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

Corrective Action Variance Application
City of Raleigh
Neuse River Wastewater Treatment Plan
Raleigh, North Carolina
December 1, 2005
TABLE OF CONTENTS
Page
1.0 Introduction ........................................................................................................................ I
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
toNRWWTP .............................................................................................. 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 1: 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 groundwater 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) if CORPUD were a non-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 ISA 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 I SA 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 ofby 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 Hydrogeology
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 O 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
and joints (Harned 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 10-0 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 EMC'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 1730) 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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depicts fields to which CORPUD has land-applied biosolids under its permit. Since 1980, fields
have been added and removed from the biosolids application program. For example, CORPUD
discontinued biosolids application on Fields 1, 2 and 3 in 1998 and the City converted them into
a police training facility. Several fields (Fields 100, 101,102,200,201, 500,512,513,522,523
and 524) were formerly leased for biosolids application but are no longer leased for this purpose.
The property containing former leased Fields 100, 101, 102, 522, 523, and 524 is currently
owned by Waste Corporation of America and is used as a construction and demolition landfill.
CORPUD currently leases fields 600,601,602 and 603. The remaining fields shown on Figure
1 are owned by CORPUD.
Groundwater quality monitoring required under the permit revealed exceedances ofNCAC
Subchapter 02L nitrate groundwater standard in proximity to the compliance boundary of
CORPUD-owned biosolids application fields. The City suspended all land application of
biosolids in September 2002 (ENSR, 2003). The following sections discuss groundwater
contamination at the Site.
3.2.1. Water Supply Wells
In 2002, CORPUD sampled thirty-six private water supply wells located in the vicinity of the
Site. Analytical data indicated that seven wells had nitrate concentrations in excess of 10 mg/L
(see Table 1 ). The source of nitrates detected in these wells was likely a combination of septic
systems, non-CORPUD fertilization ofupgradient fields, and biosolids application to upgradient
fields. CORPUD subsequently initiated a quarterly sampling program of private water supply
wells located within a half of a mile of the biosolids application field boundaries. The City
identified forty-five private and/or community water supply wells and included them in the
sampling program. A summary of the wells identified within proximity of the Site and
associated analytical results (from CORPUD sampling program) are listed in Table 1. Thirty-
nine of the forty-five properties included in the sampling program were subsequently connected
to the public water supply system. These thirty-nine properties were served by thirty-eight water
supply wells, of which thirty-seven wells have been decommissioned consistent with the NCAC
Subchapter 02L requirements. Per the information provided by CORPUD, the residential
property with the remaining private water supply well has been connected to the public water
supply system; however, the well will not be abandoned as requested by the property owner.
Based on the information provided by CORPUD, there are three private water supply wells
(identified as PW-24, PW-42, and PW-43 in Table 1) that are still in use (active) and remain in
the CORPUD sampling program. Nitrate concentrations for these currently active water supply
wells were below 10 mg/L during the January 2005 sampling event (see Table 1). These wells
are not likely receptors for nitrate-impacted groundwater migrating from the biosolids
application fields. CORPUD will continue to monitor the three remaining wells as long as
required under its land application permit.
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3.2.2. Soil Sampling Results
Analytical results of the soil samples collected from Fields 3, 100, and 500 are summarized on
Table 2. The data indicate concentrations of nitrate generally peak in 4 to 8 ft depth interval
(ENSR, 2002). The soil profile nitrate concentrations are expected to change over time, but the
peak concentrations are likely to stay in approximately same depth interval. The implication of
this feature is that nitrates are accumulating at the 4 to 8 ft depth interval through mechanisms
such as infiltration redistribution (some water takes a rather slow pathway through the soil) and
anion exchange (nitrate is an anion).
3.2.3. Groundwater Analytical Results
Groundwater analytical data for the CORPUD test wells and the CSA-SSA wells are provided in
Tables 3 and 4, respectively. The groundwater analytical data is depicted in Figure 1. The data
indicated that nitrate exceeded its 02L groundwater standard at locations near the compliance
boundary in the areas of Fields 6, 12, 18, 19, 41, 47, 50, 60, 61, 62 63, 74,100,201,500, and
503. The deep saprolite well (MW-113d) and bedrock wells (MW-lOld, MW 105d and MW-
111 d) also exceeded nitrate groundwater standard (ENSR, 2002).
Analytical results suggest a potential for nitrates from biosolids application in Field 50 to have
impacted groundwater on the residential property to the east and in the former private water
supply well (PW-22). Field 50 received biosolids routinely between 1982 and 2002 and has been
reported to have received excess PAN applications in 8 of those years (ENSR, 2002). Results
from assessment of Field 500 suggested a more limited potential for nitrate impacts from
biosolids application.
Off-site nitrate impacts to groundwater associated with biosolids application in the vicinity of the
intersection of Old Baucom Road and Mial Plantation Road does not appear to extend
significantly east of Shotwell Road or Mial Plantation Road. Nitrates in groundwater exceeded
the nitrate groundwater standard within Field 500 in the vicinity of former private water supply
wells PW-8, PW-12, PW-30, and PW-36. The application history for Field 500 indicates that
biosolids application to Field 500 ceased in 1994 and that biosolids application rates were
generally less than other application fields such as Field 50. Field 500 apparently has been
cropped several years before and after biosolids application. The SSA concluded that detected
nitrates in groundwater in Field 500 were not due to biosolids application alone (ENSR, 2003).
Analytical data from wells located across major streams such as Beddingfield Creek indicated
that migration of nitrate impacted groundwater under the stream is likely not occurring (ENSR,
2003).
3.2.4. Surface Water Results
Surface water analytical results are tabulated in Table 5 and depicted on Figure 1. The surface
water data from several samples collected in first order tributaries and seeps within the
application areas had nitrate concentrations above 10 mg/L. Nitrate in surface water suggests
6
groundwater discharges to the streams and tributaries (ENSR, 2002). Nitrate in samples
collected from Beddingfield Creek and the Neuse River were lower and did not exceed 10 mg/L.
3.2.5. Soil PAN Evaluation
An incubation study was conducted as part of the SSA to estimate the amount of PAN in soils
from fields at the NRWWTP and the residual PAN for the 2003-growing season. The 2003 soil
PAN evaluation indicated that many of the fields in the study area could supply adequate to
excessive amounts of PAN for crop production. The evaluation indicated that approximately 38
fields would supply PAN in excess of the amount required for anticipated crop production in
2003 (ENSR, 2003).
