WQ0040419_Non-Discharge Remediation Permit_20190816

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
August 16, 2019
Moniqua Williams, Environmental Program Manger
United Parcel Service
UPS Corporate Plant Engineering
55 Glenlake Parkway
Atlanta, GA 30328
RE: Non -Discharge GroundwateiRemediation Permit WQ0040419
Former UPS Greensboro Facility
Guilford County
Dear Ms. Williams:
In accordance with your request for permit application received November 8, 2018, and
completed additional information request packages received on June 4 and August 15, 2019, we
are forwarding herewith Permit No. WQ0040419 for construction and operation of the above
referenced subject groundwater remediation system. This permit shall become effective on date
of issuance until July 31, 2024, and shall be subject to the conditions and limitations stated
therein.
Please pay particular attention to the monitoring requirements in this permit. Failure to establish
an adequate system for collecting and maintaining the required operational information will
result in future compliance problems.
Please note the following in your permit:
• Part III.1- The monitoring wells (including the new proposed well located on the
west side of the property) and the treatment system's influent, mid -fluent, and
effluent sampling ports shall be sampled at the frequency and for the parameters
specified in the permit application package received on November 8, 2018, and
revised Table 1 included in the completed additional information package received
on August 15, 2019.
• Part IV.3- The Permittee shall submit a treatment system efficiency report within 3
months of operation to evaluate if system is operating according to design (a pilot
test result). A review of the pilot test may result in a revision to increase or decrease
subsequent monitoring frequency.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11636 Mail Service Center I Raleigh, North Carolina 27699-1636
919.707.9000

If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following
receipt of this permit. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made
this permit shall be final and binding.
If you need any additional information concerning this matter, please contact Michael Rogers at
919-707-3668 or [e-mail].
Sincerely,
c
j Linda rulpepper
Director, Division of Water Resources
cc: Guilford County Environmental Health Department
Winston-Salem Regional Office, WQROS
WQ0040419 Permit File

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
GROUNDWATER REMEDIATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended,
and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
United Parcel Service
Guilford County
FOR THE
construction and operation of a 8,640 gallons per day (GPD) Dynamic Groundwater Re -circulation (DGR)
groundwater remediation system consisting of two (2) pneumatic positive displacement extraction wells (EW-1 and
EW-2), 5 horse power (HP) reciprocating air compressor mounted to a 60-gallon storage tank, single bag filter,
1,000-gallon holding tank, %2 HP transfer pump, two 500-gallon liquid granular activated carbon filters (GACs),
and three (3) injection wells (IW-1, IW-2, and IW-3) to remediate petroleum contaminated groundwater, pursuant
to the application received November 8, 2018, and completed additional information request packages received on
June 4 and August 15, 2019, by the Division of Water Resources (Division), and in conformity with the project
plan, specifications, and other supporting data subsequently filed and approved by the Division and considered a
part of this permit.
This permit shall be effective from the date of issuance until July 31, 2024, and shall be subject to the
following specified conditions and limitations:
I. PERFORMANCE STANDARDS
1. Upon completion of construction and prior to operation of this permitted facility, a certification must be
received from a professional engineer (attached) certifying that the permitted facility has been installed in
accordance with this permit including, the approved plans and specifications, location and construction of
the new proposed monitoring well located on west side of the property, and other supporting materials. If
this project is to be completed in phases and partially certified, you shall retain the responsibility to track
further construction approved under the same permit, and shall provide a final certificate of completion
once the entire project has been completed. Mail the Certification to the UIC Program -Division of Water
Resources, and a copy to the Winston-Salem Regional Office at the addresses referenced in Part IV.
WQ0040419 Non -Discharge (rev. 9/12/2016) Page 1 of 7

