WI0600074_Staff Report_20110610

Rogers, Michael
From: Einsmann, Matthew [[e-mail]]
Sent: Friday, June 10, 2011 8:50 AM
To: Rogers, Michael; Barnhardt, Art; Werner, Elizabeth; Little, Geof
Cc: Steve Edge; Einsmann, Matthew
Subject: Robeson County Landfill - Groundwater Pilot Test
Michael
In accordance with the notification requirements in the UIC Permit (W10600074), we will be performing the following
activities at the Robeson County Landfill:
1. Injection and monitoring point installation —June 30 and July 1
2. Injection —July 18
If you need anything further, please contact me at 919-424-1436.
Thanks.
Matt
Matt Einsmann
Brown and Caldwell
[e-mail]
T 919.424.1436 I C 919.306.3324
1

AQUIFER PROTEC i ION SECTION REGIONHL STAFF REPORT
Date: 04/20/11
To: Aquifer Protection Section Central Office
Central Office Reviewer: M. Rogers Project Name:
Regional Login No: ??
L GENERAL INFORMATION
I . This application is (check all that apply): ® New ❑ Renewal
❑ Minor Modification ❑ Major Modification
County: Robeson
Permittee: Robeson County LF
Robeson LF Remedation Project
Application No.: WI00600074
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals
['Distribution of Residuals
❑ Attachment B included
❑ Surface Disposal
❑ 503 regulated ❑ 503 exempt
❑ Closed -loop Groundwater Remediation ® Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a.
b.
c.
d.
Date of site visit: 04/11/11
Person contacted and contact information: Steve Edge - Robeson County Solid Waste Director
Site visit conducted by: Jim Barber
Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
® Yes or n 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 VOC's in groundwater
at/near monitoring wells MW-5 & 5A at the Robeson County landfill.
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): 246 Landfill Road, St. Pauls N.C. 28384 (landfill scale house)
b. Driving Directions: From the Fayetteville Regional Office south on I-95 to the Town of St. Pauls and take
exit 31. Turn left and head east on Hwy 20 thru St. Pauls for approx. five miles. Turn right onto Landfill
Road and drive to the scalehouse office.
c. USGS Quadrangle Map name and number: SAINT PAULS, NC (H-23-SW)
d. Latitude: 34.784436 N Longitude: -78.911141 W (location of injection site near MW-5)
FORM: APSARRRobesonLFWI0600074Apri12011.doc 1

AQUIFER PROTEC i ION SECTION REGIONAJL STAFF REPORT
II. 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?
❑ Yes ❑ 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? ❑ Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
❑ Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ 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)? ❑ 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:
9. Is proposed and/or 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:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ 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
systems)
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No.
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
FORM: APSARRRobesonLFWI0600074Apri12011.doc 2

r-�
AQUIFER PROTEQ, LION SECTION REGIONtiL 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 ❑ 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 constructed and located? n 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; ❑ 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 there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
FORM: APSARRRobesonLFWI0600074ApriI2011.doc 3

AQUIFER PROTEL LION 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
I. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
Z In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5LP'Non-Discharge")
❑ Other (Specify: )
2. Does system use same well for water source and injection? ❑ Yes No
3. Are there any potential pollution sources that may affect injection? N Yes ® No
What is/are the pollution source(s)? The primary culprit for groundwater impacts is the unlined MSW landfill
that was operational from 1985 to the end 1997. The secondary culprit is the old construction/demolition
landfill that is south of the unlined MSW landfill (between the MSW and MW-5 & MW-5A) and is identified
as a disposal area on the site drawings in the injection well application (Fig. 1). What is the distance of the
injection well(s) from the pollution source(s)? 450' to 500' ft.
4. What is the minimum distance of proposed injection wells from the property boundary? 300' + ft.
5. Quality of drainage at site: ❑ Good ❑ Adequate ® Poor
6. Flooding potential of site: ❑ Low ❑ 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 current groundwater monitoring system is for the closed, unlined
Robeson County landfill. Monitoring wells exist between the new, lined landfill currently operating and the
closed, unlined MSW landfill. MW-5 & 5A are located at the compliance boundary of 500' from the waste
wells located at the site have been approved by the Division of Waste Management - Solid Waste Section for
monitoring of said landfill to meet the intent of groundwater monitoring required by 40 CFR 257 and 258
(Subtitle D Landfill rules as required by RCRA).
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ® Yes or ❑ 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 Only:
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)?
FORM: APSARRRobesonLFWI0600074Apri12011.doc 4

