WI0100106_Groundwater Injection Plan 2015_20141222

BUNNELL-LAMMONS ENGINEERING, INC.
GEOTECHNICAL, ENVIRONMENTAL AND CONSTRUCTION MATERIALS CONSULTANTS

6004 PONDERS COURT PHONE [phone]
GREENVILLE, SOUTH CAROLINA 29615 FAX [phone]

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 1st 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.

Injection Plan for the 2015 Calendar Year December 22, 2014
Former Andrex Industries, Asheville, North Carolina BLE Project Number J14-1022-38
2
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.

Injection Plan for the 2015 Calendar Year December 22, 2014
Former Andrex Industries, Asheville, North Carolina BLE Project Number J14-1022-38
3
Injection Well Construction Diagrams

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.

Andrew W. Alexander, P.G., RSM Trevor J. Benton, P.G.,
Senior Hydrogeologist Project Hydrogeologist
Registered, NC No. 1475 Registered, NC No. 2025

Attachments: Revised Figure 2 & Figure 3
Revised Tables 2, 3, & 4
Well Construction Diagrams for IW-1 and IW-3

e:\awa projects\andrex milkco\phase38 injection & monitoring 2014\injection & monitoring plan 2015\2015 injection plan andrex 1022-
38.doc

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
Injection Point or Monitoring WellYear One (2014)Year Two (2015)Year Three (2016)Year Four (2017)Year Five (2018)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.
Table 2 Inst Schedule of 1022-38 Andrex Injection Permit Tables 2015 Plan.xlsx
Prepared by : AWA
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 X 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.
Table 3 Injection Schedule of 1022-38 Andrex Injection Permit Tables 2015 Plan.xlsx
Prepared by : AWA
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
Injection Point/AreaMonitoring Station30 Days After Injection Event Completion90 Days After Injection Event Completion150 Days After Injection Event CompletionAnnually VOCs and TOCAnnually VOCs OnlySemi-Annual VOCs and TOCGroundwater
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.
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.*
Table 4 Monitoring Plan of 1022-38 Andrex Injection Permit Tables 2015 Plan.xlsx
Prepared by : AWA
Checked by: TJB

FIGURES

APPENDIX A

INJECTION WELL
CONSTRUCTION DIAGRAMS