Corrective Action Variance Application City of Raleigh Neuse River Wastewater treatment Plan Raleigh NC 12-1-2005 (2)

Corrective Action Variance Application
City of Raleigh
Neuse River Wastewater Treatment Plan
Raleigh, North Carolina
December 1, 2005
Response: Please find enclosed the City's revised variance application which includes a
requestfor a variance from 15A NCAC 02L .0107(k)(3)(A) in addition to our original
request for a variance from 15A NCAC 02L .0106(k) that limits the applicability of the
latter rule to non-permitted facilities.
With this letter, the City believes you have all required information to review and support
the variance application. Please do not hesitate to contact me at 857-4540, if you have
any immediate questions regarding the City's corrective action plan or variance request.
H. Dale C
Raleigh P ities Director
Cc: · City Manager
City Attorney
Reuse Superintendent
Wastewater Treatment Plant Superintendent
Kilpatrick Stockton -Levitas
ENSR -Thibodeau
Corrective Action Variance Application
City of Raleigh
Neuse River Wastewater Treatment Plan
Raleigh, North Carolina
December 1, 2005
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TABLE OF CONTENTS
Page
1.0 Introduction ........................................................................................................................ l
2.0 Site Background and History ............................................................................................ 2
2.1 Site Description ...................................................................................................... 2
2.2 Site Physiography, Geology and Hydrogeology .................................................. 3
2.2.1. Regional Physiography .............................................................................. 3
2.2.2. Site Geology ................................................................................................ 3
2.2.3. Hydrogeology .............................................................................................. 4
3.0 Information Supporting Variance Request.. .................................................................. .4
3.1 Resolution ............................................................................................................... 4
3.2 Description of Past/Existing/Proposed Sources of Groundwater
Contamination ........................................................................................................ 4
3.2.1. Water Supply Wells ................................................................................... 5
3.2.2. Soil Sampling Results ................................................................................ 6
3.2.3. Groundwater Analytical Results .............................................................. 6
3.2.4. Surface Water Results ............................................................................... 6
3.2.5. Soil PAN Evaluation .................................................................................. 7
3.3. Description of the Proposed Variance Area ........................................................ 7
3.4. Public Health and Environmental Exposure ....................................................... 7
3.4.1. Groundwater .............................................................................................. 7
3.4.2. Surface Water ............................................................................................. 8
3.5. Economics of Available Technology ..................................................................... 9
3.5.1. Alternative 1: Groundwater Extraction and Enhanced
Denitrification along the Compliance Boundary and Discharge
to NRWWTP .............................................................................................. 9
3.5.2. Alternative 2: Groundwater Containment in Fields 50 and
500, Discharge to NRWWTP or Land Application, and Long-
Term Monitoring in Other Areas .......................................................... .11
3.6. Financial Hardship and Lack of Public Benefit ............................................... .12
3. 7. Information Regarding Adjacent Property Owners ........................................ 13
4.0 Summary and Conclusions ............................................................................................. 13
5.0 References ......................................................................................................................... 14
LIST OF TABLES
Table 1: Private Well Nitrate Nitrogen Results and Water Supply/Service Status
Table 2: Soil Analytical Results
Table 3: Groundwater Analytical Results -City Test Wells
Table 4: Groundwater Analytical Results -CSA-SSA Monitoring Wells
Table 5: Surface Water Analytical Results
Table 6: Description of Proposed Variance Areas
Table 7: Projected Debited Total Nitrogen Allocation
Table 8: Neuse River Wastewater Treatment Plant Budget
LIST OF EXHIBITS
Exhibit I: Nitrate Analytical Results
Exhibit 2: Human Health Risk Assessment -ENSR Consulting and Engineering (NC), Inc.
Exhibit 3: Ownership Information for Variance Parcels and Parcels Adjacent to Variance
Parcels
LIST OF FIGURES
Figure I: Nitrate Analytical Results
Figure 2: Proposed Remediation Plan and Variance Areas
Figure 3: Private Wells within 0.5 miles of Neuse River Wastewater Treatment
Plant Spray Irrigation Areas
1.0 Introduction
This variance application has been prepared on behalf of the City of Raleigh Public Utilities
Department (CORPUD) to support CORPUD's request for approval of its Revised Corrective
Action Plan (CAP) to address nitrate contamination in groundwater at the biosolids application
fields serving the Neuse River Wastewater Treatment Plant (NRWWTP) in southeastern Wake
County.
In preparing the CAP, CORPUD evaluated various remedial alternatives to address nitrate
contamination at the site. CORPUD's evaluations focused on two alternatives. The first
alternative is one that fully complies with the Environmental Management Commission's (EMC)
rules and includes both hydraulically containing nitrate-impacted groundwater within the
compliance boundary and performing enhanced denitrification of groundwater beyond the
compliance boundary in areas where nitrate concentrations were predicted to exceed 10
milligrams per liter (mg/L). CORPUD determined that the capital and operation and
maintenance costs of this alternative over a thirty-year period would be nearly $80 million
dollars. Because of the economic infeasibility of the remedy, CORPUD explored alternative
remedies that would provide ample protection to human health and environment in an
economically reasonable manner.
As a result of this evaluation, CORPUD developed a second alternative remedy-its preferred
alternative -that provides for hydraulic containment of groundwateF in the area with the highest
density of existing residences immediately downgradient of the land application fields together
with long-term groundwater monitoring and natural attenuation of nitrate levels for the
remainder of the site. This remedy would fully comply with the EMC's rules for corrective
action in 15A NCAC 02L .0106(k) ifCORPUD were anon-permitted facility. Since CORPUD
is a permitted facility, this remedial alternative requires CORPUD to receive a variance from the
EMC's rules. Specifically, CORPUD requests a variance from 15A NCAC .0106(k) that limits
the applicability of that rule to non-permitted facilities.
CORPUD believes that its preferred alternative is fully protective of public health and the
environment, provided that nitrogen loading to the Neuse River via groundwater is addressed as
discussed in detail below. CORPUD does not believe the first alternative is economically
reasonable, particularly considering the minimal benefit gained from the substantial additional
expenditure. For these reasons, CORPUD believes that a variance from the rules of 15A NCAC
Subchapter 02L is appropriate and has prepared this document to support its request.
In addition to the information required by 15A NCAC 02L .0113(c), this document provides
background and historical information for the NRWWTP site in Section 2.0. Section 3.0
provides the following information that is required for the variance request:
(1) A resolution of by the City of Raleigh requesting the variance.
(2) A description of the past, existing or proposed activities or operations that have or
would result in a discharge of contaminants to groundwater.
(3) A description of the proposed area for which a variance is requested, including a
detailed location map, showing the orientation of the facility, potential for
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groundwater contaminant migration, as well as the area covered by the variance
request, with reference to at least two geographic references.
(4) Supporting information to establish that the variance will not endanger the public
health and safety, including health and environmental effects from exposure to
groundwater contaminants.
(5) Supporting information to establish that requirements of Subchapter 02L cannot
be achieved by providing the best available technology economically reasonable,
including the specific technology considered, the costs of implementing the
technology, and the impact of the costs on the applicant.
(6) Supporting information to establish that compliance would produce serious
financial hardship on the applicant.
(7) Supporting information that compliance would produce serious financial hardship
without equal or greater public benefit.
(8) A list of the names and addresses of any property owners within the proposed area
of the variance as well as any property owners adjacent to the site covered by the
variance.
A summary of this variance application and conclusions is presented in Section 4.0, and
references are located in the final section.
2.0 Site Background and History
2.1. Site Description
The NR WWTP consists of approximately 1,466 acres of mostly contiguous farmland owned or
leased by CORPUD and divided into numbered fields. Properties surrounding the Site consist of
residential properties, farmland, and state-owned forestland. The northern and eastern Site
boundaries border a 3.6-mile section of the Neuse River. Beddingfield Creek bounds the Site to
the south. Topographically, the Site ranges in elevation from an approximate high of 270 feet
above mean sea level (ft msl) in upland areas to an approximate low of 140 ft msl at the Neuse
River (ENSR, 2002). A layout of the facility, associated biosolids application fields and the
current compliance boundary are depicted on Figure 1.
The Neuse River is classified as a Class C NSW (nutrient sensitive water) from the Falls Lake
Dam to the mouth of Beddingfield Creek. From the mouth of Beddingfield Creek to
approximately 0.2 miles downstream of Johnson County State Road 1700, the Neuse River is
classified as Water Supply V Nutrient Sensitive Water (NSW). Beddingfield Creek is classified
as C NSW from the source to the Neuse River. No nitrate water quality standard has been
established for class C NSW surface water. For surface waters classified as Water Supply V
NSW, nitrate water quality standard is 10 mg/L.
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2.2. Site Physiography, Geology and Hydro geology
2.2.1. Regional Physiography
The Site is situated within the eastern Piedmont Physiographic Province of North Carolina. Area
topography consists of rolling hills dissected by narrow v-shaped drainage ways and perennial
streams that drain into Neuse River. Localized steep bluffs exist to the south along Beddingfield
Creek and along the Neuse River to the east and north of the Site (May and Thomas, 1965).
Localized bluffs in this area plateau to narrow bench cut alluvial floodplains that are nearly flat
with incised drainage ways to the Neuse River.
2.2.2. Site Geology
The Site is within the Raleigh Geologic Belt and the underlying bedrock consists of massive
granitic rock of the Rolesville series. The granitic bedrock is part of an intrusive series described
as megacrystic to equigranular and is dated between 270 and 320 million years old
(Pennsylvanian to Permian). Mafic dikes have been identified regionally and generally have a
northwest to southeast alignment. According to published literature, these dike features may be
up to 100 to 200 ft wide. Smaller dike splays may be 10 to 20 ft wide (Parker, 1979). Details of
the dikes and geologic maps can be found in the SSA (ENSR, 2003).
Lithologic units identified at the Site are typical of local piedmont geology and include the
following:
• Topsoil and weathered parent rock material, referred to as saprolite tends to be
moderately thick in locations without visible rock outcropping. Site saprolite consists of
yellow brown to orange sandy silts (ML) to silty sands (SM) with the coarser material at
depth. Regionally, saprolite can vary in thickness from a few feet to up to hundreds of
feet. Saprolite typically contains relict structures and fabric from the parent rock from
which it has weathered. Saprolite thickness at the Site commonly ranges between 30 and
60 feet below surface grade (bsg).
• Partially weathered rock (PWR), often referred to as the transition zone between saprolite
and the parent unweathered bedrock, often exhibits the same properties as deeper
saprolitic soils (SM) but with higher occurrence of rock and rock fragments. PWR
thickness often ranges from 0 to 10 ft thick on ridges and uplands to 10 to 20 ft thick
along slopes and low-lying areas (Wilson and Carpenter, 1981 ).
• Bedrock in this area typically consists of granitic rock with fractures near the interface of
PWR and bedrock. The number and size of the fractures generally dissipate with depth
while voids and vugs are common in shallow rock zones when weak exfoliation soil
zones are encountered near PWR.
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2.2.3. Hydrogeology
Hydrogeologically, the Site is situated in a meta-igneous hydrostratigraphic unit of the eastern
Piedmont of North Carolina (Daniel and Payne, 1990). Two general hydrostratigraphic units
(saprolite and PWR/upper bedrock) characterize the regional hydrogeology. The upper saprolite
unit is an unconfined aquifer that transmits water downward to the lower semi-confined PWR
and fractured confined crystalline bedrock aquifer unit. Groundwater yields often range from 2 to
20 gallons per minute (gpm) within the unit (Daniel and Payne, 1990). Groundwater occurs
where saprolite and localized sedimentary/alluvial deposits along the Neuse River overlie
bedrock. Groundwater movement in the saprolite is typographically controlled by groundwater
divides associated with ridges and streams. Typically flow of groundwater occurs from upland
areas (ridgelines) to perennial streams. The underlying granitic rocks are known to have lower
hydraulic conductivities than either saprolite or PWR and controls deep groundwater or regional
groundwater flow conditions. The PWR lies between saprolite and bedrock units and
groundwater movement flows both within the material matrix and through fractures.
Groundwater movement in bedrock is restricted to intersecting sets of water-bearing fractures
andjoints (Hamed and Daniel, 1989).
Hydraulic properties of the saprolite and PWR zones were evaluated using rising and falling
head slug test methods. Hydraulic conductivity (K) values for the shallow aquifer ranged from
1.3 x 1 o·6 to 6.4 x 10-3 centimeters per second (cm/sec). K values for PWR wells ranged from
4 .4 x 10·5 to 1.1 x 10-3 cm/sec. A transmissivity of 4.6 x 10·5 square centimeters per day
(cm2/day) (1.3 square feet per day [ft2/day]) was obtained for well MW-126d (ENSR, 2003).
Quantification of groundwater flow directions and rates has been provided by a calibrated, three-
dimensional groundwater flow model. Quantification of the movement and discharge locations
of nitrogen originating from the biosolids fields has been provided by a three-dimensional
transport model that uses the flow model to compute groundwater velocities. Both of these
models are documented in the Comprehensive Site Assessment and Supplemental Site
Assessment, and have been reviewed and approved by the Aquifer Protection Section.
3.0 Information Supporting Variance Request
3.1. Resolution
In accordance with 15A NCAC 02L .0113(c)(a), the Raleigh City Council (Council) has made
this request for a variance to the EM C's rules. A copy of the Council's resolution to this effect is
attached as Exhibit 1.
3.2. Description of Past/Existing/Proposed Sources of Groundwater
Contamination
CORPUD has been operating the NRWWTP in southeastern Wake County since 1976. It began
land-applying biosolids in 1980 under a land application permit (Permit # WQ000 173 0) issued
by the North Carolina Division of Water Quality (DWQ). The permit allows for the application
of 7,000 total dry tons of Class B Biosolids per year on fields listed in the permit. Figure 1
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permit condition, CORPUD will be required to count toward its annually-reported amount of
discharged nitrogen not only the amount actually discharged by the NRWWTP, l:5ut also the
annual amount the model predicts will be discharged to the Neuse River via groundwater as a
result of the violations of the groundwater stanaard for nitrate. The model conservatively
indicates that the amount of this additional nitrogen discharge will be 123,000 pounds in 2006
and will decrease approximately 3,000 pounds per year. Table 7 illustrates the effect of this
nitrogen debit over time. The debit can be adjusted to reflect actual field conditions and would
be eliminated whenever all monitoring wells come into compliance with the standard. As a
result of this condition, CORPUD's wastewater treatment and disposal operations at the
NRWWTP will never contribute more nitrogen to the Neuse River than is currently allocated.
3.5. Economics of Available Technology
In determining an appropriate CAP for the nitrate contamination at the NR WWTP site, ENSR
identified potentially applicable technologies and evaluated alternatives for containing and
treating nitrate-impacted groundwater at the site (ENSR, 2005). ENSR completed a detailed
evaluation of a remedial alternative that uses best available technology and achieves full
compliance with the EMC's rules for groundwater corrective action (Alternative 1). This
remedy would include both hydraulically containing nitrate-impacted groundwater within the
compliance boundary and denitrification of groundwater beyond the compliance boundary in
areas where nitrate concentration were predicted to exceed 10 mg/L. Monitoring to evaluate the
effective1,1ess of the system would occur for at least 30 years, the expected life of the project.
The capital and operation and maintenance costs of this alternative over a thirty-year period
would exceed $68 million dollars.
