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WQ0002708_Groundwater Monitoring Results Memo_20210913
Groundwater Monitoring Results Memorandum Wrenn Road Facility City of Raleigh Garner, NC September 13, 2021 F]? Table of Contents Introduction 1 Sampling Plan Review 2 Monitoring Well Installation 2 Sample Collection and Methods 4 Results 5 Results Summary 5 Arsenic Results 5 Iron Results 6 Manganese Results 7 Conclusions 8 List of Tables Table 1. Background Monitoring Well Summary 2 Table 2. Background Monitoring Well Results for Arsenic (November 2019 — March 2021) 5 Table 3. Background Monitoring Well Results for Iron (November 2019 — March 2021) 6 Table 4. Background Monitoring Well Results for Manganese (November 2019 — March 2021)7 List of Figures Figure 1. Background and Compliance Monitoring Wells 3 Figure 2. Iron Results 6 Figure 3. Manganese Results 7 Appendices Appendix 1 — Sampling and Data Analysis for Background Concentrations of As, Fe, and Mn in Groundwater (2021) Appendix 2 — Ground Water Monitoring Plan (2019) Appendix 3 — Wrenn Road Monitoring Well Installation Report (2019) Appendix 4 — Complete Groundwater Monitoring Results hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919)232-6600 Introduction The Wrenn Road Facility is located in Garner, NC, and currently receives water treatment process residuals from the Dempsey E. Benton (DE Benton) Water Treatment Plant (WTP). Liquid residuals are received through a 16-inch influent force main and spray -applied to the site's 14 irrigation zones, which are spread among over 600 acres of fields and woodlands. Historically, the facility disposed of treated wastewater from the Garner wastewater treatment plant (WWTP). The facility has been operated by Raleigh Water since the merger of Garner's water and wastewater utilities with the City of Raleigh (City) in 2001, and stopped receiving waste from the sewer system in 2008 when wastewater flow was permanently redirected to the Neuse River Resource Recovery Facility (NRRRF). A comprehensive hydrogeologic and geochemical evaluation was performed in 2010 to evaluate the site as part of the permit modification application'', 2. This study included the installation of over 20 temporary piezometers and three monitoring wells, in addition to groundwater flow, groundwater transport, and geochemical modeling. The two main purposes of the study were to: 1. Evaluate conditions before the DE Benton WTP residuals application, and 2. Identify recommended loading rates to the spray fields that would meet water quality levels established in the modified permit. The spray irrigation system and accompanying permit (WQ0002708) were modified to accept DE Benton WTP residuals in 2012. As part of this permit, North Carolina Department of Environmental Quality (NC DEQ) included the condition that the City prepare a monitoring plan to assess if background concentrations of arsenic, iron, and manganese were above the levels established in 15A NCAC 02L (referred to as "2L Standards"), which are as follows: • Arsenic: 10 micrograms per liter (pg/L) • Iron: 300 pg/L • Manganese: 50 pg/L Another goal of this sampling effort was to recommend site -specific background concentrations for these constituents that are either the existing 2L Standards or higher concentrations if data from the background samples is statistically greater than the standard. Data from the 2010 study was not used to establish background values because the wells were not permanent, and their sampling may not have met the currently recommended sampling methodology for metals. This memorandum provides an overview of the results obtained from the groundwater monitoring wells. A complete analysis of the results of the monitoring efforts, including a statistical analysis, is provided in Appendix 1, Sampling and Data Analysis for Background Concentrations of As, Fe, and Mn in Groundwater (Eagle Resources, P.A., 2021). This memorandum also briefly summarizes monitoring well installation and the sampling plan. Soil and Environmental Consultants, 2009, Site Analysis for Wrenn Road Wastewater Treatment Plant Spray Irrigation System, Garner, Wake County, North Carolina. 2 Eagle Resources, P.A. May 10, 2010, Groundwater Mounding Analysis and Groundwater Quality Assessment Wrenn Road Wastewater Treatment Plant Spray Irrigation System, Garner, Wake County, North Carolina. hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919)232-6600 1 Sampling Plan Review Future groundwater monitoring cannot be performed using the piezometers installed during the 2010 study since these piezometers were only designed to be temporary and have since been abandoned. The three monitoring wells are not adequate in number or location to use for the establishment of background concentrations. Therefore, a groundwater sampling plan was developed and four new background monitoring well locations were identified with approval from NC DEQ between February of 2017 and February of 2019. The complete sampling plan is provided in Appendix 2, Ground Water Monitoring Plan (2019). This sampling plan included information related to the following: • Installation and development of four (4) background monitoring wells at the Wrenn Road Facility, • Establishment of sampling duration and sample collection protocols, • Measurement of water quality parameters (iron, manganese, and arsenic) bi-monthly, • Determination of whether the 2010 sampling data are from the same population as 2019/2020 data, and its use in defining background statistics for groundwater monitoring, • Establishment of well maintenance protocols to ensure future resampling of wells can occur, if necessary. Monitoring Well Installation Four (4) background monitoring wells were installed in August of 2019. Background monitoring well information is summarized in Table 1, including geographic coordinates, installation dates, and depths. Figure 1 was developed by Eagle Resources, P.A. and presents a map of background and monitoring well locations. Well locations were selected using model analyses performed by Eagle Resources, P.A. and based on access requirements due to the development of the adjacent residential subdivision. Wells were drilled and completed with depths that extended at least into the Partially Weathered Rock (PWR) that lies beneath the soil and saprolite. Additional information related to well installation can be found in the Wrenn Road Background Monitoring Well Installation Report (2019), which is provided in Appendix 3. Table 1. Background Monitoring Well Summary el Easting Northing Installatio from Land Screened Name Date Surface (ft) Intervals (ft) PMW-1 • 2126151.11 691215.39 8/13/2019 43 33 to 43 PMW-2 2124505.08 691694.17 8/14/2019 20 10to20 PMW-3 2121970.60 688486.31 8/26/2019 16 6 to 16 PMW-4 2125522.18 687848.49 8/13/2019 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 74 64 to 74 2 F Mono.orknej Wells • Background Monl!oring Well • Compliance hloniLorrng well Prhlvrty Roundirie. IwAk! County GI'} Figure 1. Background and Compliance Monitoring Wells hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919)232-6600 3 Sample Collection and Methods The Ground Water Monitoring Plan (2019) provided in Appendix 2 describes the sample collection and methods followed during this project in detail. Groundwater samples were collected from each monitoring well on the same day during each sampling event. Before collecting groundwater samples, monitoring wells were purged at a low flow until turbidity reaches < 10 NTU or did not vary by more than 10%, and until pH and water temperature measurements were stable. One duplicate sample was collected from one of the background monitoring wells during each sampling event to evaluate consistency in field sampling methods and laboratory analytical methods. The first background monitoring well samples were collected in November of 2019 and monitoring well sampling continued every other month for six months (January of 2020 and March of 2020). Groundwater samples were measured by Raleigh Water staff in the field for pH, conductivity, turbidity, and temperature. Laboratory parameters for samples collected through November of 2020 were measured in the Raleigh Water laboratory for iron, manganese, and arsenic. Iron, manganese, and arsenic samples collected in March of 2021 were analyzed by an external laboratory. The 2019 and 2020 sampling results were compared to results from 2010 sampling events to evaluate any water quality changes that may have occurred. If these sampling results were deemed statistically similar to the 2010 results, the 2019/2020 results could be combined with 2010 results to serve as the background iron, manganese, and arsenic concentrations. If the results from the two sets of samples were statistically different, then only the 2019/2020 results would be used. The sampling dates for bi-monthly sampling were as follows: • November 21, 2019 • January 17, 2020 • March 12, 2020 After the completion of bi-monthly monitoring well sampling, background well monitoring continued using the same schedule used by Raleigh Water for existing compliance well monitoring. Sampling has occurred in April, August, and November of 2020 and in March of 2021 to evaluate data trends in iron, manganese, and arsenic. The dates for these sampling events are as follows: • April 14, 2020 • August 20, 2020 • November 4, 2020 • March 10, 2021 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919)232-6600 4 Results The purpose of this section is to provide an overview of arsenic, iron, and manganese results. The complete analysis of arsenic, iron, and manganese results is documented in Appendix 1, Sampling and Data Analysis for Background Concentrations of As, Fe, and Mn in Groundwater (2021), provided by Eagle Resources, P.A., and includes a statistical analysis to determine if data are similar to those obtained in 2010. During each sampling event, a log sheet was used to record sampling information (sample collector(s), date/time, and weather condition(s)), field data (depth to water, total well depth, volume of water purged before collecting the sample, turbidity, pH, temperature, and conductivity), and laboratory data (iron, manganese, and arsenic). Complete groundwater monitoring results are provided in Appendix 4. Results Summary Table 2, Table 3, and Table 4 present arsenic, iron and manganese results, respectively, from six sampling events occurring from November of 2019 to March of 2021. Many parameters were below detection limits. Arsenic Results Arsenic was below detection limits in each of the groundwater monitoring well samples collected from November of 2019 through March of 2021, as shown in Table 2. In samples collected from November of 2019 through November of 2020, the detection limit was 10 pg/L, which is also the 2L Standard. The arsenic detection limit was 5 pg/L for sample collected in March of 2021 due to the use of an external laboratory. Since data were below detection, a statistical analysis was not performed using arsenic data, and a time trend could not be developed . Table 2. Background Monitoring Well Results for Arsenic (November 2019 — March 2021) Well Arsenic (pg/L) — Detection Limit: 10 lag/L (November of 2019 through November of 2020) or 5 lag/L (March of 2021) — 2L Standard:10 pg/L Nov Jan Mar April Aug Nov March 2019 2020 2020 2020 2020 2020 2021 PMW-1 < 10 < 10 < 10 < 10 < 10 < 10 < 5 PMW-2 < 10 < 10 < 10 < 10 < 10 < 10 < 5 PMW-3 < 10 < 10 < 10 < 10 < 10 < 10 < 5 PMW-4 < 10 < 10 < 10 < 10 < 10 < 10 < 5 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 5 Iron Results Table 3 and Figure 2 present iron results from November of 2019 to March of 2021. Iron levels were often below the detection limits. Samples collected from November of 2019 to November of 2020 were analyzed using a method detection limit of 60 pg/L, whereas the sample collected in March of 2021 was analyzed using a method detection limit of 50 lag/L. Iron was detected in one sample collected from PMW-1, with a value of 97 pg/L (March of 2021). Iron was detected in two samples collected from PMW-2, with values of 72 pg/L (November of 2020) and 199 pg/L (March of 2021). Iron levels only exceeded the 2L Standard of 300 pg/L in two samples, both collected from PMW-3 (August of 2020 and March of 2021). There is a statistically significant increase in iron in PMW-3, and there is a statistically significant decrease in iron in PMW-4, which is described in detail in Sampling and Data Analysis for Background Concentrations of As, Fe, and Mn in Groundwater (Appendix 1). PMW-1 PMW-2 PMW-3 PMW-4 Table 3. Background Monitoring Well Results for Iron (November 2019 - March 2021) Iron (pg/L) — Detection Limit: 60 pg/L (November of 2019 through November of 2020) or 50 pg/L (March of 2021) — 2L Standard: 300 pg/L Nov Jan Mar April Aug Nov March 2019 2020 2020 2020 2020 2020 2021 < 60 < 60 < 60 < 60 < 60 < 60 < 60 < 60 199 < 60 141 < 60 172 68 < 60 < 60 700 600 500 J 'a 400 300 0 L 200 100 < 60 < 60 97 < 60 72 482 69 199 73 601 < 60 < 50 PMW-1 • PMW-2 ♦ PMW-3 PMW-4 —2L Standard • • •• • 0 rn rn 0 0 0 0 0 0 0 - N N N N N N N N N 1 1 1 Iffs I I 1 ++ I I Iff 7 U Z o li Q O 0 Date Figure 2. Iron Results hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 6 Manganese Results Table 4 and Figure 3 present manganese results from November of 2019 to March of 2021. Manganese levels were below detection in many samples collected from PMW-2 and PMW-3. Samples collected from November of 2019 to November of 2020 were analyzed using with a method detection limit of 50 pg/L, whereas the sample collected in March of 2021 was analyzed using a method detection limit of 10 pg/L. Manganese exceeded the 2L Standard of 50 pg/L in each sample collected from PMW-1, one sample collected from PMW-3 (March of 2021), and a majority of samples collected from PMW-4. There is no statistically significant increase in manganese in monitoring wells, which is described in detail in Sampling and Data Analysis for Background Concentrations of As, Fe, and Mn in Groundwater (Appendix 1). Table 4. Background Monitoring Well Results for Manganese (November 2019 — March 2021) Well Manganese (pg/L) — Detection Limit: 50 pg/L (November of 2019 through November of 2020) or 10 pg/L (March of 2021) — 2L Standard: 50 pg/L Nov Jan Mar April Aug Nov March 2019 2020 2020 2020 2020 2020 2021 PMW-1 90 74 64 70 88 59 71 PMW-2 < 50 < 50 < 50 < 50 < 50 < 50 16 PMW-3 PMW-4 200 180 160 �,140 120 100 • a 80 • Fa 60 • )1( 2 40 < 50 < 50 < 50 < 50 134 < 50 88 < 50 < 50 176 96 123 88 71 • PMW-1 • PMW-2 PMW-3 PMW-4 —2L Standard ♦ 20 ♦ 0 am am 0 0 0 0 0 0 0 r N N N (-1N N N N N (.1.1 1 1 i 1 1 1 �+ 1 L —) Date Figure 3. Manganese Results hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 7 Iron and manganese results were used to develop probability curves and conduct an Analysis of Variance Analysis (ANOVA). These exercises were conducted by Eagle Resources, P.A. to determine if iron or manganese measured from November of 2019 through March of 2021 were statistically similar to the results obtained in 2010. Based on this analysis, the data from the 2010 study is not statistically from the same population as the data from the compliance and new background wells and should not be used in assessing site -specific background standards. Conclusions Arsenic levels remained below the detection limits of 10 pg/L (through November of 2020) and 5 pg/L (March of 2021) throughout the monitoring efforts conducted as part of this study. Therefore, there is no statistical reasoning for setting a site -specific standard for arsenic greater than the 2L Standard of 10 pg/L. Data from the 2010 iron and manganese study and results reported as part of the November of 2019 to March of 2020 sampling are not statistically from the same population. Therefore, the 2010 data should not be used to assess site -specific background standards for iron and manganese. Iron levels were below detection in a majority of samples and exceeded the 2L Standard in two samples (PMW-3, August of 2020 and March of 2021). Since the distributions for iron samples are less than the 2L Standard of 300 pg/L, the 2L Standard should be used for compliance purposes based on the data obtained to date. However, iron levels have changed over time in some of the compliance and background wells since the start of compliance sampling in November of 2019. Therefore, it is recommended to continue assessing iron levels on an annual basis to determine if the iron standard for the site should be increased to a value greater than the 2L Standard in the future. Manganese levels were below detection in many samples, but above the detection limit and 2L Standard in each of the samples collected from PMW-1 and PMW-4 and one sample collected from PMW-3 (March of 2021). Additionally, the average manganese concentration was 66 pg/L, which is greater than the 2L standard of 50 pg/L; therefore, it is recommended that the site - specific background concentration for manganese be set at 66 pg/L. hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919)232-6600 8 1 Sampling and Data Analysis for Background Concentrations of As, Fe, and Mn in Groundwater (2021) 4alie it'escrrces Sampling and Data Analysis for Background Concentrations of As, Fe, and Mn in Groundwater Wrenn Road Wastewater Treatment Facility, Garner, NC Prepared for: HDR Engineering, Inc. of the Carolinas and City of Raleigh Public Utilities Department March 18, 2021 Updated July 27, 2021 Eric G. Lappala, P.E. Eagle Resources, P.A 215 West Moore Street Southport, NC 28461 919-345-1013 www.eagleresources.com 1 tale Pe5otirces Table of Contents Introduction 1 Installation of new Background Monitoring Wells 1 Sampling of Background and Compliance Wells 3 Data Analysis 4 Probability Plots 4 Analysis of Variance 9 Pooling of new samples and the 2010 samples 12 Time Trends 13 Conclusions 17 Attachment 1 Approved Background Sampling Program 18 Attachment 2 Sampling Reports from CORPUD 19 Figures Figure 1.-- Location of compliance and background wells and wells and piezometers sampled for the 2010 report 2 Figure 2.-- Cumulative probability plots for the log -transformed concentrations of Fe for background samples and 2010 report unfiltered samples. 5 Figure 3.-- Cumulative probability plots for concentrations of Fe for background samples and 2010 report filtered samples. 6 Figure 4.-- Cumulative probability plots for concentrations of Fe in compliance wells and new background wells 7 Figure 5.-- Cumulative probability plots for concentrations of Mn for background samples and 2010 report filtered samples. 7 Figure 6.-- Cumulative probability plots for concentrations of Mn for background samples and 2010 report filtered samples. 8 Figure 7.-- Cumulative probability plots for concentrations of Mn from compliance and new background wells 9 Figure 8.-- Time trend in Fe and Mn in compliance well MW-B3. 13 Figure 9.-- Time trend in Fe and Mn in compliance well MW-B9. 14 Figure 10.-- Time trend in Fe and Mn in new background well PMW-3. 15 Figure 11.-- Time trend in Fe and Mn in new background well PMW-4. 16 i Tables Table 1.-- Results of laboratory analyses for As, Fe, and Mn from the background and compliance wells sampled in 2019 and 2020. 3 Table 2.-- Results of laboratory analyses for As, Fe, and Mn from wells and piezometers reported in the 2010 report 4 Table 3.-- One-way ANOVA comparing the 2020 background values for Fe to the values for unfiltered samples from 2010. 9 Table 4.-- One-way ANOVA comparing the 2020 background values for Fe to the values for filtered samples from 2010. 10 Table 5.-- One-way ANOVA comparing the 2020 background values for Fe from the compliance wells and the new background wells. 10 Table 6.-- One-way ANOVA comparing the 2020 background values for Mn to the values for unfiltered samples from 2010. 11 Table 7.-- One-way ANOVA comparing the 2020 background values for Mn from the compliance wells and the new background wells. 11 Table 8.-- One-way ANOVA comparing the values for Mn from the compliance wells vs. the new background wells 12 Table 9.-- Regression analysis for the significance of the slope of the regression line for Fe in MW-B3. 13 Table 10.-- Regression analysis for the significance of the slope of the regression line for Fe in MW-B9. 14 Table 11.-- Regression analysis for the significance of the slope of the regression line for Fe in PMW-3. 15 Table 12.-- Regression analysis for the significance of the slope of the regression line for Fe in PMW-4. 16 Table 13.-- Regression analysis for the significance of the slope of the regression line for Mn in PMW-4. 