WI0600055_Permit (Modification)_20101207

Central Files: APS SWP_
12/07/10
Permit Number WI0600055
Permit Tracking Slip
Program Category
Ground Water
Permit Type
Injection In situ Groundwater Remediation Well (51)
Primary Reviewer
john.mccray
Coastal SW Rule
Permitted Flow
Facility
Facility Name
Former Abbott Facility (QualPac, Inc)
Status
Active
Project Type
Minor modification
Version Permit Classification
1.10 Individual
Permit Contact Affiliation
Grant Watkins
GMPRS
8540 Colonnade Dr
Raleigh NC 27616
Major/Minor Region
Minor Fayetteville
Location Address County
16000 Joy St Scotland
Laurinburg NC 28352 Facility Contact Affiliation
Owner'
Owner Name
Abbott Laboratories
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Corlis Murray
Bldg Ap52-S D0539
Abbott Park
IL 60064
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration,
08/24/10 10/04/10 12/03/10 12/03/10 07/31/12
Regulated Activities
Groundwater remediation
Outfall NULL
Reauested/Received Events
Region comments on draft received
Region comments on draft requested 10/28/10
Waterbody Name Stream Index Number Current Class Subbasin

NCDEM
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
December 3, 2010
Corlis D. Murray, Vice President
c/o Curt Michols
Global Engineering Services
Bldg. AP52-S, D0539
Abbott Park, I1 60064
Ref: Permit Modification for Injection Permit WI0600055
Former Abbott Laboratories Facility Site
Laurinburg, Scotland County, North Carolina.
Dear Mr. Murray:
This letter is being sent in reply to the letter received on October 4, 2010 regarding activities associated with permit
WI0600055. Our office has noted that due to subsurface conditions you have modified the number and locations of the
injection points from approximately 72 to 180. We also note that while you are increasing the number of injection points,
you are going to maintain the original volume of injectant as proposed in the original application. The modification of the
injection point grid has also slightly increased the overall volume of aquifer being impacted by the injection. This permit
shall remain effective from the date of issuance until July 31, 2012, and shall be subject to the conditions and limitations
stated therein, including the requirement to submit a final project evaluation as stated in PART VII — MONITORING
AND REPORTING REQUIREMENTS.
In regards to the well construction and abandonment requirements of the permit, we are aware that these particular
requirements are specific to permanent wells and they do not apply to temporary wells such as the direct -push injection
points permitted for this site. As far as the grouting of the injection points post -injection, this information should be
reported on the Well Abandonment Record (GW-30).
A point of clarification must be made in regards to the statement: "It is understood that a Well Abandonment Form to
address post -injection grouting of the borehole does not mean that the well then has an abandoned or discontinued use
status for our application." For each direct push point made, either a Well Construction (GW-1) AND Well Abandonment
(GW-30) Record must be submitted, or an alternate form approved by the Division and includes the information as set
forth in 15A NCAC 2C .0213(h)(1). These forms allow us to track wells across the state and are part of a database
maintained by the Division of Water Quality and used in reporting activities to federal agencies.
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh. North Carolina 27604
Phone: [phone] FAX 1: 919-715-0586; FAX 2: 919-715-60481 Customer Service: 1-877-623.6748
Internet: ww r ncwaterqualitv.orq
An Equal Opportunity \ Affirmative Action Employer
Noeth Carolina
Naturally

•
In order to continue uninterrupted legal use of the injection facility for the stated purpose, you must submit an application
to renew the permit 120 days prior to its expiration date. Please contact me at [phone] or at
[e-mail] if you have any questions about your permit.
Best Regards,
/4/—
John R. McCray
Environmental Specialist
cc: Art Barnhardt, Fayetteville Regional Office
Grant Watkins, PG, RSM
Qualpak, Inc.
WI0600055 Permit File
Enc: Permit WI0600055

