20080868 Ver 2_R-12 More Info Requested_20161128

Environmental
Quality
November 28, 2016
CERTIFIED MAIL: 7016 0750 0001 0901 7891
RETURN RECEIPT REQUESTED
Mr. Jeffrey Furness
PCS Phosphate Company, Inc.
1530 NC Highway 306 South
Aurora, NC 27806
Subject: REQUEST FOR ADDITIONAL INFORMATION
R-12 Groundwater Monitoring Plan
Dear Mr. Furness
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
JAY ZIMMERMAN
DWR Director
DWR # 2008-0868 Ver. 2
Beaufort County
On January 15, 2009, the Division of Water Resources (DWR) issued a revised 401 Individual Water Quality
and Buffer Authorization Certification to impact 25, 727 feet of stream, 3,953 acres of 404 and CAMA
wetlands, 19 acres of waters and 47.87 acres of protected riparian buffer in order to expanded mining
operation at the Potash Corporation (PCS) facility in Beaufort County.
In order to meet a portion of Condition 12 of the 401 and Buffer Authorization Certification for this project,
DWR received a groundwater monitoring plan entitled "R-12 Groundwater Monitoring Plan" on June 13,
2016. After review of the groundwater monitoring plan, the Division has determined the following items
will need to be added or clarified for proper consideration of the plan to satisfy the portion of Condition
12 of the 401 and Buffer Authorization Certification.
The plan states the monitoring of the upper portion of the Castle Hayne aquifer which varies from
-160 ft. to -180 ft. MSL according to page 5 and Figure 4. Current groundwater contours show
depths ranging from -58 ft. to -94 ft. MSL according to Figure 5. Based on current groundwater
contours, please provide justification for the proposed monitoring zone of the upper Castle
Hayne. Shallow groundwater in the Yorktown formation (-30 ft. to -90 ft. MSL) was not addressed
in the plan. If further evaluation indicates such need, shallow and deep well clusters may better
address the need to adequately monitor groundwater conditions across different zones.
• To address potential data gaps attributable to monitoring well spacing and locations, additional
wells/clusters are recommended southwest of R12MW1 and relocation of R12MW6 to the west
as shown on the amended attached figure (R-12 Proposed Groundwater Monitoring Well Sites).
• The proposed monitoring includes limited metals analysis. Please expand metals based
parameters to include total arsenic, dissolved arsenic, total chromium, dissolved chromium, total
<"' "Nlothing Compares'-_
State of North Carolina I Environmental Quality I Water Resources -Water Quality Regional Operations Section -Washington Regional Office
943 Washington Square Mall, Washington, North Carolina 27889
252-946-6481

PCS Phosphate Company, Inc.
DWR # 2008-0868 V2
ADDITIONAL INFORMATION
Page 2 of 2
lead, dissolved lead, total manganese, dissolved manganese, total nickel, dissolved nickel, total
zinc, dissolved zinc utilizing an appropriate analytical method with a corresponding method
detection limit.
Please contact Anthony Scarbraugh at 252-948-3924 or [e-mail] if you have any
questions or concerns.
Sincerely,
hj� ��
G
David May, Regional Supervisor
Water Quality Regional Operation Section
Division of Water Resources, NCDEQ
cc: Thomas Steffens, USACE Washington Regulatory Field Office (via email)
Todd Bowers, EPA, Sam Nunn Federal Center, 61 Forsyth Street SW, Atlanta, GA 30303
John Payne, NC Attorney General's Office, Environmental Division
Doug Huggett, DCM Morehead City
Cory Larson, DWR 401 & Buffer Permitting Unit (via email)
DWR WaRO
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