Alternative 2, CORPUD's preferred alternative, provides for hydraulic containment of
groundwater in the area with the highest concentration of existing residences immediately
downgradient of the land application fields together with long-term groundwater monitoring and
natural reduction in nitrate levels for the remainder of the site. 1 This remedial alternative
requires CORPUD to receive a variance from DWQ's rules. Alternative 2 would cost
approximately $9 million dollars to implement -$70 million dollars less than Alternative I -and
provide ample protection of human health and the environment. The following sections present
the details and these remedial alternatives and their associated costs.
3.5.1. Alternative 1: Groundwater Extraction and Enhanced Denitrification
along the Compliance Boundary and Discharge to NRWWTP
Extraction System Process. Based on hydrogeologic data and results of groundwater flow
modeling, it is anticipated that approximately 426 extraction wells (100-ft spacing) would be
1 CORPUD believes that a variance could be justified that required no active remediation. However, DWQ
indicated early in this process that its support for a variance request would be conditioned upon the CAP including
active remediation in the area with the highest concentration of downgradient residences , and CORPUD has agreed
to that condition .
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installed along the portions of the compliance boundary where the nitrate groundwater standard
has been exceeded and/or is estimated to be exceeded based on groundwater modeling. The
depth of extraction wells would be expected to vary in different areas of the Site based on
elevation and water table. For purposes of developing probable costs, the average depth for the
wells is assumed to be 70 ft bsg. The average groundwater yield from these wells would be 2
gpm (1,226 ,880 gallons per day) which would be pumped through a network of extraction piping
to the NRWWTP for treatment. The piping required to convey water to the NRWWTP is
assumed to be installed underground, in trenches, along the roads and fields. The design,
construction, start-up, and decommissioning costs of this alternative are estimated to be
$19,220,060. Operation and maintenance costs,c-i ncluding treating the extracted water, would
cost approximately $29,868,120 over 30 years. The present worth of the costs associated with
the groundwater extraction system is approximately $30,727,827.
Enhanced Denitrification System Process. The enhanced denitrification process involves
injection (pressure or gravity feed) of biodegradable carbon electron donor (e.g., com syrup or
sodium lactate) via injection wells to create in situ anaerobic zones that would denitrify nitrate-
enriched groundwater in plumes situated beyond the compliance boundary across the Site. The
electron donor injection allows the populations of native microorganisms to multiply to the point
where microbial respiration consumes the available dissolved oxygen in groundwater. In the
absence of dissolved oxygen the microbes would use nitrate as an electron acceptor and produce
nitrogen gas, a process referred to as denitrification. Nitrate-impacted groundwater from the
application fields that migrates into the anoxic zone would be exposed to the denitrifying
bacteria and pass through the anoxic zone with little to no nitrate remaining in the water.
Prior to implementing a full-scale in-situ denitrification system, a pilot test would have to be
conducted to evaluate the effectiveness at the Site and to collect data for full-scale design.
Injection wells would be constructed within the compliance boundaries of the above-referenced
fields to reduce nitrate concentrations in the impacted groundwater. ENSR estimated that
approximately 195 injection wells would be required to achieve this control. Injection wells
would be properly spaced to allow establishment of anaerobic zones to support denitrification.
ENSR also anticipates that the injection wells would be installed to depths ranging from 65 to 85
ft bsg using conventional drilling techniques. This process would involve preparing the electron
donor solution by mixing the required amount of electron donor ( e.g., com syrup or sodium
lactate) with appropriate amounts of potable water. The electron donor solution would then be
manually injected into injection wells by either gravity feeding or pumping.
This remedy would require a field-scale pilot study to estimate the quantities of electron donor
solution and to determine the design parameters (e.g., area of influence, spacing and number of
injection wells/points, frequency of injection) prior to designing a full scale system. For the
purpose of costing, ENSR estimated that electron donor solution would be injected quarterly for
two years.
ENSR determined that the probable costs for the denitrification portion of Alternative 1,
including capital costs, operation and maintenance, and short-term monitoring, would be
$27,769,400, which has a present worth of $25,401,200.
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compliance monitoring (for the biosolids application permit) for the Site. Analytical data from
these test wells would be used to evaluate the effectiveness of this alternative. For the purpose of
costing and comparison, it was assumed that the project life of this alternative is 30 years. The
costs to monitor compliance wells (test wells) required under the biosolids permit are not
included in this estimate. The cost of monitoring over 30 years would be approximately
$2,307,600, with a present worth of $1,046,665.
3.6. Financial Hardship and Lack of Public Benefit
The full-compliance alternative would create a serious financial hardship on CORPUD requiring
that it spend approximately $70 million dollars beyond the approximate $9 million that it will
have to spend to implement its preferred alternative. Further, the immense expenditure required
to implement the full compliance alternative would not result in commensurate public benefit
relative to the more cost-effective and fully protective proposed remedy.
To illustrate the financial hardship that the full compliance alternative would incur, the City has
provided its projected operating and capital budgets in Table 8. The operations budget for the
NRWWTP and associated spray irrigation is approximately $14,000,000 per year over the next
few years. Operations and maintenance costs for Alternative 1 would be over $5,000,000 during
the first 3 years of the project. The combined capital, operation, and maintenance costs accounts
for almost a third of CORPUD's expected total annual operations budget over the next few years.
When the denitrification system is discontinued in the third year of the project, the annual
operations and maintenance costs decrease to approximately $1,000,000. However, this is still a
significant annual cost accounting for about seven percent of the operations budget.
The projected capital costs (including design, construction and startup) of Alternative 1 are
predicted to be $35,402,500 which would have to be paid out by the City over the first 2 years of
CAP implementation. Because of the age of the facility and the need for expansion to keep up
with the growing population, the NRWWTP requires a number of expensive improvements over
the next several years. Over the next three years when the capital costs of the CAP are likely to
be incurred by CORPUD, the CORPUD's capital budget for the NRWWTP for fiscal year 2006-
07 is $58,175,000, for 2007-08 is $31,625,000, and for 2008-2009 is $19,800,000. Assuming
that the City would spend more than $17,500,000 per year for the first two years of the project,
this sum would be approximately 30 to 90 percent of its total capital budget in any of the next
few years. The City would be compelled to divert funds allocated to the numerous and extensive
capital improvements planned for the NR WWTP putting the protection of water quality and the
availability of high quality wastewater treatment service to the area's growing population at risk.
This would be a great detriment to public health and outweigh any benefits of Alternative 1.
Further, the full-compliance alternative requires the expenditure of $79 million dollars to clean
up groundwater that has a very low likelihood of actually being used by the public for drinking
water or any other purpose.
Finally, Alternative 1 would have detrimental effects on the environment as the remedy is very
invasive, requiring the installation of 426 pumping wells, each installed at 100-foot intervals,
along portions of the City's property boundary where groundwater exceeds or is expected to
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baseflow to several streams in the area, particularly Beddingfield Creek, which would be
potentially detrimental to the ecology of those streams.
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5.0 References
ENSR, 2002, Comprehensive Site Assessment, City of Raleigh, Neuse River Waste Water
Treatment Plant, December.
ENSR, 2003, Supplemental Site Assessment, City of Raleigh, Neuse River Waste Water
Treatment Plant, December.
ENSR, 2005, Revised Corrective Action Plan, City of Raleigh, Neuse River Waste Water
Treatment Plant, December.
4229980.6
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Sample ID/ Field Sample
De pth Location Date
SB-1 0-7" Field 3 12/12/02
SS-1 0-4' Field 3 11/14/02
SS-1 4-8' Field 3 11/14/02
SS-1 8-12' Field 3 11/14/02
SS-112-16' Field 3 11/14/02
SS-1 16-22' Field 3 11/14/02
SB-2 0-7" Field 3 12/12/02
SS-2 0-4' Field 3 11/14/02
SS-2 4-8' Field 3 11/14/02
SS-2 8-12' Field 3 11/14/02
SS-2 12-14' Field 3 11/14/02
SB-3 0-7" Field 100 12/12/02
S83 0-4' Field 100 11/15/02
SB3 4-8' Field 100 11/15/02
SB3 8-12' Field 100 11/15/02
SB3 12-16' Field 100 11/15/02
S83 16-20' Field 100 11/15/02
SB3 20-24' Field 100 11/15/02
SB-4 0-7" Field 100 12/12/02
SB4 0-4' Field 100 11/15/02
S84 4-8' Field 100 11/15/02
SB4 8-12' Field 100 11/15/02
S84 12-16' Field 100 11/15/02
S84 16-20' Field 100 11/15/02
SB-5 0-7" Field 500 12/23/02
S85 0-4' Field 500 11/15/02
S85 4-8' Field 500 11/15/02
S85 8-12' Field 500 11/15/02
S85 12-16' Field 500 11/15/02
SB5 16-24' Field 500 11/15/02
SB-6 0-7" Field 500 12/12/02
S86 0-4' Field 500 11/15/02
S86 4-8' Field 500 11/15/02
S86 8-12' Field 500 11/15/02
D-S86 8-12' Field 500 11/15/02
S86 12-16' Field 500 11/15/02
SB616-20' Field 500 11/15/02
Field 17 Field 17
Field 18 Field 18
Field 19 Field 19
Field 22 Field 22
Field 27 Field 27
Field 28 Field 28
Field 33 Field 33
Field 35 Field 35
Field 36 Field 36
Field 37 Field 37
Field 38 Field 38
Field 39 Field 39
Field 40 Field 40
Field 42 Field 42
Field 43 Field 43
Field 45 Field 45
Field 49 Field 49
Field 50 Field 50
Field 73 Field 73
Field 511 Field 511
Notes:
TKN -Total Kjeldahl Nitrogen
TOC -Total Organic Carbon
mg/kg -Milligrams per kilogram
J -Estimated value
NA -Not Analyzed
PAN Surf-Plant Available Nitrogen (Surface)
TABLE 2
Soil Analytical Results
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Ammonia Nitrate Nitrite Solids TKN
(mg /kg ) (m g /kg ) (m AlkA) (%) (mg /kal
1.3 2.9 <1.0 82 1600
1.1 9 <1 80 920
<0.1 9.4 <1 82 14
0.14 16 <1 79 9 .3
0.1 18 <1 90 5 .1
<0.1 16 <1 89 2.2
1.1 4 .1 <1.0 82 1800
0.6 7 .9 <1 84 480
<0.1 24 <1 72 24
<0.1 8.1 <1 93 9 .2
<0 .1 5 .9 <1 94 6 .5
1.1 8.1 <1.0 81 1800
0 .58 23 <1 81 80
0.43 58 <1 67 28
3 .1 51 <1 77 27
0 .32 24 <1 84 18
0 .36 26 <1 86 8.8
0 .29 17 <1 90 <0 .06
2.2 5.6 <1 .0 82 1600
1.1 26 <1 84 69
0 .37 61 <1 75 32
0 .94 30 <1 83 14
0.39 19 <1 72 9 .2
<0.1 27 <1 84 3 .1
2.5 <1 .0 <2 .0 83 1800
0 .67 3.5 <1 78 460
<0.1 25 <1 84 37
<0 .1 8.9 <1 84 9 .6
<0.1 14 <1 85 <0 .06
<0.1 9.4 <1 80 <0 .06
0.98 2.4 <1 .0 88 650
0.6 5 <1 88 670
<0.1 16 <1 82 51
0.6 J 10 <1 82 20
0.23J 9.9 <1 83 16
<0.1 11 <1 83 31
<0 .1 12 <1 79 <0.06
36 .2 9 .1 NA 99 1389.1
79.1 24.2 NA 97 2051 .1
45.3 12.4 NA 97 2530.1
48.3 6 .7 NA 98 3229 .0
31.8 6 .7 NA 97 1485.3
32 .6 3 .3 NA 97 1273.9
22.0 5 .0 NA 97 678.5
36 .5 9 .3 NA 97 1469.5
46.1 22 .3 NA 97 1839.1
30.4 3 .0 NA 84 1193.0
17.5 2 .0 NA 84 1598.4
32.1 4 .0 NA 86 905 .7
28.6 3.3 NA 85 497.5
25.0 3 .2 NA 84 1247.4
36 .1 13.6 NA 84 1461.6
20 .6 4 .0 NA 83 578.3
28.9 4 .1 NA 83 1264.0
33 .5 10.4 NA 83 1194.6
28.0 4 .6 NA 90 1101.2
29.1 6 .9 NA 98 705.3
PAN Sub -Plant Available Nitrogen (Subsurface)
9039324_ 1.XLS\Table 2
TOC PAN-Surf PAN -Sub
(mci /kci ) mci /k q mg/k g
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
870 NA NA
400 NA NA
8530 NA NA
400 NA NA
383 NA NA
296 NA NA
NA NA NA
2260 NA NA
209 NA NA
522 NA NA
3130 NA NA
331 NA NA
NA NA NA
6310 NA NA
296 NA NA
278 NA NA
70 NA NA
90 NA NA
NA NA NA
3860 NA NA
783 NA NA
679 NA NA
278 NA NA
574 NA NA
350 NA NA
NA 433 .1 451.2
NA 655.3 694.9
NA 780.5 803.1
NA 985 .0 1009.1
NA 458.6 474.5
NA 392.0 408.3
NA 213.0 224.0
NA 457.4 475.7
NA 583.2 606.3
NA 367.0 382.2
NA 485 .1 493.8
NA 282.1 298.1
NA 158.3 172.6
NA 382.4 394.9
NA 459.3 477.4
NA 181.7 192 .0
NA 389 .1 403.6
NA 375.5 392.2
NA 340.5 354.5
NA 224.4 238.9
Page 1 of 1
9039324_ 1 .XLS\Tab le 3
Field
Sam ple ID ID
TestWell 1 Field 12
TestWell 2 Field 28/32
Test Well 3 Field 49
TestWell4 Field 50
TestWell 9 Field 39
TestWell 11 Field 3
Test Well 13 Field42
TestWell 14 Field 33
Test Well 15 Field 16
Test Well 16 Field 35
TestWell 18 Field 27
TestWell20 Field 20
TestWell22 Field 16
TestWell 23 Plant
TestWell 24 Plant
TestWell 25 Fiela 44/45
TestWell 29 Field 29
TestWell 30 Field 602
Test Well 30.1 Field 602
TestWell 31 Field 602
TestWell 32 Field 602
TestWell 33 Field 602
TestWell 34 Field 602
Test Well 35 NA
Test Well 36 Field 602
TestWell 37 Field 602
Test Well 41 Field 3
TestWell42A Field 18/19
TestWell 43 Field 25
TestWell44 Field 26
TestWell45 Field 47
TestWell46 Field 61
TestWell47 Field 61
TestWell 48 Field 60
TestWell 49 Field 74
TestWell 50 Field 75
Test Well 51 (1) Field 12
Test Well 52 (1) Field 41
Test Well 53 (1) Field 62
TestWell 54 (1) Field 503
Test Well 641 Field 602
TestWell642 Field 602
Test Well 31A Field 602
Test Well 32A Field 602
TestWell 45A Field 47
TestWell 618 Field 61
Test Well B1C Field 61
1 SA NCAC 2L Standard
Notes:
TABLE 3
Groundwater Analytical Results -City Test Wells
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh , North Carolina
Nitrate Concentration (mQ/L)
March 2003 July 2003 November 2003 Marc h 2004 July 2004
ns 32 .0 13 .0 ns ns
ns 16.7 9.8 ns ns
<0.01 <0.1 0.1 <0 .1 ns
ns 0.6 ns ns ns
ns 168.6 ns ns ns
ns 9.5 9.9 ns ns
0.1 3.4 2.1 <0.1 4.7
ns 0.6 5.5 ns ns
ns 37.3 27 .8 ns ns
ns 8.7 3.1 ns ns
ns 179.5 130 .6 ns ns
1.9 2.2 8.3 2 .5 3.4
0.1 0.2 0.2 ns 0.7
ns ns 12.8 ns ns
ns ns 5.8 ns ns
ns ns 0.1 ns ns
ns 21.8 ns ns ns
ns 5.8 7.5 ns ns
ns 5.8 ns ns ns
0.1 <0.1 0.2 0.2 ns
ns 3.8 4 .8 ns ns
ns 5.8 6 .1 ns ns
ns 49.6 ns ns ns
ns 26 .6 ns ns ns
ns 4.3 3.2 ns ns
ns 2.4 0.4 ns ns
0.6 87.8 15 .5 82 .7 87 .1 / 84 .9
107.8 87.2 2.3 114 .7 120 .8/11 1.7
0.1 <0.1 3.5 ns ns
7.5 2.9 2.3 5.6 4.9
15.4 9.6 74 .8 9.6 17 .7 /24.7
15.2 1.8 1.6 1.7 4.0
30.9 31 .2 32.2 35 .3 36.353/34.743
50.6 43.0 51.9 56 .8 57 .3 / 55.7
0.5 0.4 0.7 1.4 4.2
5.6 37.7 7.5 31 .2 34.9/34.5
• ns ns ns ns 107.8/ 101.4
ns ns ns ns 79 .9175.4
ns ns ns ns 92.3/68.4
ns ns ns ns 67 .7173.8
ns 62.8 ns ns ns
ns 79.4 ns ns ns
ns 33.6 ns ns ns
ns 15.8 ns ns ns
ns 5.4 ns ns ns
ns 2.2 ns ns ns
ns 3.5 ns ns ns
10
1) Test Wens 51, 52 . 53 , 54 were previous ly identified as GP-2, GP-7 , GP-11. and GP -20 , re&pectlvely
mg/L · Milligrams per Liter
na • not analyzed .
ns · not sampled .
