WI0100106_Complete File - Historical_20180918

BUNNELL
LAMMONS
ENGINEERING
September 7, 2018
Underground Injection Control Program
DWQ - Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
Attention: Mr. Michael Rogers, P.G.
Program Manager
Subject: UIC Permit Application (UIC-51/5T)
Permit Renewal with Modification
UIC Permit No. W10100106
Former Andrex Industries Facility
180 Deaverview Road
Asheville, North Carolina
BLE Project Number J18-1022-50
Groundwater Incident Number 6586
Brownfields Project Number 07022-03-11
Dear Mr. Rogers:
I�ECENEDINCDEWWI
SEP 18 2018
Water Quality Regional
Operations Section
Bunnell-Lammons Engineering, Inc. (BLE) is pleased io submit documents for renewal of the UIC permit at
the subject site. The renewal includes modifications which consist of 1) changes required by the DEQ during
the last renewal, 2) changes based on observed results from 2013 through 2017, and 3) changes based on
projected available funds for future remediation and monitoring. Additionally, this renewal includes only
information germane to the proposed modifications to the existing permit. Please refer to the information
previously submitted in the prior permit application for documentation of site history, hydrogeologic
conditions, and injectant information, etc.
As required by the existing permit, the Interim Evaluation Report of the prior injections and monitoring results
to date was prepared and submitted under separate cover. Please note that an updated groundwater elevation
map, plume map, and hydrogeologic profiles are included in this application for reference.
In addition to the data provided as part of this permit renewal please reference the recent reports listed below
(if necessary) which were previously submitted to your office.
Interim Evaluation Report — 2017Injection & Monitoring dated August 30, 2018 (BLE Project
No. J17-1022-48).
Report ofAnnual Groundwater and Surface Water Sampling and Analysis for 2017 dated August
30, 2018 (BLE Project No. J17-1022-49).
I
6004 Ponders Court, Greenville. SC 29615 t864.288.1265 H864.288.4430 ![e-mail]
BLECORP.COM

North Carolina Department of Environmental Quality — Division of Water Resources
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
In Situ Groundwater Remediation (15A NCAC 02C .0225) / Tracer Injection (15A NCAC 02C .0229)
- Do not use this form for the following:
• In -situ remediation, tracer, or aquifer test injection wells permitted by rule (ref. 15A NCAC 02C .0217)
• remediation systems that reinject treated contaminated groundwater (Non -discharge) (ref. 15A NCAC 02T .1600)
Permit Number (to be completed by DYVR): WI V � 69o/
I. APPLICATION INFORMATION
1. Project is: [ ] New [ ] Modification [ ] Renewal without modification [X] Renewal with modification
2. If this application is being submitted for Renewal and/or Modification to an existing permit, provide:
(a.) Existing permit number WI0100106 Issued Date: 12-13-2013 & Expiration Date: 11-30-2018
For all Renewals, submit a status report including monitoring results of all injection activities to date.
For Renewal without modification only, fill out sections I & II only, sign the certification on the last page of this form,
and obtain the property owner's signature to indicate consent (if the applicant is not the owner).
II. WELL OWNER(S)/PERMIT APPLICANT (
1. Name(s): Milkco, Inc. (non -responsible party)
2. Signing Official's Name*: Mr. Keith Collins Title: President
* Signing Official must be in accordance with instructions in Part X on page 5.
3. Mailing address of Permittee/Applicant: Milkco, Inc.
PO Box 16160
City: Asheville State: NC Zip: 28816
4. Telephone number: 828-254-9560 Email: keith(a)milkco.com
5. Status (choose one): Individual X Business/Org. Federal State County Municipality
III. PROPERTY OWNER(S) (if different than well owners)
1. Name(s):
2. Mailing address:
City: State: Zip:
3. Telephone number: Email:
IV. PROJECT CONTACT — (generally the environmental/engineering consultant).
i
- ` 1. Name: Andrew W. Alexander, PG, RSM Title: Senior Hydrogeologist
- 2. Company: Bunnell-Lammons Engineering, eerin,g Inc. (BLE)
! 3. Address: 6004 Ponders Court
4. City: Greenville State: SC Zip: 29615
5. Telephone number: 864-288-1265 Email: andyAblecoM.com
s�
RECEIV DIN!CDEQIDWR
�In-Situ Groundwater RemSEP 18 2018ediation Application Rev. 8-28-2017 Page 1 of 6
Water OuaUty Regional
Operations sodan

V. FACILITY INFORMATION
1. Facility name:
2. Physical address:
Former Andrex Industries Corp. Phone No. if available: Not Applicable
180 Deaverview Road (Physical Address of Unoccupied Parcel)
City:
Asheville County:
Buncombe Zip: 28806
3. Geographic Coordinates:
Latitude: N 35.580496 °
Longitude: W 82.613115 °
Reference Datum: Center Parcel
Accuracy: Unknown
Method of Collection (i.e., Google Earth, GPS, etc.): Google Earth
4. Brief description of business: Former Textile Dyeing
and FinishingFacility
VI. INCIDENT DESCRIPTION
1. Source and date of contamination: Textile dyeing and finishing. Use of PCE for industrial textile cleaning_
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g., gasoline,
diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Chlorinated ethenes Chlorinated ethanes (trace level), petroleum hydrocarbons
3. Has LNAPL or DNAPL ever been observed at the site (even if outside the injection zone)?
[ ] Yes If yes, list maximum measured separate phase thickness: feet
[X] No If no, list maximum concentration of total VOCs observed at site: (MW-5) 49,830 ppb
4. Agency managing the contamination incident:
[ ] UST Section [ ] Superfund Section (including REC Program and DSCA sites)
[ ] DWR Aquifer Protection Section [ ] Solid Waste Section
[ ] Hazardous Waste Section [X] Other: Brownfields Program
5. Incident manager's name: Ms. Tracy Wahl Phone No.: 828-251-7465
6. Incident number or other incident mgmt. agency tracking number:
Brownfields Project Number 07022-03-11 & Groundwater Incident No. 6586
VII. PERMITS
List all applicable permits or construction approvals issued for the facility or incident:
1. Previous or other UIC permits issued by DWR (e.g., NOIs)
2. Other Non -Discharge or NPDES permit issued by DWR:
3. County or DEH subsurface wastewater disposal permits:
4. Hazardous waste management or other environmental permits required by state or federal law:
Former RCRA ID No. NCD074498387
See attached SummaryofPermits Issued revised (Table 1)
In -Situ Groundwater Remediation Application Rev. 8-28-2017 Page 2 of 6

I VIII. INJECTION SUMMARY (See enclosed Injection Summary and Attachments additions)
1. List all proposed injectants/additives.
' NOTE: Onlyin'ectants approved b the epidemiology section o the NC Division o Public Health, Department o
� J PP Y P gl' f .% P f
Health and Human Services can be injected. Approved injectants can be found online at
htti):Hdeg.ne. aov/about/divisions/water-resources/water-resources-permits/wastewater-brancli/ground-water-
protection/ground-water-approved-injectants. All other substances must be reviewed by the DHHS prior to use.
Contact the UIC Program for more info (919-807-6496) if you wish to get approval for a different additive.
However, please note it may take 3 months or longer.
I
Injectant: Total Amt. to be injected (gal)/event
Injectant: Total Amt. to be injected (gal)/event
- Injectant: Total Amt. to be injected (gal)/event
Injectant: Total Amt. to be injected (gal)/event
Injectant: Total Amt. to be injected (gal)/event
2. Number of separate injection events: Duration of Event:
3. Estimated Injection rate per well: gallons per minute (GPM)
4. Estimated Injection pressure: pounds/square inch (PSI)
5. Temperature at point of injection: OF
6. Injection will be via:
( Existing well(s); Total No.: , Well Type (DPT, Permanent,
( Proposed well(s); Total No.: ; Well Type (DPT, Permanent, etc.):
7. NC Certified Well Drilling Contractor's Name (if
NC Well Contractor Certification No.:
8. Date to be constructed if proposed: (attach GW-ls for existing injection wells)
9. Screened interval/Injection interval of injection wells:
Depth from to feet below land surface (BLS)(if multiple intervals, indicate shallowest
to deepest depth)
10. Well casing (leave blank if Geoprobes®):
Type: ( PVC ( Stainless steel( Other:
Casing depth: to ft. BLS
Type: ( PVC ( Stainless steel( Other:
Casing depth: to ft. BLS
11. Grout (leave blank if Geoprobes):
Type: ( Cement ( Bentonite ( Other:
Grout depth: to ft. BLS
Type: ( Cement ( Bentonite ( Other:
Grout depth: to ft. BLS
In -Situ Groundwater Remediation Application Rev. 8-28-2017 Page 3 of 6

IX. ATTACHMENTS — provide the following information in separate attachments. The attachments should be clearly
identified and presented in the order below to expedite review of the permit application package.
1. INJECTION ZONE — Per 15A NCAC 02C .0225(e)(2), specify the horizontal and vertical portion of the subsurface within
which the proposed injection activity will take place and beyond which no violations of groundwater quality standards shall
result from the injection as determined by an approved monitoring plan. The determination shall be based on the hydraulic
properties of the specified zone. Provide any supporting documentation in a separate attachment.
2. HYDROGEOLOGIC EVALUATION — Per 15A NCAC 02C .0225(e)(3). provide a hydrogeologic evaluation of the injection
zone that includes all of the following:
(A) Regional and local geology and hydrology;
(B) Changes in lithology underlying the facility;
(C) Depth to bedrock;
(D) Depth to the mean seasonal high water table;
(E) Hydraulic conductivity, transmissivity, and storativity, of the injection zone based on tests of site -specific material,
including a description of the test(s) used to determine these parameters;
(F) Rate and direction of groundwater flow as determined by predictive calculations or computer modeling; and
(G) Lithostratigraphic and hydrostratigraphic logs of any existing test and injection wells.
3. INJECTANT INFORMATION — Per 15A NCAC 02C .0225(e)(5). provide information on each injectant as indicated below:
(A) MSDS, concentration at the point of injection, and percentage if present in a mixture with other injectants;
(B) The source of fluids used to dilute, carry, or otherwise distribute the injectant throughout the injection zone. If any
well within the area of review of the injection facility is to be used as the fluid source, then the following information
shall be submitted: location/ID number, depth of source, formation, rock/sediment type, and a chemical analysis
of the water from the source well, including analyses for all contaminants suspected or historically recognized in
soil or groundwater on the site;
(C) A description of the rationale for selecting the injectants and concentrations proposed for injection, including an
explanation or calculations of how the proposed injectant volumes and concentrations were determined;
(D) A description of the reactions between the injectants and the contaminants present including specific breakdown
products or intermediate compounds that may be formed by the injection;
(E) A summary of results if modeling or testing was performed to investigate the injectant's potential or susceptibility
for biological, chemical, or physical change in the subsurface; and
(F) An evaluation concerning the development of byproducts of the injection process, including increases in the
concentrations of naturally occurring substances. Such an evaluation shall include the identification of the specific
byproducts of the injection process, projected concentrations of byproducts, and areas of migration as determined
through modeling or other predictive calculations.
4. INJECTION PROCEDURE — Per 15A NCAC 02C .0225(e)(6). submit a table with a detailed description of the proposed
injection procedure that includes the following:
(A) The proposed average and maximum daily rate and quantity of injectant;
(B) The average maximum injection pressure expressed in units of pounds per square inch (psi); and
(C) The total or estimated total volume to be injected.
In -Situ Groundwater Remediation Application Rev. 8-28-2017 Page 4 of 6

5. FRACTURING PLAN (if applicable) —Per 15A NCAC 02C .0225(e)(7), submit a detailed description of the fracturing plan
that includes the following:
(A) Material Safety Data Sheets of fracturing media including information on any proppants used;
(B) a map of fracturing well locations relative to the known extent of groundwater contamination plus all buildings,
wells, septic systems, underground storage tanks, and underground utilities located within the Area of Review;
(C) a demonstration that buildings, wells, septic systems, underground storage tanks, and underground utilities will not
1 be adversely affected by the fracturing process;
i J(D) injection rate and volume;
(E) orientation of bedding planes, joints, and fracture sets of the fracture zone;
(F) performance monitoring plan for determining the fracture well radius of influence; and
i (G) if conducted, the results of geophysical testing or pilot test of fracture behavior conducted in an uncontaminated
area of the site.
6. WELL CONSTRUCTION DETAILS — Per 15A NCAC 02C .0225(e)(8), submit the following information in tabular or
schematic form as appropriate for each item:
(A) number and depth of injection wells;
(B) number and depth of borings if using multi -level or "nested" well systems;
(C) indication whether the injection wells are existing or proposed;
(D) depth and type of casing;
(E) depth and type of screen material;
(F) depth and type of grout;
(G) indication whether the injection wells are permanent or temporary "direct push" points; and
(H) plans and specifications of the surface and subsurface construction details.
7. MONITORING PLAN — Per 15A NCAC 02C .0225(e)(9), submit a monitoring plan that includes the following:
(A) target contaminants plus secondary or intermediate contaminants that may result from the injection;
(B) other parameters that may serve to indicate the progress of the intended reactions;
(C) a list of existing and proposed monitoring wells to be used; and
(D) a sampling schedule to monitor the proposed injection.
Monitoring wells shall be of sufficient quantity and location to detect any movement of injection fluids, injection process byproducts, or
formation fluids outside the injection zone. The monitoring schedule shall be consistent with the proposed injection schedule, pace of
the anticipated reactions, and rate of transport of the injectants and contaminants.
8. WELL DATA TABULATION — Per 15A NCAC 02C .0225(e)(10), provide a tabulation of data on all existing or abandoned
wells within the area of review of the injection well(s) that penetrate the proposed injection zone, including monitoring
wells and wells proposed for use as injection wells. Such data shall include a description of each well's type, depth, and
record of construction or abandonment.
9. MAPS AND CROSS -SECTIONS — Per 15A NCAC 02C .0225(e)(11). provide scaled, site -specific site plans or maps
depicting the location, orientation, and relationship of facility components including the following:
(A) area map based on the most recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 and showing the
location of the proposed injection site;
(B) topographic contour intervals showing all facility related structures, property boundaries, streams, springs, lakes,
ponds, and other surface drainage features;
(C) all existing or abandoned wells within the area of review of the wells listed in the well data tabulation that penetrate
the proposed injection zone;
(D) potentiometric surface map(s) that show the direction of groundwater movement, existing and proposed wells;
(E) contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the contaminant plume in
soil and groundwater, and existing and proposed wells;
(F) cross-section(s) to the known or projected depth of contamination that show the horizontal and vertical extent of
the contaminant plume in soil and groundwater, major changes in lithology, and existing and proposed wells; and
(G) any existing sources of potential or known groundwater contamination, including waste storage, treatment, or
disposal systems within the area of review of the injection well or well system.
In -Situ Groundwater Remediation Application Rev. 8-28-2017 Page 5 of 6

X. CERTIFICATION (to be signed as required below or by that person's authorized agent*)
NCAC I SA 02C .0211(61 requires that all permit applications shall be signed as follows:
1. for a corporation: by a responsible corporate officer
2. for a partnership or sole proprietorship: by a general partner or the proprietor, respectively
3. for a municipality or a state, federal, or other public agency: by either a principal executive officer or
ranking publicly elected official
4. for all others: by the well owner.
*If an authorized agent is signing on behalf of the applica.nt, then supply a letter signed by the applicant
that names and authorizes their agent.
"I hereby certify under penalty of law that I have personally examined and am familiar with the information
submitted in this document and all attachments therein, and that, based on my inquiry of those individuals
immediately responsible for obtaining said information, I believe that the information is true, accurate, and
complete. I am aware that there are penalties, including the possibility offrnes and imprisonment, for submitting
false information. 1 agree to construct, operate, maintain, repair, and if applicable, abandon the injection well(s)
and all related appurtenances in accordance with the approved specifications and conditions of the Permit. "
Printed Name and
Date: CIA a A 6
XI. CONSENT OF PROPERTY OWNER (if the property is not owned by the permit applicant)
"Owner" means any person who holds the fee or other property rights in the well being constructed. A well is real
property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of contrary
agreement in writing.
"As owner of the property on which the injection well(s) are to be constructed and operated, I hereby consent to
allow the applicant to construct each injection well as outlined in this application and agree that it shall be the
responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards
(1 SA NCAC 02C .0200i. "
Printed Name and Title:
Signature: Date:
Submit TWO hard copies of the completed application package with an electronic version in CD or USB Flash Drive to:
Division of Water Resources — UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
In -Situ Groundwater Remediation Application Rev. 8-28-2017 Page 6 of 6

't'm'i
UIC Permit Renewal — 2018 September 7, 2018
Andrex Industries Corp., Asheville, NC BLE Project No. J18-1022-50
INJECTION SUMMARY and ATTACHMENTS
1�/ i I � I�AI 9C�_Y_CI)►f.Yllu lu /:\.,'1
1) List All Proposed Injectants/Additives
The proposed injectant is a 1% milk solution in water. No changes are proposed to the injectant which is
on the Approved Injectant list. However, post injection flushing with potable water is proposed to reduce
potential injection well clogging. Future injection volumes are proposed to be similar to those performed
in the past which ranged from approximately 3,000 to 27,000 gallons per well per event. Post injection
potable water flushing volumes are proposed at half the actual milk solution injection volume.
2) Number and Duration of Separate Injection Events
The site is currently in a monitor only phase based on available budget and results. If budget and milk
solution is available, new injection wells are installed, existing injection wells are not clogged, and
monitoring results indicate need, up to six (6) injection events could be performed as shown on Table 2
during the next permit renewal term. Injection events typically require less than 10 calendar days (5
working days for each well) for completion.
3) Estimated Injection Rate Per Well
Prior injections have been performed via gravity flow with adjustments based on each well's observed flow
rate. Flow rates have been highly variable and have ranged from approximately 4 to 30 gallons per minute.
4) Estimated Injection Pressure
Injections are not performed under pressure. No changes are proposed to the injection procedures which
include injection by gravity feed into each wellhead via hose from a tanker truck and/or trailer -mounted
tanks.
5) Temperature at Point of Injection
Milk solution is provided by Milkco at an initial temperature of approximately 35 degrees F. The solution
slowly reaches ambient air temperature as it is held in tanks at each well head during injection. Often the
tanks are emptied (all solution is injected) prior to the solution reaching ambient air temperature.
6) Injection Will be Via
There are four (4) existing recovery wells on -site which have been used for injection including RW-1, RW-
3, RW-5, and RW-7. There are four (4) existing injection wells on -site which have been installed and used
for injection including IW-1, IW-2, IW-3, and IW-3A. Those wells are listed on Tables 3 and 4 and are
shown on Figures 1 and 2.
There are nine (9) additional injection wells planned for future installation and injection including IW4
through IW-12. Those wells are listed on Table 4 and are shown on Figure 2.
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,1'M'i
UIC Permit Renewal — 2018 September 7, 2018
Andrex Industries Corp., Asheville, NC BLE Project No. J18-1022-50
7) NC Certified Well Drilling Contractor's Name
If injection wells are installed, BLE will utilize our drilling division Landprobe, LLC Q. Gorman — 3485 /
R. Banks — 4026) or another licensed well contractor.
8) Date to be Constructed if Proposed
The site is currently in a monitor only phase based on available budget and results. If budget and milk
solution is available, the next injection wells to be installed will be IW-5 and IW-10 (Table 4). The dates
of installation are not proposed at this time. The GW-1 forms for the existing injection wells installed as
part of the permit are included in Appendix A.
9-11) Injection Well Construction (Injection Interval, Casing, & Grout)
During the prior permit renewal an above rock and bedrock injection well construction was approved by
the DEQ for the site. Typical construction diagrams for both types designated Figure IW-A and Figure
IW-B are attached for reference. No changes to the approved construction are proposed for the permit
renewal.
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UIC Permit Renewal — 2018 September 7, 2018
Andrex Industries Corp., Asheville, NC BLE Project No. J18-1022-50
IX. ATTACHMENTS
1) Injection Zone
The proposed injection zone remains unchanged from that specified in the prior permit. The zone includes
strata within approximately 80 feet of the ground surface including zones of saprolite, partially weathered
rock (PWR) and fractured bedrock.
2) Hydrogeologic Evaluation
No additional hydrogeologic evaluations have been performed since submittal of the prior permit
application. However, a groundwater elevation map from the most recent site -wide sampling event
(September 2017) is included herein (Figure 1). The inferred groundwater flow directions and hydraulic
gradients are consistent with those observed for the past 20 years.
3) Injectant Information
The proposed injectant is a 1% milk solution in water. No changes are proposed to the injectant which is
on the Approved Injectant list. Please reference the Interim Evaluation Report for a discussion of metabolic
byproducts.
4) Injection Procedure
No changes are proposed to the injection procedures which include injection by gravity feed into each
wellhead via hose from a tanker truck and/or trailer -mounted tanks. However, post injection flushing with
potable water is proposed to reduce potential injection well clogging. Injections are not performed under
pressure. Future injection volumes are proposed to be similar to those performed in the past which ranged
from approximately 3,000 to 27,000 gallons per well per event. Post injection potable water flushing
volumes are proposed at half the actual milk solution injection volume.
5) Fracturing Plan
No fracturing is planned or proposed for this project.
6) Well Construction Details
Nine (9) new permanent injection wells designated IW-4 through IW-12 are proposed at the locations noted
on Figure 2. Note that all proposed injection wells are in their same proposed locations as the prior renewal
except IW-10 which has been moved to the MW-44 area. The injection wells will be installed as above
rock or bedrock injection wells in accordance with the DEQ approved construction for the site. Typical
injection well construction diagrams for each type are shown on Figure IW-A and Figure IW-B. Note
that if budget and milk solution is available, the next injection wells to be installed will be IW-5 and IW-
10 (Table 4).
Additionally, three (3) groundwater monitoring wells designated MW-3R, MW-8R, and MW-25R are
proposed at the locations noted on Figure 2. The wells are designed with the letter "R" are replacement
wells for those abandoned or lost as part of Milkco construction efforts. A baseline sampling event will be
performed after installation to establish groundwater quality conditions at each new well location.
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UIC Permit Renewal — 2018
Andrex Industries Corp., Asheville, NC
September 7, 2018
BLE Project No. J18-1022-50
These monitoring wells will be installed to a depth of up to 80 feet deep each. Actual depths will be
determined in the field based on are hydrogeologic conditions encountered. Each well will be constructed
with 2-inch PVC riser and a 15-foot long section of slotted well screen installed in a 6-inch diameter air -
hammered borehole. All wells will be installed with appropriate well heads and flush mount pads and
covers. We understand that well installation permits are not required for groundwater monitoring wells
installed on the subject property which is owned by Milkco (applicant). However, the appropriate
installation records will be submitted to the DWQ upon well completion. Note that no new monitoring well
installations are planned for the renewal term.
7) Monitoring Plan
The site is currently in a monitor only phase. Monitoring is scheduled for the renewal term in accordance
with the Monitor Only Matrix (Table 5). The current matrix includes a semi-annual event in March, an
interim event in June, and the annual event in September. Sampling is performed at select groundwater
locations necessary to monitor long-term remedial progress in the injection areas. The matrix also includes
the semi-annual surface water sampling required by the DEQ.
If budget and milk solution become available during the permit term, groundwater monitoring will be
performed as specified on the Injection Monitoring Plan (Table 6). In general, monitoring will be
performed at 30, 90, and 150-day milestones (depending on distance from the injection point) and annually
for all wells as required. Monitoring frequencies will be adjusted based on results obtained once the
injection program is underway. It may not be possible to obtain samples at exact milestones (30, 90, and
150 days, etc.) due to weekends, holidays, inclement weather, or other delays beyond our control. Samples
will be collected as near the milestone dates as the schedule allows. It should be noted that sampling will
only be performed at monitoring points where injections are occurring.
Groundwater samples will be analyzed for VOCs by EPA Method 8260 MSV Low Level and for total
organic carbon (TOC) by Standard Method SM 9060A (for select wells only, see Tables 5 and 6).
Surface water will be monitored for VOCs by EPA Method 8260 MSV Low Level and for TOC by Standard
Method SM 5310B (Tables 5 and 6).
8) Well Data Tabulation
A well tabulation is shown on Table 3. Since the last renewal one (1) monitoring well (MW-44) and four
(4) injection wells (IW-1, IW-2, IW-3, and IW-3A) have been installed in accordance with DEQ approved
plans. Appropriate documentation of well installations were submitted to the DEQ.
9) Maps and Cross -Sections
An updated groundwater elevation map (Figure 1) plume map (Figure 2) and hydrogeologic profile (Figure
3) are included in this application for reference. These data on these maps were sourced from:
Interim Evaluation Report— 2017Injection & Monitoring dated August 30, 2018 (BLE Project
No. J17-1022-48).
Report ofAnnual Groundwater and Surface Water Sampling and Analysis for 2017 dated August
30, 2018 (BLE Project No. J17-1022-49).
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It Im In
UIC Permit Renewal — 2018
Andrex Industries Corp., Asheville, NC
September 7, 2018
BLE Project No. J18-1022-50
The inferred groundwater flow directions and hydraulic gradients from Figure 1 are consistent with those
observed for the past 20 years. The plume map on Figure 2 has been modified to include proposed injection
wells and monitoring wells, and to show the proposed injection zone if all injection wells were utilized.
Note that proposed injection well MW-10 has been moved to the MW-44 area to address high concentration
groundwater in that area. The injection zone has been modified on Figure 2 to reflect an active IW-10.
The hydrogeologic profile (Figure 3) includes injection wells IW-1, IW-2, and IW-3A.
Please note that the plume dimensions have changed significantly since the last renewal in 2013. Significant
VOC concentration reductions have been observed in the MW-12 area with MW-12 reaching compliance.
Additionally, substantial concentrations of daughter product are not observed in several treatment areas.
Areas of significant groundwater remediation are shown circled in red dashed lines. Please refer to the
Interim Evaluation Report and Annual Report for additional information.
L WE
41 I CI;
We appreciate the opportunity to work with you at the subject site. We look forward to receiving DEQ
approval of the application and work plan. If you have any questions, please do not hesitate to contact us at
[phone].
Sincerely,
BUNNELL LAMMONS ENGINEERING INC.
Andrew W. Alex der, P.G. �RSM Trevor J. Bent , P.G.
Senior Hydrogeologist Senior Geologis
Registered, North Carolina #1475 �.�� N CAA .,,� Registered, North Carolina� CA
NSF .f :,.� • :. '••• y
1 5 = A 2025 _ s
. 4 G • Lo S
cc: Mr. Keith Collins — Milkco, Inc.
Ms. Tracy Wahl — DWM Brownfields Program
Mr. Andrew Moore, P.G. — DWR WQROS — Asheville Regional Office
Mr. Stephen Gottdiener — Andrex Industries Corp.
Attachments: Tables
Figures
Appendix A
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Tables