16 ii Introduction This report documents the methodology recommended in the approved monitoring plan', and changes to that methodology and the reasons for same to determine the statistically valid background concentrations of Fe and Mn at the Wrenn Road Site. This update includes the results from samples collected on 03/10/2021 which concludes the approved sampling period. The methodology is summarized as follows: • Install new monitoring wells to assess concentrations of As, Fe and Mn that are hydraulically up gradient or cross gradient from any field area to which treated effluent has been or may be applied. • Sample the new wells and the three existing compliance wells (MW-B3, MW-B8m and MW-B9) bi-monthly for one year using the purging and turbidity testing protocol specified in the approved plan to reduce or eliminate high -turbidity samples (background samples). • Compare the laboratory -determined concentrations of the three constituents in background samples with the ones from samples collected from monitoring wells and temporary piezometers as reported in the 2010 site investigation report2 to answer the following questions: 1. Are concentrations of the three constituents from the background samples statistically same as those in Table 8 of the 2010 report (unfiltered samples)? 2. Are the filtered sample concentrations of the three constituents in Table 9 of the 2010 report statistically the same as those from the background samples? 3. Are concentrations of the three constituents from the background samples from the new wells from the same population as those from the three compliance wells? • Based upon the answers to these questions, recommend a site -specific background concentration for all three constituents that is either the existing NC 2L groundwater standard or a higher concentration if data from the background samples is statistically greater than the standard. Installation of new Background Monitoring Wells The monitoring plan called for the installation and development of five (5) new background monitoring wells. Owing to the availability of suitable background locations only four background wells (PMW-1, PMW-2, PMW-3 and PMW-4) were approved by NC DEQ and installed as shown in Figure 1. The installation details, turbidity testing during development and hydraulic conductivity testing of these wells was documented in our 2019 letter report3 which is included as Attachment 1 to this report. Figure 1 also shows the location of wells and piezometers from which samples were analyzed for As, Fe, and Mn as documented in the 2010 site investigation report. Where two piezometers are shown at the same location they were completed at different depths. Note that MW-3 will be removed as the result of the construction of the I-540 corridor. 1 Eagle Resources, P.A.: Final_Groundwater_Baseline_Quality_Monitoring_Rev_020317 2 Eagle Resources, P.A.: Groundwater Mounding Analysis and Groundwater Quality Assessment, Wrenn Road Wastewater Treatment Plant Spray Irrigation System, Garner, Wake County, North Carolina 10, 2010 3 Eagle Resources, P.A.: Documentation of Background Monitoring Well Installation and Testing, Letter Report to HDR dated 11/08/19 1 aqi/e Pe5arcee EXPLANATION Wells and Piezometers ® Background Monitoring Well S Compliance Monitoring Well • Non -Compliance Monitoring Well O Piezometer Nest - Two depths • Piezometer Field Boundaries Active Closed owing to 1-540 impacts Property Boundaries (Wake County GIS) 500 0 500 1,000 1,500 2,000 Ft Figure 1.-- Location of compliance and background wells and wells and piezometers sampled for the 2010 report. 2 tale Pescces Sampling of Background and Compliance Wells The monitoring plan recommended that the background and compliance wells (MW-B3, MW-B8 and MW-B9) be sampled bi-monthly for one year following the installation and development of the new wells. The sampling was to follow the recommended procedure for low flow purging and field analysis for pH, conductivity, turbidity and temperature. Samples taken were to be analyzed in the City of Raleigh Public Utilities Department (CORPUD) laboratory for As, Fe and Mn. One duplicate sample was to be taken from a randomly selected background well each sampling round. CORPUD staff obtained the samples from the background and compliance wells using the protocol recommended in the monitoring plan and submitted the samples to the CORPUD laboratory. The results of these analyses are summarized in Table 1 and the sampling reports are included as Attachment 2 to this report. Note that duplicate analyses are only available for the last three sampling rounds (8/20/20, 11/4/20 and 3/10/21). Table 2 shows the values for As, Fe, and Mn from Tables 8 and 9 of the 2010 report. Constituent Date MW-B3 MW-B8 MW-B9 PMW-1 PMW-2 PMW-3 PMW-4 PMW-1 Dup ug/I ug/I ug/1 _ ug/I ug/I ug/I ug/I ug/I As 11/5/19 <10 <10 <10 <10 <10 <10 <10 ns 1/17/20 <10 ns ns <10 <10 <10 <10 ns 3/12/20 <10 <10 <10 <10 <10 <10 <10 ns 4/14/20 <10 0 0 0 ns ns <10 ns 7/8/20 <10 <10 <10 ns ns ns ns ns 8/20/20 <10 ns na <10 <10 <10 <10 <10 11/4/20 <10 <10 <10 <10 <10 <10 <10 <10 3/10/21 <5 ns ns <5 <5 <5 <5 <5 Fe 11/5/19 180 76 82 <60 <60 199 172 ns 1/17/20 98 ns ns <60 <60 <60 68 ns 3/12/20 <60 <60 89 <60 <60 141 <60 ns 4/14/20 65 ns ns <60 <60 <60 <60 ns 7/8/20 234 <60 166 ns ns ns ns ns 8/20/20 118 ns ns <60 <60 482 69 <60 11/4/20 301 <60 135 <60 72 73 <60 <60 3/10/21 108 ns ns 97 ns ns ns 132 Mn 11/5/19 <50 <50 <50 90 <50 <50 134 ns 1/17/20 <50 ns ns 74 <50 <50 <50 ns 3/12/20 <50 <50 <50 64 <50 <50 88 ns 4/14/20 <50 ns ns 70 <50 <50 96 ns 7/8/20 <50 <50 <50 ns ns ns ns ns 8/20/20 <50 ns ns 88 <50 <50 123 90 11/4/20 <50 <50 <50 59 <50 <50 88 61 3/10/21 <10 ns ns 71 16 176 71 71 Notes: ns = no sample collected. Table 1.-- Results of laboratory analyses for As, Fe, and Mn from the background and compliance wells sampled in 2019 and 2020. 3 Well As Fe Mn Unfiltered Filtered Unfiltered Filtered Unfiltered Filtered Round 1 Round 2 Round 2 Round 1 Round 2 Round 2 Round 1 Round 2 Round 2 ug/I ug/I ug/I ug/I ug/I ug/I ug/I ug/I ug/I MW-1 42 8 <50 11742 4157 16 1067 220 26 MW-2 8 ns ns 6369 ns ns 628 ns ns MW-3 8 <50 <50 42 2497 39 371 ns 101 PZ-1 68 10 <50 3834 799 130 ns 1812 1676 PZ-2 61 11 <50 11694 2324 12 ns 443 91 PZ-3 9 ns ns 3024 ns ns ns ns ns PZ-4 24 <50 <50 26276 921 78 4432 339 331 PZ-5 82 <50 <50 30202 153 8 4114 52 43 PZ-6 24 <50 <50 69147 28581 22710 561 1628 1968 PZ-7 111 6 <50 23603 1709 77 2163 144 47 PZ-8 61 <50 <50 31936 272 17 3160 21 19 PZ-9 24 ns ns 6921 ns ns 3460 ns ns PZ-10 16 <50 <50 6958 578 22 3238 106 85 PZ-11 <50 ns ns 1406 ns ns 428 ns ns PZ-12 31 <50 <50 10303 512 38 842 38 32 PZ-14 ns ns ns 1523 ns ns 553 ns ns PZ-15 ns ns ns 684 ns ns 20 ns ns PZ-16 6 ns ns 2388 ns ns 250 ns ns PZ-17 16 ns ns 2294 ns ns ns ns ns PZ-18 42 <50 <50 6160 606 103 334 37 51 PZ-19 6 ns ns 3140 ns ns 220 ns ns ns = no sample collectred Table 2.-- Results of laboratory analyses for As, Fe, and Mn from wells and piezometers reported in the 2010 report. Data Analysis Because all the values for As were below the method detection limit of 10 µg/1 for all samples, no statistical analysis was performed for this constituent. To perform the analyses on Fe and Mn using all values from the background samples that were less than the laboratory reported detection limits (10 µg/1 for Mn and 60 µg/1 for Fe) value of one (1) µg/l less that the limits was assigned (49 µg/1 for Mn and 59 µg/1 for Fe). To answer the three questions posed previously, the concentrations of As, Fe, and Mn were compared by: • Examination of plots of their log probability distributions; and • Using One -Way Analysis of Variance (ANOVA) Both statistical measures were computed using Microsoft ExcelTM Probability Plots The cumulative probability distributions of the log -transformed (ln or log base e) for Fe and Mn for the background samples (compliance wells plus background wells), for the 2010 unfiltered samples and for the 2010 filtered samples were computed and plotted for visual comparison. Figure 2 shows the probability curves for Fe in the background samples and for the 2010 unfiltered samples. This comparison shows that the Fe samples from the 2010 report are not from the same 4 eaie &mime population as the background samples. Fe concentrations for both sets of samples are approximately log - normally distributed based on the apparent fit of the curves to the data points. 1.0 0.9 0.8 ▪ 0.7 to • 0.6 0 0.5 0.4 0.3 0.2 0.1 0.0 Fe All 2020 & 2021 and 2010 Unfiltered • • L a i ■ • In Fe 2020& 2021 Dist In Fe 2020 & 2021 — —Norm • In Fe 2010, unriltered Norm Dist In Fe 2010 • In Fe2LStandard — I I I 0 2 4 6 In(Fe, ug/l) 8 10 12 14 Figure 2.-- Cumulative probability plots for the log -transformed concentrations of Fe for background samples and 2010 report unfiltered samples. Figure 3 shows the probability curves for Fe in the background samples and for the 2010 filtered samples. This comparison shows that the filtered Fe samples from the 2010 report are closer to the same population as the background samples but still probably not equal. Fe concentrations for both sets of samples are approximately log -normally distributed based on the apparent fit of the curves to the data points. 5 1.0 0.9 0.8 . ' 0.7 2 - 0.6 0 L 0.5 0.4 0.3 0.2 0.1 0.0 Fe All 2020 & 2021 and 2010 Filtered • • • • • • ....•. • s s s • • • • . • In Fe 2020 & 2021 Dist In Fe 2020 & 2021 In Fe 2010, filtered Dist In Fe 2010 In Fe2LStandard -Norm • -Norm • I I I 0 2 4 6 In(Fe, ug/I) Figure 3.-- Cumulative probability plots for concentrations of Fe for background samples and 2010 report filtered samples. 8 10 12 14 Figure 4 shows the probability curves for Fe in the background samples from the new background wells and from the compliance wells. This comparison shows that Fe from the compliance wells and from the new wells are from the same population and therefore can be pooled. Because the distributions for the pooled samples for Fe are less than the 2L standard, the 2L standard of 300 1.1,g/1 should be used for compliance purposes to establish the site -specific background value of Fe concentrations for both sets of samples are approximately log -normally distributed based on the apparent fit of the curves to the data points. 6 1.0 0.9 0.8 0.5 0.4 0.3 0.2 0.1 0.0 Fe Compliance and Background Wells • . • • • • • ■ • In FeComplianceWells Dist In Fe Compliance Wells Wells Dist In Fe Background Wells L Standard -Norm • In Fe Background -Norm • In Fe 2 2 3 4 5 In(Fe, ugil) 6 7 Figure 4.-- Cumulative probability plots for concentrations of Fe in compliance wells and new background wells. 8 Figure 5 shows the probability curves for Mn in the background samples and for the 2010 unfiltered samples. This comparison shows that the Mn samples from the 2010 report are not from the same population as the background samples. Mn concentrations for both sets of samples are approximately log -normally distributed based on the apparent fit of the curves to the data points. 1.0 0.9 0.8 0.7 n 0.6 0 a 0.5 0.4 0.3 0.2 0.1 0.0 Mn All 2020 & 2021 and 2010 Unfiltered • • • • • • InMn2020&2021 — In —Norm Dist Mn 2020 & 2021 • • In Mn2010, unfiltered In —Norm Dist Mn2010 _ • In Mn2L Standard __ I I I I 0 1 2 3 4 5 In(Mn), ug/I 6 7 8 9 10 Figure 5.-- Cumulative probability plots for concentrations of Mn for background samples and 2010 report filtered samples. 7 Figure 6 shows the probability curves for Mn in the background samples and for the 2010 filtered samples. This comparison shows that the filtered Mn samples from the 2010 report are closer to the same population as the background samples but still probably not equal. Mn concentrations for both sets of samples are approximately log -normally distributed based on the apparent fit of the curves to the data points. 1.0 0.9 0.8 0.7 0.6 L d 0.5 0.4 0.3 0.2 0.1 0.0 Mn All 2020& 2021 and 2010 Filtered • • • • • • • • • • • In Mn2020 &2021 Dist In Mn2020 Mn 2010, filtered Dist In Mn2010 Mn2LStandard Norm • In -Norm • In • -- 1 1 1 1 0 1 2 3 4 5 In(Mn), ug/I 6 7 8 9 10 Figure 6.-- Cumulative probability plots for concentrations of Mn for background samples and 2010 report filtered samples. Figure 7 shows the probability curves for Mn in the background samples from the new background wells and from the compliance wells. This comparison shows that Mn from the compliance wells and from the new wells are approximately from the same population but the compliance well data is skewed by all being at the detection limit of 50 1.1g/1. Mn concentrations for both sets of samples are approximately log -normally distributed based on the apparent fit of the curves to the data points. The mean of the distributions for Mn when all data from the background and compliance wells are considered is less than the 2L standard because of the large number of values less than the detection concentration of 50 µg/1. Therefore, if the data from all of these wells is considered, the 21 standard of 50 µg/1 should be used for compliance purposes. However, if only PMW-1 and PMW-4 are used to establish the site -specific background concentration of Mn, there is statistical support for increasing it. The mean Mn value for all samples from these two wells is 86 µg/1 and the standard deviation is 22 µg/1. If only these two wells are used, it is recommended that the site -specific background concentration be set at 80 µg/1. The large number of non -detect concentrations of Mn in the compliance wells is likely the result of dilution by historical irrigation applied to their up -gradient fields. The non -detect values of Mn in PMW-2 and PMW-3, which are located cross -gradient from all sprayfields, is likely the result of dilution from surface runoff and flow in the stream located between them and the sprayfields. 8 1.0 0.9 0.8 0.7 si cv 0.6 0.5 0.4 0.3 0.2 0.1 0.0 Mn Compliance and Background Wells l •• • r. r . • In MnComp liance Wells Dist In Mn Compliance Wells -Norm • In Mn Background Wells Norm Dist In Mn Ba Wells ckg ro and • In Mn2L Standard 2 3 4 5 In(Mn), ug/I Figure 7.-- Cumulative probability plots for concentrations of Mn from compliance and new background wells. 6 7 8 Analysis of Variance One-way Analysis of Variance (ANOVA) on the log -transformed values to further assess whether the new background results from the compliance and background wells are from the same population as the 2010 samples. The analyses were conducted using the Data Analysis Package for Microsoft ExcelTM Table 3 shows the ANOVA for Fe between the background samples and the unfiltered 2010 samples. Because the F-statistic value of 8.85 is greater than the Fcrit value of 3.96, the samples are not from the same population, consistent with the probability plot analysis. Fe Background +Compliance Wells vs 2010 Unfiltered Samples Anova: Single Factor Alpha = 0.01 Groups Count Sum Average Variance In Fe Background Samples 46 237.64 5.17 29.83 38 322.25 8.48 20.95 In Fe2010 Unfiltered Samples ANOVA Source of Variation SS df MS F P-value F crit Between Groups 228.5736 1 228.57 8.85 0.00 3.96 Within Groups 2117.4 82 25.82 Total 2345.973 83 Table 3.-- One-way ANOVA comparing the 2020 background values for Fe to the values for unfiltered samples from 2010. 9 eajle ie:AGir e5 Table 4 shows the ANOVA for Fe between the background samples and the filtered 2010 samples. Because the F-statistic value of 0.14 is less than the Fcrit value of 4.00, the samples are from the same population, consistent with the probability plot analysis and may be pooled. Fe Background +Compliance Wells vs 2010 Filtered Samples Anova: Single Factor Alpha = 0.01 Groups Count Sum Average Variance In Fe Background Samples 46 237.64 5.17 29.83 In Fe2010 Filtered Samples 17 79.05 4.65 9.27 ANOVA Source of Variation SS df MS F P-value F crit Between Groups 3.30 1 3.30 0.14 0.71 4.00 Within Groups 1490.62 61 24.44 Total 1493.93 62 Table 4.-- One-way ANOVA comparing the 2020 background values for Fe to the values for filtered samples from 2010. Table 5 shows the ANOVA for Fe between the samples from the new background wells and the compliance wells for the 2019-2020 background sampling period. Because the F-statistic value of 2.11is less than the Fcrit value of 4.11, the samples are from the same population, consistent with the probability plot analysis and may be pooled. Fe Background Wells vs Compliance Wells Anova: Single Factor Alpha = 0.01 Groups Count Sum Average Variance In Fe Compliance Wells 12 54.93 4.58 0.34 In Fe Background Wells 26 111.98 4.31 0.26 ANOVA Source of Variation SS df MS F P-value F crit Between Groups 0.60 1 0.60 2.11 0.16 4.11 Within Groups 10.27 36 0.29 Total 10.87 37 Table 5.-- One-way ANOVA comparing the 2020 background values for Fe from the compliance wells and the new background wells. Table 6 shows the ANOVA for Mn between the background samples and the unfiltered 2010 samples. Because the F-statistic value of 2.36 is slightly less than the Fcrit value of 3.97, the samples are from the same population, consistent with the probability plot analysis. 10 Ea�eeesarces Mn Background +Compliance Wells vs 2010 Unfiltered Samples Anova: Single Factor Alpha =0.01 Groups Count Sum Average Variance In Mn Background 46 220.72 4.80 30.17 In Mn 2010 Unfiltered 33 216.32 6.56 18.07 ANOVA Source of Variation SS df MS F P-value Fcrit Between Groups 59.32 1 59.32 2.36 0.13 3.97 Within Groups 1936.00 77 25.14 Total 1995.32 78 Table 6.-- One-way ANOVA comparing the 2020 background values for Mn to the values for unfiltered samples from 2010. Table 7 shows the ANOVA for Mn between the background samples and the filtered 2010 samples. Because the F-statistic value of 1.93 is less than the Fcrit value of 4.05, the samples are from the same population, consistent with the probability plot analysis and may be pooled. The differences between the two populations are the result of assigning a value of 49 µg/1. to samples that were reported to be below the detection limit of 50 µg/l. Mn Background +Compliance Wellsys 2010 Filtered Samples Anova: Single Factor Alpha = 0.01 Groups Count Sum Average Variance In Mn Background 33 216.32 6.56 18.07 In Mn 2010 Filtered 16 79.48 4.97 5.66 ANOVA Source of Variation SS df MS F P-value Fcrit Between Groups 27.1682947 1 27.17 1.93 0.17 4.05 Within Groups 663.187462 47 14.11 Total 690.355756 48 Table 7.-- One-way ANOVA comparing the 2020 background values for Mn from the compliance wells and the new background wells. Table 8 shows the ANOVA for Mn between the samples from the new background wells and the compliance wells for the 2019-2020 background sampling period. Because the F-statistic value of 5.95 is close to the Fcrit value of 4.09, the samples probably are from the same population, consistent with the probability plot analysis and may be pooled. The differences between the two populations are the result of assigning a value of 49 µg/1 to samples that were reported to be below the detection limit of 50 µg/1. 11 Mn Background vs Compliance Wells Anova: Single Factor Alpha = 0.01 Groups Count Sum Average Variance In Mn Compliance Wells 11 42.81 3.89 0.00 In Mn Background Wells 30 123.77 4.13 0.10 ANOVA Source of Variation SS df MS F P-value F crit Between Groups 0.44 1 0.44 5.95 0.02 4.09 Within Groups 2.89 39 0.07 Total 3.33 40 Table 8.-- One-way ANOVA comparing the values for Mn from the compliance wells vs. the new background wells. Pooling of new samples and the 2010 samples The monitoring plan recommended that if samples from the background sampling were statistically from the same population as those from the 2010 study that they should be pooled to determine if they should be used to set site -specific background concentrations for Fe and Mn. Because the statistical analyses in the foregoing show that the 2011 unfiltered sample results for both Fe and Mn are not from the same population as those from the background monitoring program samples to date the 2011 unfiltered samples should not be used in an assessment of a site -specific background standard for either Fe or Mn. The filtered samples from 2011 for both Fe and Mn appear to approximately from the same population as the background monitoring program samples. This is likely because purging and sampling protocol used for the background program accomplished the same reduction in turbidity and suspended fine particulate matter as filtration did for the 2010 samples. Because filtration of samples is not included in the accepted sampling and analysis protocol by NC DEQ, it is recommended that the 2010 filtered sample data not be used in assessing site -specific background standards for either constituent. 