NA . Information Not Available
November 2004 March 2005 Julv 2005
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
1.9 <0 .10 3 .82
ns ns ns
ns ns ns
ns ns ns
ns ns ns
9 .3 1.74 3.70
<0.1 ns 0.14
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
77.3177.4 80 .08 75.17
113 .2/ 113.6 125 .10 129.45
ns ns ns
5.0 6.32 6 .03
34.4 / 24.1 9.17 56 .85
1.2 1.16 1.10
34.1 /35.9 31 .09 32 .52
54 .2 /53. 41.00 37.25
1.4 2.21 4 .06
28.7 /28.5 22 .00 27 .75
101.8/95.7 79 .99 77 .13
79.1 / 74.5 93.12 76.41
78.6/63.3 59.40 51 .86
56.1 /60.2 42.95 50.40
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
ns ns ns
Page 1 of 1
9039324_ 1.X LS\Table 4
TABLE4
Groundwater Analytical Results -CSA-SSA -Monitoring Wells
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Nitrate (mg/L)
Well ID Location November/
December June 2003 July 2003
2002
MW-100 Field 18 12 15 NA
MW-101 Field 31 160 120 NA
MW-101D Field 31 100 J 97 NA
MW-102 Field 37 86 72 NA
MW-103 Field 46 49 36 NA
MW-104 Field 70 24 35 NA
MW-105 Field 50 11 17 NA
MW-105D Field 50 28 J 23 NA
MW-106 Field 75 2.5 17 NA
MW-106 (Dup) Field 75 NA 18 NA
MW-107 Field 75 <0 .1 0.12 NA
MW-108 Field 75 4 .4 18 NA
MW-109 Field 500 54 52 NA
MW-110 Field 500 33 29 NA
MW-111 Field 500 28 17 NA
MW-111D Field 500 18 see packer test results below
MW-112 Field 201 15 11 NA
MW-113D Material Recov . 21 J 53 NA
MW-114 Field 63 NA 2.6 NA
MW-115 Field 62 NA 22 NA
MW-116 Field 62 NA 5.5 NA
MW-117 Belvin NA 0.26 NA
MW-118 St. James Sub. NA NA 4 .3
MW-119 St. James Sub. NA NA 0.65
MW-120 King NA <0.05 NA
MW-121 Field 600 NA 0.38 NA
MW-122 Field 70 NA 5 NA
MW-122D Field 70 NA 1.7 NA
MW-123D Field 12 NA 120 NA
MW-124D Field 26 NA 0.29 J NA
MW~124D (Du p ) Field 26 NA 0.18 J NA
MW-125D Field 600 NA 12 NA
MW-126D Field 61 NA 6.5 NA
MW-127 Field 71 NA <0.05 NA
GP-1 Field 19 22 18 NA
GP-2 Field 12 77 110 NA
GP-2 (Dup ) Field 12 74 NA NA
GP-3 Field6 44 6.6 NA
GP-5 Field 11 29 46 NA
GP-6 Field 6 54 35 NA
GP-7 Field 41 58 70 NA
GP-8 Field 63 96 93 NA
GP-9 Field 43 6.7 NA NA
GP-10 Field 48 0.8 0.55 NA
GP-11 Field 63 40 78 NA
GP-12 Field 62 0.12 <0.05 NA
GP-16 (1) Field 500 60 NA NA
GP-17 Field 500 <0.1_ 6.8 NA
GP-18 (1 ) Field 500 0.87 NA NA
GP-19 (1) Field 500 <0.1 NA NA
March/April
2004
15.1
164.1
NS
96.1
36.4
43.8
NS
NS
NS
NS
NS
27 .2
NS
31 .8
16.7
NS
7.8
NS
2.4
32.1
7.9
NS
NS
3.1
0.4
NS
NS
NS
70.0
NS
NS
NS
NS
NS
NS
84.2
NS
NS
55.5
NS
69.0
42.3
24.7
0.4
78.7
0.2
NS
NS
NS
NS
Page 1 of2
TABLE 4
Groundwater Analytical Results -CSA-SSA • Monitoring Wells
City of Raleigh , Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Nitrate (mg/L)
Well ID Location November/
December June 2003 July 2003
2002
GP-20 Field 503 180 62 NA
GP-21 Field 75 2.2 1.9 NA
GP-22 Field 74 130 6.9 7.3
MW-1 (MAT REC) Material NA NA 2.2
MW-3 Recovery NA 53 NA
MW-5 Property NA 0.1 NA
TW-1 Field 12 NS NS NS
TW-11 Field 3 NS NS NS
TW-18 Field 27 NS NS NS
TW-44 Field 26 NA 2.3 NA
TW-48 Field 60 NA 47 NA
TW-30 Field 601-602 NS NS NS
TW-30.1 Field 601-602 NS NS NS
TW-31A Field 601-602 NS NS NS
TW-32 Field 601-602 NS NS NS
TW-32A Field 601-602 NS NS NS
TW-33 Field 601-602 NS NS NS
TW-34 Field 601-602 NS NS NS
TW-35 Field 601-602 NS NS NS
TW-36 Field 601-602 NS NS NS
TW-37 NS NS NS
PZ-1 Neuse River 0.43 NA NA
PZ-2 Neuse River <0.1 NA NA
PZ-3 Neuse River 22 NA NA
PZ-4 Neuse River 0.12 NA NA
Packer Testing Results
MW-111 D-60-90FT Field 500 NS 19 NS
MW-111 D-90-120FT Field 500 NS 20 NS
PW-39: HEATER-1-40-70Fl St. James Sub. NS 11 NS
PW-39: HEATER-1-70-100F St. James Sub. NS 6 .7 NS
PW-8: (53-72') B. Blowe Res . 20 NS NS
PW-8 : (105-135) B. Blowe Res . 20 NS NS
PW-8 : {230-290 ) B. Blowe Res . 20 NS NS
15A NCAC 2L Standard 10
Notes:
1) Well decommissioned .
March/April
2004
NS
NS
NS
NS
NS
NS
38.5
4.9
181 .8
NS
NS
11.0
5.7
43 .9
2.6
16.4
5.4
64 .8
37.4
3.5
2 .3
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
MW -monitoring well ; TW -test well; GP -geoprobe point: PZ -piezometer ; PW -private well.
J -Estimated value
Dup -Field duplicate sample
NA -Not anal yzed I NS -Not sam pled
9039324_ 1.XLS I Tab le 4 Page 2 of 2
Location
SW-1
SW-2
SW-3
SW-4
SW-5
SW-6
SW-7
SW-8
SW-9
SW-10
SW-11
SW-12
SW-13
SW-14
SW-15
SW-16
SW-17
SW-18
SW-19
SW-20
SW-20 dup
SW-21
SW-22
SW-23
SW-24
SW-25
SW-26
SW-27
SW-28
Notes:
TABLE 5
Surface Water Analytical Results
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Nitrate (mg/L)
November 2002 June 2003
52 49
0 .39 13
52 50
54 47
0 .69 2
54 46
77 83
1.2 1.6
34 36
48 19
19 47
52 41
0.46 1.3
0 .21 0.16
20 20
1.7 6.2
5 .5 0.97
3 1.7
16 21
3.8 3.3
3.5 NS
0.15 0.18
0 .25 1.5
0.72 NS
0.53 0.52
NS 4.6
NS 9.8
NS 14
NS 46
mg/L -Milligrams per Liter
NS -Not Sampled
Dup. -Duplicate sample
9039324_ 1.XLS\Table 5
September 2005
43
NS
dry
78
NS
70
98
NS
NS
NS
33
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
dry
dry
NS
Page 1 of 1
Parcel Size of
Parcel Number (acres}
119 259 .22
120 19 .50
121 3.38
122 1.08
123 1.07
125 15.65
126 8.10
128 211.53
129 13 .64
130 210 .99
131 44.84
132 8.16
133 16.91
134 20
135 0 .03
136 44 .34
137 1.60
138 0.56
139 79 .19
140 52 .61
141 1.71
142 420.23
143 1.0
144 3.44
145 1.0
146 NA
147 1.0
148 1.01
149 NA
150 8 .28
151 1.03
152 30 .75
153 1.0
154 NA
155 2 .39
Note:
TABLE 6
Description of Proposed Variance Areas
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Actual Land Use
Vacant, forested lot
A qricultural land
Residence and ag ricultural
Forested land with residence
Agricultural land
Forested land with a power substation
Forested land
Ag ricultural land with small portions of forested land
Forested land with residence
Majority forested and agricultural land and construction and
debris landfill
Forested, agricultural and residential land
Forested vacant land
Forested land
Residence on aqricultural and forested land
Forested land
A gricultural land, small amounts of forested land
Cemetery
Residence
Forested land
Ma jority forested and small portion of aqricultural land
Residence
Agricultural, forested and a pp roximatel y 12 buildin gs
Residence
Vacant, wooded lot
Vacant
NA
Residence
Residence
NA
Residence
Residence
Agricultural-farm , one home and several outbuildin gs
Vacant
NA
Residence on partiall y forested land
NA: Information not available on Wake County's Geographic Information System.
9037923.2
Residence?
No
No
Yes
Yes
No
No
Yes
No
Yes
Possibly
Yes
No
No
Yes
No
Possibl y
No
Yes
No
No
Yes
No
Yes
No
No
NA
Yes
Yes
NA
Yes
Yes
Yes
No
NA
Yes
9039112_1 .XLS
TABLE 7
Projected Debitted Total Nitrogen Allocation
Neuse River Wastewater Treatment Plant
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
TN Debit Allocation -Year Allocation (pounds) Debit (pounds) (pounds)
2006 676,496 123,000 553,496
2007 676,496 123,000 553,496
2008 676,496 120,000 556,496
2009 676,496 117,000 559,496
2010 676,496 114,000 562,496
2011 676,496 111,000 565,496
2012 676,496 108,000 568,496
2013 676,496 105,000 571,496
2014 676,496 102,000 574,496
2015 676,496 99,000 577,496
2016 676,496 96,000 580,496
2017 676,496 93,000 583,496
2018 676,496 90,000 586,496
2019 676,496 87,000 589,496
2020 676,496 84,000 592,496
2021 676,496 81,000 595,496
2022 676,496 78,000 598,496
2023 676,496 75,000 601,496
2024 676,496 72,000 604,496
2025 676,496 69,000 607,496
2026 676,496 66,000 610,496
2027 676,496 63,000 613,496
2028 676,496 60,000 616,496
2029 676,496 57,000 619,496
2030 676,496 54,000 622,496
2031 676,496 51,000 625,496
2032 676,496 48,000 628,496
2033 676,496 45,000 631,496
2034 676,496 42,000 634,496
2035 676,496 39,000 637,496
2036 676,496 36,000 640,496
2037 676,496 33,000 643,496
2038 676,496 30,000 646,496
2039 676,496 27,000 649,496
2040 676,496 24,000 652,496
2041 676,496 21,000 655,496
2042 676,496 18,000 658,496
2043 676,496 15,000 661,496
2044 676,496 12,000 664,496
2045 676,496 9,000 667,496
2046 676,496 6,000 670,496
2047 676,496 3,000 673,496
2048 676,496 0 676,496
9034 647 _ 1.XLS
TABLE 8
Operations Budget
Neuse River Wastewater Treatment Plant
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Fiscal Year Operations Budget Capital Budget
2005-2006 $14,034,696 $43,590 ,000
2006-2007 NA $58,175,000
2007-2008 NA $31,625,000
2008-2009 NA $19,800,000
2009-2010 NA $26,450,000
NA: Information not yet available.
E X HIBIT 1
RESOLUTION 2005 -734
A RESOLUTION FOR A VARIANCE REQUEST TO ALLOW THE CITY OF
RALEIGH TO IMPLEMENT ITS ALTERNATIVE CORRECTION PLAN.
WHEREAS, the City of Raleigh has been investigating groundwater
contamination resulting from the inadvertent over-application ofbiosolids on agricultural
fields at the City's Neuse River Wastewater Treatment Plant; and
WHEREAS, the City of Raleigh desires to implement a corrective action plan to
remediate nitrate-contaminated groundwater that will provide ample protection for
human health and the environment; and
WHEREAS, the implementation of a corrective action plan in full compliance
with the rules of the North Carolina Environmental Management Commission (EMC)
would produce serious financial hardship to the City without equal or greater benefit to
public health or the environment; and
WHEREAS, the City of Raleigh proposes to implement an alternative corrective
action plan utilizing hydraulic containment in select areas and monitored natural
attenuation for the remainder of the site that will be fully protective of public health and
the environment; and
WHEREAS, to receive approval by the EMC for its proposed corrective action
plan the City must obtain a variance from the EMC's rules; and
WHEREAS, as a condition of supporting the City's variance request, the North
Carolina Division of Water Quality will require the City to debit against the nitrogen
discharge allocation in its wastewater permit the amount of additional annual nitrogen
loading to the Neuse River via groundwater resulting from the exceedance of
groundwater standards at the Neuse River WWTP.
NOW, TEHREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE
CITY OF RALEIGH THAT
Section 1. The City Council of the City of Raleigh hereby requests that the
Environmental Management Commission approve the City of Raleigh's variance request
in accordance with North Carolina Administrative Code Title 15A, Subchapter 2L,
Section .0113 to allow the City to implement its alternative corrective action plan, subject
to the nitrogen debit condition described above.
