Timeline

1995 Initial letter(s) requesting access agreement for conducting groundwater assessment w/
Ilco Unican and installation of monitoring wells (went to full Board for discussion/approval in
June 1995)
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June 20, 1995 letter to WS/FCS from Ilco o “Ilco Unican reported its findings to the North Carolina Division of Environmental
Management, Groundwater Section (“DEM”). DEM has requested … that they undertake further groundwater assessment activities, including those necessary to define the extent of any groundwater contamination plume … DEM officials recently requested that
Ilco Unican extend its on-going groundwater assessment activities to the Lowrance school property. … The purpose of groundwater testing below the Lowrance school property will be to determine whether any chlorinated solvent contamination in the groundwater has migrated to the school property. It should be noted that no drinking water wells are known to exist in the surrounding area near Ilco Unican’s plant site, and the entire area is served by a public water supply.” o Signed by Martin and Lambeth

1998 Right of Entry Agreement to construct additional monitoring wells o Signed by Martin and Lambeth

2001 request for Right of Entry Agreement to add additional monitoring wells and three soil vapor sampling probes on the Lowrance property

2001 Memo from Punger to Martin re: revised right of entry: “We have received a request from
Piedmont Geologic for and in behalf of Ilco Unican to install an additional ground water monitoring well on the site at location "MW-35" as described on the attached site plan. I have
discussed this matter with Mr. Reggie Teague and he is in agreement with this request.”

2004 Letter from Piedmont Geologic to WS/FCS o “NCDENER has requested that Kaba Ilco complete one additional soil boring on the school property for the purpose of soil vapor and groundwater sampling.”

2004 memo from Punger to Miller regarding revised right of entry: “We received another request from the corporation to place another well on our property as described in the letter. It would be consistent with our prior agreement to grant this request but this is in your discretion as Assistant Superintendent of Operations. Please review the pre-existing agreement in the file and give me a call if you have any questions.” o Miller wrote back to Piedmont Geologic and authorized them “to conduct additional site
assessments.”

2005 request for additional site assessments from Piedmont Geologic
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o “Monitoring activities have included semi-annual sampling of monitoring-well MW-22 on the school property as well as other wells on the property. Around the summer of
2004, it appears that the wellhead from MW-22 was buried over, or otherwise lost, through maintenance or renovations. … Therefore, a request is being made to replace
MW-22 with a new monitoring well around the same location. … In addition to the above, Kaba Ilco is requesting access to advance up to six additional soil borings on the school property for the purpose of collecting soil vapor samples. … In conjunction with the soil borings, Kaba Ilco is requesting access to collect one indoor air sample from the school building.”

June 23, 2005: Letter from Punger to Piedmont Geologic:
“I have reviewed your request and do not have any problem with the additional monitoring-wells and additional testing, and soil borings that you would like to conduct.
I do however have a concern about waiting on the completion of the soil vapor sampling and indoor air sampling.
I just attended a meeting today with Winston-Salem Health Dept. officials, NCDENR officials with water and land quality sections, health officials from Raleigh and numerous other personnel that are concerned about this situation. As you know one of our schools sits in the middle of the plume that runs under our building.
I would like to request that you complete your testing before school starts back on
August 17, 2005.”

August 4, 2005: Dr. Luanne Williams (State Toxicologist) sends risk assessment. o “I have reviewed the July soil vapor (or air concentration in soil) and indoor air tetrachloroethylene sampling results … Tetrachloroethylene was not detected in the indoor air sample at the Lowrance Middle School. … Therefore, in the soil areas sampled, the indoor air concentrations would not be expected to exceed the recommended air concentration of 3.2 ug/m3. … I am also recommending that this indoor air sampling from these three locations continue every three months for the next year to determine if there are seasonal differences. … Tetrachloroethylene was detected at 2.2 ug/m3 in the one indoor air sample collected in the southern end of the building which is below the target indoor air concentration of 3.2 ug/m3. … I am also recommending indoor air sampling from these five locations continue every three months for the next year to determine if there are seasonal differences. … Following my review of the quarterly and annual report and in consultation with the Forsyth County Health Director, a determination will be made if additional indoor air sampling should be done sooner than in the three months and what additional sampling would be needed beyond the one year.”

August 17, 2005: Dr. Luanne Williams (State Toxicologist) revises risk assessment. o Recalculation for Lowrance: “I have calculated a more site-specific target tetrachloroethylene air concentration. Previously, I had calculated a target air concentration for screening purposes of 3.2 ug/m2 assuming 350 days per year exposure
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for 30 years of exposure at a one in 100,000 cancer risk. The children are not expected to be in the classroom for 350 days per year at 30 years. The children at most could be in these classrooms for 180 days per year for 3 years. Assuming 180 days per year exposure for 3 years and a target risk of one out of a million, the site-specific target air concentration would be 4.9 ug/m3. In other words, if one million children breathed in air containing 4.9 ug/m3 180 days per year for 3 years, then one child out of a million may be at risk of cancer. The recommended noncancer target level assuming 180 days per
year for 3 year exposure is 40 ug/m3.” o A similar recalculation was done for Hanes and shows 6.7 ug/m3 for 180 days per year for 3 years; also below cancer level of 40 ug/m3.
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April 26, 2007: Results of March 2007 Groundwater Sampling/Analysis and April 2007 Indoor-air
Sampling/Analysis from Piedmont Geologic o “Results of laboratory analysis of July 2005 to April 2007 indoor-air samples are summarized … PCE was detected in four of the April 2007 indoor-air samples … at concentrations of .75 ug/m3, 1.6 ug/m3, and .75 ug/m3. According to the Agency for
Toxic Substances and Disease Registry, a survey of indoor air in a school, office building, and home for the elderly showed median indoor-air PCE concentrations ranging from 1.7 ug/m3 to 4.8 ug/m3. The detected PCE concentrations in the April 2007 indoor-air samples are all within or below this range of background concentrations and are consistent with previously detected PCE concentrations. TCE was not detected in any of
the April 2007 indoor air samples.”
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2012 Right of Entry Agreement to add two additional groundwater monitoring wells and soil vapor probes. o Agenda page for December 2012 board meeting
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June 2014 Addendum to 2012 agreement o Per Powell’s email: “They are voluntarily proposing to add a new more aggressive treatment system for the underground chemicals. KABA asked for a modified access agreement to perform work necessary to install this more aggressive treatment process
(pumps, pipe & wells) under school property … For background, we recently agreed and
KABA performed tests in the schools which generally showed the same or less than the tests conducted over the years. All of which are well below the regulations recently established by NCDENR. Also KABA submitted the more aggressive remediation plan to
NCDENR and it is currently under the NCDENR public review process.”
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June 10, 2014 Building and Grounds Committee – Kaba folks attended and Bill Powell presented to B&G regarding their groundwater remediation efforts. Presentation included discussion of history and monitoring of the site, and a request to amend the current Right of Entry
Agreement. Present for the meeting were board members Collins, Goins, Metcalf, Parker,
Motsinger, Johnson and Davenport. o Agreement signed by Emory
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