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AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Date: 05/20/10 County: Scotland
To: Aquifer Protection Section Central Office Permittee: Abbott Laboratories
Central Office Reviewer: J. McCrav Project Name: Abbott/OualPak Remedation Project
Regional Login No: ?? Application No.: W100600055
L GENERAL INFORMATION
1. This application is (check all that apply): ® New 0 Renewal
0 Minor Modification 0 Major Modification
❑ Surface Irrigation 0 Reuse ❑ Recycle 0 High Rate Infiltration 0 Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ❑ 503 exempt
❑ Distribution of Residuals 0 Surface Disposal
0 Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or 0 No.
a. Date of site visit: 05/13/10
b. Person contacted and contact information: Sean Boyles - DWM/Superfund/Inactive Hazardous Sites
Branch/Favetteville Regional Office
c. Site visit conducted by: Jim Barber
d. Inspection Report Attached: 0 Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
® Yes or 0 No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. - Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
Groundwater remediation system consisting of injection wells for the remediation of solvent/VOC
contamination due to wastepit operations by Abbott Laboratories (former owner of site).
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to copy and paste a new section into the
document for each site. or attach additional pages for each site)
a. Location(s): 16000 Joy Street, Laurinbura NC 28352 (OualPak facility today)
b. Driving Directions: From the Fayetteville Regional Office travel to Laurinburr on Hwy 401. Upon
entering Laurinburg city limits. take Hwy 401 Bypass. to the exit for Hwy 15/501 to Aberdeen. The former
Abbott Labs/OualPak facility is on the immediate right.
c. USGS Quadrangle Map name and number: Laurinbura, NC (H-21-SW)
d. Latitude: 34.800726 N Longitude: -79.455245 W (approx. location of infection zone "A")
FORM: APSARRAbbottLab-QualPakW10600055May2010.doc 1
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
IL NEW AND MAJOR MODIFICATION APPLICATIONS (this section not needed for renewals or minor
modifications, skip to next section)
Description Of Waste(S) And Facilities
1. Please attach completed rating sheet. Facility Classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
0 Yes 0 No ❑ N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? 0 Yes ❑ No ❑ N/A. If no, please explain: ----{ Formatted J
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? 0
Yes ❑ No ❑ N/A. If no, please explain: { Formatted
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. 0 Yes 0 No ❑ ,
N/A. If no, please explain:
6. Are the propbsed application rates for new sites (hydraulic or nutrient) acceptable?
❑ Yes ❑ No 0 N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes 0 No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities.or new disposal sites)? 0 Yes or 0 No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? 0 Yes 0 No 0 N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? 0 Yes 0 No 0 N/A If yes, attach list of sites
with restrictions (Certification B?)
III. RENEWAL AND MODIFICATION APPLICATIONS (use previous section for new or major modification
s stems
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? 0 Yes or 0 No.
Operator in Charge: Certificate#:_
Backup- Operator in Charge: Certificate #:_
FORM: APSARRAbbottLab-QualPakWI0600055May2010.doc 2
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes 0 No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly contracted and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ® Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; 0 Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
15. Are thereany issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
FORM: APSARRAbbottLab-QualPakWI0600055May2010.doc 3
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
IV. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
® In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L"Non-Discharge")
❑ Other (Specify:
2. Does system use same well for water source and injection? ❑ Yes N No
3. Are there any potential pollution sources that may affect injection? 0 Yes N No
What is/are the pollution source(s)? . What is the distance of the injection well(s) from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? 200' + ft.
5. Quality of drainage at site: ® Good
6., Flooding potential of site: ® Low
❑ Adequate ❑ Poor
❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ® Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program: The site is the iurisdiction of theDivision of Waste Management - Superfund
Section - Inactive Hazardous Sites Branch, with oversight for facility activities by the Fayetteville Regional
Office staff (Sean Boyles: 910-433-3345).
8. Does the map presented represent the actual site (property lines, wells, surface drainage)?® Yes or 0 No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Injection Well Permit Renewal And Modification Onh':
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
0 Yes 0 No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes explain:
FORM: APSARRAbbottLab-QualPakWI0600055May2010.doc 4
y
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
3. For renewal or modification of groundwater remediation permits (of any tvpe) will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? n Yes ❑ No. If yes, explain:
4. Drilling contractor: Name:
Address:
Certification number.
5. Complete and attach Well Construction Data Sheet.
FORM: APSARRAbbottLab-QualFakWI0600055May2010.doc 5
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
V. EVALUATION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: .
2. Attach Well Construction Data Sheet = if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? 0 Yes N No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item
Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition
Reason
6. List specific special conditions or complianceschedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
7. Recommendation: 0 Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor.
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
A brief site visit was made to the site on 13 May 2010 to determine if any substantial chances had occurred in
FORM: APSARRAbbottLab-QualPakW10600055May2010.doc 6
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
the vicinity of the former Abbott Laboratories facility. The building located at the site is in use by OualPak
producing hand sanitizer. Site conditions, in and around the facility, have not changed since the issuance of the
original permit dated 22 September 2006.
A copy of the final UIC permit should be_provided to the Inactive Sites Branch, Superfund Section, in the
Division of Waste Management. The contact person for this site is Mr. Sean Boyles (910-433-3345). The
mailing address is as follows:
Division of Waste Management
Inactive Sites Branch
225 Green Street Suite 714
Fayetteville, NC 28301
FORM: APSARRAbbottlab-QualPakW10600055May2010.doc 7
r
AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: May 6, 2010
To: ❑ Landon Davidson, ARO-APS
® Art Bamhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
❑ Jay Zimmerman, RRO-APS
From: John McCray , Groundwater Protection Unit
Telephone: (919) 715-6168
E-Mail: john.mccray(a,ncdenr.gov
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, WSRO-APS
Fax: (919)715-0588
A. Permit Number: WI0600055
B. Owner: Abbott Laboratories
C. Facility/Operation: Former Abbott Facility (QualPak, Inc)
® Proposed ❑ Existing ❑ Facility
❑ Operation
D. Application:
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
® UIC - (51) in -situ groundwater remediation
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
Z Return a Completed Form APSSRR.
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO*.
* Remember that you will be responsible for coordinating site visits, reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer: Date:
FORM: APSARR 02/06 Page 1 of 1
North Carolina Department of Health and Human Services
Division of Public Health • Epidemiology Section
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel 919-733-3410 • Fax 919-733-9555
Michael F. Easley, Governor Carmen Hooker Odom, Secretary
November 4, 2004
r p_.:F r �n
MEMORANDUM o mrrt
c rs
TO: Evan Kane o - 00
Underground Injection Control Program r"''„r"n
-o
Aquifer Protection Section z � a
c? o
FROM: Luanne K. Williams, Pharm.D., Toxicologist Or n
Medical Evaluation and Risk Assessment Uni p'
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of ABC® by Redox Tech, LLC and KB-1t Culture by SiREM Laboratories
and Bio-Dechlor INOCULUM to Enhance Biodegradation of Groundwater
Contaminated with Chlorinated Solvents
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 burns 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 pi -ducts 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 accesstothe 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 (919) 715-6429.
' 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
Shaw Environmental & Infrastructure, Inc.
ShaW Shaw Environmental 8. Infrastructure, Inc.
-17 Princess Road
Lawrenceville, NJ 08648
609.895.5340
Fax: 609,895.1858
January 14, 2010
Thomas Slusser
NCDENR
DWQAPS
UIC Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Re. RTB-1 bacterial culture
Dear Mr. Slusser,
I- am sending you this note to confirm that the dechlorinating bacterial cultures BAC-9 marketed by EOS
Remediation, LLC and RTB-1 marketed by RedoxTech, LLC are in fact the same culture. The culture
(originally SDCYTM) is distributed under licensing agreements between the two companies and Shaw
Environmental, Inc. Under the terms of the licensing agreements these companies are allowed to re-
name the culture to fit their marketing strategies. SDC-9, RTB-1, and BAC-9 are indeed the same culture.
The culture is produced in and shipped from our facility.
Please feel free -to contact me with any questions (609-895-5350; Robsteffan@shawgrp.com)
Sincerely,
Robert Steffan, Ph.D.
Director, Biotechnology Development and Applications
A Shaw Group Company
North Carolina Department of Health and Human Services
Division of Public Health — Epidemiology Section
Occupational and Environmental Epidemiology Branch
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Telephone: 919-707-5900 Fax: 919-870-4807
Michael F. Easley, Governor Leah Devlin, DDS, MPH
Dempsey Benton, Secretary - State Health Director
January 18, 2008
MEMORANDUM
TO: Qu Qi
Underground Injection Control Program
Aquifer Protection Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist
Medical Evaluation and Risk Assessment Uni
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of a Biological Product BAC-9® to Enhance Biodegradation of Groundwater
Contaminated with Chlorinated Compounds
I am writing in response to a request for a health risk evaluation regarding the use of use
of a biological product BAC-9 ® to enhance biodegradation of groundwater contaminated with
chlorinated compounds. Based upon my review of the information submitted, I offer the
following health risk evaluation:
PRECAUTIONS DURING APPLICATION
1. The microorganisms in BAC-9® are naturally found in soil. These microorganisms are not
ordinarily associated with infection in healthy humans (except through an existing wound).
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 addition, some of the ingredients within the
BAC-9 ® product have been known to cause eye, skin, and lung irritation.
North Carolina Public Health
Working for a healthier and safer North Carolina
Everpu,erc. Everyday. Everybody.
Location: 5505 Six Forks Rd., 2"d Floor, Room 1-2-D1 • Raleigh, NC 27609
An Equal Opportuuity Employer
iths
2. Also, be aware that mixing potassium with some of the metal and acid ingredients listed in
the product have been reported to be possibly explosive. Care should be taken to review the
MSDS sheets for each ingredient listed to ensure that there would be no explosive hazard.
3. 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.
4. Persons working with this product should at least weargoggles 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.
5. 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.
6. The Material Safety Data Sheets should be followed to prevent adverse reactions and
injuries.
7: 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.
8. Efforts should be made to prevent contamination of existing or future wells and surface water
that may be located near the application area.
Please do not hesitate to call me if you have any questions at (919) 707-5912.
cc: Dr. Robert Steffan
Shaw Environmental, Inc.
17 Princess Road
Lawrenceville, NJ 08648
Mr. Gary Birk
Ms. Susan Bostian
EOS Remediation, Inc.
1101 Nowell Road
Raleigh, NC 27607