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HomeMy WebLinkAbout20171559 Ver 3_More Info Received including Residential Well Sampling and Complaint Resolution Plan_20211110Homewood, Sue From: Miller, Vickie M. (Raleigh) <Vickie.Miller@hdrinc.com> Sent: Wednesday, November 10, 2021 7:58 PM To: Homewood, Sue; Wendee Smith; Jim Melvin Cc: Masemore, Sushma; Wojoski, Paul A; Smith, Danny; Gibby, Jean B CIV USARMY CESAW (USA) Subject: [External] RE: GRMS Request for Additional Information Attachments: GRMS_Pad_Buffers_Sept 2021.pdf; GRMS Residential Well Testing Resolution Plan 11102021.pdf CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Hi Sue, In an effort to make certain we are getting information to you and team in a timely manner we will be sending responses to the comments provided on November 5, 2021 as they are developed. Assistant Secretary Masemore and Wendee have discussed this approach and determined that it would make sense to provide the information in the categories as they were identified in the letter. This email and attachment address the Residential Well Sampling and Compliant Resolution Plan (Items 26 to 31 of the letter). The attachment is the revised Plan and below you will find answers to the comments received. These were reviewed by the County staff prior to submission as well as reviewed within HDR. Please let us know if you have additional questions related to this category of comments. 26. Please provide a timeline for pre -construction well testing and confirm it can be done and adequately reviewed prior to start of any land disturbing activities on the site. The County will move as quickly as possible; however, the timeline is tight. With a 4 week period for the first mailing and assuming at least a couple weeks for the second mailing this would mean that sampling will begin at the end of the year and continue into early 2022. The County intends to begin the testing in areas that will be within 500 ft of the land disturbing activities initially and will then expand to areas that exceed the 500 feet from the disturbance until all the testing is completed. 27. Wells in this area are typically completed in the fractured rock aquifer. There is a high degree of variability in fracture density and orientation in this aquifer. A 150-foot radius from the site is insufficient to identify private and public water supply wells for potential impacts, especially given the proposed de -watering scheme. A 500-foot radius is more consistent with established regulatory setbacks for pollution sources and dewatering impacts. Please revise the residential well sampling plan accordingly. We stated 150 feet in the report; however, to better define the area we have stated this as being 150' from the property boundary. The actual boundary of the grading is well over 500 ft to the property line for a large majority of the site. I have attached a map to illustrate the buffer width on the site from the pad area to the property boundary. The 150 feet then extends outside of the property boundary to capture the properties provided in Table 1 of the plan. 28. The residential well sampling plan states that a third party, Randolph County, will perform the well sampling and well yield testing. This represents a significant resource commitment by the County and DEQ would like to have assurances that the County accepts this responsibility and has the financial 1 and technical resources to carry out the specified well sampling and yield testing. Provide documentation of assurance from the County of the commitments identified in the plan. Randolph County will hire an independent third party (Golder Associates) to conduct well sampling and testing. Randolph County will handle mailings and interactions with property owners. The Health Department will evaluate the test results, determine if a well has been compromised, and make recommendations for appropriate remedies. Both the County and Golder Associates have the manpower and technical expertise available to handle this commitment. 29. Since the proposed well yield testing constitutes a hydrogeologic assessment, it will need to be performed under the supervision of a NC licensed geologist or engineer. Please revise the plan to indicate this requirement. Golder Associates has licensed Geologists on staff. The plan now states this requirement. 30. The proposed groundwater quality testing parameters includes VOCs, SVOCs, and pesticides. These tests are very sensitive to contamination during collection, transportation, and lab analyses, and may not provide an accurate measure of possible impacts from the proposed project on groundwater quality. In addition, these samples should be collected by personnel specifically trained in sampling for VOCs, SVOCs, and pesticides. Please revise the groundwater quality testing parameters to also include bacteria, metals, turbidity, and total dissolved solids by EPA -approved drinking water testing methods, and that these analyses must be performed by laboratories that are currently certified for these testing methods by NC DWR. The parameters listed were added to the plan as well as language regarding the laboratories being certified by NCDWR. 