Adopted: November 15, 2005
Effective: November 15, 2005
Distribution: Public Utilities Director
9023996.1
CITY O F RALEIGH
Neuse River W aste W ater Treatment Plant
Raleigh, North Carolina
Hum a n Hea lth Risk A ss essment
Prepared by:
INTERNATIONAL
ENSR Consulting and Engineering (NC}, Inc.
7041 Old Wake Forest Road, Suite 103
Raleigh, North Carolina 27616
November 2005
EXHIBIT2
EN:R.
t41i¥h&liirhZtl
CONTENTS
1.0 INTRODUCTION .............................................................................................................................. 1-1
1.1 Human Health Risk Assessment ........................................................................................... 1-1
1.1.1 Data Evaluation and Hazard Assessment .................................................................. 1-2
1 .1. 2 Toxicity Assessment. ................................................................................................... 1-2
1.1. 3 Exposure Assessment ................................................................................................ 1-3
1. 1. 3 . 1 Receptors and Exposure Routes ................................................................ 1-3
1. 1. 3.2 Potential Exposure Doses ........................................................................... 1-3
1.1 . 3. 3 Exposure Point Concentrations .................................................................. 1-6
1.1.4 Risk Characterization .................................................................................................. 1-6
1.1.5 Uncertainties ................................................................................................................ 1-7
1.1.6 Summary ..................................................................................................................... 1-8
1.1. 7 References .................................................................................................................. 1-8
S:\PUBSIPROJECnR\R aleigh_ City 01\CAP
Wori<\Revised
CAP _Nov05\Risk_Ass essmentl 11 1805-
November. 2005
E~.
ttR¥ZZt&&Ztl
LIST OF TABLES
Table 1. Chemical Specific Parameters
Table 2. Summary of Potential Exposure Assumptions -Child/Teenager, Wading in Surface Water
Table 3. Summary of Potential Exposure Assumptions -Resident
Table 4. Development of Exposure Point Concentrations for Nitrate in Groundwater
Table 5. Development of Exposure Point Concentrations for Nitrate in Surface Water
Table 6 . Total Potential Hazard Index
S:IPUBSIPROJECnR\Raleigh_ City of\CAP
Wori<\Revised
CAP _NoV05\Risk_Assessmenll111805-
ii November. 2005
'
EN.1l.
tNlM?id@,XttM
1.0 INTRODUCTION
Executive Summa ry
A baseline human health risk assessment (HHRA) was conducted for nitrate in surface water and
groundwater at the City of Raleigh, North Carolina's Neuse River Wastewater Treatment Plant
(NRWWTP) site. Potential receptors were a child/teenage wader at Beddingfield Creek and the other
Neuse River tributaries and a hypothetical future resident using site groundwater for potable and/or
non-potable uses. Exposure assumptions were selected in accordance with USEPA guidance
(USEPA, 1989; 1991 ; 1997 ; 2004b). Exposure point concentrations for surface water were selected as
the maximum detected concentration from the last three sampling events and the average
concentration (temporal and area). Noncarcinogenic Hazard Indices (His) were calculated for the (
ingestion and dermal routes of exposure. There were no unacceptable risks for exposure to surface
water or for exposure to groundwater used for a non-potable purpose (swimming pool), based on
comparison of the His to the USEPA limit of 1.0. However, the His for potable use of groundwater
exceeded 1.0, indicating a potentially unacceptable risk for site groundwater used as drinking water.
1.1 Human Health Risk Assessment
ENSR conducted this baseline HHRA to evaluate potential risks that may be posed by the
concentrations of nitrate in groundwater and surface water related to biosolids application at farm fields
located at the Neuse River Wastewater Treatment Plant (NRWWTP) in Raleigh , North Carolina. The
application areas are bounded to the north and east by the Neuse River and to the south by
Beddingfield Creek. The area of interest and sampling locations are presented in Figure 1-2 of the
revised Corrective Action Plan (CAP) (ENSR, 2005). Groundwater quality studies conducted as part of
the Comprehensive Site Assessment (ENSR, 2002) and the Supplemental Site Assessment (ENSR,
2003) indicated that, in some groundwater and surface water samples, concentrations exceeded the
USEPA Maximum Contaminant Limit (MCL) of 10 milligrams per liter (mg/L (USEPA, 2002; 2004a).
The private water supply wells were later closed and the properties connected to the municipal water
supply.
The HHRA was conducted consistent with US EPA guidance, including, but not limited to, the following:
• Risk Assessment Guidance for Superfund (RAGS): Volume 1 -Human Health Evaluation
Manual (Parts A, 8, C) (USEPA, 1989; 1991a);
• USEPA Region 4 Human Health Risk Assessment Bulletins -Supplement to RAGS
(USEPA, 2000b);
• Human Health Evaluation Manual Supplemental Guidance; Standard Default Exposure
Factors. OSWER Directive 9285 .6-03 (USEPA, 1991b); and
S:IPUBSIPROJECnRIRaleigh_City of\CAP Work\Revised CAP _Nov05\Risk_Assessment\111805-Risk_Assessment.doc November. 2005
1-1
..
'
EN:R.
H1l¥WdllPXZt◄
nitrate is nearly 100%. Thus, it is not necessary to adjust the oral RfD to account for an absorbed dose.
The dose-response value for nitrate is presented in Table 1.
1.1.3 Exposure Assessment
The purpose of the exposure assessment is to predict the magnitude and frequency of potential
human exposure to the site COPCs. Potentially complete exposure pathways are based on an
evaluation of the physical conditions at the sit, the distribution of contaminants, and likely human
activity patterns.
1.1.3.1 Receptors and Exposure Routes
Nitrate was detected in Beddingfield Creek and in other tributaries to the Neuse River. The NRWWTP
site is partially fenced, which may reduce unauthorized access and use of the site . However, it is
possible that a trespasser or nearby resident might wade in one of the tributaries to the Neuse River,
located within the site or in Beddingfield Creek. For the purpose of the risk assessment, the receptor
was identified as a child or teenager (aged 7 to 16 years) wading in the surface water. For
noncarcinogenic effects (the only health effect evaluated for nitrate) a child is a more conservative
receptor than an adult, because estimated exposure doses are normalized over the lower body weight
for a child .
Potential exposure to groundwater is not complete at the site. The City of Raleigh has provided
municipal water to all landowners whose groundwater wells were impacted by, or potentially impacted
by, the nitrates contained in the biosolids applied at the site (ENSR, 2005; ENSR, 2003). To provide a
conservative estimate of potential risks , potential future use of site groundwater or downgradient
groundwater for potable or non-potable uses was evaluated. A hypothetical future resident potentially
exposed to nitrate in groundwater used as drinking water was considered. In addition, a hypothetical
future resident using groundwater for a swimming pool was also evaluate~. The receptor evaluated is
a young child (aged 0-6 years). As stated for the child/teenage wader, a child is the most sensitive
receptor for noncarcinogenic effects.
The exposure assumptions used in this HHRA are derived mainly from USEPA guidance documents,
including USEPA Region 4 bulletins (USEPA, 2000), Exposure Factors Handbook (USEPA, 1997) and
Human Health Exposure Manual (USEPA , 1991b). These assumptions are presented in Table 2.
1.1.3.2 Potential Exposure Doses
To estimate the potential risk to human health that may be posed by the presence of COPCs in
environmental media in the study area, it is first necessary to estimate the potential exposure dose of
each COPC for each receptor. The exposure dose is estimated for each chemical via each exposure
route/pathway by which the receptor is assumed to be exposed. Exposure dose equations combine
S:IPUBSIPROJECnR\Raleigh_City of\CAP Work\Revised CAP _Nov05\Risk_Assessment\ 111805-Risk_Assessment.doc November, 2005
1-3
EN:R.
t4tiifX:&@,&?tt◄
the estimates of chemical concentration in the environmental medium of interest with assumptions
regarding the type and magnitude of each receptor's potential exposure to provide a numerical
estimate of the exposure dose. The exposure dose is defined as the amount of COPC taken into the
receptor and is expressed in units of milligrams of COPC per kilogram of body weight per day (mg/kg-
day). The exposure doses are combined with the toxicity values to estimate potential risks and
hazards for each receptor. Both potential ingestion and dermal exposures to nitrate in groundwater
and surface water were considered. The exposure dose equations are as follows:
Average Daily Dose (Lifetime and Chronic) Following Ingestion of Water (mg/kg-day):
where:
ADD =
cw =
IR =
EF =
ED =
AAF =
BW =
AT =
ADD = CW x JR x EF x EDxAAF
BWxAT
Average Daily Dose (mg/kg-day)
Water concentration (mg/L)
Water ingestion rate (Uday)
Exposure frequency (days/year)
Exposure duration (year)
Absorption Adjustment Factor (unitless)
Body weight (kg)
Averaging time (days)
Average Daily Dose (lifetime and Chronic) Following Dermal Contact with Water (mg/kg-day):
where:
ADD
cw
SA
Kp
AAF
ET
EF
ED
=
=
=
=
+
=
=
=
ADD CW xSAxKp xAAFxETx EFxEDxCF
BWxAT
Average daily dose (mg/kg-day)
Water concentration (mg/L)
Exposed skin surface area (cm2 )
Dermal permeability constant (cm/hr)
Absorption Adjustment Factor (unitless)
Exposure time (hours/day)
Exposure frequency (day/year)
Exposure duration (year)
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November, 2005
EN:R.
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CF = Unit conversion factor (U103 cm 3)
BW = Body weight (kg)
Two chemical-specific factors, the permeability constant (Kp) and absorption adjustment factor (AAF)
are used in the exposure dose equations.
The estimation of exposure doses resulting from incidental dermal contact with groundwater and
surface water requires the use of a dermal permeability constant (Kp) in units of centimeters per hour
(cm/hr). This method assumes that the behavior of compounds dissolved in water is described by
Fick's Law. In Fick's Law, the steady-state flux of the solute across the skin (mg/cm 2/hr) equals the
permeability constant (kp, cm/hr) multiplied by the concentration difference of the solute across the
membrane (mg/cm\ This approach is discussed by USEPA (USEPA, 1989; 2004b).
The estimate of toxicity of a compound, termed the toxicity value, can be derived from human
epidemiological data, but it is most often derived from experiments with laboratory animals . The
toxicity value can be calculated based on the administered dose of the compound (similar to the
human exposure dose) or, when data are available, based on the absorbed dose, or internal dose, of
the compound.
In animals, as in humans, the administered dose of a compound is not necessarily completely
absorbed . Moreover, differences in absorption exist between laboratory animals and humans, as well
as between different media and routes of exposure. Therefore, it is not always appropriate to directly
apply a toxicity value to the human exposure dose. In many cases, a correction factor in the
calculation of risk is needed to account for differences between absorption in the toxicity study and
absorption likely to occur upon human exposure to a compound in an environmental medium . Without
such a correction, the estimate of human health risk could be over-or under-estimated.
The AAF is used to adjust the human exposure dose so that it is expressed in the same terms as the
doses used to generate the dose-response curve in the dose-response study. The AAF is the ratio
between the estimated human absorption for the specific medium and route of exposure, and the
known or estimated absorption for the laboratory study from which the dose-response value was
derived (USEPA, 1989, 2004b). The route of exposure for the toxicity study (oral ingestion of water) is
the same as the oral route evaluated in the HHRA (oral ingestion of surface water, potable water, or
swimming pool water). Therefore an oral AAF of 1 is used . It is assumed that dermal absorption is
similar to oral absorption; therefore, a default value of 1 was used for dermal absorption .
The Kp and AAFs for nitrate are presented in Table 1
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1.1.3.3 Exposure Point Concentrations
Exposure points are located where potential receptors may contact COPCs at or from the Site. The
concentration of COPCs in the environmental medium that receptors may contact, referred to as
exposure point concentrations (EPCs), must be estimated in order to determine the magnitude of
potential exposure.
The November 2004, March 2005, and July 2005 groundwater data, representing three recent
sampling events, were used to develop exposure point concentrations (EPCs) for groundwater. In
order to estimate the EPCs, results for duplicate samples were averaged . The maximum detected
value over the three sampling events was then selected as the EPC representing "worst case"
conditions. In addition, a temporal average for each well over the three sampling events was
calculated; the temporal averages by well were then averaged to estimate an area average . The
temporal/area average is representative of chronic exposure to water from a future private supply well,
because concentrations may vary seasonally and because an actively pumping supply well would
draw from a larger area than an individual monitoring well. Nitrate was detected in all of the wells used
for developing the average EPC; therefore, data for "non-impacted" wells were not used for calculating
averages . Selection of the EPCs for groundwater is presented in Table 3.
For surface water, the exposure point concentrations are the maximum detected concentrations in
Beddingfield Creek and in the other tributaries to the Neuse River. All of the surface water data
(November 2002 through September 2005) were used in order to provide a conservative estimate of
potential exposures. Selection of surface water EPCs is presented in Table 4.
1.1.4 Risk Characterization
The potential risk to human health associated with potential exposure to COPC in environmental
media at the site is evaluated in this step of the risk assessment process. Risk characterization is the
process in which the quantitative estimates of human exposure derived in the exposure assessment
are integrated with the dose-response information. The result is a quantitative estimate of the
likelihood that humans will experience any adverse health effects given the exposure assumptions
made.
The potential for exposure to a chemical to result in adverse noncarcinogenic health effects is
estimated for each receptor by comparing the GADD for each COPC with the RID for that COPC. The
resulting ratio, which is unitless, is known as the Hazard Quotient (HQ) for that chemical. The HQ is
calculated using the following equation :
The potential for exposure to a chemical to result in adverse noncarcinogenic health effects is
estimated for each receptor by comparing the ADD for each COPC with the RID for that COPC . The
S:IPUBSIPROJECTIR\Raleigh_ City ol\CAP Work\Revised CAP_ NovOS\Ri sk_Assessmenl\111805-Risk_Ass es sment.doc November. 2005
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•
'
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thttir&ta1,xzt:1
resulting ratio, which is unitless, is known as the Hazard Quotient (HQ) for that chemical. The HQ is
calculated using the following equation:
HQ= ADD(mg/ kg-day)
RfD(mg I kg-day)
The target HQ is defined as an HQ of less than or equal to one (USEPA, 1989). When the HQ is less
than or equal to 1, the RfD has not been exceeded, and no adverse noncarcinogenic effects are
expected. If the HQ is greater than 1, there may be a potential for adverse noncarcinogenic health
effects to occur; however, the magnitude of the HQ cannot be directly equated to a probability or effect
level. The total HI is calculated for each exposure pathway by summing the HQs for each individual
chemical. In this HHRA, in which there is only one COPC, the HQ is equal to the HI.
A summary of the His for the receptors is presented in this section and compared to the USEPA's
target HI of 1. The His are presented in Table 5.
• Child/Teenage Wader -the HI for the child/teenage wader in Beddingfield Creek is 0. 0004 and
the HI for the child/teenage wader in the other tributaries to the Neuse River is 0.002. Neither
of these His exceed the HI limit of 1.0. Therefore, there are no unacceptable risks for this
receptor.
• Hypothetical Future Resident, Potable Water Use -The HI for the hypothetical future resident
using the maximum detected concentration as the EPC is 5.2 and the HI using the average
concentration as the EPC is 1.6. Because the His exceed 1, the potential risk for potable use
of groundwater by a hypothetical future resident is unacceptable.