AQUIFER PROTE _; ielON SECTION REGIONAL' STAFF REPORT
El Yes ❑ 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:
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. If yes, explain:
4. Drilling contractor: Name:
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
FORM: APSARRRobesonLFWI0600074Apri12011.doc 5

AQUIFER PROTEc iION SECTION REGIONr i; STAFF REPORT
V. EVALUATION AND RECOMMENDATIONS
I. 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? ❑ Yes ® 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 compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition
Reason
A as -built survery of the injection well locations
shall be submitted, within 60 days, after
installation and introduction of the oxidizing
materials.
The as -built survey should address the acutal
location of each injection location, within the
defined area (shaded) on the submitted site plan.
Field conditions, i.e trees/utlities/formation
consistency/equipment access will dictate acutal
locations within the area of interest.
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; n 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:
,J) (-13A'j)ill- Fort AZT BAR.,sfthr-
FORM: APSARRRobesonLFW10600074Apri12011.doc
6

AQUIFER/PROTE% ION SECTION REGIONAi, STAFF REPORT
Date: I /2 62 hi
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Enclosed with this staff report is a copy of the 100 year floodplain map and topographic map for the area
depicting the area in and around MW-5 & 5A and the injection site. The proposed area of remediation by
injection well technology is within the 100 year floodplain (blue shading) of Big Marsh Swamp. Ground
surface elevation at the vicinity of MW-5 & 5A and the injection area is approximately 126' to 127 +/- msl and
the 100 year floodplain elevation mapped for the area is approximately 128' to 129' +/- msl.
There are no groundwater users in the area of the remediation site. Down gradient of injection site is Big Marsh
Swamp. Any private groundwater supply wells near the injection site would be across Big Marsh Swamp and
the nearest water supply well north of Big Marsh Swamp would be at least 3000' or more away.
No major or identified industrial/commercial sources of pollution at or near the landfill site (within 2000' of the
landfill property boundary). Possible minor sources of groundwater impacts in the area (other than the disposal
units) would be maintenance of equipment at the yard waste area located east of the C&D landfill (approx. 700'
from MW-5 & 5A).
A copy of the final UIC permit should be provided to the Solid Waste Section in the Division of Waste
Management. The contact person for this site is Ms. Elizabeth Werner [phone]. The mailing address is
as follows:
Division of Waste Management
Solid Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646
Attn: Ms. Elizabeth Werner
FORM: APSARRRobesonLFWI0600074Apri12011.doc 7

arse% $ se
—\ --,
f Jv �� mil•' • Q, • N.
0
p' ]
E.:• r }ilk °La '•� Ct
�t°i�'R i•.Cin�s
3
.t„ .?V7
•m�
.,. e
Y k t... 3• i•.sisi.A

Robeson LF: WI0600074
MOOT Cites Roads - 1OOyr Fioocing • Floodway (AE)
+ Benchmarks — NC Highway - tOf)yr Flooding - Has BFE's (AE)
„:„ aDFIRM Grid USHq)rway wil 1OOyr Flooding - No SFes(Ai
Rivera and Streams e. Interstate Highway gag 1 OOyr Flooding - litioetty Zane
—.— Ttansecte (Cdastar) Paioca Areas - 5O3rr Flooding (Shaded X)
County BccrodleS F7A ExMrtenitOn81 Jun94Ciiena — ease Flood Ekvatico (S./n*d)
Coeval Bamer Resource Syst^ms 11111 Coastal Sounds — Cross Swoons
1
ni
7:0 Feet
North Carolina
Floodplain Mapping Program

