WI0100106_Injection Event Record_20141222

IBLE
BUNNELL-LAMMONS ENGINEERING, INC.
GEOTECHNICAL, ENVIRONMENTAL AND CONSTRUCTION MATERIALS CONSULTANTS
December 22, 2014
Underground Injection Control Program
Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Attention: Mr. Mike Rogers
Subject: Injection Plan for the 2015 Calendar Year
UIC Permit No. WI0100106
Former Andrex Industries Facility
180 Deaverview Road
Asheville, North Carolina
BLE Project Number J14-1022-38
Groundwater Incident Number 6586
Brownfields Project Number 07022-03-11
Dear Mr. Rogers:
Bunnell-Lammons Engineering, Inc. (BLE) is pleased to submit this injection plan for the 2015
calendar year. This document is prepared in response to an email request dated December 17, 2014
from the NCDENR. The requirements for the contents of this document were discussed in several
emails between Mr. Andrew Alexander of BLE and Mr. Rogers, Mr. Landon Davidson, and Mr.
Andrew Moore of the NCDENR.
As discussed in our emails, BLE has completed the final sampling event (150 day) for the 2014
injection project at Andrex and have recently received the lab data. Recall that we installed one
injection well (IW-2) in 2014 and injected and monitored in the IW-2 area per the approved
monitoring matrix. BLE is preparing an interim evaluation report and an annual monitoring report
for 2014 which will be issued in the 1 st quarter of 2015.
Milkco and BLE are currently planning for injection in the 2015 calendar year. We are planning to
install injection wells IW-1 and IW-3 in 2015 based on the 2014 results. However, the injection
wells need to be moved from their permitted locations (about 100 lateral feet for IW-1 and 125
lateral feet for IW-3). Additionally, these wells need to be installed to shallower depths (60 feet bgs
vs 85 feet bgs) to remediate the upper groundwater. Please note that we are not proposing a change
to the approved injection well construction specifications. The monitoring matrix must be modified
so that remediation in these areas can be adequately monitored based on the new injection well
locations. No change is planned to the previously approved 30, 90, and 150-day monitoring
frequency.
It was agreed in the aforementioned emails that BLE would prepare revised tables, map, profiles,
and proposed construction diagrams which illustrate the changes for the 2015 calendar year.
6004 PONDERS COURT PHONE [phone]
GREENVILLE, SOUTH CAROLINA 29615 FAX [phone]

Injection Plan for the 2015 Calendar Year December 22, 2014
Former Andrex Industries, Asheville, North Carolina BLE Project Number J14-1022-38
Injection Zone Illustrations
The Proposed Injection Well Plan (Figure 2) has been modified to include an illustration of the
actual installation location of injection well IW-2 and monitoring well MW-44 (both installed in
2014). The figure also shows the planned relocation of injection well IW-1 and IW-3 in 2015. This
figure has been modified to include the results of the 2014 annual groundwater sampling event
(report pending).
The Hydrogeologic Profiles of the Affected Area (Figure 3) has been modified to include an
illustration of the actual installation location and depth of injection well IW-2 (installed in 2014).
The figure also shows the planned relocation and depths of injection well IW-1 and IW-3 in 2015.
Please note that these injection wells now target the contaminated upper groundwater in the source
area. Please note that the actual locations and depths of the proposed injection wells will be
determined in the field based on site access and observed hydrogeology (water bearing fractures,
depth to bedrock and groundwater, etc.). This figure has also been modified to include the results of
the 2014 annual groundwater sampling event (report pending).
Well Installation Plan
The Well Installation Plan (Table 2) has been modified to document installation of IW-2 and MW-
44 in the 2014 calendar year and to show planned installation of in IW-1 and IW-3 in the 2015
calendar year. Additionally, the installation schedule for 2016 through 2018 has been cleared since
we now anticipate adjusting the future installation schedule based on results from the prior year and
on available project budget.
Injection Schedule
The Injection Schedule (Table 3) has been modified to document injection in IW-2 in the 2014
calendar year and to show planned injection in IW-1 and IW-3 in the 2015 calendar year.
Additionally, injection schedule for 2016 through 2018 has been cleared since we now anticipate
adjusting the future injection schedule based on results from the prior year and on available project
budget.
Injection Monitoring Plan Matrix
The Injection Monitoring Plan Matrix (Table 4) has been modified to designate injection in IW-1 and
IW-3 and to include the associated monitoring in those specific injection areas during the 2015
calendar year. Those wells are demarcated on the table with bold red text. Please note that
monitoring is not performed in areas where injection is not occurring. Monitoring will occur on an
annual basis for all wells and surface water points as required. The table has also been modified to
include the requirement for semi-annual surface water monitoring of BC-1 and JW-1 as specified in
the UIC permit.
2