12 ea* Pesarces Time Trends The monitoring plan recommended sampling the new background wells for one year on the same schedule used for the compliance wells (March, July, and November) to evaluate any time trends in As, Fe, Mn to consider in compliance assessments. The values plotted and analyzed below are not log -transformed as the conclusions reached regarding the significance of the slope of the trend lines is not affected by the transformation. Plots are only included for those wells in which the number of sample results greater than the detection limits for either Fe or Mn provided for a meaningful analysis. Figure 8 and Table 9 show that there is no statistically significant increase in Fe in MW-B3 because the F -statistic value of 0.42 shown in Table 9 is less than the Significance F value of 0.54. [Fe] & [Mn], ug/I 350 300 250 200 150 100 50 0 0 Fe and Mn in MW-B3 I I • • Fe MW-B3 Mn • MW-B3 Linear (Fe MW-B3) Linear (Mn MW-B3) • • .................. • • • _ _ • ....•• ...... ♦ • • • 100 200 300 Days since 11/01/2019 Figure 8.-- Time trend in Fe and Mn in compliance well MW-B3. 400 500 Regression Statistics ANOVA Multiple R 0.257 RSquare 0.066 df SS MS F SignificanceF Adjusted RSquare -0.090 Regression 1.00 3406.05 3406.05 0.42 0.54 Standard Error 89.608 Residual 6.00 48177.82 8029.64 Observations 8 Total 7.00 51583.88 Coefficients Standard Error tStat P-value Lower95% Upper95% Lower95.0% Upper95.0% Intercept 114.84 56.59 2.03 0.09 -23.62 253.30 -23.62 253.30 0.211 0.65 0.541 -0.38 0.651 -0.38 0.65 X Variable 1 ` 0.14 Table 9.-- Regression analysis for the significance of the slope of the regression line for Fe in MW-B3. 13 Gre feces Figure 9 and Table 10 show that there is a statistically significant increase in Fe in MW-B9 because the F -statistic value of 2.85 shown in Table 10 is greater than the Significance F value of 0.23. [Fe] & [Mn], ug/I 180 160 140 120 100 80 60 40 20 0 0 Fe and Mn in MW-B9 I I I • • Fe MW-B9 • Mn MW-B9 Linear (Fe MW-B9) Linear (Mn MW-B9) • •.. • • ••... • • • • 50 100 150 200 250 300 350 400 Days since 11/01/2019 Figure 9.-- Time trend in Fe and Mn in compliance well MW-B9. Fein Compliance Well MW-B9 Regression Statistics ANOVA Multiple R 0.767 R Square 0.588 df SS MS F Significance F Adjusted RSquare 0.381 Regression 1.00 2778.98 2778.98 2.85 0.23 Standard Error 31.233 Residual 2.00 1951.02 975.51 Observations 4 Total 3.00 4730.00 Coefficients Standard Error tStat P-value Lower95% Upper95% Lower95.0% Upper95.0% Intercept 81.32 26.76 3.04 0.09 -33.82 196.46 -33.82 196.46 Days 0.19 0.12 1.69 0.23 -0.30 0.69 -0.30 0.69 Table 10.-- Regression analysis for the significance of the slope of the regression line for Fe in MW-B9. Figure 10 and Table 11 show that there is a statistically significant increase in Fe in new background well PMW-3 because the F -statistic value of 3.31 shown in Table 11 is less than the Significance F value of 0.13. 14 anan 700 600 500 400 300 200 100 0 Fe and Mn in PMW-3 I I • • Fe PMW-3 MnPMW-3 i 0 100 200 300 400 Days since 11101j2019 Figure 10.-- Time trend in Fe and Mn in new background well PMW-3. 500 600 ea* Pesarces Regression Statistics ANOVA MultipleR 0.6312 R Square 0.3985 df SS MS F Significance F Adjusted R Square 0.2782 Regression 1 116812.66 116812.66 3.31 0.13 Standard Error 187.80 Residual 5 176343.05 35268.61 Observations 7 Total 6 293155.71 Coefficients Standard Error tStat P-value Lower95% Upper95% Lower95.0% Upper95.0% Intercept 54.42 120.03 0.45 0.67 -254.12 362.96 -254.12 362.96 X Variable 1 0.80 0.44 1.82 0.13 -0.33 1.94 -0.33 1.94 Table 11.-- Regression analysis for the significance of the slope of the regression line for Fe in PMW-3. Figure 11 and Table 12 show that there is a statistically significant decrease in Fe in new background well PMW-4 because the F -statistic value of 3.14 shown in Table 12 is greater than the Significance F value of 0.13. Although samples from PMW-4 showed values of Mn greater than the detection limit, there is no significant time trend in these values because the F -statistic value of 0.27 shown in Table 13 is less than the Significance F value of 0.62. 15 [Fe] & [Mn], ug/I 200 180 160 140 120 100 80 60 40 20 0 0 Fe and Mn in PMW-4 I • Fe PMW-4 • • Mn PMW-4 Linear (Fe PMW-4) Linear (Mn PMW-4) • • ..._ _...,,....... .:t....•......... ................................�.......................... • •.*. • • • •..........• • 100 200 300 Days since 11/01/2019 Figure 11.-- Time trend in Fe and Mn in new background well PMW-4. 400 500 ea* Pesarces Regression Statistics ANOVA Multiple R 0.6213 RSquare 0.3860 df SS MS F SignificanceF Adjusted RSquare 0.2632 Regression 1 4216.53 4216.53 3.14 0.14 Standard Error 36.6256 Residual 5 6707.19 1341.44 Observations 7 Total 6 10923.71 Coefficients Standard Error tStat P-value Lower95% Upper95% Lower95.0% Upper95.0% Intercept 109.90 23.41 4.69 0.01 49.72 170.07 49.72 170.07 X Variable 1 -0.15 0.09 -1.77 0.14 -0.37 0.07 -0.37 0.07 Table 12.-- Regression analysis for the significance of the slope of the regression line for Fe in PMW-4. Regression Statistics ANOVA MultipleR 0.2278 RSquare 0.0519 df SS MS F SignificanceF Adjusted RSquare -0.1377 Regression 1 262.65 262.65 0.27 0.62 Standard Error 30.9735 Residual 5 4796.78 959.36 Observations 7 Total 6 5059.43 Coefficients Standard Error tStat P-value Lower95% Upper95% Lower95.0% Upper95.0% Intercept 101.07 19.80 5.11 0.00 50.18 151.95 50.18 151.95 X Variable 1 -0.04 0.07 -0.52 0.62 -0.23 0.15 -0.23 0.15 Table 13.-- Regression analysis for the significance of the slope of the regression line for Mn in PMW-4. 16 ea* Pesarces Conclusions The data from the 2010 study for Fe and Mn in groundwater samples is not statistically from the same population as that from the data from the compliance and new background wells and should not be used in assessing site -specific background standards. The data from the background sampling program to date show that the mean and standard deviation of the concentrations for Fe are lower than the 2L groundwater standard of 300 µg/1 respectively. Consequently, the 2L standards should continue to be used as the values for compliance monitoring for Fe. Because there appears to be statistically significant changes over time since the start of the compliance sampling in November of 2019 in Fe concentrations in some of the compliance and background wells, it is recommended that these trends be assessed on an annual basis to determine if there is a basis for increasing the Fe standard for the site to a value greater than the 2L standard. Concentrations of As in the compliance and background wells have all been less than the 2L standard of 10 µg/1 and therefore, that value should continue to be used as the value for compliance monitoring. This update, which includes samples taken on 3/10/2021, shows that the average Mn concentration 66 µg/1 is greater than the 2L standard of 50 µg/1. Therefore, it is recommended that the site -specific background concentration for Mn be set at 66 µg/1. The large number of non -detect concentrations of Mn in the compliance wells is likely the result of dilution by historical irrigation applied to their up -gradient fields. The non -detect values of Mn in PMW-2 and PMW-3 which are located cross -gradient from all sprayfields is likely the result of dilution from surface runoff to and surface flow in the stream located between them and the sprayfields. 17 ea/e►('esarces Attachment 1 Approved Background Sampling Program The following steps are recommended to implement the determination of background concentrations of Fe and Mn at the Wrenn Road Site: 1. Install and develop the five (5) new background monitoring wells as recommended herein; 2. Sample the background and compliance wells bi-monthly for six (6) months following the installation and development of the new wells. The sampling should follow the recommended low -flow purging, and field analysis for pH, Conductivity, Turbidity, and Temperature. Samples taken should be analyzed in the CORPUD laboratory for As, Fe and Mn This will provide a background sample size of 15 (5 wells x 3 samples) for each constituent. One duplicate should be taken from a randomly selected background well each sampling round; 3. Prepare probability plots of the 15 sample results for each constituent using the log transform of the raw values; and visually compare to the plots for the 2010 samples; 4. Conduct One-way Analysis of Variance (ANOVA) on the log -transformed values to assess whether the new background results are from the same population as the 2010 samples; 5. If the ANOVA shows that the new and 2010 samples are from the same population, pool both to define the background statistics to use in compliance monitoring; or 6. If the ANOVA shows that the new and 2010 samples are not from the same population, use only the new samples to define the background statistics to use in compliance monitoring; and Sample the new background wells for one year on the same schedule used for the compliance wells (March, July, and November) to evaluate any time trends in As, Fe, Mn to consider in compliance assessments. Log transformation should be applied to all these data. 18 Attachment 2 Sampling Reports from CORPUD em/e►('esarces 19 City of Raleigh Wrenn Road Groundwater Monitoring Plan Permit No. WQ0002708 Notes: Before collecting samples, low flow well purging should continue until turbidity<10 NTU or vary no morethan 10% Before collecting samples, pH and water temperature should be stable One duplicate should be collected from one ofthe background wells for each sampling round Try to usethe same equipment during sampling, and note when alternate equipment is used to help account for a difference in results Month November 2019Background MW-B3 PMW-1 PMW-2 PMW-3 PMW-4 Statistics Sampled By D. Godfrey R. Tart D. Godfrey R. Tart D. Godfrey Date 11/5/19 11/21/19 11/21/19 11/21/19 11/21/19 Time 8:05 11:18 8:40 12:23 12:10 Daily Weather Condition Clear/Cool/Sunny Field Data Depth to water 21.65' 24' 8 6' 21.9' Total well depth 30' 43' 20' 16' 74' Volumeofwater purged before sampling (gal) 4.25 gal 9.31 gal 6 gal 4.57 gal 25.5 gal Turbidity (NTU) 0.87 0.48 1.86 1.58 5.08 pH, units 5.23 5.75 5.3 6.03 5.97 Temperature, °C 16.6 16.6 16.8 16.9 17.6 Lab Data Conductivity (umhos/cm) 45.9 98.9 69.6 129.8 126.2 Iron (pg/L) 180 <60 <60 199 172 Manganese(pg/L) <50 90 <50 <50 134 Arsenic (pg/L) <10 <10 <10 <10 <10 CITY OF RALEIGH EM JOHNSON WATER PLANT LABORATORY Wrenn Road Spray Irrigation Facility Permit No. W00002708 Wells Monitoring Data Results Month: November Year: 2019 Location: MW-3 Collection Date Parameter Results Units of Measure Daily Max Limits 05-Nov-19 Arsenic <10 ug/L 10 05-Nov-19 Conductivity 45.9 umhos/cm 05-Nov-19 Iron 180 ug/L 300 05-Nov-19 Manganese <50 ug/L 50 05-Nov-19 pH 5.23 su 6.5 - 8.5 05-Nov-19 Temperature 16.6 C 05-Nov-19 Turbidity 0.87 NTU 05-Nov-19 Arsenic <10 ug/L 10 05-Nov-19 Chloride <10 mg/L 250 05-Nov-19 Conductivity 45.9 umhos/cm 05-Nov-19 DO 2.39 mg/L 05-Nov-19 Fecal MPN 0 MPN/100 ml 05-Nov-19 Nitrate 0.8 mg/L 10 05-Nov-19 pH 5.23 su 6.5 - 8.5 05-Nov-19 Sulfate <10 ppm 250 05-Nov-19 Total Dissolved Solids @ 180 degrees 86 mg/L 500 05-Nov-19 Temperature 16.6 C 05-Nov-19 TOC <1.0 mg/L Location: MW-8 Collection Date Parameter Results Units of Measure Daily Max Limits 05-Nov-19 Arsenic--10 ug/L 10 05-Nov-19 Chloride 23.07 mg/L 250 05-Nov-19 Conductivity 94.9 umhos/cm 05-Nov-19 DO 2.86 mg/L 05-Nov-19 Fecal MPN 0 MPN/100 ml 05-Nov-19 Iron 76 ug/L 300 05-Nov-19 Manganese <50 ug/L 50 05-Nov-19 Nitrate 0.37 mg/L 10 05-Nov-19 pH 5.07 su 6.5 - 8.5 05-Nov-19 Sulfate <10 ppm 250 05-Nov-19 Total Dissolved Solids @ 180 degrees 142 mg/L 500 05-Nov-19 Temperature 15.5 C 05-Nov-19 TOC <1.0 mg/L 05-Nov-19 Turbidity 0.77 NTU Location: MW-9 Collection Date Parameter Results Units of Measure Daily Max Limits 05-Nov-19 Arsenic <10 ug/L 10 05-Nov-19 Chloride 27.66 mg/L 250 05-Nov-19 Conductivity 144.6 umhos/cm 05-Nov-19 DO 1.71 mg/L 05-Nov-19 Fecal MPN 0 MPN/100 ml 05-Nov-19 Iron 82 ug/L 300 05-Nov-19 Manganese <50 ug/L 50 05-Nov-19 Nitrate 1.29 mg/L 10 05-Nov-19 pH 5.05 su 6.5 - 8.5 05-Nov-19 Sulfate 10.36 ppm 250 05-Nov-19 Total Dissolved Solids @ 180 degrees 172 mg/L 500 05-Nov-19 Temperature 17.4 C 05-Nov-19 TOC <1.0 mg/L 05-Nov-19 Turbidity 1.52 NTU City of Raleigh Wrenn Road Groundwater Monitoring Plan Permit No. WQ0002708 Notes: Before collecting samples, low flow well purging should continue until turbidity<10 NTU or vary no morethan 10% Before collecting samples, pH and water temperature should be stable One duplicate should be collected from one of the background wells for each sampling round Try to usethe same equipment during sampling, and note when alternate equipment is used to help account for a difference in results Month Januarv2020Background MW-B3 PMW-1 PMW-2 PMW-3 PMW-4 Statistics Sampled By D. Godfrey R. Tart R. Tart R. Tart D. Godfrey Date 1/17/20 1/17/20 1/17/20 1/17/20 1/17/20 Time 1002 1005 1049 818 1040 Daily Weather Condition Partly Sunny, Cool Field Data Depth to water 19.1 23.8 7.4 5.6 20.5 Total well depth 30' 43' 20' 16' 74' Volume of water purged before sampling (gal) 4.75 gals 9.4 gals 6.1 gals 6.5 gals 27 gals Turbidity (NTU) 1.3 0.98 0.48 1.06 2.04 pH, units 4.86 5.87 6.02 6.68 6.07 Temperature, °C 16.2 14 15.1 12.8 15.3 Lab Data Conductivity (umhos/cm) 43 91.6 67.2 110.1 121.2 Iron (pg/L) 98 <60 <60 <60 68 Manganese(pg/L) <50 74 <50 <50 <50 Arsenic (Ng/L) <10 <10 <10 <10 <10 City of Raleigh Wrenn Road Groundwater Monitoring Plan Permit No. WQ0002708 Notes: Before collecting samples, low flow well purging should continue until turbidity<10 NTU or vary no morethan 10% Before collecting samples, pH and water temperature should be stable One duplicate should be collected from one of the background wells for each sampling round Try to usethe same equipment during sampling, and note when alternate equipment is used to help account for a difference in results Month March 2020Background MW-B3 PMW-1 PMW-2 PMW-3 PMW-4 Statistics Sampled By D. Godfrey D. Godfrey R. Tart R. Tart D. Godfrey Date 3/12/20 3/12/20 3/12/20 3/12/20 3/12/20 Time 1040 1206 750 1230 959 Daily Weather Condition Cloudy, Cool Field Data Depth to water 19.1 20.85 7.5 5.3 16.2 Total well depth 30' 43' 20' 16' 74' Volume of water purged before sampling (gal) 5.5 gals 11 gals 7 gals 5.25 gals 28.5 gals Turbidity (NTU) 0.78 1.31 0.53 3.49 1.76 pH, units 4.85 5.31 5.93 7.03 6.16 Temperature, °C 16.6 18.2 14.6 14.3 16.8 Lab Data Conductivity (umhos/cm) 41.4 90.9 71.8 62.2 115.4 Iron (pg/L) <60 <60 <60 141 <60 Manganese(pg/L) <50 64 <50 <50 88 Arsenic (pg/L) <10 <10 <10 <10 <10 CITY OF RALEIGH EM JOHNSON WATER PLANT LABORATORY Wrenn Road Spray Irrigation Facility Permit No. WQ0002708 Wells Monitoring Data Results Month: March Year: 2020 I nra*inn• M\A/_2 Collection Date Parameter Results Units of Measure Daily Max 12-Mar-20 Arsenic <10 ug/L 10 12-Mar-20 Chloride <10 mg/L 250 12-Mar-20 Conductivity 41.4 umhos/cm 12-Mar-20 DO 3.11 mg/L 12-Mar-20 Fecal MPN 0 MPN/100 ml 12-Mar-20 Iron <60 ug/L 300 12-Mar-20 Manganese <50 ug/L 50 12-Mar-20 Nitrate 0.68 mg/L 10 12-Mar-20 pH 4.85 pH 6.5 - 8.5 12-Mar-20 Sulfate <10 ppm 250 12-Mar-20 Total Dissolved Solids @ 180 degrees C 39 mg/L 500 12-Mar-20 Temperature 16.6 C 12-Mar-20 TOC <0.5 mg/L 12-Mar-20 Turbidity 0.78 NTU • nn'ni_ Collection Date Parameter Results Units of Measure Daily Max 12-Mar-20 Arsenic <10 ug/L 10 12-Mar-20 Chloride 17.8 mg/L 250 12-Mar-20 Conductivity 77 umhos/cm 12-Mar-20 DO 5.20 mg/L 12-Mar-20 Fecal MPN 0 MPN/100 ml 12-Mar-20 Iron <60 ug/L 300 12-Mar-20 Manganese <50 ug/L 50 12-Mar-20 Nitrate 0.44 mg/L 10 12-Mar-20 pH 6.33 pH 6.5 - 8.5 12-Mar-20 Sulfate <10 ppm 250 12-Mar-20 Total Dissolved Solids @ 180 degrees C 62 mg/L 500 12-Mar-20 Temperature 15.5 C 12-Mar-20 TOC <0.5 mg/L 12-Mar-20 Turbidity 0.56 NTU Collection Date Parameter Results Units of Measure Daily Max 12-Mar-20 Arsenic <10 ug/L 10 12-Mar-20 Chloride 11.41 mg/L 250 12-Mar-20 Conductivity 76.9 umhos/cm 12-Mar-20 DO 3.14 mg/L 12-Mar-20 Fecal MPN 0 MPN/100 ml 12-Mar-20 Iron 89 ug/L 300 12-Mar-20 Manganese <50 ug/L 50 12-Mar-20 Nitrate 0.54 mg/L 10 12-Mar-20 pH 7.02 pH 6.5 - 8.5 12-Mar-20 Sulfate <10 ppm 250 12-Mar-20 Total Dissolved Solids @ 180 degrees C 54 mg/L 500 12-Mar-20 Temperature 16.0 C 12-Mar-20 TOC 0.7404 mg/L 12-Mar-20 Turbidity 3.87 NTU City of Raleigh Wrenn Road Groundwater Monitoring Plan Permit No. WQ0002708 Notes: Before collecting samples, low flow well purging should continue until turbidity<10 NTU or vary no morethan 10% Before collecting samples, pH and water temperature should be stable One duplicate should be collected from one of the background wells for each sampling round Try to usethe same equipment during sampling, and note when alternate equipment is used to help account for a difference in results Month April 2020 Compliance MW-B3 PMW-1 PMW-2 PMW-3 PMW-4 Monitoring Sampled By D. Godfrey R. Tart R. Tart R. Tart D. Godfrey Date 4/14/20 4/14/20 4/14/20 4/14/20 4/14/20 Time 1107 1015 830 1145 1028 Daily Weather Condition Sunny, Clear 60s Field Data Depth to water 19' 20.9' 7.7' 5.7' 16.4' Total well depth 30' 43' 20' 16' 74' Volumeofwater purged before sampling (gal) 5.5 Gallons 10.8 Gallons 6.5 Gallons 5.0 Gallons 28.25 Gallons Turbidity (NTU) 0.44 0.39 0.23 0.46 1.61 pH 4.82 7.15 7.32 6.27 6.05 Temperature 17.2 17.6 14.8 15.5 17 Lab Data Conductivity (umhos/cm) 39.8 92.2 68.8 116.4 110.8 Iron (pg/L) 65 <60 <60 <60 <60 Manganese(pg/L) <50 70 <50 <50 96 Arsenic (Ng/L) <10 <10 <10 <10 <10 Month: July Year: 2020 • _ CITY OF RALEIGH EM JOHNSON WATER PLANT LABORATORY Wrenn Road Spray Irrigation Facility Permit No. WQ0002708 Wells Monitoring Data Results Collection Date Parameter Units of Measure Results Daily Max 7/8/2020 pH su 5.19 6.5 - 8.5 7/8/2020 Fecal Coliform col/100 ml 0 7/8/2020 Total Dissolved Solids @ 180°C mg/I 38 500 7/8/2020 Total Organic Carbon mg/I <0.5 7/8/2020 Chloride mg/1 5.17 250 7/8/2020 Nitrate Nitrogen mg/1 0.44 10 7/8/2020 Sulfate mg/I <5 250 7/8/2020 Iron ug/I 234 300 7/8/2020 Manganese ug/I <50 50 7/8/2020 Arsenic ug/I <10 10 7/8/2020 Total Phosphorus mg/1 <0.05 7/8/2020 Acrylamide ug/I <0.50 0.008 Collection Date Parameter Units of Measure Results Daily Max 7/8/2020 pH su 5.35 6.5 - 8.5 7/8/2020 Fecal Coliform col/100 ml 0 7/8/2020 Total Dissolved Solids @ 180°C mg/I 55 500 7/8/2020 Total Organic Carbon mg/I <0.5 7/8/2020 Chloride mg/I 17.9 250 7/8/2020 Nitrate Nitrogen mg/I 0.02 10 7/8/2020 Sulfate mg/I <5 250 7/8/2020 Iron ug/I <60 300 7/8/2020 Manganese ug/I <50 50 7/8/2020 Arsenic ug/I <10 10 7/8/2020 Total Phosphorus mg/I <0.05 7/8/2020 Acrylamide ug/I <0.50 0.008 Collection Date Parameter Units of Measure Results Daily Max 7/8/2020 pH su 5.32 6.5 - 8.5 7/8/2020 Fecal Coliform col/100 ml 0 7/8/2020 Total Dissolved Solids @ 180°C mg/I 71 500 7/8/2020 Total Organic Carbon mg/I 1.01 7/8/2020 Chloride mg/1 20.9 250 7/8/2020 Nitrate Nitrogen mg/I 1.47 10 7/8/2020 Sulfate mg/I 6.99 250 7/8/2020 Iron ug/I 166 300 7/8/2020 Manganese ug/I <50 50 7/8/2020 Arsenic ug/I <10 10 7/8/2020 Total Phosphorus mg/1 <0.05 7/8/2020 Acrylamide ug/I <0.50 0.008 City of Raleigh Wrenn Road Groundwater Monitoring Plan Permit No. WQ0002708 Notes: Before collecting samples, low flow well purging should continue until turbidity<10 NTU or vary no morethan 10% Before collecting samples, pH and water temperature should be stable One duplicate should be collected from one of the background wells for each sampling round Try to usethe same equipment during sampling, and note when alternate equipment is used to he p account for a difference in results Month August 2020 Comoliance MW-B3 PMW-1 PMW-1 Dup PMW-2 PMW-3 PMW-4 Monitoring Sampled By Roy Tart Roy Tart Roy Tart Roy Tart Roy Tart Roy Tart Date 8/20/20 8/20/20 8/20/20 8/20/20 8/20/20 8/20/20 Time 14:35 13:25 13:25 12:01 15:15 12:45 Daily Weather Condition Cloudy 80°F Field Data Depth to water 20.3 22.8 22.8 9.8 6 19 Total well depth 30 43 43 20 30 74 Volume of water purged before sampling (gal) 4.7 9.8 9.8 5.1 5 26 Turbidity (NTU) 0.9 0.68 0.68 1.46 1.69 1.5 pH 5.8 5.93 5.93 6.01 6.63 6.81 Temperature 18.5 19.1 19.1 20.7 19.8 19 Conductivity (umhos/cm) 111 94.5 96.7 73.3 43.5 124.5 Iron (pg/L) 118 <60 <60 <60 482 69 Manganese(pg/L) <50 88 90 <50 <50 123 Arsenic (pglL) <10 <10 <10 <10 <10 <10 City of Raleigh Wrenn Road Groundwater Monitoring Plan Permit No. WQ0002708 Notes: Before collecting samples, low flow well purging should continue until turbidity<10 NTU or vary no morethan 10% Before collecting samples, pH and water temperature should be stable One duplicate should be collected from one ofthe background wells for each sampling round Try to usethe same equipment during samp ing, and note when alternate equipment is used to help account for a difference in