Table I
Summary of Permits Issued
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
Permit Number
Date
Permit Type
Includes
10-0226-WM-0188
4/22/1991
Monitor Well
MW-1 & MW-2
10-0226-WM-0201
7/11/1991
Monitor Well
MW-3 through MW-8 & MW-8A
NA*
May-95
Monitor Well
MW-9 through MW-12
WM0100103
4/3/1997
Monitor Well
MW-19
WM0100104
4/3/1997
Monitor Well
MW-20
WM0100105
4/3/1997
Monitor Well
MW-13 & MW-14
WM0100106
4/3/1997
Monitor Well
MW-15, MW-16, & MW-18
WM0100107
4/3/1997
Monitor Well
MW-17
WM0100108
4/3/1997
Monitor Well
MW-21 & MW-22
WM0100109
4/3/1997
Monitor Well
MW-23
WM0100110
4/3/1997
Monitor Well
MW-24 & MW-25
10-0226-WR-0265
12/18/1992
Recovery Well
RW-1 & RW-2
WRO100043
October/1999
Recovery Well
RW-3, RW-4, RW-5, RW-6 & RW-7
AC-778
5/14/1993
MSD Allocation
Ground -Water Treatment System
G-015-93
9/24/1993
MSD Discharge
Ground -Water Treatment System
GWR-13
3/29/1993
Air Permit**
Ground -Water Treatment System
WI0100106
12/13/2013
UIC Permit***
Injection of Milk Solution
Notes:
* = At the time of installation (May 1995) permits for on -site monitoring wells were no longer required.
MSD = Metropolitan Sewerage District of Buncombe County.
** = Air permit issued by the Western North Carolina Regional Air Pollution Agency.
*** = Renewal in 2013 to original issued in 2010.
Table 1 Summary Permits of Tables Permit Renewal 2018 Andrex 1022-50.xlsx

Table 2
Injection Schedule
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
Well
2 Events
(2011)
(2012)
(2014)
(2015)
(2016)
(2017)
(2018)
*Renewal [Years One to Five]
(2019-2023)
RW-1
X
X
**X**
RW-3
X
X
X
**X**
RW-5
X
X
**X**
RW-7
X
IW-1
X
X
IW-2
X
IW-3
X
IW-3A
X
**X**
IW-4
IW-5
**X**
IW-6
IW-7
IW-8
IW-9
AV-10
**X**
IW-11
IW-12
Notes:
X = Injection performed
**Next planned injections if budget and milk solution is available, new wells are installed, existing wells are not clogged, and monitoring results indicate need.
Injections during the renewal period will be based on:.
1) Available operational budget.
2) Monitoring results.
An injection volume of up to 25,000 gallons per well per event is assumed.
Injection schedule & volumes injected will be adjusted based on available milk solution.
Prepared by: AWA
Table 2 Injection Schedule of Tables Permit Renewal 2018 Andrex 1022-50.xlsx Checked by: TJB

Table 3
Well Construction and Groundwater Elevation Data
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
September 18, 2017
Well
Well
Location
Latitude
(North)
Longitude
(West)
Meas. Pt.
Elevation
Cud. Surface Depth to
Elevation Water (bmp)
Water
Elevation
*Total Borehole
Depth (bgs)
*Screen
Depth (bgs)
*Screen
Elevation
Well
Type
Well
Monitors
*Top of Rock
Depth (bgs)
*Top of
Rock Elev.
MW-1
On -Site
NP-A
NP-A
2222.34
2222.58 NP-A
NP-A
46.2
31.2 - 46.2
2191.4 - 2176.4
Ills
BR
35.0
2187.6
MW-2
On -Site
NP-A
NP-A
2222.28
2222.62
2207.76
NP-A
NP-A
45.0
28.0 - 43.0
2194.6 - 2179.6
His
BR
29.0
2193.6
MW-3
On -Site
NP-A
NP-A
2210.40
NP-A
NP-A
55.0
40.0 - 55.0
2167.8 - 2152.8
II
BR
36.5
2171.3
MW4
On -Site
NP-A
NP-A
2206.87
2207.04
NP-A
NP-A
86.7
51.7 - 86.7
2155.3 - 2120.3
ins
BR
26.0
2181.0
MW-5 I
On -Site
35.580108
82.614175
2216.75
2216.92
46.60
2170.15
53.0
43.0 - 53.0
2173.9 - 2163.9
His
BR
37.0
2179.9
MW-6
On -Site
35.579873
82.613870
2218.43
2218.67
53.60
2164.83
71.9
50.4 - 70.4
2168.3 - 2148.3
II
PWR
56.4
2162.3
MW-7
On -Site
35.580866
82.613866
2218.35
2218.60
26.20
2192.15
35.0
24.5 - 34.5
2194.1 - 2184.1
II
BR
12.0
2206.6
MW-8
On -Site
NP-A
NP-A
2182.33
2182.63
NP-A
NP-A
24.5
13.0 - 23.0
2169.6 - 2159.6
II
PWR
22.0
2160.6
MW-8A
On -Site
NP-A
NP-A
2182.52
2182.70
NP-A
NP-A
35.0
30.0 - 35.0
2152.7 - 2147.7
Ills
BR
15.5
2167.2
MW-9
On -Site
35.579817
82.612727
2175.57 1
2175.95
26.77
2148.80
1 60.0
44.0 - 54.0
2132.0 - 2122.0
II
BR
34.0
2142.0
MW-10
On -Site
35.580072
82.611828
2159.92
2159.45
17.35
2142.57
39.0
29.0 - 39.0
2130.5 - 2120.5
II
PWR
35.0
2124.5
MW-11
I On -Site
35.5807471
82.611588
2166.00
2166.39
25.81
2140.19
58.5
48.0 - 58.0
2118.4 - 2108.4
11
SAP
>80.0
<2086.4
MW-12
On -Site
35.579880
82.614410
2219.17
2219.49
48.%
2170.21
81.0
60.0 - 70.0
2159.5 - 2149.5
II
PWR
71.0
2148.5
MW-13
Off -Site
35.579603
82.611244
2138.80
2138.%
3.38
2135.42
58.5
48.0 - 58.0
2091.0 - 2081.0
II
SAP
58.5
2080.5
MW-14
Off -Site
35.57%26
82.611249
1 2138.94
2139.20
0.04
2138.90
75.0
65.0 - 75.0
2074.2 - 2064.2
Ills
BR
59.0
2080.2
MW-15
Off -Site
35.576483
82.615545
2124.89
2125.18
12.34
2112.55
40.0
33.3 - 40.0
2091.9 - 2085.2
IIIo
BR
32.5
2092.7
MW-16
Off -Site
35.576464
82.615546
2124.59
2124.85
12.25
2112.34
33.5
23.5 - 33.5
2101.4 - 2091.4
II
PWR
33.5
2091.4
MW-17
Off -Site
35.583509
82.611558
2094.64
2094.74
4.29
2090.35
14.2
4.0 - 14.0
2090.7 - 2080.7
II
SAP
14.2
2080.5
MW-18
Off -Site
35.575245
82.615122
2101.81
2101.92
9.89
2091.92
59.0
49.0 - 59.0
2052.9 - 2042.9
II
SAP
59.0
2042.9
MW-19
Off -Site
NP-D
NP-D
2127.61
2127.82
NP-D
NP-D
58.0
48.0 - 58.0
2079.8 - 2069.8
II
SAP
58.0
2069.8
MW-20
I Off -Site
35.5801861
82.609976
2180.55
2180.54
37.79
2142.76
77.0
67.0 - 77.0
2113.5 - 2103.5
II
SAP
1 77.0
2103.5
MW-21
I Off -Site
35.583947
82.611397
2091.17
2091.31
1.84
2089.33
36.5
26.5 - 36.5
2064.8 - 2054.8
11
SAP
36.5
2054.8
MW-22
Off -Site
NP
NP
2090.71
2090.84
NP
NP
57.0
47.0 - 57.0
2043.8 - 2033.8
IIIs
BR
46.0
2044.8
MW-23
Off -Site
*35.582017
82.611985
2145.05
2145.20
28.25
2116.80
41.5
31.0 - 41.5
2114.2 - 2103.7
IIlo
BR
30.0
2115.2
MW-24
Ott Site
35.579301
82.614610
2225.37
2225.49
63.24
2162.13
110.0
70.0 - 80.0
2155.5 - 2145.5
II
PWR
42.0
2183.5
MW-25
Off -Site
NP-D
NP-D
2207.91
2208.04
NP-D
NP-D
106.0
%.0 - 106.0
2112.0 - 2102.0
II
PWR
104.0
2104.0
MW-26
Off -Site
35.581075
82.616078
2207.46
2207.62
NM
NM
51.5
41.0 - 51.0
2166.6 - 2156.6
II
PWR/BR
42.0
2165.6
MW-44
Off -Site
35.57%10
82.613510
2219.15
2219.46
62.05
2157.10
81.0
65.0 - 80.0
2154.5 - 2139.5
II
SAP/PWR
80.0
2139.5
IW-1
On -Site
35.580100
82.614180
2216.24
2216.43
NM
NM
55.0
46.5 - 55.0
2169.9 - 2161.4
INJ
BR
44.0
2172.4
IW-2
On -Site
35.579900
82.613%0
2221.59
2221.78
54.10
2167.49
84.0
64.0 - 84.0
2157.8 - 2137.8
INJ
BR
64.0
2157.8
IW-3
On -Site
35.579910
82.613820
2217.41
2217.69
NM
NM
77.0
50.0 - 77.0
2167.7 - 2140.7
INJ
PWR
77.0
2140.7
IW-3A
On -Site
35.579850
82.613900
2220.14
2220.37
NM
NM
57.0
25.0 - 57.0
2195.4 - 2163.4
INJ
SAP/PWR
57.0
2163.4
RW-1
On -Site
35.579844
82.613866
2218.19
2218.61
53.28
2164.91
84.4
42.4 - 82.4
2176.2 - 2136.2
II
BR/PWR
72.4
2146.2
RW-2
On -Site
35.579993
82.613123
2182.46
2183.62
NP-A
NP-A
78.0
35.0 - 75.0
2148.6 - 2108.6
II
BR
31.0
2152.6
RW-3
On -Site
35.580081
82.614283
2217.58
2218.06
47.32
2170.26
76.0
54.0 - 64.0
2164.1 - 2154.1
II
BR
36.0
2182.1
RW-4
On -Site
NP-A
NP-A
2160.78
2161.74
NP-A
NP-A
60.0
19.6 - 59.6
2142.1 - 2102.1
II
BR
20.0
2141.7
RW-5
On -Site
35.580081
82.611909
2159.48
2160.60
16.82
2142.66
66.0
20.2 - 60.2
2140.4 - 2100.4
II
BR
16.0
2144.6
RW-6
On -Site
35.580341
82.611667
2160.44
2161.57
18.98
2141.46
67.0
20.0 - 60.0
2141.6 - 2101.6
II
SAP/BR
36.0
2125.6
RW-7
I On -Site
1 35.5806811
82.611646
1 2164.57
1 2165.60
1 24.12
1 2140.45
1 67.0
1 13.0 - 53.0
1 2152.6 - 2112.6
II
SAP/PWR
1 55.0
2110.6
Notes:
*Values rounded to the nearest 0.1-ft.
NM = Not measured
NP-A = Not Present - Abandoned
NP-D / NP = Not Present - Destroyed by Grading/Missing
bgs = below ground surface.
bmp = below measuring point.
Water levels measured on 9/18/17. IIIo = Type III open bedrock well
Measuring Point Elevation is top of casing. BR & PWR = Bedrock & Partially Weathered Rock
INJ = Injection wells are stone filled boreholes SAP = Saprolite
II = Type II well MW-24 was abandoned, redrilled and replaced in 2007 after the well head
Ills = Type III screened well was damaged by Milkco contractors in 2003.
The ground surface at RW-1 and MW-6 was raised 7.4 feet and the wells were extended. Both were resurveyed in November 2010.
GPS coordinates measured via hand-held meter in 2014 using existing well heads and/or remains of abanoned well heads.
Prepared by: AWA
Table 3 (2017) of Tables Permit Renewal 2018 Andrex 1022-50.xlsx Checked by: IAI

Table 4
Well Installation Plan
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
M
O
N
O�
3
O
v
0
w
0
0
o
�
o
o
a
•C
N
�
N
Cq
.N...
.�.
MW-3R
MW-8R
MW-25R
MW-44
X
IW-1
X
IW-2
X
IW-3
X
IW-3A
X
IW-4
IW-5
**X**
IW-6
IW-7
IW-8
IW-9
IW-10
**X**
IW-11
IW-12
Notes:
X - Well Installation Performed.
*Installations during the renewal period are based on:
1) Available operational budget.
2) Monitoring results.
"Next planned installations if budget is available and monitoring results indicate need
Prepared by: AWA
Table 4 Install Schedule of Tables Permit Renewal 2018 Andrex 1022-50.xlsx Checked by: TJB

Table 5
Monitor Only Matrix
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
❑
o
CZ
c
<
v
w
Q
Groundwater
RW-3 and IW-1
RW-3
V& T
V& T
V& T
MW-5
V&T
V&T
V&T
MW-12
V&T
V&T
V&T
IW-2, IW-3 and/or IW-3A
IW-2
V & T
V & T
V & T
RW-1
V&T
V&T
V&T
MW-6
V&T
V&T
<IW-10>
MW-44
V & T
None
<MW-3R>
<IW-4>
MW-7
V & T
<I W-5>
<M W-8R>
MW-9
V&T
<IW-6>
None
<IW-7>
RW-5
V & T
V & T
MW-10
V&T
V&T
M W-13
V & T
MW-14
V &T
<IW-8>
RW-6
V & T
V & T
<IW-9>
RW-7
V & T
MW-11
V & T
MW-23
V & T
<IW-ll>
MW-24
V & T
<I W-12>
<M W-25R>
None
NI W-15
V
MW-16
V
MW-17
V
MW-18
V
Nl W-20
V
M W-21
V
MW-26
V
Surface Water
None
Smith Mill Creek 1
V & T
Smith Mill Creek 2
V & T
Smith Mill Creek 3
V & T
Smith Mill Creek 4
V & T
Smith Mill Creek 5
V & T
Smith Mill Creek 6
V & T
Bear Creek 1
V& T
V& T
Bear Creek 2
V & T
Bear Creek 3
V & T
Bear Creek 4
V & T
Bear Creek 5
V & T
Jehovah Witness 1
V& T
V& T
Cecil's Spring 1
V & T
Cecil's Spring 2
V & T
Notes:
Wells located outside of the Injection Zone.
V = VOC analyses perfonned by EPA Method 8260 MSV Low Level.
T = TOC analyses performed by Standard Method 9060A.
<Well Name> = Well Planned for Possible Future Installation.
NP - Not Present.
NS - Not Sampled (Well not accessible).
Prepared by: AWA
Table 5 Monitoring Matrix of Tables Permit Renewal 2018 Andrex 1022-50.xlsx Checked by: IAI

Table 6 (Revised 11-7-2018)
Injection Monitoring Plan
Andrei Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
u
C
c
c
C
o
w'
c
c
0
E
0
U
o
u
n
c
o
0
E
o
V
C
>
o
o
a
v
a
o
V
u
°
O
c
=_
_
0
V
O
O
2
Groundwater
RW-3 and IW-1
RW-3
X
X
X
X
X
MW-5
X
X
X
X
X
MW-12
X
X
X
X
X
RW-1, IW-2, lW-3 and/or IW-3A
IW-2
X
X
X
X
X
RW-1
X
X
X
X
X
MW-6
X
X
X
X
X
<IW-10>
MW44
X
X
X
X
X
None
<MW-3R>
X
1IW-4>
MW-7
X
X
X
X
X
<MW-8R>
X
X
X
X
X
MW-9
X
X
X
X
X
<IW-6>
None
RW-5 or <IW-7>
RW-5
X
X
X
X
X
MW-10
X
X
X
X
X
MW-13
X
X
X
X
X
MW-14
X
X
X
X
X
RW-6
X
X
X
X
X
<tW-8>
RW-6
X
X
X
X
X
<IW-9>
RW-7
X
X
X
X
X
MW-I1
X
X
X
X
X
MW-23
X
X
X
<IW-I1>
MW-24
X
X
X
X
X
<IW-12>
<MW-25R>
X
X
X
X
X
None
MW-15
X
MW-16
X
MW-17
X
MW-18
X
MW-20
MW-21
tj
KW-26
Surface Water
None
Smith Mill Creek 1
X
Smith Mill Creek 2
X
Smnh Mitt Crtck
X
Smith Mill Creek 4
X
Smith Mill Creek 5
X
Smith Mill Creek 6
X
Bear Creek 1
X
X
Bear Creek 2
X
Bear Creek 3
X
Bear Creek 4
X
Bear Creek 5
X
Jehovah Witness 1
X
X
Cecil's Spring I
X
Cecil's Spring 2
X
Notes:
Willa located outside of the Injection Zone.
VOC analvscs performed by FPA Method 8260 MSV Low Level.
TOC analyses performed by SM Method 9060A.
It may not be possible to obtain samples at exact milestones (30, 90, and 150 days, etc)
due to weekends, holidays, inclement weather, or other delays beyond our control.
Samples will be collected as near the milestone dates as the schedule allows.
Monitoring is performed when injection is performed in corresponding well.
<Well Name> = Well Planned for Possible Future Installation.
I'reper,d hN AWA
itoring Plan (R) of Tables Permit Renewal 2018 Andrex 1022-50.x1sx Ch v ked bv. I JB

Table 6
Injection Monitoring Plan
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
\
\
�
a
.rJ'
y
N
O
CA
eo
GO
y
W
c
.�
V
W
c
o
a
U
W
•�
N
Q�y
Li-ld"
0
c
o
a
U
W
-�i
r
o
•�
U
C
y
C�
U
y
7
y
7
u
�+
F.
CYJ
Groundwater
RW-3 and IW-1
RW-3
X
X
X
X
X
MW-5
X
X
X
X
X
MW-12
X
X
X
X
X
IW-2, IW-3 and/or IW-3A
IW-2
X
X
X
X
X
RW-1
X
X
X
X
X
MW-6
X
X
X
X
X
<IW-10>
MW-44
X
X
X
X
X
None
<MW-3R>
X
<IW4>
MW-7
X
X
X
X
X
<I W-5>
<M W-8R>
X
X
X
X
X
M W-9
X
X
X
X
X
<I W-6>
None
<IW-7>
RW-5
X
X
X
X
X
MW-10
X
X
X
X
X
MW-13
X
X
X
MW-14
X
X
X
<IW-8>
RW-6
X
X
X
X
X
<IW-9>
RW-7
X
X
X
X
X
M W-11
X
X
X
X
X
MW-23
X
X
X
<IW-11>
MW-24
X
X
X
X
X
<IW-12>
<MW-25R>
X
X
X
X
X
None
MW-15
X
M W-16
X
M W-17
X
M W-18
X
M W-20
X
M W-21
X
M W-26
X
Surface Water
None
Smith Mill Creek 1
X
Smith Mill Creek 2
X
Smith Mill Creek 3
X
Smith Mill Creek 4
X
Smith Mill Creek 5
X
Smith Mill Creek 6
X
Bear Creek 1
X
X
Bear Creek 2
X
Bear Creek 3
X
Bear Creek 4
X
Bear Creek 5
X
Jehovah Witness 1
X
X
Cecil's Spring 1
X
Cecil's Spring 2
X
Notes:
Wells located outside of the Injection Zone.
VOC analyses performed by EPA Meth 260 MSV Low Level.
TOC analyses performed by SM M od 9060A.
It may not be possible to obta' amples at exact milestones (30, 90, and 150 days, etc)
due to weekends, holi , inclement weather, or other delays beyond our control.
Samples will be col ed as near the milestone dates as the schedule allows.
Monitoring is oZ when injection is performed in corresponding well.
<Well N e> = Well Planned for Possible Future Installation.
Table 6 MoniKrine Plan of Tables Pennit Renewal 2018 Andrex 1022-50.xlsx

Appendix A

WELL CONSTRUCTION REC;�._.:`J
This form can be used for single or multiple wells
1. Well Contractor Information:
John Gorman
Well Contractor Name
3485-A
NC Well Contractor Certification Number
Bunnell-Lammons Engineering, Inc.
Company Name
2. Well Construction Permit #: U I C #W 10100106
List all applicable well permits (i.e. County•, State, I"ariance, L jection, etc.)
3. Well Use (check well use):
❑Agricultural ❑Municipal/Public
❑Geothermal (Heating/Cooling Supply) ❑Residential Water Supply (single)
❑Industrial/Commercial ❑Residential Water Supply (shared)
Supply Well:
[]Aquifer Recharge
oGround,.vater Remediation
❑Aquifer Storage and Recovery
❑Salinity Barrier
❑Aquifer Test
❑Stormwater Drainage
❑Experimental Technology
❑Subsidence Control
❑Geothermal (Closed Loop)
❑Tracer
❑Geothermal (Heating/Cooling Return)
❑Other (explain under #21 Remarks)
4. Date Well(s) Completed: 3-16-15
We11ID# I W-1
- 5a. Well Location:
Milkco, Inc. (Former Andrex)
#07022-03-11
Facility/Owner Name Facility ID# (if applicable)
180 Deaverview Road, Asheville, NC 28806
Physical Address, City, and Zip
Buncombe 9667
County Parcel Identification No. (PIN)
5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees:
(if well field, one lat/long is sufficient)
35.58010 N 82.61418 W
6. Is (are) the wll(s): iaPermanent or ❑Temporary
7. Is this a repair to an esisting well: ❑Yes or ❑No
If this is a repair, fill out known well construction information and explain the nature of the
repair under #21 remarks section or• on the back of this form.
8. Number of wells constructed: One
For multiple injection or non -water supply wells ONLY with the same construction, you can
submit one form.
For Internal Use ONLY:
14. WATER ZONES
FROM TO DESCRIPTION
50 it- 50 water -bearing fracture
ft. It.
15. OUTER CASING for multi -cased wens OR LINER if o Rcable
FROM TO DIAMETER THICI4�iESS MATERIAL
0 ft 47 H 6 i- Sch40 I PVC
16. INNER CASING OR TUBING eothermaI closed -loop)
FROM TO DL1.\PETER I THICKNESS MATERIAL
ft. IL in.
it. IL
17. SCREEN
FROM TO DIAMETER SLOT SIZE THICKNESS MATERIAL
ft. M in.
ft. It. in.
19. GROUT
FROM TO MATERIAL EMPLACEM&NT METHOD & ANIOURT
0 rt. 2 0 ft. cement gravity - 2 bags
2 it. 44.5 IL bentonite gravity - 25 bags
ft. u.
19. SAND/GRAVEL PACK if a licable
FROM TO MATERIAL EMPLACEMENT METHOD
44.5 it- 46.5 it- pea gravel gravity
46.5 fl• 55 ft. #3 stone I gravity
20. DRILLING LOG attach additional sheets if necessary)
FROM TO DESCRIPTION color, hardness, soWuock type. grain size, etc.
0 6 H red-brn mic f-m sandy SILT w/ some clay
6 10 ft red-brn mic silty f-m SAND (residutim)
10 it- 16 n• rock seam (PWR)
16 1L 32 ft. red-brn mic silty f--m SAND
32 ft 44 1t bm mic silty f-m SAND w/ rock fragments (PWR)
44 rt: 55 1I bedrock
ft. fr.
21. REMARKS
22. Certification:
�r 3-1&15
Signature of Certified Well Contractor Date
By signing this form. I hereby certify that the well(s) isus (were) constructed in accordance
with.15A NCAC 01C.0100 or 15A NCIC 01C.0100 Well Construction Standards and that a
copy of this record has been provided to the Nell oaaer.
23. Site diagram or additional well details:
You may use the back of this page to provide additional well site details or well
construction details. You may also attach additional pages if necessary.
SUBNIITl'AL INSTUCTIONS
9. Total well depth below land surface: .55 (ft.) 24a. For All Wells: Submit this form within 30 days of completion of well
For multiple wells list all depths if different (example- 3@200' and 2@100') construction to the following:
10. Static water level below top of casing: 47 (ft,) Division of Water Resources, Information Processing Unit,
Ifwater level is above casing, use "+" 1617 Mail Service Center, Raleigh, NC 27699-1617
11. Borehole diameter: 10 (in.) 24b. For Injection Wells ONLY: In addition to sending the form to the address in
air hammer 24aabove, also submit a copy of this form within 30 days of completion of well
12. Well construction method: construction to the following:
(i.e. auger, rotary, cable, direct push, etc.)
Division of Water Resources, Underground Injection Control Program,
FOR WATER SUPPLY WELLS ONLY: 1636 Mail Service Center, Raleigh, NC 27699-1636
13a. Yield (gpm) Method of test: 24c. For Water Supply & Iniection Wells:
Also submit one copy of this fowl within 30 days of completion of
13b. Disinfection type: Amount: well construction to the county health department of the county where
constructed.
Form GW-1 North Carolina Department of Environment and Natural Resources - Division of Water Resources Revised August 2013