• Hypothetical Future Resident, Non-potable Water Use (Swimming Pool) -The HI for the
hypothetical future resident is 0.02 using the maximum detected concentration as the EPC and
0.007 using the average concentration as the EPC. Therefore, there are no unacceptable risks
for the hypothetical future resident by the non-potable water pathway.
1.1.5 Uncertainties
The His presented in this HHRA are estimates of potential risk that are useful in regulatory decision
making. It is improper to consider these values as representing actual risk to exposed individuals
because there is an unquantifiable uncertainty associated with them. Numerous assumptions must be
made in each step of the risk characterization process. Some of the assumptions have a firm scientific
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Etal.
thtiikN&fill'6'tU◄
ENSR, 2005. Revised Corrective Action Plan, City of Raleigh, Neuse River Wastewater Treatment
Plant, Raleigh, North Carolina.
ENSR, 2003. Supplemental Site Assessment, City of Raleigh, Neuse River Wastewater Treatment
Plant, Raleigh, North Carolina.
ENSR, 2002. Comprehensive Site Assessment, City of Raleigh, Neuse River Wastewater Treatment
Plant, Raleigh, North Carolina.
USEPA. 1989. Risk Assessment Guidance for Superfund: Volume I. Human Health Evaluation
Manual (Part A). Interim Final. Office of Emergency and Remedial Response. U.S. Environmental
Protection Agency, Washington, D.C. EPA 540/1-89/002.
USEPA. 1991a. Risk Assessment Guidance for Superfund: Volume I. Human Health Evaluation
Manual (Part B, Development of Risk-Based Preliminary Remediation Goals). Interim. Office of
Emergency and Remedial Response. U.S . Environmental Protection Agency, Washington, D.C.
9285 .7-01B, December.
USEPA. 1991 b. Human Health Exposure Manual, Supplemental Guidance; Standard Default
Exposure Factors. OSWER Directive No . 9285.6-03. U.S. Environmental Protection Agency,
Washington, D.C.
USEPA. 1997. Exposure Factors Handbook, Volumes I, II and Ill. EPA/600/P-95/002F. Office of
Research and Development. U.S . Environmental Protection Agency, Washington, D.C.
USEPA. 2000. Supplemental Guidance to RAGS: Region 4 Bulletins, Human Health Risk
Assessment. United States Environmental Protection Agency, Region 4. Waste Management
Division . Atlanta, GA. Update 0'5/01/2000. [URL:
http://www.e pa.g ov/region4/waste/oftecser/healthbul .htmj
USEPA. 2002. National Recommended Water Quality Criteria. EPA-822-R-02-047 . November 2002.
USEPA. 2004a. 2004 Edition of the Drinking Water Standards and Health Advisories. U.S.
Environmental Protection Agency. Office of Water. EPA 822-R-04-005. Winter 2004.
USEPA. 2004b. Risk Assessment Guidance For Superfund. Volume I: Human Health Evaluation
Manual (Part E, Supplemental Guidance for Dermal Risk Assessment) Final. EPA/540/R/99/005.
July 2004.
USEPA. 2005. Integrated Risk Information System . URL: htt p://www.epa.gov/iris/index.html.
Accessed November 16, 2005.
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TAB LE 1
CHEMICAL-SPECIFIC PARAMETERS
NEUSE RIVER WASTEWATER TREATMENT PLANT, RALEIGH , NC
HUMAN HEAL TH RISK ASSESSMENT
CHEMICAL-SPECIFIC PARAMETERS FOR NITRATE Value
Reference Dose 1.6.E+00
Absorption Adjustment Factor (Oral and Dermal) 1.E+00
Permeability Coefficient 1.E-03
Notes:
Units REFERENCE/NOTES
mg/kg-day USEPA. 2005. Integrated Risk Information Syst,
http ://www.epa.gov/iris/subst/index.html
unitless Assumed value. ASTDR (2005) indicates that or
absorption of nitrate is nearly 100%.
cm/hour USEPA. 2005. Risk Assessment Guidance for ~
Volume I: Human Health Evaluation Manual. Pa
Supplemental Guidance for Dermal Risk Assess
Default value for inorganics . Exhibit 3-1.
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I
11/18/2005
TABLE2
SUMMARY OF POTENTIAL EXPOSURE ASSUMPTIONS -CHILD/TEENAGER, WADING IN SURFACE WATER
H_UMAN HEAL TH RISK ASSESSMENT
NEUSE RIVER WASTEWATER TREATMENT PLANT
RALEIGH, NORTH CAROLINA
Child/Teenager
Wading in Surface Water
Parameter (7 to 16 yrs)
Parameters Used in the Surface Water Pathway -Wading
Exposure Frequency (EF) (days/year) 45
Exposure Duration (ED) (yr) 10
Surface Water Ingestion Rate (IR) (I/hour) 0.01
Skin Contacting Medium (SA) (cm'2) 1975
Body Weight (BW) (kg) 45
Exposure Time (El) (hr/day) 1
Notes:
(a) -1 day per week for 39 weeks (9 warmest months) of the year, and 2 days per month for the 3 coldest months of the year.
This is also the USEPA Region 4 default for swimming.
(b) -Wader is assumed to range in age from 7 to 16 (USEPA, 2000). Therefore, total exposure duration is 10 years.
(c) -USE PA, 2000. US EPA Region 4 Human Health Risk Assessment Guidance. Default value .
(d) -US EPA, 1997. Exposure Factors Handbook. Average surface area of feet and one-quarter legs of males and females aged 7 to 16,
listed in EFH Tables 6-6 to 6-8.
(e) -US EPA, 2000. US EPA Region 4 Human Health Risk Assessment Guidance. Default value.
(I) -Best professional judgment.
S:\PUBS\PROJECnR\Raleigh_City of\CAP Work\Revised CAP _Nov05\Risk_Assessment\TABLES.xls
(a)
(b)
(c)
(d)
(e)
(I)
November, 2005
TABLE 3
SUMMARY OF POTENTIAL EXPOSURE ASSUMPTIONS -RESIDENT
H_UMAN HEALTH RISK ASSESSMENT
NEUSE RIVER WASTEWATER TREATMENT PLANT
RALEIGH , NORTH CAROLINA
Parameter
Parameters Used in the Groundwater as Swimming Pool Water Pathway
Exposure Frequency (EF) (days/year)
Exposure Duration (ED) (yr)
Water Ingestion Rate (IR) (I/day)
Exposure Time Swimming (hour/event)
Skin Contacting Medium (cm2)
Body Weight (BW) (kg)
Parameters Used in the Groundwater as Drinking Water Pathway
Exposure Frequency (EF) (days/year)
Exposure Duration (ED) (yr)
Water Ingestion Rate (IR) (I/day)
Exposure Time Bathing (hour/event)
Skin Contacting Med ium (cm2)
Body Weight (BW) (kg)
Notes:
Resident
Child (0 to 6 yrs)
90
6
0 .01
1
6600
15
350
6
1
1
6600
15
{a) -2 day per week for 39 weeks (9 warmest months) of the year, and 4 days per month for the 3 coldest months of the year.
This is also the USEPA Region 4 default value for a swimming pool.
(b) -US EPA, 1997. Exposure Factors Handbook. Recommended average for lime residing in a household, Table 1-2. (9 years total,
assuming 7 years as an adult and 2 as a child -assumes that the 2 years as a child can occur anywhere between the ages of
O lo 6 . Therefore, exposure factors for a O to 6 year old child are employed).
(c) -USEPA, 2000. USEPA Region 4 Human Health Risk Assessment Guidance. Default value .
(d) -Best professional judgment.
(e) -USEPA, 2004 . Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual. Part E.
Supplemental Guidance for Dermal Risk Assessment. Default Value . Bathing exposure lime is Reasonable
Maximum Exposure value.
(f) -USEPA, 1991 . Standard Default Exposure Factors.
S:IPUBSIPROJECTIR\Raleigh_City ot\CAP Work\Revised CAP _Nov05\Risk_Assessment\TABLES.xls
(a)
(b)
(C)
(d)
(e)
(f)
(f)
(b)
(f)
(e)
(e)
{f)
November, 2005
TABLE 4
Development of Exposure Point Concentrations for Nitrate in Groundwater
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Nitrate Concentration (mg/L
Average for
Each Well
Over Time
Sample ID Field ID November 2004 March 2005 July 2005 (2004-2005)
Test Well 13 Field 42 1.9 0.05 U* 3.82 1.9
Test Well 20 Field 20 9.3 1.74 3.70 4.9
Test Well 22 Field 16 0.05 U* NS 0.14 0.10
Test Well 41 Field 3 77.4 D* 80.08 75.17 77.5
TestWell42A Field 18/19 113.4 D* 125.10 129.45 122.7
Test Well 44 Field 26 5.0 6.32 6.03 5.8
Test Well 45 Field 47 29.3 D* 9.17 56.85 31.8
Test Well 46 Field 61 1.2 1.16 1.10 1.2
TestWell 47 Field 61 35.0 D* 31.09 32.52 32.9
TestWell48 Field 60 53.6 D* 41.00 37.25 44.0
TestWell49 Field 74 1.4 2.21 4.06 2.6
TestWell 50 Field 75 28.6 D* 22.00 27.75 26.1
Test Well 51 (1) Field 12 98.8 D* 79.99 77.13 85.3
Test Well 52 (1 ) Field 41 76.8 D* 93.12 76.41 82.1
Test Well 53 (1) Field 62 71.0 D* 59.40 51.86 60.7
Test Well 54 (1) Field 503 58.2 D* 42.95 50.40 50.5
Maximum Detect, by Month 113.4 125.1 129.45
Maximum Detect, November 2004-July 2005 129.45 39.37
Notes:
1) Test Wells 51, 52, 53, 54 were previously identified as GP-2, GP-7, GP-11, and GP-20, respectively.
mg/L -Milligrams per Liter
NS -Not Sampled
U* -Reported as not detected. One-half the sample quantitation limit is shown.
D* -Concentration shown is the average of duplicates.
TABLES.xls\4
Average for All
Sampled Wells
Page 1 of 1
TABLE 5
Development of Exposure Point Concentrations for Nitrate in Surface Water
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Nitrate (m ~/L)
Location November 2002 June 2003 May/June 2004 September 2005
Bettingfield Creek
SW-19 16 21 NS NS
SW-20 3 .8 3 .3 NS NS
SW-20 du o 3 .5 NS NS NS
SW-20, du plicate averag e 3.65 3.3 NS NS
SW-21 0.15 0 .18 NS NS
SW-22 0 .25 1.5 NS NS
SW-24 0 .53 0 .52 NS NS
Maximum Concentration, All Bettin C1 field Creek Samplin g Stations
Other Tributaries, Neuse River
SW-1 52 49 NS 43
SW-2 0.39 13 NS NS
SW-3 52 50 NS dry
SW-4 54 47 NS 78
SW-5 0 .69 2 NS NS
SW-6 54 46 NS 70
SW-7 77 83 NS 98
SW-8 1.2 1.6 NS NS
SW-9 34 36 NS NS
SW-10 48 19 NS NS
SW-11 19 47 NS 33
SW-12 52 41 NS NS
SW-13 0.46 1.3 NS NS
SW-14 0.21 0.16 NS NS
SW-15 20 20 NS NS
SW-16 1.7 6 .2 NS NS
SW-17 5 .5 0.97 NS NS
SW-18 3 1.7 NS NS
SW-23 0 .72 NS NS NS
SW-25 NS 4.6 NS NS
SW-26 NS 9.8 9 .2 # dry
SW-27 NS 14 22.9 # dry
SW-28 NS 46 NS NS
Maximum, Other Tributaries Sampling Stations
Notes:
mg/L -Milligrams per Liter
NS -Not Sampled
Dup. -Duplicate sample
Maximum
Concentration
21
--
--
3.65
0 .18
1.5
0.53
21
52
13
52
78
2
70
98
1.6
36
48
47
52
1.3
0.21
20
6 .2
5 .5
3
0.7
4.6
9.8
22 .9
46
98
# -Samples were collected May 9, 14, 18, 20, 24, and 26 and June 7 and 9, 2004. The concentrations shown are
averages of the concentrations reported for these multiple sampling events.
TABLES.xls\5 Page 1 of 1
TABLE6
TOTAL POTENTIAL HAZARD INDEX
NEUSE RIVER WASTEWATER TREATMENT PLANT
RALEIGH, NORTH CAROLINA
Chemical
Nitrate
Notes:
Ing/Denn -Ingestion/Dermal Contact.
EPC -Exposure Point Concentration
Surface Water -ChlldfTeenager
Other Neuse River Potable Water -
Bettingfleld Creek Tributaries Maximum EPC
Ing/Denn. lna/Oerm. lnnrol!!nn.
0.0004 0.002 5 ,2
S:\PUBS\PROJECT\R\Raleigh_City of\CAP Work\Revised CAP _Nov0S\Risk_Assessment\TABLES.xls/6
Groundwater. Resident (Young Child)
Potable Water -Swimming Pool -Swimming Pool •
Average EPC MulmumEPC Average EPC
Ina/Denn. ------,;;,;/Denn. Ing/Denn.