3.3. Description of the Proposed Variance Area
The location of the areas proposed for a variance from the standards of 15A NCAC 02L is
depicted on Figure 2 with hatching or cross hatching ( cross hatching denoting areas that will
receive active remediation). The parcels containing variance areas are colored green and labeled
as parcel numbers 119 through 155. Most of the variance area is not currently owned by
CORPUD. The actual land uses for each parcel are provided in Table 6. The parcels for which a
variance is requested are primarily rural, agricultural or forested lands. While some of the
parcels have private residences (i.e., Parcels 121, 122, 126, 129, 131, 134, 138, 141, 143, 146
through 148, 150 through 152, and 155), the majority of the land for which a variance is
requested is vacant. The land south of Beddingfield Creek at the southern portion of the site
(Parcels 119, 139 and 140) comprises a portion of Clemmons State Forest. The large parcel to
the west of site (Parcel 130) is owned by Waste Corporation of America (WCA) and is currently
used as a construction and demolition debris landfill. Parcel 13 7 to the east of the site is a
cemetery. All of the properties for which a variance is requested, except Parcels 119, 130, 139
and 140, have public water service or access to public water service should a residence or place
of business be constructed on the parcel. Only the WCA parcel and Parcel 134 (an individual
residence) use well water from the vicinity of the site, though for non-potable uses exclusively.
3.4. Public Health and Environmental Exposure
ENSR prepared a baseline human health risk assessment on behalf of CORPUD to evaluate the
potential risk to human health from nitrate-impacted groundwater at the site. A copy of this risk
assessment is attached as Exhibit 2. The following sections discuss the potential receptors and
exposure routes at the site and evaluate the potential risks to public health under several
conservative exposure scenarios. It also discusses the measures that CORPUD will take to
ensure protection of surface water in the vicinity of the site if its variance request is granted.
3.4.1. Groundwater
All wells within a half-mile radius of the site are shown on Figure 3. Well construction
information for these wells is not available. In 2002, CORPUD instituted a testing program for
nearby private water supply wells that were likely to impacted by nitrate-contaminated
groundwater from the site. Since that time, most water supply wells at nearby residences have
7
been replaced with public water supply and the former water supply wells have been abandoned.
(ENSR, 2005; ENSR, 2003). CORPUD offered free connections and water service to all
properties within its testing program, regardless whether the well serving that property had
experienced an exceedance of the groundwater standard and regardless whether there was any
evidence of or potential for contamination of the well by nitrate-contaminated groundwater
emanating from the CORPUD biosolids application fields. There are three private water supply
wells originally in the testing program that are currently in use but nitrate concentrations in those
wells are below the nitrate groundwater standard. See Figure 3. The remaining wells shown on
Figure 3 that were not part of CORPUD's testing program are at no risk from nitrate-
contaminated groundwater as indicated by CORPUD's conservative groundwater models.
To provide a conservative estimate of potential risks, ENSR evaluated potential future use of site
groundwater or downgradient groundwater by considering a hypothetical future resident
potentially exposed to nitrate in groundwater used as drinking water. For non-potable uses,
ENSR considered a hypothetical future resident using groundwater for a swimming pool. The
receptor evaluated was a young child (aged 0-6 years) as a child is the most sensitive receptor for
noncarcinogenic effects. ENSR considered both ingestion and dermal routes of exposure.
Further details of the methods and data used and assumptions made are found in ENSR's report
in Exhibit 2. After calculating the noncarcinogenic hazard indices (HI) and comparing it to the
EPA index, ENSR found that there were no unacceptable risks for exposure to groundwater used
for a non-potable purpose (swimming pool). The Hls also indicated that there were no
unacceptable risks for using groundwater for irrigation purposes. The Hls for potable use of
groundwater indicated a potentially unacceptable risk for site groundwater if it were used as
drinking water. However, no property owners in the vicinity of the NRWWTP are using
groundwater for drinking water that exceeds the nitrate groundwater standard or is predicted to
exceed the standard. Moreover, the City will monitor nitrate levels in groundwater at the
compliance boundary for as long as nitrate concentrations in groundwater are above the 10 mg/L
standard to ensure the protection of human health and the environment.
3.4.2. Surface Water
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. To ensure a conservative risk
assessment, the receptor was identified as a child or teenager ( aged 7 to 16 years) wading in the
surface water. As with the non-potable use of groundwater, ENSR found that there were no
unacceptable risks for exposure to surface. See Exhibit 2.
Nor does the nitrate contamination in groundwater present a localized risk to surface water
quality or aquatic life. In order to protect the Neuse River estuary from any increased risk of
eutrophication, CORPUD has agreed that, as a condition of the variance, it will accept a
condition in its wastewater discharge permit to account for the amount of nitrogen estimated to
enter the Neuse River from groundwater in excess of the nitrate groundwater standard.
CORfUD is currently allowed to discharge 676,496 pounds of nitrogen per year to the Neuse
River, but its actual discharge is substantially below the permitted amount. Under the proposed
8
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, but 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 standard 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
NR WWTP 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
effectiveness 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 1 -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, including 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., corn 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 deptvs 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., corn 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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Monitoring. To monitor effectiveness of Alternative I, approximately 20 monitoring wells,
20 injection wells, and 10 surface water locations would be sampled three times a year and
analyzed for nitrate for the life of the project. In addition, 20 samples would be analyzed
annually for biogeochemical parameters (i.e., ferrous iron, total organic carbon etc.) to evaluate
denitrification/anaerobic conditions. ENSR estimated that 88 recovery wells would be sampled
annually for nitrates. It should be noted that CORPUD currently samples the compliance wells
three times a year as part of the compliance monitoring. Test well data would be used in
evaluating the performance of this alternative. The actual cost of the long-term monitoring (30-
year) program would be approximately $3,024,000, with a present worth of $1,382,373.