2. The Winston-Salem Regional Office, telephone number 336-776-9800, shall be notified at least forty-eight
(48) hours in advance of operation of the installed facilities, including the initiation of injection operations,
so that an in -place inspection can be made. Such notification to the regional supervisor shall be made
during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays
3. This permit shall become voidable and may be rescinded unless the facilities/wells are installed, maintained,
and operated in a manner which will protect the assigned water quality standards of the surface and
groundwaters. In the event that the facility or injection wells fail to perform satisfactorily, or the injection
zone fails to adequately assimilate the injected fluid, the Permittee shall take immediate corrective actions,
including the repair, modification, or abandonment of the facility/wells, as required by the Division of
Water Resources. The Permittee may be required to reduce or eliminate the permitted activity to protect
the assigned water quality standards of surface and groundwaters [15A NCAC 2T .1605(a)].
4. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface or
groundwaters resulting from the operation of this facility [15A NCAC 2B .0200; 2L .0100].
5. Any residuals generated from these treatment facilities must be disposed in accordance with General Statute
143-215.1 and in a manner approved by the Division [15A NCAC 2T .1100].
6. Diversion or bypassing of the untreated groundwater from the treatment facilities is prohibited [15A NCAC
2T .0108(b)(1)].
7. Adequate measures shall be taken to divert stormwater from the disposal area and prevent wastewater runoff
from the subsurface disposal field [15A NCAC 2T .0108(b)(1)].
II. FACILITY OPERATION AND MAINTENANCE REQUIREMENTS
1. The facility shall be properly maintained and operated as a non -discharge system to prevent the discharge
of any wastewater resulting from the operation of this facility. The groundwater treatment system shall
consistently achieve at least 95% removal of the influent contaminants or 2L Groundwater Quality
Standards (whichever is higher) prior to discharge to the injection wells. If the treatment system fails to
consistently achieve this standard, additional treatment units or changes in operational needs may be
required [15ANCAC 2T .1604(g)].
2. The groundwater recovery, treatment and disposal system shall be inspected at least weekly. If it is
determined that the system is malfunctioning, all repairs should be made as soon as possible and reported
to the Winston-Salem Regional Office with 48 hours. All components of the groundwater recovery,
treatment, and disposal system shall be properly weather -proofed to prevent freezing and failure of the
system. [15ANCAC 2T .0108(b)].
3. Upon classification of the wastewater treatment and remediation facilities by the Water Pollution Control
System Operators Certification Commission (WPCSOCC), the Permittee shall designate and employ a
certified operator to be in responsible charge (ORC) and one or more certified operator(s) to be back-up
ORC(s) of the facilities in accordance with 15A NCAC 8G .0201. The ORC shall visit the facilities in
accordance with 15A NCAC 8G .0204 or as specified in this permit and shall comply with all other
conditions specified in these rules [15A NCAC 2T .0117].
WQ0040419 Page 2 of 7

4. The Permittee shall maintain a log or report including dates and times of inspections, maintenance, repairs
or corrective actions taken by the Permittee, and removal of all residuals from this facility. Residual
removal information shall include the name of the hauler, permit authorizing the disposal of a letter from a
municipality agreeing to accept the residuals, date the residuals were hauled, and volume of residuals
removed. This record shall be maintained by the Permittee and include three years of data and shall be
made available to the Division or other permitting authority, upon request [15A NCAC 2T .1607(a)].
5. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the disposal site or facilityat
any reasonable time for the purpose of determining compliance with this permit (including inspection,
observation, and sampling associated with injection and any related facilities as provided for in N.C.G.S.
87-90), may inspect or copy any records or annual facility report that must be maintained under the terms
and conditions of this permit, and may obtain samples of groundwater, surface water, injection fluids, or
leachate [N.0 .G. S. 143-215.3 (a)(2)].
III. MONITORING REQUIREMENTS
1. The monitoring wells (including the new proposed well located on the west side of the property) and the
treatment system's influent, mid -fluent, and effluent sampling ports shall be sampled at the frequency and
for the parameters specified in the permit application package received on November 8, 2018, and revised
Table 1 (attached) included in the completed additional information package received on August 15,
2019.
2. Prior to sampling the parameters in the on -site wells, the measurement of water levels must be taken. The
depth to water in each well shall be measured from the surveyed point on the top of the casing. The
measuring points (top of well casing) of all monitoring wells shall be surveyed relative to a common
datum [15A NCAC 2L .0110].
3. Any laboratory selected to analyze parameters must be Division of Water Resources certified for those
parameters required [15A NCAC 2H .0800].
4. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be provided
[15A NCAC 2T .0108(c)].
IV. REPORTING REQUIREMENTS
1. Copies of all reporting forms including Annual Reports required in this Permit shall be submitted to the
addresses below [15A NCAC 2T .1607]:
UIC Program
NC Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Water Quality Regional Operations Section
and DWR Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
2. The Permittee shall retain records of all monitoring information, including calibration and maintenance
records, continuous monitoring data and reports required by this permit, for at least 3 years from the date
of the sample measurement, report or application. Records of this monitoring information shall include,
but not be limited to, the following [15A NCAC 2T .1607]:
WQ0040419 Page 3 of 7