31. The proposed dewatering activities are significant, and little information has been provided on the location, process, and duration of this activity. Construction dewatering is a deemed permitted activity, but it must be conducted in a manner that does not result in water quality violations. Provide additional detail on the location and groundwater extraction system elements so that the Division may evaluate this proposed activity. It is highly unlikely that the significant proposed lowering of the water table could be maintained after construction without active pumping or the installation of horizontal and vertical hydraulic barriers. Please provide further details on how this is to be accomplished. Control of groundwater during construction operations will be performed by maintaining positive drainage off the work area and directed toward downstream features. The permanent groundwater management system will consist of ditches and trench drains placed underneath the pad area on an as -needed basis that allow the groundwater to flow into French drains that will be located in the natural channels on -site within proposed fill areas. This will allow the groundwater to flow through the site and into natural downstream channels. Based on permeability testing of soil samples on -site and pump testing of piezometers on -site, the groundwater flow rate is relatively slow within the proposed cut depths such that groundwater extraction using pumps or barriers is not anticipated for long term groundwater management. Thank you, Vickie Vickie Miller, AICP, Pws D 919.232.6637 M 919.559.2632 hdrinc.com/follow-us 2 From: Homewood, Sue <sue.homewood@ncdenr.gov> Sent: Friday, November 5, 2021 1:57 PM To: Miller, Vickie M. (Raleigh) <Vickie.Miller@hdrinc.com>; Wendee Smith <wsmith@s2cnc.com>; Jim Melvin <jimmelvin@aol.com> Cc: Masemore, Sushma <sushma.masemore@ncdenr.gov>; Wojoski, Paul A <Paul.Wojoski@ncdenr.gov>; Smith, Danny <danny.smith@ncdenr.gov>; Gibby, Jean B CIV USARMY CESAW (USA) <Jean.B.Gibby@usace.army.mil> Subject: GRMS Request for Additional Information CAUTION: [EXTERNAL] This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Per our recent conversations and meetings, and as a follow up to the preliminary items sent via email on 11/3/21, please see the attached Request for More Information. Sue Homewood Division of Water Resources, Winston Salem Regional Office Department of Environmental Quality 336 776 9693 office 336 813 1863 mobile Sue.Homewood@ncdenr.gov 450 W. Hanes Mill Rd, Suite 300 Winston Salem NC 27105 Errsll correspondence to aI7d from Os actkass is subject to #fie North Q81r Pubec Placards Law &id rrtay be disclosed to third dies. 3 Residential Well Sampling and Complaint Resolution Plan Greensboro Randolph Megasite Attachment A Randolph County, North Carolina November 10, 2021 Table of Contents 1.0 WATER RESOURCES IDENTIFICATION AND TESTING PLAN 2 2.0 IDENTIFYING WATER RESOURCES 2 2.1 Private Wells and Springs 2 3.0 WATER RESOURCE EVALUATION 3 3.1 Private Water Supplies 3 4.0 POST -CONSTRUCTION BASELINE WATER RESOURCE TESTING 4 5.0 COMPLAINT RESOLUTION PROCESS 4 6.0 REFERENCES 5 Tables 6 Table 1. Potential Properties with Private Water Supply Wells Within 150 Feet 6 Appendices 8 Appendix A. Water Sample Application 9 Appendix B. Well Test for Yield 11 1 1.0 WATER RESOURCES IDENTIFICATION AND TESTING PLAN Randolph County prepared and will execute the terms of this Residential Well Testing and Complaint Resolution Plan (Plan) in connection with the Greensboro Randolph Megasite (Project) to document pre - construction baseline and post- construction water quality and quantity of privately -owned water supply systems. This Plan summarizes protocols for identifying and assessing private water supplies in the vicinity of the Project. Randolph County documented locations and characteristics of private water supplies directly adjacent to the Project boundary and will offer pre- and post -construction quality and yield testing for all water wells located within 150 feet of construction workspaces. Several wells have already been tested by the County. This Plan discusses the outreach methodology that will be followed and the general plan for testing. Private water resources identified for water quality and quantity testing within 150 feet of the GRMS property boundary are summarized in Table 1. Prior to construction, the private water supply owners will be contacted by Randolph County via certified mail to confirm the location and characteristics of water resource(s) on the owner' s property and to request permission for the Project to conduct water quality and quantity sampling. Field confirmation of private water sources began in 2018 but has not been completed on some parcels because property access permission has not been granted. Therefore, this Plan is subject to change following the completion of field environmental investigations. 