WI0600055_Permit (Issuance)_20100902

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 72 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 points will be located at the former Abbott Facility
now owned by QualPak, Inc., 16000 Joy St., Laurinburg, Scotland County, North Carolina, and will
be operated in accordance with the application submitted April 27, 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 hereof. I through X
Permit issued this the Z day of ltr(v� , 2010.
rColeen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0600055 PAGE 1 OF 7
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PART I - WELL CONS UCTION GENERAL CONDITION
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 insureagainst 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
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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 - INSPECTI(ms
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 injection 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 monthsafter 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
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5. The Permittee shall report oy 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 VHI - 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
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(D) Drilled wells snail 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 IX (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: burns
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.
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. 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
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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

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
August 24, 2010
PERMIT ISSUANCE MEMO
TO: Debra Watts Ye 41 .
THROUGH: Thomas Slusser !J S
FROM: John McCray v "i r.1, - @�G 1
RE: Permit To Inject Anaerobic BioChem (ABC) and RTB-1 f tr-A-
'2-In6P
I recommend that Permit Number WI0600055 be issued to Abbott Laboratories to inject Anaerobic BioChem (ABC)
and RTB-1 to remediate groundwater contaminated with chlorinated solvents.
Former Abbott Laboratories Site
SITE DESCRIPTION Chlorinated volatile organic compounds (primarily TCE) were released to the groundwater
through the use of a former waste evaporation/disposal pit. Contaminants have been known to be in the soil and
groundwater at the site since 1989. Remedial Injection utilizing zero-valent iron and a thixotrophic slurry for
reductive dehalogenation and HRC for further enhancement of biological reduction has occurred at the facility under
two previous permits; WI0600010 and WI0600011. Currently the site is being used by QualPak to manufacture and
package hand sanitizer. Contamination is located within the matrix of fine grained sediment and within the
groundwater of the surficial aquifer and is moving toward the south-southwest.
HYDROGEOLOGIC DESCRIPTION The site is located within the inner Coastal Plain Physiographic Province and
is underlain primarily by inter -bedded sand, silt and clay of the Coastal Plain Middendorf Formation. Within the
constraints of the site, these sediments compose a surficial aquifer contained primarily within the sand and silty sand
layers (Fig. 7B). Interlayered silt and clay act as a retaining media for contaminants and contribute to residual
contamination. The average depth to groundwater is -10.5 feet below ground surface which flows to the south-
southwest under a hydraulic gradient of .003 ft/ft through an aquifer with a hydraulic conductivity ranging from 2.16
to 2.76 ft/day. The average velocity for groundwater under these conditions is approximately .01 ft/day. ��--��2
EXTENT OF CONTAMINATION Contaminant distribution of TCE for concentrations above the CGQVQ)in
the upper portion of the surficial aquifer based on the most recent sampling event, has an ovate shape in plan view
(-810 feet in length) with the long axis trending north -northeast -south-southwest and is -275 ft wide. In the lower
portion of the surficial aquifer, distribution of TCE for concentrations above the NCGWQS based on the most recent
sampling event has a crescent shape in plan view (-1300 feet in length) with the long axis trending north -northeast -
south -southwest, curving to the west near MW-104C and is -350 ft wide at the widest portion. The plume extends to
a depth greater than the monitoring well network (>65ft bgl)(Fig. 6 and 7).
PROPOSED INJECTION The applicant proposes to inject 59,900 gallons of solution composed of Anaerobic
BioChem at a pressure between 30 -100 psi into the surficial aquifer through 72 direct push points and a-25 gallons
of DHC culture through 19 of the 72 total direct push points, divided between 3 injection vents separated by a 3 to 9
month waiting period. The total volume of injectants comprises approximately an average of -5% of the injection
area.
HOW IT WORKS The main remedial activity of the injectant solution is to promote a more favorable
environment for naturally occurring halorespirating bacteria to continue consumption and degredation of the
contaminants. RTB-1 is a proprietary blend of Dehalococcoides spp. bacteria that will supplement the naturally
occurring organisms consumption of chlorinated VOCs.