results Month November 2020 Compliance MW-B3 PMW-1 PMW-1 Dup PMW-2 PMW-3 PMW-4 Monitoring Sampled By D. Godfrey D. Godfrey D. Godfrey D. Godfrey D. Godfrey D. Godfrey/E. Batchelor Date 11/4/20 11/4/20 11/4/20 11/4/20 11/4/20 11/4/20 Time 9:43 8:25 8:25 9:08 10:44 12:00 Daily Weather Condition Clear 48 °C Clear 40 °C Clear 40 °C Clear 40 °C Clear 55 °C Clear 62 °C Field Data Depth to water 19.95 22.3 22.3 7.8 5.7 18.9 Total well depth 30' 43' 43' 20' 16' 74' Volume of water purged before sampling (gal) 5 10.25 10.25 6 5.25 27 Turbidity(NTU) 0.73 1.12 1.12 1.86 0.44 0.72 pH 4.79 5.32 5.32 5.08 5.65 5.87 Temperature 17.8 17 17 18.5 18.1 18.2 Conductivity (umhos/cm) 41.4 82 82.4 73.6 101.5 129.8 Iron )pg/L) 301 <60 <60 72 73 <60 Manganese(pg/L) <50 59 61 <50 <50 88 Arsenic (pg/L) <10 <10 <10 <10 <10 <10 CITY OF RALEIGH EM JOHNSON WATER PLANT LABORATORY Wrenn Road Sorav Irrieation Facility Permit No. W00002708 Wells Monitorine Data Results Month: November Year: 2020 Location: MW-3 Collection Date Parameter Results Units of Measure Daily Max 04-Nov-20 Arsenic <10 ug/L 10 04-Nov-20 Conductivity 41.4 umhos/cm 04-Nov-20 Iron 334 ug/L 300 04-Nov-20 Manganese <50 ug/L 50 04-Nov-20 pH 4.79 su 6.5 - 8.5 04-Nov-20 Temperature 17.8 C 04-Nov-20 Turbidity 0.73 NTU 05-Nov-20 Arsenic <10 ug/L 10 05-Nov-20 Chloride 6.073 mg/L 250 05-Nov-20 Conductivity 40.3 umhos/cm 05-Nov-20 DO 2.06 mg/L 05-Nov-20 Fecal MPN 0 MPN/100 ml 05-Nov-20 Iron 301 ug/L 300 05-Nov-20 Manganese <50 ug/L 50 05-Nov-20 Nitrate 0.35 mg/L 10 05-Nov-20 pH 4.52 su 6.5 - 8.5 05-Nov-20 Sulfate <5 ppm 250 05-Nov-20 Total Dissolved Solids (&, 180 degrees 41 mg/L 500 05-Nov-20 Temperature 17.2 C 05-Nov-20 TOC <1.0 mg/L 05-Nov-20 Total Phosphorus <0.04 mg/L 05-Nov-20 Turbidity 0.76 NTU Collection Date Parameter Results Units of Measure Daily Max 05-Nov-20 Arsenic <10 ug/L 10 05-Nov-20 Chloride 21.932 mg/L 250 05-Nov-20 Conductivity 91.4 umhos/cm 05-Nov-20 DO 3.78 mg/L 05-Nov-20 Fecal MPN 0 MPN/100 ml 05-Nov-20 Iron <60 ug/L 300 05-Nov-20 Manganese <50 ug/L 50 05-Nov-20 Nitrate <0.04 mg/L 10 05-Nov-20 pH 4.69 su 6.5 - 8.5 05-Nov-20 Sulfate <5 ppm 250 05-Nov-20 Total Dissolved Solids A 180 degrees 73 mg/L 500 05-Nov-20 Temperature 16.2 C 05-Nov-20 TOC <1.0 mg/L 05-Nov-20 Total Phosphorus <0.04 mg/L 05-Nov-20 Turbidity 0.88 NTU • Collection Date Parameter Results Units of Measure Daily Max 05-Nov-20 Arsenic <10 ug/L 10 05-Nov-20 Chloride 22.576 mg/L 250 05-Nov-20 Conductivity 122.0 umhos/cm 05-Nov-20 DO 1.41 mg/L 05-Nov-20 Fecal MPN 0 MPN/100 ml 05-Nov-20 Iron 135 ug/L 300 05-Nov-20 Manganese <50 ug/L 50 05-Nov-20 Nitrate 1.04 mg/L 10 05-Nov-20 pH 4.64 su 6.5 - 8.5 05-Nov-20 Sulfate 8.892 ppm 250 05-Nov-20 Total Dissolved Solids A 180 degrees 81 mg/L 500 05-Nov-20 Temperature 17.3 C 05-Nov-20 TOC <1.0 mg/L 05-Nov-20 Total Phosphorus <0.04 mg/L 05-Nov-20 Turbidity 5.97 NTU City of Raleigh Wrenn Road Groundwater Monitoring Plan Permit No. WQ0002708 Notes: Before collecting samples, low flow well purging should continue until turbidity<10 NTU or vary no morethan 10% Before collecting samples, pH and water temperature should be stable One duplicate should be collected from one of the background wells for each sampling round Try to usethe same equipment during samp ing, and note when alternate equipment is used to help account for a difference in results Month March 2021 Compliance MW-B3 PMW-1 PMW-1 Dup PMW-2 PMW-3 PMW-4 Monitoring Sampled By D. Godfrey D. Godfrey D. Godfrey D. Godfrey D. Godfrey D. Godfrey Date 3/10/21 3/10/21 3/10/21 3/10/21 3/10/21 3/10/21 Time 7:50 8:50 8:50 9:22 11:16 13:00 Daily Weather Condition Sunny39°C Sunny43°C Sunny43°C Sunny50°C Sunny65°C Sunny67°C Field Data Depth to water 16.8' 18.3 18.3 6.9 5.9 14.1 Total well depth 30' 43' 43' 20' 16' 74' Volume of water purged before sampling (gal) 6.5 12.25 12.25 6.5 5 30 Turbidity(NTU) 0.72 3.52 3.52 1.52 2.83 0.72 pH 5.3 5.62 5.62 5.75 6.48 5.85 Temperature 15.8 16.5 16.5 15.5 14.2 19.8 Conductivity (umhos/cm) 38.35 84.53 83.03 79.36 85.17 123.9 Iron )pg/L) 108 97 132 199 601 <50 Manganese(pg/L) <10 71 71 16 176 71 Arsenic(pg/L) <5 <5 <5 <5 <5 <5 *Trace Metal Analysis by Environment 1 2 Ground Water Monitoring Plan (2019) F�2 Ground Water Monitoring Plan Wrenn Road Facility Wastewater Irrigation System Garner, NC February 26, 2019 hdrinc.com February 26, 2019 Mr. Rick Bolich NC Department of Environmental Quality Division of Water Resources Water Quality Regional Operations Section Raleigh Regional Office 3800 Barrett Drive Raleigh, NC 27609 Re: Ground Water Monitoring Plan Permit No. WQ0002708 City of Raleigh Wrenn Road Facility Wastewater Irrigation System Wake County, North Carolina Dear Mr. Bolich, On behalf of the City of Raleigh Public Utilities Department, we are resubmitting the Ground Water Monitoring Plan requested in the approval for Permit Number WQ0002708 to support background concentrations of manganese, iron and arsenic above the 15A NCAC 02L standards. The sampling plan has been prepared with consideration to the guidance material suggested in the Permit Approval letter: Aquifer Protection Section Policy for metals Determinations Required by Title 15A, NCAC, Subchapter 2L (May, 2013) and Evaluating Metal in Groundwater at DWQ Permitted Facilities: A Technical Assistance Document for DWQ Staff (NC DENR, July, 2012). Also, the following US EPA groundwater monitoring guidance document was utilized: Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities -Unified Guidance: EPA 530/R-09-007. Additionally, recommendations offered by DEQ during discussions with the City and HDR were incorporated into the sampling plan. In summary, the revised sampling plan will: 1. Install and develop four (4) background monitoring wells at the Wrenn Road Facility; 2. These wells will be sampled for iron, manganese, and arsenic bi-monthly for the first six (6) months to develop background statistics for compliance monitoring; 3. Determine if 2010 sampling data is from the same population and for use in defining background statistics for ground water monitoring; 4. Sample the new background wells for one (1) year on the same schedule used for compliance monitoring to evaluate any time trends to consider in compliance assessments; 5. The new ground water monitoring wells will be maintained such that resampling can be accomplished in the future if necessary. 555 Fayetteville Street Suites 900 & 210, Raleigh, NC 27601-3034 (919) 232-6600 hdrinc.com This package contains the following: Attachment A — The ground water monitoring plan submitted to DEQ on February 28, 2017 Attachment B — Responses to comments provided to DEQ on October 7, 2017 Attachment C — The resubmittal to DEQ by the City/HDR on December 14, 2018, providing revised background monitoring well locations Attachment D — Meeting minutes from a meeting held with the City, HDR, Eagle Resources, and DEQ on January 31, 2019 Attachment E — Water well locations for the subdivision located adjacent to the Wrenn Road Facility Attachment F — Ground water well levels Attachment G — A contour map of the proposed monitoring well locations The groundwater permit WQ0002708 expires June 30, 2020. The 1-540 project will impact the Wrenn Road Facility and the compliance boundary. The exact timing of the 1-540 project is unknown at this time. The City will keep DEQ informed as to the progress of this project. We have submitted a full package in order to hopefully help the review process. Should you have any questions, please do not hesitate to call me at 919-232-6657. We look forward to hearing from the NC Department of Environmental Quality. Sincerely, HDR Engineering Inc. of the Carolinas Chris Brown, PE Project Manager Enclosures CC: Chris Phelps, City of Raleigh Dennis Lassiter, City of Raleigh Whit Wheeler, City of Raleigh Eric Lappala, Eagle Resources Samantha Black, HDR Manish Bhandari, HDR 555 Fayetteville Street Suites 900 & 210, Raleigh, NC 27601-3034 (919) 232-6600 A Ground Water Monitoring Plan — Submitted February 28, 2017 E�Z hdrinc.com February 28, 2017 Mr. Troy Doby Non -Discharge Permitting Unit Water Quality Permitting Section Division of Water Resources 512 N. Salisbury Street Raleigh, NC 27604 Re: Ground Water Monitoring Plan Permit No. WQ0002708 City of Raleigh Wrenn Road Facility Wastewater Irrigation System Wake County, North Carolina Dear Mr. Doby, On behalf of the City of Raleigh Public Utilities Department, we are providing the Ground Water Monitoring Plan requested in the approval for Permit Number WQ0002708 to support background concentrations of Manganese, Iron and Arsenic above the 15A NCAC 02L standards. The sampling plan has been prepared with consideration to the guidance material suggested in the Permit Approval letter: Aquifer Protection Section Policy for metals Determinations Required by Title 15A, NCAC, Subchapter 2L (May, 2013) and Evaluating Metal in Groundwater at DWQ Permitted Facilities: A Technical Assistance Document for DWQ Staff (NC DENR, July, 2012). Also, the following US EPA groundwater monitoring guidance document was utilized: Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities -Unified Guidance: EPA 530/R-09-007. Based on these sources and other groundwater modeling tools a ground water monitoring plan has been developed. This detailed groundwater monitoring pian is attached, "Proposed Monitoring Plan to Establish Background Concentration of Iron and Manganese at the Wrenn Road Spray Fields, Wake County NC" (Plan) by Eric Lappala, P.E., P.H., Eagle Resources. In summary the sampling plan will: 1. Install and develop five (5) new monitoring wells at the Wrenn Road Facility; 2. These wells will be sampled for Iron, Manganese and Arsenic, bi-monthly for the first six (6) months to develop the background statistics for compliance monitoring; 3. Determine if 2010 sampling data is from the same population and for use in defining background statistics for ground water monitoring; 4. Sample the new background wells for one (1) year on the same schedule used for compliance monitoring, to evaluate any time trends to consider in compliance assessments. 5. The new ground water monitoring wells shall be maintained such that resampling can be accomplished if necessary. 3733 National Drive Suite 207, Raleigh NC 27612 T 919.232.6600 F 919.785.1187 Should you have any questions, please do not hesitate to call me at (910) 575-8800. Sincerely, HDR Engineering Inc. of the Carolinas Randy Plummer, PE Project Manager RTP Enclosures cc: Chris Phelps Dennis Lassiter 3733 National Drive Suite 207, Raleigh NC 27612 T 919.232.6600 F 919.785.1187 Proposed Monitoring Plan to Establish Background Concentration of Iron and Manganese at the Wrenn Road Sprayfields, Wake County, NC North Carolina Non -Discharge Permit WQ0002708 Prepared for City of Raleigh Pubic Utilities Department and HDR Engineering of the Carolinas April 1, 2016 (Revised February 1, 2017) Eric G. Lappala, P.E., P.H. 11115 tag& PeAarce5 Eagle Resources, P.A. P.O. Box 11189 Southport, NC www.eagleresources.com 1 Contents Introduction 1 Purpose 1 Model Analyses to select sites for background monitoring 2 Sampling Design 8 1. Identical and Independent Distributions of background and forward samples 8 2. Temporal Stationarity of Samples 10 3. Spatial Stationarity of Samples 10 4. Statistical Outliers 12 5. Use of Parametric Methods 12 6. Minimum Number of Background Samples 12 a) Additional Background Wells 13 b) Sampling to Establish Background 14 c) Initial Sampling Methodology Assessment 14 Recommended Background Determination Methodology 15 Conclusions 16 Figures Figure 1.-- Measured and modeled water level elevations in B-3, B-8, and B-9 3 Figure 2.-- Modeled concentrations of the modeled constituent in model layer 1 as of 12/31/15. 5 Figure 3.-- Modeled concentrations of the modeled constituent in model layer 2 as of 12/31/15. 6 Figure 4.-- Modeled concentrations of the modeled constituent in model layer 3 as of 12/31/15. 7 Figure 5.-- Probability Plots for (Fe / 2L standard) and (Mn / 2L standard) for the 2010 study samples.. 9 Figure 6.-- Probability plots of log -transformed values of (Fe 2L Standard) and (Mn / 2L Standard) for the 2010 study samples. 10 Figure 7.-- Log -transformed multiple of Fe (left panel) and Mn (right panel) multiples of the 2L Standards for samples from the 2010 study. 11 Figure 8.-- Dissolved Fe and Mn plotted against each other showing little correlation between them.... 12 Tables Table 1.—Dissolved Fe and Mn from the 2010 study, their multiples of the 2L standards and the log transform of the multiples of the 2L standards. 9 Table 2.-- Coordinates of Proposed Background Monitoring Wells. 13 Table 3.-- Results of purging of compliance wells on February 5, 2016 and laboratory analyses for dissolved Fe and Mn in samples taken at the end of purging 15 i Introduction NC DEQ has granted Permit WQ0002708 to the City of Raleigh (City) for the continued operation and irrigation at the Wrenn Road Facility in southeastern Wake County. This permit is a renewal for the permit of the same number that was in effect originally to permit the same facilities for the disposal of wastewater effluent from the treatment facilities. The Wrenn road Facility stopped receiving domestic wastewater in 2008. The spray irrigation facilities were modified to allow treatment of residuals from the DE Benton Water Treatment Plant (DEBWTP). WQ0002708 was amended in 2012 for the spray irrigation modifications and to change the influent waste source to residuals from the DEBWTP. The spray irrigation permit was renewed in 2015. The sprayfields have been used since 1989 to dispose of treated wastewater from the Garner wastewater treatment plant (Garner WWTP). The Town of Garner operated the WR Sprayfields until the merger of the Garner water and sewer utility systems with the City of Raleigh in July 2000. The City of Raleigh Public Utilities Department (CORPUD) has operated the Garner wastewater plant and the WR Sprayfields since that date. A comprehensive Hydrogeologic and Geochemical evaluation of the site was completed by Soil and Environmental Consultants (S&EC) and Eagle Resources for the site in 2010 and approved by DEQ as part of the application for the currently issued permit,2,. These studies comprised the installation of over 20 temporary piezometers, three monitoring wells, and groundwater flow, groundwater transport, and geochemical modeling to assess both conditions prior to the application of residuals from the WTP and to recommend loading rates to the sprayfields to assure that the likely depth to the watertable would be compliant with the conditions of the permit. Purpose The permit was issued by DEQ with the condition that the City prepare a monitoring plan to assess the background concentrations of arsenic, iron and/or manganese above the 15A NCAC .02L groundwater standards (2L Standards). The 2010 reports documented concentrations of these constituents in samples collected from piezometers and monitoring wells that exceeded the 2L Standards. The permit condition also requested that CORPUD consider DWQ Staff guidance documents3,4 in preparing the plan. These guidance documents include the statistical evaluation of data used to establish background concentrations to account for spatial variations across complex sites. Because the piezometers from the 2010 studies have been abandoned, they and are no longer available to use for re -development and sampling to provide this data. The three monitoring wells that have been used for compliance reporting since the original permit was issued for the site (MW-B3, MW-B8, and MW-B-9) also are not adequate in number or location to use for the establishment of background concentrations. These wells are not located in areas where the 2010 study showed concentrations of the regulated metals to be above the 2L Standards. Additionally, only three rounds of samples have been taken that have included analyses for the metals of concern since the permit was issued and application of residuals was started in 2014. The objective of this report is to present a plan for using data and analyses from the 2010 study documents combined with data from additional monitoring locations to respond to the permit condition to assess the background concentrations of iron and manganese at the facility. 1 Soil and Environmental Consultants, 2009, Site Analysis for Wrenn Road Wastewater Treatment Plant Spray Irrigation system, Garner., Wale County, North Carolina 2 Eagle Resources, P.A., May 10, 2010, Groundwater Mounding Analysis and Groundwater Quality Assessment Wrenn Road Wastewater Treatment Plan Spray Irrigation System Garner, Wake County, North Carolina 3 NC Division of Water Quality, July 2012: Evaluating Metals in Groundwater at DWQ Permitted Facilities: a Technical Assistance Document for DWQ Staff. 4 NC Division of Water Quality, May 13, 2013: Aquifer Protection Section Policy for Metals Determinations Required by Title 15A North Carolina Administrative Code, Subchapter 2L. 1 Based upon the DEQ guidance documents, determination of the quality and quantity of background data needed should consider the following: 1. Physical complexity of the site a. Does site geology vary horizontally across the site b. Are off -site wastes likely to migrate to and contaminate background or compliance boundary wells c. Have Hydrogeologic anomalies been identified? d. Have wastes been disposed across particularly large or undocumented areas e. Spatial extent and complexity of the waste disposal practices 2. Are background concentrations expected to be similar to 2L standards and/or similar to on -site concentrations at the compliance boundary 3. Will site be used as a precedent for similar sites in the state 4. Will statistical proof be required to justify a non-compliance determination At a minimum, collected data should measure maximum concentrations of permitted waste constituents that exist at the compliance boundary and at ambient background locations, along with any spatial or temporal trends. Moreover, sample numbers and locations should align with statistical data needs.... Therefore, background data should be collected from a hydraulically up gradient location (outside the influence of site wastes) in immediate proximity to the site and within the same groundwater horizon (depth/zone) as samples collected from compliance boundary wells....." Model Analyses to select sites for background monitoring The 2010 studies and analyses provide the documentation of the items listed above that define the physical complexity of the site. The calibrated groundwater flow and transport model constructed for those studies was based on site -specific data from borings, piezometers (19) monitoring wells (3), water levels, tests for hydraulic conductivity, chemical and geochemical analyses of water samples. The model was constructed using three layers: The Saprolite at the site was modeled as two layers each 17.7 feet thick which are referred to as the Upper Saprolite and Lower Saprolite respectively. The third layer comprised Partially Weathered Rock (PWR) and was 15 feet thick. Transient analyses using the model have been used to help identify those areas that are not likely to have been impacted by migration of constituents in water applied to the Wrenn Road fields during 2014 and 2015. The initial water levels used for the transient analyses with the model were the steady state values from the calibrated 2010 model which used a natural recharge rate of using a recharge rate of 15 inches per year. Monthly recharge for 2014 and 2015 used for model input was determined as follows: Recharge on non-sprayfield areas = Precipitation — Evapotranspiration (ET); and (1) Recharge on spray areas = Precipitation + Applied Effluent — ET. (2) Precipitation for each month was taken from the grid centered on the site out of the 4km x 4km gridded values from the National Precipitation Dataset from the PRISM website5. The PRISM datasets are 5 http://www.prism.oregonstate.edu/ 2 computed using measurements from a wide range of monitoring networks that cover the conterminous United States to which sophisticated quality control measures and a variety of modeling techniques are applied and are available as daily, monthly and yearly time scales for the period from 1895 to the present. ET was taken from the global monthly ET 0.05 degree grid corresponding to the site from the MODIS projects. This project is part of NASA/EOS project to estimate global terrestrial evapotranspiration from earth land surface by using satellite remote sensing data. The MOD16 ET datasets are estimated using Mu et al.'s improved ET algorithm (2011) over previous Mu et al.'s paper (2007a). The ET algorithm is based on the Penman -Monteith equation (Monteith, 1965). Surface resistance is an effective resistance to evaporation from land surface and transpiration from the plant canopy. Applied effluent to each field for each month was computed using the volume applied as reported on the Discharge Monitoring Reports (DMRs) provided by CORPUD and tables provided by HDR of the percentage of spray heads applying to each soil type within each field that are included as Attachment 1 to this report. Attachment 2 provides a summary tabulation of the monthly effluent applied to each soil type within each field. The unit rate applied effluent in equation (2) was determined by dividing the volume applied by the area occupied by each soil within each field. Modeled water level elevations in B-3, B-8, and B-9 for the period 2014 through 2015 are shown on Figure 1 along with measured water level elevations for 2007 through 2015 Although water levels fluctuate, they tend to fluctuate in unison over the site and model analyses show that the pattern of groundwater flow that are determined by recharge and discharge areas does not change significantly. 