2.0 IDENTIFYING WATER RESOURCES 2.1 Private Wells and Springs Private wells located within 150 feet of the GRMS property boundary will be identified by desktop review and field observation (where property access was granted). The private water supply sources will be confirmed through pre -construction water supply testing (see Table 1) as described in this Plan. As part of the desktop review for potential drinking water sources an indirect method was employed to identify potential private wells. GIS data taken from the various counties were used to identify if a structure was present on the parcel. To maximize the potential for identifying private water resources all structures were assumed to have one or more private wells. As discussed in this Plan, the property owners identified by desktop review along the Project boundaries will be contacted by Randolph County prior to construction via certified mail to confirm drinking water sources on the identified property and to request permission to conduct water quality and quantity testing. If a private property owner does not respond to the certified mail request for information within approximately four (4) weeks of submittal by Randolph County, a second request will be sent. If no response is provided to the Project through the second submittal, no further contacts will be initiated with the property owner regarding water resources. Potential locations with private wells within 150 feet of the property boundary are identified as described above in Table 1. Appendix A includes the provides the Water Sample Application that will be requested from the water supply owners during the initial contact along with a request for permission to sample the water supply. 2 3.0 WATER RESOURCE EVALUATION The following discussion outlines protocols water supply testing activities. The testing results will be documented by Randolph County and provided directly to the water supply owner. 3.1 Private Water Supplies 1. Randolph County will offer pre- and post- construction quality and yield testing for all water wells and water supple springs located within 150 feet of the Project property boundary. The Project proposes to collect one sample before construction and a second sample three to six months post construction and conduct a well yield test. 2. All private property owners with a known or suspected water source (see earlier discussion) will be contacted prior to construction as discussed below: a. Send contact by mail to mailing address listed for the property owner; b. If no response is received within approximately 4 weeks of sending the first letter, a second follow-up letter will be sent; c. If no response is provided by property owner after two (2) attempts this result will be documented and Randolph County will suspend further contact to the property owner regarding water quality testing; d. If a property owner declines permission to conduct water quality testing, this will be documented, and the Project will suspend further contact with the property owner regarding water quality testing; 3. Property and water supply access approval documentation will be secured by Randolph County before entering the property. See Appendix A for information to be collected from the water supply owner during initial and follow-up contact. 4. A field crew will be deployed to collect water samples at the identified locations. 5. The sampling location coordinates will be collected using GPS (1-meter resolution) and recorded. 6. Field testing, sample collection and sample management techniques will be implemented consistent with industry standards and approved guidance (U.S. EPA and North Carolina Department of Environmental Quality). 7. For water well testing, a water sample will be collected from a flowing spigot (after a minimum of 10 minutes purging) upstream of any treatment system (if applicable) in order to collect a raw water sample in the appropriate laboratory -prepared sample bottle with appropriate preservatives. Field parameters will be analyzed at the time of water sample collection. a. If the well does not have a pump installed, or does not demonstrate artesian flow, there will be limited ability to complete the testing described in this plan. 8. Water samples will be kept cool and transported to the analytical laboratory(ies) under Chain of Custody. 9. The water quality testing will include groundwater quality standards for Bacteriological, Inorganic Chemical, Volatile Organic Compounds, Pesticides, Metals, Turbidity, and Total Dissolved Solids (15A NCAC 02L .0202 GROUNDWATER QUALITY STANDARDS) and the USEPA drinking water testing methods EPA 524.2, EPA 525.2, respectively, and Total Petroleum Hydrocarbons in EPA SW846 8015C. a. The pre and post -construction sampling events will be comprised of the same tests per the groundwater quality standards unless there is a concern noted by the property owner, or if there is a verified detection of a VOC or SVOC or TPH from the first sampling event. 