WI0500242_PERMIT_20100724

MEMORANDUM
TO:
FROM:
THROUGH:
Debra Watts
Michael Rogers
Thomas Slusser t�
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
July 24, 20] 0
RE: Permit To Inject Sodium Persulfate (Permit #WI0500242)
United Parcel Service (UPS)
1 recommend that Permit Number WI0500242 be issued to the applicant to inject sodium persulfate (SP) to remediate
groundwater contaminated with petroleum products.
SITE DESCRIPTION: The subject Site is active UPS service center located 1108 Instrument Dr., Rocky Mount, Nash
County, NC 27801 (Figures I and 2). The source of contamination is from a former underground storage tank containing
gasoline, which evidently leaked.
HYDROGEOLOGIC DESCRIPTION: The Site is located in the upper Coastal Plain near the fall line, which separates the
Coastal Plain from the Piedmont Physiographic Province. In the area of the Site, the overburden consists of interbedded
sand, silt, and clay. Depth to groundwater (GW) is approximately 15 to 17 feet below land surface (BLS). GW generally
flows east to northeast at proximately 3.55 ft/year (Figures 3 and 4).
EXTENT OF CONTAMINATION: The benzene contaminant plume is generally circular and is approximately 100 feet in diameter
(Figures 5 and 6). The benzene 10 ug/L contour line is not drawn correctly on Figure 6, but the extent of the contamination is
still for the most part on property. According to the Applicant, there are some water supply wells within 1500 feet of the Site.
They are located upgradient approximately 200 feet west of the Site along Instrument Dr./Crusenberry Road (refer to Table 1).
PROPOSED INJECTION: The proposed injection consists of injecting a total of approximately 20,000 gallons of SP via 8
pre-existing injection wells. Approximately 2400 gallons of SP will be injected through each well from about 16 to 26 feet
BLS (500 gallons per day per well). There are 3 events planned according to the application. The actual number of events
will be dependent upon injection effectiveness. Each event will last 4 to 5 days with 10 to 12 months in between each
event. The estimated amount of fluid displacement from injection is approximately 36%. The potential displacement of
the plume is, therefore, low to medium. However, due to the relatively small injection pressures (<5 psi) and slow
groundwater flow rate (3.55 feet/year), the risk of displacement of the plume is probably more on the low side.
HOW IT WORKS: Sodium persulfate is used to remediate groundwater contaminated with petroleum products by acting as
an oxidizer to the hydrocarbon compounds and enhancing the naturally occurring biologic community. Between natural
attenuation and injection of this compound, petroleum contamination in the GW is reduced.
MONITORING: The following wells will be monitored for injection effectiveness: IW-1, IW-3, IW-7, MW-4, MW-7, MW-8,
MW-10, MW-PT, and RW-C. Additionally, per our request, the following parameters were added to the monitoring plan:
ethene, carbon dioxide, and chloride. Monitoring frequency will be once prior to injection and then every 3 months thereafter
for one year. However, if additional injection events are warranted, monitoring of these subsequent events will be the same.
EPIDEMIOLOGY: Dr. Luanne Williams has reviewed and approved sodium persulfate as an injectant.

REGIONAL OFFICE COMMENTS: Each of the RRO comments/recommendations are discussed below (RRO's
comments/recommendations are underlined). Most of the Region's comments/recommendations below were addressed in the
Additional Information Letter received from ARCADIS on July 1, 2010.
Item #1- Permittee should restate injection volumes given the change of iniectant composition in regards to the deletion of the
use of ferrous sulfite and citric acid. ARCADIS supplied injectant design calculations in the Add Info Letter referenced above
(Bullet No. 5 and Attachment 4).
Item #2- Request construction logs for injection wells. Construction logs were submitted in the Add Info Letter (Attachment 2).
I reviewed the well construction logs and noticed that there was no bentonite seal above the sand pack for 7 of the wells per 2C
.0100, and the proposed depth of grout was not in strict compliance with 2C .0200 (i.e., a minimum of 20 feet of grout for wells
deeper than 20 feet). I reviewed these construction logs with Eric Rice, and he decided to see if they had the GW-1 forms and to
run the logs by Jay for his comment. Eric was able to locate the GW-1s except for IW-1, and they showed a bentonite seal
above the screen. However, there was not a minimum of 20 feet of grout for a well deeper than 20 feet in depth. After
reviewing the logs and GW-1 s, Jay gave approval for well construction per 2C .213(c)(1)(B)(iii) (refer to attached e-mail dated
July 23, 2010). Per Thomas's request for confirmation of the well construction of lW-1, I was able to get GW-1 for this well
from Matt Schnobrich with ARCADIS (refer to e-mail from Matt, dated July 28, 2010).
Item #3- A Complete explanation of the details of the benchmark study is required. ARCADIS provided further explanation in
the Add Info Letter text (Bullet No. 6).
Item #4- Request the following hydrogeological parameters: groundwater seepage velocity, hydraulic conductivity,
transmissivity, and specific yield. ARCADIS provided this information in the Add Info Letter (Bullet No. 1 and Attachment 1).
Item #5- Recommend MW-4, MW-8, MW-PT, and MW-7 be included in monitoring plan. ARCADIS agreed to this in the Add
Info Letter (Bullet No. 3 and revised page 7-1).
Item #6- Recommend several parameters to be analyzed for. ARCADIS has agreed to this in Add Info Letter (Bullet No. 3 and
revised page 7-1).
Item #7- Recommend pre -infection sampling. and quarterly thereafter. ARCADIS has agreed to this (revised page 7-1).
Jay Zimmerman and Eric Rice of the Raleigh RO recommend issuance of this 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
United Parcel Service
FOR THE CONSTRUCTION AND/OR OPERATION OF 8 TYPE 5I INJECTION WELLS, defined
in Title 15A North Carolina Administrative Code 2C .0209(e)(3)(C), to inject sodium persulfate, for
the remediation of groundwater contaminated with petroleum products. These injection wells/points
will be located at the United Parcel Service - Rocky Mount Center, 1108 Instrument Dr., Rocky
Mount, Nash County, NC 27804, and will be operated in accordance with the application submitted
February 22, 2010, and in conformity with the specifications and supporting data received July 1,
2010, and July 28, 2010, 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 June 30, 2013, and
shall be subject to the specified conditions and limitations set forth in Parts I through X hereof.
Permit issued this the 30th day of July 2010.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission.
Permit No. W10500242
ver. Jan.2010 AP/UIC-6
PAGE 1 OF 6