3.5.2. Alternative 2: Groundwater Containment in Fields SO and 500,
Discharge to NRWWTP or Land Application, and Long-Term
Monitoring in Other Areas
Based on the available information, and groundwater flow and transport modeling, nitrate
concentrations have exceeded the groundwater standard at or beyond the compliance boundary
for Fields 50 and 500. This alternative is intended to control further off-site migration of nitrate
impacted groundwater from these areas. Long-term monitoring only is proposed for the
remaining areas of the site where exceedances of nitrate groundwater standard have occurred at
or beyond the compliance boundary.
Groundwater Extraction Process. Alternative 2 involves the collection of nitrate-impacted
groundwater using appropriately-spaced extraction wells in Fields 50 and 500. The groundwater
extraction (recovery) wells would be installed within the compliance boundaries in these two
fields to allow containment of the dissolved nitrate plume exceeding nitrate groundwater
standard. These extraction wells are expected to be installed to depths ranging from 60 to 80 ft
bsg. Based on hydro geologic data and results of the groundwater capture zone modeling, ENSR
determined that 7 extraction wells would be installed near the eastern compliance boundary of
Field 50 to a depth of approximately 80 ft bsg. In addition, 22 extraction wells would be
installed near the eastern compliance boundary of Field 500. The depth of extraction wells in
Fields 500 is approximately 60 ft bsg. Figure 2-2 presents a layout of the proposed extraction
wells . Based on the results from the aquifer tests, yield from each well is assumed to be
approximately 2 gpm. Approximately 83,520 gallons per day of extracted groundwater would be
pumped to the NR WWTP for treatment. The design, construction, start-up, and
decommissioning costs of this alternative would be $2,391,920. Operation and maintenance
costs, including treating the extracted water, would cost approximately $4,206,240 over 30 years.
The present worth of the costs associated with the extraction process is $4,012,835.
Monitoring. ENSR assumed that 10 monitoring wells (MW-105, MW-108, MW-109, MW-110,
MW-111, MW-112, MW-117, MW-118, MW-119, and MW-120) and 2 surface water locations
(SW-20 AND SW-22) would be sampled triennially and analyzed for nitrate for the life of the
project, in addition to the monitoring wells that are monitored triennially for the land application
permit. In addition, the 29 extraction wells would be sampled and analyzed for nitrates annually
for the life of the project. Groundwater data from these extraction wells, monitoring wells, and
surface water samples would be used to monitor the performance of this alternative. It should be
noted that CORPUD already samples the compliance wells three times a year as part of the
11
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 NR WWTP 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 NRWWTP 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
12
exceed the nitrate groundwater standard. This hydraulic barrier would result in reducing
groundwater discharge and thus stream baseflow to several streams in the area, particularly
Beddingfield Creek. This reduced flow would be potentially detrimental to the ecology of those
streams.
On potential benefit of Alternative 1 is that it accelerates the time by which off-site groundwater
in the downgradient areas could be used for human consumption if needed. However, there is no
net public benefit in spending an extra $70 million to accelerate the cleanup of groundwater in
area where there is little or no need to use the groundwater for human consumption. While it is
desirable that the groundwater eventually be remediated to unrestricted use standards, the
additional time required to achieve that goal utilizing CORPUD's preferred remedial alternative
will not endanger public health because no one is using or can use any contaminated
groundwater as a water supply.
3.7. Information Regarding Adjacent Property Owners
CORPUD obtained the names and address of those owning property within the proposed
variance area as well as property owners adjacent to the site covered by the variance from the
Wake County Geographic Information System. A list of these names and addresses are provided
in Exhibit 3.
4.0 Summary and Conclusions
The nitrate contamination at the site does not and will not endanger public health or the
environment provided that (i) contaminated groundwater is not used for human consumption,
and (ii) the impacts of nitrogen loading to the nutrient-sensitive Neuse River are offset.
CORPUD has provided city water service to all properties in the area where there was any risk
from using groundwater as a water supply.
CORPUD does not believe the alternative that would fully comply with the EMC's rules is
economically reasonable. It would cost in excess of $79,000,000 to remediate all areas where
the groundwater standard has been exceeded by installing and operating extraction wells around
the entire compliance boundary and implementing enhanced denitrification in area where nitrate
contamination has already migrated beyond the compliance boundary. Although the proposed
installation of a limited number of extraction wells is not strictly needed to protect public health
and the environment, it does provide a measure of additional benefit (by accelerating the time by
which off-site groundwater in the downgradient area could be used for human consumption if
needed) at a much more reasonable and manageable cost ($9,000,000). The full compliance
alternative would create a financial hardship on CORPUD and in particular would divert needed
funds from the numerous and extensive capital improvements planned for the NRWWTP in the
near future to ensure the protection of water quality and the availability of high quality
wastewater treatment service to the area's growing population. Nor would the immense
expenditure required to implement the full compliance alternative result in commensurate public
benefit relative to the more cost effective and fully protective proposed remedy. Moreover, the
full compliance alternative would result in reducing groundwater discharge and thus stream
13
baseflow to several streams in the area, particularly Beddingfield Creek, which would be
potentially detrimental to the ecology of those streams.
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
14
PRIVATE WELLS SAMPLED IN VICINITY OF NRWWTP ON DATES NOTED TO RIGHT
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
OWNER'S NAME
Adams Dalton
Adams Diane
Adams Jimm y
Adams, Shirle y
Baucom Julian I Clifton
Baucom William
Belvin Dann v
Blowe, Bobby
Brown Sybil
Carroll Kath v
Clark John
Ross, Clee
Cowin q, Be ttv
Daniels Earl
Debnam Catherine
Debnam Clarence
Debnam Judson &Shir/e v
Debnam . Rene/la
Debnam Retha
Dunstan , Ollie
Frison, Brenda
Hash, David
Ho pkins John
Howell, Kenn y
23
24
25 , 1Munter. Teri
26
27
28
29
30
31
McKinnon Charles
Ci lv of Raleiah
Perkins Marvin
Rhodes William
"
"
9039830_3.XLS
Home# Work# Address
772-6706 8401 Old Baucom Road
772-2348 787-0125 8513 Old Baucom Road
772-6376 8428 Old Baucom Road
772-5956 8404 Old Baucom Road
772-1647 3021 I 3005 Hickorv Tree Pl
772-2242 -8004 7920 Old Baucom Road
772-7898 6208 Mia/ Plantation Rd
779-1399 2853 Shotwell Rd
773-2467 8529 Old Baucom Road
779-0683 8500 Old Baucom Road
662-5504 8416 Old Baucom Road
772-0428 2823 Shotwell Rd
772-1226 8100 Old Baucom Road
266-3581 5716 Mia/ Plantation Rd
266-3616 5717 Mia/ Plantation Rd
266-1923 5525 Mia/ Plantation Rd
266-1708 5700 Mia/ Plantation Rd
266-2387 5616 I 5620 Mia/ Plant Rd
266-4548 5600 Mia/ Plantation Rd
266-1829 5520 Mia/ Plantation Rd
773-1171 546-4197 8549 Old Baucom Road
772-7049 6216 Mial Plantation Rd
772-0739 8321 Old Baucom Road
661-5785 773-7184 2820 Brown Field
553-5667 1340 Pine .Trail
266-3073 5708 Mia/ Plantation Rd
553-5936 8208 Old Baucom Road
771-0714 6200 Mia/ Plantation Rd
553-7008 553-7008 6205 Firecracker
. . 6309 Mial Plantation
" " 6317 Shotwell/ Mial Plant.