3 b. National Environmental Laboratory Accreditation Program (NELAP)- accredited laboratories will be utilized for water sample analyses. These analyses must be performed by laboratories that are also currently certified for these testing methods by NCDWR. 10. Water resources testing activities (including the condition of the water resource and equipment) will be photo -documented. All field activities and meter calibration for each water resources sampling event will be documented. 11. The first pre -construction sampling event provides an opportunity to evaluate the condition of each well, surrounding topography, land characteristics/land-use, and generally assess the overall vulnerability of the water supply to existing or future sources of impact. 12. Randolph County will provide the water supply owner with the water supply testing results. Concurrent with providing the owner these results, the County will discuss with the owner any conditions that observed at the water supply that represent potential for existing or future sources of impacts. 13. The second sampling event will also include well yield testing. The water supply owner will be apprised of the well yield testing procedure, and Randolph County will request permission to access the well for the quantity testing, at the owner's discretion. This testing will be performed under the supervision of a NC licensed geologist or engineer. 14. Randolph County will consult with an owner who appears to have a compromised water supply based on pre -construction sampling results. The Project will tailor an evaluation protocol for the second round of water quality testing as appropriate to evaluate the integrity of the water supply and ensure a comprehensive pre and post construction assessment is completed. 4.0 POST -CONSTRUCTION BASELINE WATER RESOURCE TESTING Randolph County will conduct post -construction testing of all water supply wells within 150 feet of the GRMS property boundaries within properties where the owner has accepted the testing offer. Randolph County will follow the same procedures described above for water supply sampling. The Project will provide the post -construction monitoring results directly to the property owner. Randolph County will maintain water supply contingency planning efforts through the construction period and until final land reclamation is completed. 5.0 COMPLAINT RESOLUTION PROCESS If a claim of impact is made by a private well owner, a thorough investigation of the alleged impact will be conducted by qualified groundwater and surface water scientists and engineers using industry standard hydrogeologic investigative practices. This will include a review of the timing of the claim relative to the construction schedule, detailed interview with the supply owner, mechanical evaluation of the water system, possible resampling and analysis of the supply, performance of a hydrogeologic assessment, and other pertinent evaluations. Because each water supply system and hydrogeologic setting is unique, the only means to establish a clear link between a water supply quality or quantity issue and Project activities is through a comprehensive evaluation leading to complaint resolution. If the Randolph County Health Department determines that an impact was related to construction of the GRMS, then the investigations described above will provide valuable information concerning the appropriate remedies. Restoration of a water supply could include: • temporary supplied water until the water quality returns to baseline; • connection to secondary source, if available; and/or 4 • temporary treatment to establish baseline quality (or better). If the hydrogeologic assessment indicates that a long-term solution is needed, the following remedies as appropriate may be used to restore water quality and quantity to pre- construction conditions: • a new on -site source (new water well); or a combination of source replacement and treatment options; or • connection to the City of Greensboro's water supply system. 6.0 REFERENCES National Environmental Laboratory Accreditation Program (NELAP), 2016. http://www.nelacinstitute.org/content/NELAP/index.php 5 Tables Table 1. Potential Properties with Private Water Supply Wells Within 150 Feet of the Property Boundary Parcel ID Street Address City State Zip 8708735760 6135 JULIAN AIRPORT RD LIBERTY NC 27298 8708735798 6135 JULIAN AIRPORT RD LIBERTY NC 27298 8717960600 5014 TROY SMITH RD LIBERTY NC 27298 8717993994 5948 MACEDONIA LOOP RD LIBERTY NC 27298 8718915221 5948 MACEDONIA LOOP RD LIBERTY NC 27298 8728002688 5948 MACEDONIA LOOP RD LIBERTY NC 27298 8708733381 4742 CALHOUN DR LIBERTY NC 27298 8708710363 5731 JULIAN AIRPORT RD LIBERTY NC 27298 8728024087 7611 OLD 421 RD LIBERTY NC 27298 8717335231 6041 STARMOUNT RD LIBERTY NC 27298 8717442907 4807 HOOTS HOLLOW RD LIBERTY NC 27298 8708724777 5945 JULIAN AIRPORT RD LIBERTY NC 27298 8717648977 4595 TROY SMITH RD LIBERTY NC 27298 8707990472 5536 JULIAN AIRPORT RD LIBERTY NC 27298 8708803377 565 W PERRY RD SILER CITY NC 27344 8708734021 6029 JULIAN AIRPORT RD LIBERTY NC 27298 8718446055 P O BOX 1691 LIBERTY NC 27298 8708616529 5775 JULIAN AIRPORT RD LIBERTY NC 