WI0700459_Correspondence_20170912

Shrestha, Shristi R
From:
Sent:
To:
Subject:
Attachments:
Ed Hollifield <[e-mail]>
Tuesday, September 12, 2017 12:34 PM
Shrestha, Shristi R
RE: WI0700459 Former West Pharmaceutical Services Facility
Fig5_PropinjGrid Rev20170911.pdf
Ms. Shrestha,
As requested, please see the revised figure 5 with the injection area shown.
Please call with any questions.
Kind regards,
Ed Hollifield, P.G. (NC, SC)
Technical Director - CSM Practice
ERM
15720 Brixham Hill Avenue, Suite 120 I Charlotte, NC, USA 128277
Main-704.541.8345 I Mobile-704.301.2262 I Direct — 704.409.3431
ed.hollifield(ci)erm.com I www.erm.com
ERM The business ofsus tainabilihy
From: Shrestha, Shristi R [mailto:[e-mail]]
Sent: Monday, September 11, 2017 2:36 PM
To: Ed Hollifield
Subject: RE: WI0700459 Former West Pharmaceutical Services Facility
RECEIVEDINCDEGDWR
SEP 1 2 2017
Water Quality
Regional Operations Section
Good afternoon ,
As per Debra Watts the Figure 5 should have an area labelled as injection zone . This means the Fig 5 should show an
area on top of the radius of influence of all the injection points and this should be labelled as "Injection zone " instead
of proposed radius of influence.
Please call me if you have any question.
Thank you,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
RECE1VEvWR
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Re.giorr690%***1§Won
Regions
919 807-6406 office
shristi.shresthaAncdenr.gov

512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Shrestha, Shristi R
Sent: Thursday, September 07, 2017 11:08 AM
To: 'Ed Hollifield' <[e-mail]>
Subject: RE: WI0700459 Former West Pharmaceutical Services Facility
Thank you for addressing all the items requested. I have forwarded a draft permit to my supervisor for final approval.
Thank you,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(a�ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Ed Hollifield [mailto:[e-mail]]
Sent: Wednesday, September 06, 2017 10:04 AM
To: Shrestha, Shristi R <shristi.shrestha@,ncdenr.gov>
Subject: WI0700459 Former West Pharmaceutical -Services Facility
Ms. Shrestha,
In response to your e-mail request for additional information regarding the UIC permit application for the referenced
former West Pharmaceutical Site in Kinston, NC, please see responses in blue to your questions and requests below.
We are reviewing the permit application for Former West Pharmaceutical Services Facility and 1 would need the
following to proceed further.
1. A map of injection zone overlaying the contaminated area. In Fig 5 I can see all DPT points but I would like
to see an area that shows the radius of influence from the injection points.
Figure 5 previously submitted with the application package shows the contamination and the injection zone.

(see attached). Also, the spacing of the injection points is 35' on center as showninthe edited notes of the
figure.
2. The injection zone map should also show location of monitoring wells. It is preferred that the monitoring
wells are located outside the injection zone. Also, the proposed monitoring wells should be labelled in the
figure.
The original figure submitted with the application package shows the proposed additional monitoring wells
(2 wells were located outside the zone to account for migration of groundwater, I inside the injection zone in
addition to existing wells and, and 1 additional proposed well upgradient). The proposed well symbol and ID
labels have been added as requested.
3. A plan to account for any accidental spill or daylighting effect in the injection area since there is a drainage
ditch in the nearby. A spill plan has been added (see attached). Please note ABC compound is biodegradable
food grade emulsified oil and is ingestible so it poses very little hazard to the area, if any.
4. Ifpossible I would like to add another well on the southeast side of the injection zone, in line with the 2
proposed monitoring well. A 3rd downgradient well (labeled MW-1 6 in this figure) has been added to the
proposed monitoring wells.
Please call me direct with any additional questions or requests.
With kind regards,
Ed Hollifield, P.G. (NC, SC)
Technical Director - CSM Practice
ERM
15720 Brixham Hill Avenue, Suite 120 I Charlotte, NC, USA 128277
Main-704.541.8345 I Mobile-704.301.2262 I Direct — 704.409.3431
[e-mail] I www.erm.com
ER VI The business ofsastainability
This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED
BY LAW FROM DISCLOSURE, and (b) Intended only for the use of the Addressee (s) names herein. If you are not the Addressee (s), or the person
responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message Is prohibited. If you have
received this electronic mall message in error, please contact us immediately at [phone] and take the steps necessary to delete the message
completely from your computer system. Thank you, ERM NC, Inc.
This electronic mail message may contain Information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED
BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee (s), or the person
responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have
received this electronic mall message in error, please contact us immediately at [phone] and take the steps necessary to delete the message
completely from you(computer system. Thank you, ERM NC, Inc.

Shrestha, Shristi R
From:
Sent:
To:
Subject:
Ed Hollifield <[e-mail]>
Monday, September 11, 2017 3:59 PM
Shrestha, Shristi R
RE: WI0700459 Former West Pharmaceutical Services Facility
Shrestha,
We will make the requested change and send to you for review.
Kind regards,
Ed Hollifield, P.G. (NC, SC)
Technical Director - CSM Practice
ERM
15720 Brixham Hill Avenue, Suite 120 I Charlotte, NC, USA 128277
Main-704.541.8345 I Mobile-704.301.2262 I Direct — 704.409.3431
ed.hollifield(ct�erm.com I www.erm.com
ERM The business of susrainabiliry
From: Shrestha, Shristi R [mailto:[e-mail]]
Sent: Monday, September 11, 2017 2:36 PM
To: Ed Hollifield
Subject: RE: WI0700459 Former West Pharmaceutical Services Facility
itootit.C. suu/Jejod
sat:
L! 0
&Mom
Good afternoon ,
As per Debra Watts the Figure 5 should have an area labelled as injection zone . This means the Fig 5 should show an
area on top of the radius of influence of all the injection points and this should be labelled as "Injection zone " instead
of proposed radius of influence.
Please call me if you have any question.
Thank you,
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations Si Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(cr�ncdenr.ciov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
RECENE0fNCDEQfDWR
SEP 1 2 2017
Water Quality
Regional Operations Section
Email correspondence to and from this address is subject to the
Adnrth f'arrdina Arthur PrInnrrre 1 aui and mAU hR riicrdncarl to third nartia+.c

From: Shrestha, Shristi R
Sent: Thursday, September 07, 2017 11:08 AM
To: 'Ed Hollifield' <Ed.Hollifieldeerm.com>
Subject: RE: WI0700459 Former West Pharmaceutical Services Facility
Thank you for addressing all the items requested. I have forwarded a draft permit to my supervisor for final approval.
Thank you,
Shristi
Shristi R. Shrestha.;. •,'
Hydrogeologist
Water Quality Regional Operations Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
shristi.shrestha(a ncdenr.gov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Ed Hollifield jmailto:Ed.HollifieldAerm.comj
Sent: Wednesday, September 06, 2017 10:04 AM
To: Shrestha, Shristi R <[e-mail]>
Subject: WI0700459 Former WesfPharmaceutical Services Facility
Ms. Shrestha,
In response to your e-mail,request for additional information regarding the UIC permit application for the referenced
former West Pharmaceutical, Site in Kinston, NC, please see responses in blue to your questions and requests below.
We are reviewing the permit application for Former West Pharmaceutical Services Facility and I would need the
following to proceed further.
1. A map of injection zone overlaying the contaminated area. In Fig 5I can see all DPT points but I would like
to see an area that shows the radius of influence from the injection points.
Figure 5 previously submitted with the application package shows the contamination and the injection zone.
As requested, anticipated 15 foot radius of influence zones (shown as circles) have been added to the figure
(see attached). Also, the spacing of the injection points is 35' on center as shown in the edited notes of the
figure.