WELL CONSTRUCTION REC�. ,.
This form can be used for single or multiple wells
For Internal Use ONLY:
1. Well Contractor Information:
Brunson L. King
Well Contractor Name
3290-A
NC Well Contractor Certification Number
Landprobe, LLC
Company Name
2. Well Construction Permit #: U I C #W 10100106
List all applicable well permits (i.e. Coum)4 State, Variance, Injection, etc.)
3. Well -Use (check well use):
❑Agricultural ❑Municipal/Public
❑Geothermal (Heating/Cooling Supply) El Residential Water Supply (single)
❑Industr"ial/Commercial ❑Residential Water Supply (shared)
Non -Water Supply Well:
❑Aquifer Recharge
©Groundwater Remediation
❑Aquifer Storage and Recovery
❑Salinity Barrier
❑Aquifer Test
❑Stormwater Drainage
❑Experimental Technology
❑Subsidence Control
❑Geothermal (Closed Loop)
❑Tracer
❑Geothermal (Heating/Cooling Return)
❑Other (explain under 9211
4. Date Well(s) Completed: 4-9-14
Well ID# I W-2
5a. Well Location:
Milkco, Inc. (Former Andrex) #07022-03-11
Facility/Owner Name Facility ID# (if applicable)
180 Deaverview Road, Asheville, NC 28806
Physical Address, City, and Zip
Buncombe 9667
County Parcel Identification No. (PIN)
5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees:
(ifwell field, one lat/long is sufficient)
35.57990 N 82.61396 W
6.Is (are) the well(s): 1211'erimment or ❑Temporary
7. Is this a repair to an existing well: ❑Yes or ONo
If this is a repair fill out known well construction information and explain the nature of the
repair under #21 remaria section or on the back of this form.
8. Number of wells constructed: One
For multiple injection or non -water supply wells ONLY with the same construction, you can
submit oneform.
9. Total well depth below land surface: 84
For multiple wells list all depths ifdderent (example- 3 200' and 2@100)
10. Static water level below top of casing: 56 00
If water letel is above casing, rise "+,"
11. Borehole diameter: 10 (in.)
12. Well construction method: air hammer
(i.e. auger, rotary, cable, direct push, etc.)
Division of Water Resources, Underground Injection Control Program,
FOR WATER SUPPLY WELLS ONLY: 1636 Mail Service Center, Raleigh, NC 276994636
13a. Yield (gpm) Method of test: 24c. For Water Supply & Injection Wells:
Also submit one copy of this form within 30 days of completion of
13b. Disinfection type: Amount: well construction to the county health department of the county where
constructed.
i
Form GW-1 North Carolina Department of Environment and Natural Resources - Division of Water Resources Revised August 2013
14. WATER ZONES " "
FROM TO DESCRIPTION
70 [' 73 ft water bearing fractures
ft ft
15.OUTER CASING for multi -cased wells OR LINER tf a licable
FROM TO DLAAIETER THICKNESS b1ATFRiei.
0 ft 64 n- 6 in• Sch 40 1 PVC
16. INNER CASING OR TUBING eother al closed -loop)
FROM TO DIAMETER THICKNESS MATERIAL
ft. ft. in
ft. ft in.
17. SCREEN
FROM TO DLAbIETER SLOT SIZE THICKNESS MATERIAL.
n. ft in.
M M in.
18. GROUT
FROM TO MATERIAL EMPLACEMENT METHOD & AMOUNT
0 ft- 2 ft• cement gravity - 1 bag
2 fL 64 fL bentonite gravity - 13 bags
rt. ft.
19. SAND/GRAVEL PACK it applicable)
FROM TO DL4TERLIL EMPLACEDIENr METHOD
64 ft- 84 ft. #3 stone gravity
ft. 1't
20. DRILLING LOG attach additional sheets if necessary)
FROM I TO DESCRIPTION color, hardness, soi0rock type, gmin size, etc.)
0 ft 25 ft red-bm f-m sandy SILT (fill)
25 IL 35 ft• red -bra silty f-m SAND (residuum)
35 it- 64 ft brown silty f-m SAND (PWR)
64 ft• 84 ft• gray-brn f-m SAND (bedrock)
ft. ft.
ft. ft
ft ft
21. RENIARKS
Well construction per UIC permit
22. Certification:
i " /0� - 5-8-14
Signature of Certified Well Contractor Date
By signing this form. I hereby certify that the well(s) was (were) constructed in accordance
with 15.4 NCAC 02C .0100 or ISA NC4C 02C .0200 Well Constriction Standards and that a
copy of this record has been provided to the well owner.
23. Site diagram or additional well details:
You may use the back of this page to provide additional well site details or well
construction details. You may also attach additional pages if necessary.
SUBMITTAL INSTUCTIONS
24a. For All Wells: Submit this form within 30 days of completion of well
construction to the following:
Division of Water Resources, Information Processing Unit,
1617 Mail Service Center, Raleigh, NC 27699-1617
24b. For Iniection Wells ONLY: In addition to sending the form to the address in
24a above, also submit a copy of this form within 30 days of completion of well
construction to the following:

WELL CONSTRUCTION REC'.._ �)
This form can be used for single or multiple wells
For Internal Use ONLY:
1. Well Contractor Information:
John Gorman
Well Contractor Name
3485-A
NC Well Contractor Certification Number
Bunnell-Lammons Engineering, Inc.
Company Name
2. Well Construction Permit #: U I C #W 10100106
List all applicable well permits (i.e. County, State, Variance, Injection, etc.)
3. Well Use (check well use):
Water Supply Well:
❑Agricultural ❑Municipal/Public
❑Geothermal (Heating/Cooling Supply) ❑Residential Water Supply (single)
❑Industrial/Commercial ❑Residential Water Supply (shared)
Non -Water
❑Aquifer Recharge
©Groundwater Remediation
❑Aquifer Storage and Recovery
❑Salinity Barrier
❑Aquifer Test
❑Stornnvater Drainage
❑Experimental Technology
❑Subsidence Control
❑Geothermal (Closed Loop)
❑Tracer
❑Geothermal (Heatina/Coolina Return)
❑Other (explain under #21 1
4. Date Well(s) Completed: 3-18-15
5a. Well Location:
Milkco, Inc. (Former Andrex)
Well ID# I W-3
#07022-03-11
Facility/Owner Name Facility ID# (if applicable)
180 Deaverview Road, Asheville, NC 28806
Physical Address, City, and Zip
Buncombe
9667
County Parcel Identification No. (PIN)
5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees:
(if well field, one lat/long is sufficient)
35.57991 N 82.61382 W
6. Is (are) the well(s)- [OPermanent or ❑Temporary
7. Is this a repair to an existing well: DYes or E]No
If this is a repair, fill out known well construction information and explain the nahire of the
repair under #21 remarks section or on the back of this form.
8. Number of wells -constructed: One
For multiple injection or non -water supply wells ONLY with the same construction, your can
submit one form.
9. Total well depth below land surface: 77
For midtiple wells list all depths if different (example- 3@200' and 2@1001
10. Static water level below top of casing: 52 (ft.)
If water level is above casing, use '•+"
11. Borehole diameter: 10 (in.)
12.Weilconstruction method: air hammer
(i.e. auger, rotary, cable, direct push, etc.)
Division of Water Resources, Underground Injection Control Program,
FOR WATER SUPPLY WELLS ONLY: 1636 Mail Service Center, Raleigh, NC 27699-1636
13a: Yield (gpm) Method of test 24c. For Water Supply & lnlection Wells:
Also submit one copy of this form within 30 days of completion of
- 13b. Disinfection type: Amount: well construction to the county health department of the county where
constructed.
14. WATER ZONES
FROM TO DESCRIPTION
ft. ft.
ft. tL
15. OUTERCING for mDHwellOiHI%a cable
FROM MATERL4L
0 It 50 fL 6 ID Sch40 PVC
16. INNER CASING OR TUBING eothermaI closed-loo
FROM TO DIAMETER THICKNESS MATERIAL
ft. ft. in.
ft. fL tn.
17. SCREEN
FROM TO DIAMETER SLOT SIZE THICKNESS MATERIAL
IL fL in.
M ft.
18. GROUT
FROM I TO MATERIAL EMPLACEMENT METHOD & AMOUNT
0 ft. 3 ft. cement gravity - 3 bags
3 n- 15 It- bentonite gravity - 9 bags
ft. ft.
19. SAND/GRAVEL PACK if a licable
FROM TO bL4TERULL EMPLACEMENT METHOD
15 It: 50 I`• pea gravel gravity
50 It- 77 H- 1 #3 stone I gravity
20. DRILLING LOG attach additional sheets if necessary):
FROM TO DESCRIPTION color. hardness, soWrock type, grain size, etc.)
0 ft. 10 It• red-bm mic f-m sandy SILT (fill)
10 rt- 25 ft. red-brn mic f-m sandy SILT (residuum)
25 fL 38 ft. brn mic silty f-m SAND (PWR)
38 ft-77 It• brn mic silty f-m SAND (PWR)
ft. 77 ft. bedrock
ft. ft.
ft. ft.
21. REMARKS
22. Certification:
3-18-15
Signature of Certified Well Contractor Date
By signing this form. I hereby cernfv that the wel(s) was (were) constntcted in accordance
with 15A NCAC 02C.0100 or 15A NCAC 02C.0200 Well Construction Standards and that a
copy of this record has been provided to the well owner.
23. Site diagram or additional well details:
You may use the back of this page to provide additional well site details or well
construction details. You may also attach additional pages if necessary.
SUBMITTAL INSTUCTIONS
24a. For All Wells: Submit this form within 30 days of completion of well
construction to the following:
Division of Water Resources, Information Processing Unit,
1617 Mail Service Center, Raleigh, NC 27699-1617
24b. For Iniection Wells ONLY: In addition to sending the form to the address in
24a above, also submit a copy of this form within 30 days of completion of well
construction to the following:
Form GW-1 North Carolina Department of Environment and Natural Resources - Division of Water Resources Revised August 2013

WELL CONSTRUCTION REC__ _D GW-1
1. Well Contractor Information:
John Gorman
Well Contactor Name
3485-A
NC Well Contractor Certification Number
Bunnell-Lammons Engineering, Inc.
Company Name
2. Well Construction Permit #: U I C #W 10100106
List all applicable well construction permits (t.e. UIC, County, State, Variance, etc.)
3. Well Use (check well use):
Water Supply Well:
❑Agricultural
❑Geothermal (Heating/Cooling Supply)
❑Industrial/Commercial
Supply Well:
❑Aquifer Recharge
[]Aquifer Storage and Recovery
❑Aquifer Test
❑Experimental Technology
❑Geothermal (Closed Loop)
❑Geothermal (Heating/Cooling
4. Date Well(s) Completed: 3/18/16
5a. Well Location:
Milkco, Inc. (Former Andrex)
❑Municipal/Public
❑Residential Water Supply (single)
❑Residential Water Supply (shared)
CGroundwater Remediation
❑Salinity Barrier
❑Stormwater Drainage
❑Subsidence Control
❑Tracer
❑Other (explain under #21 1
Well m# I W-3A
#07022-03-11
Facility/Owner Name Facility ID# (if applicable)
180 Deaverview Road, Asheville, NC 28806
Physical Address, City, and Zip
Buncombe 9667
County Parcel Identification No. (PIN)
For Internal Use Onl ",
14. WATER ZONES '
FROM
TO
DESCRIPTION
rt.
tt.
ft.
ft.
15.OUTER CASING for
muitirased wells OR LINER if a licable
FROM
TO
DIAMMETER
THICKNESS
MATERIAL
0 ft-
30 ft.
6 t°
Sch 40
PVC
16. INNER CASING OR TUBING eothermaI closed -loop)
FROM
TO
DIAMETER
THICKNESS
MATERIAL
ft.
tt.
In.
tt.
ft.
in.
17. SCREEN
FROII
TO
DIAMETER
SLOT SIZE
THICKNESS
MATERIAI.
ft.
rL
in.
ft.
ft.
in.
18. GROUT
FROM
I TO
MATERMLL
EMPLACEMENT METHOD & AMOUNT
0 ft-
3 tt
cement
gravity -- 3 bags
3 ft•
20 fL
bentonite
gravity - 13 bags
rt.
rt.
19. SAND/GRAVEL PACK
if a licable
FROM
TO
MATERrAL
EMPLACEMENT METHOD
20 ft•
25 tt
pea gravel
gravity
25 ft.
57 ft•
#3 stone
gravity
20. DRILLING LOG attach additional sheets N necessary)
FROM
I TO
DESCRIPTION (color, hardness, soiltrock type, plain size, etc.)
0 ft.
12 ft.
red-bm mic f-m sandy SILT (fill)
12 ft.
14 ft-
drk bm mic f-m sandy SILT w/some topsoil
14 ft.
57 ft-
light brn mic silty f-m SAND with PWR seams
It.
57 fL
bedrock
tt.
tt.
rt.
tt.
21. REMARKS
5b. Latitude and longitude in degrees/minutes/seconds or decimal degrees:
(if well field one lat/long is sufficient)
22. Certification: y,
"
35.57985 N 82.61390 W
'fr'
3/18/16
6. Is(are) the well(s): NPermanent or ❑Temporary
Signature of Certified well Contractor Date
By signing this form. I hereby certify that the wells) was (were) constructed in accordance
7. Is this a repair to an existing well: ❑Yes or NNo
with 15A NCAC 01C .0100 or 15A NCAC 02C.0200 Ir ell Construction Standards and that a
If this is a repair, fill out b-nown well construction information and explain the nature of the
copy of this record has been provided to the well owner.
repair tinder #21 remarks section or on the back of this form.
23. Site diagram or additional well details:
8. For Geoprobe/DPT or Closed -Loop Geothermal '*Veils having the same
You may use the back of this page to provide additional well site details or well
construction, only 1 GW-1 is needed. Indicate TOTAL NUI%MER of wells
construction details. You may also attach additional pages if necessary.
drilled: one
SURNU TAL INSTRUCTIONS
9. Total well depth below land surface: 57 (ft- )
24a. For All Wells: Submit this form within 30 days of completion of well
For multiple wells list all depths ifdiferent (example- 3@200' and 2@I00)
construction to the following:
52
10. Static water level below top of casing: (ft.)
Division of Water Resources, Information Processing Unit,
Ifwater level is above casing, use ••+"
1617 Mail Service Center, Raleigh, NC 27699-1617
11. Borehole diameter: 10 (in.)
24b. For Infection Wells: In addition to sending the form to the address in 24a
Well method: Air hammer
above, also submit one copy of this form within 30 days of completion of well
constlucton
construction to the following:ie.
(Le auger, rotary, cable, direct push, etc.) '
Division of Water Resources, Underground Injection Control Program,
FOR WATER SUPPLY WELLS ONLY:
1636 Mail Service Center, Raleigh, NC 27699-1636
13a. Yield (gpm) Method of test:
24c. For Water Supply & Infection Wells: In addition to sending the form to
the address(es) above, also submit one copy of this form within 30 days of
13b. Disinfection type: Amount:
completion of well construction to the county health department of the county
where constructed.
IForm GW-1 North Carolina Department of Environmental Quality - Division of Water Resources Revised 2-22-2016

ri
North Carolina Department of Environment and Natural Resources
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
In Situ Groundwater Remediation (15A NCAC 02C .02251 I Tracer Injection (15A NCAC 02C .02291
Do not use this form for the following:
• in situ remediation, tracer, or aquifer test injection wells permitted by rule (ref. 15A NCAC 02C .0217)
• remediation systems that reinject treated contaminated groundwater (ref. 15A NCAC 02T .16001
Application Number (to be completed by DWQ):
I. APPLICATION INFORMATION
1. Project is: [ ] New [ ] Modification [ ] Renewal without modification [X] Renewal with modification
2. If this application is being submitted for renewal or modification to an existing permit, provide:
existing permit number WI0100106 and the issuance date December 22, 2010
For renewal without modifications, fill out sections I & H only, sign the certification on the last page of this form, and obtain
the property owner's signature to indicate consent (if the applicant is not the owner).
For all renewals, submit a status report including monitoring results of all injection activities to date.
II. WELL OWNER ( )
1. Name: Milkco, Inc (non -responsible party)
2. Signing Official's Name*: Mr. Keith Collins Title: President
* Signing Official must be in accordance with instructions in Part IX on page 5.
3. Mailing address of applicant: Milkco, Inc.
PO Box 16160
City: Asheville State: NC Zip: 28816
4. Telephone number: 828-254-9560 Email: keithamilkco.com
5. Status (choose one): Individual X Business/Org. Federal State County Municipality
III. PROPERTY OWNER (if different than well owner)
1. Name:
2. Physical address:
City:
3. Mailing address:
City:
4. Telephone number: Email:
State: Zip:
State: Zip:
IIII. PROJECT CONTACT — Person who can answer technical questions about the proposed injection project.
1. Name: Andrew W. Alexander, PG, RSM Title: Senior Hydrogengist
2. Company: Bunnell-Lammons En ing eering, Inc. (BLE)
3. Address: 6004 Ponders Court
4. City: Greenville State: SC Zip: 29615
S. Telephone number: 864-288-1265 Email: andyaa,blecgM.com
RECEIVEMENHWQ
Revised 10/8/2012 A U G G 6 UIC-5I/5T Pagel of 5
Aquifer orntnrttrn :ArtipO

V.
VI.
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
In Situ -Groundwater Remediation I Tracer Injection
FACILITY INFORMATION
1. Facility name: Former Andrex Industries Corp. Ph#:, Not Applicable
2. Mailing address: 180 Deaverview-Road (Physical Address of Unoccupied Parcel)
City: Asheville County: Buncombe State:NC-Zip: 28806
.3. Geographic Coordinates: Latitude: N: 35.580496 0: Longitude: W 82.613115 °
Reference Datum:. .:Center Parcel Accuracy: Unknown
Method of Collection: Google Earth
4. Brief description of business: Former Textile Dyeing and FinishingFacility
INCIDENT DESCRIPTION
1. Source and date of contamination: Textile dyeing and finishing. Use of PCE for industrial textile cleaning_
2. List all contaminants present in soils or groundwater at the site (contaminants may be listed in groups, e.g., gasoline,
diesel, jet fuel, fuel oil, chlorinated ethenes, chlorinated ethanes, metals, pesticides/herbicides, etc):
Chlorinated ethenes, Chlorinated ethanes (trace level), petroleum hydrocarbons-
3. Has LNAPL or DNAPL ever been observed at, the site (even if outside. the inj ection zone)?
[ ] Yes If yes, list maximum measured separate:phase thickness: feet
[X] No If no, list maximum concentration :of total: VOCs observed at site: (MW-5) 49,830= ppb
4. Agency managing the contamination incident:
[ ]UST Section [ ] Superfund Section (including REC Program and DSCA sites)'
[ ] DWQ Aquifer Protection. Section []So lid Waste Section
[ ] Hazardous Waste -Section [X]:Other: Brownfields Program
5. Incident manager's name: Ms. Tracy Wahl Ph#: .828-251-7465
6. Incident number or other incident mgmt. agency tracking number:
Brownfields Project Number 07022-03-11 & Groundwater Incident No. 6586
VII. PERMITS
List all applicable permits or construction approvals issued for the facility or incident:
1. Hazardous Waste Management program permits under RCRA: Former RCRA ID No. NCD074498387
2. DWQ Non -Discharge or NP:DES permits`.
3. County or DEH;subsurface wastewater disposal permits:
4. Other environmental permits required by state or federal law:
See attached Summary of Permits Issued revised (Table 1)
Revised 10/8/2012 UIC-51/5T Page 2 of 5

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
In Situ Groundwater Remediation I Tracer Injection
VIII. ATTACHMENTS — provide the following information in separate attachments. The attachments should be
clearly identified and presented in the order below to expedite review of the permit application package.
1. INJECTION ZONE - Per 15A NCAC 02C .0225(e)(2) specify the horizontal and vertical portion of the subsurface within
which the proposed injection activity will take place and beyond which no violations of groundwater quality standards
shall result from the, injection as determined. by an approved monitoring plan. The determination shall be based on the
hydraulic properties of the specified zone. Provide any supporting documentation in a separate attachment.
2. HYDROGEOLOGIC EVALUATION Per 15A NCAC 02C .0225(e)(3) provide a hydrogeologic evaluation of the
injection zone that includes all of the following:
(A) Regional and local geology and hydrology;-
(B) Changes in lithology underlying the facility;
(C) Depth to bedrock;
(D) Depth to. the mean seasonal high water table;
(E) Hydraulic.. conductivity, transmissivity, and storativity, of the injection -zone based on tests of site -specific
material, 'including a description of the test(s) used to determine these parameters;
(F) Rate and direction of groundwater flow as determined by predictive calculations or computer modeling; and
(G) Lithostratigraphic and hydrostratigraphic-logs of any existing test and injection wells.
3. INJECTANT INFORMATION — Per 15A NCAC 02C .0225(e)(5) list each injectant in.the space.below and provide. the
following information for each injectant. NOTE: Approved injectants can be found online at
hyp://portal.ncdenr.orgwweb/wq/aps/�-►vpro. All other substances must be reviewed by the Division of Public Health,
Department of Health and Human Services. Contact -the UIC Program for more information (Ph# 919-807-6496).
1% milk solution in water
No changes are proposed to the injectant which is on the Approved Injectants list.
(A) MSDS, concentration at the point of injection, and percentage if present in a mixture with other injectants;
(B) The source of.fluids used:to dilute, carry, or otherwise, distribute the injectant throughout the injection zone. If
any well within the area of review of the injection facility_ is to be used as the fluid source, then the following
information shall be submitted: location/ID number, depth -of source, .formation; rock/sedirrient type, . and a
chemical analysis of the. water from the source well, including analyses for all contaminants suspected or
historically recognized in soil or.groundwater on -the site;
(C). A description of the rationale for selecting --the injectants and concentrations proposed for injection, including an .
explanation or calculations of how the proposed injectant volumes and concentrations were determined;
A description of the reactions between the injectants and the contaminants present including specific: breakdown
products. or intermediate compounds that.may be formed by the injection;
(E) A summary of results if modeling or testing was performed to investigate the injectarifs potential or susceptibility
for biological, chemical, or physical change in the subsurface; and
(F) An evaluation .concerning the development- of -byproducts of the injection process, including increases in the
concentrations of naturally occurring substances. Such an evaluation shall include the identification of the specific.
byproducts of the injection process, projected concentrations of byproducts, and areas of migration as determined
through modeling or other predictive calculations.
4. INJECTION PROCEDURE — Per 15A NCAC 02C .0225(e)(6) submit a table witha detailed description of the proposed.
injection procedure that includes the following:
(A) The proposed average and maximum daily rate and quantity of injectant;
(B) The average.maximum injection pressure expressed in units of pounds.per square inch (psi);:and
(C) The total or estimated total volume to be injected:
Revised 10/8/2012
UIC-5I/5T
Page 3 of 5

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
In Situ Groundwater Remediation I Tracer Injection
5. TRACTURING.PLAN (if applicable) — Per 15A NCAC 02C .0225(e)(7) submit a detailed. description of the fracturing plan -
that. includes the following:
(A) Material Safety Data Sheets of fracturing media including information on any proppants used;
(B) a map of fracturing well locations relative to the known extent of groundwater contamination plus all buildings,
wells; septic systems, underground storage tanks, and underground utilities located within -the Area of Review;
(C) a .demonstration that buildings, wells, septic- systems, underground storage tanks, and underground utilities will
not be adversely affected by the fracturing process;
(D) injection rate and volume;
(E) orientation of bedding planes, joints, and fracture sets of the fracture zone;
(F) performance monitoring plan for determining the fracture well radius of influence; and
(G) if conducted, the:results of geophysical testing or pilot test:of fracture behavior conducted in an uncontaminated:
area of the site.
6. WELL CONSTRUCTION DETAILS — Per 15A NCAC 02C .0225(e)(8) submit .the following information in tabular or
schematic form as appropriate for each item:
(A) number and depth of injection wells;
(B) number and depth of borings if using -multi -level or "nested" well systems;
(C) indication. whether the injection wells are existing or proposed;
(D) depth and type of casing;
(E) depth and type of screen material;
(F) depth and type of gout; -:
(G) indication whether the- injection wells are permanent or temporary "direct push" points; and
(H) plans and specifications of the surface and.subsurface construction details. _
7. MONITORING PLAN — Per 15A NCAC .02C .0225(e)(9) submit a monitoring plan that includes the following:
(A) target contaminants plus secondary or intermediate contaminants that may result from the injection;
(B) other parameters that may serve to indicate the progress of the intended reactions;
(C) a list of existing and proposed monitoring wells to be used;. and
(D) a sampling. schedule to monitor the proposed injection.
Monitoring wells shall be of sufficient quantity and location to detect any movement of injection fluids, injection process byproducts,
orformationfluidsoutside the injection zone. The monitoring.schedule shall be consistent with the proposed injection schedule, pace
of the anticipated reactions, and rate of transport of the injectants and contaminants.
8. WELL DATA.TABULATION—:Per.15ANCAC 02C .0225(e)(10) provide a tabulation of data on all existing or abandoned
wells within the area of.review of the injection well(s) that penetrate the proposed injection zone,,including monitoring
wells and wells proposed for use as injection wells. Such data shall include a description of each well's type, depth, and
record of construction or abandonment.
9. MAPS AND CROSS -SECTIONS Per 15A NCAC 02C :0225(e)(11) provide scaled, site=specific site plans or maps
depicting the location, orientation,: and relationship of facility components including the following:
(A) area map based on the most. recent USGS 7.5' topographic map of the area, at a scale of 1:24,000 .and showing the
location of the proposed injection site;
(B) topographic contour intervals showing all facility related structures, property boundaries, streams, springs, lakes,
ponds, and other surface drainage features;
(C) all existing or abandoned wells within the area of -review of the wells listed in the well . data tabulation that
penetrate the proposed injection zone; -
(D) potentiometric surface map(s) that show the direction of groundwater movement, existing and proposed wells;
(E) contaminant. plume map(s) with isoconcentration lines that show the. horizontal: extent of .the contaminant plume
in soil .and groundwater, and existing and proposed wells;
(F) cross -sections) to the known or projected depth: of contamination that show the horizontal and vertical extent of
the contaminant plume in soil and groundwater, major changes in lithology, and existing and proposed wells; and
(G) any existing sources of potential or known groundwater contamination, including waste storage, treatment, or
disposal systems within the area of review of the injection well or well system.
I
Revised 10/8/2012 UIC-5I/5T Page 4 of 5