361.75 331.5 v v LL co 301.25 co z c 271 ro w 240.75 u 210.5 180.25 150 6/1/06 5/22/075/11/08 5/1/09 4/22/104/12/11 4/1/12 3/22/133/13/14 3/3/15 t B-3 t B-8 —~ B-9 — B-3 Modeled Sy = 0.25 — B-8 Modeled Sy = 0.25 — B-9 Modeled Sy = .25 Figure 1.-- Measured and modeled water level elevations in B-3, B-8, and B-9 6 http://www.ntsg.umt.edu/project/mod16 3 Transient transport analyses for 2014 through 2015 were conducted to assess potential migration of COCs in effluent from DEB WTP and to locate areas where it is not likely to have impacted groundwater and hence where background monitoring sites should be located. The source term used for these analyses was an arbitrary constituent at a concentration of 10 arbitrary units applied to the areas that received effluent during 2014 and 2015. Figures 2 through 4 show the modeled concentrations of the arbitrary constituent as of December 31, 2015 for each of the modeled layers. 4 13 M,= %MW-3 4 1500 2000 Ft f 101 63 1043 EXPLANATION Layer 1 [C] Monitoring Wells EM 0 Compliance Well - 1 2 * Monitoring Well 3 * Proposed Background Well 0 2010 Mn X 2L Std (Purple) 2010 Fe X 2L Std (Orange) Areas Irrigated in 2014 and 2015 CORPUD_Property_Boundary Base: USGS 2010 NI to Pecs Eagle Resources, P.A. P.O. Box 11189 Southport, NC 28461 919-345-1013 elappala@eagleresources.com City of Raleigh Public Utilties Department Project No. 24041.1 Approved: EGL Date: 02/21 /16 Design data and recommendations included herein are provided as a matter of information and should not be used for final design. Rely only on hard copy bearing consultants original seal and signature Modeled concentrations in Upper Saprolite of an arbitrary solute on 12/31/2015 applied in irrigation water at concentration of 10 arbitrary units for 2014 and 2015. DRAFT FIGURE 2 4 0 '36%5 EXPLANATION Layer 1 [C] Monitoring Wells EM 0 Mi 1 In 2 3 4 5 6 7 8 9 10 Compliance Well * Monitoring Well • Proposed Background Well O 2010 Mn X 2L Std (Purple) • 2010 Fe X 2L Std (Orange) Areas Irrigated in 2014 and 2015 n CORPUD_Property_Boundary Base: USGS 2010 ei to Pecs Eagle Resources, P.A. P.O. Box 11189 Southport, NC 28461 919-345-1013 elappala@eagleresources.com City of Raleigh Public Utilties Department Project No. 24042.1 Approved: EGL Date: 02/21/16 Design data and recommendations included herein are provided as a matter of information and should not be used for final design. Rely only on hard copy bearing consultants original seal and signature Modeled concentrations in Lower Saprolite of an arbitrary solute on 12/31/2015 applied in irrigation water at concentration of 10 arbitrary units for 2014 and 2015. DRAFT FIGURE 3 5 MWgBr3 '4 EXPLANATION PWR [C] Monitoring Wells IM 0 1 2 3 4 5 f 6 7 8 9 10 1500 2000 Ft Itr Compliance Well * Monitoring Well • Proposed Background Well o 2010 Mn X 2L Std (Purple) O 2010 Fe X 2L Std (Orange) %° Areas Irrigated in 2014 and 2015 n CORPUD_Property_Boundary Base: USGS 2010 i eagle Peoarce, Eagle Resources, P.A. P.O. Box 11189 Southport, NC 28461 919-345-1013 elappala@eagleresources.com City of Raleigh Public Utilties Department Project No. 24041.1 Approved: EGL Date: 02/21/16 Design data and recommendations included herein are provided as a matter of information and should not be used for final design. Rely only on hard copy bearing consultants original seal and signature Modeled concentrations in Lower Saprolite of an arbitrary solute on 12/31/2015 applied in irrigation water at concentration of 10 arbitrary units for 2014 and 2015. DRAFT FIGURE 4 6 Sampling Design DEQ has determined that the data from the 2010 report should not be used to establish background values because the wells were not permanent and because their sampling may not have met the currently recommended sampling methodology for metals. However, because the sample size is relatively large (n = 21) from that study and to provide a guide to the approximate variability in concentrations of iron and manganese over the site as an aid to establishing a background monitoring program to meet these requirements, we have included that data its summary statistics in Table 1 as well as their as multiples of the 2L standards. Their multiples of the 2L Standards are also shown on Figures 2 through 4 to illustrate their spatial variability. The USEPA guidance document7 on groundwater monitoring for compliance purposes which is referenced in the DEQ guidance document provides the following six requirements for establishing prediction limits for comparing background and future compliance samples: 1. Background and future sample measurements need to be identically and independently distributed; 2. Sample data do not exhibit temporal non-stationarity in the form of trends, autocorrelation, or other seasonal or cyclic variation; 3. For inter -well tests (e.g., up-gradient-to-downgradient comparisons), sample data do not exhibit non - stationary distributions in the form of significant natural spatial variability; 4. Background data do not include statistical outliers; 5. For parametric prediction limits, background data are normal or can be normalized using a transformation; and 6. A minimum of 8 background measurements is available; more for non -parametric limits or when accounting for multiple, simultaneous prediction limit tests. 1. Identical and Independent Distributions of background and forward samples To assess the likely distributions of these data, probability plots for the multiples of the 2L standards are shown in Figure 5. Examination of these plots and the value of the skew coefficients in Table 1 show that the raw data is not normally distributed. However, the the log transform of the multiples of the 2L standards closely approximate normal distributions as shown by the fit to the straight normal probability line in Figure 6. Therefore, to meet the requirements 1 and 5 above, all background and forward compliance samples should be log -transformed. Note that for both Mn and Fe a value of the log transformed value of 0.0 for the multiple of the standard is equivalent to the 2L Standard (Value / Standard = 1.0). U.S. Environmental Protection Agency, March, 2009: Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities - Unified Guidance: EPA 530/R-09-007, chapter 18, pp 18-4. 8 v 0 u 3 2.5 2 1.5 1 0.5 0 -0.5 -1 -1.5 -2 RZ = 0.68701 • 2 1.5 • 0 50 100 150 200 250 Fe / 2L Standard 0.5 0 cn 0 N -0.5 .' • -1 • • -1.5 •• RZ = 0.7386 • • -2 0 20 40 60 80 100 Mn / 2L Standard Figure 5.-- Probability Plots for (Fe / 2L standard) and (Mn / 2L standard) for the 2010 study samples.. Study Well No. Fe, mg/I Mn, mg/I Fe x Std Log Fe x Std Mnx Std Log Mn x Std M W-1 11.74 1.06 39.13 1.593 21.2 1.326 M W-2 6.37 0.63 21.23 1.327 12.6 1.100 M W-3 12.33 0.04 41.1 1.614 0.8 -0.097 PZ-1 3.83 4.43 12.77 1.106 88.6 1.947 PZ-2 11.69 4.11 38.97 1.591 82.2 1.915 PZ-3 3.02 0.56 10.07 1.003 11.2 1.049 PZ-4 26.28 2.16 87.6 1.943 43.2 1.635 PZ-5 30.2 3.16 100.67 2.003 63.2 1.801 PZ-6 69.14 3.46 230.47 2.363 69.2 1.840 PZ-7 23.6 0.43 78.67 1.896 8.6 0.934 PZ-8 31.94 0 106.47 2.027 0 n/a PZ-9 6.92 0.84 23.07 1.363 16.8 1.225 PZ-10 6.96 0.55 23.2 1.365 11 1.041 PZ-11 1.41 0.02 4.7 0.672 0.4 -0.398 PZ-12 10.3 0.25 34.33 1.536 5 0.699 PZ-14 1.52 0.33 5.07 0.705 6.6 0.820 PZ-15 0.68 0.22 2.27 0.356 4.4 0.643 PZ-16 2.39 0.26 7.97 0.901 5.2 0.716 PZ-17 2.29 0.09 7.63 0.883 1.8 0.255 PZ-18 6.16 0.08 20.53 1.312 1.6 0.204 PZ-19 3.14 0.57 10.47 1.020 11.4 1.057 Mean 12.95 1.11 43.16 1.361 22.14 0.986 Median 6.92 0.55 23.07 1.363 11.00 1.045 Variance 260 2 2887 0.268 821 0.439 Std Dev 16.12 1.43 53.73 0.517 28.65 0.662 Skew 2.40 1.45 2.40 0.012 1.45 -0.340 Table 1.-Dissolved Fe and Mn from the 2010 study, their multiples of the 2L standards and the log transform of the multiples of the 2L standards. 9 2 1.5 1 N N R2 = 0.98704 1.5 1 ' • 0.5 ...4 • 0.5 •• • 0 `• N.5 - 0.5 ... -1 • -1.5 •' -2 -2 -1 - 1.5 R2 = 0.97568 e.. 4 ••' • • :• •. • 0.000 0.500 1.000 1.500 2.000 2.500 -0.500 0.000 0.500 1.000 1.500 2.000 2.500 Log (Fe / 2L Standard) Log(Mn / 2L Standard) Figure 6.-- Probability plots of log -transformed values of (Fe 2L Standard) and (Mn / 2L Standard) for the 2010 study samples. Conformance with requirement 1 for compliance samples will have to be assessed by periodically determining their log transformed values and plotting their distribution compared to the background distribution. 2. Temporal Stationarity of Samples Conformance with Requirements 1 and 2 above will require the periodic assessment of time trends in both background and compliance samples to assess whether such trends are consistent with each being similarly distributed. The evaluation of the background and compliance samples should be evaluated for temporal trends using regression and/or analysis of variance. These analyses will not be possible until a sufficient number of compliance (and background) samples are available. 3. Spatial Stationarity of Samples Examination of the spatial patterns of the log transformed values from the 2010 for Fe shows that concentrations of Fe were elevated in the northwest portion of the property and Mn concentrations were elevated in the northern portion of the property as shown in Figure 7. These patterns are likely the result of increased weathering and leaching of the soils and saprolite from the uplands at the north end of the property to the lowlands at the southern part of the property. These patterns are not apparently correlated with either the presence or absence of application fields or with the modeled concentrations of the arbitrary constituent shown in Figures 4 through 4. 10 Figure 7.-- Log -transformed multiple of Fe (left panel) and Mn (right panel) multiples of the 2L Standards for samples from the 2010 study. A similar spatial variability assessment should be made using new background data and compliance data once a samples have been collected for at least one year on the current compliance schedule. To further assess the spatial distribution of Fe and Mn, the log -transformed values of their respective multiples of the 2L standards are plotted against each other for the 2010 study samples in Figure 8. While there is a general trend in this relationship, the correlation coefficient between them is very low, indicating a very weak relationship. 11 Log(Mn / 2L Standard) 3.5 3 2.5 2 1.5 1 0.5 0 -0.5 -1 0 f R2 = 0.1431 • • • • • • • • • • • •• • • • • • • 1 2 3 Log(Fe / 2L Standard) Figure 8.-- Dissolved Fe and Mn plotted against each other showing little correlation between them. 5 4. Statistical Outliers The EPA guidance document lists two screening tools (Probability and Box Plots) and two formal outlier tests (Dixon's and Rosner's) to identify statistical outliers8. The probability plots shown in Figure 6 for the samples from the 2010 study show that there are no apparent outliers for the log - transformed data for either Fe or Mn. Because samples from multiple time periods are not available for the 2010 study samples, Box Plots to compare the values are not appropriate. However after a sufficient number of additional background and compliance samples are available they may be useful in identifying any outliers. Because there do not appear to be any statistical outliers for either the log - transformed Fe or Mn data shown in Figure 6, it does not seem appropriate to apply either parameter. 5. Use of Parametric Methods Using parametric methods to assess compliance with background requires that the background and compliance data are both drawn from normal distributions or that the data can be transformed to normal distributions. As shown in Figure 6 both Fe and Mn are log normally distributed and therefore at least the data from the 2010 study meet this requirement. 6. Minimum Number of Background Samples The EPA guidance document states that at least 8 samples should be available to establish background for the use of prediction intervals for compliance assessment9. As few as three background observations can be used to compute compliance but would result in a very large upper prediction limit for background and would limit the statistical power of the test. 8 USEPA Unified Guidance document, Chapter 12. 9 USEPA Unified Guidance Document, p. 18-4. 12 Although DEQ has determined as previously stated that the sample analyses from the 2010 study cannot be used by themselves to establish background, it is our professional opinion that that dataset as well as samples from the 1990 study can and should be use in conjunction with additional samples to achieve this objective. As demonstrated in the previous five sections the 2010 dataset is a) larger than the minimum of 8 required; b) shows that parametric tests for compliance can be used if the data is log - transformed; c) shows that the spatial variability in Fe and Mn is the result of natural variability and not the result of past applications to fields; and d) apparently does not contain statistically significant outliers. The recommended monitoring plan utilizes this information from the 2010 samples in conjunction with additional background samples to be obtained from new permanent background monitoring wells. With the exception of compliance well MW-B3, none of the existing wells on site meet the necessary criteria to establish background. MW-B 1 is the only well up -gradient of the fields. The remaining compliance wells (MW-B-8 and MW-B9 and the three other permanent wells remaining on site (MW-1, MW-2, and MW-3) are down gradient of the fields and therefore do not meet the DEQ criteria for background wells going forward. However, data from the 2010 study for MW-1, MW-2, and MW-3 can and should be use as part of the overall dataset used to establish background. The modeling analysis shown in the previous section showed that there is the potential for Fe and Mn to have migrated in some concentrations to these wells as the result of applications in 2014 and 2015 and therefore these and future data from these wells should be excluded from the background analysis. Because Fe and Mn were not required compliance parameters prior to the issuance of the current permit, there is no data from the three compliance wells prior to 2015 for these parameters that could be used to establish background. a) Additional Background Wells This plan recommends the installation and sampling of new wells at five (5) sites and sampled twice at 6 month intervals be used to establish background concentrations for iron and manganese. These sites were selected based upon the transient model analyses discussed above the are shown on Figures 2 through 4 and were chosen to meet the criteria listed in the DEQ and EPA guidance. The coordinates of these sites are shown in Table 2 below. Well No Easting Northing P-MW-1 2126155 691193 P-MW-2 2124156 688177 P-MW-3 2123614 686726 P-MW-4 2125044 688180 P-MW-5 2126427 689422 Table 2.-- Coordinates of Proposed Background Mon'toring Wells. Type 1 monitoring wells should be constructed at these sites that are screened from the depth of the seasonal high water permanent watertable to the top of PWR. Based upon the 2009 S&EC hydrogeologic report for the site the new wells will be approximately 25 feet deep and have ten (10) feet of well screen. The preferred well construction method should be sonic or air rotary drilling to eliminate blinding off of the formation by drilling muds with hydraulic rotary or smearing of the formation by hollow stem auger methods. 13 The wells are to be constructed using new threaded 2-inch diameter PVC casing and wire -wound screen with a number 10 (0.01 inch) opening. The wells are to be completed with a graded sand pack installed in the annulus between the well screen and borehole wall from the bottom of the boring to two feet above the top of the screened interval. A bentonite seal at least 1 foot thick is to be placed on top of the sand pack and a concrete seal placed above it to the land surface. The wells are to be completed with above -ground, lockable, protective metal well casings. The new background wells should be developed using industry standard procedures as documented in the DEQ guidance document. Pumping, surging, and bailing should be used in an effort to develop the sand pack used so as to minimize the potential for fine sediment to enter the wells during the sampling events. Development should continue until the produced water is visibly clear and preferably has a turbidity of 10 NTU or less or the turbidity levels are stable (three consecutive turbidity measurements do not vary by more than 10%). b) Sampling to Establish Background The newly constructed background wells and the three compliance wells should be sampled on a bi- monthly basis for the first six months following their installation to develop an adequate sample population for background assessment. Thereafter, these wells should be sampled on the same schedule used for the existing three compliance wells (March, July, and November) for one year to assess any longer term time trends. Low flow purging and sampling of all wells should be used to conform with the DEQ guidance document0. Low flow well purging should continue until turbidity levels are less than 10 NTU or vary no more than 10% and field measured pH and water temperature are similarly stable. c) Initial Sampling Methodology Assessment An initial evaluation of low -flow purging and sampling was conducted of the three existing compliance wells (MW-B-3, MW-B-8, and MW-B9) on February 5,2016 by CORPUD staff using procedures recommended by Eagle Resources to assess the ability to implement the procedures for obtaining valid metal samples recommended by DEQ. Low flow well purging was conducted for approximately 30 minutes with pH, temperature and turbidity measurements made at approximately 7 minute intervals. The wells were purged with the dedicated bladder pumps installed in each well controlled with a GeoControl Pro system which filled the bladder for 20 seconds and discharged for 10 seconds, resulting in a flow rate of 0.375 gallons per minute. The field measurements for this purging event are shown in Table 3. Water samples were taken at the end of the purging in pre -acidified sample containers supplied by the CORPUD laboratory and the results of these analyses are shown in Table 3. It is apparent that the DEQ requirements for low flow purging and sampling can be implemented for the compliance wells. While the turbidity in well MW- B9 was slightly greater than 10 NTU, subsequent measurements were stable within 10% of the initial value. 10 NC Division of Water Quality, May 13, 2013: Aquifer Protection Section Policy for Metals Determinations Required by Title 15A North Carolina Administrative Code, Subchapter 2L. 14 ialie,7esarces Elapsed Time, Min 1 8 16 23 Purge Volume Gal 0.38 3.00 6.00 8.63 MW-B-3 pH 4.81 4.55 4.57 4.59 Temp Deg C 15.20 15.6 15.8 15.80 NTU 0.20 1.30 1.35 0.95 Dissolved Fe (mg/I) 0.111 Dissolved Mn (mg/I) < .05 Conductivity (umhos/cm) 43.4 MW-B-8 pH 4.80 4.74 4.83 4.79 Temp Deg C 14.80 15.1 15.1 15.10 NTU 2.43 2.00 1.48 1.86 Dissolved Fe (mg/I) 0.109 Dissolved Mn (mg/I) 0.148 Conductivity (umhos/cm) 189 MW-B-9 pH 5.61 5.15 5.06 4.97 Temp Deg C 14.20 13.8 13.9 13.90 NTU 14.90 13.40 13.10 13.30 Dissolved Fe (mg/I) 0.57 Dissolved Mn (mg/I) < .05 Conductivity (umhos/cm) 64.2 Table 3.