WQ0004268_Hydrogeological Report_20090415

Aquifer Protection Section
Washington Regional Office
April 15, 2009
MEMORANDUM
-: To: Jim Barber (APS FRO) .
From: Randy Sipe (APS — WaRO)
Subject: Aliens Inc. — WQ0004P224. 11269 8
For your records I am transmitting with this memo all the documents produced by the APS Washington
Regional Office during the express review of the hydrogeologic report submitted with this permit modification.

Re: [Fwd: Re: WQ0004268 --Allens, Inc. DraftComments]
Subject: Re: [Fwd: Re: WQ0004268 - Allens, Inc. Draft Comments].
From: Randy Sipe <[e-mail]>
Date: Thu, 02 Apr 2009 16:50:30 -0400
To: Nathaniel Thornburg <[e-mail]>
CC: Rich Hayes <[e-mail]>
Nathaniel Thornburg wrote:
I suggest requiring them to abandon any well, that is not a monitoring well within the compliance
boundary. Since I did not go on the site visit, I do not even know what type of wells these are.
NT
Randy Sipe wrote:
' Nathaniel Thornburg wrote:
Thought's?
NT
Subject:'
Re: WQ0004268
From:
- Allens, Inc. Draft Comments
Jim Barber <[e-mail]>
Date:
Thu, 02 Apr 2009 15:55:56 -0400
To:
Nathaniel Thornburg <Nathaniel.Thornburg@NCMail.,net>, Art Barnhardt <[e-mail]>,
Joel Shields <[e-mail]>
To:
Nathaniel Thornburg'<[e-mail]>, Art Barnhardt <[e-mail]>,
Joel Shield's <[e-mail]>
Nathaniel;
Your comments look fine.
In reviewing the monitoring' well diagram..sent_in a previous email, I noticed that two "active
wells" are identified on the map. One,is.'located near monitoring well R-8 and the other on the
east'side'of Zone 1. Are these monitoring wells or water supply wells? Other wells identified
off -site are called "active wells". Should these wells be abandoned if water supply.wells and/or
should a alternate compliance boundary be requested to move these wells outside of the 250'. CB?
Jim Barber
Nathaniel Thornburg.wrote:
Here are' my thoughts on the draft comments, feel free to reply or call me.,
1. Pipe Length -.OK.
2. Monitoring Wells - I -think that wells R-2 and R-5 need to be.abandoned due to their lying
outside the RB.'I propose having them install wells R-2a, R-5a and a well to the north of Zone
10 (R-9?).
In addition; I think we need a permit condition stating:
:"The Permittee has approved the location of monitoring wells R-1, R-3, R-4,. R-6, R-7 and R-8
within the review boundary as specified in 15A NCAC 02L .0108. Per a letter dated April 1,
2009, in the event of 2L Groundwater Standard exceedances'.in monitoring wells R-1,'R-3, R-4,
R-6, R-7 and R-8, the Permittee has agreed to either take the necessary actions cited in 15A
NCAC 02L .0106(d) (1) or abandon any of the aforementioned wells' within the review boundary
that exceed 2L Groundwater Standards and replace said well with a iiew downgradient monitoring
well on the review boundary."
3. Waste Level Gauges - Since the upper lagoon has an overflow pipe, I'm fine with not
requiring a gauge. However, I.want to keep the current language in the permit for the,lower
lagoon
4. Freeboard - Remove the requirement to measure freeboard in the upper lagoon.
5. Soil Analysis for.Acidity - Acidity is measured by determining the amount of H ions in meq
per 100'g of sample.
6. Metal Monitoring - I will defer to FRO, but I do not have an issue with reducing the
metals monitoring.
1 of 2 4/15/2009 9:42 AM

Le: [Fwd: Re: WQ0004268 - Allens, Inc: Draft Comments]
7. pH Monitoring in Attachment A - Section Policy is to require 5 x Week pH sampling for all
facilities greater than 10,000 GPD. There is a caveat for passive lagoon treatment systems
that allows weekly sampling,however, that is for systems less than 30,000 GPD. Also, the
daily sampling can be done using a field pH test by the ORC, not the contracted laboratory
staff:
8. Zones for Field A - I will fix, BIMS was incorrect...
9. Field C Hydraulic Limit - I will fix,' BIMS was incorrect...
10. pH Groundwater Standard - I'think this.could be handled two different ways (1) Using our
best professional judgment when we get BIMSviolations, or.(2) having them submit a
modification request to prove baseline pH values for the facility are less than 6.5 su. - I
will defer to FRO.'
Thoughts?
NT
Could we give them the option of doing one (abandoning wells) or the,other ;(request an alt. CB)?
OK, let's go with that.
Randy Sipe
Division of Water Quality
Aquifer Protection Section
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
2 of 2 4/15/2009 9:42 AM