APPLICATION FOR PERMIT TO CONSTRUCT AND/OR USE A WELL(S) FOR INJECTION
In Situ Groundwater Remediation I Tracer Injection
IX. CERTIFICATION* (to be signed as required below or by that person's authorized agent*)
NCAC 15A 02C .0211(e) requires that all permit applications shall be signed as follows:
1. for a corporation: by a responsible corporate officer
2. for a partnership or sole proprietorship: by a general partner or the proprietor, respectively
3. for a municipality or a state, federal, or other public agency: by either a principal executive officer or
ranking publicly elected official
4. for all others: by the well owner.
*If an authorized agent is signing on behalf of the applicant, then supply a letter signed by the applicant
that names and authorizes their agent.
"I hereby certt& under penalty of law that I have personally examined and am familiar with the information
submitted in this document and all attachments therein, and that, based on my inquiry of those individuals
immediately responsible for obtaining said information, I believe that the information is true, accurate, and
complete. I am aware that there are penalties, including the possibility offines and imprisonment, for submitting
false information. I agree to construct, operate, maintain, repair, and if applicable, abandon the injection well(s)
and all related appurtenances in accordance with the approved specifications and conditions of the Permit. "
Printed Name and
Signature:
Date: /
/3oA3
X. CONSENT OF PROPERTY OWNER (if the property is not owned by the permit applicant)
"Owner" means any person who holds the fee or other property rights in the well being constructed. A well is real
property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of
contrary agreement in writing.
"As owner of the property on which the injection well(s) are to be constructed and operated, I hereby consent to
allow the applicant to construct each injection well as outlined in this application and agree that it shall be the
responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards
(I SA NCAC 02C . 0200). "
Printed Name and Title:
Signature: Date:
Submit TWO copies of the completed application package, including all attachments, to:
DWQ - Aquifer Protection Section
RECEIVEDIDENR M 1636 Mail Service Center RECEIVEDIDENRinwo
Raleigh, NC 27699-1636
AUG 0 6 2013 Telephone [phone] AUG 0 6
Aquifer Protection Section
Aquifer Protection bection
Revised 10/8/2012 UIC-5I/5T Page 5 of 5

a1,S
UIC Permit Application — Renewal with Modification July 30, 2013
Former Andrew Industries, Asheville, North Carolina BLE Project Number J12-1022-35
SECTION VII ATTACHMENTS
1) Injection Zone
The proposed injection zone remains unchanged from that specified in the prior permit. The zone --)
includes strata within approximately 80 feet of the ground surface including zones of saprolite,
partially weather rock (PWR) and fractured bedrock.
2) Hydrogeologic Evaluation
No additional hydrogeologic evaluations have been performed since submittal of the prior permit
application. However, a groundwater elevation map from the most recent site -wide sampling event
(September 2012) is included herein (Figure 1). The inferred groundwater flow directions and
hydraulic gradients are consistent with those observed for the past 20 years.
3) Injectant Information
The proposed injectant is a 1% milk solution in water. No changes are proposed to the injectant
which is on the Approved Injectant list.
4) Injection Procedure
No changes are proposed to the injection procedures which include injection by gravity feed into
each wellhead via hose from a tanker truck and/or trailer -mounted tanks.
Injections are proposed for the existing recovery welkRW-3 anik for twelve new injection wells 3
Wesignated IW-I through IW-12 (Figure 2). Please refer to Section 6) Well Construction Details of
this application for information on the proposed injection wells. Please refer to the Well Installation
Plan (Table 2) for the schedule of well installations.
Based on prior injections and estimated installation depths of the proposed injection wells we have
assumed that ups to 21lons of injectant will be required for each well for each injection event.
We have assumed that Milkco can produce and deliver up to 5,000 gallons of milk solution per day.
Based on these assumptions, up to 5 working days will be required for each injection event for each
well.
Injections are proposed annually with options for semi-annual injection as shown on the Injection
Schedule (Table 3).
5) Fracturing Plan
No fracturing is planned or proposed for this project.
2

I i
UIC Permit Application — Renewal with Modification July 30, 2013
- Former Andrez Industries, Asheville; North Carolina_' BLEProject Number J12-1022-35
Well Construction Deta'
Twelve (12) new permanent: injection wells designated IW-1 through IW-12 are proposed at the
locations noted on Figure 2..: The wells :will be advanced to an estimated. depth of up to 80 feet each.
Actual well .depths; will be determined in the field based on hydrogeologic conditions encountered:
Wells will be constructed in a 10-inch diameter air -hammered borehole and filled with -No. 3 stone
- (or:sirnilar) to within 10. feet. of the:ground surface. A 6-inch diameter solid PVC. riser with stone,
gravel layer, a bentonite seal, and a cement. seal will comprise the upper 10 feet of the well. A 3 by,:
3: foot concrete pad and steel flush.mount=cover and compression cap will complete the well head. A
typical injection well construction diagram is included in Appendix A.
Additionally, four (4) groundwater monitoring wells designated MW-3R, MW-8R, MW-25R, and
:. MW-44 are proposed at the locations noted .on Figure: 2. Wells. designed. with the letter "W' are:
replacement wells for those abandoned: or lost as: part of Milkco construction efforts. Proposed
monitoring well MW-44 is: anew well.. These 4 wells are proposed as monitoring points for the
future injections proposed herein. -A baseline, sampling.event will be performed after installation to:
establish groundwater quality.,conditions prior to the planned injection events.
These monitoring Wells will be installed -to a depth of up to 80 feet deep each. _Actual depths will be
determined in the field based on are hydrogeologic conditions encountered. Each well will be
constructed with 2-inch PVC riser and a 15-foot' long section -of slotted well screen.'installed in a 6-
inch diameter ' air -hammered borehole. All wells will be installed with appropriate well heads and
flush mount.pads and covers. We understand that well installation permits are not required. for
- groundwater monitoring wells installed on. the subject property which.: is owned by Milkco
(applicant). However, the appropriate installation, records will be submitted to the.DWQ upon well
completion. .
7) Monitoring Plan
Groundwater monitoring will ,be performed as specified :on Table 4. In general, monitoring will be
- performed at 30, 90, and 150-day milestones (depending on distance from the injection point) and
annually for all wells as required. Monitoring frequencies will be adjusted based on: results obtained .
once the injection program:: is underway. It may not be possible to obtain samples at ::exact
milestones (30, 90, and :150 days, etc) due to weekends, holidays, inclement weather, or other delays;'
beyond our control. -Samples will: be collected as near the milestone dates as the schedule allows.
Groundwater, samples will -be analyzed for VOCs by EPA Method 8260 MSV Low Level and for
total organic carbon (TOC) by Standard Method SM 53 JOB (for select wells only, see Table 4).
Surface water will be monitored annually for VOCs by EPA. Method 8260 MSV Low Level and for
TOC by Standard Method SM 53108 (Table 4).
8) - Well Data Tabulation
No changes to the existing or abandoned wells have occurred since the last :permit application.
3

MILE
U1C Permit Application — Renewal with Modification
Former Andrew Industries, Asheville, North Carolina
9) Maps and Cross -Sections
July 30, 2013
BLE Project Number J12-1022-35
An updated groundwater elevation map (Figure 1) and plume map (Figure 2) are included in this
application for reference. These maps were sourced from the report titled Report of Annual
Groundwater and Surface Water Sampling and Analysis for 2012 dated July 17, 2013 (BLE
Project No. J12-1022-34) which was previously submitted to your office.
The inferred groundwater flow directions and hydraulic gradients from Figure 1 are consistent with
those observed for the past 20 years. The plume map on Figure 2 has been modified to include
proposed injection wells and monitoring wells. Please note that the plume dimensions have changed
significantly since the 2011 annual event. The plume now appears to be detached from the upper
and lower site areas due to remediation in the RW-5 area. Additionally, the total VOCs in the MW-
12 area consist primarily of cis-1,2-DCE due to dechlorination of PCE. Please note that the results
of the injection and monitoring efforts to date will be presented in an Interim Evaluation Report
submitted under separate cover.
CLOSING
We appreciate the opportunity to work with you at the subject site. We look forward to receiving
NCDENR approval of the application and work plan. If you have any questions, please do not
hesitate contacting us at [phone].
Sincerely,
BUNNELL-LAMMONS ENGINEERING, INC.
&&/ a15�WAI�
Andrew W. Alex der, P.G., RSM
Senior Hydrogeologist
Registered, NC No. 1475
Attachments: Tables
Figures
Appendix A
Trevor J. Bento P.G.
Project Hydrogeologist
Registered, NC No. 2025
c: krwalactive projectslandrex milkcolphase35 3rd injection and monitoringU022-35 permit renewalluic permit app text renewal with
modification andrex 1022-35.doc
N CAgp '�''% .�`�`g�N. CAR
�• 2025 :
"'yF`0 F°L°G' A

TABLES

Table 1
Summary of Permits Issued
Andrex Industries
Asheville, North Carolina
NCDENR Groundwater Incident Number 6586
BLE Project No. J12-1022-35
Permit Number
Date
10-0226-WM-0188
4/22/1991
10-0226-WM-0201
7/ 11 / 19 91
NA*
May-95
WM0IOOI03
4/3/1997
WM0IOOI04
4/3/1997
WM0IOOI05
4/3/1997
WM0100106
4/3/1997
WM0IOOI07
4/3/1997
WM0IOOI08
4/3/1997
WM0IOOI09
4/3/1997
WMO100110
4/3/1997
10-0226-W R-0265 12/ 18/ 1992
WR0100043 October/1999
AC-778
5/14/1993
G-015-93
9/24/1993
GWR-13
3/29/1993
WI0100106 12/22/2010
Permit Type
Includes
Monitor Well
MW-1 & MW-2
Monitor Well
MW-3 through MW-8 & MW-8A
Monitor Well
MW-9 through MW-12
Monitor Well
MW-19
Monitor Well
MW-20
Monitor Well
MW-13 & MW-14
Monitor Well
MW-15, MW-16, & MW-18
Monitor Well
MW-17
Monitor Well
MW-21 & MW-22
Monitor Well
MW-23
Monitor Well
MW-24 & MW-25
Recovery Well RW-1 & RW-2
Recovery Well RW-3, RW-4, RW-5, RW-6 & RW-7
MSD Allocation Ground -Water Treatment System
MSD Discharge Ground -Water Treatment System
Air Permit* * Ground -Water Treatment System
UIC Permit Injection of Milk Solution
Notes:
* = At the time of installation (May 1995) permits for on -site monitoring wells were no longer required.
MSD = Metropolitan Sewerage District of Buncombe County.
** = Air permit issued by the Western North Carolina Regional Air Pollution Agency.
Table 1 Summary Permits of 1022-35 Andrex Injection Permit Tables.xlsx

Table 2
Well Installation Plan
Andrex Industries
Asheville, North Carolina
NCDENR Groundwater Incident Number 6586
BLE Project No. J12-1022-35
3
0
0
a
0
a
0
•y
U
N
Year One
Year Two
Year Three
Year Four
Year Five
MW-3R
X
MW-8R
X
MW-25R
X
MW-44
X
IW-1
X
IW-2
X
IW-3
X
IW-4
X
IW-5
X
IW-6
X
IW-7
X
IW-8
X
IW-9
X
IW-10
X
IW-11
X
IW-12
X
Notes:
X - Well Scheduled for Installation.
Well installation schedule may be altered based on operational budget.
Well installation schedule may be altered based on monitoring results.
Prepared by: AWA
Table 2 Inst Schedule of 1022-35 Andrex Injection Permit Tables.xlsx Checked by: TJB

Notes:
X = Injection scheduled:.,
XB = Injection,may be performed based on monitoring results.
j p g P
An in ection.volume of u to 25 000 gallons: per well per event is assumed.
Actual injection schedule will be, adjusted:based on monitoring results.
Actual injection schedule &volumes injected will be adjusted based
on available milk solution.
Injections will be semi-annual. or annual based on:monitoring results.
Prepared by: AWA
Table 3 Injection Schedule of 1022-35 Andrex Injection. Permit Tables.xlsx Checked by; TJB

Table 4 (Revised November 2013)
Injection Monitoring Plan Matrix
Andrex Industries
Asheville, North Carolina
NCDENR Groundwater Incident Number 6586
BLE Project No. J12-1022-35
c
•C
inn
eo
.5
�C.
G
c
�
a
U
W
A
O
M
�
�
w
U
W
0
A
OO
�
o
a
�
U
a
W
C
Cd
d
c
n
U
O
H
U
O
>
a.
T
>
Groundwater
RW-3 & 1W-1
RW-3
X
X
X
X
MW-5
X
X
X
X
MW-12
X
X
X
X
INV-2
RW-1
X
X
X
X
MW-6
X
X
X
X
MW-44
X
X
X
X
INV-3
MW-3R
X
X
X
X
IW4
MW-7
X
X
X
X
IW-5
MW-8R
X
X
X
X
MW-9
X
X
X
X
None
INN-7
RNV-�
X
X
X
X
MNN'-ill
X
X
X
X
MNN-13
X
X
NINN-14
X
X
IW-8
RW-6
X
X
X
X
IW-9
RW-7
X
X
X
X
MW-11
X
X
X
X
IW-10
NIIV-23
X
X
IW-11
MW-24
X
X
X
X
IW-12
MW-25R
X
X
X
X
None
MW-15
X
MNA'-16
X
MNI'-17
X
MW-18
X
MW-20
X
MW-21
X
NINN-22
X
MINA-26
X
Surface Water
None
Smith Mill Creek 1
X
Smith Mill Creek 2
X
Smith Mill Creek 3
X
Smith Mill Creek 4
X
Smith Mill Creek 5
X
Smith Mill Creek 6
X
Bear Creek I
X
Bear Creek 2
X
Bear Creek 3
X
Bear Creek 4
X
Bear Creek 5
X
Jehovah Witness 1
X
Cecil's Spring 1
X
Cecil's Spring 2
X
Notes:
Wells located outside of the Injection Zo -.39121111111=14=2
VOC analyses performed by EPA Method 8260 MSV Low Level.
TOC analyses performed by SM Method 531013.
It may not be possible to obtain samples at exact milestones (30, 90, and 150 days, etc)
due to weekends, holidays, inclement weather, or other delays beyond our control.
Samples will be collected as near the milestone dates as the schedule allows.
Prepared by: AWA
Table 4 Monitoring Plan of 1022-35 Andrex Injection Permit Tables Addendum.xlsx Checked by: TJB

Table 4
Injection MonitoringPlan Matrix.
Andrex Industries
Asheville, North .Carolina'
NCDENR Groundwater Incident Number 6586
BLE Project No. J12-1022-35
..
..
:
0
p
U
a
W
W
W
U
O
�7
G
_
C
U
C
cCa
d
?;
0
Ll,
fa .
G .
o
GroundFvater
RW-3 & IW4
RW-3..
X
_, X ::::...
g ::.
X
MW-5
X
X
X .
X
MW-12, ..
X.
X
X...
X..,•
IW-2
RW-1.
X
:X
X
X
MW-6
X
X
X
X
MW-44
X
X
X
X
11W-3
MW-3R
X
X
X
X
IW-4
MW-7
X
X
X
X
IW-5
MW-8R.
X
X
X .
X .
_MW-9 .
X..
X
IW-6
None
IW4:
RW-5
X
X
X
X
MW-10
X
X ...
X
X
MW-13
X
X
. MW-14::::.
X.
X
....... IW-8 :.:. _
.... RW-6..
X :..
.. X
X.
X,
nV-9
RW-7
X
X ..
X..,,
X . .
p.
MW-11
X
X
X
X
IW-10
MW-23
X
X
1W-11
MW-24
X
X
X
X
IW-12
MW-25:.....
X
X
X
X
X
None-...
MW-15
MW-16 .
X
...
... .
MW-17
X ._
:.
MW-18
X
MW-20
X
MW-21
X
MW-22
X
MW-26
_
X
Surf
ee Watcr
None
Smith Mill Creek 1.
X:,
Smith Mill Creek 2
X
Smith Mill Creek 3
X
Smith. Mill Creek 4
X
Smith, Mill Creek's..
X.:.••
Smith Mill Creek 6
X
Bear Creek L .
X
Bear Creek 2
X
Bear Cre
X
B e a Orerreek 4
X
ar Creek 5:
X
ehovah Witness.l.
pX.:.
Cecil's Spring 1
X
::. Cecil's Spring 2 _
X
_.. Notes:.
-
VOC yses.performed by, EPA Method: MSV Low Level.
T analyses performed by SM Method 531OB:
It may not be possible to obtain samples at exact milestones (30, 90,'and 150 days, etc)
due to weekends; holidays, inclement weather, or other delays beyond our control..
Samples will be collected as near the milestone dates as the schedule allows.
Prepare AWA "
Table onitoring Plan of 1022-35 Andrex Injection Permit Tables.xlsx
Checked b TJB

APPENDIX A
TYPICAL INJECTION WELL
CONSTRUCTION DIAGRAM

TYPICAL ABOVE BEDROCK INJECTION WELL
CONSTRUCTION DIAGRAM
4—INCH THICK
CONCRETE PAD
GROUND SURFACE
2—FEET CEMENT GROUT
TO GROUNDWATER SURFACE
[if GW ABOVE BEDROCK]
VARIBLE
#3 STONE
10—INCH AIR —HAMMERED
BOREHOLE
FLUSH MOUNT STEEL
WELL COVER
COMPRESSION
WELL CAP
— BENTONITE SEAL
[VARIBLE THICKNESS]
GRAVEL
6—INCH ID PVC RISER
GROUNDWATER LEVEL
TOTAL DEPTH
OF BORING
BORING TERMINATED AT
TOP OF BEDROCK
JOB
� NO.: J13-1022-35 FIGURE
11LENC. TYPICAL ABOVE BEDROCK INJECTION WELL DIAGRAM
DAM 09-26-13 BUNNELL—LAMMONS ENGINEERING, INC. FORMER ANDREX INDUSTRIES
A
SCALE e004 PONDERS SHEVILLE, NORTH CAROLINA
cauaT
NOT TO SCALE pHa�° � F,- � s 44M

0
TYPICAL BEDROCK INJECTION WELL
CONSTRUCTION DIAGRAM
4-INCH THICK
CONCRETE PAD
GROUND SURFACE
2-FEET CEMENT GROUT
TOP OF BEDROCK
[if GW BELOW BEROCK]
\\
GROUNDWATER LEVEL
/
#3 STONE
10-INCH AIR -HAMMERED
BOREHOLE
FLUSH MOUNT STEEL
WELL COVER
COMPRESSION
WELL CAP
- BENTONITE SEAL
[VARIBLE THICKNESS]
6-INCH ID PVC RISER
TOP OF BEDROCK
TOTAL DEPTH
OF BORING
JOB NO.: J13-1022-35 FIGURE
13LEM TYPICAL BEDROCK INJECTION WELL DIAGRAM
09-26-13 BUNNELL-LAMMONS ENGINEERING, INC. FORMER ANDREX INDUSTRIES
SCALE SON PONDEM COURT ASHEVILLE, NORTH CAROLINA
�W NOT TO SCALE NW W rWW-44W

TYPICAL INJECTION WELL
CONSTRUCTION DIAGRAM
4-INCH THICK FLUSH MOUNT STEEL
CONCRETE PAD WELL COVER
GROU SURFACE COMPRESSION
WELL CAP
Q'4
2-FEE CEMENT GROUT
BENTONITE EAL
[VARIBLE CKNESS]
TOP OF PWR [if GW BELOW BEROCK]
OR TO GROUNDWATER SURFACE
[if GW ABOVE BEDROCK]
6 FEET 6-FEET GRAVEL
6-INCH ID PVC RISER
� o 0
�o
TOTAL DEPTH
#3 STONE o OF BORING
10
,74NCH AIR -HAMMERED
BOREHOLE
JOB NO.: J13-1022-35 FIGURE
DATE: IBLEIMM TYPICAL INJECTION WELL DIAGRAM
07-22-13 BUNNELL-LAMMONS ENGINEERING, INC. FORMER ANDREX INDUSTRIES
SCALE. 6004 PONDERS COURT ASHEVILLE, NORTH CAROLINA
NOT TO SCALE ZF %jWOU7N OARdJ 86 67 �0
PHONE [phone] FAX eA

TYPI CAL INJECTION =-WELL
CONSTRUCTION' DIAGRAM

ABOVE BEDROCK INJECTION WELL
CONSTRUCTION DIAGRAM
4—INCH THICK
FLUSH MOUNT STEEL
3' X 3' CONCRETE PAD.
WELL COVER
COMPRESSION
GROUND SURFACE
WELL CAP
a•9
CEMENT GROUT
a •a a
BENTONITE SEAL
TO GROUNDWATER SURFACE
(VARIABLE DEPTH)
(VARIABLE DEPTH)
GRAVEL
6—INCH ID PVC RISER
GROUNDWATER LEVEL
�o 0
o 0
TOTAL DEPTH
#3 STONE
o
OF BORING
(VARIABLE THICKNESS)
(VARIABLE DEPTH)
Do 0
�o 0
o 0
o 0
10—INCH AIR —HAMMERED
BOREHOLE
0 0
�o a
BORING TERMINATED AT
TOP OF BEDROCK
o 0
(VARIABLE DEPTH)
o 0
,roe No.:
FIGURE
J18-1022-50
' IM BUNNELAMMUNS LL
� AMMO
it0� ENGINEERING
6004 Ponders Court, Greenville, SC 29615
ABOVE
BEDROCK INJECTION WELL DIAGRAM
FORMER ANDREX INDUSTRIESSul
ASHEVILLE, NORTH CAROLINA
I�
DAIS
08-27-18
NOT TO SCALE
Phone: [phone] Fax: [phone]

3EDROCK INJECTION
CONSTRUCTION DIAGRAM
4—INCH THICK
3' X 3' CONCRETE PAD
GROUND SURFACE
CEMENT GROUT
TOP OF BEDROCK
(VARIABLE DEPTH)
APPROXIMATELY 2—FEET OF PEA GRAVEL
#3 STONE
(VARIABLE THICKNESS)
GROUNDWATER LEVEL
10—INCH AIR —HAMMERED
BOREHOLE
FLUSH MOUNT STEEL
WELL COVER
COMPRESSION
WELL CAP
— BENTONITE SEAL
(VARIABLE THICKNESS)
6—INCH ID PVC RISER
TOP OF BEDROCK
APPROXIMATELY 3 FEET I
TOTAL DEPTH
OF BORING
(VARIABLE DEPTH)
2000 1000 0 2000 4000
APPROXIMATE SCALE IN FEET
JOB NO- J18-1022-50 B U N N E L L FIGURE
III111111 LAMMONB; BEDROCK INJECTION WELL DIAGRAM
DAM 08-27-18 M ENOINEEiliG FORMER ANDREX INDUSTRIES
60114 Ponders Court, Greenville, SC 29615 ASHEVILLE, NORTH CAROLINA I W-B
NOT TO SCALE Phone: (854] 288-1265 Fox (8641288-4430

J
Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL
TO: Underground Injection Control Program
NC Division of Water Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
ATTENTION: Mr. Michael Rogers, P.G.
CC:
DATE: November 12, 2018
RE: Modified Figure 2
Application for UIC Permit Renewal with Modification
Former Andrei Industries Corp.
UIC Permit No. W10100106
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
❑ Report ❑ Prints ❑ Change order ❑ Letter
® Figure ❑ W.A.S. ❑ Plans ❑ Samples
❑ Proposal ❑ Preliminary Data:
THESE ARE TRANSMITTED AS CHECKED BELOW:
® For approval ❑ For your use ® As requested ❑ Other
Number of copies: l (one)
REMARKS: Michael,
❑ Application
❑ Specifications
❑ For project records
Modified Figure 2 per your telephone request on 11-9-2018 is enclosed.
a4./ aL144�
Andrew W. AleiiCnder, P.G. RSM
Senior Hydrogeologist
s:\02 awa projects\andrex milkco\phase50 monitoring 2018\permit renewal application 2018\transmittal 2018 uic permit renewal
andrex - fig 2 revised.docx
i?F���p�CDRQ/DwR
NOV 192018
VvclRegiona D , �uadty
�Perations Section

Rogers, Michael
From: Moore, Andrew W
Sent: Thursday, November 8, 2018 8:23 AM
To: Rogers, Michael
Subject: RE: [External] Andrex UIC Permit Renewal Application
Michael,
The response and the attached Table address my comments regarding permit renewal.
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Andy Alexander <[e-mail]>
Sent: Wednesday, November 07, 2018 4:28 PM
To: Moore, Andrew W <[e-mail]>
Cc: Rogers, Michael <[e-mail]>
Subject: RE: [External] Andrex UIC Permit Renewal Application
Hello Andrew,
Thanks for your call today. I have attached a revised Table 6 which shows monitoring
for injections (if performed) into RW-1 and RW-5.
If IW-10 is installed it will be top of rock (above rock) and will bracket the same strata
as MW-44. There is sufficient contaminated groundwater above rock there to
target. Please refer to Figure IW-A in the application for a conceptual injection well
diagram.
Thanks again, --Andy
1

Andrew W. Alexander,, P.G., RSM
Senior Hydrogeologist
't, HUNNELL
LAMMONS
ElfamEIIN.IN6
T: 864.288.1265 1 M: 864.201.5530
BLECORP.com I LinkedIn I Facebook
6004 Ponders Court I Greenville, SC 29615
Andrew W. Alexander is a licensed professional geologist in SC, NC, GA, AL, MS, LA, FL, TN, IN and a registered site manager in NC.
This electronic transmission contains.information from the sender (Bunnell Lammons Engineering, Inc.).,that maybe confidential or
privileged. The information is intended solely for the recipient. 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
contact the sender immediately and delete this message.
From: Moore, Andrew W <[e-mail]>
Sent: Wednesday, November 07, 2018 3:35 PM
To: Andy Alexander <[e-mail]>
Cc: Rogers, Michael <[e-mail]>
Subject: RE: [External] Andrex UIC Permit Renewal Application
Andy,
Thank you for sending the permit renewal. I've reviewed the application and have the following questions/comments:
1. Table 2 of the permit renewal indicates injections are planned in wells RW-1 and RW-5 during the renewal years
(2019-2023) if budget and milk solution allow. However, these injection points are not included on Table 6
(Injection Monitoring Plan). Is there an injection monitoring plan for these wells? If so, please provide a revised
Table 6 which includes these injection points.
2. MW-44 is listed as the only monitoring station for proposed injection well IW-10. It's not clear if MW-44 will be
an appropriate monitoring station for IW-10 as it is not clear what zone (above rock or bedrock) IW-10 will be
installed per Section IX.6) of the application. Please confirm that IW-10 will be installed as above rock injection
well or explain how MW-44 would be an appropriate monitoring point for a bedrock injection well.
Thank you and feel free to contact me if you have any questions.
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: And rew.W. Moore(a)-ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Andy Alexander <[e-mail]>
Sent: Friday, September 14, 2018 10:23 AM

