WI0100106_UIC Permit Renewal With Modification 2018_20180907

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-5I/5T)
Permit Renewal with Modification
UIC Permit No. WI0100106
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:

Bunnell-Lammons Engineering, Inc. (BLE) is pleased to 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 – 2017 Injection & Monitoring dated August 30, 2018 (BLE Project
No. J17-1022-48).

Report of Annual Groundwater and Surface Water Sampling and Analysis for 2017 dated August
30, 2018 (BLE Project No. J17-1022-49).

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)
In-Situ Groundwater Remediation Application Rev. 8-28-2017 Page 1 of 6
Permit Number (to be completed by DWR): WI
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 (generally the responsible party)
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: [e-mail]
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).
1. Name: Andrew W. Alexander, PG, RSM Title: Senior Hydrogeologist
2. Company: Bunnell-Lammons Engineering, Inc. (BLE)
3. Address: 6004 Ponders Court
4. City: Greenville State: SC Zip: 29615
5. Telephone number: 864-288-1265 Email: [e-mail]

In-Situ Groundwater Remediation Application Rev. 8-28-2017 Page 2 of 6
V. FACILITY INFORMATION
1. Facility name: Former Andrex Industries Corp. Phone No. if available: Not Applicable
2. Physical address: 180 Deaverview Road (Physical Address of Unoccupied Parcel)
City: Asheville County: Buncombe Zip: 28806
3. Geographic Coordinates: Latitude: N 35.580496 o Longitude: W 82.613115 o
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 Finishing Facility

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 Summary of Permits Issued revised (Table 1)

In-Situ Groundwater Remediation Application Rev. 8-28-2017 Page 3 of 6
VIII. INJECTION SUMMARY (See enclosed Injection Summary and Attachments additions)
1. List all proposed injectants/additives.

NOTE: Only injectants approved by the epidemiology section of the NC Division of Public Health, Department of
Health and Human Services can be injected. Approved injectants can be found online at
http://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/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.
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, etc.):
( Proposed well(s); Total No.: ; Well Type (DPT, Permanent, etc.):

7. NC Certified Well Drilling Contractor’s Name (if known):
NC Well Contractor Certification No.:

8. Date to be constructed if proposed: (attach GW-1s 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 4 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 5 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
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 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.

UIC Permit Renewal – 2018 September 7, 2018
Andrex Industries Corp., Asheville, NC BLE Project No. J18-1022-50

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INJECTION SUMMARY and ATTACHMENTS

VIII. INJECTION SUMMARY

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 IW-4
through IW-12. Those wells are listed on Table 4 and are shown on Figure 2.

UIC Permit Renewal – 2018 September 7, 2018
Andrex Industries Corp., Asheville, NC BLE Project No. J18-1022-50

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7) NC Certified Well Drilling Contractor’s Name

If injection wells are installed, BLE will utilize our drilling division Landprobe, LLC (J. 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.

UIC Permit Renewal – 2018 September 7, 2018
Andrex Industries Corp., Asheville, NC BLE Project No. J18-1022-50

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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.

UIC Permit Renewal – 2018 September 7, 2018
Andrex Industries Corp., Asheville, NC BLE Project No. J18-1022-50

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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 – 2017 Injection & Monitoring dated August 30, 2018 (BLE Project
No. J17-1022-48).

Report of Annual Groundwater and Surface Water Sampling and Analysis for 2017 dated August
30, 2018 (BLE Project No. J17-1022-49).

UIC Permit Renewal – 2018 September 7, 2018
Andrex Industries Corp., Asheville, NC BLE Project No. J18-1022-50

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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.

CLOSING

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. Alexander, P.G. RSM Trevor J. Benton, P.G.
Senior Hydrogeologist Senior Geologist
Registered, North Carolina #1475 Registered, North Carolina #2025

