WI0300181_Permit (Issuance)_20120220

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
February 20, 2012
PERMIT ISSUANCE MEMO
14�TO: Debra Watts &�
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Modification of Permit To Inject Zero Valent Iron, Sodium Persulfate, and Hydrogen
Peroxide at Safety-Kleen Systems, Inc.
I recommend that Permit Number W10300181 be modified (as requested) to inject Zero Valent Iron, Sodium
Persulfate, and Hydrogen Peroxide to remediate soils and groundwater contaminated with chlorinated and
petroleum solvents. The four permanent injection wells that were initially proposed and permitted, although not
installed, will be replaced with six permanent well pairs (12 wells total) that will perform the same intended
injection function. Each well pair will consist of a shallow injection well that will be screened from 15 to 18
feet, and a deeper well that will be screened from 21 to 25 feet.
REGIONAL OFFICE COMMENTS Maria Schutte of the Mooresville Regional Office recommends issuance of
this permit. The Regional Office's recommendations for the original permit (issued on October 21, 2011)
recommended that the proposed monitor wells be sampled on a quarterly schedule for the first year after
injection, and that Iron and Sulfate be added to the list of sample parameters. The RO further recommended that
a monitor well be installed (if accessible) between MW-4 and TW-5, and added to the sampling program. These
requirements were retained in the new permit.

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 12 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 bioremediation 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
..•,i .�) 51��) _ii�_ :Ill's ;J�il;�! �..i',�;,`,. +�'_1!!;�, iillii ,�C'! ili.il(lliS �iCI;'.'.ii1I -i "vc. .,�;11-iu; "il"1!1'.i��rl
r
use.
This permit shall be effective, unless revoked, from the date of its issuance until September 30,
2014, shall void Injection Permit WI0300181 issued October 20, 2011, and shall be subject to the
specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 28th day of February, 2012.
Charles Wakild, P.E., Director
Division of Water Quality
By Authority -of the Environmental Management Commission.
Permit No. WI0300181 PAGE 1 OF 7
ver. June 2011 UIC-51/5T

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 mariner 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.
111J CC L' 1 11 %'Y t:il Of riloallul w V11 "hail Vim% a" rd t: I 1 , — U1 ' . 1, ' ' . "..fill "tbci.11lJ ,
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 919-807-6352 and the Mooresville Regional Office
Aquifer Protection Section Staff, telephone number [phone].
t '. ;. CI a 1', �)+J li A`1 lfi i'�: `<1i'1V �.,>>"I1
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-5I/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.
-T, �(% 1`iS.'C'. t- Ji') i 1i C8. ilc'::5 IU
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 919-807-6352. Notification is required so that Division staff
can inspect or otherwise review the injection facility and determine if it is u1 compliance with
permit conditions.
PermitNo. WI0300181 PAGE 3 OF 7
ver. June 2011 UIC-51/5T

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,
�7 total iron, sulfate by EPA
? Pr"t }vi+.:t;7t?l: R')60, gnu C; f i v(�� _;1t;
Organic Compounds (polynuciear aromatic iiycirocarbon5 only) by EPA Maiiod 62 i 0 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 Pernuttee 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
injecUoii p1UJl'JUS llndLigs in a VEiLlCri JlrlliliA l}'. lhv until piojca ineahltdoJ' Shall also
contain monitoring well sampling data, contaminant plume maps and potentiometric surface
maps.
Permit No. WI0300181 PAGE 4 OF 7
ver. June 2011 UIG51/5T

�44
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 colitribute to contaiZiinaiion of .tile
groundwaters.
Permit No. V10300181 PAGE 5 OF 7
ver. June 2011 UIC-5I/5T

(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.
(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 is2 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
PARYX— WORKER PRECAUTIONS DUIUNG APPI.,ICAXlON
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. Ealing, c ii>i ing; smoking, handling coiliact leiises, and applying cosmetics should not ur
permitted in the application area during or inuiiediately following application.
Permit No. W10300181
ver. June 2011
UIC-51/5T
PAGE 6 OF 7

ji
4. Safety controls should be in place to ensure that the check valve and the pressure .delivery
systems are working properly. ry
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.
Permit No. WI0300181
ver. June 2011 UIC-5I/5T
PAGE 7 OF 7

f
DOCUMENTS ASSOCIATED
WITH
THE ORIGINAL PERMIT
APPLICATION
(-ISSUED OCTOBER 21, 2011)

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 bioremediation 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 21st day of October, 2011.
or Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0300181 PAGE 1 OF 7
ver. June 2011 UIC-5I/5T

PART I - WELL CONS'" ":'JCTION 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 Aot 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 H - WELL CONSTRUCTION SPECIAL CONDITIONS
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. WI0300184 PAGE 2 OF 7
ver. Tune 2011 UIC-5M