To: Moore, Andrew W <[e-mail]>; Wahl, Tracy <tracy.wahl(@ncdenr.gov>
Subject: [External] Andrex UIC Permit Renewal Application
Hello Andrew and Tracy,
I have attached PDF copies of the subject document and a transmittal letter for your
records. Hard copies have been sent to Michael Rogers as required for the renewal.
Thanks, --Andy
Andrew W. Alexander, P.G., RSM
Senior Hydrogeologist
It 1 1' BMMONS
CANNONS �
ENGINE[SINB
T: 864.288.1265 1 M: 864.201.5530
BLECORP.com I LinkedIn I Facebook
6004 Ponders Court I Greenville, SC 29615
Andrew W. Alexander is a licensed professional geologist in SC, NC, GA, AL, MS, LA, FL, TN, IN and a registered site manager in NC.
This electronic transmission contains information from the sender (Bunnell Lammons Engineering, Inc.) that may be confidential or
privileged. The information is intended solely for the recipient. 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
contact the sender immediately and delete this message.
3

NORTH CAROLINA
ROY COOPER, Environmental Quality
Covrrnar
MICHAEL S. REGAN
S"-gary
UNDA CULPEPPER
tntertin Dlreaw
September 28, 2018
Mr. Keith Collins, President
Milkco, Inc.
P.O. Box 16160
Asheville, NC 28816
RE: Acknowledgement of Application No. WI0100106
Former Andrex Industries Corp.
In -Situ Groundwater Remediation Well System
Buncombe County
Dear Mr. Collins:
The Water Quality Regional Operations Section (WQROS) acknowledges receipt of your
permit application on September 18, 2018. Your application package has been assigned the number
listed above, and the primary reviewer is Michael Rogers.
Central and Asheville Regional Office staff will perform a detailed review of the provided
application, and may contact you with a request for additional information. To ensure maximum
efficiency in processing permit applications, the Water Quality Regional Operations Section
(WQROS) requests your assistance in providing a timely and complete response to any additional
information requests.
Please note that processing standard review permit applications may take as long as 60 to
90 days after receipt of a complete application. If you have any questions, please contact Michael
Rogers at 919-707-3668 or [e-mail].
Sincerely,
For Debra J. Watts, Supervisor
(� Or Animal Feeding Operations & Groundwater
Protection Branch
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources IAFOGW Section
512 North Salisbury Street 11636 Mail Service Center I Raleigh, North Carolina 27699-1636
919.707.9129

cc: Andrew Alexander, PG, Bunnell-Lammons Engineering, Inc., 6004 Ponders Court,
Greenville, SC 29615
Asheville Regional Office, WQROS
Permit File WI0100106

Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL RECEIVEDUDEQ/ W1,
TO: Underground Injection Control Program S E P i 8 2018
NC Division of Water Resources Water Quality Regional
1636 Mail Service Center Operations Section
Raleigh, North Carolina 27699-1636
ATTENTION: Mr. Michael Rogers, P.G. — 2 Copies w/ CD
CC: Mr. Keith Collins — Milkco, Inc. — PDF via Email
Ms. Tracy Wahl — NCDEQ—Brownfields — PDF via Email
Mr. Stephen Gottdiener — Andrex —1 Copy w/ CD
Mr. Andrew Moore, P.G. — NCDEQ (ARO)—DWR — PDF via Email
DATE: September 14, 2018
RE: Application for UIC Permit Renewal with Modification
Former Andrex Industries Corp.
UIC Permit No. WI0100106
WE ARE SENDING YOU:
E Attached ❑ Under separate cover via: U.S. MAIL
❑ Report ❑ 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 requested ❑ Other
Number of copies: As specified above.
REMARKS: Michael,
Copies of the subject document are transmitted as shown.
® Application
❑ Specifications
❑ For project records
&&/ d4ZA4�
Andrew W. Alexinder, P.G. RSM
Senior Hydrogeologist
sA02 awa projects\andrex milkco\phase50 monitoring 2018\permit renewal application 2018\transmittal 2018 uic permit renewal
andrex.docx

Michael
From: Moore, Andrew W
Sent: Wednesday, April 01, 2015 3:57 PM
To: Andrew W. Alexander; Rogers, Michael; Davidson, Landon
Cc: Nisbeth, Ben (blecorp)
Subject: RE:=UI-C=P rm r01i004106-Notice of Injection April 6, 2016 - Milkco/Andrex
We have received you notification.
Thanks Andy.
Andrew W. Moore, P.G.—[e-mail]
North Carolina Dept. of Environment and Natural Resources
Division of Water Resources — Water Quality Regional Operations Section
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
From: Andrew W. Alexander rmailto:andy(ftlecorp.com]
Sent: Wednesday, April 01, 2015 3:48 PM
To: Rogers, Michael; Davidson, Landon; Moore, Andrew W
Cc: Nisbeth, Ben (blecorp)
Subject: UIC Permit WI0100106- Notice of Injection April 6, 2016 - Milkco/Andrex
Hello Michael, Andrew, and Landon,
This email is_ notice of intent to inject milk.solution into injection wells IWA and IW-3 at
the former Andrex property (UIC Permit WI0100106) beginning April 6, 2015.
Injection will be performed in accordance with the Permit and the DENR approved
2015 Injection Plan. An Injection Event Record will be prepared and submitted as
required after the injection event is complete.
Actual start date and time will be dependent upon milk solution availability and
weather. DENR inquiry into the up to date project schedule should be made via.
telephone to Ben Nisbeth of BLE at 8287545-3414. It's anticipated that up to 2 weeks
will be required to complete the injection event.
This detailed email notice is made as a substitute for the verbal notice specified in the
permit. If this email notice is not sufficient, please contact me and verbal notice will be
provided.
1

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)
andySaD-blecorp.com
www.blecorp.com
This electronic transmission contains information from the consulting fine 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 ([e-mail]). Thank you for your cooperation.
2

Rogers, Michael
From: Andrew W. Alexander [[e-mail]]
Sent: Wednesday, March 11, 2015 11:28 AM
To: Davidson, Landon; Moore, Andrew W; Rogers, Michael
Cc: Nisbeth, Ben (blecorp); Collins, Keith (Milkco), Roger Noel; Taylor, Sherry (BLE); Horner, John
(blecorp)
Subject: UIC Permit W10100106 Notice of Injection Well Installation
Hello Michael, Andrew, and Landon,
This email is notice of intent to install injection wells IW-1 and IW-3 at the former
Andrex property (UIC Permit W10100106) during the week of March 16, 2015.
Installations will be performed in accordance with the Permit and the DENR approved
2015 Injection Plan.
Actual start date and time will be dependent upon drill rig and crew availability and
weather. DENR inquiry into the up to date project schedule should be made via
telephone to Ben Nisbeth of BLE at 828-545-3414. It's anticipated that up to 4 days
will be required to complete the work. If project delays occur we anticipate that the well
installation project will be complete no later than March 27, 2015.
This detailed email notice is made as a substitute for the verbal notice specified in the
permit. If this email notice is not sufficient, please contact me and verbal notice will be
provided.
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)
andy6a�blecorp.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.
1

Rogers, Michael
From: Andrew W. Alexander [[e-mail]]
Sent: Tuesday, January 06, 2015 2:40 PM
To: Moore, Andrew W; Davidson, Landon; Rogers, Michael
Cc: Nisbeth, Ben (blecorp); Wahl, Tracy; Collins, Keith (Milkco)
Subject: RE: Andrex 2015 Injection Plan
Hello Everybody,
Just a follow up. Hard copies were mailed to Rogers, Collins, and Wahl on December
30th (the rest of you just have your PDF copy in email).
Last time I mailed something to Michael Rogers it ended up in the DENR Mooresville
office. So Michael let me know when/if you get your copies.
Thanks and please contact me with comments or questions. --Andy
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Monday, December 22, 2014 3:34 PM
To: Moore, Andrew W; Davidson, Landon; Rogers, Michael'
Cc: Nisbeth, Ben (blecorp); Wahl, Tracy (NCDWM); Collins, Keith (Milkco)
Subject: Andrex 2015 Injection Plan
Hello Team Milk Solution,
I have attached a transmittal letter and the 2015 injection plan for the former Andrex
facility as we discussed in last week's emails. I'll mail hard copies as shown on the
-_._transmittal letter unless someone requires something different. Might be next Monday
-before this gets mailed since everybody is on vacation this week. So let me know
before then, especially if you don't want a hard copy!
After NCDENR provides review and comment, Keith (Milkco) and I will get together and
work out the details -for 2015.
'I hope everyone has a safe a joyous holiday. M0000, --Andy
Andrw:N.-Alexander, P.G., F�SM
...Biirtrtt_aons-Erfgineering, Inc. (BLE)
6004 Pdhddrs-court
[phone] (voice.).
[phone]-(fax)4
�Rd f7 �CQr?:COfYlS
VVIlt11N li�COTA 6Qrm --
'` As _

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(&blecoro.com). Thank you for your cooperation.

Rogers, Michael
From: Moore, Andrew W
Sent: Tuesday, December 30, 2014 10:52 AM
To: Davidson, Landon; Rogers, Michael
Subject: RE: Andrex 2015 Injection Plan
Landon and Michael,
took a look at the 2015 Injection Plan and compared it to the UIC Permit Renewal Application dated July 30, 2013; the
Addendum to UIC Permit Application dated November 19, 2013; and Injection Permit W10100106 dated December 13,
2013.
I noted the following proposed changes:
• Injection well IW-1 proposed location was moved approximately 100 feet to the southeast;
• Injection well IW-3 proposed location was moved approximately 125 feet to the southwest;
• MW-3R was removed from the list of monitoring locations for IW-3;
• IW-2, RW-1, MW-6, and MW-44 were added to the list of monitoring locations for IW-3;
• IW-1 is still proposed to be screened in the upper bedrock, but the proposed screen length is shortened.
It was not specified why BLE proposes moving the locations of injection wells IW-1 and IW-3. It appears that IW-3 was
moved closer to the area of IW-2 (screened in bedrock) to target the regolith/tz.
Based on the Groundwater Elevation Contour Map included with the permit application, it appears that MW-3R
(originally proposed to be installed in Year 1, but never installed) is located upgradient of the new proposed location of
IW-3, which is likely the reason BLE proposes removing it from the monitoring list. RW-1, MW-6, and MW-44 appear to
be downgradient of the proposed IW-3 location, and appropriate monitoring locations to detect the movement of
injection fluids and/or injection byproducts from IW-3.
I don't have any concerns with the proposed changes.
Michael, feel free to contact Landon or myself if you would like to discuss further.
Andrew W. Moore, P.G.—[e-mail]
North Carolina Dept. of Environment and Natural Resources
Division of Water Resources — Water Quality Regional Operations Section
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed t4o third parties.
x- I

From: Andrew W. Alexander [mailto':andvCabblecorp.com]
Sent: Monday, December 22, 2014 3:34 PM
To: Moore, Andrew W; Davidson, Landon; Rogers, Michael
Cc: Nisbeth, Ben (blecorp); Wahl, Tracy; Collins, Keith (Milkco)
Subject: Andrex 2015 Injection Plan
Hello Team Milk Solution,
I have attached a transmittal letter and the 2015 injection plan for the former Andrex
facility as we discussed in last week's emails. I'll mail hard copies as shown on the
transmittal letter unless someone requires something different. Might be next Monday
before this gets' mailed since everybody is on vacation this week. So let me know
before then, especially if you don't want a hard copy!
After NCDENR provides review and comment, Keith (Milkco) and I will get together and
work out the details for 2015.
I hope everyone has a safe a joyous holiday. M0000, --Andy

rs, Michael
From: Andrew W. Alexander [[e-mail]]
Sent: Monday, June 23, 2014 9:54 AM
To: Rogers, Michael
Cc: Moore, Andrew W; Davidson, Landon; Gottdiener, Stephen (Andrex); Collins, Keith (Milkco);
Nisbeth, Ben (blecorp)
Subject: IER Andrex/Milkco Permit No. W10100106
Attachments: 1022-38 Andrex Injection NCDENR Event Record 2014.pdf
Hello Michael,
I have attached the Injection Event Record for injection into IW-2 at the former Andrex
facility [Injection Permit No. W10100106 (Milkco, Inc.)].
A hard copy will not be mailed unless requested. 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)
andyCcD-blecorp.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(CD-blecorp.com). Thank you for your cooperation.
1

1- .JECTION EVENT REC01-1
North Carolina Department of Environment and Natural Resources — Division of Water Resources
Permit Number WT 01 bo ID&
1. Permit Information
ftw
Permittee
?"mye &q fAJA""$ Cote. Fo+lilil9
Facility Name
M puu visa Rd NS�ILV1�� t1(, Z�iQao
Facility Address
2. Injection Contractor Information
&n,iA " kAmMOAS ginttX�/l4.
Injection Contractor / Comp ny Nam
Street Address (pOD4 OAAtxs COL44
(auymyiu Sc, 29e l s
City State Zip Code
(&+) 'M - 12(05
Area code — Phone number
3. Well Information
Number of wells used for injection
Well names 10 2-
Were any new wells installed during this injection
event?
x Yes ❑ No
If yes, please provide the following information:
Number of Monitoring Wells
Number of Injection Wells
Type of Well Installed (Check applicable type):
❑ Bored © Drilled ❑ Direct -Push
❑ Hand -Augured ❑ Other (specify)
Please include a copy of the GW-I form for each
��++ well installed.
' CIIAI' 1Dt^^j WUt. 64'. m Ptio� �p IA�G�17'n
Were any wells abandoned during this injection
event?
❑ Yes ®. No
If yes, please provide the following information:
Number of Monitoring Wells
Number of Injection Wells
Please include a copy of the GW-30 for each well
abandoned.
4. Injectant Information
Ito Mik 7oIN �IOi1
Injectant Type
0
Concentration a
If the injectant is diluted please indicate the source
dilution fluid. 00.�'GtP
Total Volume Injected 2-+ , 000 15JQAS
Volume Injected per well Z4 000_
5. Injection History Injection date(s) 5 - Z014 A(K (o •OZ• U+
Injection number (e.g. 3 of 5) -4,+
Is this the last injection at this site?
❑ Yes �R No
I DO HEREBY CERTIFY THAT ALL THE
INFORMATION ON THIS FORM IS CORRECT TO
THE BEST OF MY KNOWLEDGE AND THAT THE
INJECTION WAS PERFORMED WITHIN THE
STANDARDS LAID OUT IN THE PERMIT.
• Zo Zol �-
I OF fNJECTION CONTRACTOR DATE
?->e,11�01VAvA V ►I b .
PRINT NAME OF PERSON PERFORMING THE INJECTION
Submit the original of this form to the Division of Water Resources within 30 days of injection. Form UIC-IER
Attn: UIC Program, 1636 Mail Service Center, Raleigh, NC 27699-1636, Phone No. 919-807-6464 Rev. 8/5/2013

Rogers, Michael
From: Rogers, Michael
Sent: Wednesday, November 20, 2013 2:05 PM
To: 'Andrew W. Alexander
Subject: FW: W10100106 Milkco, Inc. Permit Renewal Additional Information Request
Andy -
Just wondering where you were on sending in some revised site maps w/injection zones
delineated.
O
Thanks
From: Rogers, Michael
Sent: Wednesday, October 23, 2013 10:28 AM
To: 'Andrew W. Alexander'
Cc: Davidson, Landon; Watts, Debra
Subject: RE: WI0100106 Milkco, Inc. Permit Renewal Additional Information Request
Andrew -
Could we arrange a conference call this afternoon. Any time after 1:00 PM is OK. Let me
know what time works for you. Thanks.
From: Andrew W. Alexander [mailto:andy(ablecorp.com]
Sent: Wednesday, October 23, 2013 7:18 AM
To: Rogers, Michael
Cc: Davidson, Landon; Watts, Debra
Subject: RE: WI0100106 Milkco, Inc. Permit Renewal Additional Information Request
Michael,
Thanks for talking to me yesterday. As we discussed I will be able to provide a map showing the
injection zones and one profile through several injection wells and the plume which will also show
injection zones.
As for the this issue of DWR acceptable locations of monitoring wells outside --of the injection zones,
we will need to resolve that issue. Per your recommendation,- I'll call Debra (today 10-23-13) to get
her opinion.
Debra, if you could let me know if a particular time works for you it would be helpful. I am in all day
today. --Andy
From: Rogers, Michael[mailto:michael.rogers(aIncdenr.gov]
Sent: Thursday, October 17i 2013 3:42 PM
To: Andrew W. Alexander

Cc: Davidson, Landon; Watts, Debr
Subject: RE: WI0100106 Milkco, Inc. Permit Renewal Additional Information Request
Andy -
After permit review, the horizontal and vertical extent of the injection zone is not clearly
shown in the application. Per 15A NCAC 2C .0225(e)(2), the injection zone must be shown
along with a monitoring plan, which would indicate any violations of groundwater quality
outside the injection zone due to injection activities.
To continue the renewal process, please provide map(s) indicating the extent of the injection
zone and a monitoring plan which will detect any violations outside the zone. I will be out of
the office from Friday through Monday. If you have any questions/comments that cannot wait
until I return, please contact Debra Watts at the email above or at 919-807-6338.
Thanks
From: Andrew W. Alexander fmailto:[e-mail]]
Sent: Monday, August 26, 2013 3:12 PM
To: Rogers, Michael
Cc: Davidson, Landon
Subject: RE: WI0100106 Milkco, Inc. Permit Renewal Additional Information Request
Hello Michael,
Please call me Andy. As we discussed via telephone, I am providing answers to your
questions/comments via email. If you feel that further explanation or documentation for anything is
required, please ask and I will send it to you.
item 1 — Injection Well Design) The groundwater present in the soil, PWR, and bedrock aquifers is
equally contaminated by chlorinated solvents. There are no differences in water quality currently
observed between these units or that would result from the installation or operation of the injections
wells as designed. The injection wells are designed to treat the affected groundwater across all 3
units since they do not act as discrete aquifers. Additionally, several of the recovery wells which were
formerly utilized as injection wells (per the approved permit — including RW-3) also bracket multiple
zones.
Item 2 — Injection Volumes) The proposed injection volumes of 25,000 gallons per well are based on
the same assumptions in the prior permit applications. They include a treatment area of about 68,000
cubic feet per well which is equivalent to 3,400 cubic feet (25,0.00 gallons) of injectant to achieve a
5% by volume solution at 50 feet radius per well. This is a similar volume approved for injection in
RW-3 during the 3�d injection event. Please see the injection Event Record for more information.
Based on the data in the Interim Evaluation Report it appears that the plume was not displaced by
the prior injections, rather the affected groundwater was remediated as the organic carbon (milk
solution) was introduced into the subsurface.

Rog+ers,'iVlichael
From: Rogers, Michael
Sent: Thursday, October 17, 2013.3:42 PM
To: 'Andrew W. Alexander'
Cc: Davidson, Landon; Watts, Debra
Subject: RE: W10100106 Milkco, Inc. Permit Renewal Additional Information Request
Andy -
After permit review, the horizontal and vertical extent of the injection zone is not clearly
shown in the application. Per 15A NCAC 2C .0225(e)(2), the injection zone must be shown
along with a monitoring plan, which would indicate any violations of groundwater quality
outside the injection zone due to injection activities.
To continue the renewal process, please provide map(s) indicating the extent of the injection
zone and a monitoring plan which will detect any violations outside the zone. I will be out of
the office from Friday through Monday. If you have any questions/comments that cannot wait
until I return, please contact Debra Watts at the email above or at 919-807-6338.
Thanks
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Monday, August 26, 2013 3:12 PM
To: Rogers, Michael
Cc: Davidson, Landon
Subject: RE: WI0100106 Milkco, Inc. Permit Renewal Additional Information Request
Hello Michael,
Please call me Andy. As we discussed via telephone, I am providing answers to your
questions/comments via email. If you feel that further explanation or documentation for anything is
required, please ask and I will send it to you.
Item 1 — Injection Well Design) The groundwater present in the soil, PWR, and bedrock aquifers is
equally contaminated by chlorinated solvents. There are no differences in water quality currently
observed between these units or that would result from the installation or operation of the injections
wells as designed. The injection wells are designed to treat.the affected groundwater across all 3
units since they do not act as discrete aquifers. Additionally, several of the recovery wells which were
formerly utilized as injection wells (per the approved permit — including RW-3) also bracket multiple
zones.
Item 2 — Injection Volumes) The proposed injection volumes of 25,000 gallons per well are based on
the same assumptions in the prior permit applications. They include a treatment area of about 68,000
cubic feet per well which is equivalent to 3,400 cubic feet (25,000 gallons) of injectant to achieve a

5% by volume solution at 50 f"-radius per well. This is a similar me approved for injection in
RW-3 during the 3rd injection event. Please see the injection Event Record for more information:
Based on the data in -the Interim Evaluation Report it appears that the plume was not displaced by
the prior injections, rather the affected groundwater was remediated as the organic carbon (milk
solution) was introduced into the subsurface.
Thanks for your help on this project and please contact me if you need anything else. —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(cD-blecorp.com
www.blecbrp.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 Qnfo(afblecorp.com). Thank you for your cooperation.
From: Rogers, Michael[mailto:[e-mail]]
Sent: Thursday, August 15, 2013 5:01 PM
To: andy(a)blecorp.com
Cc: Davidson, Landon -
Subject: WI0100106 Milkco, Inc. Permit Renewal Additional Information Request
Andrew -
I did a preliminary review of the above permit renewal application. I have. the following questions/comments:
The -proposed well design as presented in Figure 1 allows for the --commingling of separate aquifers (i.e.,
saprolite, PWR, and bedrock). The proposed well design is approximately 80 feet deep and only has 10 feet of
casing. This design is essentially an open hole allowing for a conduit between all of the aquifers. Per NCAC 2C
.0225(g)(19)(D), packing material shall be "emplaced such that it shall not connect aquifers or,zones having
differences in water quality that would result in the deterioration of the water -qualities in any aquifer or zone".
The previous injection wells, and the existing well RW-3, which is proposed for injection, have well construction
allowing injection in targeted, separate aquifers.
• Please..provide data/calculations that 25,000 gallons proposed to be injected into each well is the optimum and
will not result in any displacement or'pushing' of the plume.
Thank you for your cooperation.
Michael Rogers, P.G. (NC & FL)
Hyd rogeologist

NCDENR - DWR
1636 Mail Service Center
Raleigh, NC 27699
Direct No. 919-807-6406
NCDENR - DWQ APS GPU Reporting Forms
NOTE: Per Executive Order No. 150, all e-mails sent to and frc
Records Law and maybe disclosed to third parties.
0

Rogers, Michael
i
From:
Moore, Andrew W
Sent:
Friday, September 27, 2013 4:54 PM
To:
Rogers, Michael
Cc:
Davidson, Landon
Subject:
%' FW: UIC diagrams
Attachments:
/! INJECTION ABOVE BEDROCK WELL DIAGRAM.pdf; INJECTION BEDROCK WELL1
DIAGRAM.pdf
Michael,
C
Please find attached the revised injection well construction diagrams.for the former Andrex facility (W10100106). The
regional staff report will go out with the courier on Monday.
Andrew W. Moore, P.G.—[e-mail]
North Carolina Dept. of Environment and Natural Resources
Division of Water Resources — Water Quality Section
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
From: Andrew W. Alexander fmailto:andy(ablecorp.com]
Sent: Friday, September 27, 2013 7:55 AM
To: Davidson, Landon
Cc: Moore, Andrew W
Subject: RE: UIC diagrams
Prior email bounced. Trying again. --Andy
From: Andrew W. Alexander fmailto:andy(d)blecorp.com]
Sent: Friday, September 27, 2013 7:49 AM
To: 'Davidson, Landon'
Cc: 'Moore, Andrew W'
Subject: RE: UIC diagrams
I have attached both revised diagrams. Thanks again for your help. Please let me know if you need
anything else.. Happy Friday, --Andy
From: Davidson, Landon[mailto:landon.davidson(5)ncdenr.govI
Sent: Thursday, September 26, 2013 11:08 AM
To: Andrew W. Alexander
Cc: Moore, Andrew W
Subject: RE: UIC diagrams

r-
Thanks, we'll look for it then. - --'
Landon
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Section
Regional Supervisor - Asheville Regional Office
2090 U.S.. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.org
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law
and may be disclosed to third parties.
From: Andrew W. Alexander fmailto:andy(dblecorp.com]
Sent: Thursday, September 26, 2013 11:01 AM
To: Davidson, Landon
Subject: RE: UIC diagrams
Will have the revised diagrams to you guys on Friday AM. Thanks again, --Andy
From: Davidson, Landon fmailto:[e-mail]
Sent: Thursday, September 26, 2013 10:38 AM
To: Andrew W. Alexander (andy(a)blecorp.com)
Subject: UIC diagrams
Attached. We'll call in five minutes. Thanks.
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Section
Regional Supervisor -Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.ork
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law
and may be disclosed to third parties.
2

Rogers, Michael
From:
Andrew W. Alexander [[e-mail]]
Sent:
Tuesday, September 17, 2013 1:53 PM
To:
Moore, Andrew W; Davidson, Landon
Cc:
Rogers, Michael
Subject:
RE: Former Andrex Industries UIC Permit Renewal
Attachments:
TYPICAL INJECTION WELL DIAGRAMFM REV.pdf
Gents,
Based on our teleconference today I have revised the proposed injection well construction diagram
(attached). It now reflects two possible conditions; water below bedrock and water above bedrock.
If you find this revision acceptable, please replace the diagram in the application with this revision. If
not.acceptable, please contact me so we can discuss. --Andy
From: Moore, Andrew W[mailto:andrew.w.moore(dncdenr.gov]
Sent: Tuesday, September 17, 2013 10:57 AM
To: Davidson, Landon; Andrew W. Alexander
Cc: Rogers, Michael
Subject: RE: Former Andrex Industries UIC Permit Renewal
I am available at 11:30. Will that work for you Andy?
Andrew
From: Davidson, Landon
Sent: Tuesday, September 17, 2013 10:56 AM
To: Andrew W. Alexander; Moore, Andrew W
Cc: Rogers, Michael
Subject: RE: Former Andrex Industries UIC Permit Renewal
I'm good with 11:30 today.
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.org
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law
and may be disclosed to third parties.
From: Andrew W. Alexander [mailto:andy(cbblecorp.com]
Sent: Tuesday, September 17, 2013 10:56 AM
To: Moore, Andrew W

Cc: Davidson, Landon; Rogers, Mid -
Subject: RE: Former Andrex Industries UIC Permit Renewal
Andrew,
will be out of town and on vacation from Wednesday to Friday (181h to 20th). The following week I
am currently available any day except Wednesday (25th) or Friday (27th)
am typically in the office from 7:00 AM to 4:30 PM each day.
am available all day today, or next week as specified.
Any of my available dates work for you guys? --Andy
From: Moore, Andrew W[mailto:andrew.w.mooreCabncdenr.gov]
Sent: Tuesday, September 17, 2013 10:27 AM
To: Andy(5)blecorp.com
Cc: Davidson, Landon; Rogers, Michael
Subject: Former Andrex Industries UIC Permit Renewal
Andy,
I met with Ben Nisbeth last week at Milkco for the facility site inspection. Thanks for the help setting that up.
In reviewing your UIC permit renewal application, we have some concerns regarding your proposed injection well
construction. Would you be willing, and are you able, to attend a conference call with Landon Davidson and myself to
discuss your proposed injection well construction? .
If so, I'd like to propose Thursday afternoon at 4:00 for the call. Let me know if this time works for you.
Thanks,
Andrew W. Moore, P.G.—[e-mail]
North Carolina Dept. of Environment and Natural Resources
Division of Water Resources — Water Quality Section
Asheville Regional Office
_ ' 2090 _U.S. 70 Highway - - - - - - - - - ---
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
2

1
Rogers, Michael
From: Andrew W. Alexander [[e-mail]]
Sent: Monday, August 26, 2013 3:12 PM
To: Rogers, Michael
Cc: Da,s�onLndo�,n ry�
Subject: RE 1NI0'1'00"I°06 Mllkco, Inc. Permit Renewal Additional Information Request
Hello Michael,
Please call me Andy. As we discussed via telephone, I am providing answers to your
questions/comments via email. If you feel that further explanation or documentation for anything is
required, please ask and I will send it to you.
Item 1 — Injection Well Design) The groundwater present in the soil, PWR, and bedrock aquifers is
equally contaminated by chlorinated solvents. There are no differences in water quality currently
observed between these units or that would result from the installation or operation of the injections
wells as designed. The injection wells are designed to treat the affected groundwater across all 3
units since they do not act as discrete aquifers. Additionally, several of the recovery wells which were
formerly utilized as injection wells (per the approved permit — including RW-3) also bracket multiple
zones.
Item 2 — Injection Volumes) The proposed injection volumes of 25,000 gallons per well are based on
the same assumptions in the prior permit applications. They include a treatment area of about 68,000
cubic feet per well which is equivalent to 3,400 cubic feet (25,000 gallons) of injectant to achieve a
5% by volume solution at 50 feet radius per well. This is a similar volume approved for injection in
RW-3 during the 3rd injection event. Please see the injection Event Record for more information.
Based on the data in the Interim Evaluation Report it appears that the plume was not displaced by
the prior injections, rather the affected groundwater was remediated as the organic carbon (milk
solution) was introduced into the subsurface.
Thanks for your help on this project and please contact me if you need anything else. —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)
andyCaD_blecorp:com
www.blecorp.com
KLIS
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 (infoe-blecora.com). Thank you for your cooperation.

