WI0100106_Permit (Modification)_20131119

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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:
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 request 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]

MILE
Addendum UIC Permit Application — Renewal with Modification November 19, 2013
Former Andrex Industries, Asheville, North Carolina BLE Project Number J12-1022-35
Injection Zone Illustration
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 Figure 3) 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 (water bearing 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 MW-13 / 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
2

1`LIE
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 residents
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.
Atl A"40�
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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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
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Groundwater
RW-3 & IW-1
RW-3
X
X
X
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
IW-3
MW-311
X
X
X
X
IW-4
MW-7
X
X
X
X
IW-5
MW-811
X
X
X
X
MW-9
X
X
X
X
IW-6
None
IW-7
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
IW-9
RW-7
X
X
X
X
MW-11
X
X
X
X
IW-10
MW-23
X
X
IW-11
MW-24
X
X
X
X
IW-12
MW-25R
X
X
X
X
None
MW-15
X
MW-16
X
MW-17
X
MW-18
X
MW-20
X
MW-21
X
MW-22
X
MW-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
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 Zone.
VOC analyses performed by EPA Method 8260 MSV Low Level.
TOC analyses performed by SM Method 5310B.
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

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MW-26
ER CECICS LEGE RESIDENTIAL
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TWEN TH MW-2
r0 R 486
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CO. NC RESIDE AT 6,011 5,867 AB
1
r S0 oR\� Iw-12 Mw-s* Iw-
��� MW-25R MW-25 5s8 R IW-4 MW-7
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MW-44
WLKCO, j M B 3 _3 H ONES CORP.
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IW-5 MW-4
P--� RW62 AB sO \ _
HAVILTON
PROPERTY
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II COURTS I ����
I—
RUMBOUGH PLACE
REFERENCE: ORTHOPHOTO MAP OF BUNCOMBE COUNTY, N.C. PREPARED BY L. ROBERT KIMBALL & ASSOCIATES, EBENSBURG, PENNSYLVANIA
FROM PHOTOGRAPHY DATED MARCH—APRIL 1985 IN ACCORDANCE WITH NATIONAL MAP ACCURACY STANDARDS.
RESIDENTIAL
RESIDENTIAL
MID EDLMID MOB
i
1
ICE
RV \\
ORE—
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M i o
USTRIES, I �'
IW-7 Fri
R 58 IW—
MW-10
29 \�
MW-13
1,388
----------------------
SILVERS
PROPERTY
BOWLING MW-14*i►
RESIDENTIAL
9000
500
1,490
PROPERTY
RESIDENTIAL
NN�NVE
MW-20
ND
200 100 0 200 400
APPROXIMATE SCALE IN FEET
1
I
I
I
1
1
1
i
J
S CORP ���./
* rl
4.
iL•
J
- - SM-1
F ND
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SM-2 1 0
0.88 J 2
RESIDENTIAL
MW-23 _ — _ �� MW 2
95 I ` —
E
Mw-11\ROY D. EARVER BARK I SM-3 RASH ROAD
\ I 0._68 MW-21
2,191 \ I \ 0.66 (CHLOROFORM ONLY)
675 7 \ I } �\ MW-22
JW 1 \ ND
33 ,' FORMER JEHOVA4 \
SEXTON WITNESS PROPERTY.\BIESTERFEDLT
/� \ •PROPERTY
5 MW-19 ��RFo�K SOUTyE SM-4 �.
2.6 •�;
qi�
1 L— O FORMER READ 5�2.0
WATER WELL
SATTEREIELD � � - - CRYDERMAN
— — — w PROPERTY _ HOUSE - _ PROPERTY \
— ND — —
RESIDENTIAL
r
RESIDENTIAL
1. LABORATORY ANALYSIS BY EPA METHOD 8260.
2. WELLS AND SURFACE WATER WAS SAMPLED ON SEPTEMBER 10-13, 2012.
3. CONCENTRATIONS DETECTED IN MW-21 ARE PRIMARILY CHLOROFORM,
PROBABLY RELATED TO LEAKING WATER SUPPLY LINES IN CLOSE
PROXIMITY TO THE WELLS.
4. SAMPLES FROM STREAMS DESIGNATED AS FOLLOWS:
SM = SMITH MILL CREEK TRIBUTARY
CS = CECIL'S SPRING
BC = BEAR CREEK
JW = FORMER JEHOVAH WITNESS PROPERTY
5. NP = NOT PRESENT, WELL WAS NOT PRESENT AT TIME OF SAMPLING.
6. ** SKY LANES BOWLING CENTER
NCDEH — PUBLIC WATER SYSTEM ID #10-11-025
WELL NAME: WELL #1
AS OF 5-19-2009, MR. MARC FOWLER OF BUNCOMBE COUNTY HAS STATED
"...THE ESTABLISHMENT HAS BEEN RESTORED TO CITY WATER."
7. * THE WELLS MAY INTERCEPT FRACTURE SETS OR MAY BE SCREENED AT
ELEVATIONS AT WHICH GROUNDWATER CONTAMINANT CONCENTRATIONS ARE
INCONSISTENT WITH THE ESTABLISHED PLUME. THE VALUES WERE IGNORED FOR
CONTOURING PURPOSES.
8. THE FORMER WATER SUPPLY WELL ON THE CRYDERMAN PROPERTY APPEARED
TO BE ABANDONED AND COULD NOT BE SAMPLED AS OF OCTOBER 2005.
9. MW-19 WAS NOT PRESENT IN OCTOBER 2003 AND WAS PRESUMED TO BE
DESTROYED BY GRADING PERFORMED BY THE CITY OF ASHEVILLE. MW-25 WAS
NOT PRESENT IN OCTOBER 2003 AND WAS PRESUMED TO BE DESTROYED BY
GRADING PERFORMED BY MILKO, INC.
10. RECOVERY WELLS WERE NOT OPERATIONAL AT THE TIME OF SAMPLING.
11. AB =WELL ABANDONED IN 2008 PER APPROVED BROWNFIELD REDEVELOPMENT PLAN
PROPOSED INJECTION WELL (IW-1 THROUGH IW-12)
PROPOSED MONITORING WELL (MW-3R, MW-8R, MW-25R AND MW-44)
APPROXIMATE LOCATION OF EXISTING (SAPROLITE OR SHALLOW
BEDROCK) GROUNDWATER MONITORING WELL
INJECTION ZONE
0
APPROXIMATE LOCATION OF EXISTING (TYPE III —BEDROCK)
GROUNDWATER MONITORING WELL
0
RECOVERY WELL
-
APPROXIMATE LOCATION OF SURFACE WATER SAMPLES (SEE NOTE 4)
(WATER SAMPLES COLLECTED 9-13-12).
O
WATER SUPPLY WELL
162
CONCENTRATION OF TOTAL DETECTED CHLORINATED VOLATILE ORGANIC
COMPOUNDS IN PARTS PER BILLION (ppb).
—]f-- �—
BELOW GROUND STREAM SHOWING FLOW DIRECTION
—" �—
ABOVE GROUND STREAM SHOWING FLOW DIRECTION
PROPERTY LINE
APPROXIMATE LOCATION OF SANITARY SEWER MANHOLE WITH SEWER LINE
100
TOTAL CHLORINATED CONCENTRATION CONTOUR IN PARTS PER BILLION
ESTIMATED LIMIT OF VOC'S
REVISIONS
No. DESCRIPTION BY
DRAWN:
ACE
CHECKED: AWA
APPROVED:
DATE: 11-19-13
CAD FILE:
ANDREX35—INJECTPLAN
JOB NO: J12-1022-35
NIL
BUNNELL-LAMMONS ENGINEERING, INC.
6004 PONDERS COURT
INC. PHONE: (64I)288 1 65 FAX: [phone]
PROPOSED INJECTION WELL PLAN
WITH CONTOUR MAP OF TOTAL CHLORINATED VOLATILE ORGANIC COMPOUND ISOCONCENTRATIONS — SEPTEMBER 10-13, 2012
ANDREX INDUSTRIES
ASHEVILLE, NORTH CAROLINA
FIGURE NO.
2