1.6 0.02 0.007
January, 2005
EXHIBIT3
TABLE 1 -JOHNSTON COUNTY PROPERTIES ADJACENT TO VARIANCE PARCELS
Number OWNER AD DRl<SS CITY STATE ZIP
1 WAY OF LIFE BAPTIST CHURCH 2100 HARMONY COURT CLAYTON NC 27520-0000
2 WAUGH, DONALD & WAUGH, JEAN 2610 RIDGE CT CLAYTON NC 27520-8809
3 BOLEN, HOWARD & BOLEN, MELISSA 2016 RIDGE CT CLAYTON NC 27520-0000
4 JOHNSON, ROYS & CHARLOTTE M 2008 RIDGE CT CLAYTON NC 27520-8809
5 FLEMING, JANET LYNN 2004 FOREST DR CLAYTON NC 27520-8811
6 AVIE CO 1000 CCC DR CLAYTON NC 27520-0000
7 MORRIS, SONDRA & GARY 2016 ELIZABETH CT CLAYTON NC 27520-0000
8 ETTRIDGE, JAMES F & JUDITH L 2020 ELIZABETH COURT CLAYTON NC 27520-0000
9 STRICKER, RALPH & SONDRA 2024 ELIZABETH CT CLAYTON NC 27520-8818
10 STAMEY, ROBERT & JODIE 2000 ELIZABETH CT CLAYTON NC 27520-8818
11 JENKINS, GARY L & JANET H 2012 ELIZABETH CT CLAYTON NC 27520-0000
12 STRICKER, WILLIAM MICHAEL 2004 ELIZABETH CT CLAYTON NC 27520-0000
13 JOHNSON, TONY LEE & MARTHA P 2008 ELIZABETH CT CLAYTON NC 27520-0000
14 PRIVETTE, WILLIS E & JANICE 1925 OLD US 70 W CLAYTON NC 27520-0000
15 EVANS, BRUCE L & CAROLYN M 2004 PINEBARK LANE CLAYTON NC 27520-0000
16 WILLIAMS, DONALD K& VIRGINIA 2013 VALLEY CT CLAYTON NC 27520-8804
17 JEWELL, GARY A & RHONDA 2003 PINEBARK LN CLAYTON NC 27520-0000
18 CAUGHMAN, CE & REBECCA 2009 VALLEY COURT CLAYTON NC 27520-8804
19 MUNT, HERBERT F Ill . 2017 VALLEY COURT CLAYTON NC 27520-0000
20 SHREVE, JAMES DANIEL & MITSY 2000 PINE BARK LN CLAYTON NC 27520-0000
21 SMITH, SANDY M & MATTHEW 2007 PINEBARK LANE CLAYTON NC 27520-0000
22 GRANT, LONNIE G & PATTIE M 2021 VALLEY COURT CLAYTON NC 27520-0000
23 RUSSELL, TRAVIS E & DEBRA 121 PEBBLE DRIVE CLAYTON NC 27520-8042
24 CARROLL, LARRY W JR 125 PEBBLE ORIVE CLAYTON NC 2 7520-8042
25 JOHNSON, MALCOM DEWITT & CAROL POBOX966 CLAYTON NC 2 7520-0966
26 BOONE,CAROLBEARD 422 BISCAYNE DRNE WILMINGTON NC 28411-0000
27 HORNE. SARAH BEARD 214 TARP ON CT NAGSHEAO NC 27 959-0000
28 BENSON, IRENE P 2501 OLD US 70 W CLAYTON NC 27520-6520
29 BEN SON, !RENE LF EST &STEVEN 2501 OLD US 70 WEST CLAYTON NC 27520-6520
30 BEN SON, IR ENE P 2501 OLD US 70 W CLAYTON NC 27520-6520
31 BENSON, IRENE P 2501 OLD US 70 W CLAYTON NC 2 7520-6520
32 STATE OF NC C/O STATE PROPERTY 116 W JONES STREET RALEIGH NC 27603-0000
33 STATE OF NORTH CAROLINA 116 W JONES STREET RALEIGH NC 27603-0000
34 JONES, CHRISTOPHER & ANITA 2025 ELAINE DR CLAYTON NC 27520-8212
35 BELVIN, JUDITH W & LARRY E 321 EMAIN ST CLAYTON NC 27520-2463
36 JOHNSON, CLARENCE & WIFE 201 MEADOW RUN KNIGHTDALE NC 27520-2463
37 JOHNSON, DAVID IRA & MARNIE 5009 COVERED BRIDGE RD CLAYTON NC 27520-0000
38 PARKER, DONALD A 300S PINE ST BENSON NC 27504-0000
39 PARKER, DONALD A 300S PINEST BENSON NC 27504-0000
40 JAMES M GILBERT INC POBOX236 CLAYTON NC 27520-0000
41 JAMES M GILBERT INC PO BOX236 CLAYTON NC 27520-0000
42 JAMES M GILBERT INC PO BOX236 CLAYTON NC 27520-0000
43 JAMES M GILBERT INC PO BOX236 CLAYTON NC 27520-0000
44 JAMES M GILBERT INC POBOX236 CLAYTON NC 27520-0000
45 NA NA NA NA NA
NOTES:
NA: Parcel owner information not available on Wake County Geographic Information System
#905 1632v2
EXHIBIT3
TABLE 2 -WAKE COUNTY PROPERTIES ADJACENT TO VARIANCE PARCELS
l!j(ii'i)l>jr' OWER ~QP~l;§S J::ITY STATE !ZIP
46 FRANKLIN PATRICIA A 3435 DEER TRACE LN CLAYTON NC 27520-5931
47 AUTON, SUSAN M & JERRY L 3524 BALLOT RD CLAYTON NC 27520-9301
4B DOUGLAS PHILLIP N & BARBARA S 413 HARDWOOD RIDGE CT CLAYTON NC 27520-8603
49 DONATI, BRIAN C & DEBORAH M 1316 PINE TRL CLAYTON NC 27520-9324
50 DEBOCK, RICHARD M & JOANNE 1320 PINE TRL CLAYTON NC 27520-9324
51 WHITE DENNIS C & RUTH H 1324 PINE TRL CLAYTON NC 27520-9324
52 TERRY, AMANDA & RYAN GROULX 1109PINETRL CLAYTON NC 27520-9360
53 LEBING, WYTOLD R & CAROLBARBOUR, SWADE E JR 1304 PINE TRL CLAYTON NC 27520-9324
54 NA NA NA NA NA
55 CARROLL , KATHY LYNN B500 OLD BAUCOM RD RALEIGH NC 27610-9266
56 DEBNAM , CATHERINE 5717 MIAL PLANTATION RD RALEIGH NC 27610-8529
57 SEAWELL, VIRGINIA D 5529 M IAL PLANTATION RD RALEIGH NC 27610-8526
58 TANKARD, ANNE M MCINNES , CORNELIA STEWART C MCINNES 8419 KALB RD RICHMOND VA 23229-4133
59 BAUCOM. JOHN R JR & MARIE A 4400 AUBURN CHURCH RD GARNER NC 27529-8765
60 OKAMOTO, ERIC B & JUDITH F 1113 PINE TRL CLAYTON NC 27520-9360
61 HEDRICK, ROBERT A & PATRICIA 0 4704 STILLER ST RALEIGH NC 27609-5640
62 EDGE OF AUBURN LLC PO BOX 19808 RALEIGH NC 27619-9808
63 HINZ KYLE D & KAREN K 3401 DEER RACE LA CLAYTON NC 27520-0000
64 BEAVERS, RICHARD W & SHARON ROSE 654 CORBETT RD CLAYTON NC 27520-8452
65 NORTH CAROLINA STATE OFC/O STATE PROPERTY OFFICE 116W JONES ST RALEIGH NC 27603-1300
66 BROADWELL, BOBBY H & PAMELA S 132B PINE TRL CLAYTON NC 27520-9324
67 HUNTER, TERI FULK TRUSTEE 1340 PINE TRL CLAYTON NC 27520-9324
6B BAKER, LULA ANNE BAKER , TIMOTHY JOEL 3345 STONEY CREEK DR CLAYTON NC 27520-595B
69 SARROCCO, NICHOLAS A & EUGENIA S 7820 OLD BAUCOM RD RALEIGH NC 27610-9252
70 BRUFF, MICHAELS & KIMBERLY B 1312 PINE TRL CLAYTON NC 2752Q-9324
71 GAZDA, SHANE GAZDA , MARGERY CARNEY 2704 EMMETT CREST CT CLAYTON NC 27520-9322
72 AD AMS, JIMMY C & TONDRA E 8428 OLD BAUCOM RD RALEIGH NC 27610-9264
73 GA RRETT, DARYL J & RAMONA C 7027 FARMDALE RD RALEIGH NC 27610-9732
74 LEHOCKY, RICHARD D & BETTY A 1336 PIN E TRL CLAYTON NC 27520-9J24
75 GIL, PAUL J & DARCY A 2708 EM METT CREST CT CLAYTON NC 2:7520-9322
76 MCLEAN, ROBERTS & JOHNNIE F 1333 PINE TR L CLAYTON NC 27520-9345
77 SLAVI N, JAMES A & MARYE 1205 PINE TRL CLAYTON NC 2752Q-9361
7B DEBNAM SHIRLEY H 5700 MIAL PLANTAT ION RD RALEIGH NC 27610-8528
79 MCCLUNG, DOUGLAS E & AMY E 420 HARDWOOD RIDGE CT CLAYTON NC 27520-8803
80 BARBOU R SWADE E JR HEIRS 326 LOMBAR ST CLAYTON NC 27620-0000
B1 MA!.AAKEY, WILLIAM J & CECELIA GALE 132$ PINE TRL CLAYTON NC 27620-!IJ.45
82 DEBNAM, RETHA M, DEBNAM , CHRISTOPHER HENRY W DEBNAM 1501 CHURCHILL DOWNS DR WA:IIJ-IAW NC 27173-6610
83 PHI LLIPS, LESTER L PHILLIPS REBECCA 2700 BALLOT RD CLAYTON NC 2752Q-9304
84 WOO, HEA K & CHUN I 3425 DEER TRACE LN CLAYTON NC 27520-5~1
85 BALL. DOUGLAS 1027 HWY 70 W SUITE 225 GARNER NC 27529-0000
86 TALTON, MARGARETB 2728 BRANCH RD RALEIGH NC 27610-9214
87 MCKINNON, SWANOLA DEBNAM 5708 MIAL PLANTATION RD RALEIGH NC 27610-8528
88 D'ALLAIRD DANIEL & EMMA 2436 NEUSEHILL LN RALEIGH NC 27610-9102
89 MORGAN, ELIZABETH B PO BOX4721 CHAPEL HILL NC 27515-4721
90 LONG BRANCH FARM LLC 2400 BRANCH RD RALEIGH NC 27610-9208
91 BAUCOM, JULIAN & MARLENE 3021 HICKORY TREE PL RALEIGH NC 27610-8539
92 HAWLEY, WILLIAM J & ROBERTA L 2709 EMMETT CREST CT CLAYTON NC 27520-9322
93 DUNN, PHYLLIS DEBNAM 2916 OLD MILBURNIE RD RALEIGH NC 27604-9655
94 DAUGHERTY, GLADYS YOUNGDANIEL HOLLAND 572 BOGGS RANCH RD GRAHAM NC 27253-0000
95 BAUCOM, WILLIAM BYRD POBOX248 CLAYTON NC 27528-0248
96 BAUCOM, CLIFTON P 3005 HICKORY TREE PL RALEIGH NC 27610-B539
97 MIESCH JOHN F & LINDA T 3420 E GARNER RD CLAYTON NC 27520-9307
98 DANIELS, EARL & JOELINE Y 5717 MIAL PLANTATION RD RALEIGH NC 27610-B529
99 ROBERTSON-JETHRO, ETHEL BARBOUR 1009 PINE TRL CLAYTON NC 27520-9358
100 BIDDIX, THOMAS L & DEBORAH W 1117 PINE TRL CLAYTON NC 27520-9360
101 CHAMPION, ROBERT & MONA 2700 EMMETT CREST CT CLAYTON NC 27520-9322
102 MARRINER, LOUIS & FRANCES OWENS 1125 PINE TRL CLAYTON NC 27520-9360
103 QUINN, POLLY S POBOX132 HINESBURG VT 05461-0132
104 MCCARDLE, VAN R & CHERYL M 1105 PINE TRL CLAYTON NC 27520-9360
105 FREEMAN, DANNA F 1101 PINE TRL CLAYTON NC 27520-9360
106 BAUCOM, JULIAN M 3021 HICKORY TREE PL RALEIGH NC 27610-8539
107 PRICE, RALPH L & BEVERLY W 1201 PINE TRL CLAYTO N NC 27520-9361
108 MCKIN NON, SWANOLA DEBNAM 5708 MIAL PLANTATION RD RALEIGH NC 27610-8528
109 REED, CHARLES E 7020 FARMDALE RD RALEIGH NC 27610,9732
110 NORTH CAROLINA STATE OFC/0 STATE PROPERTY OFFICE 116 W JONES ST RALEIGH NC 27603-1300
111 KELLY, JOSEPH A & JOAN B 1332 PINE TRL CLAYTO N NC 27520-9324
112 BELL, JAN & ELMA C 1308 PINE TRL CLAYTO N NC 27520-932.4
113 JON ES, CHRISTOPHER & ANITA A 2025 ELAINE DR CLAYTON NC 27520-B212
114 P8R GROUP LLC RTE 2 2400 BRANCH RO RALEIGH NC 27610-0000
115 PERKINS. MARVIN CLAUDE & SUSAN J 6200 MIAL PLANTATION RO RALEIGH NC 27610-9.643
116 RHO DES, WILLIAM T & GWYN K 3751 E GARNER RD CLAYTON NC 27520-6541
118 GILBERT, JENNIFER P 273C BLUE POND RO CLAYTON NC 27520-7493
NOTES:
NA : Parcel owner information not available on Wake County Geographic Information System
#9051632"2
EXHIBIT3
TABLE 3 -WAKE COUNTY VARIANCE PARCELS AND CITY OF RALEIGH PROPERTY
N!iro~r ()Wt-l!;R ADDRESS CITY STATE ZIP
119 NC STATE OF C/O PROPERTY CONTROL OFFICE 9001 MAIL SERVICE CTR RALEIGH NC 27699-9001
120 DUNN, PHYLLIS DEBNAM 2916 OLD MILBURNIE RD RALEIGH NC 27604-9655
121 ADAMS, PAUL M HEIRS C/O WANDA S ADAMS EXECUTRIX 8404 OLD BAUCOM RD RALEIGH NC 27610-9264
122 ADAMS, DAL TON HICKMAN ADAMS, GEORGIA M COOPER 8401 OLD BAUCOM RD RALEIGH NC 27610-9265
123 NICHOLSON , CHEYNEY A POBOX33065 RALEIGH NC 27636-3065
124 RALEIGH CITY OF POBOX590 RALEIGH NC 27602-0590
125 CAROLINA POWER & LIGHT CO ATTN W H KEITH CX1G PO BOX14042 ST PETERSBURG FL 33733-4042
126 WHEELER, PAMELA ANN WHEELER, BRIAN KEITH 6029 MIAL PLANTATION RD RALEIGH NC 27610-8534
127 NA NA NA NA NA
128 RALEIGH CITY OF PO BOX590 RALEIGH NC 27602-0590
129 COWING, BETTY B 8100 OLD BAUCOM RD RALEIGH NC 27610-9258
130 MATERIAL RECOVERY LLC 421 RALEIGH VIEW RD RALEIGH NC 27610-4623
131 HOPKINS, JOHN H 2293 STANDING ROCK RD CAMDENTON MO 65020-4626
132 BAUCOM, JOHN R JR 4400 AUBURN CHURCH RD GARNER NC 27529-8765
133 HINTON, JAMES E 333 LAFAYETTE AVE APT 121 BROOKLYN NY 11238-1337
134 BAUCOM, WILLIAM B & ANN R POBOX248 CLAYTON NC 27528-0248
135 DUNN, PHYLLIS DEBNAM 2916 OLD MILBURNIE RD RALEIGH NC 27604-9655
136 RALEIGH CITY OF 222 W HARGETT ST RALEIGH NC 27601 -1316
137 TIPPETTS CHAPEL ORIGINAL RR1 KNIGHTDALE NC 27545-9801
138 DANIELS, EARL & JOELINE Y 5717 MIAL PLANTATION RD RALEIGH NC 27610-8529
139 NORTH CAROLINA STATE OF C/O DEPT OF ADMINISTRATION 116WJONESST RALEIGH NC 27603-1300
140 NC STATE OF 1321 MAIL SERVICE CTR RALEIGH NC 27699-1321
141 RALEIGH CITY OF 222 W HARGETT ST RALEIGH NC 27601 -1316
142 RALEIGH CITY OF POBOX590 RALEIGH NC 27602-0590
143 AD AMS, JERRY WAYNE ADAMS. BRENDA DIANNE 8513 OLD BAUCOM RO RALEI GH NC 27610-9267
144 HASH , DAVI D W & LINDA B 6216 MIAL PLANTATION RD RALEIGH NC 27610-9643
145 BROWN, SHERRY ADAMS & STEPHEN DALE 135 RIDGE WAY LN CLAYTON NC 27520-8084
146 NA NA NA NA NA
147 BROWN . SYBLE B 8529 OLD BAUCOM RD RALEJ GH NC 27610-9267
148 FAISON, BRENDA J 8549 OLD BAUCOM RO RALEIG H NC 27610-9267
149 NA NA NA NA NA
150 HASH, DAVID W & LINDA B 6218 MIAL PLANTATION RD RALEIGH NC 27610-9643
151 YOUNG, EVELYN C 8537 OLD BAUCOM RD RALEIGH NC 27610-9267
152 RHODES, WILLIAM T & GWYN K 3751 EGARNERRD CLAYTON NC 27520-6541
153 ADAMS, BRENDA DIANNE D MADAMS JR 8513 OLD BAUCOM RD RALEIGH NC 27610-9267
154 NA NA NA NA NA
155 OSBORN, ARNOLD L JR 6208 MIAL PLANTATION RD RALEIGH NC 27610-9643
NOTES:
NA: Parcel owner infonnation not available on Wake County Geographic lnfonnation System
#9051632v2
ENSR
7041 Old Wake Forest Road, Suite 103, Raleigh, North Carolina 27616
T 919.872.6600 F .919.872.7996 www .ensr.aecom.com 1
October 18, 2006
Mr. Jay Zimmerman, P.G.