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH, NORTH CAROLINA
PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WELL FOR INJECTION
In accordance with the provisions of Article 7, Chapter 87; Article 21, Chapter 143, and other
applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Abbott Laboratories
FOR THE OPERATION OF 180 TYPE 5I INJECTION WELLS, defined in Title 15A North
Carolina Administrative Code 2C .0209(e)(3)(C), to inject Anaerobic BioChem (ABC) solution and
RTB-1 (a proprietary blend of Dehalococcoides spp. bacteria), for the enhancement of
bioremediation of chlorinated aliphatic solvents. These injection wells will be located at the former
Abbott Facility now owned by QualPak, Inc., 16000 Joy St., Laurinburg, Scotland County, North
Carolina, will be temporary in nature, constructedusing direct -push probe technology, and will be
operated in accordance with the application submitted April 27, 2010, and revisions submitted in the
letter dated October 1, 2010, and in conformity with the specifications and supporting data
submitted, all of which are filed with the Department of Environment and Natural Resources and are
considered a part of this permit.
This permit is for Construction and Operation only, and does not waive any provisions of the Water
Use Act or any other applicable Laws, Rules, or Regulations. Operation and use of an injection well
shall be in compliance with Title 15A North Carolina Administrative Code 2C .0100 and .0200, and
any other Laws, Rules, and Regulations pertaining to well construction and use.
This permit shall be effective, unless revoked, from the date of its issuance until July 31, 2012, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 0 sd day offr'n \Der , 2010.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI060005
ver.8/07 AP/UIC-6
PAGE 1 OF 7

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions of this permit and with the standards and criteria
specified in Criteria and Standards Applicable to Injection Wells (15A NCAC 2C .0200). Any
noncompliance with conditions of this permit constitutes a violation of the North Carolina Well
Construction Act and is grounds for enforcement action as provided for in N.C.G.S. 87-94.
2. This permit shall become voidable unless the facility is constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is valid only for construction of the number of injection wells described in the
application and other supporting data. Construction of additional injection wells must be
approved in advance by the Aquifer Protection Section.
4. Each injection well shall not hydraulically connect separate aquifers.
5. Each injection well shall be constructed in such a manner that water from land surface cannot
migrate into the gravel pack or well screen.
6. Each injection well shall be secured to reasonably insure against unauthorized access and use.
Each well shall be permanently labeled with a warning that it is for injection purposes and the
entrance to each well must be secured with a locking cap.
7. Each injection well shall be afforded reasonable protection against damage during construction
and use.
8. Each injection well shall have permanently affixed an identification plate.
9. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify the
Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff, telephone
number [phone] and the Fayetteville Regional Office Aquifer Protection Section Staff,
telephone number [phone].
Permit No. WI0600055 PAGE 2 OF 7
ver.8/07 AP/UIC-6

PART III - OPERATION AND USE GENERAL CONDITIONS
1. This permit is effective only with respect to the nature, volume of materials, rate of injection, and
number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to change
ownership, or there is a name change of the Permittee, a formal permit amendment request must
be submitted to the Director, including any supporting materials as may be appropriate, at least
30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying with
any and all statutes, rules, regulations, or ordinances which maybe imposed by other local, state,
and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not
imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is no
contamination of groundwater which will render it unsatisfactory for normal use. In the event
that the facility fails to perform satisfactorily, including the creation of nuisance conditions or
failure of the injection zone to adequately assimilate the injected fluid, the Permittee shall take
immediate corrective actions including those actions that may be required by the Division of
Water Quality such as the repair, modification, or abandonment of the injection facility.
2. The Permittee shall be required to comply with the terms and conditions of this permit even if
compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director of
any planned physical alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
3. At least forty-eight (48) hours prior to the initiation of the operation of the facility for injection,
the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central Office staff,
telephone number [phone]. Notification is required so that Division staff can inspect or
otherwise review the injection facility and determine if it is in compliance with permit
conditions.
Permit No. WI0600055 PAGE 3 OF 7
ver.8/07 AP/UIC-6