MONITORING Twenty-three (23) existing monitoring wells located at the site are currently being used to
monitor for changes in groundwater flow and contaminant concentrations as part of ongoing activities at the site. On-
going sampling for constituents will be augmented by monthly and quarterly sampling of wells in the vicinity of the
injection area for metabolic organic acids, DHC bacteria, and Dehalobacter spp. (DHB) bacteria for a duration of six
months.
EPIDEMIOLOGY On November 4, 2004, the DHHS'. Epidemiology Branch provided comments on the use of
Anaerobic BioChem (ABC) for groundwater remediation. Dr: Luanne K. Williams did not present any information
that would preclude the use of these products for injection but did provide a health risk analysis and worker safety
precautions, which are in Part X of the attached permit. On January 18, 2008, the DHHS' Epidemiology Branch
provided comments on BAC-9 for groundwater remediation which was verified as the same culture as the proposed
injectant RTB-1 on January 14, 2010 by Dr. Robert Steffan of Shaw Environmental & Infrastructure, Inc.. Dr.
Luanne K. Williams did not present any information that would preclude the use of these products for injection but
did provide a health risk analysis and worker safety precautions, which are in Part X of the attached permit.
REGIONAL OFFICE COMMENTS Jim Barber of the Fayetteville Regional Office has no issues with the application
and recommends issuance of this permit.

Abbott Global Citizenship: Environmental Management & Policy
http://www. abbott.com/global/url/content/en_US/40.3 5.25:25/general...
Global Citizenship
OUR STRATEGIC PRIORITIES
Innovating
for the
Future
Enhancing
Access
Protecting
Patients and
Consumers
Safeguarding the Environment
Environmental Management & Policy
.Abbott
A F&'r a ice Lite
Safeguarding
the
Environment
Clear policies, standards and management systems ensure we
operate in a manner that protects both human health and the
environment. Our environmental management metrics, auditing
and reporting mechanisms are evaluated regularly, and we hold
our managers responsible for improving their performance
against these targets as part of our annual performance appraisal
process. For a second straight year, Abbott achieved the
maximum score In the environmental policy and management
category of the Dow Jones Sustainability Index.
Our environmental policy achieves these objectives:
t Improve the efficiency and sustainability of our business
activities and products, reducing greenhouse gas
emissions, water use and waste.
s Require contractors working on behalf of Abbott to
conform to regulatory requirements and meet applicable
internal Environment, Health and Safety (EHS) standards.
) Establish goals and strategies for the enterprise and
report publicly on our progress.
r Integrate sound EHS practices consistent with our
management system into all aspects of the business,
maintaining legal compliance.
Assurance Statement
Abbott has engaged ERM to conduct an assurance of its
greenhouse gas and water data, as well as the related
management systems. Click here fora copy of the statement.
ERM Statement (PDF)
Energy and Water Policies
Abbott has outlined two key sets of commitments In the following documents:
Energy Policy (PDF)
This policy outlines a number of aggressive and significant goals to further reduce our environmental footprint,
including the commitment to a carbon -neutral fleet end to dramatically reduce our overall CO2e emissions.
Access to Water Policy (PDF)
This policy details Abbott's commitments to improve access to clean water in communities around the globe as
well as our own commitment to reduce and manage efficiently the company's water use.
"Abbott strives to be a good
steward of the earth and its
resources — with every product
we make and in every market
we serve. We are committed to
reducing our carbon intensity
and water use, while revising
product features and design to
minimize environmental
impact."
Corks Murray, Vice President,
Global Engineering Services
Environmental Standards
Codis Murray, Vice President,
Global Engineering Services, leads
a team of more than 1,000
professionals In advancing Abbott's
operational excellence while
ensuring environment, health and
safety leadership.
We have clear, consistent policies and standards requiring that we operate in a manner that protects human
health and the environment Our global standards Include technical program requirements, metrics and audit
and reporting mechanisms that serve as a baseline expectation for environmental performance is evaluated
regularly.
Our management standards set minimum requirements in the following areas:
Environmental Policy and Program.
Strategic Planning.
Self Assessment/Risk Assessment.
Business Integration.
Training and Awareness.
Communication and Information.
Performance Measures.
Assurance Reviews.
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Environmental Global Standards.
These technical standards allow Abbott to have consistent technical expectations in all our manufacturing
operations around the world.
