WI0400246_PERMIT_20120515

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
YRC Enterprise Services, Inc.
FOR THE CONSTRUCTION AND OPERATION OF 3 TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject sodium persulfate,
ferrous sulfate, and citric acid, for the oxidation of tetrachloroethene (PCE). These injection
wells/points will be located at the Roadway Kemersville Site, 1522 Highway 66 South,
Kemersville, Forsyth County, North Carolina, and will be operated in accordance with the
application submitted April 9, 2012, 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 April 30, 2014,
and shall be subject to the specified conditions and limitations set forth in Parts I through X
hereof.
Permit issued this the 15th day of May, 2012.
()A, \t74K-
J Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. WI0400246 PAGE 1 OF 7
ver. June 2011 UIC-51/5T

PART I - WELL CONSTRUCTION GENERAL CONDITIONS
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 insure against 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.
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
1. 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 919-807-6352 and the Winston-Salem 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. WI0400246 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.
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 919-807-6352. 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. WI0400246 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 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 Program
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
2. The proposed monitoring plan included in the application shall be 'followed. All sample
results shall be submitted to the Aquifer Protection Section's Winston-Salem Regional Office
and the Raleigh Central Office. Any monitoring (including groundwater, surface water, or
soil sampling) deeihed 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.
5. The monitoring results and the final project evaluation shall be submitted to:
UIC Program Staff
DWQ — Aquifer Protection Section and
1636 Mail Service Center
Raleigh, NC 27699-1636
DWQ - Aquifer Protection Section
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Permit No. WI0400246
ver. June 2011 UIC-5I/5T
PAGE 4 OF 7

6. The Permittee shall report by telephone, within 48 hours of the occurrence or first knowledge
of the occurrence, to the Winston-Salem 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 1 SA 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
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. WI0400246 PAGE 5 OF 7
ver. June 2011 UIC-5I/5T

(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 and burning. Inhalation exposure can cause
coughing, wheezing, and/or shortness of breath including asthma -like allergy. Future
exposure can cause asthma attacks with shortness of breath, wheezing, cough, and/or chest
tightness. Inhalation can cause severe respiratory irritation and inflammation leading to
shock, coma and seizures. 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.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse
reactions and injuries.
Permit No. WI0400246 PAGE 6 OF 7
ver. June 2011 UIC-5I/5T

6. Access to the area of application should be limited to the workers applying the product. In
order to minimize exposure to unprotected individuals, measures should be taken to prevent
access to the area of application.__
Permit No. WI0400246 PAGE 7 OF 7
ver. June 2011 UIC-5J/5T

DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
May 8,2012
PERMIT ISSUANCE MEMO
TO: Debra Watts
THROUGH: Thomas Slusser
FROM: David Goodrich
RE: Permit To Inject Sodium Persulfate, Ferrous Sulfate, and Citric Acid
Roadway facility
I recommend that Permit Number WI0400246 be issued to YRC Enterprise Services, Inc. to inject sodium
persulfate, ferrous sulfate, and citric acid to remediate soils and groundwater contaminated with
tetrachloroethene.
SITE DESCRIPTION The site is a freight terminal which experienced a leak from a UST at some time prior to
1992. Tetrachloroethene is the primary contaminant that is still present, with smaller amounts of naphthalene
and 2-methylnaphthalene. Natural attenuation has been used to remediate the site, but high levels of
tetrachloroethene persist.
HYDROGEOLOGIC DESCRIPTION The site is situated in the Piedmont Physiographic Province. The
bedrock consists of intruded granite that is part of the Churchland Plutonic Suite. The surface of the bedrock is
weathered and is overlain by approximately 50 to 60 feet of saprolite material that is primarily silty clay and
clayey silt with minor amounts of coarse sand. Gravely clay and gravely sand are also present in some areas of
the site. Ground water is encountered at a depth of approximately 18 feet, and the hydraulic gradient is
approximately 1 to 2% in an east-southeast direction. The average groundwater velocity in the shallow zone is
estimated to be approximately 1.2 feet per year.
EXTENT OF CONTAMINATION The impacted soil and ground water is 240 feet long, averages
approximately 160 feet in width, and has an average vertical thickness of approximately 20 feet (Figures H4 and
H5). This represents a total volume of approximately 768,000 cubic feet, and an impacted groundwater volume
of approximately 864,000 gallons.
PROPOSED INJECTION The predominant reaction that will oxidize the PCE in the subsurface
environment will be the activation of sodium persulfate by ferrous sulfate. The radicals thus created will
facilitate the oxidation of the PCE (and minor contaminants). Citric acid will be used to maintain a low pH that
is critical to the activation of the sodium persulfate. Three permanent wells will be used for the injection, which
will have a total volume of 3,000 gallons per well. A maximum of six injection events may be performed,
representing a total injected volume of 54,000 gallons, which is less than 7% of the estimated total volume of
the impacted ground water.
HOW IT WORKS Remediation will take place by the oxidation of the PCE and other minor contaminant
substances. Citric acid will be used to maintain a low pH, providing an optimal environment for the desired
chemical reactions, which will consist of activating sodium persulfate by using ferrous sulfate. The radicals
formed by this activation process will server to oxidize the contaminant substances.
MONITORING The proposed monitoring plan will be followed. Three performance monitoring wells
will be monitored for persulfate, sulfate, total iron and dissolved iron during injection to confirm successful
injection into the shallow aquifer unit. Groundwater samples will be obtained from the three performance