PART VI - INSPECTIONS
1. Any duly authorized officer, employee, or representative of the Division of Water Quality may,
upon presentation of credentials, enter and inspect any property, premises, or place on or related
to the injection facility at any reasonable time for the purpose of determining compliance with
this permit, may inspect or copy any records that must be maintained under the terms and
conditions of this permit, and may obtain samples of groundwater, surface water, or injection
fluids.
2. Department representatives shall have reasonable access for purposes of inspection, observation,
and sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the, inj ection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed monitoring plan included in the application shall be followed. All sample results
shall be submitted to the Aquifer Protection Section's .Fayetteville Regional Office and the
Raleigh Central Office. Any monitoring (including groundwater, surface water, or soil sampling)
deemed necessary by the Division of Water Quality to insure surface and ground water
protection, will be established and an acceptable sampling reporting schedule shall be followed.
2. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
3. The Permittee shall produce a final project evaluation within 9 months after completing all
injection -related activity associated with this permit or produce a project interim evaluation
before submitting a renewal application for this permit. This document shall assess the injection
projects findings in a written summary. The final project evaluation shall also contain
monitoring well sampling data, contaminant plume maps and potentiometric surface maps.
4. The monitoring results and the final project evaluation shall be submitted to:
and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Fayetteville Regional Office
225 Green St., Suite 714
Fayetteville, NC 28301
Permit No. WI0600055 PAGE 4 OF 7
ver.8/07 AP/UIC-6

i
5. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge of
the occurrence, to the Fayetteville Regional Office, telephone number [phone] , any of the
following:
(A) Any occurrence at the injection facility which results in any unusual operating
circumstances;
(B) Any failure due to known or unknown reasons, that renders the facility incapable of
proper injection operations, such as mechanical or electrical failures.
6. Where the Permittee becomes aware of an omission of any relevant facts in a permit application,
or of any incorrect information submitted in said application or in any report to the Director, the
relevant and correct facts or information shall be promptly submitted to the Director by the
Permittee.
7. In the event that the permitted facility fails to perform satisfactorily, the Permittee shall take such
immediate action as may be required by the Director.
PART VIII - PERMIT RENEWAL
In order to continue uninterrupted legal use of the injection facility for the stated purpose, the
Permittee must submit an application to renew the permit 120 days prior to its expiration date.
PART IX - CHANGE OF WELL STATUS
1. The Permittee shall provide written notification within 15 days of any change of status of an
injection well. Such a change would include the discontinued use of a well for injection. If a
well is taken completely out of service temporarily, the Permittee must install a sanitary seal. If a
well is not to be used for any purpose that well must be permanently abandoned according to
15A NCAC 2C .0113, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .0113(b), including but not limited to the following:
(A) All casing and screen materials may be removed prior to initiation of abandonment
procedures if such removal will not cause or contribute to contamination of the
groundwaters.
(B) The entire depth of each well shall be sounded before it is sealed to insure freedom from
obstructions that may interfere with sealing operations.
(C) The well shall be thoroughly disinfected, prior to sealing, if the Director determines that
failure to do so could lead to the contamination of an underground source of drinking
water.
Permit No. WI0600055 PAGE 5 OF 7
ver.8/07 AP/UIC-6

(D) Drilled wells shall be completely filled with cement grout, or bentonite grout which shall
be introduced into the well through a pipe which extends to the bottom of the well and is
raised as the well is filled.
(E) In the case of gravel -packed wells in which the casing and screens have not been
removed, neat -cement, or bentonite grout shall be injected into the well completely filling
it from the bottom of the casing to the top.
(F) In those cases when, as a result of the injection operations, a subsurface cavity has been
created, each well shall be abandoned in such a manner that will prevent the movement
of fluids. into or between underground sources of drinking water and in accordance with
the terms and conditions of the permit.
(G) The Permittee shall submit a Well Abandonment Record (Form GW-30) as specified in
15A NCAC 2C .0213(h)(1) within 30 days of completion of abandonment.
3. The written documentation required in Part DC (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows: bums
to the eyes, skin, nose, and throat can be caused by exposure; can cause dizziness,
lightheadedness, and loss of consciousness; and can be significantly absorbed through the skin
and lungs. If the product is 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.
9.
Persons working with these products should wear goggles or a face shield, gloves, and protective
clothing. Face and body protection should be used for anticipated splashes or sprays.
3. This product is highly flammable and vapors may form explosive mixtures with the air. Vapors
may travel to an ignition source and flashback by spreading along the ground and collecting in
low, confined areas. The storage containers for this product should be kept well closed and
runoff to sewer may create a fire or explosion hazard. Also containers may explode when
heated. In addition, this product releases toxic hydrogen sulfide on contact with acids and reacts
violently with carbon, diazonium salts, n-dichloromethylamine, o-nitroaniline diazonium salt,
and water.
4. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
Permit No. WI0600055 PAGE 6 OF 7
ver.8/07 AP/UIC-6

