WI0700124_Staff Report_20101209

Slusser, Thomas
From: May, David
Sent: Thursday, December 09, 2010 11:09 AM
To: Slusser, Thomas
Cc: Hart, William
Subject: RE: injection permit W10700124
OK with me.
David May, Regional Aquifer Protection Supervisor
Washington Regional Office
Division of Water Quality
Aquifer Protection Section
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
Fax: [phone]
E-mail: david.mayAncdenr.gov
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: Slusser, Thomas
Sent:-Thursday,_December-09,2010 11:49 AM- _
To: May, David; Hart, William
Subject: injection permit WI0700124
Hey guys,
For the subject permit I got a request from the permittee to do an additional injection event. I plan to send a letter of
approval, so let me know if you have any concerns about me doing this.
Take care,
- Thomas Slusser, L.G.
Program Manager
Underground Injection Control Program
DWQ - Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
thomas.slusset @ncdenr.gov
ph# 919-715-6164
fax# [phone]
E-mail correspondence to and Pram this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

t
AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
® 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 repoited 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)? El
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. El Yes ❑ NoZ
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?
0 Yes ❑ No El 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 Z 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?)
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 (51)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify:
2. Does system use same well for water source and injection? ❑ Yes Z No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ® No

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AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
What is/are the pollution source(s)? former dry-cleaning operation. What is the distance of the injection well(s)
from the pollution source(s)? 0 ft.
4. What is the minimum distance of proposed injection wells from the property boundary? ft.
5. Quality of drainage at site: ❑ Good ® Adequate ['Poor
6. Flooding potential of site: ® Low 0 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:
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.
Iniection 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)?
❑ Yes ❑ No. If yes, explain:
-2. . For -closed -loop -heat -pump systems, :has -system lost pressure_or requiredmake-up fluid since permit issuance
or last inspection? ❑ Yes 0 No. If yes. explain:
3. For renewal or modification of groundwater remediation permits (of any time). 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: Gary Meyers
Address:
Certification number: 3380
5. Complete and attach Well Construction Data Sheet.
V. EVALUATION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: The site is located on an out -parcel
at Southgate Mall in Elizabeth City, NC. The site is currently operating as a Captain D's seafood restaurant.
Site consists of a building and is covered with asphalt parking lot. The permit is being sought to remediate a
perchloroethylene (PCE) plume, resulting from the former dry-cleaning operation on the property, using ABC+
(addition of zero valent iron). More time may be needed to complete the injection activities than the 13 days
indicated in the application.

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]
Michael F. Easley, Governor Carmen Hooker Odom, Secretary
November 4, 2004
MEMORANDUM
TO: Evan Kane
Underground Injection Control Program
Aquifer Protection Section / N
FROM: Luanne K. Williams, Pharm.D., Toxicologist U"
Medical Evaluation and Risk Assessment Uni
Occupational and Environmental Epidemiology Branch
North Carolina Department of Health and Human Services
SUBJECT: Use of ABC® by Redox Tech, LLC and KB-1Th Culture by SiREM Laboratories
and Bio-Dechlor INOCULUM to Enhance Biodegradation of Groundwater
Contaminated with Chlorinated Solvents
- _-- I am:writingin=response=to•a-rec uest.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 theinformation-submitted, I offer the
following health risk evaluation:
PRECAUTIONS DURING APPLICATION
n
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 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 reviewedby 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 access to the 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 Lalce 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 [phone].
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

North Carolina
Department of Health and Human Services
Division of Epidemiology
P.O. Box 29601 • Raleigh, North Carolina 27626-0601
Tel: [phone] Fax: [phone]
James B: Hunt Jr., Governor - H. David Bruton, M.D., Secretary
J. Steven Cline, DDS, MPH, Acting Director
MEMORANDUM
TO:
October 2, 1998
Amy Axon
Underground Injection Control Program
Groundwater Section
FROM: Luanne K. Williams, Pharm.D., Toxicologist
Medical Evaluation and Risk Assessment Branch
Occupational and Environmental Epidemiology Section
SUBJECT: Health Risk Evaluation Regarding the Use of Certain Products Manufactured by
Peerless Metal Powders and Abrasive in the Treatment of Groundwater at the
DuPont Kinston Plant in Lenoir County
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I am writing in response to a request from Mr. Clifford Lee with DuPont for a health risk
--evaluation-regarding-the use of certain products manufactured .by_Peerless.Metal Powders and_
• Abrasive in the treatment of groundwater at the referenced site. Based upon my review of the
information submitted, I offer the following health risk evaluation:
WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the products proposed to be used are as
follows: eye, skin, nose, throat, and lung irritation. 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 proper personal protective
equipment should be used. The application process should be reviewed by an industrial
hygienist to ensure that the most appropriate personal protective equipment is used.
2. 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. Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be
permitted in the application area during or immediately following application.
North Carolina: Host of the 1999 Special Olympic World Summer Games

Amy Axon Memo
October 2, 1998
Page Two
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
5. It is imperative that the Material Safety Data Sheets be followed to prevent incompatible
or adverse reactions and injuries.
• OTHER PRECAUTIONS
1. 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.
2. According to the information submitted with the letter dated September 18, 1998, "The
only groundwater production wells within one mile of the study area are DuPont Kinston
Plant wells (used for non -contact cooling water). The nearest public water supply well is
the City of Grifton Well No.2, located 3.4 miles to the northeast. The treatment wall
will be emplaced in the surficial aquifer at the site. This aquifer is not used as either a
public or private source of water; therefore, there will be no impact to any of the
identified wells (which pump groundwater from depths greater than 200 feet). DuPont
Kinston Plant potable water supply is provided by the local municipal water district."
In order to protect public health, it is recommended to confirm the absence of nearby well
users in the area. Measures should be taken to prevent contamination of existing or future
wells that may be located near the application area.
3. According to the information submitted, Beaverdam Branch is the nearest surface water
body located approximately 1,800 feet north of the study area. It is recommended to
contact Ms. Dianne Reid with the Water Quality Section at [phone] extension 568
to determine if these products or process could impact Beaverdam Branch.
If you have any questions, contact me at [phone].
LKW:dg
cc: Ms. Linda Blalock, Groundwater Section
Mr. Bob Cheek, Groundwater Section
Mr. Clifford Lee, DuPont Fibers
Dianne Reid, Water Quality Section