Wi0G0007(7/

N!... •
`34153114:
• preview 'Extent Next ixtent Fuji Extent
•
m
• • •
National Wetlands Inventory
Map Scale: 1:18056 Lat: 34,7963: Lrig: -78,8949
onsolmomigimak
wioCecoo747,

Date: April 4, 2011
To: ❑ Landon Davidson, ARO-APS
® Art Barnhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
0 Jay Zimmerman, RRO-APS
From: Michael Rogers Groundwater Protection Unit
Telephone: [phone]
E-Mail: Michael.Rogers@,ncmail.net
A. Permit Number: WI 0600074
B. Owner: Robeson County Solid Waste
C. Facility/Operation:
Proposed ® Existing
AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM RECEIVED i t _. Aquifer Prot, rn.7 !^.Tio
n
APR 29 2011
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, W-SRO-APS
Fax: [phone]
• ` E a..` n.—. Y V E
APR 0 5 2011
DENR-FAYETTEVILLE REGIONAL OFFICE
❑ Facility n Operation
D. Application:
1. Permit Type: ❑ Animal 0 SFR-Surface Irrigation❑ Reuse ❑ H-R Infiltration
❑ Recycle 0 I/E Lagoon ❑ GW Remediation (ND)
® UIC — 5I Groundwater Remediation Well
-For Residuals: 0 Land App.
0 503
❑ D&M 0 Surface Disposal
0 503 Exempt ❑ Animal
2. Project Type: ►1 New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal 0 Renewal w/ Mod.
E. Comments/Other Information: ❑
NOTE: If you plan to conduct a site visit, I would like to go along (providing my schedule will
allow).
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within, please take the following actions:
® Return a Completed APSARR Form and attach laboratory analytical results, if applicable.
❑ Attach Well Construction Data Sheet.
0 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 and 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: � j M �-- Date: Z/fA 4'l
FORM: APSARR 07/06 Page ] of 1

Rogers, Michael
From: Barber, Jim
Sent: Friday, May 20, 2011 2:44 PM
To: Rogers, Michael
Subject: RE: Robeson County landfill WI 0600074
Mike;
10-4. It appears that we both have the same document and that both are missing the maps, figures, plan sheets called
out in Attachment H.
Jim Barber
From: Rogers, Michael
Sent: Friday, May 20, 2011 2:22 PM
To: Barber, Jim
Subject: RE: Robeson County landfill WI 0600074
Right -I have a copy of this figure also. However, it indicates on the Attachment H page that' a map of the injection and
monitoring point locations is included'. Also, Figure 5 shows a series of injection points, but page 5 of the application
shows 3 proposed injection Wells are to be constructed. I'll ask for clarification in an Add Info letter.
Thanks
Michael Rogers, P.G. (NC & FL)
Environmental Specialist
NC Div of Water Quality- Aquifer Protection Section (APS)
1636 Mail Service Center
Raleigh, NC 27699-1636
Direct Line [phone]; Fax [phone] (put to my attn on cover letter)
http://portal.ncdenr.orq/web/w /aps/gwpro/permit-applications#geothermApps
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties
From: Barber, Jim
Sent: Friday, May 20, 2011 2:16 PM
To: Rogers, Michael
Subject: RE: Robeson County landfill WI 0600074
Mike;
The document binder that I have does not contain maps or other figures in the back under Attachment H. The only map
that indicates proposed injection points is under tab "A" and identified as fig. 5 (see attached map).
Jim Barber
From: Rogers, Michael
Sent: Friday, May 20, 2011 1:50 PM
To: Barber, Jim
Subject: Robeson County landfill WI 0600074
Jim-
1