2. The injection zone map shoul4 uc.,u show location of monitoring wells. It is .1— ajerred that the monitoring
wells are located outside the injection zone. Also, the proposed monitoring wells should be labelled in the
figure.
The original figure submitted with the application package shows the proposed additional monitoring wells
(2 wells were located outside the zone to account for migration of groundwater, 1 inside the' injection zone in
addition to existing wells and, and 1 additional proposed well upgradient). The proposed well symbol and ID
labels have been added as requested.
3. A plan to account for any accidental spill or daylighting effect in the injection area since there is a drainage
ditch in the nearby. A spill plan has been added (see attached). Please note ABC compound is biodegradable
food grade emulsified oil and is ingestible so it poses very little hazard to the area, if any.
4. If possible I would like to add another well on the southeast side of the injection zone, in line with the 2
proposed monitoring well. A 3rd downgradient well (labeled MW-16 in this figure) has been added to the
proposed monitoring wells.
Please call me direct with any additional questions or requests.
With kind regards,
Ed Holli£eld, P.G. (NC, SC)
Technical Director - CSM Practice
ERM
15720 Brixham Hill Avenue, Suite 120 I Charlotte, NC, USA 128277
Main-704.541.8345 I Mobile-704.301.2262 I Direct — 704.409.3431
ed.hollifield(@erm.com I www.erm.com
EitNi The business of sustainabitky
This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED
BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee (s), or the person
responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have
received this electronic mail message in error, please contact us Immediately at [phone] and take the steps necessary to delete the message
completely from your computer system. Thank you, ERM NC, Inc.
This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED
BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee (s), or the person
responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have
received this electronic mail message in error, please contact us immediately at [phone] and take the steps necessary to delete the message
completely from your computer system. Thank you, ERM NC, Inc.

w •
Shrestha, Shristi R
From: Ed Hollifield <[e-mail]>
Sent: Wednesday, September 06, 2017 10:04 AM RECE►VED/NCDE
To: Shrestha, Shristi R OIDWR
Subject: WI0700459 Former West Pharmaceutical Services Facility
Attachments: Fig5_PropInjGridRev20170824.pdf; Chemical Handling Memo.paf p 6 2011
Water Quality
Ms. Shrestha, Regional Operations Section
In response to your e-mail request for additional information regarding the UIC permit application for the referenced
former West Pharmaceutical Site in Kinston, NC, please see responses in blue to your questions and requests below.
We are reviewing the permit application for Former West Pharmaceutical Services Facility and I would need the
following to proceed further.
1. A map of injection zone overlaying the contaminated area. In Fig 5 I can see all DPT points but 1 would like
to see an area that shows the radius of influence from the injection points.
Figure 5 previously submitted with the application package shows the contamination and the injection zone.
As requested, anticipated 15 foot radius of influence zones (shown as circles) have been added to the figure
(see attached). Also, the spacing of the injection points is 35' on center as shown in the edited notes of the
figure.
2. The injection zone map should also show location of monitoring wells. It is preferred that the monitoring
wells are located outside the injection zone. Also, the proposed monitoring wells should be labelled in the
figure.
The original figure submitted with the application package shows the proposed additional monitoring wells
(2 wells were located outside the zone to account for migration of groundwater, 1 inside the injection zone in
addition to existing wells and, and 1 additional proposed well upgradient). The proposed well symbol and ID
labels have been added as requested.
3. A plan to account for any accidental spill or daylighting effect in the injection area since there is a drainage
ditch in the nearby. A spill plan has been added (see attached). Please note ABC compound is biodegradable
food grade emulsified oil and is ingestible so it poses very little hazard to the area, if any.
4. If possible I would like to add another well on the southeast side of the injection zone, in line with the 2
proposed monitoring well. A 3rd downgradient well (labeled MW-16 in this figure) has been added to the
proposed monitoring wells.
Please call me direct with any additional questions or requests.
With kind regards,
Ed Hollifield, P.G. (NC, SC)
Technical Director - CSM Practice
ERM
15720 Brixham Hill Avenue, Suite 120 I Charlotte, NC, USA 128277
Main-704.541.8345 I Mobile-704.301.2262 I Direct — 704.409.3431
ed.hollifield(a?erm.com I www.erm.com
The business €:<f su inabitiry

•
This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED
BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee (s), or the person
responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have
received this electronic mail message in error, please contact us immediately at [phone] and take the steps necessary to delete the message
completely from your computer system. Thank you, ERM NC, Inc.