Aquifer Protection Section
Washington Regional Office
March 2, 2009
MEMORANDUM
To: Nathaniel Thornburg
Aquifer Protection Section - Land Application Permits & Compliance Unit
Rich Hayes
Aquifer Protection Section — Raleigh Regional Office
From: Randy Sipe
Aquifer Protection Section — Washington Regional Office -
Subject: Additional Information Review Comments — Express Review Permit. Modification
Application No. WQ0004268
Aliens, Inc.
Wastewater Surface Irrigation Modification
Included below are my comments based upon my review of the additional information package submitted on
February 25, 2009.
Hydrogeologic Report
a) Revised Figure 4 shows a few relatively small areas of potential breakout at or slightly less than 100 feet
from the spray field boundaries (the setback to surface waters allowed in 2T .0506(a)). Given that the
mounding analysis was, performed using a conservative 80th percentile precipitation value, it does not
appear that,breakout will be a widespread or pervasive problem during operation of the spray fields.
However, I do suggest that the modified permit include a condition specifically requiring inspections of
the spray fields and surrounding areas for evidence of ponding, runoff, and breakout during and after
each irrigation event. The results of these inspections should also be documented in the operators log
book.
Site Plan
a) The proposed monitoring wells shown on Figures 1 and 4 of the Hydrogeologic Report should also be
shown on the Site Map.

Re: WQ0004268 - Allens,.Inc. Draft Permit
Subject: Re: WQ0004268 - Allens, Inc. Draft Permit
From: Randy Sipe <[e-mail]>
Date: Fri, 27 Mar 2009 09:27:55'-0400
To: Rich Hayes <[e-mail]>, Nathaniel Thornburg <[e-mail]>
Rich Hayes wrote:
Nathaniel,
I would like to add the following permit condition:
Upon completion of construction and prior irrigation in Zones 1 to 18A, a soil scientist evaluation -
shall be completed for all areas where old farm roads lie within the wetted area of irrigation fields.
The report shall certify that the renovated former road areas are capable of accepting the designed
loading rate. This report shall specifically address, but not be limited to, soil features such as soil
compaction and. saturated hydraulic conductivity of the least permeable layer, as.well as any other'_
properties that might impact the soil's ability to accept irrigation water. The requested information
must be received and acknowledged in writing by the Aquifer Protection Section.,.1628 Mail Service
-Center, Raleigh, NC 27699-1628,.prior to any irrigation of wastewater in Zones 1 to 18A.
This condition, should also be mentioned in the cover letter section that lists new permit conditions.
Monitoring wells R-1, R-2, R-3, R-4, R-6, and R-8 should be abandoned and replaced by monitoring wells
on the review boundary. I'll defer to Randy.for the.location of the new wells but would suggest that
one of them be placed north of Zone 10 to -provide -protection for the_water_supply well on the'adjacent
property.
Rich
nathaniel.thornbur•encmail.net wrote:
Rich and Randy,
Please review the attached draft permit and provide comments to me by around lunch time Friday. The
attachments are not complete (I am having trouble with RIMS froth home but Lori is going to help me
in the morning), but when I send_the draft out to the Applicant, I will copy you guys so you can
review the attachments.
Also, could you please flesh but the well names for me. Which wells need to be abandoned, etc.
Have we considered replacement wells for the ones to be abandoned or should we make the Applicant do
that?
'Thanks!
NT- -
•
"-E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law
and may be disclosed to third parties."
With the inclusion of an additional well north of Zone 10, as Rich noted, the current aerial distribution
is wells appears adequate to characterize groundwater quality at the site. However, I would like to
mention that based on what I saw on the site visit with regards to surface topography and proximity to
wetlands, I don't think wells R-2 and R-3 can be practically moved away from the spray zones. By doing
so, it would make it very possible that these wells would. be in.stariding water at least. part of the year, -
which I don't.think would be a good thing.
Randy Sipe
Division of Water Quality
Aquifer Protection Section
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
Fax: [phone]-
E-mail correspondence to and from this address may be subject to the NorthCarolinaPublic Records Law and
may be disclosed to third parties. -
1 of 1 . 4/15/2009 9:41 AM