Injection Plan for the 2015 Calendar Year
Former Andrex Industries, Asheville, North Carolina
Injection Well Construction Diagrams
December 22, 2014
BLE Project Number J14-1022-38
Injection well construction diagrams for IW-1 and IW-3 (Appendix A) have been prepared based on
anticipated subsurface conditions. Please note that the actual depths of the injection wells will be
determined in the field based on observed hydrogeology (water bearing fractures, depth to bedrock
and groundwater, etc.). The proposed construction is in accordance with the previously approved
construction specifications in the permit.
Closing
We appreciate the opportunity to work with you at the subject site. We look forward to receiving
NCDENR approval of the injection plan for the 2015 calendar year. If you have any questions,
please do not hesitate contacting us at [phone].
Sincerely,
BUNNELL-LAMMONs ENGINEERING, INC.
&&/ A"W4--t-
Andrew W. Alex nder, P.G., RSM
Senior Hydrogeologist
Registered, NC No. 1475
Attachments: Revised Figure 2 & Figure 3
Revised Tables 2, 3, & 4
Well Construction Diagrams for IW-1 and IW-3
Trevor J. Bento P.G.
Project Hydrogeologist
Registered, NC No. 2025
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TABLES

Table 2
Well Installation Plan (Revised for the 2015 Calendar Year)
Andrex Industries
Asheville, North Carolina
NCDENR Groundwater Incident Number 6586
BLE Project No. J14-1022-38
3
0
°
o00
a
MW-3R
MW-8R
MW-25R
MW-44
X
IW-1
X
IW-2
X
IW-3
X
IW-4
IW-5
IW-6
IW-7
IW-8
IW-9
IW-10
IW-11
IW-12
Notes:
X - Well Scheduled for Installation.
Installations beyond 2015 will be determined based on 2015 results.
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 1022-38 Andrex Injection Permit Tables 2015 Plan.xlsx Checked by: TJB

Table 3
Injection Schedule (Revised for the 2015 Calendar Year)
Andrex Industries
Asheville, North Carolina
NCDENR Groundwater Incident Number 6586
BLE Project No. J14-1022-38
Well
Year One (2014)
Year Two (2015)
Year Three (2016)
Year Four (2017)
Year Five (2018)
RW-3
XB
IW-1
X
IW-2
XB
IW-3
X
IW-4
IW-5
IW-6
IW-7
IW-8
IW-9
IW-10
IW-11
IW-12
Notes:
X = Injection scheduled
XB = Injection may be performed based on monitoring results.
Injections beyond 2015 will be based on 2015 results.
An injection volume of up 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.
Prepared by: AWA
Table 3 Injection Schedule of 1022-38 Andrex Injection Permit Tables 2015 Plan.xlsx Checked by: TJB

Table 4 (Revised for the 2015 Calendar Year)
Injection Monitoring Plan Matrix
Andrex Industries
Asheville, North Carolina
NCDENR Groundwater Incident Number 6586
BLE Project No. J14-1022-38
y
a
0
U
W
0
Q
0
U
W
00
o
�
o
U
v
F
T
FO
y
O
ti
Q
O
b
UO
CIO
Groundwater
RW-3 and/or *IW-1*
*RW-3*
X
X
X
X
*MW-5*
X
X
X
X
*MW-12*
X
X
X
X
IW-2 and/or *IW-3*
*IW-2*
X
X
X
X
*RW-1*
X
X
X
X
*MW-6*
X
X
X
X
*MW-44*
X
X
X
X
None
MW-3R
IW-4
MW-7
X
X
X
X
IW-5
MW-8R
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
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. EMME
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.
* Injection / monitoring in the 2015 calendar year.*
Prepared by: AWA
Table 4 Monitoring Plan of 1022-38 Andrex Injection Permit Tables 2015 Plan.xlsx Checked by: TJB

