMP
2,2-Dichloropropane
WG779515
SAMP
1,2,3-Trimethylbenzene
L756288-03
WG779515
SAMP
n-Butylbenzene
WG780646
SAMP
2-Chloroethyl vinyl ether
WG779515
SAMP
2,2-Dichloropropane
WG779515
SAMP
1,2,3-Trimethylbenzene
L756288-04
WG779514
SAMP
2-Chloroethyl vinyl ether
WG779514
SAMP
Vinyl chloride
L756288-08
WG780646
SAMP
n-Butylbenzene
WG780646
SAMP
2-Chloroethyl vinyl ether
WG780646
SAMP
2,2-Dichloropropane
L756288-09
WG780646
SAMP
n-Butylbenzene
WG780646
SAMP
2-Chloroethyl vinyl ether
WG780646
SAMP
2,2-Dichloropropane
Run
ID Qualifier
R3029010 J4
R3029509 J4
R3029010 J4
R3029010 J4
R3029010 J4
R3029509 J4
R3029010 J4
R3029010 J4
R3029010 J4
R3029509 J4
R3029010 74
R3029010 J4
R3028770 J6
R3028770 J6
R3029509 J4
R3029509 J4
R3029509 J4
R3029509 J4
R3029509 J4
R3029509 J4
Page 20 of 21

Attachment B
Explanation of QC Qualifier Codes
Qualifier Meaning
J4 The associated batch QC was outside the established quality control range
for accuracy.
J6 The sample matrix interfered with the ability to make any accurate
determination; spike value is low
Qualifier Report Information
ESC utilizes sample and result qualifiers as set forth by the EPA Contract Laboratory Program and
as required by most certifying bodies including NELAC. In addition to the EPA qualifiers adopted
by ESC, we have implemented ESC qualifiers to provide more information pertaining to our analytical
results. Each qualifier is designated in the qualifier explanation as either EPA or ESC.
Data qualifiers are intended to provide the ESC client with more detailed information concerning
the potential bias of reported data. Because of the wide range of constituents and variety of -
matrices incorporated by most EPA methods,it is common for some compounds to fall outside of
established ranges. These exceptions are evaluated and all -reported data is valid and useable
"unless qualified as 'R' (Rejected)."
Definitions
Accuracy - The relationship of the observed value of a known sample to the
true value of a known sample. Represented by percent recovery and
relevant to samples such as: control samples, matrix spike recoveries,
surrogate recoveries, etc.
Precision - The agreement between a set of samples or between duplicate samples.
Relates to how close together the results are and is represented by
Relative Percent Differrence.
Surrogate - Organic compounds that are similar in chemical composition, extraction,
and chromotography to analytes of interest. The surrogates are used to
determine the probable response of the group of analytes that are chem-
ically related to the surrogate compound. Surrogates are added to the
sample and carried through all stages of preparation and analyses.
TIC - Tentatively Identified Compound: Compounds detected in samples that are
not target compounds, internal standards, system monitoring compounds,
or surrogates.
Page 21 of 21

Billing Information;
Anaty�is
%
Cortair5et',/
Pr&5r+ruatine
Chain of 'Custgdy ragr — G1
Bunnell - Lammons Engineering, Inc.
PrajeCt Manager
*E�)�
6004 Panders Court
6004 Panders Court
Greenville, SC 29615
Greenville, SC 29615
E
lrhonr6]S.rsR4ti#
moue l~'Yebtnm N3 o
1llauat Iu�H, T19 S7I22
7.-
rawc1 q tSu �115
Report to:
Mr, Andy Alexander
Email [e-mail]
€aj�ct
City/Stat
�t�Liz,�"
Desrriptjon: Andrei Industries
Collected
Lab Projtct M
64-28 -126
Phone $64 �$$ 1265
Client Project It
J14.1022-40
SUNLAMGSC-JI4102240
J166
Fax; $ 4430
ra
a.
Atcin r. BUNLAMGSC
Collected by ipiintl:
Site/Fatuity ID x
P.O. e
p, yht
ASHEVILLE, NC
�
Template;1r98401
Preleglw P5030465
1SR° 35n ldmnTy Hu kt
Collected by (signaivat,e
Ruxh i sib € u T Beae Netitiedj
_ Same Aay tCtY^4
Renultt Need +d
• �"" _
—
ediatety
v"
Packed pet Ice N .�... �` _..
Moa t day,., 100%
_ twnDay 5{Y�t
Three Day ......,.
_..,.. ,..........259t
Email? X -yes
FAX? N � _._,y�°S
"`LP,
01
r�i
c
Shl eat sue.
pp v FedFX Ground
r
Sample ID
Comp/Grab
Matrix
Depth
Date
Time
r7 tiir
! j '
.S,
t i�'4.'
X
X
iY t
GW
3
3
X
X
Xq
'X
.a
_.._
_.......
x3
W - 1 L
Val
GW
'�' I
I( d
yye��tr'� ��
I W AA
GW
3 ' I
3
X
X
t t
GW
` I
y
6"
3
X
4n 3-
G W
I�
3
X
X
2Tri
j
I a�s
_
f
lr,
GW
,
J4
3
X
X .
law
3
x
X
GW 3 X
Matrix; SS - $nit GW - Groundwater WW - Wastewater 0W - Drinking Water OT . Other ..
—
pN Temp
Remarks:
3? 3) �/.
Flow Othee Hale! A
Relinquished by : (Signatur
bate:
timer
Received by' lrxignatorrl
Sample,returned via: 0 UPS L intlltlDet � jlab i�se actlyj
�
J
EJ F ,c 0 Couner ©
Rel n ed by : l5ip,l sc�rc<j
Date:
Time:Rec:eiaer9
by', I gnaturej
Tent Pnttlt°e Fkrceivll .mo t
a
l COC Seal liltattt; _ r A
Retinqutshed by:
Time:
Received for iab by{SIR a urel
pats: ;.rr) pH Chet eel:
rltF: