Loading...
HomeMy WebLinkAboutWI0600055_Staff Report_20100520_/ 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