August815 DWQ8/23
NO3 mg/L NO3 mgll
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
Confinn 9111 January 118 Confinn 2120 April July Oct Jan'04 April'04
NO3 mg/L NO 3 mg/L NO3 mgll NO3 mglL NO3 mg/L N03 mg/L NOamg/L NO 3 mglL
6.3 3.4 NIA NIA NIA NIA
3 1.4 1.6 1.6 NIA NIA
0.9 1.0 NIA N/A 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 N/A N/A
2.1 5 2.2 2.4 2.3 NIA N/A
0.5 0.5 NIA N/A NIA N/A
1.7 1.4 NIA NIA NIA N/A
23.5 52.9 20.3 23.1 20.3 N/A N/A
0.5 0.5 0.9 N/A NIA 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 N/A NIA
11.6 16.2 15.2 14.4 18.0 NIA NIA
7.4 2.6 2.9 NIA NIA NIA
8.9 20.5 6.9 8.5 8.7 8.7 7.8
o .. a. 0,5 0.5 0,5 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 N/A N/A N/A
7.8 13.9 7 4.8 8.5 NIA NIA N/A
July'04 Oct'04 Jan/Feb '05 April'05 August'05 Bottle Water
Currentl y
Bold indicates results greater GWQ std
NO3 mg/L NO3 mg/L N03 mg/L NO3 mg/L NO3 mg/L STATUS
agreement rec 4/22, CONNECT 6/10103, Well
NIA NIA NIA NIA NIA abandoned 11/26/2003
agreement rec 7/17, CONNECT .10114103, Well
N/A NIA NIA NIA NIA abandoned 11/18/2003
agreement rec 4125, CONNECT 6110103, Well
NIA N/A NIA N/A NIA abandoned 11/17/2003
agreement rec 7124, CONNECT 10/1103, Well
N/A NIA NIA NIA NIA NL abandoned 11/26/2003
agreement rec 12/29/03, CONNECT 6/22/04,
NIA NIA NIA NIA NIA Well abandoned 9/14/2004
2.5 1.3 NIA N/A NIA aareement rec 4/16/04 CONNECT9/28/04
agreement rec 12/20/03, CONNECT6/1/04,
NIA NIA NIA N/A NIA Well abandoned 09/09/2004
agreement rec 7/24, CONNECT 10/21/03, Well
N/A NIA NIA N/A NIA NL abandoned 4/30/2004
agreement rec 10/28, CONNECT 11118/03,
N/A NIA NIA NIA N/A Well abandoned 01/28/2005
agreement rec 4/25, CONNECT 5/29/03, Well
N/A N/A NIA NIA NIA abandoned 11/18/2003
City property, CONNECT5/29/03, Well
NIA NIA NIA N/A NIA abandoned 11/18/2003
agreement rec 7/24, CONNECT 10/21/03, Well
NIA N/A N/A N/A N/A 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 12/31/03, CONNECT6/2/04,
NIA NIA NIA NIA N/A Well abandoned 9/13/2004
agreement rec 9/13/04,.CONNECT 10/13/04,
3.7 6.4 N/A NIA N/A Welt abandoned 1/27/05
agreement rec 9/20/04,CONNECT10/19/04,
2.1 2.4 N/A NIA N/A Well abandoned 12/06/04
agreement rec 9/13/04,CONNECT10/12/04,
4.5 21 NIA NIA NIA NL Well abandoned 1/27/05
agreement rec 9/20/04,CONNECT10/20/04,
2.9 1.0 NIA NIA N/A Welt abandoned 1/26105
agreement rec 9/13104., CONNECT10/12/04,
7.4 7.3 NIA NIA NIA NL Well abandoned 1/26/05
agreement rec 11129/04, CONNECT, Well
4.9 4.1 0.5 NIA NIA abandoned 1/26/05
agreement rec 7/24, CONNECT 10122/03, Well
NIA NIA NIA NIA NIA abandoned 4128/04
agreement rec 7/24, CONNECT 12/2/03, Well
N/A NIA NIA NIA N/A NL abandoned 4/28/04
agreement rec 5/14, CONNECT 8/13/03, Well
NIA N/A NIA NIA NIA abandoned 11/26/03
agreement received 2005 . Well abandoned
4.4 6.1 3.4 8 N/A X 4/18/05
0-(j 0.5 0.7 0.1 <0,05 ,not armJl c,able -water service not available
agreement rec 9/20/04,CONNECT11/16/04,
7.2 4.8 N/A N/A N/A Welt abandoned 1/26/05
0.5 0.5 NIA N/A NIA City oro oertv Well abandoned
agreement rec 6/10/04, CONNECT9/16/04,
13.9 NIA NIA NIA NIA NL Well abandoned 1/27/05
agreement rec 12/07/03,CONNECT5/28/04,
NIA NIA NIA N/A NIA Well abandoned 918/04
agreement rec 6/9, CONNECT 8/4/03, Well
N/A NIA NIA NIA NIA NL abandoned 11 /17 /03
agreement rec 6/9, CONNECT 8/7/03, Well
NIA N/A N/A N/A NIA NL abandoned 11 /17 /03
1 of2
PRIVATE WELLS SAMPLED IN VICINITY OF NRWWTP ON DATES NOTED TO RIGHT
32
33
34
35
36
37
38
39
40
OWNER'S NAME
"
"
Debman Marda
Seawell Vira inia
Wheeler Pamela
Young, Evelyn
Belvin, La rry
City of Ralei oh
HEATER UTILITIES
Mattress Albert
Wood Wendv & Gerry
Doremus Stanley & Joan
Mcfarlino Mike & Beth
Norbero. Eric & Linda
Allemand Carlton & Lisa
Henderson Shanon
Coward Shirle v & Bill
.; Hiah, Jo1Jnnie
: Watk'fn$, Glenda
44 Kina Ronald
Debnam Rene/la 45
NOTES:
Home# Work# Address . . 2862 Shotwell Road
. . 4608 Roads Hill
5532 Mia/ Plantation
266-1823 5529 Mia/ Plantation Rd
219-2629 6029 Mia/ Plantation Rd
TT2-4762 8537 Old Baucom Road
553-7188 291-0520 2757 Shotwell Rd
553-5936 82 32 Old Baucom Road
467-7854 St JAMES SUBDIVISION
., .. 1 19 Jamison Dr Ral
127 Jamison Dr Rat
143 Jamison Dr
165 Jamison Dr
546-3318 186 Jamison Dr
269 Jamison Dr
TT3-9843 2750 Shotwell Road
266-3935 5509 Mia/ Plantation Road
26.6-2496 MQfJ Mitil Plantation Road
$()1-:2-92-82.21 5115 Mi~l Plan(!fltion Road
773-2303 2834 Shotwell Road
266-2387 5605 Mia/ Plantation Road
August8/5
NO3 mg/L .