5. Site access should be limited to worker's involved in the injection of the solution. Safety
controls should be in place to ensure that the check valve and the pressure delivery systems are
working properly.
6. It is imperative that the Material Safety Data Sheets be followed to prevent incompatible or
adverse reactions and injuries.
Permit No. WI0600055 PAGE 7 OF 7
ver.8/07 AP/UIC-6

ABBOTT LABORATORIES
Curtis R. Michols
Principal Specialist
Global Environment, Health, Safety & Energy
October 1, 2010
Mr. John McCray
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Aquifer Protection Section
Underground Injection Control Program
1636 Mail Service Center
Raleigh, NC 27699-1636
Dept. 539, Bldg. AP52-S
200 Abbott Park Road
Abbott Park, Illinois 60064-6212
Office: [phone]
Facsimile: [phone]
[e-mail]
Subject: Notification and Revisions Regarding Injection Control Permit WI0600055
Former Abbott Labs Facility -Solvent Release Remediation
Laurinburg, Scotland County, NC
NCDENR-DWM #NONCD-000-0040
Dear Mr. McCray:
CD
o -r'
C-i i'
Abbott Laboratories (Abbott) is contacting you regarding several clarifications and proposed
revisions for Injection Permit W10600055 that was recently issued for the above -referenced
facility. This information is provided as a follow-up to conversations that you had with our
environmental consultant for the remediation we are conducting, Mr. Grant Watkins of AECOM
on July 27, 2010 and on September 21, 2010 concerning initial estimates for the number of direct
push injection boreholes and the procedures for notifying the NCDENR if additional injection
boreholes are required. Based on current permit provisions and refinements of the injection plan,
Abbott hereby presents an update to the proposed injection program for NCDENR's approval in
accordance with Permit articles Part I.3 and Part III.1.
Revisions to Injection Layout
The initial injection plan for the permit application in April 2010. Although the original plan
estimated that up to 72 individual injection boreholes would be installed at twenty-five separate
locations, it also stated that additional multi -depth injection boreholes may be necessary based on
site -specific lithology and injection conditions. The Permit currently allows only 72 individual
direct push injection boreholes, each of which we understand that NCDENR considers a separate
Type 5I injection well. Since submittal of the permit application, the injection plan has been
further refined by adding more closer -spaced borehole clusters and allowances for more than
three injection depth intervals per location. The current 72-injection well limit in the Permit also
aA Promise for Life
Abbott