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

Tables

Table 1
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
WR0100043 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
IW-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.
Table 2 Injection Schedule of Tables Permit Renewal 2018 Andrex 1022-50.xlsx
Prepared by: AWA
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 Latitude Longitude Meas. Pt.Gnd. Surface Depth to Water *Total Borehole *Screen *Screen Well Well *Top of Rock *Top of
Well Location (North)(West)Elevation Elevation Water (bmp)Elevation Depth (bgs)Depth (bgs)Elevation Type Monitors Depth (bgs)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 IIIs BR 35.0 2187.6
MW-2 On-Site NP-A NP-A 2222.28 2222.62 NP-A NP-A 45.0 28.0 -43.0 2194.6 -2179.6 IIIs BR 29.0 2193.6
MW-3 On-Site NP-A NP-A 2210.40 2207.76 NP-A NP-A 55.0 40.0 -55.0 2167.8 -2152.8 II BR 36.5 2171.3
MW-4 On-Site NP-A NP-A 2206.87 2207.04 NP-A NP-A 86.7 51.7 -86.7 2155.3 -2120.3 IIIs BR 26.0 2181.0
MW-5 On-Site 35.580108 82.614175 2216.75 2216.92 46.60 2170.15 53.0 43.0 -53.0 2173.9 -2163.9 IIIs 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 IIIs BR 15.5 2167.2
MW-9 On-Site 35.579817 82.612727 2175.57 2175.95 26.77 2148.80 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 On-Site 35.580747 82.611588 2166.00 2166.39 25.81 2140.19 58.5 48.0 -58.0 2118.4 -2108.4 II SAP >80.0 <2086.4
MW-12 On-Site 35.579880 82.614410 2219.17 2219.49 48.96 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 2138.96 3.38 2135.42 58.5 48.0 -58.0 2091.0 -2081.0 II SAP 58.5 2080.5
MW-14 Off-Site 35.579626 82.611249 2138.94 2139.20 0.04 2138.90 75.0 65.0 -75.0 2074.2 -2064.2 IIIs 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 Off-Site 35.580186 82.609976 2180.55 2180.54 37.79 2142.76 77.0 67.0 -77.0 2113.5 -2103.5 II SAP 77.0 2103.5
MW-21 Off-Site 35.583947 82.611397 2091.17 2091.31 1.84 2089.33 36.5 26.5 -36.5 2064.8 -2054.8 II 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 IIIo BR 30.0 2115.2
MW-24 Off-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 96.0 -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 35.579610 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 82.613960 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 On-Site 35.580681 82.611646 2164.57 2165.60 24.12 2140.45 67.0 13.0 -53.0 2152.6 -2112.6 II SAP/PWR 55.0 2110.6
Notes:
*Values rounded to the nearest 0.1-ft.Water levels measured on 9/18/17.IIIo = Type III open bedrock well
NM = Not measured Measuring Point Elevation is top of casing.BR & PWR = Bedrock & Partially Weathered Rock
NP-A = Not Present - Abandoned INJ = Injection wells are stone filled boreholes SAP = Saprolite
NP-D / NP = Not Present - Destroyed by Grading/Missing II = Type II well MW-24 was abandoned, redrilled and replaced in 2007 after the well head
bgs = below ground surface.IIIs = Type III screened well was damaged by Milkco contractors in 2003.
bmp = below measuring point.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.
Table 3 (2017) of Tables Permit Renewal 2018 Andrex 1022-50.xlsx
Prepared by: AWA
Checked by: IAI
Table 4
Well Installation Plan
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
Injection Point or Monitoring Well(2014)(2015)(2016) (2017) (2018)*Renewal [Years One to Five] (2019-2023)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
Table 4 Install Schedule of Tables Permit Renewal 2018 Andrex 1022-50.xlsx
Prepared by : AWA
Checked by: TJB
Table 5
Monitor Only Matrix
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
Injection Point/AreaMonitoring StationMarch (Semi-Annual)June (Interim Event)September (Annual)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
<IW-5><MW-8R>
MW-9 V & T
<IW-6>None
<IW-7>RW-5 V & T V & T
MW-10 V & T V & T
MW-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-11>MW-24 V & T
<IW-12><MW-25R>
None MW-15 V
MW-16 V
MW-17 V
MW-18 V
MW-20 V
MW-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 performed 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).
Table 5 Monitoring Matrix of Tables Permit Renewal 2018 Andrex 1022-50.xlsx
Prepared by : AWA
Checked by: IAI
Table 6
Injection Monitoring Plan
Andrex Industries
Asheville, North Carolina
NCDEQ Groundwater Incident Number 6586
BLE Project No. J18-1022-50
Injection Point/AreaMonitoring StationBaseline Before Injection Event30 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 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
<IW-4>MW-7 X X X X X
<IW-5><MW-8R>X X X X X
MW-9 X X X X X
<IW-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
MW-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
MW-16 X
MW-17 X
MW-18 X
MW-20 X
MW-21 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 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.
Table 6 Monitoring Plan of Tables Permit Renewal 2018 Andrex 1022-50.xlsx
Prepared by : AWA
Checked by: TJB

Figures

Appendix A