In your copy of the application for tt . __Love site, is there a figure/map in Attach.::_.;t H showing the injection and
monitoring points?
If you have a map (my copy doesn't have this map), would you please scan and e-mail to me.
Thanks
Michael Rogers, P.G. (NC & FL)
Environmental Specialist
NC Div of Water Quality- Aquifer Protection Section (APS)
1636 Mail Service Center
Raleigh, NC 27699-1636
Direct Line [phone]; Fax [phone] (put to my attn on cover letter)
http://portal.ncdenr.orq/web/wq/aps/gwpro/permit-applications#geofhe rmApps
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties
2

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: April 4, 2011
To: ❑ Landon Davidson, ARO-APS
® Art Barnhardt, FRO-APS
❑ Andrew Pitner, MRO-APS
❑ Jay Zimmerman, RRO-APS
From: Michael Rogers Groundwater Protection Unit
Telephone: [phone]
E-Mail: Michael.Rogers@,nomail.net
❑ David May, WaRO-APS
❑ Charlie Stehman, WiRO-APS
❑ Sherri Knight, W-SRO-APS
Fax: [phone]
A. Permit Number: WI 0600074
B. Owner: Robeson Countv Solid Waste
C. Facility/Operation: -
❑ Proposed
® Existing
❑ Facility n Operation
D. Application:
1. Permi(_Type: ❑ Animal ❑ SFR-Surface Irrigation❑ Reuse , ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
• UIC - SI Groundw ater Remedration Well
For Residuals: ❑ Land App. ❑ D&M ❑ Surface Disposal
❑ 503 ❑ 503 Exempt ❑ Animal
2. ProjectType: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑
NOTE: If you plan to conduct a site visit I;would like to go n `along (providig ay_.schedule will
_ ry _ .._ _ a
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within, please take the following actions:
® Return a Completed APSARR Form and attach laboratory analytical results, if applicable.
❑ 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 and 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 07/06 Page 1 of 1

Michael F. Easley, Governor
:'
v
LAJ
u.
i
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]
January 17, 2007
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 Non -Biological Product by Regenesis to Enhance Biodegradation
of Contaminated Groundwater
Carmen Hooker Odom, Secretary
I am writing in response to a request for a health risk evaluation regarding the use
of a non -biological product by Regenesis to enhance biodegradation of contaminated
groundwater. Based upon my review of the information submitted, I offer the following
health risk evaluation:
1. Ingestion may result in burns to the lips, tongue, and mouth. Exposure to
the eyes can cause distortion of cellar membranes, loss of corneal,
conjunctival and lens epithelium and loss of endothelium of the cornea
and blood vessels. Inhalation may produce upper airway edema,
respiratory failure, wheezing, pulmonary edema, and pneumonitis. Skin
exposure may cause pain, redness, irritation and severe burns
(Micromedex TOMEs Plus System CD-ROM Database, Volume 71,
2007).
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 proper personal protective equipment
should be used. The application process should be reviewed by an
c.' industrial hygienist to ensure that the most appropriate personal protective
equipment is used.
O
3. Persons working with this product should at least wear goggles or a face
shield, gloves, and protective clothing. Face and body protection should
Location: 5505 Six Forks Road, 2nd Floor, Room D1 • Raleigh, N.C. 27609
An Equal Opportunity Employer

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. Violent reactions or ignition could occur under the appropriate conditions
with acids, alcohols, p-bis (1, 3-dibromoethyl) benzene, cyclopentadiene,
germanium, hyponitrous acid, maleic anhydride, nitroalkanes, 2-
nitrophenol, potassium peroxodisulfate, sugars, 2, 2, 3, 3-
tetrafluoropropanol, and thorium dicarbide. Measures should be taken to
prevent such reactions (Micromedex TOMEs Plus System CD-ROM
Database, Volume 71, 2007).
8. Measures should be taken to prevent contamination of existing or future
wells and surface waters that may be located near the application area.
Please do not hesitate to call me if you have any questions at [phone].
ear
L:,y