WI0600064_Correspondence_20041104

North Carolina Department of Health and Human Services
Division of Public Health • Epidemiology Section
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone]
Michael F. Easley, Governor Carmen Hooker Odom, Secretary
November 4, 2004
MEMORANDUM
TO: Evan Kane
Underground Injection Control Program
Aquifer Protection Section , A�
FROM: Luanne K. Williams, Phann.D., Toxicologist
Medical Evaluation and Risk Assessment Uni
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of ABC® by Redox Tech, LLC and KB-frm Culture by SiREM Laboratories
and Bio-Dechlor INOCULUM to Enhance Biodegradation of Groundwater
Contaminated with Chlorinated Solvents
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I am writing in response to a request for a health risk evaluation regarding the use of
ABC® by Redox Tech, LLC and KB-1 Culture by Solutions Industrial & Environmental
Services and Bio-Dechlor INOCULUM to enhance biodegradation of groundwater contaminated
with chlorinated solvents. Based upon my review of the information submitted, I offer the
following health risk evaluation: -
PRECAUTIONS DURING APPLICATION
1. Some effects or hazards reported to be associated with the chemicals proposed for use are
as follows: -
• Exposure can cause bums on the skin, eyes, nose and throat and cause dizziness,
lightheadedness, and loss of consciousness. Can be significantly absorbed through
the skin and lungs (New Jersey Department of Health and Senior Services Hazardous
Substance Fact Sheet, Micromedex TOMEs Plus System -CD-ROM Database,
Volume 62, 2004). -
• The chemical is highly flammable. It will be easily ignited by heat, sparks, or flames.
Vapors may form explosive mixtures with air. Vapors may travel to source of
ignition and flash back. The vapors will spread along ground and collect in low
confined areas (sewers, basements, and tanks). The storage containers for the
chemical should be kept well closed. Runoff to sewer may create fire or explosion
hazard. Containers may explode when heated (Hazardous Substances Data Bank
Micromedex TOMEs Plus System CD-ROM Database, Volume 62, 2004).
Location: 2728 Capital Boulevard • Parker Lincoln Building • Raleigh, N.C. 27604 An Equal Opportunity Employer

Precautions should be taken to prevent explosions to protect on -site workers,
nearby residents, and off -site workers.
• Liberates toxic hydrogen sulfide on contact with acids. Reacts violently with carbon,
diazonium salts, n-dichloromethylamine; o-nitroaniline diazonium salt, and water.
• Based on testing and method used to produce the microorganisms (grown in a mineral
salt medium), the microorganisms are not likely to be pathogenic. These
microorganisms are not ordinarily associated with infection in healthy humans
(except through an existing wound) (Madigan MT, Martinko JM, and Parker Jack
2003. Brock Biology of Microorganisms, Tenth Edition. Pearson Education, Inc.).
However, these microorganisms may cause infection in the young, the aged, and
immunocompromised such as individuals with AIDS, cancer, hepatitis, or with
individuals following dialysis or surgical procedures. In order to provide an
additional margin of safety, it is recommended to maintain an aerobic zone around the
treatment zone, which should minimize the survival of the obligate anaerobes outside
the treatment zone.
2. If the products are released into the environment in a way that could result in a
suspension of fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or
mixing), then it is imperative that proper personal protective equipment be used. The
application process should be reviewed by an industrial hygienist to ensure that the most
appropriate personal protective equipment is used.
• 3. Persons working with this product should at least wear goggles or a face shield, gloves,
and protective clothing. Face and body protection should be used for anticipated splashes
or sprays. Again, consult with an industrial hygienist to ensure proper protection.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should never
be permitted in the application area during or immediately following. application. Safety
controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. The Material Safety Data Sheets should be followed to prevent adverse reactions and'
injuries.
6. Access to the area of application should be limited to the workers applying the product.
In order to minimize exposure to unprotected individuals, measures should be taken to
prevent access to the area of application.
7. According to the information submitted, the area is served by a public water supply.
Based upon injections of the product at several sites, the approximate maximum distance
of travel is estimated to be 25 feet. Two unnamed tributaries to Belmont Lake are located
approximately 100 feet from the pilot test injection area. Belmont Lake' is located
approximately 130 feet downstream of the full-scale injection. Due to the shallow depth
to groundwater`at the injection site, it is possible that the injected fluid could migrate into
the unnamed tributaries to Belmont Lake. Nearest residence is greater than 1,500 feet and
nearest workplace is 600 feet. Because of the potential risks associated with the use of

this product and the proximity of supply wells and surface waters, efforts should be
made to prevent contamination of existing or future wells and nearby surface waters
near the application area.
Please do not hesitate to call me if you have any questions at [phone].
cc: -Mr. Mike Ranck, Underground Injection Control Program, Aquifer Protection Section
-Mr. Jerry Prosser, ERM NC, PC, 8000 Corporate Center Drive, Suite 200
Charlotte, NC 28226
-Mr. Bob Gorham, The Tuscarora Corporation, 2442 Sunset Avenue
Rocky Mount, NC 27804
-Mr. David Sordi, Ingersoll-Rand, 70 North Street, Torrington, CT 06790
-Mr. John Haselow, Redox Tech, LLC, 1006A Morrisville Parkway
Morrisville, NC 27560
-Mr. Phil Dennis, Operations Manager, SiREM Laboratories, 130 Research Lane, Suite 2,
Guelph, Ontario Canada, N1G 5G3