-- Results of purging of compliance wells on February 5, 2016 and laboratory analyses for dissolved Fe and Mn in samples taken at the end of purging.. Recommended Background Determination Methodology The following steps are recommended to implement the determination of background concentrations of As, Fe, and Mn at the Wrenn Road Site: 1. Install and develop the five (5) new background monitoring wells as recommended herein; 2. Sample the background and compliance wells bi-monthly for six (6) months following the installation and development of the new wells. The sampling should follow the recommended low -flow purging, and field analysis for pH, Conductivity, Turbidity, and Temperature. Samples taken should be analyzed in the CORPUD laboratory for As, Fe and Mn This will provide a background sample size of 15 (5 wells x 3 samples) for each constituent. One duplicate should be taken from one of the background wells that is randomly selected for each sampling round; 3. Prepare probability plots of the 15 sample results for each constituent using the log transform of the raw values; and visually compare to the plots for the 2010 samples; 4. Conduct One-way Analysis of Variance (ANOVA) on the log -transformed values to assess whether the new background results are from the same population as the 2010 samples; 5. If the ANOVA shows that the new and 2010 samples are from the same population, pool both to 15 Ea%,7esa«es define the background statistics to use in compliance monitoring; or 6. If the ANOVA shows that the new and 2010 samples are not from the same population, use only the new samples to define the background statistics to use in compliance monitoring; and 7. Sample the new background wells for one year on the same schedule used for the compliance wells (March, July, and November) to evaluate any time trends in As, Fe, Mn to consider in compliance assessments. Log transformation should be applied to all these data. Conclusions A recommended methodology for establishing the background statistics for the concentrations of Arsenic (As) Iron (Fe) and Manganese (Mn) in groundwater at the Wrenn Road facility that can be used in assessing compliance in the three compliance wells monitored at the site under the currently issued permit WQ0002708. This methodology was prepared in response to a condition of the issuance of the permit by NC DEQ. Information on As, Fe, and Mn concentrations is available from the 2010 study at the site that was collected before application of residual effluent from the Dempsey E. Benton Water Treatment Plant began in 2014 under the permit. However, the wells used to collect these samples were temporary and could not be re -sampled and the sample purging and collection methods used for that study were not necessarily conformant with DEQ guidance for metals evaluation that was published in 2012 and 2013. Consequently, additional background wells are recommended to be installed to supplement the 2010 data. Five additional background wells are recommended at sites where modeling analyses conducted as part of this plan showed that concentrations of mobile constituents contained in effluent applied in 2014 and 2015 were not likely to have reached. The plan recommends sampling the new wells bi-monthly for six months to provide an adequate sample size for assessing background concentrations of As, Fe, and Mn. To assess the additional value provided by also considering the results from the 2010 study, statistical evaluations are recommended to ascertain if data from the new wells is from the same population as that from the 2010 study. If so, all the data should be pooled to provide a more robust sample size to establish the distributions and statistics to use in compliance assessment. If these tests show that the new and 2010 data are not from the same population only the new data should be used. This assessment concluded that to enable the use of parametric tests for compliance that the raw As, Fe, and Mn concentrations should be log - transformed. To assess any time trends in background values of As, Fe, and Mn it is recommended that the background wells be sampled for one year on the same schedule used for the compliance wells. The background wells should be maintained in such as a condition that they can be resampled following this period if necessary. 16 B Responses to DEQ Comments — Provided October 7, 2017 11_ 54e Peoarce5 Rick Bolich, L.G. Assistant Supervisor N.C. Dept. of Environmental Quality Division of Water Resources Water Quality Regional Operations Section Raleigh Regional Office 3800 Barrett Drive Raleigh, NC 27609 rick. bolich@ncdenr. gov October 7, 2017 Subject: Groundwater Monitoring Plan for City of Raleigh Wrenn Road Facility Permit WQ0002708. Dear Rick; This letter responds to your email dated May 2, 2017 to Chris Brown of HDR regarding the location of proposed new monitoring wells to establish ambient concentrations of iron and manganese in groundwater at the Wrenn Road Facility. Our response to the issues you provided in that email are attached. Please contact us if you need any further information on this matter. We are available to meet with you if necessary to discuss any additional information that you may need to approve the monitoring plan. Sincerely yours, 01/ Eric G. Lappala, P.E., P.H. Attachment: Response to additional information request Eagle Resources, P.A. 215 West Moore Street Southport, NC 28461 919-345-1013 www.eagleresources.com eaie ieerces Comment: The proposed background wells P-MW-1 and P-MW-5 appear to be in a topographically upgradient areas that would be good locations for background assessment of groundwater conditions. P-MW-2, P-MW-3. and P-MW-4 are not in locations suited to be background locations. They may be suitable monitoring stations for site conditions affected by lagoon and spray field activities, but these locations are not representative of background concentrations as they appear to be hydraulically downgradient of the waste application areas. DWR recommends moving these two wells to a location that is unlikely to be impacted by waste application. Response: The groundwater flow and transport modeling performed for this site demonstrate that all wells chosen to establish background conditions, including P-MW-2, P-MW-3, and P-MW-4, are unlikely to have been impacted by the application of water treatment residuals, even if they are within the boundaries of the facility. The objective of the proposed monitoring plan is to establish statistically significant ambient background conditions that include any contribution from applied wastewater effluent during that period. The site was used previously by the Town of Garner and operated by the City of Raleigh to dispose of treated wastewater effluent from 1989 through 2008 under permit WQ0002708 (Permit). • Sampling and analysis for iron and manganese in groundwater was not required under that permit. • The Eagle Resources 2010 study used to support the modification of the Permit detected elevated concentrations of iron and manganese in temporary monitoring wells that were located within and down gradient of fields that had been used for wastewater effluent from 1989 to 2008. • Therefore, any concentrations of these constituents that are currently in groundwater are the result of both their natural occurrence and any concentrations that may have been present in the wastewater effluent applied under the permit from 1989 through 2008. The application of water treatment residuals from the Dempsey E. Benton Water Treatment Plant under the amended permit that was issued in 2012 began in 2014. The three-dimensional groundwater flow and transport model used in the 2010 report was updated and used to assess the likely extent of migration of iron and manganese may have occurred as the result of the application of water treatment residuals. As documented in the 2010 report the migration of both iron and manganese in groundwater is influenced by the complex geochemical interaction of these constituents with the soils, saprolite and weathered bedrock that underlie the site. These interactions all act to attenuate the migration of iron and manganese relative to the migration of groundwater via a variety of sorption processes. However, to provide the likely maximum extent of their migration from the application of water treatment residuals, the updated model did not include any of these attenuation processes. The DEQ guidance document on establishing ambient background also requires that a statistically valid data set be present that accounts for the spatial variability hydrogeologic conditions as well concentrations of the regulated constituents that were present prior to the application of water treatment residuals. Because of the size and complexity of the Wrenn Road site, it therefore is necessary to include monitoring sites that are within the boundaries of the site and that may be apparently hydraulically down gradient of some application fields but that have not been impacted by the application of water treatment residuals. 2 All the proposed monitoring wells locations were selected to meet above criteria. Locating additional wells only at topographically up -gradient locations of all fields will not meet the requirement to account for this spatial variability and account for presence of iron and manganese interior to the site that were detected in samples taken for the 2010 report that may have included a contribution from the application of wastewater effluent prior to 2008. Therefore, we believe that it is scientifically appropriate to install monitoring wells at the proposed locations in order to establish background conditions. Comment: Please use caution if you intend to use groundwater quality data from the 2010 Eagle Resources study and report to establish background metals concentrations as some of the wells in this study had turbidity in excess of the levels recommended in the NCDEQ July 2012 "Evaluating Metals in Groundwater at DWQ Permitted Facilities: A Technical Assistance Document for DWQ Staff" as mentioned in previous correspondence. Please also note filtered samples are not acceptable for use in establishing metals concentrations at permitted facilities in accordance with the May 13, 2013 policy memo by Jay Zimmerman, "Aquifer Protection Section Policy for Metals Determinations Required by Title 15A, North Carolina Administrative Code, Subchapter 2L ". Response: We intend to use only data that we deem in our professional opinion to be representative of background conditions. Comment: DWR also recommends that any new compliance monitoring wells used to monitor potential impacts from waste applications be placed at the review or compliance boundary. Response: We will consult with DWR on the location of any new compliance wells if they become necessary. 3 c Ground Water Monitoring Plan Resubmittal — Submitted on December 14, 2018 Transmittal Date: Friday, December 14, 2018 Project: City of Raleigh Wrenn Road Facility To: Rick Bolich, L.G., DEQ From: Chris Brown, PE, HDR Subject: Groundwater Permit We are sending you: ❑Z Attached ❑ Shop drawings ❑ Samples ❑ Change Order ❑ Under separate cover via the following items: ❑ Prints ❑ Plans ❑ Specifications ❑ Copy of letter ❑ Other: Copies Date No. Description 1 Dec 13 2018 Letter from Eagle Resources — Relocated Wells These are transmitted as checked below: ❑X For your approval ❑X For your use ❑X As requested ❑X For review/comment ❑ For bids due ❑ Approved as submitted ❑ Approved as noted ❑ Returned for corrections ❑ Other: ❑ Resubmit ❑ Submit ❑ Return ❑ Prints returned after loan to us Remarks: Mr. Bolich — HDR Engineering, Inc. of the Carolinas (HDR) is pleased to provide DEQ with the above item. This is a follow up to comments received at our Oct 2017 meeting. The team has been working with the adjacent land owner on acquisition of property. We would like to meet in Jan 2019 to discuss a path forward. Please let us know if you have any questions. Copy to: Dennis Lassiter, Chris Phelps, Whit Signed: Chris Brown 919.677.9350 Wheeler, Jesse Walker, Tracy McLamb - chris.brown@hdrinc.com City of Raleigh; Eric Lappala, Eagle Resources; Samantha Black, Manish Bhandari - HDR 555 Fayetteville Street, Suite 900, Raleigh, NC 27601 hdrinc.com (919) 232-6600 ra taie Peoarce,5 Rick Bolich, L.G. Assistant Supervisor N.C. Dept. of Environmental Quality Division of Water Resources Water Quality Regional Operations Section Raleigh Regional Office 3800 Barrett Drive Raleigh, NC 27609 rick.bolich@ncdenr.gov December 13, 2018 Subject: Groundwater Monitoring Plan for City of Raleigh Wrenn Road Facility Permit WQ0002708 Dear Rick, This letter transmits the revised locations of the four (4) proposed background monitoring wells for the subject facility that are shown on the attached map. Wells PMW-2 and PMW-3 will be installed on property recently acquired by the City of Raleigh. Well PMW-3 is to be accessed for installation from the adjacent subdivision which has provided permission for same. The location of PMW-1 has not changed from the original monitoring plan We have moved the location of PMW-4 to the location shown on the attached map to provide better access for drilling equipment. We are available at your convenience to meet to discuss the monitoring plan and these locations if it is necessary. Sincerely yours, Eric G. Lappala, P.E., P.H. Attachments: Proposed monitoring well location map Eagle Resources, P.A. 215 West Moore Street Southport, NC 28461 919-345-1013 www.eagleresources.com EXPLANATION 0 Proposed Background Monitoring Wells Property Boundaries (Wake County GIS) Well No. Easting PMW-1 PMW-4 PMW-2 2126151.11 2125522.18 2124505.08 Northing 691215.39 687848.49 691694.17 PMW-3 2121970.6 688486.31 F1 ta Pesar-ces Eagle Resources, P.A. 215 West Moore Street Southport, NC 28461 919-345-1013 elappala@eagleresources.com City of Raleigh Public Utilties Department Project No. 24041.1 Approved: EGL Date: 11/28/18 Design data and recommendations included herein are provided as a matter of information and should not be used for final design. Rely only on hard copy bearing consultants original seal and signature Location of proposed background moniitoring wells Wrenn Road Facilty. ;�tltIVY CArjQ4i�fe.i s ".7- 6990 • ;Gt4NE,r, FIGURE 1 D Minutes from Resubmittal Discussion Meeting — Meeting Held on January 31, 2019 Meeting Minutes Project: City of Raleigh — Wrenn Road Facility Ground Water Monitoring Plan Subject: Meeting with City and DEQ Date: Thursday, January 31, 2019 Location: DEQ Offices, 3800 Barrett Drive Attendees: Chris Phelps — City of Raleigh Samantha Black — HDR Rick Bolich — DEQ Manish Bhandari — HDR Brion Byers — DEQ Chris Brown — HDR Eric Lappala — Eagle Resources Goal of the Meeting The goal of this meeting was to gain verbal approval of the Wrenn Road Facility Ground Water Monitoring Plan so the City may proceed to the implementation and monitoring phase. An additional goal was to make DEQ aware of changes that may come to the existing Wrenn Road Facility following the future expansion of Interstate-540 (1-540). History of the Wrenn Road Facilties Ground Water Monitoring Plan A brief history of the Wrenn Road Facility Ground Water Monitoring Plan was provided during the meeting as follows: • The current permit (WQ0002708) was issued in 2015, and allowed the continued operation of the Wrenn Road Facility. Part of this permit was the requirement that the City monitor ground water wells for manganese, iron, and arsenic. • In February 2017, a revised monitoring plan was submitted to DEQ. • In May 2017, comments on the revised plan were received by DEQ. • In October 2017, the City/HDR provided responses to DEQ comments, and a meeting was held with the City, DEQ, and HDR to discuss these responses. Changes to some of the background wells were requested by DEQ during this meeting. • In 2018, the City obtained a parcel of land adjacent to the Wrenn Road Facility. This parcel provided options for locating background wells. This parcel will provide easier access to monitoring well #3. • In December 2018, revised background well locations were submitted to DEQ for review. These locations were selected based on fieldwork conducted by Eagle Resources and the well driller. Two well locations were added to the west of the Wrenn Road Facility. Revised Well Locations There are four proposed monitoring wells (PMWs). PMW-4 was relocated to avoid a drilling access issue, and it is now on the access road. DEQ is interested in the ground water flow directions for PMW-4, and requested a 5-ft contour map of this site. Additionally, a water table map and water levels were requested. Wells will be drilled into partially weathered rock, and are not considered bedrock wells. It is estimated that the depth of these wells will be less than 50 feet. The nearby subdivision ground water well might influence PMWs if they are to be drilled into partially weathered rock. It was suggested that a monitoring device be put in to observe the diurnal influence of the subdivision well. The partially weathered rock is a relatively high permeability, and there is no significant change in water level based on a recent study. The screening level of the PMWs will be from the bottom, across the water table. Impacts of 1-540 to the Wrenn Road Facility In the future, 1-540 will be expanded on a portion of the Wrenn Road Facility. It is expected that this expansion will result in the abandonment of at least one MW, consumed 15 to 16 acres of irrigation land, and change the compliance boundary. The 1-540 design -build project is in the early stage of design, and it is anticipated that it will be one year until the design is complete. A conceptual drawing of where 1-540 will be located was provided in the agenda. The City will deal with the changes caused by the 1-540 expansion project when the design is closer to completion. The PMWs will not be impacted by 1-540. It may be beneficial to submit the ground water monitoring plan once changes from the 1-540 project are established since construction will impact the water table. However, the City will need to submit a permit modification after the new compliance boundary is established. Alternatively, having a plan in place prior to 1-540 construction may be beneficial as well to get background data collected before construction for comparison purposes. The City plans to wait to abandon wells impacted by 1-540 until they can no longer use associated the spray irrigation area. Although 15 to 16 acres of land will be lost due to the 1-540 expansion, the City currently has excess capacity. However, the permit will still need to be modified to reflect the new capacity. Action Items and Next Steps • HDR/Eagle Resources to provide existing subdivision water well locations, ground water well levels, well depth, and a contour map to DEQ. • DEQ will review information and generate a ground water flow map. • HDR to resubmit the revised Wrenn Road Facility Ground Water Monitoring Plan to DEQ for review. These minutes were prepared by Samantha Black with HDR> Please provide comments within 5 days of receipt to Samantha.black@hdrinc.com or 919-232-6638. E Water Well Locations for Subdivision Adjacent to the Wrenn Road Facility Appendix E — Water Well Locations for Subdivision Adjacent to the Wrenn Road Facility HDR has identified three wells located within the Glen Creek Community: 1. Well 1: One drinking water well is completely developed, and is located on the north side of the community (Figures 1 and 2). 2. Well 2: A second drinking water well has been drilled, but is not currently in use, and is located the south side of the community (Figures 3 and 4). 