WI0100106_Addendum to UIC Permit Application 2013_20131119

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

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

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-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 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.

Addendum UIC Permit Application – Renewal with Modification November 19, 2013
Former Andrex Industries, Asheville, North Carolina BLE Project Number J12-1022-35
2

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

Addendum UIC Permit Application – Renewal with Modification November 19, 2013
Former Andrex Industries, Asheville, North Carolina BLE Project Number J12-1022-35
3
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.

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 Table 4
Revised Figure 2 & New Figure 3

c:\awa\active projects\andrex milkco\phase35 3rd injection, permit & ier\1022-35 permit renewal\permit addendum\addendum uic
permit app text renewal with modification andrex 1022-35.doc
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
Injection Point/AreaMonitoring Station30 Days After Injection Event Completion90 Days After Injection Event Completion150 Days After Injection Event CompletionAnnually VOCs and TOCAnnually VOCs OnlyGroundwater
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-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 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.
Table 4 Monitoring Plan of 1022-35 Andrex Injection Permit Tables Addendum.xlsx
Prepared by : AWA
Checked by: TJB