WI0100106_Permit (Issuance)_20181121

ROY COOPER
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MICHAEL S. REGAN
LINDA CULPEPPER
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Mr. Keith Collins, President
Milkco, Inc.
P.O. Box 16160
Asheville, NC 28816
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NORTH CAROLINA
Frwronmentard Quality
November 21, 2018
Re: Issuance of Injection Permit WI0100106
Fo"tmer Andres Industries Corp. Facility
Buncombe County, NC
Dear Mr. Collins:
In accordance with the permit renewal with modification request received on September 28, 2018,
and additional information -re c'eived November 7, 2018, and November 19, 2018, we are forwarding
permit number WI0100106. This permit is to inject 1 % milk solution to remediate groundwater
contaminated with VOCs at the above referenced facility.
This permit shall be effective from December 1, 2018 (i.e., the day after the expiration date of the
existing permit), which may differ from the date of this letter, until November 30, 2023, and shall be
subject to the conditions and limitations stated therein, including the requirement to submit a Final
Project Evaluation (FPE) as stated in PART VII — MONITORING AND REPORTING
REQUIREMENTS. Please read the entire permit to ensure that you are aware of all compliance
requirements of the permit.
Please note the following:
Per permit condition VI.2, sample results shall be submitted to the WQROS Central
Office and Raleigh Regional Office annually starting from date permit is issued.
Monitoring reports shall include, a summary of injection activities and monitoring
results, historical analytical data presented in a tabular/spreadsheet format distinguishing
between pre -injection and post injection data, and an update on the status and location of
monitoring and injection wells;.
North Carolina Department of Environmental Quality I Division of Water Resources I AFOGW Section
512 North Salisbury Street 11636 Mail Service Center I Raleigh, North Carolina 27699-1636
919.707.9129

• Per permit condition Part VI.S, prior to closing this permit, the Permittee must meet
groundwater quality standards or pre -injection levels, whichever concentration is higher
for all of the injection constituents; otherwise, continued monitoring as approved in the
monitoring plan will be required until such levels can be established;
• Per permit conditions Part VI.3 &4, and IX.2(G), within 30 days after each injection
event, please provide the well construction (if not previously submitted) and injection
information on the applicable forms listed below. Note: if well
construction/abandonment information is essentially the same (e.g., direct push points or
geo-probes), then only one GW-1 or GW-30 form is needed. Just indicate in the
comments section on the form the total number of well points. These forms are available
on the Division of Water Resources' website at https:Hdeq.nc.gov/about/divisions/water-
resources/water-resources-permits/wastewater-brancb/ground-water-protection/ ogr und-
water-applications
➢ Injection Event Record
➢ Well Construction Record (GW-1)
➢ Well Abandonment Record (GW-30)
In order to continue uninterrupted legal use of this well for the stated purpose, you should submit an
application to renew the permit 120 days prior to its expiration date. As indicated in the permit, this
permit is not ttansferable to any person without prior notice to, and approval by, the Director of the
Division of Water Resources. If you have any questions regarding your permit or the Underground
Injection Control Program, please call me at [phone].
Best Regards,
Michael Rogers, P.G. (NC & FL)
Underground Injection Control (UIC) Manager - Hydrogeologist
Division of Water Resources
Water Quality Regional Operations Section
cc: Landon Davidson, Zan Price WQROS — Asheville Regional Office
Central Office File, WI0100106
Andrew Alexander, Bunnell-Lammons Engineering, Inc., 6004 Ponders Court, Greenville, SC
29615