a. the date, exact place, and time of sampling or measurements,
b. the individual who performed the sampling or measurements,
c. the date the analyses were performed,
d. the analytical techniques or methods used, and
e. the results of such sampling, measurements, and analyses.
3. The Permittee shall submit a treatment system efficiency report within 3 months of operation to evaluate
if system is operating according to design (a pilot test result). A review of the pilot test may result in a
revision to increase or decrease subsequent monitoring frequency.
4. The Permittee shall submit an Annual Report summarizing the volume and injection pressures of
effluent discharged into the injection wells and the summary results of related groundwater, influent, and
effluent monitoring. Isoconcentrations (horizontal and vertical direction) and water level
contour/potentiometric surface maps shall be prepared on an annual basis and submitted with this report.
If an annual report containing this information (e.g. corrective action plan) is required by a regulatory
agency, the Permittee may submit two (2) copies of that report in lieu of the preceding information within
thirty days of its publication [15A NCAC 2T .1607(c)].
5. Within fifteen days of any change of status of an injection well, the Permittee shall provide written
notification to the Division. 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 shall install a sanitary seal or
otherwise ensure the wells are protected against unauthorized use.
V. NON-COMPLIANCE NOTIFICATION
1. The Permittee shall report by telephone to the Winston-Salem Regional Office, telephone number 336-776-
9800 and the Division of Waste Management (DWM) Incident Manager as soon as possible, but in no case
more than 24 hours or on the next working day following the occurrence, or first knowledge of the
occurrence of any of the following [15A NCAC 2T .0108(b)(1)]:
a. Any occurrence at the groundwater remediation facility which results in any unusual operating
circumstances, or in the treatment of significant amounts of contaminated groundwaters which are
abnormal in quantity or characteristic, such as the dumping of the contents of a basin or tank, the known
passage of a slug of hazardous substance through the facility, or any other unusual circumstances;
b. Any process unit failure, due to known or unknown reasons, that renders the groundwater treatment
and disposal system, including injection wells, incapable of adequate treatment and disposal, such as
mechanical or electrical failures of pumps, aerators, compressors, etc.;
c. Any non-compliance with a permit condition due to a malfunction of the system;
d. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion of the influent to such station or facility; or
e. Any time that monitoring or other information indicates that the groundwater treatment and disposal
system is not in compliance with any specified permit limitations, that any contaminant may be causing
an endangerment to an underground source of drinking water.
2. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at telephone number [phone] or to the Emergency Management's switchboard at (919)
733-3300. Also, persons reporting such occurrences by telephone shall file a written report within five
(5) days following first knowledge of the occurrence. This report must outline the actions taken or
proposed to be taken to ensure that the problem does not recur [15A NCAC 2T .0108(b)(1)].
WQ0040419 Page 4 of 7