EHS Technical Standards (PDF)
Environmental Management, Performance & Training
Improving our performance requires clear lines of accountability and senior -level leadership and support. We
have multiple levels of environmental management oversight within businesses and across the company. The
Vice President for Global Engineering Services, a corporate officer, reviews metrics, key programs and
progress with the Chairman and CEO on a regular basis.
We recognize that continuously improving our environmental performance demands clear lines of
accountability and senior -level leadership and support. The following groups implement our Environment,
Health and Safety (EHS) programs and initiatives:
Global Operations Council: This body sets priorities for all Abbott plants, and makes resources available to
meet local needs. Chaired by a corporate officer, the council consists of our heads of manufacturing and
senior EHS executives.
Commercial EHS Executive Council: This council sets and implements EHS goals and objectives for our
sales operations around the world. A corporate officer chairs this group.
EHS Executive Council: This group develops and implements programs and actions that are consistent with
the priorities set by the Global Operations Council and the Commercial EHS Executive Council. This team
meets regularly to share best practices and discuss EHS issues with companywide implications. This group
also builds awareness of EHS performance, promotes our EHS Excellence Awards, supports EHS training and
conferences, and communicates our performance improvement initiatives.
Property Remediation
Under the Comprehensive Environmental Response, Compensation, and Liability Act, commonly known as
Superfund, we have been identified as one of many potentially responsible parties in investigations at 13
locations in the United States, none of which are owned or operated by Abbott, for releases of materials into
the environment. At four of these locations, there has been no involvement on the part of Abbott, and we
believe that we have no liability at those locations. We also are engaged in remediation at five other locations,
some of which are owned by Abbott, in cooperation with the U.S. Environmental Protection Agency or similar
agencies. While it is not feasible to predict with certainty the final costs related to these investigations and
remedial activities, we believe that such costs should not have a materially adverse effect on our financial
position, cash flours or operations.
Waste Management
All vendors responsible for the management of Abbott -generated waste are expected to meet minimum
requirements in areas such as compliance, financial assurance, inventory control/record keeping, facility
design/operating conditions and permission, among others. Vendors who do not meet these standards are not
permitted to do business with our company. Substandard waste management firms are identified through the
implementation of Abbott's waste vendor assessment program. This includes periodic on -site evaluations and
documentation reviews to help ensure that only appropriately qualified and responsible vendors are permitted
to manage Abbott waste. Our approach helps us to quickly identify emerging issues and resolve problems in a
timely fashion.
Managing Potentially Hazardous Materials
Abbott's Process Safety Management Program is aimed at preventing the consequences of incidents involving
hazardous materials used in our manufacturing processes. In 2006, we refined our long-range plan to help
ensure consistent implementation of the systems necessary for process -safety in each Abbotl division. We
conducted more than 80 process hazard analyses at our sites around the world. Additionally, communication
between our sites has improved through the use of online training, working committees to exchange ideas and
the deployment of technical guidelines.
Global EHS Audits
Abbott's Global EHS audit function systematically evaluates our EHS-related performance and compliance
status, These periodic assessments serve several purposes, including Identifying significant risks to
employees, the environment and the company; fostering continuous improvement developing staff expertise;
and promoting knowledge transfer. Abbott facilities are typically audited once every 36 months to assess
compliance with regulatory and internal requirements. If noncompliant situations are found, audited facilities are
responsible for developing and implementing action plans, which are tracked through completion.
To ensure compliance with intemal Abbott Global EHS Management and Technical Standards, Abbott EHS
professionals have partnered with commercial management to complete formal on -site EHS GAP
assessments. During these assessments, affiliates are provided with compliance tools and implementation
resources designed to ensure sustainable compliance and program improvement.
During 2009, Abbott conducted 24 integrated EHS site audits, compared with 28 in 2008, placing greater
emphasis on commercial locations and distribution centers, especially
2015 Goals, Performance & Regional Data
Abbott has a long track record of setting environmental performance targets — and challenging ourselves.to
achieve even greater results. Because we achieved our previous environmental goals well ahead of schedule,
Abbott in 2009 established a series of new targets to further minimize our environmental impacts. By 2015, we
seek to reduce:
1 Absolute CO2 emissions (from direct emissions or sources we own or control and from electricity we
purchase) by 15 percent.
•1 Total water intake by 50 percent (adjusted for growth).
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