Mr. John McRay
NC DENR
Page 2 of 4
October 1, 2010
does not allow sufficient capacity for the bioaugmentation injection boreholes, which will be
installed separate from the ABC® injection boreholes.
A Preconstruction Report has been submitted to the NCDENR Division of Waste Management
that describes the current, detailed injection plan. The only significant change being proposed is
the number of locations and the total number of individual boreholes (i.e., injection wells) that
may ultimately be required based on actual site conditions and injection responses. Please
consider the following updated information for your review and approval:
• The number of injection locations (i.e., multi -depth "clusters"), is increased from 25 to
55. This is due to a larger number and closer spaced rows of injection boreholes and
tightening of the location spacing from 30-foot centers to 20-foot centers. See the
attached Figure 3-3 from the Preconstruction Report for more details on the revised
layout.
• The total number of individual injection boreholes (Type 5I wells) is increased from 72 to
180. This increase is due to the both the greater number of locations and the need for
more flexibility in the number of individual injection depths targeted by the boreholes at
each location based on subsurface conditions. The proposed increase allows more
efficient distribution of the ABC® and also allows additional capacity for injection
boreholes related to the bioaugmentation pilot test.
• The injection zone boundary has increased slightly to the south to allow ABC® substrate
injection in areas closer to the where the RTB-1 may be injected for the bioaugmentation
pilot test. The depths of the injection zone have not changed from the original permit
application.
There are several important factors to note about these proposed changes in the context of the
overall injection program as currently permitted. First, the total volume of injectate fluids will
not increase and will remain at 59,900 gallons or less per injection event. Second, the overall
volume of the aquifer being treated increases to about 800,000 cubic feet by expanding the
footprint 35 feet further to the south. In summary, compared to conditions in the permit
application these proposed changes allow the same volume of ABC® injectate fluids to be
injected into a slightly larger aquifer volume using a larger number of wells (boreholes) that are
spaced closer together. Each individual borehole will therefore receive a lower volume of
injectate fluid per injection depth interval than originally specified.
Also, we would like to clarify how the RTB-1 injection program will be conducted. The initial
injections will be in a limited area and involve only 20 liters of RTB-1 to perform a
bioaugmentation pilot study. Based on the outcome of the pilot study and other testing, Abbott
may decide to expand the bioaugmentation program to larger areas of the dissolved plume prior
to expiration of Permit WI0600055 in July 2012. The NCDENR Division of Water Quality will
be notified if and when the bioaugmentation program will be expanded and if approval for
additional injection wells (boreholes) are needed at that time.
aA Promise for Life
Abbott

Mr. John McRay
NC DENR
Page 3 of 4
Other Permit Issues and Clarifications
October 1, 2010
In our review of Injection Permit WI0600055, Abbott and AECOM noted that several permit
requirements are listed that are not applicable to the injection processes planned for the
Laurinburg site. Specifically, some provisions of the permit were written based on rules and
requirements for construction, maintenance, and abandonment of permanent injection wells. No
permanent injection wells will be used for our injection program, and the temporary direct push
boreholes will function quite differently. Permit articles, as currently written, that are not
applicable to our proposed injection process include but may not be limited to the following:
• Part I, Items 5, 6, 7, and 8.
• Part IX, Items 1, 2 (A), 2(B), 2(C), and 2(E).
To clarify our positions regarding these permit requirements, Abbott provides the following
information regarding our plans and requests to NCDENR:
• Due to their construction nature, the temporary injection boreholes (wells) cannot be
completed with secured locking caps or with permanently affixed identification plates or
sanitary seals. So we propose to not have to perform these actions.
• A change of status notification for discontinued use of an injection well is not possible in
our situation. Once the injectate fluid is introduced to the borehole the injection well
becomes active and that is the only time injection will occur at that specific borehole.
Other than the Permit expiration date, we cannot determine a date at which the injection
well becomes inactive or its use is otherwise considered `discontinued' as stated in the
Permit.
• The temporary injection wells will be grouted to the ground surface within 12 hours after
the one-time ABC® injection occurs at each borehole. Abbott requests confirmation if
this grouting process fulfills the requirements for constructing the injection well and is
reported on the Well Construction Record (Form GW-1); or if this process fulfills the
requirement for well abandonment and is reported on a Well Abandonment Record (Form
GW-30). It is understood that submittal of a Well Abandonment Form to address post -
injection grouting of the borehole does not mean that the well then has an abandoned or
discontinued use status for our application.
We appreciate your review of this submittal and look forward to NCDENR's prompt written
response and approval to these requests. Currently we are planning to start injections on October
14, 2010 and would appreciate a response from NCDENR prior to that date, so that the field
activity plans and schedules can be maintained. If you have any questions and/or require
additional information, please contact either me or Grant Watkins with AECOM at 919-239-
7183.
aA Promise for Life
Abbott

Mr. John McRay
NC DENR
Page 4 of 4
Best regards,
Ab)dtt Icab , . tories
is Mic s s
Principa Specialist
Global Environment, Health, Safety & Energy
c.c.: G. Watkins, AECOM
October 1, 2010
aA Promise for Life
Abbott

LEGEND NOTES
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