monitoring wells and the three injection wells prior to injection , six weeks after injection, and twelve weeks
after injection and analyzed for VOCs, TOC, sulfate, total iron, dissolved iron, manganese and chloride. An in -
situ detection probe will be used during each sampling event to monitor pH, ORP, dissolved oxygen, and
conductivity. Persulfate analysis will also be performed after injection using field testing kits. Semiannual
groundwater monitoring will continue at the 12 existing monitoring wells.
EPIDEMIOLOGY On September 2, 2003 and May 8, 2012, the DHHS' Epidemiology Branch provided
comments on Sodium Persulfate and Citric Acid for groundwater remediation. Drs. Luanne Williams and Ken
Rudo 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. Ferrous Sulfate
has been approved for injection under the Fenton's Reagent treatment series. Dr. Rudo recommended that pre -
injection groundwater monitoring take place at this site, and at other sites utilizing Citric Acid for pH
modification, to compare with the post -injection monitoring to assess the effectiveness of using Citric Acid to
change the pH and (thereby enhancing chemical processes), as well as to detect possible (additional)
contamination resulting from the use of this product (Citric Acid). Pre -injection groundwater monitoring is
being performed, and is standard procedure for remedial injection activities.
REGIONAL OFFICE COMMENTS Shuying Wang of the Winston-Salem Regional Office recommends issuance
of this permit.

Application Reviewer:
Pre -Review:
O.K. to Process?
If No, What Action Is Needed?
Conducted? ] Yes ❑ No
Yes ❑ No
❑ Pre -Review Return
❑ Hold, Pending Receipt of Addinfo.:
Name/Affiliation of Person Contacted:
Assignt .t Date:
"(k- it)
Date to Processing: 4-1 (3 / ('
Date(s) of Contact: ❑ By Phone ❑ By E-Mail D By Letter
Owner: ❑ Existing
❑ Unknown Owner Type
Facility/Operation: ❑ Proposed
Regulated Activities:
❑ Existing
❑ Non -Gov't (❑ Ind. or ® Org) ❑ Gov. -Municipal
❑ Gov. -County ❑ Gov. -State ❑ Gov. -Federal
❑ Facility ❑ Operation
Application/Permit:
Permit Type:
Injection Water Only GSHP Well System (5QW)
❑ Injection Mixed Fluid GSHP Well System (5QM)
❑ Injection Tracer Well (5T)
Injection Experimental Technology (5X25)
Project Type:
N tes:
Injection In situ Groundwater Remediation Well (5I)
Injection Heating/Cooling Water Return Well (5A7)
Injection Other Wells (5Z)
Injection Aquifer Recharge (5R21)
It New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
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FORM: BIMS 10/04/2007
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