5.5
4.3
3.1
5.8
17.8
31.8
1.5
These test wells are sampled triennially by the City and these analytical results have been provided by the City.
NO3, Nitrate
mg/L . milligrams per liter
Private water supply wells currently active (not abandoned) and in CORPUD's sampling program .
9039830_3.XLS
DWQ8/23
NOamg/L
"
16
3.2
TABLE 1
Private Well Nitrate Nitrogen Results and Water Supply/Service Status
Neuse River Waste Water Treatment Plant
Raleigh, North Carolina
Confirm 9/11 January 1/8 Confirm 2/20 April July Oct Jan'04 April'04
NO3 mglL NOa mg/L N03 mg/L NO3 mg/L NOamg/L NO3 mg/L NO3 mglL NO3 mg/L
" " " " NIA NIA N/A N/A
5.3 14.1 4.8 5.3 5.7 6.3 5.9 5.1
10.8 4 .1 5.4 4.8 4.4 5.3 5.0
6 3.7 3.3 3.0 3.1 3.7
5.2 15.1 7.7 8.5 11.5 11.9 14.5 15.0
15.1 38.5 12.5 18.4 18.5 NIA NIA
2.8 2 4.7 2.7 2.2 NIA NIA
2.2 2 1.8 0.5 1.1 1.0 0.6
16.7 8 .1 8.0 NIA NIA N/A N/A
5 .3 0 .5 0.5 NIA NIA NIA
3.2 6.2 10.4ll.1 5.2 4.3
6.4 3.6 3.5 4.0 4.8
6.4 .2:6 Z,6 3.2 3.$
5 5 .6 5.0 5 .6 5 .9
4.4 NIA
July'04 Oct'04 Jan/Feb '05 Apri l '05 August '05 Bottle Water Bold indicates results greater GWQ std
CurrenU v
NO3 mg/L NO3 mg/L NO3 mglL NO3 mglL NO3 mg/L STATUS
NIA NIA NIA NIA NIA " served by 6317 , CONNECT 8/7/03
agreement rec 12/07/03,CONNECT5/25/04,
NIA NIA NIA NIA NIA NL Well abandoned 919/04
agreement rec 3/11/04, CONNECT6/4/04, Well
NIA NIA NIA NIA NIA NL abandoned 1/26/05
agreement rec 7/8/04,CONNECT9/24/04, Well
4.1 0.6 NIA NIA NIA abandoned 1126/05
agreement rec 12130/03, CONNECT6/9/04,
NIA NIA NIA NIA NIA NL Well abandoned 917/04
agreement rec 8/21, CONNECT 10/21/03, Well
N/A N/A NIA NIA NIA NL abandoned 11/26/03
agreement rec 8/14, CONNECT 10/22/03, Well
N/A NIA N/A NIA N/A NL abandoned 4/29/04
2.6 1.2 NIA N/A N/A Cl tv oro oertv Well abandoned
N/A N/A NIA NIA NIA NL agreement rec 4/12 , CONNECT 4/25/03
NL see above
NL see above
NL see above
NL see above
NL see above
NL see above
agreement rec 5/9 , CONNECT 8/14/03, Well
NIA N/A N/A NJA NIA abandoned 11 /18/03
agreement rec 12/30/03, CONNECT6/9/04,
NIA NIA NIA N/A NIA NL Well abandoned 9/14/04
7.5 3.7 NIA 1.8 4.3 Active Well
2.5 1,9 NIA 2,.7 2.8 Active Well
agreement rec 1/21/04,CONNECT 9/2/04, Well
2.7 NIA NIA NIA NIA abandoned 12/06/04
agreement rec 9/20104, CONNECT10/21/04,
NIA NIA N/A N/A N/A Well abandoned1/26/05
2 012
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-1 12-16' 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
S83 4-8' Field 100 11/15/02
S83 8-12' F ield 100 11/15/02
S83 12-16' Field 100 11/15/02
S83 16-20' Field 100 11/15/02
S83 20-24' Field 100 11/15/02
SB-4 0-7" Field 100 12/12/02
S84 0-4' Field 100 11/15/02
S84 4-8' Field 100 11/15/02
S84 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
S85 16-24' Field 500 11/15/02
SB-6 0-7" Field 500 12/12/02
S86 0-4' Field 500 11/15/02
S864-8' 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
S86 16-20' 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 Field45
Field 49 Field 49
Field 50 Field 50
Field 73 Field 73
Field 511 Field 511
Notes:
TKN -To tal 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
Soll Analytical Results
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Ammonia Nitrate Nitrite Solids TKN
(m!llk!l) (mci lkci ) (mC1 lk ci l (%) l m a /ka l
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
0.23 J 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 .X LS\Table 2
TOC PAN· Surf PAN -Sub
(m !l lk A) mg /k g m g /kg
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\Table 3
Field
Samp le ID ID
TestWell 1 Field 12
TestWell 2 Field 28/32
Test Well 3 Field 49
TestWell4 Field 50
TestWell9 Field 39
TestWell 11 Field 3
TestWell 13 Field 42
TestWell 14 Field 33
TestWell 15 Fic·ld 16
TestWell 16 Field 35
TestWell 18 Field 27
TestWell 20 Field 20
TestWell 22 Field 16
TestWell 23 Plant
Test Well24 Plant
TestWell 25 Field 44/45
TestWell 29 Field 29
TestWell 30 Field 602
Test Well 30.1 Field602
TestWell 31 Field 602
TestWell 32 Field 602
TestWell 33 Field 602
TestWell 34 Field 602
TestWell 35 NA
TestWell 36 Field 602
TestWell37 Field 602
Test Well 41 Field 3
TestWell 42A Field 18/19
TestWell 43 Field 25
TestWell44 Field 26
TestWell 45 Field 47
TestWell 46 Field 61
TestWell 47 Field 61
TestWell48 Field 60
TestWell49 Field 74
TestWell 50 Field 75
TestWell51 (1) Field 12
TestWell 52 (1) Field 41
Test Well 53 11 ) Field 62
Test Well 54 11l Field 503
Test Well 641 Field 602
TestWell 642 Field 602
Test Well 31A Field 602
TestWell32A Field 602
TestWell45A Field 47
TestWell 618 Field 61
TestWell61C 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 Julv 2003 November 2003 March 2004 Julv 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/ 111.7
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 .9 / 75.4
ns ns ns ns 92 .3 /68.4
ns ns ns ns 67 .7 173.8
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 Wells 51, 52, 53, 54 were previously identified as GP-2. GP-7, GP-11, and GP-20, res pectively .