1
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. WI0300181 PAGE 3 OF 7
ver. June 2011 UIC-5I/5T

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 3.0 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 anInjection 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. WI0300181 PAGE 4 OF 7
ver. June 2011 UIC-5M

r
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. WI0300181 PAGE 5 OF 7
ver. June 2011 UIC-5I/5T

4
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. WI0300181 PAGE 6 OF 7
ver. June 2011 UIC-5I/5T

i
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.
Permit No. WI0300181 PAGE 7 OF 7
ver. June 2011 - UIC-5I/5T

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
October 14, 2011
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich (3-'.
RE: Permit To Inject Zero Valent Iron, Sodium Persulfate, and Hydrogen Peroxide
Safety-Kleen Systems, Inc.
I recommend that Permit Number WI0300181 be issued to Safety-Kleen Systems, Inc. to inject Zero Valent
Iron, Sodium Persulfate, and Hydrogen Peroxide to remediate soils and groundwater contaminated with
chlorinated and petroleum solvents.
SITE DESCRIPTION The site is an active hazardous material storage and recycling facility that has been in
operation since 1978. The source of the contamination is believed to be two underground storage tanks that were
used to store used mineral spirits and were removed in 1985. Assessments began in 1998, and, although there
have been no remedial activities performed, a soil vapor extraction system is currently being planned.
HYDROGEOLOGIC DESCRIPTION The site is located in the Charlotte Belt of the Piedmont Physiographic
Province. The bedrock consists of a metamorphosed granitic bedrock, overlain by regolith materials which
represent weathered bedrock. Bedrock has been encountered at the site at approximate depths ranging from 10
feet to 30 feet below land surface. The water table is typically encountered at a depth range of approximately 14
to 21 feet. The most recent well water level data indicates that shallow groundwater flow is towards the north-
northeast under an approximate gradient of 1.6%. Hydraulic conductivity is estimated to be approximately 1
ft/day, and, assuming an effective porosity of 20%, the average groundwater velocity is estimated to be
approximately 0.08 ft/day.
EXTENT OF CONTAMINATION The impacted groundwater zone is approximately 100 feet long, 50 feet
wide, and 15 feet in thickness (shared by regolith and fractured bedrock media)(Figures 3, 6, 7 & 8).
Assuming a typical effective porosity of 20% in the regolith (5 feet thick) and 1% in the bedrock (10 feet thick)
would result in a total volume of approximately 5,500 cubic feet, or 41,250 gallons of impacted ground water.
PROPOSED INJECTION The three injectant substances are designed to promote chemical oxidation and
to enhance anaerobic bioremediation. Mixing water will be obtained from a municipal water supply source. The
first phase of injection will involve 14 direct push points to a target depth. Depending on the local geology and
consequent success of reaching the target depth of 25 feet, a second phase may be needed that would consist of
installing four permanent injection wells. The first phase will inject 2,508 gallons and the second phase will
inject 1,692 gallons. The total injected volume of 4,200 gallons represents approximately 10% of the total
estimated volume of the impacted ground water.
HOW IT WORKS Nitrogen gas will be used to force the injectant substances into the formation. Sodium
Persulfate is acted upon by zero valent iron and hydrogen peroxide to create sulfate free radicals which are a
strong oxidant. The oxidation produces ferric iron and sulfate ions which stimulate longer term anaerobic
bioremediation in the subsurface. Corrosion of the iron metal yields ferrous iron and hydrogen which spport the
biological reduction of chlorinated compounds.

MONITORING. The proposed monitoring plan will not be followed. Six monitor wells will be sampled
prior to injection, and then quarterly for the first year after injection for Volatile Organic Compounds,
Polynuclear Aromatic Hydrocarbons, Sulfate, Iron, water level, temperature, Dissolved Oxygen, pH, Oxidation-
reduction Potential, and Specific Conductivity. Since well TW-5 is dry and it is not in the best location for
monitoring, the proposed monitoring of TW-5 will be replaced by the monitoring of a new well which will be
installed between MW-4 and TW-5.
EPIDEMIOLOGY On October 2, 1998, September 25, 2009, and June 3, 1998, the DHHS' Epidemiology
Branch provided comments on Zero Valent Iron, Sodium Persulfate, and Hydrogen Peroxide for groundwater
remediation. Dr. Luanne K. Williams and Sandy Mort 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 Maria Schulte of the Mooresville Regional Office recommends issuance of
this permit. The Regional Office recommends that the proposed monitor. wells be sampled on a quarterly
schedule for the first year after injection, and that Iron and Sulfate be added to the list of sample parameters. The
RO further recommends that a monitor well be installed (if accessible) between MW-4 and TW-5, and added to
the sampling program.