FIGURES

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LEGEND
I z
v NOTES:
PROPOSED INJECTION WELL (IW-1 AND IW-3 THROUGH IW-12)
1.
LABORATORY ANALYSIS BY EPA METHOD 8260.
z
2.
WELLS AND SURFACE WATER WAS SAMPLED ON SEPTEMBER 2-5, 2014.
��
PROPOSED MONITORING WELL (MW-3R, MW-8R, AND MW-25R)
3.
CONCENTRATIONS DETECTED IN MW-21 ARE PRIMARILY CHLOROFORM,
PROBABLY RELATED TO LEAKING WATER SUPPLY LINES IN CLOSE
APPROXIMATE LOCATION OF EXISTING (SAPROLITE OR SHALLOW
PROXIMITY TO THE WELLS.
BEDROCK) GROUNDWATER MONITORING WELL
4.
SAMPLES FROM STREAMS DESIGNATED AS FOLLOWS:
SM = SMITH MILL CREEK TRIBUTARY
0
APPROXIMATE LOCATION OF EXISTING (TYPE III -BEDROCK)
CS = CECIL'S SPRING
GROUNDWATER MONITORING WELL
BC = BEAR CREEK
JW = FORMER JEHOVAH WITNESS PROPERTY
0
RECOVERY WELL
5.
NP = NOT PRESENT, WELL WAS NOT PRESENT AT TIME OF SAMPLING.
APPROXIMATE LOCATION OF SURFACE WATER SAMPLES (SEE NOTE 4)
GAR'rr�rr��'
�bfi
6.
�k�k SKY LANES BOWLING CENTER
WATER SAMPLES COLLECTED 9-5-14 .
( )
.` Q� `•
' �=
NCDEH - PUBLIC WATER SYSTEM ID #10-11-025
WELL NAME: WELL #1
JGENS
?
AS OF 5-19-2009, MR. MARC FOWLER OF BUNCOMBE COUNTY HAS STATED
O
WATER SUPPLY WELL
s S =
"...THE ESTABLISHMENT HAS BEEN RESTORED TO CITY WATER."
1475 ¢
162
CONCENTRATION OF TOTAL DETECTED CHLORINATED VOLATILE ORGANIC
FOLOd�•'�'�'��
7.
* THE WELLS MAY INTERCEPT FRACTURE SETS OR MAY BE SCREENED AT
COMPOUNDS IN PARTS PER BILLION (ppb).
':d
ELEVATIONS AT WHICH GROUNDWATER CONTAMINANT CONCENTRATIONS ARE
INCONSISTENT WITH THE ESTABLISHED PLUME. THE VALUES WERE IGNORED FOR
BELOW GROUND STREAM SHOWING FLOW DIRECTION
'rrrrrr,�m,`'�
CONTOURING PURPOSES.
8.
THE FORMER WATER SUPPLY WELL ON THE CRYDERMAN PROPERTY APPEARED
ABOVE GROUND STREAM SHOWING FLOW DIRECTION
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
PROPERTY LINE
DESTROYED BY GRADING PERFORMED BY THE CITY OF ASHEVILLE. MW-25 WAS
NOT PRESENT IN OCTOBER 2003 AND WAS PRESUMED TO BE DESTROYED BY
APPROXIMATE LOCATION OF SANITARY SEWER MANHOLE WITH SEWER LINE
GRADING PERFORMED BY MILKO, INC.
10.
RECOVERY WELLS WERE NOT OPERATIONAL AT THE TIME OF SAMPLING.
100
TOTAL CHLORINATED CONCENTRATION CONTOUR IN PARTS PER BILLION
REFERENCE: ORTHOPHOTO MAP OF BUNCOMBE COUNTY, N.C. PREPARED BY L. ROBERT KIMBALL & ASSOCIATES, EBENSBURG, PENNSYLVANIA 200 100 0 200
400
FROM PHOTOGRAPHY DATED MARCH-APRIL 1985 IN ACCORDANCE WITH NATIONAL MAP ACCURACY STANDARDS.
11.
AB =WELL ABANDONED IN 2008 PER APPROVED BROWNFIELD REDEVELOPMENT PLAN.
— Np
ESTIMATED LIMIT OF VOC'S
APPROXIMATE SCALE IN FEET
REVISIONS
No. DESCRIPTION BY
DRAWN:
ACE
CHECKED: AWA
APPROVED:
DATE: 12-19-14
CAD FILE:
ANDREX38-INJECTPLAN
JOB NO: J14-1022-38
BUNNELL-LAMMONS ENGINEERING, INC.
6004 PONDERS COURT
INC. PHONE: (64I)288 1 65 FAX: [phone]
PROPOSED INJECTION WELL PLAN FOR 2015
WITH CONTOUR MAP OF TOTAL CHLORINATED VOLATILE ORGANIC COMPOUND ISOCONCENTRATIONS - SEPTEMBER 2-5, 2014
ANDREX INDUSTRIES
ASHEVILLE, NORTH CAROLINA
FIGURE NO.
2

