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HomeMy WebLinkAboutWI0800040_Correspondence_1998031703/17/98 TUE 17:45 FAX 512 425 2199 DE&S AUSTIN DATE: March 17. 1998 TO: Mr. Marcus Geist PHONE: 919-715-6165 North Carolina DEHNR FAX: 919-715-0588 FROM: John Londergan PHONE: (512)425-2028 RE: Use of food grade calcium chloride at Camp Leieune CC: NA Number of pages including cover sheet: 5 Comments: The work we are proposing to undertake at Camp Leieune is in preparation for 1:he remediation of a portion of the shallow aquifer contaminated with tetrachloroethene_ Remediation of the contamination will require the infection of fluids into the aquifer as well as extraction operations To prevent the mobilization of fines during the proposed injection operations, all solutions iniected must contain approximately one thousand parts per million calcium chloride in potable water. The calcium prevents the deflocculation of the clan minerals present in the aquifer. If this is not done, fines are mobilized in the aquifer until they lodge in pore spaces small enough to capture them. This leads to a significant degradation in hydraulic conductivity making the infection/extraction operations required to remediate the shallow aquifer impractical_ We have investigated many sources for the quantities of calcium chloride we will require as well as alternate sources of calcium such as calcium carbonate and calcium sulfate. We have not found a source which has a stated maximum possible concentration of arsenic which is less than 3 parts per million (ppmb. Apparently. the 3 ppm general criteria is based upon the Food Chemical Codex which stipulates a concentration of arsenic no greater than 3 ppm in calcium chloride used in food. Please see the materials faxed with this cover page. Duke Engineering & Services, Inc. 9111 Research Boulevard Austin, Texas 78758 Telephone: (512) 425-2000 Facsimile: (512) 425-2099 DESKS Duke Engineering &Services Cj001 03/17/98 TUE 17:46 FAX 512 425 2199 DE&S AUSTIN We propose to mix a solution of 1,000 ppm calcium chloride. If the calcium chloride used in the mix were to have the maximum allowable amount of arsenic present, the injected solution would have 3 parts per billion (ppb) arsenic. In terms of analyzing for arsenic. I called Star Analvtical in Fort Worth. The chemist I spoke to said they can run an SW 846 206.2 method for waste water which will detect down to the 5 o b level. They are not aware of a standard method that will detect lower concentrations. We are currently evaluating predicted downgradient concentrations of arsenic given permission to iniect at the.maximum 3 ppb arsenic level. Duke Engineering & Services, Inc. 9111 Research Boulevard Austin, Texas 78758 Telephone: (512) 425-2000 Facsimile: (512) 425-2099 DE&S Duke Engineering & Services C1 002 03/17/98 TUE 17:46 FAX 512 425 2199 DE&S AUSTIN WAIS Document Retrieval Page 1 of 2 [Code of Federal Regulations] [Title 21, Volume 3, Parts 170 to 199] [Revised as of April 1, 1997] From the U.S. Government Printing Office via GPO Access [CITE: 21CFR184.1193] [Page 460-461] TITLE 21--FOOD AND DRUGS CHAPTER I --FOOD AND DRUG ADMINISTRATION, DEPARTMENT OF HEALTH AND HUMAN SERVICES PART 184--DIRECT FOOD SUBSTANCES AFFIRMED AS GENERALLY RECOGNIZED AS SAFE --Table o Subpart B--Listing of Specific Substances Affirmed as GRAS Sec. 184.1193 Calcium chloride. (a) Calcium chloride (CaCl<INF>2</INF><t-bullet>2H<INF>2</INF>0, CAS Reg. No. 10035-04-8) or anhydrous calcium chloride (CaCl<INF>2,</INF> CAS Reg. No. 10043-52-4) may be commercially obtained as a byproduct in the ammonia -soda (Solvay) process and as a joint product from natural salt brines, or it may be prepared by substitution reactions with other calcium and chloride salts. (b) The ingredient meets the specifications of the Food Chemicals Codex, 3d Ed. (1981), p. 47, which is incorporated by reference. Copies are available from the National Academy Press, 2101 Constitution Ave. NW., Washington, DC 20418, or available for inspection at the Office of the Federal Register, 800 North Capitol Street, NW., suite 700, Washington, DC 20408. (c) The ingredient is used as an anticaking agent as defined in Sec. 170.3(0)(1) of this chapter; antimicrobial agent as defined in Sec. 170.3(0)(2) of this chapter; curing or pickling agent as defined in Sec. 170.3(0)(5) of this chapter; firming agent as defined in Sec. 170.3(0)(10) of this chapter; flavor enhancer as defined in Sec. 170.3(0)(11) of this chapter; humectant as defined in Sec. 170.3(0)(16) of this chapter; nutrient supplement as defined in Sec. 170.3(0)(20) of this chapter; pH control agent as defined in Sec. 170.3(0)(23) of this chapter; processing aid as defined in Sec. 170.3(0)(24) of this chapter; stabilizer and thickener as defined in Sec. 170.3(o)(28) of this chapter; surface-active agent as defined in Sec. 170.3(0)(29) of this chapter; synergist as defined in Sec. 170.3(0)(31) of this chapter; and texturizer as defined in Sec. 170.3(o)(32) of this chapter. (d) The ingredient is used in foods at levels not to exceed current good manufacturing practices in accordance with Sec. 184.1(b)(1). Current good manufacturing practices result in a maximum level, as served, of 0.3 percent for baked goods as defined in Sec. 170.3(n)(1) of this chapter and for dairy product analogs as defined in Sec. 170.3(n)(10) of this chapter; 0.22 percent for nonalcoholic beverages and beverage bases [[Page 461]] as defined in Sec. 170.3(n)(3) of this chapter; 0.2 percent for cheese as defined in Sec. 170.3(n)(5) of this chapter and for processed fruit and fruit juices as defined in Sec. 170.3(n)(35) of this chapter; 0.32 percent for coffee and tea as defined in Sec. 170.3(n)(7) of this chapter; 0.4 percent for condiments and relishes as defined in Sec. 170.3(n)(8) of this chapter; 0.2 percent for gravies and sauces as defined in Sec. 170.3(n)(24) of this chapter; 0.1 percent for commercial jams and jellies as defined in Sec. 170.3(n)(28) of this chapter; 0.25 I1003 http://fwebgate2.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=524604521+1+0+0&WA][Sa?t Setrieve 03/17/98 TUE 17:46 FAX 512 425 2199 DE&S AUSTIN WAIS Document Retrieval Page 2 of 2 percent for meat products as defined in Sec. 170.3(n)(29) of this chapter; 2.0 percent for plant protein products as defined in Sec. 170.3(n)(33) of this chapter; 0.4 percent for processed vegetables and vegetable juices as defined in Sec. 170.3(n)(36) of this chapter; and 0.05 percent for all other food categories. (e) Prior sanctions for this ingredient different from the uses established in this section do not exist or have been waived. [47 FR 27808, June 25, 1982, as amended at 61 FR 14247, Apr. 1, 1996] L 004 http://frwebgate2.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=524604521+1+0+0&WAISalt tgetrieve 03/17/98 TUE 17:47 FAX 512 425 2199 DE&S AUSTIN e1005 ....................................... ..... ..... .................................................... ...... : : .................................................................... ........................... ............................. I ................................................. 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