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH, NORTH CAROLINA
PERMIT FOR THE USE 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 6 (six) IN SITU REMEDIATION /
TRACER INJECTION WELLS (4 existing and 2 proposed), defined in Title 15A North Carolina
Administrative Code 2C .0209(5)(b)(viii), to inject the following additives (either individually or
in combination): 1 % milk solution, for the remediation of groundwater contaminated with volatile
organic compounds (VOCs) products. 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 permit renewal with modification request
received September 18, 2018, and _in conformity with the specifications and supporting data
submitted November 7, 2018, and November 19, 2018, all of which are filed with the Department
of Environmental Quality and are considered a part of this permit.
This permit is for continued monitoring only, and does not waive any provisions of the Water Use
Act or 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 02C .0100 and .0200,
and any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from December 1, 2018 (i.e., the day after the
expiration date of the existing permit), until November 30, 2023.
Permit issued this the 21 st day of November 2018.
�o Linda Culpepper, Interim Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. WI0100106 PAGE 1 OF 7
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r
PART I — PERMIT GENERAL CONDITIONS
1. The Permittee shall 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).
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 [I 5A
NCAC 02C .0211(1)].
3. This permit is valid only for construction or operation 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 Division of Water Resources (DWR) [15A NCAC
.0211(a)].
4. This permit is not transferable without prior notice and approval. 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 and any supporting materials must be submitted at least 30 days prior to
the date of the change [15A NCAC 02C .021 I(q)].
5. The issuance of this permit shall not relieve the Permittee of the responsibility of complying
with any and all statutes, rules, regulations, or ordinances that may be imposed by other local,
state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit does
not imply that all regulatory requirements have been met [ 15A NCAC 02C .0203].
PART II - WELL CONSTRUCTION GENERAL CONDITIONS
1. Each injection well shall not hydraulically connect separate aquifers [15A NCAC 02C
.0211(c)].
2. Multi -screened wells shall not hydraulically connect different aquifers or zones having
differences in water quality that would result in a degradation of any aquifer or zone [15A
NCAC 02C .0225(g)(17)].
3. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen [15A NCAC 02C .0225(g)(4)].
4. Bentonite grout shall not be used to seal any water -bearing zone with a chloride concentration
equal to or greater than 1,500 milligrams per liter. In areas where elevated chloride levels are
known to exist or are probable, such as coastal areas, chloride levels shall be verified in the
field to determine existing conditions. [15A NCAC .0225(g)(8)].
5. 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 shall be secured with a locking cap as defined in G.S. 87-85(16) [15A
NCAC 02C .0225(g)(23)].
Permit No. WI0100106 PAGE 2 OF 7
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6. Each injection well shall be afforded reasonable protection against damage during construction
and use [15A NCAC 02C .0225(i)(3)].
7. Each permanent injection well shall ' have a permanently affixed identification plate [15A
NCAC .0225(g)(20)].
8. A copy of the completed Well Construction Record (Form GW-I) shall be submitted as
described in Part VI.3 of this permit (the original document goes to the address indicated on
the form).
PART III - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing or operating any injection well, the
Permittee shall notify the Underground Injection Control (UIC) Central Office staff, telephone
number 919-807-6406, and the Asheville Regional Office staff, telephone number 828-296-
4500 [15A NCAC 02C-.0211(k)].
PART IV - OPERATION AND USE CONDITIONS
1. 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 [15A NCAC 02C
.02110)].
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface water or groundwater resulting from the operation of this facility [ 15A NCAC 02C
.0206].
The injection facility shall be properly maintained and operated at all times to achieve
compliance with the conditions of this permit and the rules of 15A NCAC 02C .0200, even
if compliance requires a reduction or elimination of the permitted activity [ 15A NCAC 02C
.02110)].
4. 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 that may be required, such as the repair,
modification, or abandonment of the injection facility [15A NCAC 02C .0206].
Permit No. WI0100106 PAGE 3 OF 7
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PART V - INSPECTIONS [15A NCAC 02C .0211(k)]
Any duly authorized officer, employee, or representative of the Division of Water Resources
(DWR) 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. DWR 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 VI - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application and modified per Additional
Information received November 7, 2018, shall be followed. Any additional monitoring,
including groundwater, surface water, or soil sampling, deemed necessary to ensure surface
water and groundwater protection may be established and an acceptable sampling reporting
schedule shall be followed [ 15A NCAC 02C .02250)].
2. An Annual Report with all historical monitoring results shall be submitted in bound hard copy
format with attached CD or flash drive to the WQROS Central Office, and Asheville Regional
Office starting from date permit is issued. Monitoring reports shall include, a summary of
injection activities and monitoring results, analytical data presented in a spreadsheet
distinguishing between pre -injection and post injection data, and an update on the status and
location of monitoring and injection wells. Well locations may be given in a table with the
name and geographic coordinates or shown on an updated version of the site map [ 15A NCAC
02C .0225(k)(2)].
3. Records of well construction, repair, or abandonment shall be submitted within 30 days of
completion of such activities [15A NCAC 02C .0225(k)(1)(A)].
4. An Injection Event Record shall be submitted within 30 days of each injection event [15A
NCAC 02C .0225(k)(1)(B)].
5. The Permittee shall submit a Final Project Evaluation (FPE) within 9 months after completing
all injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume and
potentiometric surface maps. PLEASE NOTE: Inj ectants and related reaction byproducts must
attenuate to pre -injection concentrations or groundwater standards specified in rule 15A NCAC
02L .0202, whichever is greater, in order for this permit to be closed. Otherwise, corrective
action as described in Part VII may be required [15A NCAC 02C .0225(k)(2)].
Permit No. WI0100106 PAGE 4 OF 7
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6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program
NC Division of Water Resources and
1636 Mail Service Center
Raleigh, NC 27699-1636
Water Quality Regional Operations Section
DWR Asheville Regional Office
2090 US Hwy 70
Swannanoa, NC 28778
7. The Permittee shall report any monitoring or other information that indicates noncompliance
with a specific permit condition, that a contaminant may cause a violation of applicable
groundwater quality standards, or that a malfunction of the injection system may cause the
injected fluids to migrate outside the approved injection zone or area. As specified in rule
15A NCAC 02C .0211(r), noncompliance notification shall be as follows:
(A) Oral notification shall be given within 24 hours of the occurrence, or first knowledge
of the occurrence, to the Asheville Regional Office, telephone number 828-296-4500.
(B) Written notification shall be made within five days of the occurrence and submitted
to the addresses in Item #6 above.
(C) The written notification shall contain a description of the noncompliance and its
cause; the period of noncompliance, including dates and times; if the noncompliance
has not been corrected, the anticipated time it is expected to continue; and any steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
8. 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 [15A NCAC 02C .0211(b)].
PART VII - CORRECTIVE ACTION [15A NCAC 02C .0206]
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of inj ectants or reaction
byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
(B) Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206, depending
on the type, concentration, and distribution of the groundwater quality standards being
exceeded.
Permit No. WI0100106 PAGE 5 OF 7
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PART VIII - PERMIT RENEWAL [I 5A NCAC 02C .0211(b)]
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee should submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS [15A NCAC 02C .0240]
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 .0240, 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 .0240, 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 WQROS staff determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Drilled wells shall be 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 .0225(k)(1)(A) within 30 days of completion of abandonment.
Permit No. WI0100106 PAGE 6 OF 7
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3. The written documentation required in Part IX (1) and (2)(G) shall be submitted to:
UIC Program
DEQ-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION [15A NCAC 02C
.0225(a)]
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.
Permit No. WI0100106 PAGE 7 OF 7
ver. 2-25-2016 UIC-5I/5T

