WI0300181_Final Permit_20111115

North Carolina
Beverly Eaves Perdue
Governor
CDENR
Department of Environment and
Division of Water Quality
Robert A. Schoepke, Director of Remediation
1502 East Villa Street, 2"d Floor
Elgin, Illinois 60120
Coleen H. Sullins
Director
October 21, 2011
Ref: Issuance of Injection Permit WI0300181
Safety-Kleen Facility
Charlotte, Mecklenburg County, North Carolina.
Dear Mr. Schoepke:
Natural Resources
Dee Freeman
Secretary
p3 is kL9 T, t! VPiF I. ,
OCT 2 5 2011
In accordance with the application received on September 1, 2011, we are forwarding permit number WI0300181. This
permit is to inject Zero Valent Iron, Sodium Persulfate, and Hydrogen Peroxide to remediate groundwater contaminated
with chlorinated solvents and petroleum solvents at the facility referenced above. This permit shall be effective from the
date of issuance until September 30, 2014, 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. Please note that some of the monitoring requirements have changed from o�pplication, and that
these include the installation and monitoring of a new well. Please read the entire permit to ensure that you are aware of
all compliance requirements of the permit.
You will need to notify this office by telephone 48 hours prior to initiation of operation of the facility. 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,
David Goodrich
Hydrogeologist
cc: Andrew Pitner, Mooresville Regional Office
Genna K. Olson, ATC Associates of North Carolina, PC, 2725 East Millbrook Road, Suite 121, Raleigh, NC 27604
Adam Ulishney, NCDWM Hazardous Waste Section, 1646 Mail Service Center, Raleigh, NC 27699-1546
WI0300181 Permit File
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh. North Carolina 27604
Phone: [phone] FAX 1: 919-715-0588: FAX 2: 919-715-60481 Customer Service: 1-877-623-6748
Internet: www,ncwaterguality.org
An Ewa] Opportunity � Affirmative Action Employer
One
Norfh Carolina
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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
Safety-Kleen Systems, Inc.
FOR THE CONSTRUCTION AND OPERATION OF 14 DIRECT PUSH TYPE 5I
INJECTION WELLS AND 4 PERMANENT TYPE 5I INJECTION WELLS, defined in Title
15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject Zero Valent Iron, Sodium
Persulfate, and Hydrogen Peroxide, for the oxidation and enhanced anaerobic pioremediation of
chlorinated and petroleum solvents. These injection points and injection wells will be located at
the Safety-Kleen Systems facility at 2320 Yadkin Avenue, Charlotte, Mecklenberg County,
North Carolina, and will be operated in accordance with the application submitted September 1,
2011, and in conformity with the specifications and supporting data submitted therein, 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 September 30,
2014, and shall be subject to the specified conditions and limitations set forth in Parts I through
X hereof.
Permit issued this the 21 st day of October, 2011.
or Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0300181 PAGE ] OF 7
ver. June 2011 UIC-5I/5T

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
1. Prior to the commencement of injection activities, a new 2-inch diameter monitor well shall
be constructed between MW-4 and TW-5. The well shall be constructed such that the water
level in the well is never above or below the screened (open) portion of the well at any time
during the year and in accordance with 15A NCAC 02C .0108.
2. 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) and Criteria and Standards Applicable to Water Supply and Certain Other Wells (15A
NCAC 2C .0100), as appropriate. 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.
3. 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.
4. This permit is valid only for construction of the number of injection wells and monitor wells
described in the application and other supporting data, or in the permit. Construction of
additional injection wells or monitor wells must be approved in advance by the Aquifer
Protection Section.
5. Each injection well or monitor well shall not hydraulically connect separate aquifers.
6. Each injection well or monitor well shall be constructed in such a manner that water from
land surface cannot migrate into the gravel pack or well screen.
7. Each injection well or monitor 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 or monitoring purposes and the entrance to each well must be secured
with a locking cap.
8. Each injection well or monitor well shall be afforded reasonable protection against damage
during construction and use.
9. Each injection well or monitor well shall have permanently affixed an identification plate.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. At least forty-eight (48) hours prior to constructing each injection well or monitor well, the
Permittee shall notify the Aquifer Protection Section -Underground Injection Control (UIC)
Central Office staff, telephone number 919-715-6162 and the Mooresville Regional Office
Aquifer Protection Section Staff, telephone number [phone].
2. Bentonite grout shall not be used to seal any water -bearing zone with a chloride
concentration equal to or greater than 1,500 milligrams per liter. In areas where elevated
chloride levels are known to exist or are probable, such as coastal areas, chloride levels shall
be verified in the field to determine existing conditions.
Permit No. WI0300181 PAGE 2 OF 7
ver. June 2011 UIC-51/5T

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 that may be imposed by other
local, state, and federal agencies having 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.
2. 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.
3. 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.
4. 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 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 919-715-6162. 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. W10300181 PAGE 3 OF 7
ver. June 2011 UIC-5115T

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 injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well and the new monitor well to:
Aquifer Protection Section-UIC Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
2. The proposed monitoring plan included in the application shall not be followed. Monitor
Wells MW-2, MW-3, MW-4, MW-5, and TW-6, along with a new monitor well installed
between MW-4 and TW-5, shall be monitored for water level, temperature, dissolved
oxygen, pH, oxidation-reduction potential, specific conductivity, total iron, sulfate by EPA
Method 9056, Volatile Organic Compounds by EPA Method 8260, and Semi -volatile
Organic Compounds (polynuclear aromatic hydrocarbons only) by EPA Method 8270 prior
to injection, and quarterly thereafter for the first year following injection. All sample results
shall be submitted to the Aquifer Protection Section's Mooresville 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 ensure surface and ground
water protection, will be established and an acceptable sampling reporting schedule shall be
followed.
3. The Permittee shall submit an Injection Event Record within 30 days of completing each
injection.
4. 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.
Permit No. W10300181 PAGE 4 OF 7
ver. June 2011 UIC-5I/5T

5. The monitoring results and the final project evaluation shall be submitted to:
UIC Program Staff DWQ - Aquifer Protection Section
DWQ — Aquifer Protection Section and Mooresville Regional Office
1636 Mail Service Center 610 East Center Avenue, Suite 301
Raleigh, NC 27699-1636 Mooresville, NC 28115
6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Mooresville 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.
7. 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.
8. 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 .0214, 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 .0214, 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
Permit No. W103001 91 PAGE 5 OF 7
ver. June 2011 UIC-51/5T

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.
(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 IX (1) and (2) (G) shall be submitted to:
Aquifer Protection Section-UIC Program
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:
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.
4. Safety controls should be in place to ensure that the check valve and the pressure delivery
systems are working properly.
Permit No, W I03001 S 1 PAGE 6 OF 7
ver. June 2011 UIC-5I/5T

5. Sodium Persulfate is a strong oxidant capable of causing severe shin and eye irritation and
burns, as well as causing coughing, wheezing, asthma, and/or shortness of breath. It can also
cause skin allergies and dermatitis. Strong precautions need to be taken to minimize the risk
of its exposure to the skin, eyes, and respiratory system.
6. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
7. Access to the area of application should be limited to the workers applying the products. In
order to minimize exposure to unprotected individuals, measures should be taken to prevent
access to the area of application.
a
Peanit No. W10300181 PAGE 7 OF 7
.ver. June 2011 - UIC-51,'5T