2245
2235
2225
2215
2205
2195
2185
J
Cf�
2175
~ 2165
LL
Z 2155
O
2145
W
LiJ 2135
2125
2115
2105
2095
2085
2075
2065
2055
I AB
2225 -
2215
2205 -
2195
2185 -
2175
2165 -
2155
C� 2145 -
2135
z 2125 -
O_
~ 2115
Q
W
2105 -
W
2095
2085 -
2075
2065 -
2055
2045 -
2035
2025 -
m
♦kinnry uini lvT lrn
Fil
0 200 400 600 800 1000 1200 1400 1600 1800
DISTANCE, FT.
I SOUT
GEOLOGIC PROFILE A -A'
2245
2235
2225
2215
2205
2195
2185
I
C/)
2175
2165 ~
LL
2155 z
O
2145
W
2135 LLJ
2125
2115
2105
2095
2085
2075
2065
2055
CAA
JpENS'�'��
cs
sr 1475
A "
OL
LEGEND
APPROXIMATE POTENTIOMETRIC SURFACE ON 9-10-2012
GROUND SURFACE
75, Wr APPROXIMATE LOCATION OF BEDROCK ENCOUNTERED IN BORINGS
> GROUNDWATER FLOW DIRECTION
76 SCREENED OR OPEN BEDROCK INTERVAL WITH CONCENTRATION OF TOTAL CHLORINATED
VOLATILE ORGANICS IN ug/I ON 9/10-13/2012
AB WELL WAS ABANDONED
0
_ VERTICAL EXAGGERATION = 10X
N
SCALE 1I^ch
200 Feet
INJECTION ZONE
NOTE:
ALL INJECTION WELLS (IW—#) ARE PROPOSED. ACTUAL CONSTRUCTION TO
BE DETERMINED IN THE FIELD.
2225
2215
2205
2195
2185
2175
2165
2155
2145 C�
2135
Li
2125 z
O_
2115 ~
Q
W
2105
W
2095
2085
2075
2065
2055
2045
2035
2025
64�
�sa�d
A'
0 200 400 600 800 1000 1200 1400 1600 1800 2000 2200 2400 2600 2800 3000 3200 3400 3600 3800 PROFILE LOCATI ON PLAN
DISTANCE, FT.
GEOLOGIC PROFILE 13-13 )
I I
REVISIONS
DRAWN:
ACE
DATE: 11-19-13
BUNNELL—LAMMONS ENGINEERING, INC.
6004 GREEMALLE, SOUTDHERCAROLINA 29615
IRLIEINC. PHONE: [phone] FAX: [phone]
HYDROGEOLOGIC PROFILES OF THE AFFECTED AREA
ANDREX INDUSTRIES
DEAVERVIEW ROAD
ASHEVILLE, NORTH CAROLINA
FIGURE NO.
No.
DESCRIPTION
BY
CHECKED:
AWA
CAD FILE: PROFILE UIC PERMIT APPLICATION
3
APPROVED: TLL
JOB NO:
J12-1022-35