Aquifer Protection Section
Washington Regional Office
February 6, 2009
MEMORANDUM
To: Nathaniel Thornburg
Aquifer Protection Section - Land Application Permits & Compliance Unit
Rich Hayes
Aquifer Protection Section — Raleigh Regional Office
From:
Subject:
Randy Sipe
Aquifer Protection Section — Washington Regional Office
Review Comments — Express Review Permit Modification Application No. WQ0004268
Allens, Inc.
Wastewater Surface Irrigation Modification
Included below are my comments based upon my review of the permit modification application package
submitted" on January 28, 2009 and observations made during the site visit on February 5, 2009.
Application
a) The annual loading rates for the surface irrigation zones presented in Item VII.10 are not consistent with
the loading rates recommended in the Hydrogeologic Report and Water Balance. The application
should be revised to be consistent with these reports.
Hydrogeologic Report
a) Please revise Figures 1 and 4 to show the existing irrigation pond observed during the site visit east of.
irrigation zones 2 and 3. Does the presence of this pond affect the calibration of the model and the
results of the mounding analysis?
b) Existing water wells WW-1 through WW-5 have been identified in the vicinity of the site and are
discussed in the report text and shown in Table 1; however, Figures 1 and 4 do not show the location of
well WW-2. Please revise the figures to show the locations of all five wells.
c) The values for annual precipitation and evapotranspiration (ET) used to calibrate the groundwater flow
model are different that those used in the water balance. Why is there a discrepancy between the two
sets of values and does this discrepancy affect, the validity of the model and/or the water balance? Also,
the amount of precipitation used for the 80th percentile annual precipitation in the mounding analysis is
not given. What was this value and is it consistent with the corresponding value used in the water
balance?

d) In the discussion of boundary conditions used in the groundwater flow model on page 15 of the report it
is mentioned that drain boundary conditions were assigned to the entire upper surface of the model
(ground surface) allowing the site to drain if the water table intercepts the land surface. Please expand
the report to discuss whether or not during the mounding analysis the water table was observed to
intercept the land surface within the compliance boundary in areas other that existing surface water
features and existing or proposed drainage features.
e) The results of background groundwater quality analyses performed at the site presented in Table 12
indicate that the 2L groundwater quality standard for nitrate was exceeded in monitoring well R-8,
which appears to be in an upgradient location at the site, based on the groundwater flow contours shown
on Figure 4. Given that upgradient groundwater quality already exceeds 2L standards at the site, how
does the applicant propose to evaluate groundwater quality in the monitoring wells during the operation
of the spray fields so that any impacts to groundwater quality from the fields can be detected?
f) Monitoring wells R-2 and R-3 are located essentially at the edge of the delineated wetlands around
irrigation zone 18. If groundwater contamination is detected in these wells what will be the applicant's
plan of action to address this situation, given the presence of the wetlands between the wells and the
compliance boundary?
Detailed Plans
a) The e-mail message provided with the application from the Surface Water Protection Section regional
office approving the use of a subsurface groundwater lowering drain in irrigation zone 18 stated that this
approval was given with the understanding that the outlet of this drain would be located some distance
from the wetland boundary. The outlet for the drain shown on Sheet C-107 is only approximately 20
feet from the wetland boundary. Is this location consistent with the approval given by the Surface Water
Protection Section regional office?
b) The existing irrigation pond observed during the site visit east of irrigation zones 2 and 3a should be
shown on Sheet C-105 and it should be determined if the required setback has been maintained between
the pond and the spray fields.
c) The exiting ditch that extends north -south through the site between irrigation zones 10, 11, 12, and 13 on
the west and zones 14, 15, and 16 on the east should be shown on Sheets C-105, C-106, and C-107.
d) The groundwater lowering drain trench detail on Detail 2 of Sheet D-102 shows a filter fabric to be
placed around the aggregate surrounding the drain pipe. This office is concerned that if this filter fabric
becomes clogged the effectiveness of the drain will be reduced and we recommend that it be removed
from the design unless the engineer can prove that the drain will continue to operate in themanner
depicted in the model simulation performed by the hydrogeologist if the fabric becomes clogged.
e) During the site visit an approximately 6-inch diameter PVC pipe was observed in the existing ditch east
of irrigation zones 5 and 6 near monitoring well R-6. The extent of the pipe that crosses the ditch should
be determined, as well as its purpose. If the pipe is to remain in place during operation of the irrigation
fields, it's location and extent should be shown on the detailed plans.