-PART I - WELL CONSI-ic CTION GENERAL CONDITIONS
1. The Permittee must comply with all conditions ofthis 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.
9. Within 30 days of completion of well construction, a completed Well Construction Record
(Form GW-1) must be submitted for each injection well to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART II - WELL CONSTRUCTION SPECIAL CONDITIONS
At least forty-eight (48) hours prior to constructing each injection well, the Permittee shall notify the
Aquifer Protection Section -Underground Injection Control (UIC) Central Office staff, telephone
number [phone] and the Raleigh Regional Office Aquifer Protection Section Staff, telephone
number [phone].
Permit No. WI0500242 PAGE 2 OF 6
ver. Jan.2010 AP/UIC-6

PART III - OPERATION AND USE GENERAL CONDITIONS'
1. This permit is effective onlywith respect to the nature, volume ofmaterials, rate of injection, and
number of injection wells as described in the application and other supporting data.
2. This permit is not transferable without prior notice to, and approval by, the Director of the
Division of Water Quality (Director). In the event there is a desire for the facility to change
ownership, or there is a name change of the Permittee, a formal permit amendment request must
be submitted to the Director, including any supporting materials as may be appropriate, at least
30 days prior to the date of the change.
3. The issuance of this permit shall not relieve the Permittee of the responsibility of complying with
any and all statutes, rules, regulations, or ordinances which maybe imposed by other local, state,
and federal agencies which have jurisdiction. Furthermore, the issuance of this permit does not
imply that all regulatory requirements have been met.
PART IV - PERFORMANCE STANDARDS
1. The injection facility shall be effectively maintained and operated at all times so that there is no
contamination of groundwater which will render it unsatisfactory for normal use. In the event
that the facility fails to perform satisfactorily, including the creation of nuisance conditions or
failure of the injection zone to adequately assimilate the injected fluid, the Permittee shall take
immediate corrective actions including those actions that may be required by the Division of
Water Quality such as the repair, modification, or abandonment of the injection facility.
2. The Permittee shall be required to comply with the terms and conditions of this permit even if
compliance requires a reduction or elimination of the permitted activity.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwater resulting from the operation of this facility.
PART V - OPERATION AND MAINTENANCE REQUIREMENTS
1. The injection facility shall be properly maintained and operated at all times.
2. The Permittee must notify the Division and receive prior written approval from the Director of
any planned physical alterations or additions in the permitted facility or activity not specifically
authorized by the permit.
3. At least forty-eight (48) hours prior to the initiation of the operation of the facility for injection,
the Permittee must notify by telephone the Aquifer Protection Section-UIC, Central Office staff,
telephone number [phone]. Notification is required so that Division staff can inspect or
otherwise review the injection facility and determine if it is in compliance with permit
conditions.
Permit No. WI0500242 PAGE 3 OF 6
ver. Jan.20.10 AP/UIC-6

PART VI - INSPECTIO1v'
1. Any duly authorized officer, employee, or representative of the Division of Water Quality may,
upon presentation of credentials, enter and inspect any property, premises, or place on or related
to the injection facility at any reasonable time for the purpose of determining compliance with
this permit, may inspect or copy any records that must be maintained under the terms and
conditions of this permit, and may obtain samples of groundwater, surface water, or injection
fluids.
2. Department representatives shall have reasonable access for purposes of inspection, observation,
and sampling associated with injection and any related facilities as provided for in N.C.G.S. 87-
90.
3. Provisions shall be made for collecting any necessary and appropriate samples associated with
the injection facility activities.
PART VII - MONITORING AND REPORTING REQUIREMENTS
1. The proposed revised monitoring plan received June 15, 2010, which is included in the
application, shall be followed.
2. All sample results shall be submitted to the Aquifer Protection Section's Raleigh Regional Office
and the Raleigh Central Office. Any monitoring (including groundwater, surface water, or soil
sampling) deemed necessary by the Division of WaterQuality to insure 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:
and to:
Aquifer Protection Section-UIC Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
Aquifer Protection Section
DENR-DWQ Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Permit No. WI0500242 PAGE 4 OF 6
ver. Jan.2010 AP/I IC-6

6. The Permittee shall report by telephone, within 48 hours of the occurrence or first lmowledge of
the occurrence, to the Raleigh 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 .0113, Well Construction Standards.
2. When operations have ceased at the facility and a well will no longer be used for any purpose,
the Permittee shall abandon that injection well in accordance with the procedures specified in
15A NCAC 2C .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. WI0500242 PAGE 5 OF 6
ver. Jan.2010 AP/UIC-6

(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 Staff
DENR-Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
PART X — WORKER PRECAUTIONS DURING APPLICATION
1. Some effects reported to be associated with the product proposed to be used are as follows: 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.
5. The Material Safety Data Sheets should be followed to prevent incompatible or adverse reactions
and injuries.
Permit No. WI0500242 PAGE 6 OF 6
ver. Jan.2010 AP/UIC-6