Telephone Record/Log
PERMIT NO. WI0700459
DATE: 9/1/2017
Telephone Record/Log Completed By: Shristi Shrestha- WQROS
Telephone Call
® Made to: Rick Tarravechia
❑ Received from:
Telephone No.: 704-409-3440
RE: Add info request inquiry
COMMENTS/NOTES: Add info was requested on 8/22/2017 and haven't back anything.
Called to inquire in info request was rec'd.

Shrestha, Shristi R
From: Shrestha, Shristi R
Sent: Tuesday, August 22, 2017 3:53 PM
To: '[e-mail]'; Thomas,Allen; '[e-mail]'
Cc: Sipe, Randy
Subject: WI0700459 Former West Pharmaceutical Services Facility
Good afternoon,
We are reviewing the permit application for Former West Pharmaceutical Services Facility and I would need the
following to proceed further.
1. A map of injection zone overlaying the contaminated area. In Fig 5 I can see all DPT points but I would like to
see an area that shows the radius of influence from the injection points.
2. The injection zone map should also show location of monitoring wells. It is preferred that the monitoring wells
are located outside the injection zone. Also, the proposed monitoring wells should be labelled in the figure.
3. A plan to account for any accidental spill or daylighting effect in the injection area since there is a drainage
ditch in the nearby.
4. If possible I would like to add another well on the southeast side of the injection zone, in line with the 2
proposed monitoring well.
If you have any questions please contact me at the number below.
Thank you for your cooperation.
Shristi
Shristi R. Shrestha
Hydrogeologist
Water Qualit—y Regi—ionai Opera ions Section
Animal Feeding Operations & Groundwater Protection Branch
North Carolina Department of Environmental Quality
919 807-6406 office
sh risti.shresth a (a)ncd enr. qov
512N. Salisbury Street
1636 Mail Service Center
Raleigh, NC 27699 1636
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Water Resources
Environmental Quality
July 21, 2017
Steven Walton
530 Herman O. West Drive
Exton, PA 19341
RE: Acknowledgement of Application No. WI0700459
Former West Pharmaceutical Service Facility
In Situ Groundwater Remediation, Well System
Lenoir County
Dear Mr. Walton:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
The Water Quality Regional Operations Section (WQROS) acknowledges receipt of your
permit application on July 18, 2017. Your application package has been assigned the number listed
above, and the primary reviewer is Shristi Shrestha
Central and Washington Regional Office staff will perform a detailed review of the
provided application, and may contact you with a request for additional information. To ensure
maximum efficiency in processing permit applications, the Water Quality Regional Operations
Section (WQROS) requests your assistance in providing a timely and complete response to any
additional information requests.
Please note that processing standard review permit applications may take as long as 60 to
90 days after receipt of a complete application. If you have any questions, please contact Shristi
Shrestha at 919-807-6406 or [e-mail].
Sincerely,
awe ,axedida
For Debra J. Watts, Supervisor
Animal Feeding Operations & Groundwater
Protection Branch
Division of Water Resources
cc: Washington Regional Office, WQROS
Rick Tarravechia, ERM NC Inc., 15720 Brixham Hill Avenue, Suite 120, Charlotte, NC
28277
Permit File WI0700459
Nothing Compares'>
State of North Carolina I Environmental Quality I Division of Water Resources
Water Quality Regional Operations Section
1636 Mail Service Center I Raleigh, North Carolina 27699-1636
919-707-9129