mg/L -Mill igrams per Li ter
na -not analyzed .
ns -not sampl ed.
NA -Informat ion 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
77,3 / 77.4 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
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
MW-100 Field 18 12 15 NA
MW-101 Field 31 160 120 NA
MW-1010 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 (Du p) 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-1110 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 (Du p ) Field 12 74 NA NA
GP-3 Field 6 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 of 2
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 f9 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 / NS -Not sampled
9039324_1 .XLS\Table 4 Page 2 of2
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:
TABLE6
Description of Proposed Variance Areas
City of Raleigh, Neuse River Wastewater Treatment Plant
Raleigh, North Carolina
Actual Land Use
Vacant, forested lot
Aqricultural land
Residence and agricultural
Forested land with residence
Agricultural land
Forested land with a power substation
Forested land
Agricultural 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 agricultural and forested land
Forested land
Agricultural land, small amounts of forested land
Cemete ry
Residence
Forested land
Ma ioritv forested and small portion of agricultural land
Residence
Agricultural, forested and aoo 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
Possibly
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
903464 7 _ 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 .
EXHIBIT 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 of biosolids 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 OF RALEIGH
Neuse Ri v er Waste Water Treatment Plant
Raleigh, North Carolina
Hu man Heal th R is k A ssessment
Prepared by:
INTERNATIONAL
ENSR Consulting and Engineering (NC), Inc.
7041 Old Wake Forest Road, Suite 103
Raleigh, North Carolina 27616
November 2005
EXHIBIT2
EN:R9
1Nli¥Xtt?OXZ fl
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 :IPUBSIPROJECT\R\Raleigh_Cily of\CAP
Work\Revised
CAP _Nov05\Risk_Assessmentl111805-
ii November. 2005
E~.
t&?ii;N#fik&tt◄
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
(US EPA , 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 1 O milligrams per liter (mg/l (USE PA, 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, B, 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, 1991 b); and
S:\PUBSIPROJECnRIRaleigh_City of\CAP Work\Revised CAP _Nov05\Risk_Assessmenl\11180S-Risk_Assessment.doc November. 2005
1-1
Etal.
t&2&Mttik4'/4M
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 evaluated. 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:\PUBS\PROJECT\R\Raleigh_City ot\CAP Wor11\Revised CAP _Nov0S\Risk_Assessment\111805-Risk_Assessment.doc November, 2005
1-3
EN3l.
dii¥ititrX¥tl
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= CWxSAxKpxAAFxETx 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)
S:IPUBSIPROJECT\R\Raleigh_Cily of\CAP Wor1<\Revised CAP _Nov05\Risk_Assessmentl111805-Risk_Assessment.doc
1-4
November , 2005
EN:R .
t4tiikl?4tllrXZtl
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 I kg-day)
RJD(mgl 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
S:\PUBSIPROJECT\R\Raleigh_City of\CAP Work\Revised CAP _Nov05\Risk_Assessmentl111805-Risk_Assessment.doc November, 2005
1-7
EN:R.
t&2it&tli❖Xtf.l
basis, while others do not. Some level of uncertainty is introduced into the risk characterization every
time an assumption is made.
In regulatory risk characterization, the methodology dictates that the analyst err on the side of
overestimating human risk whenever there is a question concerning the appropriate value to assume
for any given parameter. The effect of using numerous parameters that each overestimate the actual
or realistic value is that the risk characterization produces an exaggerated estimate of human risk.
Such an analysis is useful for regulatory decision making, but it does not provide a realistic estimate of
the potential health impacts at commercial or industrial sites. Any one person's potential exposure and
subsequent risk are influenced by many variable parameters, which differ for individuals and
compounds.
Although average concentrations better represent exposure potential over time, the maximum detected
concentration in surface water was used as the EPC. This has the effect of increasing the estimate of
potential risks . Both the maximum and average concentrations in groundwater were used for
evaluation of potential risks posed by groundwater.
The most recent groundwater data (2004 and 2005) were used to develop groundwater EPCs to
evaluate potential future risks from use of the groundwater as a potable or non-potable water source.
However, it is likely that the nitrate concentrations will diminish over time . Therefore, potential future
risks may be overestimated .
1.1.6 Summary
A baseline HHRA was conducted for nitrate in surface water and groundwater at the City of Raleigh
Wastewater Treatment Plant 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). EPCs for surface water were maximum detected
concentration from the last three sampling events and the average concentration (temporal and area).