VI. APPLICABLE BOUNDARIES
1. The COMPLIANCE BOUNDARY for the waste disposal area is specified by regulations in 15A NCAC
2L, Groundwater Classifications and Standards. The Compliance Boundary for the disposal system
individually permitted after December 30, 1983 is established at either (1) 250 feet from the waste disposal
area, or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area. An
exceedance of Class GA Standards at or beyond the Compliance Boundary is subject to remediation action
according to 15A NCAC 2L .0106(d)(2).
2. The REVIEW BOUNDARY is established around the waste disposal area midway between the Compliance
Boundary and the perimeter of the waste disposal area. Any exceedance of Class GA Standards at the
Review Boundary may require action in accordance with 15A NCAC 2L .0106(d)(1).
VII. GENERAL CONDITIONS
1. Issuance of this permit does not constitute approval for reimbursement from the Leaking Petroleum
Underground Storage Tank Cleanup Fund (15A NCAC 2P) or any other fund. Additionally, the issuance
of this permit does not remove the Permittee's responsibility to comply with the corrective action
requirements of the Division of Waste Management. Furthermore, the Permittee should notify and report
all changes concerning the remedial system to the Division of Waste Management. It is the Permittee's
responsibility to comply with the requirements of all involved agencies.
2. This permit shall become voidable unless the facilities are constructed in accordance with the conditions of
this permit, the approved plans and specifications, and other supporting data [15A NCAC 2T .0110].
3. This permit is effective only with respect to the nature and volume of wastes described in the application
and other supporting data [N.C.G.S. 143-215.1]
4. This permit is not transferable. In the event the facilities change ownership, or there is a name change of
the Permittee, a formal name change request must be submitted to the Division accompanied by
documentation from the parties involved, and other supporting materials as may be appropriate. The
approval of this request will be considered on its merits and may or may not be approved [15A NCAC 2T
.0104].
5. A set of approved plans and specifications for the subject project must be retained by the Permittee for the
life of this project [15A NCAC 2T .0108(b)(1)].
6. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statute 143-215.6A to 143-
215.6C.
7. The annual administering and compliance fee must be paid by the Permittee within thirty (30) days after
being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate action to
revoke this permit as specified by 15A NCAC 2T .0105 (e)(3).
8. The issuance of this permit does not preclude the Permittee from complying with any and all statutes, rules,
regulations, or ordinances, which may be imposed by other government agencies (local, state, and federal),
which have jurisdiction.
WQ0040419 Page 5 of 7

9. Requirements for System Closure
1. 30 days prior to initiation of closure of a groundwater remediation system, the permittee shall submit
the following documentation to the Division [15A NCAC 02T .1608]:
a. the reason(s) for closure,
b. a letter from the oversight agency authorizing closure of the system, and
c. a description of the proposed closure procedure.
2. The following closure procedures shall be followed [15A NCAC 02T .1608]:
a. injection well closure procedures as specified in 15A NCAC 02C .0240, and
b. infiltration galleries shall be closed such that the infiltration gallery will be rendered permanently
unusable for the disposal or infiltration of fluids and will not serve as a source or channel of
contamination.
3. Within 30 days following upon completion of the closure of a groundwater remediation system, the
permittee shall submit the following documentation to the Division [15A NCAC 02T .1608]:
a. a description of the completed closure procedure;
b. the dates of all actions taken relative to the procedure; and
c. a written certification that the closure has been accomplished, and that the information submitted is
complete, factual and accurate.
10. If the Permittee wants to continue operation of this system, at least six (6) months prior to the expiration of
this permit, the Permittee shall request its extension. Upon receipt of the request, the Commission will
review the adequacy of the facilities described therein, and if warranted, will extend the permit for such
period of time and under such conditions and limitations as it may deem appropriate [15A NCAC 2T .0109].
Permit issued the 4, ' 71ay of
, 2019
NOIZ' 'H CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Linda CLI epper, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0040419
WQ0040419
Page 6 of 7

Permit No.: WQ0040419
Permittee: United Parcel Service
ENGINEER'S CERTIFICATION
Partial Final
I, , as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the project,
Facility Name Location and County
for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and intent of
this permit, the approved plans and specifications, and other supporting materials.
Signature: NC Registration No.
Print or Type Name:
Date
WQ0040419 Page 7 of 7

Table 1
Revised Monitoring Plan
Former UPS Greensboro
3015 Thurston Avenue
Greensboro, North Carolina
Sample Location
Prior to Discharge/Baseline
Week 1
Week 2
m
Y
G)
G)
30 Days
90 Days
INF
X
X
X
X
X
X
MID
X
X
X
X
X
X
EFF
X
X
X
X
X
X
MW-1
X
X
X
MW-2
X
X
X
MW-3
X
X
X
MW-4
X
X
X
MW-6
X
X
X
MW-7
X
X
X
MW-8
X
X
X
MW-9
X
X
X
MW-10
X
X
X
MW-11
X
X
X
Proposed
New Well
X
X
X
Notes:
INF - Remediation System Influent Sample Port
MID - Remediaiton System Mid -fluent Sample Port
EFF - Remedation System Effluent Sample Port
All Sample Analysis Shall Be Environmental Protection Agency Method 8260
Proposed New Well To Be Installed Near Thruston Avenue