2245 -
2235
2225 -
2215
2205 -
2195
2185 -
J
Cf�
2175
~ 2165 -
LL
Z 2155
2145 -
W
w 2135
2125 -
2115
2105 -
2095
2085 -
2075
2065 -
2055 -
2225 -
2215
2205 -
2195
2185 -
2175
2165 -
2155
C%) 2145 -
2135
z 2125 -
0
~ 2115
Q
W
2105 -
W
2095
2085 -
2075
2065 -
2055
2045 -
2035
2025 -
MW
AB
ml
nji
II I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I r-7-7-7 I I
0 200 400 600 800 1000 1200 1400 1600 1800
DISTANCE, FT.
GEOLOGIC PROFILE A -A'
1 SOUT
2245
2235
2225
2215
2205
2195
2185
C/)
2175
2165 ~
LL
2155 z
0
2145
W
2135 LLJ
2125
2115
2105
2095
2085
2075
2065
2055
LEGEND
APPROXIMATE POTENTIOMETRIC SURFACE ON 9-2-2014
GROUND SURFACE
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 9/2-4/2014
AB WELL WAS ABANDONED
0
_ VERTICAL EXAGGERATION = 10X
N
SCALE 11nch
200 Feet
INJECTION ZONE
,'`,`t111#111#,,1
.�` CAAp�r
oNS 't
S =
1475 [r z NOTE:
7 A�� INJECTION WELLS IW-1, IW-3, IW-4, IW-5, IW-7, AND IW-11 ARE PROPOSED. ACTUAL CONSTRUCTION TO
;y0 Ctc�t�(��;;•'.10; BE DETERMINED IN THE FIELD.
too, it INJECTION WELLS IW-1 AND IW-3 ARE PROPOSED FOR INSTALLATION IN 2015
2225
2215
2205
2195
2185
2175
- 2165
2155
- 2145 C�
2135
Li
- 2125 Z
O
2115 ~
Q
I
- 2105
W
2095
2085
2075
2065
2055
- 2045
2035
2025
0
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'
REVISIONS
DRAWN:
ACE
DATE: 12-19-14
BUNNELL-LAMMONS ENGINEERING, INC.
GREEMALLE SOUTDHERCAROLINA 29615
IRLIEINC. PHONE: [phone] FAX: [phone]
HYDROGEOLOGIC PROFILES OF THE AFFECTED AREA FOR THE 2015 INJECTION PLAN
ANDREX INDUSTRIES
DEAVERVIEW ROAD
ASHEVILLE, NORTH CAROLINA
FIGURE NO.
No.
DESCRIPTION
BY
CHECKED:
AWA
CAD FILE: PROFILE FOR 2015 PLAN
3
APPROVED: TLL
JOB NO:
J13-1022-38

APPENDIX A
INJECTION WELL
CONSTRUCTION DIAGRAMS

PROPOSED IW-1 BEDROCK INJECTION WELL
CONSTRUCTION DIAGRAM
4-INCH THICK
3' X 3' CONCRETE PAD
GROUND SURFACE
2-FEET CEMENT GROUT
TOP OF BEDROCK
(ESTIMATED 40 FEET)
2-FEET OF PEA GRAVEL
#3 STONE
(ESTIMATED 17.5 FEET)
GROUNDWATER LEVEL
JOB NO.: J14-1022-38
DATE:
12-18-14
SCALE: NOT TO SCALE
10-INCH AIR -HAMMERED
BOREHOLE
IRLEINC.
BUNNELL-LAMMONS ENGINEERING, INC.
6004 PONDERS COURT
GREENVILLE, SOUTH CAROLINA 29615
PHONE: [phone] FAX: [phone]
FLUSH MOUNT STEEL
WELL COVER
COMPRESSION
WELL CAP
BENTONITE SEAL
(38.5 FEET)
6-INCH ID PVC RISER
TOP OF BEDROCK
TOTAL DEPTH
OF BORING
(ESTIMATED 60 FEET)
PROPOSED IW-1
BEDROCK INJECTION WELL DIAGRAM
FORMER ANDREX INDUSTRIES
ASHEVILLE, NORTH CAROLINA
FIGURE

PROPOSED IW-3 ABOVE BEDROCK INJECTION WELL
CONSTRUCTION DIAGRAM
4-INCH THICK
3' X 3' CONCRETE PAD
GROUND SURFACE
FLUSH MOUNT STEEL
WELL COVER
COMPRESSION
WELL CAP
2-FEET CEMENT GROUT °
as
3-FEET BENTONITE SEAL
TO GROUNDWATER SURFACE
(ESTIMATED 45 FEET)
(ESTIMATED 40 FEET) GRAVEL
6-INCH ID PVC RISER
GROUNDWATER LEVEL
� o 0
TOTAL DEPTH
#3 STONE o OF BORING
(ESTIMATED 15 FEET) (ESTIMATED 60 FEET)
0 0
�o 0
10-INCH AIR -HAMMERED
BOREHOLE
BORING TERMINATED AT
TOP OF BEDROCK
(ESTIMATED 60 FEET)
JOB NO.: J14-1022-38 INC.IGURE
NIL�PROPOSED IW-3
DATE: ABOVE BEDROCK INJECTION WELL DIAGRAM
12-18-14 BUNNELL-LAMMONS ENGINEERING, INC. FORMER ANDREX INDUSTRIES '���
SCALE: 6004 PONDERS COURT ASHEVILLE, NORTH CAROLINA
NOT TO SCALE GREENVILLE, SOUTH CAROLINA 29615
PHONE: [phone] FAX: [phone]