V
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
December 9, 2013
MEMORANDUM
TO: Debra Watts
FROM: Michael Rogeray,
RE: Renewal of Permit to Inject 1% milk solution (Permit #WI0100106)
Milkco, Inc.
I recommend that Permit Number W10100106 be re -issued to the above applicant to inject 1% milk solution to remediate
groundwater (GW) contaminated with VOCs and petroleum products. This permit was issued on December 22, 2010, and
expired on November 30, 2013. Following the review of the performance monitoring data collected after the injection
events, the Permittee has requested the permit be modified and renewed to include a total larger volume of injectant
(25,000 gallons/well), 12 new permanent injection wells, and permission for additional injection events. Previous
injections of 1% milk solution have resulted in decrease of COCs and the Permittee believes additional injections will
continue this reduction.
Since the permit for this injection activity has previously been approved, and information contained therein is essentially
the same, I am attaching this modified memo reflecting those proposed changes from the previous permit. Please refer to
the previous permit issuance memorandum for more information on this site.
PROPOSED INJECTION: As previously mentioned, 25,000 gallons of 1% milk solution will be injected via 12 new
proposed permanently installed injection wells (IW-1 thru IW-12) + one existing well (RW-3). Injections are proposed
annually with options for semi-annual injection based upon evaluation of injection effectiveness. Each injection for each
well will be approximately 5 days in duration. The potential displacement of the plume is low. Please refer to Figure 2 in
the application package for the location of the injection wells (new injection wells are green dots, existing injection well
RW-3 is highlighted in orange). NOTE- for the first year of injection only 3 wells are injected (RW-3, IW-2, and IW-5).
MONITORING: Four new monitoring wells, MW-3R, 8R, 25R, and 44, are proposed to be installed (highlighted in pink on
REVISED Figure 2). Monitoring will continue as in the issued permit except that surface locations BC-1 and JW-1 are
increased to semi-annually.
REGIONAL OFFICE COMMENTS: Each of the RO comments/recommendations are discussed below (RO's
comments/recommendations are underlined).
The monitories schedule for surface water sample locations BC-1 and JW-1 should be increased to semi-annually. This
was put in the permit.
November 2013 UPDATE
The Permittee has submitted a third additional information packet received 11/26/13. After several emails and telephone
call conferences between Andy Alexander with BLE and the regional and central office staff (including you), Andy has
submitted more information delineating the estimated vertical and horizontal injection zones.
Below I have addressed each of your numbered review notes.