Division of Water Quality
1628 Mail Service Center
ENSR 1AECOM
,u·~ce ~.~~I
1~11 OCT 1 9 2006
J Raleigh, North Carolina 27699~1628
.. 1 REG\OH/\L OFFICE
Subject: Response to Comments on Corrective Action Variance Application, Neuse River Waste
Water Treatment Plant, 15A NCAC 02L .0106(k) Va.riance Request
Dear Mr. Zimmerman,
On behalf of the City of Raleigh Public Utilities Department (CORPUD), ENSR Consulting and Engineering
(NC), Inc. (ENSR) respectfully provides the following response to comments and request for information
from the June 22, 2006Division of Water Quality (DWQ) correspondence (Attachment A) to ENSR and
CORPUD regarding the Corrective Action Variance Application for the Neuse River Waste Water Treatment
Plant (NRWWTP) farm fields. · In this e-mail correspondence, DWQ requested that the City obtain specific
details of well construction for six identified private wells located within the 0.5-mile radius of the NRWWTP
site (see Attachment A).
The property owners and well locations identified by DWQ are:
• PIN #1741639103, owned by Materials Recovery LLC, now WCA, and located at 2820 Brownfield Rd.
There are two wells identified on this property.
• PIN #17 41609431, owned by William B. Baucom and located at 7920 Old Baucom Rd.
• PIN #1750071189, owned by Robert and Johnnie McClean and located at 1333 Pine Trail.
• PIN #1750075290, owned by Richard and Betty Lehocky and located at 1336 Pine Trail.
• PIN #1750076209, owned by Teri F. Hunter, trustee, and located at 1340 Pine Trail.
In response to this DWQ information request, CORPUD sent letters with well survey forms to each of the
property owners for the six identified private wells. Please note that it was previously documented during
the CAP application process that information for these wells was not contained in City or County private well
databases. A copy of the well survey form is included with this response as Attachment B. CORPUD
received only one response to this request for information. WCA submitted a completed well survey form to
CORPUD on July 30, 2006 (Attachment C). There have been no responses from the other property owners.
Private wells in this area are generally deep bedrock wells, to supply drinking water to private homes. The
saprolite unit that extends from the surface to bedrock is not suitable for water supply wells due to the poor
hydraulic conductivity of the saprolite material. Typically, these are 6-inch diameter wells with variable
depths dependent on intervals of water-producing fractures. Wells are only required to be grouted for the
top 20 feet from the surface: the extents and depths of casing and grouting may be variable at increasing
depths for individual wells. Well construction details are not available for individual wells identified by DWQ
and described above, and have not been provided by property owners.
I
. Mr. Jay Zimmerman
Page2
It is CORPUD's position that this level of information represents a reasonable level of effort to obtain private
well information and is consistent with communication from DWQ (July 20, 2006, Attachment D herein)
regarding an appropriate response to their information request.
Please feel free to contact either Dr. Peter Thibodeau or Dr. Bill Doucette with any questions at (919) 872-
6600. .
Sincerely yours,
Peter M. Thibodeau, Ph,D., P.G., P.H.
Senior Project Manager
Attachments:
A June 22, 2006 E-mail Correspondence from DWQ
B. .CORPUD Well Survey Form
C . Completed Well Survey Form from WCA
D. July 20, 2006 E-mail Correspondence from DWQ
Cc: Tim Woody
Robert Massengill
Steve Levitas
William H. Doucette, Ph.D., P.G.
Senior Regional Program Manager
ENSR I AECOM
l
Kilcrease, Paige
From:
Sent:
To:
Cc:
Subject:
Pelter:
Rick Bolich [rick.bolich@ncmail .net]
Thursday, June 22, 2006 10:04 AM
Thibodeau, Peter
JAY ZIMMERMAN
City of Raleigh varianc.e request
As we discuss.ed civerthe tefephone yesterday; the Raleigh regional
office is requesting that the city to obtain specific details of well
construction for a certain number of private water supply wells located
within a 0.5 mile radius of the site. There are a total of six such
wells located on five properties. The five properties for which we are
requesting the actual detailed well information are as follows:
1) PIN #1741639103, owned by Materials Recovery LLC and located at 2820
Brownfield Rd. There are two wells identified on this property.
2) PIN #1741609431, owned by William B. Baucom and located at 7920 Old
Baucom Rd. ·
3) PIN #1750071189, owned by Robert and Johnnie McClean and located at
1333 Pine Trail. ..
4) PIN#1750075290, owned by Richard .and Betty Lehocky and located at
1336 Pine Trail.
5) PIN #1750076209, owned by Teri F. Hunter, trustee, and located at
1340 Pine Trail. ·
We believe that a more generic description of well construction (average
well depth, casing depth and material, sizes, etc.) would be sufficient
to meet the intent of the requirements specified in NCAC 2L .0113(c)(4 ).
I will be FAXing a copy of "Figure 1" from the March 31, 2006
Corrective Action Variance Application, which will graphically identify
the well locations for which the detailed information will be required.
Please provide us with the above-requested information on well
construction as soon as possible. We are currently drafting a letter
approving the Corrective Action Plan, and we will submit the Variance
application to the Director and EMC as soon as we receive a satisfactory
response to the well construction detail information issue.
If you have any questions about this request or any other matters
related. to the City of Raleigh's variance request or CAP, please contact
me or Jay Zimmerman.
rb
1
Kilcrease, Pai ge
From:
Sent:
To:
Cc:
Subject:
Attachments:
jay.zimmerman.vcf
Jay Zimmerman [e-mail]]
Thursday, July 20,. 2006 3:29 PM
Levitas, Steve
Rick Bolich; Thibodeau, Peter; [e-mail]; [e-mail];
~achl, Carolyn
Re: City of Raleigh v~riance request
jay.zimmerman. vcf
Unless Rick had other ideas this sounds like a good approach to me.
would ask if you draft a letter you include Rick and I as contacts in
the event the well owner has questions or is suspicious of the nature of
the letter. Beyond that, and in discussing the issue with Ted Bush, we
believe a generic description of the typical well construction details
for the other wells provides sufficient information to meet the spirit
of the rule (e.g. - a note that wells in the area are typically 6"
dia., range in depth from?-?, etc.) unless you have already supplied
this level of information.
Jay
Levitas, Steve wrote:
>Just to confirm my understanding of this situation, it is as follows:
> The City was not able to obtain any well construction information on
>these wells from any public records. We will therefore write the owners
>and ask if they can provide such information. If they fail to do so,
>then we will conclude that no such information exists and therefore
>cannot be provided as part of the variance request. Is that correct?
>
>-· Original Message-
>From: Rick Bolich [mailto:[e-mail]]
>Sent: Thursday, June 22, 2006 10:04 AM
>To: [e-mail]
>Cc: JAY ZIMMERMAN
>Subject: City of Raleigh variance request
>
>Peter:
>
>As we discussed over the telephone yesterday, the Raleigh regional
>office is requesting that the city to obtain specific details of well
>construction for a certain number of private water supply wells located
>within a 0.5 mile radius of the site. There are a total of six such
>wells located on five properties. The five properties for which we are
>requesting the actual detailed well information are as follows:
>
>1) PIN #1741639103, owned by Materials Recovery LLC and located at 2820
>Brownfield Rd. There are two wells identified on this property.
>2) PIN #1741609431, owned by William B. Baucom and located at 7920 Old
>Baucom Rd.
>3) PIN #1750071189, owned by Robert and Johnnie McClean and located at
>1333 Pine Trail.
>4) PIN #1750075290, owned by Richard and Betty Lehocky and located at
>1336 Pine Trail.
1
r
>5) PIN #1750076209, owned by Teri F. Hunter, trustee, and located at
>1340 Pine Trail.
>
>We believe that a more generic description of well construction (average
>well depth, casing depth and material, sizes, etc.) would be suffici~nt
>to meet the intent of the requirements specified in NCAC 2L .0113(c)(4).
>
> I will be F AXing a copy of "Figure 1" from· the March 31, 2006
>Corrective Action Variance Application, which will graphically identify
>the well locationsforwhich the detailed information will be required.
>. f .
>Please provide us with the above-requested information on well
· >construction as soon as possible. We are currently drafting a letter
>approving the Corrective Action Plan, and we will submit the Variance
>application to the Director and EMC as soon as we receive a satisfactory
>response to the well construction detail information issue.
>
>If you have any questions about this request or any other matters
>related to the City of Raleigh's variance request or CAP, please contact
· >me or Jay Zimmerman.
>
>rb
>
>
>
2
AboutENSR:
ENSR. an AECOM company, is a leading
worldwide environmental services firm.
Founded in 1968, ENSR serves industrial
companies and government agencies with
consulting , engineering. remediation. and
environmental health and safety solutions.
ENSR is a recipient of the BP HSSE
Diamond Award, Textron Environmental
Remediation Partner in Excellence Award.
and Environmental Business Journal
awards. As an AECOM company, ENSR is
part of a qlobal desiqn and manaqement
company with 24 ,000 employees
worldwide serving the transportation,
facilities, and environmental markets.
www.ensr.aecom.com
ENSR Locations
Belg ium
Cali fornia Bolivi a
Colorado Brazil
Connecticut
China
1111
'j Germany
t~., -Ireland
I,'' JI
~ ... 1i111,c:;cto ' ' '
" , Thailand
L I! ,,
~c r r
I ' 1, Headquarters ·, r r Westford
./,r I i1 USA
''" JI r
'v·
ENSR AECOM
ENSR
7041 Old Wake Forest Road , Suite 103, Raleigh, North Carolina 27616
T 919.872.6600 F 919.872 . 7996 www .ensr.aecom.com
May 23, 2006
Mr. Jay Zimmerman, P.G.
Division of Water Quality
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
ENSR I AECO M
Subject: Response to Comments on Corrective Action Variance Application, Neuse River Waste
Water Treatment Plant, 15A NCAC 02L .0106(k) Variance Request
Dear Mr. Zimmerman ,
On behalf of the City of Raleigh Public Utilities Department (CORPUD), ENSR Consulting and Engineering
(NC), Inc. (ENSR) is pleased to provide the following response to comments and request for information
from the May 1, 2006 Division of Water Quality (DWQ) letter to CORPUD regarding the Corrective Action
Variance Application for the Neuse River Waste Water Treatment Plant (NRWWTP) farm fields. For ease of
review, ENSR has listed the comments below, along with the appropriate response.
DWQ Comment: "The locations of the three new monitoring wells to be installed near the
groundwater extraction system in Fields 50 and 500 have not been identified on Figure A-2. Please
submit a revised figure showing the locations of these new wells."
Res ponse: Please see Figure A-2 , attached , which has been revised to indicate the locations of the three
new monitoring wells .
DWQ Comment: "We believe that the three new monitoring wells proposed for Fields 50 and 500
should be sampled at the same frequency as the other monitoring wells and not subject to delay as
proposed on page 3 of the response letter. The baseline and start-up data from these new wells will
be important to evaluate the performance of the proposed groundwater extraction system".
Res ponse: ENSR 's March 31, 2006 response to DWQ comments included a recommendation to delay
installation of the three new monitoring wells for 3 months to better understand the site-specific aquifer
heterogeneities and actual performance of the extraction wells . The intention , as stated, was to use to the
performance data for the extraction wells to devise appropriate distances and settings for the three new
monitoring wells. As a result, there would be a greater probability of locating the three new monitoring wells
beyond the collective capture zone of the extraction wells and so that the new monitoring wells would reflect
actual changes in down-gradient groundwater nitrate concentrations rather than reflect the nitrate
concentrations in the extracted groundwater. However, ENSR understands DWQ's desire to include the
three new monitoring wells in the initial stages of the system's evaluation. The three new monitoring wells
will be installed prior to the system's start-up, to provide baseline and operational water quality data. As
initially planned, the three new monitoring wells will be sampled on the same frequency as the other 58
monitoring wells in the sampling program.
NOV 2 Q "",f'5 u (.,,J
November 21, 2005
Mr. Tommy Cline, Manager
General Real Estate
State Property Office
1321 Mail Service Center
Raleigh, N.C. 27699-1321
Dear Mr. Cline:
(jitg <9f Cfi_aleigh
:North &olJ.na
CERTIFIED MAIL
As you may know, the City of Raleigh (City), in conjunction with the North Carolina
Department of Environment and Natural Resources (NCDENR), has been investigating
soil and groundwater impacts resulting from the inadvertent over-application ofbiosolids
on agricultural fields at the Neuse River Waste Water Treatment Plant (NRWWTP)
located at 8500 Battle Bridge Road. These investigations revealed that nitrate is present
in the groundwater at and in the vicinity of the NRWWTP at concentrations above North
Carolina's groundwater standard of 10 milligrams per liter (mg/L). Over the last year,
the City has been developing a corrective action plan (CAP) to address this groundwater
nitrate exceedance.
The City's consultants, ENSR Consulting and Engineering (NC), Inc. (ENSR), performed
a comprehensive study of remedial alternatives in preparation of a CAP. As a result of its
study and in its expert opinion, ENSR made the following determinations:
• It would cost in excess of $68,000,000.00 to actively remediate all areas where
the groundwater standard has been exceeded beyond the City's compliance
boundary (Remedial Alternative A).
• The installation of extraction wells in select locations and monitored natural
attenuation for the remainder of the entire site can be accomplished at an
approximate cost of $8,000,000 (Remedial Alternative B).
• The less costly remedial alternative will fully protect public health and the
environment provided that (i) the affected groundwater is not used for human
consumption, and (ii) the impacts of nitrogen loading to the Neuse River are
9008626.3
offset.
The rules of the North Carolina Environmental Management Commission (EMC) require
a pennitted party like the City to utilize best available technology to actively remediate
exceedances of state groundwater standards. However, the rules also provide that a party
may seek a variance from that requirement when it can show, among other things, that (1)
full compliance with the rules would produce serious financial hardship without equal or
greater benefit, and (2) the variance will not endanger public health or the environment.
In order to implement Remedial Alternative B rather than Remedial Alternative A, which
would provide very little additional benefit but would cost an extra $60,000,000, the City
must obtain a variance from the EMC, which it is preparing to seek.
There are a number of reasons why we believe that Remedial Alternative B provides
ample protection to human health and the envirmunent:
• While nitrate concentrations will remain above the groundwater standard of 10
mg/L for a period of time, the concentrations will naturally decrease over time
due to natural attenuation.
• The City has provided free water service to properties where residents were
using the groundwater for drinking water, thereby eliminating any risk to human
health.
• The City will monitor groundwater regularly.
• The City will account for the amount of additional nitrogen that is being
conveyed via groundwater to the Neuse River by debiting this amount against
the City's nitrogen discharge allocation in its wastewater permit.