3. Well 3: The third well is an irrigation well, which supplies irrigation water to the community (Figures 5 and 6). Table 1 provides a summary of these community wells, and the following figures show photographs of wells and their locations relative to the closest proposed monitoring wells (PMWs). Table 1. Glen Creek Community Wells Well Use Latitude, Longitude Closest PMW 1 Drinking Water 35.6466, -78.5855 PMW-2 2 Drinking Water 35.6363, -78.5937 PMW-3 3 Irrigation Water 35.6503, -78.5803 PMW-2 Figure 1. Existing Drinking Water Well Located on the North Side of the Glen Creek Community 1 Well No. Easting 2126151.11 2125522.18 2124505.08 PMW-3 2121970.6 Northing 691215.39 687848.49 691694.17 688486.31 Approximate location of existing drinking water well Figure 2. Existing Drinking Water Well Location Relative to PMW-2 `LW POOLE WELL & PUMP CO. _ 'O BOX 1958 WENDELL, N.C. 27591 919-266-9223 CERTIFICATION #J DATE COMPLETED: Fi _ DEPTH:- CASING DEPTH:_ _FL DIAMEiER:`1N. STATIC WATeq LEVEL_ _ Y1ELp; GPM i 0sP Via. _r i Figure 3. Future Drinking Water Well Located on the South Side of the Glen Creek Community Approximate location of future drinking water well Figure 4. Future Drinking Water Well Location Relative to PMW-3 2 Figure 5. Existing Irrigation Well Located on the North Side of the Glen Creek Community Approximate location of irrigation well Figure 6. Irrigation Well Location Relative to PMW-2 3 F Ground Water Well Levels City of Raleigh Ground Water Monitoring Plan Wrenn Road Facility Ground Water Well Levels B-3 MP Elev 346.00 B-8 MP Elev 226.46 B-9 MP Elev 247.94 Date DTW WL EL Date DTW WL EL Date DTW WL EL 3/9/2017 19.70 326.30 42803.00 20.50 205.96 42803.00 11.20 236.74 7/5/2017 20.60 325.40 42921.00 21.10 205.36 42929.00 12.10 235.84 11/7/2017 22.80 323.20 43046.00 23.60 202.86 42937.00 12.30 235.64 3/8/2018 22.00 324.00 43167.00 22.30 204.16 43046.00 12.20 235.74 7/5/2018 22.40 323.60 43286.00 23.00 203.46 43167.00 11.40 236.54 7/12/2018 22.60 323.40 43293.00 23.20 203.26 43286.00 12.60 235.34 11/8/2018 21.50 324.50 43412.00 22.70 203.76 43293.00 12.50 235.44 G Contour Map of Proposed Monitoring Well Locations 500 EXPLANATION 0 Compliance Wells and July 2018 Water Level Q Background Wells Property Boundaries (Wake County GIS) Land Surface Elevation Modeled Steady State Watertable 2014 Well No. Water Table Elev MW-B-9 235.34 MW-B-8 203.26 MW-B-3 323.4 0 MW-B-9 '4235.34 500 1000 1500 2000 Ft MW-B-3 323.4 0 PMW-4, PMW-1 PP� taie Pesarces Eagle Resources, P.A. 215 West Moore Street Southport, NC 28461 919-345-1013 elappala@eagleresources.com City of Raleigh Public Utilties Department Project No. 24041.1 Approved: EGL Date: 02/02/19 Design data and recommendations included herein are provided as a matter of information and should not be used for final design. Rely only on hard copy bearing consultants original seal and signature Proposed background moniitoring wells, existing compliance wells, topography, modeled steady state watertable elevations, and measured water level elevations in July 2018, Wrenn Road Facilty FIGURE 1 This page intentionally left blank HDR Engineering, Inc. of the Carolinas 555 Fayetteville Street Suite 900 Raleigh, North Carolina, 27601 919-232-6600 NCBELS Number F-0116 hdrinc.com © 2019 HDR, Inc., all rights reserved 3 Wrenn Road Background Monitoring Well Installation Report (2019) E�Z hdrinc.com November 19, 2019 Mr. Rick Bolich NC Department of Environmental Quality Division of Water Resources Water Quality Regional Operations Section Raleigh Regional Office 3800 Barrett Drive Raleigh, NC 27609 Re: Ground Water Monitoring Plan Permit No. WQ0002708 City of Raleigh Wrenn Road Facility Wastewater Irrigation System Wake County, North Carolina Dear Mr. Bolich, On behalf of the Public Utilities Department I Raleigh Water, we are submitting the attached Installation and Testing of Background Wells report prepared by Eagle Resources, P.A., under subcontract to HDR. This report was prepared to satisfy requirements of the Ground Water Monitoring Plan for the Wrenn Road Facility Wastewater Irrigation System Package, submitted to NC DEQ DWR in February 2019, and approved in April 2019. Should you have any questions, please do not hesitate to call us at 919-232-6657. Sincerely, HDR Engineering Inc. of the Carolinas Chris Brown, PE Project Manager Enclosures CC: Chris Phelps, Public Utilities Department I Raleigh Water Dennis Lassiter, Public Utilities Department I Raleigh Water Whit Wheeler, Public Utilities Department I Raleigh Water Eric Lappala, Eagle Resources Samantha Black, HDR Manish Bhandari, HDR 555 Fayetteville Street Suites 900 & 210, Raleigh, NC 27601-3034 (919) 232-6600 Ira taqiePeoarce,5 Chris Brown, P.E. HDR 555 Fayetteville Street Suite 900 Raleigh, NC 27601 11/08/19 Subject: Wrenn Road Background Monitoring Well Installation Report Dear Chris; This letter transmits the updated data and information from my observations of the installation and testing of the four background monitoring wells at the Wrenn Road facility. These wells were installed as part of the monitoring program to establish background concentrations of Fe, Mn, and As in groundwater in accordance with the monitoring plan documented in our report dated February 2017 and approved by the NC Division of Water Resources, Raleigh Regional Office (NCDWR RRO). This update includes the results of turbidity testing on PMW-3 and PMW-4 that was conducted on 11/06/19 at your request. Sincerely yours, Eric G. Lappala, P.E., P.H. Attachment: Well Installation Report? Eagle Resources, P.A. 215 West Moore Street, Southport, NC 28461 919-345-1013 www.eagleresources.com Installation and Testing of Background Wells City of Raleigh Wrenn Road Facility, Garner, NC Prepared for: HDR and City of Raleigh Public Utilities Department September 25, 2019 (Updated 11/08/19) t4kAl 4-4 x I• �rl Eric G, Lappala, P.E., P.H. esai, kien5urce -; EAGLE RESOURCES, P.A. 215 WEST MOORE STREET SOUTHPORT, NC 28461 Table of Contents Introduction 1 Well Installation 1 Turbidity Testing 2 Pump Testing 4 Sampling Protocol Recommendations 5 Attachment 1 Photos and Description of Drill Cutting Samples 7 PMW-1 7 Attachment 2 Well Completion Records 11 Attachment 3 Pumping Test Analysis Curves 15 Figures Figure 1.-- Locations of Installed Background Monitoring Wells. 6 Tables Table 1.-- Well Completion Information 1 Table 2.-- Turbidity measurements in PMW-1. 2 Table 3.-- Turbidity measurements in PMW-2. 2 Table 4.-- Turbidity measurements in PMW-4. 3 Table 5.--Pumping and recovery test analysis results. 5 i eaiSPegu-ces Introduction This report documents the installation, turbidity testing, water level measurements, and estimated aquifer hydraulic parameters for four wells installed at the Wrenn Road facility. These wells were installed to be used as part of the program' that has been approved by NC DWR to establish background concentrations of iron (Fe), Manganese (Mn), and Arsenic (As) to use as alternatives to the NC 2L groundwater standards for these constituents. The locations of these wells are shown on Figure 1 and were determined by GPS by Eagle Resources. Well Installation The wells were all installed by Geologic Exploration of Statesville, NC under the direction and contract to HDR. The installation dates and completion information provided by driller are shown in Table 1. At the direction of Eagle Resources, all wells were drilled and completed with depths that extended at least into the Partially Weathered Rock (PWR) that underlies the soil and saprolite at all locations. All wells were drilled with a GeoprobeTM track -mounted drill rig that had the capabilities for both down -hole air - percussion (Air) and hollow -stem auger (HSA) methods. Units Well ID PMW-1 PMW-2 PMW-3 PMW-4 Date Drilled 8/13/19 8/14/09 8/26/19 8/13/19 Drill Method HSA HSA HSA Air/ HSA Drill Diameter In 10/6 8 8 8 Depth Ft 43 20 16 74 Screen Top Depth Ft 33 10 6 64 Screen Bottom Depth Ft 43 20 16 74 Sand Pack Top Depth Ft 31 8 4 61 Sand Pack Bottom Depth Ft 43 20 16 74 Bentonite Top Depth Ft 29 6 3 58 Bentonite Bottom Dept Ft 31 8 4 61 Grout Top Depth Ft 0 0 0 0 Grout Bottom Depth Ft 29 6 3 58 Static Water Level Depth Driller Ft 22 5 2 22 Stickup Ft 3.0 3.0 3.7 2.9 Depth to Water from TOC (8/26/19) Ft 23.63 7.99 7.60 20.22 Table 1.-- Well Completion Information. Well PMW-4 was installed to the completed depth using Air but HSA was used to complete the well as the open hole caved at a depth of approximately 22 feet. All other wells were installed using the HSA method. Completion of all wells was accomplished by installation of screen, casing, sand pack, bentonite, and grout as the HSA was removed. Grout was installed by pumping with a tremie pipe to assure no bridging. All wells were developed by the driller by surging and pumping with a submersible pump until the pump discharge was visibly clear. Soil samples were collected by either the driller or Eagle Resources at 5 to 10-foot intervals or significant 1 Eagle Resources, 2017: Proposed Monitoring Plan to Establish Background Concentration of Iron and Manganese at the Wrenn Road Sprayfields Wake County, NC. 1 eaie 1e:irce5 change in the visual appearance of drill cuttings during drilling. The sample descriptions and photos of the sampled materials are shown in Attachment 1. The logs of materials encountered by the driller and well construction details are included in the Well Completion Records (Forms GW-3) and are included as Attachment 2. Turbidity Testing Wells PMW-1, PMW-2, and PMW-4 were tested for turbidity during pumping on August 26, 2019 by Eagle Resources. PMW-3 was not tested because it was bit installed prior to the time turbidity testing equipment having to be returned. However, turbidity testing in this well was completed on 11/06/19 as discussed below. Pumping was conducted by Geologic Exploration using a downhole submersible pump. Turbidity measurements were made on samples collected during pumping with a Hanna HI 98703 Portable Turbidimeter. For wells PMW-1 and PMW-2, pumping continued until the turbidity readings became stable or were less than 5 NTU. Well PMW-4 was cycled between pumping and recovery in an attempt to produce stable and low turbidity readings. Pumping rates were determined by using a bucket of known volume and a stopwatch. Turbidity readings and chart for each well are shown in Tables 2, 3, and 4. Well Pumping Time Turbidity Pumping Rate Minutes NTU GPM PMW-1 5 524 0.94 9 21.4 0.94 13 5.47 0.94 20 2.79 0.94 25 1.38 0.94 30 1,05 0.94 1000 D 1- Z 100 42 10 1 PMW-1 0 10 20 30 40 Pumping Time, Minutes Table 2.-- Turbidity measurements in PMW-1. Well Pumping Time Turbidity Pumping Rate Minutes NTU GPM PMW-2 2 210 1.41 6 22.9 1.41 10 7.95 1.41 21 4.86 1.41 25 5.78 1.41 35 5.57 1.41 40 4.64 1.41 1000 1 PMW-2 0 10 20 30 40 50 Pumping Time, Minutes Table 3.-- Turbidity measurements in PMW-2. 2 tag& Pea rCe5 Well Pumping Time Turbidity Pumping Rate Minutes NTU GPM PMW-4 2 610 0.84 5 484 0.84 9 394 0.65 17 368 0.56 24 216 0.56 29 254 0.56 38 pump off 50 pump on 51 184 0.76 57 174 0.60 65 136 0.53 75 213 0.56 80 442 0.56 83 462 0.56 Turbidity, NTU 1000 100 10 Table 4.-- Turbidity measurements in PMW-4. PMW-4 ti J 0 20 40 60 80 100 Pumping Time, Minutes On 11/06/19 PMW-3 and PMW-4 were tested for turbidity using a portable downhole submersible pump and a portable turbidity meter. Pumping from PMW-3 was continuous at an estimated 1 gpm. Pumping from PMW-4 was cyclic as the measured depth to water in the well was 22.55 feet below the top of casing and only 25 feet of discharge line was available and after approximately 10 seconds of pumping the water in the well was drawn down below the pump intake. Consequently, samples were taken after the well was allowed to recover for approximately 15 seconds. The turbidity readings for these tests are shown in Tables 5 and 6. Well Pumping Time Turbidity Pumping Rate Minutes NTU GPM PMW-3 (11/06/19) 1 46.6 nm 5 22.5 nm 10 8.01 nm 15 5.06 nm 20 6.54 nm 25 1.67 nm 30 3.05 nm 100 D 1- Z 10 197 PMW-3 (11/06/19) 0 10 20 30 40 Table 5.-- Results of turbidity testing on PMW-3 on 11/06/19. Pumping Time, Minutes 3 to /e Pe5arce5 Well Pumping Cycle Turbidity Pumping Rate No NTU GPM PMW-4 (11/06/19) 2 39.3 nm 3 33 nm 4 31.3 nm 5 25.6 nm 6 18.7 nm 7 25 nm 8 18.9 nm 9 26.9 nm 10 28.7 nm Turbidity, NTU 100 10 PMW-4 (11/06/19) 1 3 5 Table 6.-- Results of turbidity testing on PMW-4 on 11/06/19. Pumping Cycle 9 Based upon the turbidity readings in PMW-1, PMW-2, and PMW-3 it appears that purging these wells for at least 30 minutes of continuous pumping should achieve levels consistent with the sampling and analysis protocol recommended in the approved monitoring program of 10 NTU or less. The initial turbidity readings in PMW-4 did not stabilize and were not as low as potentially may be achieved. Subsequent testing on 11/06/19 showed that pumping from the top of the water column in the well was approximately stable at 20 NTU. Because the dedicated air-lift pump in this well is set at the bottom of the well, it is recommended that this well be further developed by air-lift pumping and surging and additional turbidity measurements made if this low level is not observed while purging before sampling. . Pump Testing Although it was not required as part of the approved monitoring program, water level changes during pumping and recovery cycles of PMW-1, PMW-2, and PMW-4 were recorded by manual measurements with an electric water level sounder and with a downhole recording transducer that was read at the surface (In -Situ LevelTrollTM 400). These water level changes and the corresponding pumping rates were used to evaluate the transmissivity, hydraulic conductivity, and storage properties of the formation sections in which the wells were screened. The water level and pumping data were analyzed using AgteSOLVTM. The results are summarized in Table 5. The analysis curves for both the Theis and Neuman analysis methods for unconfined aquifers are presented as Attachment 3. 4 tag& Pe5arC85 Well ID Units PMW-1 PMW-2 PMW-3 PMW-4 formation thickness, b ft 21 15 No test 52 Pumping rate(s), Q oz 18 18 18 gal 0.140625 0.140625 0.140625 sec 9 6 15 min 0.15 0.1 0.25 gpm 0.94 1.41 0.56 Aquifer type Unconfined Unconfined Method Theis Theis Transmissivity, T ft"2/d 32 162 1.5 Hydraulic conductivity, K ft/d 1.5 10.8 0.029 Storage Coefficient, S Dim 8.00E-05 0.0025 0.0056 Vertical to Horizontal K, Kz/Kr) Dim 1 1 1 Neuman Neuman Neuman Transmissivity, T ft"2/d 7.2 131 1.07 Hydraulic conductivity, K ft/d 0.34 8.73 0.02 Storage Coefficient, S Dim 0.009 0.0035 0.02 Table 7.--Pumping and recovery test analysis results. Sampling Protocol Recommendations Sampling protocol should meet the requirements of the approved background sampling program for the site as documented on page 14 of the approved report (footnote 1). Documentation of sampling should use the spreadsheet developed by HDR. 5 EXPLANATION Monitoring Wells 40 Background Monitoring Well O Compliance Monitoring Well Property Boundaries (Wake County GIS) 2000 Ft Eagle Resources, P.A. 215 West Moore Street Southport, NC 28461 919-345-1013 elappala@eagleresources.com City of Raleigh Public Utilties Department Project No. 24041.1 Approved: EGL Date: 09/25/19 Design data and recommendations included herein are provided as a matter of information and should not be used for final design. Rely only on hard copy bearing consultants original seal and signature Location of installed background moniitoring wells and compliance wells. Wrenn Road Facilty. kyt cod.* Jr 6990 111 FIGURE 1 tale Pe5arce5 Attachment 1 Photos and Description of Drill Cutting Samples PMW-1 PMW-2 PMW-2 Depth, Ft Description Color 5 Brown to tan silty sand soil and saprolite 10 YR 7/4 F 10 Dark brown sandy saprolite minor rock fragments, moist 10 YR 2/2 r 15 Dark brown sandy saprolite minor rock fragments, moist 10 YR 2/2 20 Dark Brown to green brown sandy saprolite minor mica 10 YR 2/2 8 tag& Pe5arC85 PMW-3 PMW-3 Depth, Ft Description Color 5 Dark Brown organic sandy saprolite minor mica 5 YR 2/2 PP 10 Dark brown sandy saprolite, large rounded pebbles abundant mica flakes moist to saturated 5 Y 4/4 15 Dark brown sandy saprolite minor rock fragments saturated 10 YR 2/2 9 PMW-4 PMW-4 Depth, Ft Description Color 0 -5 Reddish Brown Sandy Soil, dry 2.5 YR 2/8 10 Orange Brown Coarse sandy saprolite, dry 10 YR 4/6 15 Dark tan to orange brown sandy saprolite dry 5 YR 4/4 20 Tan saprolite - sandy clay very moist to saturated 10 YR 6/6 25 Tan saprolite - sandy clay very moist to saturated 10 YR 6/6 30 Tan saprolite - sandy clay very moist to saturated 10 YR 6/6 35 Clayey silt slightly sandy saprolite - saturated 10 YR 5/4 40 Weathered to partially weathered rock drier 5 YR 6/4 45 Weathered to partially weathered rock very moist 10 YR 4/4 50 Weathered to partially weathered rock saturated 10 YR 4/4 10 tale Pe5arce5 Attachment 2 Well Completion Records 11 WELL CONSTRUCTION RECORD This form can be used for single or multiple wells 1. Well Contractor Information: For Internal Use ONLY: JOHNNY BURR Well Contractor Name A - 3098 NC Well Contractor Certification Number GEOLOGIC EXPLORATION, INC Company Name 2. Well Construction Permit #: List all applicable well construction permits (i.e. County, State, Variance, etc.) 3. Well Use (check well use): Water Supply Well: ❑ Agricultural ❑Geothermal (Heating/Cooling Supply) ❑Indu strial/Commercial ❑Irrigation ❑Municipal/Public ❑Residential Water Supply (single) ❑Residential Water Supply (shared) Non -Water Supply Well: OMonitoring ❑Recovery Injection Well: El Aquifer Recharge ❑Aquifer Storage and Recovery El Aquifer Test ElExperimental Technology ❑Geothermal (Closed Loop) El Geothermal (Heating/Cooling Return) El Groundwater Remediation ❑ Salinity Barrier ❑ Stormwater Drainage El Subsidence Control ❑ Tracer El Other (explain under #21 Remarks) 4. Date Well(s) Completed: 08/14/19 Well ID# 5a. Well Location: WRENN ROAD WASTE WATER PLANT Facility/Owner Name PMW-1 Facility ID# (if applicable) 8828 WRENN ROAD GARNER 27529 Physical Address, City, and Zip WAKE County Parcel Identification No. (PIN) 5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees: (if well field, one lat/long is sufficient) 35° 38' 20.87" N 78° 34' 59.72" 6. Is (are) the well(s): ©Permanent or ❑Temporary W 7. Is this a repair to an existing well: ❑Yes or ❑No If this is a repair, fill out known well construction information and explain the nature of the repair under #21 remarks section or on the back ofthis form. 8. Number of wells constructed: For multiple injection or non -water supply wells ONLY with the same consfruethn, you can submit one form. 1 9. Total well depth below land surface: 43'0 (ft.) For multiple wells list all depths rf d fferent (example- 3g200' and 2@100) 10. Static water level below top of casing: 22.0 (ft.) If water level is above casing, use ••+" 11. Borehole diameter: 10.016.0 (in.) 12. Well construction method: AUGER/AIR (i.e. auger, rotary, cable, direct push, etc.) FOR WATER SUPPLY WELLS ONLY: 13a. Yield (gpm) Method of test: 13b. Disinfection type: Amount: 14. WATER ZONES FROM TO DESCRIPTION ft. ft. ft. ft. 15. OUTER CASING (for multi -cased wells) OR LINER (if ap licable) FROM TO DIAMETER THICKNESS MATERIAL ft. ft. in. 16. INNER CASING OR TUBING (geothermal closed -loop) FROM TO DIAMETER THICKNESS MATERIAL 0.0 ft 33.0 IL 2.0 in. SCH 40 PVC ft. ft. in. 17. SCREEN FROM TO DIAMETER SLOT SIZE THICKNESS MATERIAL 33.0 ft. 43.0 ft. 2.0 m• .010 SCH 40 PVC ft. ft. in. 18. GROUT FROM TO MATERIAL EMPLACEMENT METHOD & AMOUNT 0.0 ft. 29.0 ft PORTLAND1BJTONITE SLURRY ft. ft. ft. ft. 19. SAND/GRAVEL PACK (if applicable) FROM TO MATERIAL EMPLACEMENT METHOD 31.0 ft. 43.0 ft 20-40 FINE SILICA SAND ft. ft. 20. DRILLING LOG (attach additional sheets if necessary) FROM TO DESCRIPTION (color, hardness, soiVrock type, grain size, etc) 0.0 ft. 1.0 rt• GRAVEL 1.0 ft 6.0 ft ORANGE SANDY CLAY 6.0 ft 40.0 ft. BROWN SILTY CLAY 40.0 ft 43.0 ft. BROWN ROCK ft. ft. ft. ft. ft. ft. 21. REMARKS BENTONITE SEAL FROM 29.0 TO 31.0 FEET 22. Certification: Signature of Certified Well Contractor 09/05/19 D ate By signing this form, I hereby certlfy that the well(s) was (were) constructed in accordance with 15A NCAC 02C .0100 or 15A NCAC 02C .0200 Well Construction ,Standards and that a copy of this record has been provided to the well owner. 