From: Rogers, Michael [mailto:michae .rogers(a)ncdenr.gov]
Sent: Thursday, August 15, 2013 5:01 PM
To: andy blecorp.com
Cc: Davidson, Landon
Subject: WI0100106 Milkco, Inc. Permit Renewal Additional Information Request
Andrew -
I did a preliminary review of the above permit renewal application. I have the following questions/comments:
The proposed well design as presented in Figure 1 allows for the commingling of separate aquifers (i.e.,
saprolite, PWR, and bedrock). The proposed well design is approximately 80 feet deep and only has 10 feet of
casing. This design is essentially an open hole allowing for a conduit between all of the aquifers. Per NCAC 2C
.0225(g)(19)(D), packing material shall be "emplaced such that it shall not connect aquifers or zones having
differences in water quality that would result in the deterioration of the water qualities in any aquifer or zone".
The previous injection wells, and the existing well RW-3, which is proposed for injection, have well construction
allowing injection in targeted, separate aquifers.
• Please provide data/calculations that 25,000 gallons proposed to be injected into each well is the optimum and
will not result in any displacement or'pushing' of the plume.
Thank you for your cooperation.
Michael Rogers, P.G. (NC & FL)
Hydrogeologist
NCDENR - DWR
1636 Mail Service Center
Raleigh, NC 27699,_
Direct No. 919-807-6406
NCDENR - DWQ APS GPU Reporting Forms
NOTE: Per Executive Order No. 150, all a -mails sent to and from this account are subject to the North Carolina. Public
Records Law and may be disclosed to third parties.

Rogers, Michael
From: Andrew W. Alexander [[e-mail])
Sent: Thursday, August 15, 2013 8:52 PM U�
To: Rogers, Michael
Subject: Re: W10100106 Milkco, Inc. Permit Renewal Additional Information Request
Thanks for the quick feedback. III probably call you to talk about both of these issues. l LA- gim-s
Andy Alexander
[e-mail]
On Aug 15, 2013, at 5:01 PM, "Rogers, Michael" <[e-mail]> wrote:
Andrew -
I did a preliminary review of the above permit renewal application. I have the following
questions/comments:
The proposed well design as presented in Figure 1 allows for the commingling of separate
aquifers (i.e., saprolite, PWR, and bedrock). The proposed well design is approximately 80 feet
deep and only has 10 feet of casing. This design is essentially an open hole allowing for a
conduit between all of the aquifers. Per NCAC 2C .0225(g)(19)(D), packing material shall be
"emplaced such that it shall not connect aquifers or zones having differences in water quality
that would result in the deterioration of the water qualities in any aquifer or zone". The
previous injection wells, and the existing well RW-3, which is proposed for injection, have well
construction allowing injection in targeted, separate aquifers.
• Please provide data/calculations that 25,000 gallons proposed to be injected into each well is
the optimum and will not result in any displacement or `pushing' of the plume.
Thank you for your cooperation.
Michael Rogers, P.G. (NC & FL)
Hydrogeologist
NCDENR - DWR
1636 Mail Service Center
Raleigh, NC 27699
Direct No. 919-807-6406
NCDENR - DWQ APS GPU Reporting Forms
NOTE: Per Executive Order No. 150, all e-mails sent to and from this account are subject to the North
Carolina Public Records Law and may be disclosed to third parties.

AV14
FAA
NCDENR
North Carolina Department of Environment.and Natura
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder
Governor Director
August 9, 2013
Mr. Keith Collins — President
Milkco, Inc.
P.O. Box 16160
Asheville, NC 28816
Dear Mr. Collins:
Resources
John E. Skvarla, III
Secretary
Subject: Acknowledgement of
Application No. WI0100106
Former Andrex Industries Corp
Facility
Injection In situ Groundwater
Remediation Well System
Buncombe County
The Aquifer Protection Section acknowledges receipt of your permit application and supporting
documentation received on 08/06/2013. Your application package has been assigned the number listed
above, and the primary reviewer is Michael Rogers.
Central and Asheville Regional Office staff will perform a detailed review of the provided
application, and may contact you with a request for additional information. To ensure maximum.
efficiency. in processing permit applications, the Aquifer. Protection Section requests your assistance in
providing a timely and complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt Qf a complete application. , If you have any gytestions, please contact q
Michael Rogers at [phone] or [e-mail]. 1.
incerely,
for Debra . Watts
Groundwater Protection Unit Supervisor
cc: Asheville Regional Office, Aquifer Protection Section
Andrew W. Alexander, PG, RSM — Bunnell-Lammons Engineering, Inc. (BLE), 6004 Ponders
Court, Greenville, SC 29615
Perinit_File WIQ100106L,,
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Salisbury St., Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] NorthCaroli..tla
Internet: hdp:lloortal.nedenr.oralweb/wq/aps
An Equal Opportunity 1 Affirmative Action Employer
NatlrrallY

,RL13
BUNNELL-LAMMONS ENGINEERING, INC.
GEOTECHNICAL, ENVIRONMENTAL AND CONSTRUCTION MATERIALS CONSULTANTS
July 30, 2013
Underground Injection Control Program
DWQ - Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
Attention: Mr. Thomas Slusser, L.G.
Program Manager
Subject: UIC Permit Application (UIC-5I/5T)
Permit Renewal with Modification
UIC Permit No. WI0100106
Former Andrex Industries Facility
180 Deaverview Road
Asheville, North Carolina
BLE Project Number J12-1022-35
Groundwater Incident Number 6586
Brownfields Project Number 07022-03-11
Dear Mr. Slusser:
Bunnell-Lammons Engineering, Inc. (BLE) is pleased to submit documents for renewal of the UIC
permit at the subject site. As we discussed, the renewal includes modifications which primarily
consist of the addition of permanent injection wells. Additionally, this renewal includes only
information germane to the proposed modifications to the existing permit. Please refer to the
information previously submitted in the prior permit application for documentation of site history,
hydrogeologic conditions, and injectant information, etc.
As required by the existing permit, an Interim Evaluation Report of the prior injections and
monitoring results to date will be prepared and submitted under separate cover. Please note that an
updated groundwater elevation map and plume map are included in this application for reference.
RECEIVENENRIDWQ
Aquifer Protection Section
6004 PONDERS COURT
GREENVILLE, SOUTH CAROUNA 29615
PHONE [phone]
FAX [phone]

RECEIVEDIDENRIDW0
AUG 06M3
MILE Aquifer Pmtat+,,., a,
Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL
TO: Underground Injection Control Program
NC Division of Water Quality
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
ATTENTION: Mr. Thomas Slusser, LG — 2 Copies w/ CD
CC: Mr. Keith Collins — Milkco, Inc. —1 Copy w/ CD
Ms. Tracy Wahl — NCDENR--Brownfields -1 Copy w/ CD
Mr. Ben Nisbeth, PG — BLE Asheville - PDF via Email
Mr. Landon Davidson. PG — NCDENR--DWQ — PDF via Email
Mr. Mark Pinkston — Van Winkle — 2 Copies w/ CD
DATE: July 30, 2013
RE: Andrex Industries Corp.
Application for UIC Permit Renewal with Modification
UIC Permit No. WI0100106
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
❑ Report ❑ 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 requested ❑ Other
Number of copies: As specified above.
REMARKS: Thomas,
RECEIVED/ni`NR/OWQ
AU
Aquifer Protection Section
® Application
❑ Specifications
❑ For review and comment
As we discussed I have enclosed 2 copies of the subject document. The Interim Evaluation Report
will be mailed to your office by this Friday (August 2, 2013).
Andrew W. Ale nder, P.G.
Senior Hydrogeologist
c:\awa\active projects\andrex milkco\phase35 3rd injection and monitoring\1022-35 permit renewahtransmittal 2013 uic permit
renewal.doc

Rogers, Michael
From: Rogers, Michael
Sent: Thursday, December 17, 2015 11:50 AM
To: 'Andrew W. Alexander'; Moore, Andrew W
Cc: Davidson, Landon; 'Nisbeth, Ben (blecorp)'; 'Benton, Trevor (blecorp)'
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Also, email copies of the GW-1 and GW-30s (if applicable).
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Thursday, December 17, 2015 9:08 AM
To: Moore, Andrew W <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; 'Nisbeth, Ben (blecorp)' <[e-mail]>; 'Benton, Trevor
(blecorp)' <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Hello Andrew,
Thanks for your help and approval of the 2016 plan. We will comply with the
notification requirement. Thanks again, --Andy
From: Moore, Andrew W jmailto:[e-mail]]
Sent: Thursday, December 17, 2015 8:59 AM
To: Andrew W. Alexander <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; 'Nisbeth, Ben (blecorp)' <[e-mail]>; 'Benton, Trevor
(blecorp)' <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Andy,
The proposed changes to the subject permit as described in the emails below are acceptable.
Please remember to notify this office prior to construction of injection well IW-3A and prior to initiation of injection
activities as required in the permit. _
J
Feel free to contact me if you have any questions.
Thanks,
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: And rew.W.Moore(cDncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778

NC_ Nothing Compares-..__
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Monday, December 14, 2015 11:22 AM
To: Moore, Andrew W <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: Davidson, Landon<[e-mail]>;'Nisbeth, Ben (blecorp)' <[e-mail]>; 'Benton, Trevor
(blecorp)' <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Attached now. Doh! --Andy
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Monday, December 14, 2015 11:20 AM
To: 'Moore, Andrew W' <[e-mail]>; 'Rogers, Michael' <[e-mail]>
Cc: 'Davidson, Landon' <[e-mail]>; 'Nisbeth, Ben (blecorp)' <[e-mail]>; 'Benton, Trevor
(blecorp)' <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Hello Andrew,
Just to remove all doubt I have prepare a revised Table 2, 3, and 4 for the 2016
calendar year.
Table 4 is the monitoring matrix. Note the wells in *red* text will be monitored. Wells
in ^purple^ will be injected.
Also note that the water levels in IW-1 and IW-3 are below gravel pack so those wells
cannot be sampled. Proposed injection well IW-3A will also have the water level below
gravel pack and cannot be sampled.
Let me know if you need anything else. Thanks, --Andy
From: Moore, Andrew W [mailto:[e-mail]]
Sent: Monday, December 14, 2015 10:18 AM
To: Andrew W. Alexander <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Nisbeth, Ben (blecorp) <[e-mail]>; Benton, Trevor
(blecorp) <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Andy,
2

Can you clarify one item?
For 2016, in addition to the monitoring stations associated with injection area RW-3/IW-1, are you proposing to sample
the same 30, 90, and 150 day monitoring stations for IW-3A as are required for IW-3?
Thanks,
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: Andrew.W.Moore(a7ncdenr ciov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
NT".- -'- "Nothing Compares.—_
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Monday, December 14, 2015 8:35 AM
To: Rogers, Michael <[e-mail]>
Cc: Moore, Andrew W <[e-mail]>; Davidson, Landon <[e-mail]>; Nisbeth,
Ben (blecorp) <[e-mail]>; Benton, Trevor (blecorp) <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Hello Gents;
wanted to make sure you received this email. Please confirm receipt and let me
know if you have any questions. Thanks. --Andy
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Wednesday, December 09, 2015 10:08 AM
To: Rogers, Michael <[e-mail]>
Cc: Moore, Andrew W <[e-mail]>; Davidson, Landon <[e-mail]>; Nisbeth,
Ben (blecorp) <[e-mail]>; Benton, Trevor (blecorp) <[e-mail]>
Subject: 2016 Andrex/Milkco Permit No. W10100106
Hello Michael,
We have completed the final sampling event (150 day) for the 2015 injection project at
Andrex and have recently reviewed the lab data. Recall that we installed two injection
3

wells (IW-1 and IW-3) in 2Q -r,., and injected and monitored iVi--'u�ie both areas per the
matrix. Recall that BILE prepared a 2015 Injection Plan at your request last year
because we moved the proposed locations of IW-1 and IW-3 from their original
locations specified in our permit.
I will prepare 2015 interim evaluation report and a 2015 annual monitoring report to
document the 2015 findings. Both reports will be issued in the 1St quarter of 2016. -It
appears from the data that the installation and injection into IW-1 met our project
goals. However, the depth to rock at the IW-3 location (30 feet north of MW-6 as
approved) was significantly deeper than we anticipated and it appears that the injection
into IW-3 did not affect MW-6 as planned.
We are currently planning for injection in the 2016 calendar year. We have a
conceptual plan which includes installation of a new injection well (designated IW-3A)
to the west and within 10 feet of MW-6. This proposed injection well will be installed to
the top of bedrock which has already been determined at the MW-6 location (56.4 feet
bgs). Please note that I am not proposing a change to the approved injection well
construction specifications.
Injections for 2016 would include the new injection well IW-3A (25,000. gallons) and
RW-3 and IW-1 (12,500 gallons each). Injection volumes of 25,000 gallons per well
are already approved in the permit. Monitoring would include the existing wells in both
areas, per the matrix 'at the at the previously approved 30, 90, and 150-day intervals, no
change is proposed.
May we proceed in general accordance with the existing permit and as described
herein for 2016? -
Happy Holidays. 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(d)-blecorp.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)blecoro.com). Thank you for your cooperation.
4

Rogers, Michael
From: Moore, Andrew W
Sent: Monday, December 14, 2015 1:16 PM
To: Andrew W. Alexander; Rogers, Michael
Cc: Davidson, Landon; 'Nisbeth, Ben (blecorp)'; 'Benton, Trevor (blecorp)'
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Thanks Andy. We'll confer with Michael when he returns from leave. I anticipate we'll have a response by the end of the
week.
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
C` -.-'Nothing Compares . —,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Monday, December 14, 2015 11:22 AM
To: Moore, Andrew W <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; 'Nisbeth, Ben (blecorp)' <[e-mail]>; 'Benton, Trevor
(blecorp)' <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Attached now. Doh! --Andy
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Monday, December 14, 2015 11:20 AM
To: 'Moore, Andrew W' <[e-mail]>; 'Rogers, Michael' <[e-mail]>
Cc: 'Davidson, Landon' <[e-mail]>; 'Nisbeth, Ben (blecorp)' <[e-mail]>; 'Benton, Trevor
(blecorp)' <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Hello Andrew,
Just to remove all doubt I have prepare a revised Table 2. 3, and 4 for the 2016
calendar year.
1

Table 4 is the monitoring matrix. Note the wells in *red* text will be monitored. Wells
in ^ purple ^ will be injected.
Also note that the water levels in IW-1 and IW-3 are below gravel pack so those wells
cannot be sampled. Proposed injection well IW-3A will also have the water level below
gravel pack and cannot be sampled.
Let me know if you need anything else. Thanks, --Andy
From: Moore, Andrew W [mailto:[e-mail]]
Sent: Monday, December 14, 2015 10:18 AM
To: Andrew W. Alexander <[e-mail]>; Rogers, Michael <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Nisbeth, Ben (blecorp) <[e-mail]>; Benton, Trevor
(blecorp) <[e-mail]>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Andy,
Can you clarify one item?
For 2016, in addition to the monitoring stations associated with injection area RW-3/IW-1, are you proposing to sample
the same 30, 90, and 150 day monitoring stations for IW-3A as are required for IW-3?
Thanks,
Andrew W. Moore, P.G.
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email Andrew.W.Moore(c)ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
"'Nothing Compares..,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Monday, December 14, 2015 8:35 AM
To: Rogers, Michael <[e-mail]>
Cc: Moore, Andrew W <[e-mail]>; Davidson, Landon <[e-mail]>; Nisbeth,
2

i
f
Ben (blecorp) <[e-mail];;;; 'denton, Trevor (blecorp) <trevor@bleco, �.�om>
Subject: RE: 2016 Andrex/Milkco Permit No. W10100106
Hello Gents,
wanted to make sure you received this email. Please confirm receipt and let me
know if you have any questions. Thanks, --Andy
From: Andrew W. Alexander [mailto:[e-mail]]
Sent: Wednesday, December 09, 2015 10:08 AM
To: Rogers, Michael <[e-mail]>
Cc: Moore, Andrew W <[e-mail]>; Davidson, Landon <[e-mail]>; Nisbeth,
Ben (blecorp) <[e-mail]>; Benton, Trevor (blecorp) <[e-mail]>
Subject: 2016 Andrex/Milkco Permit No. W10100106
Hello Michael,
We have completed the final sampling event (150 day) for the 2015 injection project at
Andrex and have recently reviewed the lab data. Recall that we installed two injection
wells (IW-1 and IW-3) in 2015 and injected and monitored in the both areas per the
matrix. Recall that BLE prepared a 2015 Injection Plan at your request last year
because we moved the proposed locations of IW-1 and IW-3 from their original
locations specified in our permit.
I will prepare 2015 interim evaluation report and a 2015 annual monitoring report to
document the 2015 findings. Both reports will be issued in the 11t quarter of 2016. It
appears from the data that the installation and injection into IW-1 met our project
goals. However, the depth to rock at the IW-3 location (30 feet north of MW-6 as
approved) was significantly deeper than we anticipated and it appears that the injection
into IW-3 did not affect MW-6 as planned.
We are currently planning for injection in the 2016 calendar year. We have a
conceptual plan which includes installation of a new injection well (designated IW-3A)
to the.west and within 10 feet of MW-6. This proposed injection well will be installed to
the top of bedrock which has already been determined at the MW-6 location (56.4 feet
bgs). Please note that I am not proposing a change to the approved injection well
construction specifications.
Injections for 2016 would include the new injection well IW-3A (25,000 gallons) .and
RW-3 and IW-1 (12,500 gallons each). Injection volumes of 25,000 gallons per well
are already approved in the permit. Monitoring would include the existing wells in both
areas per the matrix at the at the previously approved 30, 90, and 150-day intervals, no
change is proposed.
3

i I -
May we proceed in general`_i_�.,ordance with the existing pelrrlit and as described
herein for 2016?
Happy Holidays. 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(d)-blecorp.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(d_)blecorp.com). Thank you for your cooperation.
J
4

Rogers, Michael
From: Davidson, Landon
Sent: Monday, December 09, 2013 2:21 PM
To: Rogers, Michael
Subject: RE: Andrex addendum (WI0100106)
M-
We're (Andrew W. Moore) good to move with issuance. Thanks
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.or�
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law
and may be disclosed to third parties.
From: Rogers, Michael
Sent: Monday, December 09, 2013 1:20 PM
To: Davidson, Landon
Subject: FW: Andrex addendum (WI0100106)
Landon -
Have you reviewed the add info yet? If so are you OK w/permit renewal?
Thanks
From: Andrew W. Alexander [mailto:andyftblecorp.com]
Sent: Wednesday, November 27, 2013 10:45 AM
To: Slusser, Thomas
Cc: Rogers, Michael; Davidson, Landon
Subject: RE: Andrex addendum (WI0100106)
Thanks guys. Snowed down here this morning. Holiday weather! Don't each too much
turkey... Gobble, --Andy
From: Slusser, Thomas fmailto:thomas.slusser(&ncdenr.gov]
Sent: Wednesday, November 27, 2013 10:14 AM
To: Andrew W. Alexander
Cc: Rogers, Michael; Davidson, Landon
Subject: Andrex addendum (WI0100106)
Greetings.Andy,
1

Yesterday I received the addendum for the Andrex injection well permit renewal with modification. I gave one copy to
Mike Rogers, the permit reviewer, and forwarded one copy to staff in the Asheville Regional Office. Mike and regional
office staff will respond as needed.
Have a nice Thanksgiving holiday,
Thomas Slusser, L.G.
Underground Injection Control Program Manager
thomas.slusser@ncdenrgov I ph# 919-807-6412 1 fax# [phone]
Mailing Address: DWR - Aquifer Protection Section 1 1636 Mail Service Center I Raleigh, NC 27699-1636.
Physical Address: Room 640M, Archdale Building, 512 N. Salisbury St., Raleigh, NC 27604.
Internet Address: http://portal.ncdenr.org/web/wq/ays/gwpro
f--mail correspondence to and from this address may he subject to the North Carolina Public Records lawandmsy bs disclosed to third parties unless the content is
exempt by statute ar other regulation.

Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone] RECEIVED/DENR/DWR
LETTER OF TRANSMITTAL
NOV 2 6 2013
TO: Underground Injection Control Program
NC Division of Water Resources Water Quality Regional
1636 Mail Service Center Operations Section
Raleigh, North Carolina 27699-1636
ATTENTION: Mr. Thomas Slusser, LG — 2 Copies w/ CD
CC: Mr. Keith Collins — Milkco, Inc. —1 Copy w/ CD
Ms. Tracy Wahl — NCDENR—Brownfields -1 Copy w/ CD
Mr. Ben Nisbeth, PG — BLE Asheville - PDF via Email
Mr. Landon Davidson. PG — NCDENR--DWR — PDF via Email
Andrex Industries —1 Copy w/ CD
DATE:
November 19, 2013
RE: Andrex Industries Corp.
Addendum to Application for UIC Permit Renewal with Modification
UIC Permit No. WI0100106
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
❑ Report ❑ 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 requested ❑ Other
Number of copies: As specified above.
REMARKS: Thomas,
® Application
❑ Specifications
❑ For review and comment
Two copies of the subject document are attached for the UIC program's review.
&14/ A414-4�
Andrew W. Ale nder, P.G.
Senior Hydrogeologist
c.\awa\active projects\andrex milkco\phase35 3rd injection, permit & ier\1022-35 permit renewal\permit addendum\transmittal
2013 uic permit renewal addendum.doc

It
,IL13
BUNNELL-LAMMONS ENGINEERING, INC.
GEOTECHNICAL, ENVIRONMENTAL AND CONSTRUCTION MATERIALS CONSULTANTS
November 19, 2013
Underground Injection Control Program
DWR - Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
Attention: Mr. Thomas Slusser, L.G.
Program Manager
Subject: Addendum to UIC Permit Application (UIC-51/5T)
Permit Renewal with Modification
UIC Permit No. WI0100106
Former Andrex Industries Facility
180 Deaverview Road
Asheville, North Carolina
BLE Project Number J12-1022-35
Groundwater Incident Number 6586
Brownfields Project Number 07022-03-11
Dear Mr. Slusser:
RECEIVEDIDEN�, DwR
NOV 2 6 2013
Opera"Iffy R
Perations onal
Bunnell-Lammons Engineering, Inc. (BLE) is pleased to submit this addendum for renewal of the
UIC permit at the subject site. This addendum is prepared in response to an email rqquest dated
October 17, 2013 which was prepared by Mr. Michael Rogers. The requirements for the contents of
this addendum were discussed during several teleconferences between Mr. Andrew Alexander and
Mr. Rogers, Mr. Landon Davidson, and Ms. Debra Watts from October 22 through October 23,
2013 and during a meeting at the Asheville Regional Offices on October 31, 2013 between Mr.
Alexander and Mr. Davidson.
We understand that recent changes to the Title 15A North Carolina Administrative Code (NCAC)
Subchapter 02C .0225 for groundwater remediation wells require that the applicant specify the
horizontal and vertical portion of the injection zone. Additionally, a monitoring plan must be
proposed (and approved by the Division) which will determine if violations of NCAC Subchapter
02L groundwater standards occur outside of the injection zone as a result of the injection.
It was agreed in the aforementioned meetings that BLE would prepare a map and profile which
illustrates the anticipated injection zone. It was also agreed that BLE would modify the injection
monitoring plan matrix to indicate which monitoring points are outside of the injection zone and will
meet the monitoring requirements specified herein. Furthermore, it was agreed that in areas where
monitoring cannot be performed, BLE would prepare a description of the restrictive conditions
which limit monitoring in those areas.
6004 PONDERS COURT PHONE [phone]
GREENVILLE, SOUTH CAROLINA 29615 FAX [phone]

1LE
Addendum UIC Permit Application — Renewal with Modification
Former Andrex Industries, Asheville, North Carolina
Injection Zone lHustration
November 19, 2013
BLE Project Number J12-1022-35
The Proposed Injection Well Plan (Figure 2) has been modified to include -an illustration of the
horizontal extent of the injection zone. We have estimated the limits based on. our observation of the
injection zone limits (by monitoring for total organic carbon) during the three -injection events
conducted as part of the field scale pilot test from May- 2011 to March 2013. - These results were
documented in the report titled Interim Evaluation Report — Field -Scale Pilot Test dated July 20,
2013.
A new figure titled,Hydrogeologic Profiles of the Affected Area (Figure 3) has been prepared as
part of this addendum. This figure was previously submitted as Figure 4 in the 2010 permit
application. It has been renamed (as Figure3) and modified to 'illustrate the vertical limits of the
injection zone. The injection zone .was °determined as ' specified above.,: This figure has also been
modified to include the results of the.:2012 annual groundwater sampling event and include the
proposed injection and monitoring wells which will be -present on: or near the designated transects.
Please note that the actual locations and depths of the proposed. injection. and monitoring wells will
be determined in the field based on site access and observed hydrogeology (waterbearing fractures,.
etc.).
Injection Monitoring Plan Matrix
The:' Injection Monitoring Plan .Matrix (Table 4) has been modified to designate whether wells are
inside or .outside the .injection.zone. Based on the results obtained during _the field scale pilot, the
sampling frequency specified on the matrix will be sufficient for monitoring. and no changes are ;
recommended.- Please see the following section on restrictive conditions for further monitoring
information.
Restrictive Conditions and Limited Monitoring
The anticipated limit -of the injection zone extends to the north, east, and south and should follow
preferential flow pathways exhibited by the plume -(Figure 2). Western migration: is not anticipated
due.to hydraulic conditions. The, northern injection zone boundary is delineated by monitoring well
MW-23 which is located inside Roy D. Farmer City Park. Based on our discussion with the City: of
Asheville during the comprehensive site assessment it is doubtful that the City would allow the
installation of additional wells in the park. Furthermore, it appears that MW-23's location is
.sufficient for monitoring of the northern boundary of the injection zone.
The eastern boundary of the injection zone is delineated by the MW43 / MW-14 well pair (Figures
2 & 3). These wells are located in a hydraulic convergence zone where ' clean west flowing
-groundwater meets contaminated east flowing groundwater from the source area (please refer to the
Groundwater Elevation Contour Map —.Figure 1 from the previously submitted application). Based
on these data, additional monitoring points east of the railroad line are not required.
The southern injection zone boundary is located within the "Bear Creek Residential Area" (Figures 2
& 3). During the comprehensive assessment the neighborhood property owners were solicited for.
K

.ABLE
Addendum UIC Permit Application — Renewal with Modification November 19, 2013
Former Andrex Industries, Asheville, North Carolina BLE Project Number J12-1022-35
property access for the installation of groundwater monitoring wells. However, none of the residen#
would allow monitoring well installations on their property and/or failed to respond to requests. We
anticipate that permission for the installation of additional monitoring wells in the residential area
would not be granted. It should be noted that the MW-15 / MW-16 well pair (Figures 2 & 3) is
located outside the limits of the injection zone and provides monitoring in that flow direction.
CLOSING
We appreciate the opportunity to work with you at the subject site. We look forward to receiving
NCDENR approval of the application, addendum, and work plan. If you have any questions, please
do not hesitate contacting us at [phone].
Sincerely,
BUNNELL-LAMMONS ENGINEERING, INC.
4A— t—/ dJ14 ~�
Andrew W. Alex nder, P.G., RSM
Senior Hydrogeologist
Registered, NC No. 1475
Attachments: Revised Table 4
Revised Figure 2 & New Figure 3
Trevor J. Bento P.G.
Project Hydrogeologist
Registered, NC No. 2025
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permit app text renewal with modification andrex 1022-35.doc
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MILE
Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL RECEIVED/DENWDWR
TO: Division of Water Resources MAY 16 2014
Information Processing Unit Water quality Regional
1617 Mail Service Center Operations SeChOn
Raleigh, North Carolina 27699-1617
CC: Mr. Keith Collins — Milkco, Inc. —1 Copy
DWR UIC Program (Raleigh) —1 Copy
DWR WQROS (Asheville) —1 Copy
Buncombe County — Environmental Health Division —1 Copy
Mr. Ben Nisbeth, PG — BLE Asheville - PDF via Email
DATE: May 8, 2014
RE: Milkco / Former Andrex Industries Corp.
GW-1 forms for IW-2 and MW-44
UIC Permit No. WI0100106
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
❑ Report ❑ Prints ❑ Change order ❑ Letter
❑ Other ❑ W.A.S. ❑ Plans ❑ Samples
❑ Proposal ® Well Construction Record Forms GW-1
THESE ARE TRANSMITTED AS CHECKED BELOW:
❑ For approval ❑ For your use ® As required ❑ Other
Number of copies: As specified above.
REMARKS:
I have enclosed subject documents as required in the UIC permit.
❑ Application
❑ Specifications
❑ For review and comment
aC/ A& 14osw�
Andrew W. Ale nder, P.G.
Senior Hydrogeologist
e:\awa\active projects\andrex milkco\phase38 injection & monitoring 2014\mw-44 & iw-2 boring logs\transmittal iw-2 and mw-44
form gw-I andrex milkco.doc

WELL CONSTRUCTION RECG_
This form can be used for single or multiple wells
1. Well Contractor Information:
Brunson L. King
Well Contractor Name
3290-A
NC Well Contractor Certification Number
Landprobe, LLC
Company Name
2. Well Construction Permit #: U IC #W10100106
List all applicable well permits (i.e. County, State, Variance, Injection, etc.)
3. Well Use (check well use):
Water Supply Well:
❑Agricultural ❑MunicipaMblic
❑Geothermal (Heating/Cooling Supply) ❑Residential Water Supply (single)
❑Industrial/Commercial ❑Residential Water Supply (shared)
Non -Water Supply Well:
❑Aquifer Recharge
OGroundwater Remediation
❑Aquifer Storage and Recovery
❑Salinity Barrier
❑Aquifer Test
❑Stolmwater Drainage
❑Experimental Technology
❑Subsidence Control
❑Geothermal (Closed Loop)
❑Tracer
❑Geothermal (Heatine/Cooling Return)
❑Other (explain under #21 1
4. Date Well(s) Completed: 4-9-14
5a. Well Location:
Milkco, Inc. (Former Andrex)
Well ID# IW-2
#07022-03-11
Facility/Owner Name Facility ID# (if applicable)
180 Deaverview Road, Asheville, NC 28806
Physical Address, City, and Zip
Buncombe
County
9667
Parcel Identification No. (PIN)
5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees:
(ifwell field, one lat/long is sufficient)
35.57990 N 82.61396 W
6. Is (are) the well(s): 21'ermanent or ❑Temporary
7. Is this a repair to an existing well: ❑Yes or ONo
If this is a repair, fill out known well construction information and explain the nature of the
repair under #21 remarks section or on the hack of this form.
8. Number ofwells constructed: One
For multiple injection or non -water supply wells ONLY with the same construction, you can
submit one form.
9. Total well depth below land surface: 84
For multiple wells list all depths if different (example- 3@200' and 2@100)
10. Static water level below top of casing: 56
If water level is above casing. use '•+"
11. Borehole diameter: 10 (in.)
For Internal Use ONLY:
14. WATER ZONES
FROM
TO
DESCRIPTION
70 ft.
73 ft•
water bearing fractures
ft.
ft.
15. OUTER CASING for multi -cased wells) OR
LINER if a
ticable
FROM
TO
DIAMETER
THICKNESS
MATERIAL
0 ft.
64 ft.
6 i°
Sch 40
PVC
16. INNER CASING OR TUBING(geothermal closed -loop
FROM
TO
DIAMETER
THICKNESS
MATERIAL
ft.
ft.
in.
ft.
ft.
in.
17.SCREEN
FROM
TO
DIAMETER
SLOT SIZE
THICKNESS
MATERIAL
ft.
ft.
in.
ft.
ft.
in.
18. GROUT
FROM
TO
MATERIAL
EMPLACEMENT METHOD & AMOUNT
0 e•
2 f`
cement
gravity -- 1 bag
2 ft-
64 f`•
bentonite
gravity -- 13 bags
ft.
ft.
19. SAND/GRAVEL PACK(if applicable)
FROM
TO
MATERIAL
EMPLACEMENT METHOD
64 f`
84 ft.
#3 stone
gravity
ft.
ft.
20. DRILLING LOG attach additional sheets if necessary)
FROM
TO
DESCRIPTION color, hardness, soiUrock type, grain size, etc.)
0 ft.
25 ft•
red -bra f-m sandy SILT (fill)
25 ft.
35 ft•
red-bm silty f-m SAND (residuum)
35 ft.
64 ft•
brown silty f-m SAND (PWR)
64 ff.
84 f`•
gray-brn f-m SAND (bedrock)
ft.
ft.
ft.
ft.
ft.
ft.
21. REMARKS
Well construction per UIC permit
22. Certification:
5-8-14
Signature of Certified Well Contractor Date
By signing this form, I hereby certify that the well(s) was (were) constructed in accordance
with 15A NCAC 02C .0100 or 15A NCAC 02C .0100 Well Construction Standards and that a
copy of this record has been provided to the well owner.
23. Site diagram or additional well details:
You may use the back of this page to provide additional well site details or well
construction details. You may also attach additional pages if necessary.
SUBMITTAL INSTUCTIONS
24a. For All Wells: Submit this form within 30 days of completion of well
construction to the following:
Division of Water Resources, Information Processing Unit,
1617 Mail Service Center, Raleigh, NC 27699-1617
24b. For Iniection Wells ONLY: In addition to sending the form to the address in
24a above, also submit a copy of this forth within 30 days of completion of well
12.Wellconstructionmethod: air hammer construction to the following:
(i.e. auger, rotary, cable, direct push, etc.)
Division of Water Resources, Underground Injection Control Program,
FOR WATER SUPPLY WELLS ONLY: 1636 Mail Service Center, Raleigh, NC 27699-1636
13a. Yield (gpm) Method of test: 24c. For Water Supply & Injection Wells:
Also submit one copy of this form within 30 days of completion of
13b. Disinfection type: Amount: well construction to the county health department of the county where
constructed.
Form GW-1 North Carolina Department of Environment and Natural Resources - Division of Water Resources Revised August 2013

WELL CONSTRUCTION REC(
i, This form can be used for single or multiple wells
1. Well Contractor Information:
Brunson L. King
Well Contractor Name
3290-A
NC Well Contractor Certification Number
Landprobe, LLC
Company Name
2. Well Construction Permit #: U I C #W l0100106
List all applicable well permits (i.e. County, State, Variance, Injection, etc.)
3. Well Use (check well use):
Water Supply Well:
❑Agricultural
❑Geothermal (Heating/Cooling Supply)
❑ Industrial/C ommercial
..
Non -Water Supply Well:
-.A�z _ --
❑Aquifer Recharge
❑Aquifer Storage and Recovery
❑Aquifer Test
❑Experimental Technology
❑Geothermal (Closed Loop)
❑Geothermal (Heating/Coolina
❑Municipal/Public
❑Residential Water Supply (single)
❑Residential Water Supply (shared)
❑Groundwater Remediation
❑Salinity Barrier
❑ Stormwater Drainage
El Subsidence Control
❑Tracer
❑Other (exDlain under #21 1
4. Date Well(s) Completed: 4-9-14 Well ID#"MW-44 - r
5a. Well Location:
Milkco, Inc. #07022-03-11
Facility/Owner Name Facility ID# (if applicable)
220 Deaverview Road, Asheville, NC 28806
Physical Address, City, and Zip
Buncombe 2678
County
Parcel Identification No. (PIN)
5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees:
(if well field, one lat/long is sufficient)
35.57961 N 82.61351 W
6. Is (are) the well(s): IZPermanent or ❑Temporary
7. Is this a repair to an existing well: ❑Yes or RiNo
If this is a repair, fill out known well construction information and explain the nature of the
repair under #21 remarks section or on the back of this form.
8. Number of wells constructed: One
For multiple injection or non -water supply wells ONLY with the same construction, you can
submit one form.
9. Total well depth below land surface: 81
For multiple wells list all depths ifdierent (example- 3@200' and 2@100')
10. Static water level below top of casing: 59.7
Ifater level is above casing, use
11. Borehole diameter: 6 (in.)
12. Well construction method: air hammer
(i.e. auger, rotary, cable, direct push, etc.)
(ft.)
For Internal Use ONLY:
14. WATER
ZONES
FROM
TO
DESCRIPTION
59.7 ft.
81 It.
saprolite and PWR
ft.
ft.
15.OUTER..CASING
for
mull-casedwells OR LINER ifa "licable
FROM
TO
DIAMETER
THICKNESS
MATERIAL
ft.
ft.
in.
16. INNER CASING OR TUBING eother
at closed-loo
FROM
TO
DIAMETER
THICKNESS
MATERIAL
ft.
ft.
in.
ft.
ft,
in.
17:ESCREEN
FROM
TO
DIAMETER
SLOT SIZE
THICKNESS
MATERIAL
65 "'
80 ft.
2 in.
0.0101,
Sch 40
PVC
ft.
ft.
in.
18. GROUT
FROM
TO
MATERIAL
EMPLACEMENT
METHOD
& AMOUNT
0 ft.
57 ft•
cement
gravity --17 bags
57 ft.
62 ft-
bentonite
gravity" 1 bag
ft.
ft.
19. SAND/GRAVEL PACK Ha licable
FROM
TO
MATERIAL'
EMPLACEMENT METHOD
62 ft.
81 ft.
#2 sand
gravity -- 6.5 bags
ft.
ft.
20. DRILLING
LOG attach additional sheets if necessa
FROM
TO
DESCRIPTION color, hardness, soiltrock e, rain size, etc.)
0 ft*
25 ft.
brown f-m sandy SILT (fill)
25 ft•
70 ft•
brown silty f-m SAND (residuum)
70 ft.
81 ft.
brown silty f-m SAND (PWR)
It.
81 ft.
bedrock
ft.
ft.
ft.
ft.
ft.
ft.
21.'vREMARKS
22. Certification:
5-8-14
Signature of Certified Well Contractor Date
By signing this form, I hereby certify that the well(s) was (were) constructed in accordance
with 15A NCAC 02C .0100 or 15A NCAC 02C .0200 Well Construction Standards and that a
copy of this record has been provided to the well owner.
23. Site diagram or additional well details:
You may use the back of this page to provide additional well site details or well
construction details. You may also attach additional pages if necessary.
SUBMITTAL INSTUCTIONS
24a. For All Wells: Submit this form within 30 days of completion of well
construction to the following:
Division of Water Resources, Information Processing Unit,
1617 Mail Service Center, Raleigh, NC 27699-1617
24b. For Injection Wells ONLY: In addition to sending the form to the address in
24a above, also submit a copy of this form within 30 days of completion of well
construction to the following:
Division of Water Resources, Underground Injection Control Program,
FOR WATER SUPPLY WELLS ONLY: 1636 Mail Service Center, Raleigh, NC 27699-1636
13a. Yield m Method oftest: 24c. For Water Supply & Injection Wells:
(gp ) Also submit one copy of this form within 30 days of completion of
13b. Disinfection type: Amount: well construction to the county health department of the county where
constructed.
Form GW-1 North Carolina Department of Environment and Natural Resources - Division of Water Resources Revised August 2013

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
December 13, 2013
Mr. Keith Collins, President
Milkco, Inc.
P.O. Box 16160
Asheville, NC 28816
Ref: Issuance of Injection Permit WI0100106
Milkco, Inc.
Buncombe County, North Carolina
Dear Mr. Collins:
In accordance with the application received on August 6, 2013, and additional information received
August 26, September 27, and November 26, 2013, we are forwarding permit number W10100106. This
permit is to inject 1% milk solution for the remediation of volatile organic compounds (VOCs). These
injection wells/points will be located at the Former Andrex Industries Corporation Facility, 180
Deaverview Road, Asheville, Buncombe County, NC 28806. This permit shall be effective from the date
of issuance until November 30, 2018, 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 Part VII.1, the proposed monitoring plan included in the application
shall be followed except that (a.) AM-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 semi-annually;
• Per permit condition Part VII.5, 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 VII.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. Mote: if well construction/abandonment information
is essentially the same (e.g., direct push points or geo-probes), then only one GW-1 or GW-
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterouality.oro
An Equal Opportunity %Affirmative Action Employer

Milkco, Inc.
Page 2 of 2
-, �
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's website at
httn://Portal.ncdenr..orL/web/wci/aps/gwpro/reporting-forms
➢ 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 transferable 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)
Hydrogeologist
Groundwater Protection Branch
Water Quality Regional Operations Section
Division of Water Resources
cc Landon Davidson, Asheville Regional Office
Central Office File, WI0100106
Andrew W. Alexander, Bunnell-Lammons Engineering, Inc., 6004 Ponders Ct., Greenville, SC
29615

DocuSign Envelope ID: B21B585C-FM8-4677 441437EDC858
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
Permit No. WI0100106
Date: October 8, 2018 County: Buncombe
To: Michael Rogers Permittee/Applicant: Milkco Inc.
Central Office Reviewer Facility Name: Former Andrex Industries Facility
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal
❑ Minor Modification ❑ Major Modification
a. Date of Inspection:
b. Person contacted and contact information:
c. Site visit conducted by:
d. Inspection Report Printed from BIMS attached: ❑ Yes ❑ No.
e. Physical Address of Site including zip code:
f. Driving Directions if rural site and/or no physical address:
g. Latitude: Longitude:
Source of Lat/Long & accuracy (i.e., Google Earth, GPS, etc.):
II. DESCRIPTION OF INJECTION WELLS) AND FACILITY
1. Type of injection system:
❑ Geothermal Heating/Cooling Water Return
otCEIVEDINCDE ��'
® In situ Groundwater Remediation
❑ Non -Discharge Groundwater Remediation
O C T = U 2018
❑ Other (Specify:_)
Water Quality Region, i
10eration!z SP( tjrr
2. For Geothermal Water Return Well(s) only
a. For existing geothermal system:
Were samples collected from Influent/Effluent sampling ports? ❑ Yes ❑ No.
Provide well construction information from well tag:
b. Does existing or proposed system use same well for water source and injection? ❑ Yes ❑ No
If No please provide source/supply well construction info (i.e., depth, date drilled, well contractor,
etc.) and attached map and sketch location of supply well in relation to injection well and any other
features in Section IV of this Staff Report.
3. Are there any potential pollution sources that may affect injection? ❑ Yes ® No
What is/are the pollution source(s)?
What is the distance of the injection well(s) from the pollution source(s)?
4. What is the minimum distance of proposed injection wells from the property boundary? —200 feet
5. Quality of drainage at site: ❑ Good ® Adequate ❑ Poor
6. Flooding potential of site: ® Low ❑ Moderate ❑ High
Rev. 6/1/2015 Page 1

DocuSign Envelope ID: B2lB585C-F2A8-4677-8870-' ,,-37EDC858
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
7. For Groundwater Remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ® No. If No,
attach map of existing monitoring well network if applicable and recommend any changes to the groundwater -
monitoring program. See staff review comments.
8. Does the map included in the Application reasonably represent the actual site (property lines, wells, surface
drainage)? ® Yes ❑ No. If No, or no map, please attach a sketch of the site. Show property boundaries,
buildings, wells, potential pollution sources, roads, approximate scale, and north arrow.
9. For Non -Discharge groundwater remediation systems only:
a. Are the treatment facilities adequate for the type of waste and disposal system? ❑ Yes ❑ No ❑ N/A.
If no, please explain:
b. Are the site conditions (soils, topography, depth to water table, etc.) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:.
III. EVAL UATIONAND RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ®No. If yes, explain.
2. List any items that you would like WQROS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item
Reason
Injection monitoring plan for RW-1 and RW-5.
Injections are proposed into RW-1 and RW-5 as
noted on Table 2 of the renewal application.
However, there is no injection monitoring plan
included on Table 6 for these wells.
Confirmation that, if constructed, IW-10 will
It's difficult to determine whether MW-44 is an
be installed as an "above rock" well. If not,
appropriate monitoring point for IW-10, as is
,MW-44 may not be an appropriate monitoring
proposed on Table 6, as it is not clear in what
point for a bedrock injection well.
aquifer zone IW-10 will be installed. MW-44 is
screened in saprolite/partially-weathered rock
(PWR)-
3. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
4. Recommendation
Rev. 6/1/2015 Page 2

DocuSign Envelope ID: B2113585C-F2A84677-' >A41437EDC858
WQROS REGIONAL STAFF REPORT FOR
UIC Program Support
❑ Deny. If Deny, please state reasons:
❑ Hold pending receipt and review of additional information by regional office
® Issue upon receipt of needed additional information
❑ Issue 000asigned by:
5. Signature of report preparer(s):`�"" mom'
SC147F587AE940 ...
Signature of WQROS Regional Supervisor:
7E617A38285848C...
Date: 10/8/2018
IV. ADDITIONAL REGIONAL STAFF REVIEW COMMENTS/ATTACHMENTS (If Needed)
The previous version of the injection permit, issued December 13, 2013, required that MW-13, MW-14, and
MW-23 be sampled at 30- and 150-day intervals, in addition to the proposed 90-day interval, following
injection into IW-7 and IW-10. MW-13 and MW-14 were proposed monitoring points associated with injection
into IW-7 and MW-23 was the proposed monitoring point associated with IW-10. During the previous permit
period, injections did not occur within IW-7 or IW-10, and therefore the monitoring associated with these
injections wells was not required. Table 6 included with the current renewal application does not include the
30- and 150-day monitoring schedule for these wells as was required in the previous version of the permit. Note
that the proposed location of IW-10 has moved since the 2013 application so that MW-23 is no longer
applicable for evaluation of injection into IW-10 and is not proposed as a monitoring point associated with IW-
10. Rather, it is now a monitoring point associated with IW-9. It may be advantageous to note the requirements
for MW-13 and MW-14 if the consultant is contacted regarding RW-1, RW-5, and IW-10.
Rev. 6/1/2015 Page 3

WATER QUALITY REGIONAL OPERATIONS SECTION
APPLICATION REVIEW REQUEST FORM
Date: September 28, 2018
To: Landon Davidson- ARO
From: Michael Rogers, WQROS — Animal Feeding Operations and Groundwater Protection Branch
Telephone: [phone] E Mail. [e-mail]
A. Permit Number: WI0100106
B. Applicant: Milkco Inc..
C. Facility Name: Former Andrex Industries Facility
D. Application:
Permit Type: Groundwater Remediation Well
Project Type: Renewal with Modification
E. Comments/Other Information:
❑ I would like to accompany you on a site visit.
Attached, you will fmd all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please return a completed WQROS Staff
Report.
When you receive this request form, please write your name and dates in the spaces below, make a copy of
this sheet, and return it to the appropriate Central Office Groundwater Protection Branch contact person
listed above.
RO-WOROS Reviewer:
COMMENTS:
NOTES Thanks for your support!
Date:
FORM: WQROS-ARR ver. 092614 Page 1 of 1

AQUIFER PROTECTIG,,4 SECTION - GROUNDWATLim PROTECTION UNIT
REGIONAL STAFF REPORT
Date: September 27, 2013 Permittee(s): Milkco, Inc.
Permit No.: WI0100106
To: APS Central Office County: Buncombe
Central Office Reviewer: Michael Rogers Project Name: Former Andrex Industries Corp. Facility
Regional Login No: RECEIVERENR/M
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ SFR Waste Irrigation System ® UIC Well(s) 0 C T 0 2 2013
❑ New ® Renewal
® Minor Modification ❑ Major Modification Aquifer Protection Section
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ❑ Yes or ❑ No.
a. Date of site visit: September 12, 2013
b. Person contacted and contact information: Andrew Alexander [phone], Ben Nisbeth (828) 545-
3414
c. Site visit conducted by: Andrew Moore
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
® Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For SFR Treatment Facilities:
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude: Method Used (GPS, GoogleTM, etc.);
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For UIC Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s):
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude: Method Used (GPS, GoogleTM, etc.);
APS-GPU Regional Staff Report (Sept 09) Page 1 of 6 Pages

AQUIFER PROTECTION SECTION - GROUNDWATER PROTECTION UNIT
REGIONAL STAFF REPORT
II NEWAND MAJOR MODIFICATIONAPPLICATIONS (this section not needed for renewals or minor
modirications, skip to next section)
Description of Waste System and Facilities
1. Please attach completed rating sheet. Facility Classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
❑ Yes ❑ No ❑ N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
❑ Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or ❑ No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
III. RENEWAL AND MODIFICATIONAPPLICATIONS (use previous section for new or major modification
systems)
Description of Waste System and Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No.
Operator in Charge:
Backup- Operator in Charge
Certificate #:
Certificate #:
APS-GPU Regional Staff Report (Sept 09) Page 2 of 6 Pages

AQUIFER PROTECTI(i i SECTION - GROUNDWAThK PROTECTION UNIT
REGIONAL STAFF REPORT
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
APS-GPU Regional Staff Report (Sept 09) Page 3 of 6 Pages