• The detected nitrate concentrations are not known to be toxic to aquatic
organisms.
We would like to be able to tell the EMC that the owners of all neighboring properties
within the variance area that are not served by City water have consented to the City's
use of Remedial Alternative B. As you will see from the enclosed map, a portion of your
property is within the variance area. We are therefore seeking your consent to our
variance request.
If you consent to our request, please indicate such consent by signing this letter in the
space indicated below and returning it to me. For the reasons stated above, we believe
that Remedial Alternative B provides ample protection to human health and environment
in a cost effective manner.
The City will be contacting you in the next few days to discuss this letter with you
personally. However, we are happy to talk to you before then, and at your convenience,
9008626.3
about any concerns you may have. Please call me at 919-831-6044 or feel free to contact
Tim Woody at 662-5700 or Q25-5558 (cell).
We thank you for your consideration of this matter. Please sign and print your name(s)
and date below, if your consent to the City's use of Remedial Alternative B. We would
like to have a copy of the signed letter and will arrange to make a copy when we contact
you.
Sincere!
.Dal
Ralei
,P.E.
·c Utilities Director
Cc: Reuse Superintendent
Kilpatrick and Stockton
ENSR
9008626.3
AboutENSR:
ENSR, an AECOM company, is a leading
worldwide environmental services firm.
Founded in 1968. ENSR serves industrial
companies and government agencies with
consulting, engineering, remediation, and
environmental health and safety solutions.
ENSR is a recipient of the BP HSSE
Diamond Award, Textron Environmental
Remediation Partner in Excellence Award.
and Environmental Business Journal
awards. As an AECOM company, ENSR 1s
part of a global design and management
c;ornpcmy with 24,000 employees
worldwide serving the transportation,
facilities, and environmental markets.
www.ensr.aecom.com
ENSR Locations
Id'.° Azerbaijan
" .. t _j' I 7
I. \lll
Connecticut ".
,I ' JI, I' II ... i ,,
Germany
'·Ill Ireland
'~ H !•~111t Italy
I, I'" 11 ti ~ 11 I ' ' I" r 1,
I I ·~ Mexico
I ., H II
, l: II •I r
Thailand
' I Turkey
Venezuela
Pennsylvania
Rhode Island Headquarters
II
II
Washington USA
Wisconsin
ENSR AECOM
Attachment A-July 18, 2006 Letter from NC DENR DWQ
,,
HDR Engl ■eilrlilg, Inc. e1·11t• Cai'lilhiiij
Please note that failure to provide this additional infonnatio11 on or before the above requested
date may result in your application being returned as incomplete.
If you have any questions regarding this request, please do not hesitate to contact me at (919)
715-6188 or via e-mail at [e-mail]. Thank you for your cooperation.
cc: Donald Safrit, HDR Engineering, Inc. of the Carolinas
Sincerely,
Chonticha McDaniel
Aquifer Protection Section
Keith Larick, Raleigh Regional Office, Aquifer Protection Section
APS Central Files
Attachment B -Eagle Resources~ P .A -Model Reassessment
HDR EngbiHrl11a. r.-o. tifth• -C:iroll•i•
\
Figure 1 shows the CORPUD fields that are presently irrigated and those that are proposed to
be irrigated in Phase II. (HOR Preliminary Engineering Report, Sheet C-01, 04/06)
The CORPUD groundwater flow and transport model was used previously to determine the
likely historical and future nitrogen loading via groundwater discharge to the Neuse River and
its tributaries that drain the CORPUD Biosolids fields (Eagle Resources, 2003). The results of
analyses with that model were used in support of the variance petition to NCOENR to allow
this loading to be accommodated by reductions in CORPUD's allowable nitrogen allocation
under the Neuse Rules. These analyses resulted in a declining rate of such reductions that
resulted from the difference in the simulated future loading from groundwater discharge and
the loading that would have resulted if the NC 2L nitrate standard of 10 mg/I had not been
exceeded at the CORPUD compliance boundaries. Figure 2 shows the modeled loading rates
under these conditions.
The nitrogen source term for the model that generated the loading curves in Figure 2 used
nitrogen recharge to groundwater from 1979 to 2003 that was a function of both the annual
recharge rate and the Plant A vailable~itrogen (PAN) present in the fields in excess of an
asswned agronomic uptake rate of 140 lbiac/year. (Eagle Resources, 2003, Table G-4)
Effects of Recharge from Spraytields
.L
The recharge rates used in Table G-4 were derived from simulation with the Soil and Water
Assessment Tool (SWAT) which simulates a daily water balance using climatic, soils, and
crop data specific to the CORPUD site. These rates ranged from 3. 7 inches per year in 1980 to
12.5 inches per year in 1981, and averaged 8.0 inches per year.
The water balance model used by EAA to assess irrigation rates for the Phase II sprayfields
used a soil drainage rate of 1.4 inches per month (16.8 inches per year). This value was
derived by applying a drainage coefficient of 0.04 to the lowest measured value of
permeability of the least permeable horizon of 0.05 inches/hour (Table on p. 3 of EAA report).
The EAA analyses assume that water lost to drainage is not taken up by plants and hence
becomes groundwater recharge. Consequently, the recharge asswned by the EAA analysis is
more than twice that used in the previous groundwater flow and transport modeling.
We used the groundwater flow and transport model to assess changes in the likely nitrogen
loading to the Neuse River and tributaries for the period from 2007 through 2050 resulting
from recharge to the Phase II sprayfields at the rate of 16. 8 inches per year from the EAA ·
water balance analysis. The same average recharge rage of 8 inches per year used in the
original model for non-irrigated areas of the model was used for the present analyses.
Analysis of the effects ofrecharge from irrigation of the existing sprayfields was not included
in our analysis.
The initial nitrogen concentration in groundwater for these analyses was that simulated at the
end of 2006 with the previous model. Nitrogen in the recharge water from the sprayfields was
assumed to have an arbitrary concentration of 5 mg/I. We note that this is a conservative
analysis because the average total nitrogen concentration in the NTWWTP effluent for the past
two years has been less 3 mg/I or less as shown in Appendix A of the HOR report.
Leter Report Model Assessment of lrrigtion Impacts 08_21_06.doc 2
1
Attachment C -Hydraulic and Nutrient Loadings Reassessment
HDI E■glitiarl ■g. Inc. DI lhirC:ilroliH:S
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
PRIVATE WELLS SAMPLED IN VICINITY OF NRWWTP ON DATES NOTED TO RIGHT
OWNER'S NAME Home# Work# Address
Adams Dalton 772-6706 8401 Old Baucom Road
Adams Diane 772s2348 787-0125 8513 Old Baucom Road
Adams Jimmv 772-6376 8428 Old Baucom Road
Adams, Shirle y 772-5956 8404 Old Baucom Road
Baucom Julian I Clifton 772-1647 3021 I 3005 Hickorv Tree Pl
Baucom William 772-2242 -8004 7920 Old Baucom Road
Belvin Dann v 772-7898 6208 Mia/ Plantation Rd
Blowe, Bobbv 779-1399 2853 Shotwell Rd
Brown Svbil 773-2467 8529 Old Baucom Road
Carroll Kathv 779-0683 8500 Old Baucom Road
Clark John 662-5504 8416 Old Baucom Road
Ross, Glee 772-0428 2823 Shotwell Rd
Cowina. Bettv 772-1226 8100 Old Baucom Road
Daniels Earl 266-3581 5716 Mia/ Plantation Rd
Debnam Catherine 266-3616 5717 Mia/ Plantation Rd
Debnam Clarence 266-1923 5525 Mia/ Plantation Rd
Debnam Judson &Shirle v 266-1708 5700 Mia/ Plantation Rd
Debnam Rene/la 266-2387 5616 I 5620 Mia/ Plant Rd
Debnam Retha 2664548 5600 Mia/ Plantation Rd
Dunstan Ollie 266-1829 5520 Mia/ Plantation Rd
Frison, Brenda 773-1171 546-4197 8549 Old Baucom Road
Hash, David 772-7049 6216 Mial Plantation Rd
Ho okins John 772-0739 8321 Old Baucom Road
Howell, Kenn y 661-5785 773-7184 2820 Brown Field
Hunter Ted 553-5667, 1 MO Pi~e Trail
Mc#(jnnon Charles 266-3073 5708 Mia/ Plantation Rd
Citv of Ralei q h 553-5936 8208 Old Baucom Road
Perkins Marvin 771-0714 6200 Mia/ Plantation Rd
Rhodes William 553-7008 553-7008 6205 Firecracker
. . .. 6309 Mial Plantation
" " n 6317 Shotwell/ Mial Plant.
9039830_3 .XLS
August 8/5 DWQ8123
NO3 mg/L NO3 mg/l
3.8
1.5
1
4.4
2.6
4.1
20.9 21
2.1
0.1
1.6
24 23
0.7
2.8
2.7
1.7
4.7
4.6
7.1
2.5
5.2
12.4 9.7
1.3
13
0.3
4.7
6.3
4.1
15.4 18
7.6
TABLE 1
Private Well Nitrate Nitrogen Results and Water Supply/Service Status
Neuse River Waste Water Treatment Plant
Raleigh, North Carolina
Confirm 9/11 January 118 Confirm 2/20 April July Oct Jan'04 April'04
NO 3 mg/l NO3 mglL NO3 mg/l NO3 mg/L NOa mg/l NO3 mg/l NO3 m9IL NO3 m9/l
6.3 3.4 NIA NIA NIA NIA
3 1.4 1.6 1.6 NIA NIA
0.9 1.0 NIA NIA NIA N/A
10.9 4.3 4.4 4.8 NIA NIA N/A
0.1 0.5 0.5 0.5 0.5 0.5 0.5
6 2.4 2.4 2.7 2.5 2.6
3.9 7.5 3.7 3.8 4.1 5.7 4.2
20 23.4 19.7 20.3 19.5 NIA N/A
2.1 5 2.2 2.4 2.3 NIA NIA
0.5 0.5 NIA NIA NIA NIA
1.7 1.4 NIA NIA NIA NIA
23.5 52.9 20.3 23.1 20.3 NIA NIA
0.5 0.5 0.9 NIA NI A NIA
5.9 2.5 3.1 3.2 3.5 3.2
6.4 3.1 3.3 3.9 3.9 3.7
2.1 2.1 2.1 2.1 2.3 2
10.3 4.4 4.7 4.7 5.1 5.6 5.4
8.4 3.8 4.6 3.9 3.7 4.4 3.9
7 15 6.2 7.3 6.6 5.7 7.2 6.5
1.9 2.9 3.0 3.1 3.2 3.9
5.2 13.5 6.5 7.4 7.7 6.9 NIA NIA
11.6 16.2 15.2 14.4 18.0 NIA N/A
7.4 2.6 2.9 NIA NIA NIA
8.9 20.5 6.9 8.5 8.7 8.7 7.8
0.6 M 0.5 Q;S 0.6 0.5
9.6 5 4.3 5.5 5.5 5.4 5.4
0.5 0.5 0.5 0.5 0.5 0.5
5.8 13.3 10.8 11.2 12.5 13.8 14.2 12.1
4.1 8.7 4.1 4.2 5.0 5.5 5.9 6.6
17.2 37.4 18.4 21.3 NIA NIA NIA
7.8 13.9 7 4.8 8.5 • NIA NIA NIA
July'04 Oct'04 Jan/Feb '05 April'05 August '05 Bottle Water Bold indicates results greater GWQ std
Currentl v
NOa mg/l NO 3 m9IL NO3 mg/l NO3 m9IL NO3 m9IL STATUS
agreement rec 4/22, CONNECT 6/10/03, Well
NIA NIA NIA NIA NIA abandoned 11/26/2003
agreement rec 7/17, CONNECT 10/14/03, Well
NIA NIA NIA NIA N/A abandoned 11/18/2003
agreement rec 4/25, CONNECT 6/10103, Well
NIA NIA NIA NIA N/A abandoned 11/17/2003
agreement rec 7/24, CONNECT 10/1/03, Well
NIA NIA NIA NIA NIA NL abandoned 11/26/2003
agreement rec 12129/03, CONNECT 6122104,
NIA NIA NIA NIA NIA Well abandoned 9/14/2004
2.5 1.3 N/A NIA NIA aareement rec 4/16/04 CONNECT9/28/04
agreement rec 12120/03, CONNECTB/1/04,
NIA NIA NIA NIA NIA Well abandoned 09/09/2004
agreement rec 7/24, CONNECT 10/21/03, Well
N/A NIA NIA NIA NIA NL abandoned 4/30/2004
agreement rec 10/28, CONNECT 11/18/03,
NIA NIA NIA NIA NIA Well abandoned 01/28/2005
agreement rec 4/25, CONNECT 5/29/03, Well
NIA NIA NIA NIA NIA abandoned 11/18/2003
City property, CONNECT5/29/03, Well
NIA NIA NIA NIA NIA abandoned 11/18/2003
agreement rec 7/24, CONNECT 10/21/03, Well
NIA NIA NIA NIA NIA NL abandoned 4/29/2004
agreement rec 4/30 , CONNECT 7/14/03, Well
NIA NIA NIA NIA NIA abandoned 11/26/2003
agreement rec 12131/03, CONNECT6/2/04,
NIA NIA NIA NIA NIA Well abandoned 9/1312004
agreement rec 9/13/04,.CONNECT 10/13/04,
3.7 6.4 NIA NIA NIA Well abandoned 1/27/05
agreement rec 9/20/04,CONNECT10/19l04,
2.1 2.4 NIA NIA NIA Well abandoned 12106/04
agreement rec 9/13/04,CONNECTt 0112104,
4.5 2.1 NIA NIA NIA NL Well abandoned 1/27105
agreement rec 9/20/04,CONNECT10/20/04,
2.9 1.0 NIA NIA NIA Well abandoned 1126105
agreement rec 9/13/04,.CONNECT10/12104,
7.4 7.3 NIA NIA NIA NL Well abandoned 1/26105
agreement rec 11/29/04, CONNECT, Well
4.9 4.1 0.5 NIA NIA abandoned 1/26/05
agreement rec 7/24, CONNECT 10/22/03, Well
NIA NIA NIA NIA NIA abandoned 4/28/04
agreement rec 7/24, CONNECT 12/2/03, Well
NIA NIA NIA NIA NIA NL abandoned 4/28/04
agreement rec 5/14, CONNECT 8/13/03, Well
NIA NIA NIA NIA NIA abandoned 11 /26/03
agreement received 2005. Well abandoned
4.4 6.1 3.4 8 NIA X 4/18/05
.-0.5 0.5 Q.7 0,7 <0,05 irn>t aooilcable -wa~r service rmt available
agreement rec 9/20/04,CONNECT11/16104,
7.2 4.8 NIA NIA NIA Well abandoned 1/26105
0.5 0.5 NIA NIA NIA Citv oro oe rtv. Well abandoned
agreement rec 6110/04, CONNECT9/16104,
13.9 NIA NIA NIA NIA NL Well abandoned 1127/05
agreement rec 12107/03,CONNECTS/28/04,
NIA NIA NIA NIA NIA Well abandoned 9/8/04
agreement rec 6/9, CONNECT 8/4/03, Well
NIA NIA NIA NIA NIA NL abandoned 11 /17/03
agreement rec 6/9, CONNECT 8/7/03, Well
NIA NIA NIA NIA N/A NL abandoned 11 /17 /03
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