Noncarcinogenic His were calculated for the ingestion and dermal routes of exposure. Based on
comparison of the His to the USEPA limit of 1.0, there were no unacceptable risks for exposure to
surface water or for exposure to groundwater used for a non-potable purpose (swimming pool).
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. 7 References
Agency for Toxic Substances and Disease Registry (ATSDR). 2005 . URL:
htt p://atsdr1 .atsdr.cdc.qov:8080/.
S:\PUBSIPROJECnRIRaleigh_City of\CAP Woo\Revised CAP _NoV05\Risk_Assessment\ 111805-Risk_Assessment.doc November, 2005
1-8
EtGR.
t&U¥-?,t1@16\&t◄
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 .7-018, 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. EPN600/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 05/01/2000. [URL:
http://www.e pa.g ov/re gion4/waste/oftecser/healthbul .htm]
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: http://www.epa.gov/iris/index.html.
Accessed November 16, 2005.
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1-9
-
TABLE 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+OO
Absorption Adjustment Factor (Oral and Dermal) 1.E+OO
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. ASTOR (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 .
S:\PUBS\PROJECT\R\Raleigh_City of\CAP Work\Revised CAP _Nov05\Risk_Assessment\TABLES .xls
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) -USEPA, 2000. USEPA 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) -USEPA, 2000 . US EPA Region 4 Human Health Risk Assessment Guidance. Default value.
(I) -Best professional judgment.
S:IPUBSIPROJECnRIRaleigh_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
HIJMAN 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 Medium (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)-USEPA, 1997. Exposure Factors Handbook. Recommended average for time 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
0 to 6 . Therefore, exposure factors for a Oto 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. PartE.
Supplemental Guidance for Dermal Risk Assessment. Default Value. Bathing exposure time is Reasonable
Maximum Exposure value.
(f) -USEPA, 1991. Standard Default Exposure Factors.
S:IPUBS\PROJECT\R\Raleigh_ City of\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
Test Well 47 Field 61 35 .0 D* 31.09 32.52 32 .9
TestWell48 Field 60 53.6 D* 41.00 37 .25 44.0
Test Well 49 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 1/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 dup 3 .5 NS NS NS
SW-20, du plicate averag e 3:55 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 gfield Creek Samplinci Stations
Other Tributaries, Neuse River
SW-1 52 49 NS 43
SW-2 0.39 13 NS NS
SW-3 52 50 NS d ry
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 # d ry
SW-27 NS 14 22 .9 # d rv
SW-28 NS 46 NS NS
Maximum, Other Tributaries Samplin g 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
TABLE 6
TOTAL POTENTIAL HAZARD INDEX
NEUSE RIVER WASTEWATER TREATMENT PLANT
RALEIGH, NORTH CAROLINA
Chemical
NHrate
Notes :
Ing/Denn -lngestion/Dennal Contact.
EPC -Exposure Point Concentrat ion
Surface Water -Child/Teenager
Other Neuse River Potable Water -
Bettlngfleld Creek Tributaries Maximum EPC
lng/Derm, lng/Derm. lng/Derm.
0.0004 0.002 5.2
S:IPUBSIPROJECT\R\Raleigh_City of\CAP Work\Revised CAP _Nov05\Risk_Assessment\TABLES .xls/6
Groundwater. Resident (Young Child)
Potable Water -Swimming Pool -Swimming Pool -
Average EPC Maximum EPC Average EPC
lng/Derm. lng/Derm. Ing/Dorm.
1.6 0.02 0,007
January, 2005
EXHIBIT3
TABLE 1 • JOHNSTON COUNTY PROPERTIES ADJACENT TO VARIANCE PARCELS
Number OWNJ;R ADDRESS Cn:Y 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, TONYLEE&MARTHAP 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 27520-6804
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 DRIVE CLAYTON NC 27520--8042
25 .J OHNSON, MALCOM DEWITT & CAROL P OBOX966 CLAYTON N C 27520-0966
26 BOON E,CAROLBEARD 422 BISCAYNE DRIVE WILMINGTON N C 28411--0000
27 HORN E,SARAHBEARD 21 4 TARPON CT NAGS HEAD NC 27959-0000
28 B ENSON, IRENE P 2501 OLD US 70 W CLAYTON NC 27520-6520
29 B ENSON, IR ENE LF EST &STEVEN 2501 OLD US 70 WEST CLAYTON NC 27520-6520
30 B ENSON, IRENE P 2501 OLD US 70 W CLAYrON NC 27520-6520
31 BENSON, IRENE P 2501 OLD US 70 W CLAYTON NC 27520-6520
32 STATE OF NC C/O STATE PROPERTY 116 W JONES STREET RALEIGH NC 27603-0000
33 ST A TE 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 EMAINST 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 PINE ST BENSON NC 27504-0000
40 JAMES M GILBERT INC PO BOX 236 CLAYTON NC 27520-0000
41 JAMES M GILBERT INC PO BOX 236 CLAYTON NC 27520-0000
42 JAMES M GILBERT INC POBOX236 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
#9051632v2
EXHIBIT 3
TABLE 2 -WAKE COUNTY PROPERTIES ADJACENT TO VARIANCE PARCELS
N!iiti.1/'1!' :QWl!ll:R AP.P.R!:~S CITY .ST~TI: 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