r
1. The summary memo has been revised and updated.
2. The groundwater flow for this site is roughly radial (GW elevation related to a topographic high). Therefore,
monitoring wells MW-44, MW-13, MW-14, and MW-23 are downgradient. The wells way outside the IZ are part
of their monitoring plan per the DWM/Brownfields and are not necessarily there for monitoring for an injection
permit.
3. I agree that they add 30 and 150 days to monitoring schedule for MW-13, MW-14, and MW-23 to be consistent
with MW-44. I added this to the permit. The RO has seen the add info packet and are OK w/permit re -issuance
(see email dated 12/9/13).
4. I updated BIMS per your request.
In conclusion, I think with the submittal of this 3rd add info package, this is the best the Permittee is going to be able to do
as far as meeting requirements per 2C .0225. They have looked into installing additional monitoring wells on surrounding
properties, but have been denied access (see add info letter). I think they have made a reasonably good faith effort to be in
compliance based upon field conditions and `real world realities'. If you conclude they still do not strictly meet 2C .0225,
then it looks like we will have to deny them the permit renewal. _

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 ISHEREBY GRANTED TO
Milkco, Inc.
FOR THE CONSTRUCTION AND/OR OPERATION OF 13 (THIRTEEN) IN SITU
REMEDIATION/TRACER INJECTION WELLS, defined in Title 15A North Carolina
Administrative Code 2C .0209(5)(b)(viii), to inject 1% milk solution, for the remediation of
volatile organic compounds (VOCs). These injection wells/points will be located at Former
Andrex Industries Corporation Facility, 180 Deaverview Road, Asheville, Buncombe County,
NC 28806, and will be operated in accordance with the application submitted August 6, 2013,
and in conformity with the specifications and supporting data submitted August 26, September
27, and November 26, 2013, 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 Act or 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,
2018, and shall be subject to the specified conditions and limitations set forth in Parts I through
XI hereof.
Permit issued this the 13th day of December 2013.
13
homas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission.
Permit No. W10100106 PAGE 1 OF 7
ver. 11 / 14/2013 UIC-51/5T

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). 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 or operation 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 Water Quality Regional Operations Section
(WQROS).
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.
PART II -.WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall
notify the WQROS Central Office staff, telephone number 919-807-6406, and the WQROS
Asheville Regional Office staff,. telephone number 828-296-4500.
2. .Bentonite grout shall not be used to seal any water -bearing zone with a chloride
concentration equal to or greater than 1,500 milligrams per liter. -In areas where elevated
chloride levels are known to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing conditions.
Permit No. WI0100106 PAGE 2 OF 7
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PART III - OPERATION AND USE GENERAL CONDITIONS
1. 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 and approval. 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 and any supporting materials must be submitted 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 that may be imposed by other
local, state, and federal agencies having jurisdiction. Furthermore, the issuance of this permit
does not imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. 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.
2. 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, such as the repair, modification, or abandonment of the injection facility.
3. The Permittee shall be required to comply with the terms and conditions of this permit even
if compliance requires a reduction orelimination of the permitted activity.
4. 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 WQROS staff and receive prior approval of any planned
alterations or additions in the permitted facility or activity not specifically authorized by the
permit.
3.. 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 WQROS Central Office staff, telephone
number 919-807-919-807-6406, and the WQROS Asheville Regional Office staff, telephone
number 828-296-4500. Notification is required so that staff can inspect or otherwise review
the injection facility and determine if it is in compliance with permit conditions.
Permit No_ WI01001.06 PAGE 3 OF 7
ver. 11/ 14/2013 UIC-51/5T

PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the WQROS 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. WQROS 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
1. The proposed revised monitoring plan received November 26, 2013, included in the
application shall be followed except that:
(A) MW-13, MW-14, and MW-23 are added to the 30 and 150 day sampling schedule to be
consistent with MW-44; and
(B) Surface water sampling locations BC-1 and JW-1 shall be sampled semiannually. .
Any additional monitoring, _including.. groundwater, surface--water-or soil,. sampling, deemed
necessary to ensure surface water and groundwater protection may be established and an
acceptable sampling reporting schedule shall be followed.
2. All sample results shall be submitted to the WQROS Central Office and Asheville Regional
Office. Monitoring reports shall include, at a minimum, analytical data and an update on the
status and location of monitoring and injection wells. Well locations may be given in a table
with the name and geographic coordinates or shown on an updated version of the site map.
3. A Well Construction Record (Form GW-1) shall be submitted within 30 days of
completion of well construction.
4. An Injection Event Record (Form GW-30) shall be submitted within 30 days of each
injection event.
5. The Permittee shall submit a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce an interim evaluation to be
submitted with a renewal application for this permit. Both the final project evaluation and
interim evaluation shall contain historical monitoring data and updated contaminant plume
and potentiometric surface maps. PLEASE NOTE: Injectants and related reaction byproducts
must attenuate to pre -injection concentrations or groundwater standards specified in rule 15A
NCAC 02C .0202, whichever is greater, in order for this permit to be closed: Otherwise,
corrective action as described Part VIII shall be required.
Permit No. WI0100106 PAGE 4 OF 7
ver. 11 /14/2013 UIC-5I/5T

6. All monitoring results, forms, and reports required in this Part shall be submitted to:
UIC Program Staff DWR - WQROS
DWR — WQROS and Asheville Regional Office
1636 Mail Service Center 2090 US HWY 70
Raleigh, NC 27699-1636 Asheville, NC 28778
7. 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 828-296-4500, 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.
8. 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 Permitte6.
9. 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 - CORRECTIVE ACTION
1. Any injection well not constructed or operated in accordance with this permit, or the criteria
and standards specified in 15A NCAC 02C .0200, shall be subject to corrective action as
provided under rule 15A NCAC 02C .0206.
2. The following corrective actions shall apply to elevated concentrations of injectants or
reaction byproducts resulting from the permitted injection activity:
(A) Continued monitoring until concentrations return to pre -injection values or meet the
standards specified in 15A NCAC 02L .0202, whichever are greater. The frequency,
duration, and location of monitoring shall be appropriate for site specific conditions and
potential receptors.
-(B) Groundwater quality parameters that do not attenuate as described in 2(A) above may
warrant a corrective action plan as provided under rule 15A NCAC 02C .0206,
depending on the type, concentration, and distribution of the groundwater quality
standards being exceeded.
Permit No_ WIQ100106 PAGE 5 OF T.
ver. l l / 14/2013 UIC-5 U5T

PART IX - 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 X - 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 .0240, 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 .0240, 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 WQROS staff determines
that failure to do so could lead to the contamination of an underground source of
drinking water.
(D) Drilled wells shall be 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 .0225(k)(1)(A) within 30 days of completion of abandonment.
Permit No.. WI0100106 PAGE 6 OF 7
ver. 1:1 / 14/2013 UIC-5I/5T

J
3. The written documentation required in Part X (1) and (2) (G) shall be submitted to:
Water Quality Regional Operation Section-UIC Program
DENR-Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
PART XI — 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.
Permit No. W 10100106 PAGE 7 OF 7
ver. IT/ 14/2013 UIC=51/5T

Permit Number W10100106
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well
Primary Reviewer
michael:rogers
Coastal SW Rule
Permitted Flow
Central Files: APS SWP
12/12/13
Permit Tracking Slip
Status Project Type
In review Renewal with major mod
Version Permit Classification
Individual
Permit Contact Affiliation
Andrew W. Alexander
Hydrogeologist Senior
6004 Ponders Court
Greenville SC 29615
Facility
Facility Name Major/Minor Region
Former Andrex Industries Corp Facility Minor Asheville
Location Address County
180 Deaverview Rd Buncombe
Asheville NC 28806 Facility Contact Affiliation
Owner
Owner Name Owner Type
Milkco Inc Non -Government
Owner Affiliation
Keith Collins
President
PO Box 16160
Asheville NC 28816
Dates/Events
Scheduled
Orig Issue App Received Draft Initiated Issuance
Public Notice Issue Effective
Expiration
12/22/10 08/06/13
Regulated Activities
Requested/Received Events
Groundwater remediation
Additional information requested
08/15/13
r
Additional information received
08/26/13
t
RO staff report requested
08/27/13
Additional information requested
09/17/13
Additional information received
09/27/13
RO staff report received
10/02/13
Additional information requested
10/17/13
Additional information received
11/26/13
Outfall NULL
Waterbody Name Stream Index Number Current Class Subbasin

Central Files: APS SWP
12/12/13