23. Site diagram or additional well details: You may use the back of this page to provide additional well site details or well construction details. You may also attach additional pages if necessary. SIJB141ITTAL INSTUCTIONS 24a. For All Wells: Submit this form within 30 days of completion of well construction to the following: Division of Water Quality, Information Processing Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617 24b. For Infection Wells: In addition to sending the form to the address in 24a above, also submit a copy of this form within 30 days of completion of well construction to the following: Division of Water Quality, Underground Injection Control Program, 1636 Mail Service Center, Raleigh, NC 27699-1636 24c. For Water Supply & Injection Wells: In addition to sending the form to the address(es) above, also submit one copy of this form within 30 days of completion of well construction to the county health department of the county where constructed. Form GW-1 North Carolina Department of Environment and Natural Resources -Division of Water Quality Revised Jan. 2013 WELL CONSTRUCTION RECORD This form can be used for single or multiple wells 1. Well Contractor Information: For Internal Use ONLY: JOHNNY BURR Well Contractor Name A - 3098 NC Well Contractor Certification Number GEOLOGIC EXPLORATION, INC Company Name 2. Well Construction Permit #: List all applicable well construction permits (i.e. County, State, Variance, etc.) 3. Well Use (check well use): Water Supply Well: ❑ Agricultural El Geothermal (Heating/Cooling Supply) ❑Industrial/Commercial ❑Irrigation ❑Municipal/Public ❑Residential Water Supply (single) ❑Residential Water Supply (shared) Non -Water Supply Well: ❑✓Monitoring ❑Recovery Injection Well: ❑ Aquifer Recharge ❑ Aquifer Storage and Recovery ❑Aquifer Test ❑Experimental Technology El Geothermal (Closed Loop) ❑Geothermal (Heating/Cooling Return) ❑ Groundwater Remedi ation ❑ Salinity Barrier ❑ Stormwater Drainage ❑Subsidence Control ❑ Tracer ❑ Other (explain under #21 Remarks) 4. Date Well(s) Completed: 08/14/19 Well ID# 5a. Well Location: WRENN ROAD WASTE WATER PLANT PMW-2 Facility/Owner Name Facility ID# (if applicable) 8828 WRENN ROAD GARNER 27529 Physical Address, City, and Zip WAKE County Parcel Identification No. (PIN) 5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees: (if well field, one tat/long is sufficient) 35° 38' 20.87" N 78° 34' 59.72" 6. Is (are) the well(s): ©Permanent or ❑Temporary W 7. Is this a repair to an existing well: ❑Yes or ONo If this is a repair, fill out known well construction information and explain the nature of the repair under #21 remarks section or on the back of this form. 8. Number of wells constructed: 1 For multiple injection or non -water supply wells ONLY with the same constnw ion, you can submit one form. 9. Total well depth below land surface: 20'0 (ft.) For multiple wells list all depths if different (example- 3@200'and 2@100) 10. Static water level below top of casing: 5'0 (ft.) If water level is above casing, use "+" 11. Borehole diameter: 10.0/6.0 (in.) 12. Well construction method: AUGER/AIR (i.e. auger, rotary, cable, direct push, etc.) FOR WATER SUPPLY WELLS ONLY: 13a. Yield (gpm) Method of test: 13b. Disinfection type: Amount: 14. WATER ZONES FROM TO DESCRIPTION ft. ft. ft. ft. 15. OUTER CASING (for multi -cased wells) OR LINER (if ap licable) FROM TO DIAMETER THICKNESS MATERIAL ft. ft. in. 16. INNER CASING OR TUBING (geothermal closed -loop) FROM TO DIAMETER THICKNESS MATERIAL 0.0 ft. 10.0 it. 2.0 in. SCH 40 PVC ft. ft. in. 17. SCREEN FROM TO DIAMETER SLOT SIZE THICKNESS MATERIAL 10.0 ft. 20.0 ft• 2.0 m' .010 SCH 40 PVC ft. ft. in. 18. GROUT FROM TO MATERIAL EMPLACEMENT METHOD & AMOUNT 0.0 ft. 6.0 ft. PORTL5 D1BJTONITE SLURRY ft. ft. ft. ft. 19. SAND/GRAVEL PACK (if applicable) FROM TO MATERIAL EMPLACEMENT METHOD 8.0 ft. 20.0 It 20-40 FINE SILICA SAND ft. ft. 20. DRILLING LOG (attach additional sheets if necessary) FROM TO DESCRIPTION (color, hardness, soillrock type, grain size, etc.) 0.0 ft. 5.0 It• BROWN SANDY CLAY/ROCKS 5.0 ft• 9.0 ft• BROWN PWR 9.0 ft• 20.0 ft• BROWN ROCK ft. ft. ft. ft. ft. ft. ft. ft. 21. REMARKS BENTONITE SEAL FROM 6.0 TO 8.0 FEET 22. Certification: Signature of Certified Well Contractor 09/05/19 D ate By signing this form, I hereby certify that the well(s) was (were) constructed an accordance with 15A NCAC 02C .0100 or 15A NCAC 02C .0200 Well Construction Standards and that a copy of this record has been provided to the well owner. 23. Site diagram or additional well details: You may use the back of this page to provide additional well site details or well construction details. You may also attach additional pages if necessary. SUBMITTAL INSTUCTIONS 24a. For All Wells: Submit this form within 30 days of completion of well construction to the following: Division of Water Quality, Information Processing Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617 24b. For Infection Wells: In addition to sending the form to the address in 24a above, also submit a copy of this form within 30 days of completion of well construction to the following: Division of Water Quality, Underground Injection Control Program, 1636 Mail Service Center, Raleigh, NC 27699-1636 24c. For Water Supply & Infection Wells: In addition to sending the form to the address(es) above, also submit one copy of this form within 30 days of completion of well construction to the county health department of the county where constructed. Form GW-1 North Carolina Department of Environment and Natural Resources -Division of Water Quality Revised Jan. 2013 WELL CONSTRUCTION RECORD This form can be used for single or multiple wells 1. Well Contractor Information: For Internal Use ONLY: JOHNNY BURR Well Contractor Name A - 3098 NC Well Contractor Certification Number GEOLOGIC EXPLORATION, INC Company Name 2. Well Construction Permit #: List all applicable well construction permits (i.e. County, State, Variance, etc.) 3. Well Use (check well use): Water Supply Well: ❑ Agricultural El Geothermal (Heating/Cooling Supply) ❑Industrial/Commercial ❑Irrigation ❑Municipal/Public ❑Residential Water Supply (single) ❑Residential Water Supply (shared) Non -Water Supply Well: ❑✓Monitoring ❑Recovery Injection Well: ❑ Aquifer Recharge ❑ Aquifer Storage and Recovery ❑Aquifer Test ❑Experimental Technology El Geothermal (Closed Loop) ❑Geothermal (Heating/Cooling Return) ❑ Groundwater Remedi ation ❑ Salinity Barrier ❑ Stormwater Drainage ❑Subsidence Control ❑ Tracer ❑ Other (explain under #21 Remarks) 4. Date Well(s) Completed: 08/27/19 Well ID# 5a. Well Location: WRENN ROAD WASTE WATER PLANT PMW-3 Facility/Owner Name Facility ID# (if applicable) 8828 WRENN ROAD GARNER 27529 Physical Address, City, and Zip WAKE County Parcel Identification No. (PIN) 5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees: (if well field, one tat/long is sufficient) 35° 38' 20.87" N 78° 34' 59.72" 6. Is (are) the well(s): ©Permanent or ❑Temporary W 7. Is this a repair to an existing well: ❑Yes or ONo If this is a repair, fill out known well construction information and explain the nature of the repair under #21 remarks section or on the back of this form. 8. Number of wells constructed: 1 For multiple injection or non -water supply wells ONLY with the same constnw ion, you can submit one form. 9. Total well depth below land surface: 16.0 (ft.) For multiple wells list all depths if different (example- 3@200'and 2@100) 10. Static water level below top of casing: 2'0 (ft.) If water level is above casing, use "+" 10.0 11. Borehole diameter: (in.) 12. Well construction method: AUGER (i.e. auger, rotary, cable, direct push, etc.) FOR WATER SUPPLY WELLS ONLY: 13a. Yield (gpm) Method of test: 13b. Disinfection type: Amount: 14. WATER ZONES FROM TO DESCRIPTION ft. ft. ft. ft. 15. OUTER CASING (for multi -cased wells) OR LINER (if ap licable) FROM TO DIAMETER THICKNESS MATERIAL ft. ft. in. 16. INNER CASING OR TUBING (geothermal closed -loop) FROM TO DIAMETER THICKNESS MATERIAL 0.0 ft. 6.0 ft. 2.0 in. SCH 40 PVC ft. ft. in. 17. SCREEN FROM TO DIAMETER SLOT SIZE THICKNESS MATERIAL 6.0 ft• 16.0 ft• 2.0 m' .010 SCH 40 PVC ft. ft. in. 18. GROUT FROM TO MATERIAL EMPLACEMENT METHOD & AMOUNT 0.0 ft. 3.0 ft. POFRPND1BJTONITE SLURRY ft. ft. ft. ft. 19. SAND/GRAVEL PACK (if applicable) FROM TO MATERIAL EMPLACEMENT METHOD 4.0 ft. 16.0 It 20-40 FINE SILICA SAND ft. ft. 20. DRILLING LOG (attach additional sheets if necessary) FROM TO DESCRIPTION (color, hardness, soillrock type, grain size, etc.) 0.0 ft• 1.0 It• BROWN/BLACK TOPSOIL 1.0 ft• 4.0 ft• BROWN/WHITE SAND 4.0 ft• 16.0 ft• BROWN ROCK ft. ft. ft. ft. ft. ft. ft. ft. 21. REMARKS BENTONITE SEAL FROM 3.0 TO 4.0 FEET 22. Certification: Signature of Certified Well Contractor 09/05/19 D ate By signing this form, I hereby certify that the well(s) was (were) constructed an accordance with 15A NCAC 02C .0100 or 15A NCAC 02C .0200 Well Construction Standards and that a copy of this record has been provided to the well owner. 23. Site diagram or additional well details: You may use the back of this page to provide additional well site details or well construction details. You may also attach additional pages if necessary. SUBMITTAL INSTUCTIONS 24a. For All Wells: Submit this form within 30 days of completion of well construction to the following: Division of Water Quality, Information Processing Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617 24b. For Infection Wells: In addition to sending the form to the address in 24a above, also submit a copy of this form within 30 days of completion of well construction to the following: Division of Water Quality, Underground Injection Control Program, 1636 Mail Service Center, Raleigh, NC 27699-1636 24c. For Water Supply & Infection Wells: In addition to sending the form to the address(es) above, also submit one copy of this form within 30 days of completion of well construction to the county health department of the county where constructed. Form GW-1 North Carolina Department of Environment and Natural Resources -Division of Water Quality Revised Jan. 2013 WELL CONSTRUCTION RECORD This form can be used for single or multiple wells 1. Well Contractor Information: For Internal Use ONLY: JOHNNY BURR Well Contractor Name A - 3098 NC Well Contractor Certification Number GEOLOGIC EXPLORATION, INC Company Name 2. Well Construction Permit #: List all applicable well construction permits (i.e. County, State, Variance, etc.) 3. Well Use (check well use): Water Supply Well: ❑ Agricultural El Geothermal (Heating/Cooling Supply) ❑Industrial/Commercial El Irrigation ❑Municipal/Public ❑Residential Water Supply (single) ❑Residential Water Supply (shared) Non -Water Supply Well: ❑✓Monitoring El Recovery Injection Well: ❑ Aquifer Recharge ❑ Aquifer Storage and Recovery ❑Aquifer Test ❑Experimental Technology El Geothermal (Closed Loop) ❑Geothermal (Heating/Cooling Return) ❑ Groundwater Remedi ation ❑ Salinity Barrier ❑ Stormwater Drainage ❑Subsidence Control ❑ Tracer ❑ Other (explain under #21 Remarks) 4. Date Well(s) Completed: 08/14/19 Well ID# 5a. Well Location: WRENN ROAD WASTE WATER PLANT PMW-4 Facility/Owner Name Facility ID# (if applicable) 8828 WRENN ROAD GARNER 27529 Physical Address, City, and Zip WAKE County Parcel Identification No. (PIN) 5b. Latitude and Longitude in degrees/minutes/seconds or decimal degrees: (if well field, one latllong is sufficient) 35° 38' 20.87" N 78° 34' 59.72" 6. Is (are) the well(s): ©Permanent or ❑Temporary W 7. Is this a repair to an existing well: ❑Yes or ONo If this is a repair, fill out known well construction information and explain the nature of the repair under #21 remarks section or on the back of this form. 8. Number of wells constructed: 1 For multiple injection or non -water supply wells ONLY with the same constnw ion, you can submit one form. 9. Total well depth below land surface: For multiple wells list all depths if different (example- 3@200'and 2@100) 10. Static water level below top of casing: 22.0 (ft.) If water level is above casing, use "+" 11. Borehole diameter: 10.0/6.0 (in.) 12. Well construction method: AUGER/AIR 74.0 (ft.) (i.e. auger, rotary, cable, direct push, etc.) FOR WATER SUPPLY WELLS ONLY: 13a. Yield (gpm) Method of test: 13b. Disinfection type: Amount: 14. WATER ZONES FROM TO DESCRIPTION ft. ft. ft. ft. 15. OUTER CASING (for multi -cased wells) OR LINER (if ap licable) FROM TO DIAMETER THICKNESS MATERIAL ft. ft. in. 16. INNER CASING OR TUBING (geothermal closed -loop) FROM TO DIAMETER THICKNESS MATERIAL 0.0 ft. 64.0 ft• 2.0 in. SCH 40 PVC ft. ft. in. 17. SCREEN FROM TO DIAMETER SLOT SIZE THICKNESS MATERIAL 64.0 ft• 74.0 ft• 2.0 m' .010 SCH 40 PVC ft. ft. in. 18. GROUT FROM TO MATERIAL EMPLACEMENT METHOD & AMOUNT 0.0 ft. 58.0 ft' POFRPNDEwTONITE SLURRY ft. ft. ft. ft. 19. SAND/GRAVEL PACK (if applicable) FROM TO MATERIAL EMPLACEMENT METHOD 61.0 ft• 74.0 ft• 20-40 FINE SILICA SAND ft. ft. 20. DRILLING LOG (attach additional sheets if necessary) FROM TO DESCRIPTION (color, hardness, soil/rock type, grain size, etc.) 0.0 ft• 1.0 It• BROWN SAND 1.0 ft• 8.0 ft• TAN/ORANGE CLAY 8.0 ft• 62.0 ft. TAN/BROWN SANDY CLAY 62.0 ft• 74.0 ft. BROWN ROCK ft. ft. ft. ft. ft. ft. 21. REMARKS BENTONITE SEAL FROM 58.0 TO 61.0 FEET 22. Certification: Signature of Certified Well Contractor 09/05/19 D ate By signing this form, I hereby certify that the well(s) was (were) constructed an accordance with 15A NCAC 02C .0100 or 15A NCAC 02C .0200 Well Construction Standards and that a copy of this record has been provided to the well owner. 23. Site diagram or additional well details: You may use the back of this page to provide additional well site details or well construction details. You may also attach additional pages if necessary. SUBMITTAL INSTUCTIONS 24a. For All Wells: Submit this form within 30 days of completion of well construction to the following: Division of Water Quality, Information Processing Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617 24b. For Infection Wells: In addition to sending the form to the address in 24a above, also submit a copy of this form within 30 days of completion of well construction to the following: Division of Water Quality, Underground Injection Control Program, 1636 Mail Service Center, Raleigh, NC 27699-1636 24c. For Water Supply & Infection Wells: In addition to sending the form to the address(es) above, also submit one copy of this form within 30 days of completion of well construction to the county health department of the county where constructed. Form GW-1 North Carolina Department of Environment and Natural Resources -Division of Water Quality Revised Jan. 2013 tale Pe5arce5 Attachment 3 Pumping Test Analysis Curves 15 Displacement (ft) 10. 1. 0.1 10. 100. Time (sec) pill 1111111,111111,1,111 ull 1000. 1.0E+4 WELL TEST ANALYSIS Data Set: Date: 08/27/19 Time: 08:48:48 PROJECT INFORMATION Company: Eagle Resources Client: CORPUD Location: Wrenn road Test Well: pmw-1 Test Date: 8/25/19 AQUIFER DATA Saturated Thickness: 21. ft WELL DATA Pumping Wells Observation Wells Well Name X (ft) Y (ft) Well Name X (ft) Y (ft) PMW-1 0 0 ° PMW-1 0 0 SOLUTION Aquifer Model: Unconfined Solution Method: Neuman T = 7.156 ft2/day S = 0.009562 Sy = 0.5 13 =0.01761 Displacement (ft) 10. 1. 0.1 10. 100. Time (sec) 1000. 1.0E+4 WELL TEST ANALYSIS Data Set: Date: 08/27/19 Time: 09:21:45 PROJECT INFORMATION Company: Eagle Resources Client: CORPUD Location: Wrenn road Test Well: pmw-2 Test Date: 8/26/19 AQUIFER DATA Saturated Thickness: 15. ft WELL DATA Pumping Wells Observation Wells Well Name X (ft) Y (ft) Well Name X (ft) Y (ft) PMW-2 0 0 ° PMW-2 0 0 SOLUTION Aquifer Model: Unconfined Solution Method: Neuman T = 130.9 ft2/day S = 0.003477 Sy = 0.006212 R = 0.0003113 Displacement (ft) 100. 10. 1. 10. 100. Time (sec) 1000. 1.0E+4 WELL TEST ANALYSIS Data Set: Date: 08/27/19 Time: 10:03:50 PROJECT INFORMATION Company: Eagle Resources Client: CORPUD Location: Wrenn road Test Well: pmw-4 Test Date: 8/26/19 AQUIFER DATA Saturated Thickness: 50. ft WELL DATA Pumping Wells Observation Wells Well Name X (ft) Y (ft) Well Name X (ft) Y (ft) PMW-4 0 0 ° PMW-4 0 0 SOLUTION Aquifer Model: Unconfined Solution Method: Neuman T = 1.071 ft2/day S = 0.01199 Sy = 0.5 R = 0.0001824 4 Complete Wrenn Road Facility Results Raleigh Water I DRAFT Interim Groundwater Monitoring Results Memorandum Appendix4—Complete Groundwater Monitoring Results Appendix 4 — Complete Groundwater Monitoring Results November 2019 Sampled By R. Tart D. Godfrey R. Tart D. Godfrey Date Time Weather Condition Field Data Depth to Water (ft) Total Well Depth (ft) Volume of Water Purg Before Sampling (gal) Turbidity (NTU) pH (standard units) Temperature (°C) Conductivity (pmhos/ Laboratory Data Iron (pg/L) Manganese (pg/L) Arsenic (pg/L) 11/21/2019 11/21/2019 11/21/2019 11/21/2019 11:18AM 8:40 AM 12:23 PM 12:10 PM Clear/Cool/Sunny 24 8 6 21.9 43 20 16 74 d 9.31 6 4.57 25.5 0.48 1.86 1.58 5.08 5.75 5.3 6.03 5.97 16.6 16.8 16.9 17.6 m) 98.9 69.6 129.8 126.2 <60 <60 199 172 90 <50 <50 134 <10 <10 <10 <10 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 Raleigh Water I DRAFT Interim Groundwater Monitoring Results Memorandum Appendix4—Complete Groundwater Monitoring Results January 2020 [ Parameter PMW-1 Sampled By Date Time Weather Condition Field Data Depth to Water (ft) Total Well Depth (ft) Volume of Water Purg Before Sampling (gal) Turbidity (NTU) pH (standard units) Temperature (°C) Conductivity (pmhos/ Laboratory Data Iron (lag/L) Manganese (lag/L) Arsenic (lag/L) R. Tart R. Tart R. Tart D. Godfrey 1/17/2020 1/17/2020 1/17/2020 1/17/2020 10:05 AM 10:49 AM 8:18 AM 10:40 AM Partly Sunny, Cool 23.8 7.4 5.6 20.5 43 20 16 74 9.4 6.1 6.5 27 0.98 0.48 1.06 2.04 5.87 6.02 6.68 6.07 14 15.1 12.8 15.3 m) 91.6 67.2 110.1 121.2 <60 <60 <60 68 74 <50 <50 <50 <10 <10 <10 <10 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 Raleigh Water I DRAFT Interim Groundwater Monitoring Results Memorandum Appendix4—Complete Groundwater Monitoring Results March 2020 [ Parameter PMW-1 PMW-2 PMW-3 PMW-4 Sampled By Date Time Weather Condition Field Data Depth to Water (ft) Total Well Depth (ft) Volume of Water Purg Before Sampling (gal) Turbidity (NTU) pH (standard units) Temperature (°C) Conductivity (pmhos/ Laboratory Data Iron (lag/L) Manganese (lag/L) Arsenic (lag/L) D. Godfrey R. Tart R. Tart D. Godfrey 3/12/2020 3/12/2020 3/12/2020 3/12/2020 12:06 PM 7:50 AM 12:30 PM 9:59 AM Cloudy, Cool 20.85 7.5 5.3 16.2 43 20 16 74 d 11 7 5.25 28.5 1.31 0.53 3.49 1.76 5.31 5.93 7.03 6.16 18.2 14.6 14.3 16.8 m) 90.9 71.8 62.2 115.4 <60 <60 141 <60 64 <50 <50 88 <10 <10 <10 <10 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 Raleigh Water I DRAFT Interim Groundwater Monitoring Results Memorandum Appendix4—Complete Groundwater Monitoring Results April 2020 Parameter PMW-1 PMW-2 PMW-3 PMW-4 Sampled By D. Godfrey R. Tart R. Tart R. Tart Date 4/14/2020 4/14/2020 4/14/2020 4/14/2020 Time 10:15 AM 8:30 AM 11:45AM 10:28 AM Weather Condition Sunny, Clear, 60's Field Data Depth to Water (ft) 20.9 7.7 5.7 16.4 Total Well Depth (ft) 43 20 16 74 Volume of Water Purged Before Sampling (gal) 10.8 6.5 5.0 28.25 Turbidity (NTU) 0.39 0.23 0.46 1.61 pH (standard units) 7.15 7.32 6.27 6.05 Temperature (°C) 17.6 14.8 15.5 17 Conductivity(pmhos/cm) 92.2 68.8 116.4 110.8 Laboratory Data Iron (lag/L) <60 <60 <60 <60 Manganese (lag/L) 70 <50 <50 96 Arsenic (lag/L) <10 <10 <10 <10 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 Raleigh Water I DRAFT Interim Groundwater Monitoring Results Memorandum Appendix4—Complete Groundwater Monitoring Results August 2020 Parameter PMW-1 PMW-1 D PMW-2 PMW-3 PMW-4 Sampled By R. Tart R. Tart R. Tart R. Tart R. Tart Date 8/20/2020 8/20/2020 8/20/2020 8/20/2020 8/20/2020 Time 1:25 PM 1:25 PM 12:01 PM 3:15 PM 12:45 PM Weather Condition Cloudy, 80's Field Data Depth to Water (ft) 22.8 22.8 9.8 6 19 Total Well Depth (ft) 43 43 20 30 74 Volume of Water Purged Before Sampling (gal) 9.8 9.8 5.1 5 26 Turbidity(NTU) 0.68 0.68 1.46 1.69 1.5 pH (standard units) 5.93 5.93 6.01 6.63 6.81 Temperature (°C) 19.1 19.1 20.7 19.8 19 Conductivity (pmhos/cm) Laboratory Data Iron (pg/L) 94.5 <60 96.7 <60 73.3 <60 43.5 482 124.5 69 Manganese (pg/L) 88 90 <50 <50 123 Arsenic (pg/L) <10 <10 <10 <10 <10 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 Raleigh Water I DRAFT Interim Groundwater Monitoring Results Memorandum Appendix4—Complete Groundwater Monitoring Results November 2020 Parameter PMW-1 PMW-1 ' PMW-2 PMW-3 PMW-4 Sampled By D. Godfrey D. Godfrey D. Godfrey D. Godfrey D. Godfrey/ E. Batchelor Date 11/4/2020 11/4/2020 11/4/2020 11/4/2020 11/4/2020 Time 8:25 AM 8:25 AM 9:08 AM 10:44 AM 12:00 PM Weather Condition Clear, 40's/50's Field Data Depth to Water (ft) 22.3 22.3 7.8 5.7 18.9 Total Well Depth (ft) 43 43 20 16 74 Volume of Water Purged Before Sampling (gal) 10.25 10.25 6 5.25 27 Turbidity (NTU) 1.12 1.12 1.86 0.44 0.72 pH (standard units) 5.32 5.32 5.08 5.65 I 5.87 Temperature (°C) 17 17 18.5 18.1 18.2 Conductivity (pmhos/cm) 82 82.4 73.6 101.5 129.8 Laboratory Data Iron (pg/L) <60 <60 72 73 <60 Manganese (pg/L) 59 61 <50 <50 88 Arsenic (pg/L) <10 <10 <10 <10 <10 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 Raleigh Water I DRAFT Interim Groundwater Monitoring Results Memorandum Appendix4—Complete Groundwater Monitoring Results March 2021 1 Parameter PMW-1 PMW-1 ' PMW-2 PMW-3 PMW-4 Sampled By D. Godfrey D. Godfrey D. Godfrey D. Godfrey D. Godfrey Date 3/10/2021 3/10/2021 3/10/2021 3/10/2021 3/10/2021 Time 8:50 AM 8:50 AM 9:22 AM 11:16 AM 1:00 PM Weather Condition Sunny, 40's - 60's Field Data Depth to Water (ft) 18.3 18.3 6.9 5.9 14.1 Total Well Depth (ft) 43 43 20 16 74 Volume of Water Purged Before Sampling (gal) 12.25 12.25 6.5 5 30 Turbidity (NTU) 3.52 3.52 1.52 2.83 0.72 pH (standard units) 5.62 5.62 5.75 6.48 5.85 Temperature (°C) 16.5 16.5 15.5 14.2 19.8 Conductivity (pmhos/cm) Laboratory Data Iron (pg/L) 84.5 97 83.0 132 79.3 199 85.2 123.9 601 <50 Manganese (pg/L) 71 71 16 176 71 Arsenic (pg/L) <5 <5 <5 <5 <5 hdrinc.com 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 FY 555 Fayetteville Street Suite 900 Raleigh, NC 27601-3034 (919) 232-6600 NCBELS License Number F-0116 hdrinc.com © 2021 HDR, Inc., all rights reserved