48 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 1109 PINE TRL 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 8500 OLD BAUCOM RD RALEIGH NC 27610-9266
56 DEBNAM, CATHERINE 5717 MIAL PLANTATION RD RALEIGH NC 27610-8529
57 SEAWELL, VIRGINIA D 5529 MIAL 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 1113PINETRL 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 OFCIO STATE PROPERTY OFFICE 116 W JONES ST RALEIGH NC 27603-1300
66 BROADWELL, BOBBY H & PAMELA S 1328 PINE TRL CLAYTON NC 27520-9324
67 HUNTER, TERI FULK TRUSTEE 1340 PINE TRL CLAYTON NC 27520-9324
68 BAKER, LULA ANNE BAKER, TIMOTHY JOEL 3345 STONEY CREEK DR CLAYTON NC 27520-5958
69 SARROCCO, NICHOLAS A & EUGENIA S 7820 OLD BAUCOM RD RALEIGH NC 27610-9252
70 BRUFF, MICHAEL S & KIMBERLY B 1312 PINE TRL CLAYTON NC 27520-9324
71 GAZDA, SHANE GAZDA, MARGERY CARNEY 2704 EMMETT CREST CT CLAYTON NC 27520-9322
72 ADAI\.IS, JIMMY C & TONDRA E 8-428 OLD BAUCOM RD RALEIGH NC 27610-9264
73 GARRETT, DARYL J & RAMONA C 7027 F ARMDALE RD RALEIGH NC 27610-9732
74 LEHOCKY, RICHARD D & BETTY A 1336 PINE TRL CLAYTON NC 27520-9324
75 GIL PAUL J & DARCY A 2708 EMMETT CREST CT CLAYTON NC 27520-9322
76 MCLEAN, ROBERTS & JOHNN IE F 1333 P INE TRL CLAYTON NC 27520-9345
77 SLAVIN , JAMES A & MARYE 1205 P INE TRL CLAYTON NC 27520-9361
78 CEBNAr,,I , SHIRLEY H 5700 MIAL PLANTATION RC RALEJGH NC 27610-8528
79 MCCLUNG, DOUGLAS E & AMY E 420 HARDWOOD RIDGE CT CLAYTON NC 27520-8603
80 BARBOUR, S\IVADE E JR HE IRS 326 LOMBAR ST CLAYTON NC 27520-0000
81 MALARKEY, WILLIAM J & CECELIA GALE 1325 PINE TRL CLAYTON NC 27520-9345
82 DEBNAM, RETHA M, DEBNAM, CHRISTOPHER HENRY W DEBNAM 1501 CHU RCHILL DOWNS DR WAXHAW NC 27173-6610
83 PHILLl!'S, LESTER L PHILLIPS REBECCA 2700 BALLOT RD CLAYTON NC 27520-9304
1M WOO. HEA K & CHUN I 3425 DEER TRACE LN CtAYTON NC 27520-5931
85 BALL, DOUGLAS 1027 HWY 70 W SUITE 225 GARNER NC 27529-0000
86 TALTON, MARGARET B 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 CHA!'ELHILL 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 !' 3005 HICKORY TREE PL RALEIGH NC 27610-8539
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 27610-8529
99 ROBERTSON~ETHRO,ETHELBARBOUR 1009 !'INE TRL CLAYTON NC 27520-9358
100 BIDDIX, THOMAS L & DEBORAH W 1117PINETRL CLAYTON NC 27520-9360
101 CHAMPION, ROBERT & MONA 2700 EMMETT CREST CT CLAYTON NC 27520-9322
102 MARRINER, LOUIS & FRANCES OWENS 1125PINETRL CLAYTON NC 27520-9360
103 QUINN , !'OLLY S !'OBOX132 HINESBURG VT 05461-0132
104 MCCARDLE, VAN R & CHERYL M 1105 PINE TRL CLAYTON NC 27520-9360
105 FREEMAN, DANNA F 1101 !'INE TRL CLAYTON NC 27520-9360
106 BAUCOM, JULIAN M 302 1 HICKORY TREE !'L RALEIGH NC 27610-8539
107 PRICE, RALPH L & BEVERLY W 1201 PINE TRL CLAYTON NC 27520-9361
108 MCKINNON, SWANOLA DEBNAM 5708 MIAL PLANTATION RD RALE IGH NC 27610•6528
109 REED CHARLES E 7020 FARMDALE RD RALEIGH NC 27610-9732
11 0 NORTH CAROLINA STATE OFCIO STATE PRO!'ERTY OFFICE 116 W JONES ST RALEIGH NC 27603-1300
111 KELLY, JOSE!'H A & JOAN B 1332 !'INE TRL CLAYTON NC 27520-9324
11 2 BELL, IAN & ELMA C 1308 PINE TRL CLAYTON NC 27520-9324
11 3 JONES, CHRISTOPHER & ANITA A 2025 ELAINE DR C LAYTON NC 27520,8212
114 PBR GROU!' LLC RTE 2 2400 BRANCH RD RALEIGH NC 27610-0000
115 !'ERK.INS, MARVIN CLAUDE & SUSAN J 6200 MIAL PLANTATION RD RALEIGH NC 27610-9643
118 RHODES, WILLIAM T & GWYN K 3751 E GARNER RD CLAYTON NC 27520-6541
118 GILBERT, JENNIFERP 273C BLUE POND RD CLAYTON NC 27520-7493
NOTES:
NA: f>arcel owner information not available on Wake County Geographic Information System
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EXHIBITJ
TABLE 3 -WAKE COUNTY VARIANCE PARCELS AND CITY OF RALEIGH PROPERTY
Ngrol),er OWNeR ADDRESS CITY STATE ZIP
119 NC STATE OF C/0 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/0 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 BOX 14042 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 PO BOX248 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 RR 1 KNIGHTDALE NC 27545-9801
138 DANIELS, EARL & JOELINE Y 5717 MIAL PLANTATION RD RALEIGH NC 27610-8529
139 NORTH CAROLINA STATE OF C/0 DEPT OF ADMINISTRATION 116 W JONES ST 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 PO BOX590 RALEIGH NC 27602-0590
143 ADAMS, JERRY WAYNE ADAMS , BRENDA DIANNE 8513 OLD BAUCOM RD RALEIGH NC 2 7610-926 7
144 H ASH, DAVID W & LINDA B 6216 MIAL PLANTATION RD RALEIGH NC 27610-9643
145 OR OWN, SHERRY ADAMS & STEPHEN DALE 135 RIDGE WAY LN CLAYTON NC 27620-8084
146 N A NA NA NA NA
147 BROWN, SYBLE B 8529 OLD BAUCOM RD RALEIGH NC 27610-9267
148 FRISON, BRENDA J 8549 OLD BAUCOM RD RALEIGH NC 27610 -9267
149 N A NA NA NA NA
150 HASH, DAVID W & LINDA B 6216 MIAL PLANTATION RD RALEIGH NC 27610-9643
151 YOUNG, EVELYN C 8537 OLD BAUCOM RO RALEIGH NC 27610-9267
152 RHODES, WILLIAM T & GWYN K 3751 E GARNER RO CLAYTON NC 27520-6541
153 ADAMS, BRENDA DIANNE D M ADAMS JR 8513 OLD BAUCOM RO 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 informatlon not available on Wake County Geographic Information System
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