AQUIFER PROTECTION SECTION - GROUNDWATER PROTECTION UNIT
REGIONAL STAFF REPORT
IY. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description of Well(s) and Facilities — New, Renewal, and Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
® In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: _)
2. Does system use same well for water source and injection? ❑ Yes ® No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ® No
What is/are the pollution source(s)? What is the distance of the injection wells from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? 50 ft.
5. Quality of drainage at site: ❑ Good ® Adequate ❑ Poor
6. Flooding potential of site: ® Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ® No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program: In addition to the existing annual monitoring requirements for surface water,
surface water sample locations JW-1 and BC-1 should be monitored semi-annually for VOCs to evaluate the
effects of the proposed injections on PCE and associated daughter product discharges to surface water. The
increased monitoring frequency for these locations was discussed with, and agreed upon by, the permittee's
consultant.
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Injection Well Permit Renewal and Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes, explain:
APS-GPU Regional Staff Report (Sept 09) Page 4 of 6 Pages

AQUIFER PROTECTIUii SECTION - GROUNDWATLn PROTECTION UNIT
REGIONAL STAFF REPORT
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ® No. If yes, s, explain:
4. Drilling Contractor: Name:
Address:
NC Certification number:
5. Complete and attach NEW Injection Facility Inspection Report, if applicable
V. EVAL UATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the Application: The proposed injection well
construction details included in the permit renewal application would have resulted in a highly conductive
conduit between the saprolite, PWR, and bedrock zones. We discussed the proposed injection well construction
details with the permittee's consultant and made a recommendation to modify the injection well design. The
permittee's consultant revised the well construction design for the facility to include two scenarios based on site
conditions; one in which the water table is located above the top of bedrock, and one in which the water table is
located below the top of bedrock. In cases where the water table is located above the top of bedrock, the boring
will extend to the top of bedrock and the injection well will be screened from the water table surface to the top
of bedrock. In cases where the water table is located below the top of bedrock, the boring will extend into
bedrock, the well casing will extend to the top of bedrock, the injection well will be screened from the top of
bedrock to the boring terminus, and the borehole will be sealed at the top of bedrock. Copies of the revised
well construction diagrams are attached.
2. Attach new Injection Facility Inspection Form, if applicable
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
APS-GPU Regional Staff Report (Sept 09)
Page 5 of 6 Pages

AQUIFER PROTECTION SECTION - GROUNDWATER PROTECTION UNIT
REGIONAL STAFF REPORT
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
The monitoring schedule for surface water
sample locations BC-1 and JW-1 should be
increased to semi-annually.
To better evaluate the effect of injections on the
discharge of PCE and associated daughter
products to surface water.
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report Preparer(s):
Signature of APS regional supervisor: ��_ \C�
Date: 5, Zl • 1- a k )
VI. ADDITIONAL INFORMATIONAND SITE MAP (Sketch of site showing house and waste irrigation
system, spray or drip field, location of well(s), and/or other relevant information- SHOW NORTHARROM
APS-GPU Regional Staff Report (Sept 09) Page 6 of 6 Pages

7
TYPICAL BEDROCK INJECTION WELL
CONSTRUCTION DIAGRAM
4—INCH THICK
CONCRETE PAD
GROUND SURFACE
2—FEET CEMENT GROUT
TOP OF BEDROCK
[if GW BELOW BEROCK]
#3 STONE
GROUNDWATER LEVEL
10—INCH AIR —HAMMERED
BOREHOLE
FLUSH MOUNT STEEL
WELL COVER
COMPRESSION
WELL CAP
— BENTONITE SEAL
[VARIBLE THICKNESS]
— 6—INCH ID PVC RISER
TOP OF BEDROCK
TOTAL DEPTH
OF BORING
,108 NO.: J13-1022-35 FIGURE
DATE 11LEINC. TYPICAL BEDROCK INJECTION WELL DIAGRAM
09-26-13 BUNNELL—LAMMONS ENGINEERING, INC. FORMER ANDREX INDUSTRIES
SCALE: 6OD4 PONDERS COURT ASHEVILLE, NORTH CAROLINA
NOT TO SCALE PHONES: E�6N8�4%6 51265 FA (a941288---4430

i
TYPICAL ABOVE BEDROCK INJECTION WELL
CONSTRUCTION DIAGRAM
4-INCH THICK
CONCRETE PAD--\
GROUND SURFACE—--
2-FEET CEMENT GROUT
TO GROUNDWATER SURFACE
[if GW ABOVE BEDROCK]
VARIBLE
#3 STONE
10-INCH AIR -HAMMERED
BOREHOLE
\\iW/W/W/\\%\\%\\ %
° C
FLUSH MOUNT STEEL
WELL COVER
COMPRESSION
WELL CAP
- BENTONITE SEAL
[VARIBLE THICKNESS]
GRAVEL
6-INCH ID PVC RISER
GROUNDWATER LEVEL
TOTAL DEPTH
OF BORING
BORING TERMINATED AT
TOP OF BEDROCK
JOB NO.: J13-1022-35
JOBS NIL 13 INC. TYPICAL ABOVE BEDROCK INJECTION WELL DIAGRAM FIGURE
09-26-13 BUNNELL-LAMMONS ENGINEERING, INC. FORMER ANDREX INDUSTRIES
SCALE: 6004 PONDERS COURT ASHEVILLE, NORTH CAROLINA
NOT TO SCALE PHONE* 4�2 1265 FAX [phone]

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: August 27, 2013
To: ® Landon Davidson, ARO-APS
❑ Art Barnhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
❑ Rick Bolich, RRO-APS
❑ David May, WaRO-APS
❑ Morella Sanchez King, WiRO-APS
❑ Sherri Knight, W-SRO-APS
From: Michael Rogers Groundwater Protection Unit
Telephone. [phone] Fax: [phone]
E Mail: Michael.Rogers@n—cdenr.gov MUD /CAln;AlDMWQ
A. Permit Number: WI0100106 SEP 04 2013
B. Owner: Milko, Inc./Andrei Industries AgudeFProtection SeCiiQn
C. Facility/Operation:
❑ Proposed ® Existing ❑ Facility ❑ Operation
D. Application:
1. Permit Type: ❑
Animal
❑ SFR-Surface Irrigation❑ Reuse
❑ H-R Infiltration
❑
Recycle
❑ UE Lagoon ❑ GW Remediation (ND)
®
UIC
—Groundwater Remediation Well
For Residuals: ❑
Land
App. ❑ D&M ❑
Surface Disposal
❑
503
❑ 503 Exempt ❑
Animal
2. Project Type: ❑
New
❑
Major Mod. ❑ Minor Mod. ❑ Renewal
® Renewal w/ Mod.
E. Comments/Other Information: ❑
NOTE:
Attached, you will find all information submitted in support of the
review, comment, and/or action. Please take the following actions:
® Return a Completed APSARR Form. AUG 2 9 2013
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU. A.shc;uiii Rap, ;:r : Office
❑ Issue an Attachment B Certification from the RO.* Nquiicr Protection
* Remember that you will be responsible for coordinating site visits and reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer: And'e w 1Ko&x Date:
FORM: APSARR 07/06 Page I of I

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REOUEST FORM
Date: August 27, 2013
To: ® Landon Davidson, ARO-APS
❑ Art Barnhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
❑ Rick Bolich, RRO-APS
From: Michael Rogers Groundwater Protection Unit
Telephone: [phone]
E-Mail: [e-mail]
A. Permit Number: WI0100106
B. Owner: Milko, Inc./Andrei Industries
D. Application:
❑ David May, WaRO-APS
❑ Morella Sanchez King, WiRO-APS
❑ Sherri Knight, W-SRO-APS
Fax [phone]
❑ Proposed ® Existing ❑ Facility ' ❑ Operation
I Permit Type: ❑ Animal ❑ SFR-Surface Irrigation❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
® UIC —Groundwater Remediahon Well .
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2 Project Tyke: ❑ New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ® Renewal w/ Mod.
E. Comments/Other Information: ❑
NOTE.!
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Please take the following actions:
® Return a Completed APSARR Form.
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO.*
* Remember that you will be responsible for coordinating site visits and reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer:
Date:
FORM: APSARR 07/06 Page 1 of 1

1 % Milk Solution Health Risk Evaluation -
From: Rudo, Ken
Sent: Tuesday, August 17, 2010 9:41 AM
To: Slusser, Thomas
Subject: 1 % Milk Solution Health Risk Evaluation
Mr.Slusser, I have evaluated the information of the use of the 1 % milk solution for enhanced
bioremediation at the former Andrex Industries Corp Site in Asheville, NC. I have reviewed the
composition analysis and the statements regarding the absence of private wells and public water
use of the groundwater in the area based on the information provided for me in the 7/7/10 memo.
Based on this information, there should not be any significantly increased human health risks
upon the use of this remediation product. If you have any further questions regarding this matter,
please feel free to contact me at 9f9-707-5911. Sincerely Kenneth Rudo, Ph.D, Toxicologist,
OEEB
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to
third parties by an authorized State official. Unauthorized disclosure of juvenile, health, legally privileged, or
otherwise
confidential information, including confidential information relating to an ongoing State procurement effort, is
prohibited by
law. If you have received this e-mail in error, please notify the sender immediately and delete all records of this
e-mail.
Page 1

It Im NO
Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone] !17;K vrti'ill�j/
LETTER OF TRANSMITTAL
TO: Milkco, Inc.ty
220 Deaverview Road onai pPewbns Sew
Asheville, NC 28816
ATTENTION:
Mr. Keith Collins — Milkco, Inc. -1 copy iv/�CD
CC:
Mr. Stephen. Gottdiener - Andrex —1 copy w/ CDs
Ms. Tracy Wahl — NCDEQ—Brownfields�=.CD Only:;,
Mr. Andrew Moore; P G. - NCDEQ (ARO)--DWR_-�1 Copy w/ CD
Mi% Michael Rogers, P.G NCDEQ =�Oe Program 1 copy w/ CD
DATE:
August 23, 2019
RE:
2018 Groundwater and Surface Water.Report dated UL*d ,
Former Andrex Industries Corp.. f ;.�
BLE Project No: J18-1022-51
WE ARE SENDING
YOU: •p`
® Attached
❑ Under separate cover via: U.S. MAIL
. :w•�c
® Report
❑ Prints ❑ Change order ❑Letter ❑Copy ofreport
'
❑ Other
❑ W.A.S. ' ❑ Plans ❑-Samples •❑' Specifications,.
❑ Proposal
❑ Preliminary Data:
!A
A`
THESE ARE TRANSMITTED AS CHECKED BELOW: 4 ,
❑ For approval
❑ For your use ❑, As requested ❑ Other ® For project records
Number of copies:
As specified above.
4;
REMARKS:='}.Keith,
I have enclosed oiW" 6pyyof the subject report and have transmitted copies to others on behalf of Milkco
as shown above. ;Q - -
Andrew ex6nder, P.G., RSM
Senior Hydrogeologist
c:\users\andy.O.eiander\bunnell-lammons engineering inc\solid waste projects - files\02 awa projects\andrex milkco\phase5l gw samp
2018\1022-51 r'port\transmittal 2018 gw report.docx

Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL
TO: Underground Injection Control Program
NC Division of Water Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
ATTENTION: Mr. Michael Rogers, P.G. —1 Copy w/ CD
~"nK
AUG $ 8 2019
Reglorle, enly
o` fi�d na
secoom
CC: Mr. Keith Collins — Milkco, Inc. —1 Copy w/ CD
Ms. Tracy Wahl — NCDEQ—Brownfields — CD Only
Mr. Stephen Gottdiener — Andrex —1 Copy w/ CD
Mr. Andrew Moore, P.G. — NCDEQ (ARO)—DWR —1 Copy w/ CD
DATE: August 23, 2019
RE: Interim Evaluation Report — 2018 Injection & Monitoring
Former Andrex Industries Corp.
UIC Permit No. W10100106
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
® Report ❑ 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 requested ❑ Other
Number of copies: As specified above.
REMARKS: Michael,
Copies of the subject document are transmitted as shown.
❑ Application
❑ Specifications
® For project records
A4'/
Andrew W. Alexinder, P.G. RSM
Senior Hydrogeologist
https://blecorp.sharepoint.com/sites/sw/files/02 awa projects/andrex milkco/phase50 monitoring 2018/1022-50 interim evaluation
report/transmittal 2018 ier andrex.docx

Routine Monitoring Report Review (RMRR) Checklist
Permit No.: WI0100106
Report Name: 2018 Annual Rgpt
Date Stamped in Received: 8/28/2019
Reviewer: MR
Date Reviewed: 3-10-20 (glanced at it last fall)
1. BIMS: Permit Issued date: 12/1/2018 . Expiration date:
11/30/23 . If Expired, check with Permittee if they want to renew. If
not will need to close out permit and send completion permit letter, and make permit
"Inactive" in BIMS.
2. For Non -Discharge (Now referred to as Injection Closed -loop GW Remediation)
- permit; if they don't want to renew, they will have to request rescission.
3. BIMS: Log report in Events Tab. Select-> `Compliance Schedule Met' and enter name
and date of report, and date we received. Also, note that a RMRR was completed and
inserted into report. Date Completed: 3/10/2020
4. BIMS: For 5I/In-Situ reports- Has Injection Event Report (IER) been received and info
entered into BIMS Y (Yes, No, or N/A). If No, check file to see if
we have received and then enter into BIMS. If never received, then request from
Consultant and CC Permittee via email. After receipt of IERs from these parties enter
into BIMS.
For Non-Discharge/Closed-Loop reports- Is billing is up to date? (Yes, No,
or N/A). If past due, notify Permittee/Consultant via email, and include contact info for
Peggie Simpson to send payment (contact info below).
NC Department of Environmental Quality
Division of Water Resources
Budget Office
Attn: Peggie Simpson
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
919-707-3698
5. BIMS: Check Wells Tab and see if GW-is/GW-30s (if applicable) have been entered:
Y (Yes, No, or N/A). If No, and well status is still `proposed', then
check file to see if we have received GW-ls and then enter into BIMS. If not received,
then request from consultant and CC Permittee. After receipt from these parties, enter as -
built well construction into BIMS (change status of well from proposed to `Active'); and
well abandonment data, if applicable.
Continued On Other Side
Page 1 of 2 Rev. 3-8-2020

6. For 5I/In-situ groundwater remediation reports- Do a quick review of report to see if
there are any obvious impacts from injection activities by reading Summary and
Conclusions/Recommendation Section, and monitoring data tables. Compare pre -
injection levels of sulfate, iron, phosphate, etc. to post injection levels and note this
below. If there are no impacts evident, indicate `No impacts from injection evident'.
Note: The groundwater quality at the site must be monitored until concentrations
meet pre -injection levels or 2L standards before the permit can eventually be
Completed in BUMS, and a Completion Letter Sent to Permittee.
For Non -Discharge reports- Also check influent and effluent concentrations, most
permits require a minimum 95% reduction in concentrations.
NOTES/COMMENTS:
Evaluation of milk effectiveness continuing. Requested an update on status of injection
wells via email. Monitoring to continue.
7. When this Monitoring Report Review is complete, securely insert inside cover of
monitoring report and file. Done? Y (Y or N).
Page 2 of 2 Rev. 3-8-2020

11101MM0
Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615 �ry�
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL SEP 5 201�
TO: Milkco, Inc. l.tu;ors en- C�1 011
220 Deaverview Road Operat►
Asheville, NC 28816
ATTENTION: Mr. Keith Collins — Milkco, Inc. -1 copy w/ CD
CC: Mr. Stephen Gottdiener — Andrex —1 copy w/ CDs
Ms. Tracy Wahl — NCDEQ—Brownfields — CD Only
Mr. Andrew Moore, P.G. — NCDEQ (ARO)—DWR —1 Copy w/ CD
Mr. Michael Rogers, P.G. NCDEQ — UIC Program --1 copy w/ CD
DATE:
August 31, 2018
RE: 2017 Groundwater and Surface Water Report dated August 30, 2018
Former Andrex Industries Corp.
BLE Project No. J17-102249
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
® Report ❑ 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 requested ❑ Other
Number of copies: As specified above.
REMARKS: Keith,
❑ Copy of report
❑ Specifications
® For project records
I have enclosed one copy of the subject report and have transmitted copies to others on behalf of Milkco
as shown above.
atl a4 Z.44�
Andrew W. Ale nder, P.G., RSM
Senior Hydrogeologist
s:\02 awa projects\andrex milkco\phase49 gw samp 2017\1022-49 report\transmittal 2017 gw report.docx

IM�e
a
Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL
TO: Underground Injection Control Program
NC Division of Water Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
ATTENTION: Mr. Michael Rogers, P.G. —1 Copy w/ CD
CC: Mr. Keith Collins — NMco, Inc. —1 Copy w/ CD
Ms. Tracy Wahl — NCDEQ—Brownfields — CD Only
Mr. Stephen Gottdiener — Andrex —1 Copy w/ CD
Mr. Andrew Moore, P.G. — NCDEQ (ARO)—DWR —1 Copy w/ CD
DATE: August 31, 2018
RE: Interim Evaluation Report — 2017 Injection & Monitoring
Former Andrex Industries Corp.
UIC Permit No. WI0100106
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
® Report ❑ Prints ❑ Change order ❑ Letter ❑ Application
❑ Other ❑ W.A.S. ❑ Plans ❑ Samples ❑ Specifications
❑ Proposal ❑ Preliminary Data:
THESE ARE TRANSMITTED AS CHECKED BELOW:
❑ For approval ❑ For your use ❑ As requested ❑ Other ® For project records
;�cE1,►��,►�1cn��nw
Number of copies: As specified above.
SEP - 2013
REMARKS: Michael, Water Quality Regional
Copies of the subject document are transmitted as shown. ')neiations Secti,)n
A4./ a4 Z.44�
Andrew W. Ale nder, P.G. RSM
Senior Hydrogeologist
s:\02 awa projects\andrex milkco\phase48 monitoring 2017\1022-48 interim evaluation report\transmittal 2017 ier andrex.docx

MIL13 1 DD) 0 6
Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615 RECEIVEDINCDEOIDWR
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL MAR 0 7 W6
TO: Milkco Inc. Water Quality
220 Deaverview Road Regional Operations Sectiura
Asheville, NC 28816
ATTENTION: Mr. Keith Collins — Milkco, Inc. -1 copy w/ CD
CC: Mr. Stephen Gottdiener — Andrex —1 copy w/ CDs
Ms. Tracy Wahl — NCDEQ—Brownfields -1 Copy w/ CD
Mr. Andrew Moore — NCDEQ (ARO)—DWR —1 Copy w/ CD
Mr. Mike Rogers —NCDEQ — UIC Program --1 copy w/ CD
DATE: March 3, 2016
RE: 2015 Groundwater and Surface Water Report dated February 29, 2016
Former Andrex Industries Corp.
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
® Report ❑ Prints ❑ Change order ❑ Letter ❑ Copy of report
❑ Other ❑ W.A.S. ❑ Plans ❑ Samples ❑ Specifications
❑ Proposal ❑ Preliminary Data:
THESE ARE TRANSMITTED AS CHECKED BELOW:
❑ For approval ❑ For your use ❑ As requested ❑ Other ® For project records
Number of copies: As specified above.
REMARKS: Keith,
I have enclosed one copy of the subject report and have transmitted copies to others on behalf of Milkco
as shown above.
A4/aze4e4i-
Andrew W. Alemifnder, P.G.
Senior Hydrogeologist
e:\awa projects\andrex milkco\phase43 gw samp 2015\transmittal 2015 gw report.docx

Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
TO:
ATTENTION:
CC:
DATE:
LETTER OF TRANSMITTALCaNc���p
Underground Injection Control Program MAR
NC Division of Water Resources U 7 2016
1636 Mail Service Center
Raleigh, North Carolina 27699-1636 Reg io water Qua►!ty
"al oae,avo„s section
Mr. Mike Rogers —1 Copy w/ CD
Mr. Keith Collins — Milkco, Inc. —1 Copy w/ CD
Ms. Tracy Wahl — NCDEQ—Brownfields -1 Copy w/ CD
Mr. Stephen Gottdiener — Andrex —1 Copy w/ CD
Mr. Andrew Moore — NCDEQ (ARO)—DWR —1 Copy w/ CD
March 3, 2016
RE: Interim Evaluation Report —
2015 Injection & Monitoring dated February 29, 2016
Former Andrex Industries Corp.
UIC Permit No. W10100106
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
® Report ❑ 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 requested ❑ Other
Number of copies: As specified above.
REMARKS: Mike,
Copies of the subject document are transmitted as shown.
❑ Application
❑ Specifications
® For project records
LAW
Andrew W. Alex6nder, P.G.
Senior Hydrogeologist
e:\awa projects\andrex milkco\phase42 injection and monitoring 2015\102242 interim evaluation report\transmittal 2015 ier
andrex.docx

Bunnell-Lammons Engineering, Inc. KtUrIVrU►i��.�.:c�,tila�rs<
6004 Ponders Court
Greenville, South Carolina 29615 A U G 3 12017
Phone [phone] FAX [phone]
Water Quality Regional
LETTER OF TRANSMITTAL Operations Section
TO: Milkco, Inc.
220 Deaverview Road
Asheville, NC 28816
ATTENTION: Mr. Keith Collins — Milkco, Inc. -1 copy w/ CD
CC: Mr. Stephen Gottdiener — Andrex —1 copy w/ CDs
Ms. Tracy Wahl — NCDEQ—Brownfields -1 Copy w/ CD
Mr. Andrew Moore — NCDEQ (ARO)—DWR —1 Copy w/ CD
Mr. Mike Rogers —NCDEQ — UIC Program —1 copy w/ CD
DATE: August 29, 2017
RE: 2016 Groundwater and Surface Water Report dated August 29, 2017
Former Andrex Industries Corp.
BLE Project No. J16-102247
WE ARE SENDING YOU:
® Attached ❑ Under separate cover via: U.S. MAIL
® Report ❑ 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 requested ❑ Other
Number of copies: As specified above.
REMARKS: Keith,
❑ Copy of report
❑ Specifications
® For project records
I have enclosed one copy of the subject report and have transmitted copies to others on behalf of Milkco
as shown above.
4(/&/ A414,�
Andrew W. Allevinder, P.G.
Senior Hydrogeologist
s:\02 awa projects\andrex milkco\phase47 gw samp 2016\1022-47 repor6transmittal 2016 gw report.docx

Routine Monitoring Report Review (MRR) Checklist
Permit No.: (,J r6 i D 0 / C) G
Permittee/Facility Name:
T 4 l (_(Cy — iY! & t7&&,6X
Report Name and Date:
Reviewer: /art • R .
Date Reviewed: 9/
1. BIMS: Permit issued date: Expiration date: //00/a
. If Expired, check with Permittee if they want to renew. For
Non -Discharge (ND) permit, if they don't want to renew, they will have to request
rescission.
2. BIMS: Log report in Events Tab. Select-> `Compliance Schedule Met' and enter name
and date of report, and date we received. Also, note that a MRR was completed and
inserted into report.
3. BIMS: For SI reports- has Injection Event Report (IER) been received and info entered
into BIMS (Yes or No). If No, check file to see if we have received and then
enter into BI S. If never received, then request from Consultant and CC Permittee via
email. After receipt of IERs from these parties, enter into BIMS. For ND reports- Also,
check if billing is up to date. If past due, notify Permittee/Consultant via email, and
include contact info for Teresa Revis to send payment (contact info below).
NC Department of Environmental Quality
Division of Water Resources
Budget Office
Attn: Teresa Revis
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
[phone]
4. BIMS: Check Wells Tab and see if GW-is/GW-30s (if applicable) have been entered:
(Yes or No). If No and well status is still `proposed', then check file to see if
we have received GW-ls and then enter into BIMS. If not received, then request from
consultant and CC Permittee. After receipt from these parties, enter as -built well
construction into BIMS; and well abandonment data, if applicable.
Page 1 of 2 Rev. 7-17-2017

5. For 5I reports- Do a quick review of report to see if there are any obvious impacts from
injection activities by reading Summary and Conclusions/Recommendation Section, and
monitoring data tables. Compare pre -injection levels of sulfate, iron, phosphate, etc. to
post injection levels and note this below. Also, note if there are any spikes in daughter
products. If there are no impacts evident, indicate `No impacts from injection evident'.
NOTE: The groundwater quality at the site must be monitored until concentrations meet
pre -injection levels or 2L standards before the permit can eventually be Completed in
BIMS, and a Completion Letter Sent to Permittee.
For Non -Discharge reports- Also check influent and effluent concentrations, most
permits require a minimum 95% reduction in concentrations. ,D
NOTES: 6 G D
6. When this Monitoring Report Review is complete, securely insert inside cover of
monitoring report and file.
Page 2 of 2 Rev. 7-17-2017

Bunnell-Lammons Engineering, Inc.
6004 Ponders Court
Greenville, South Carolina 29615
Phone [phone] FAX [phone]
LETTER OF TRANSMITTAL
TO: Underground Injection Control Program
NC Division of Water Resources
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
ATTENTION: Mr. Mike Rogers —1 Copy w/ CD
CC: Mr. Keith Collins — Milkco, Inc. —1 Copy w/ CD
Ms. Tracy Wahl — NCDEQ—Brownfields -1 Copy w/ CD
Mr. Stephen Gottdiener — Andrex —1 Copy w/ CD
Mr. Andrew Moore — NCDEQ (ARO)—DWR —1 Copy w/ CD
DATE: August 29, 2017
RE: Interim Evaluation Report — 2016 Injection & Monitoring
Former Andrex Industries Corp.
UIC Permit No. W10100106
WE ARE SENDING YOU:
® Attached [:]Under separate cover via: U.S. MAIL
® Report ❑ 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 requested ❑ Other
Number of copies: As specified above.
REMARKS: Mike,
Copies of the subject document are transmitted as shown.
❑ Application
❑ Specifications
® For project records
RECENEWDEWWR
AUG 31 2017
Water Quality Regional
Operations Section
&1 /
Andrew W. Alexinder, P.G.
Senior Hydrogeologist
s:\02 awa projects\andrex milkco\phase46 injection and monitoring 2016\1022-46 interim evaluation report\transmittal 2016 ier
andrex.docx