27298 8708709448 5616 JULIAN AIRPORT RD LIBERTY NC 27298 8708807291 4606 CRUTCHFIELD FARM RD LIBERTY NC 27298 8708743132 9154 OLD 421 RD JULIAN NC 27283 8708722536 5925 JULIAN AIRPORT RD LIBERTY NC 27298 8718540083 324 W WENDOVER AVE, SUITE 207 GREENSBORO NC 27408 8708723471 4813 WOODVERY DR LIBERTY NC 27298 8717728661 5466 STARMOUNT RD LIBERTY NC 27298 8717982190 5230 TROY SMITH RD LIBERTY NC 27298 6 8717989604 5230 TROY SMITH RD LIBERTY NC 27298 8717442242 P O BOX 887 LIBERTY NC 27298 8708607893 2309 MICHELLE LN GREENSBORO NC 27407 8708713955 2309 MICHELLE LN GREENSBORO NC 27407 8708724709 200 HAMMOCK FARM RD WINSTON SALEM NC 27105 8708713423 5324 SHADY HOLLOW RD STALEY NC 27355 8718738218 PO BOX 326 LIBERTY NC 27298 8718823833 PO BOX 326 LIBERTY NC 27298 8708614323 5729 JULIAN AIRPORT RD LIBERTY NC 27298 8718733763 7846 OLD 421 RD LIBERTY NC 27298 8717520081 204 LOYD RD STATESVILLE NC 28625 8708704424 5667 JULIAN AIRPORT RD LIBERTY NC 27298 8717996279 5334 TROY SMITH RD LIBERTY NC 27298 8717950680 4948 TROY SMITH RD LIBERTY NC 27298 8708723262 5085 STALEYS DAIRY RD LIBERTY NC 27298 8718537779 8124 OLD 421 RD LIBERTY NC 27298 8708734596 P O BOX 434 LIBERTY NC 27298 8708713756 5781 JULIAN AIRPORT RD LIBERTY NC 27298 8717558375 6767 BROOKBANK RD SUMMERFIELD NC 27358 8717971072 4977 PEARL FERGUSON RD LIBERTY NC 27298 8717969801 4977 PEARL FERGUSON RD LIBERTY NC 27298 8708723059 600 PURTIS CREEK LN GEORGETOWN TX 78628 7 Appendices 8 Appendix A. Water Sample Application 9 Applicant: Address: Application #: City, ST ZIP Parcel number: COUNTY OF RANDOLPH Health Department 204 E Academy St - Asheboro, NC 27203 WATER SAMPLE APPLICATION Date: Owner: Contact name: Address: Contact phone: City, ST ZIP Contact e-mail: LOCATION INFORMATION: Location: Subdivision: Lot number: WELL AND WATER INFORMATION: Facility Type: Well Type: Select the well type. Well Location: Select the well location. Faucet at well: Select faucet at well. If No, Specify Location: Water Treatment System Present: Select treatn Treatment Type: WATER SAMPLE INFORMATION: Type of water sample needed: Type of water sample needed. Additional water sample needed: Type of water sample needed. Additional water sample needed: Type of water sample needed. COMMENTS: AUTHORIZATION TO PROCEED: I have read this application and certify that the information provided herein is true, complete and correct. Authorized County and State officials are granted right of entry to conduct necessary inspections to determine compliance with applicable laws and rules. I understand that I am solely responsible for making the site accessible so that a water sample can be collected. Signature of property owner/legal representative Date LOCAL TELEPHONE NUMBERS Asheboro: (336) 318-6262 • Archdale/Trinity: (336) 819-3262 http://www.randolphcountync.gov Water Sample Application (EHWS 1) Rev. 9/5/2019 Appendix B. Well Test for Yield 11 15A NCAC 02C .0110 WELL TESTS FOR YIELD (a) Every domestic well shall be tested for capacity by one of the following methods: (1) Pump Method (A) select a permanent measuring point, such as the top of the casing; (B) measure and record the static water level below or above the measuring point prior to starting the pump; (C) measure and record the discharge rate at intervals of 10 minutes or less; (D) measure and record water levels using a steel or electric tape at intervals of 10 minutes or less; (E) continue the test for a period of at least one hour; and (F) make measurements within an accuracy of plus or minus one inch. (2) Bailer Method (A) select a permanent measuring point, such as the top of the casing; (B) measure and record the static water level below or above the measuring point prior to starting the bailing procedure; (C) bail the water out of the well for a period of one hour or longer; (D) determine and record the bailing rate in gallons per minute at the end of the bailing period; and (E) measure and record the water level after stopping bailing process. (3) Air Rotary Drill Method (A) measure and record the amount of water being inj ected into the well during drilling operations; (B) measure and record the discharge rate in gallons per minute at intervals of one hour or less during drilling operations; (C) after completion of the drilling, continue to blow the water out of the well for 30 minutes or longer and measure and record the discharge rate in gallons per minute at intervals of 10 minutes or less during the period; and (D) measure and record the water level after discharge ceases. (4) Air Lift Method. Measurements shall be made through a pipe placed in the well. The pipe shall have an inside diameter of at least five -tenths of an inch or greater and shall extend from top of the well head to a point inside the well that is below the bottom of the air line. (A) Measure and record the static water level prior to starting the air compressor; (B) Measure and record the discharge rate at intervals of 10 minutes or less; (C) Measure and record the pumping level using a steel or electric tape at intervals of 10 minutes or less; and (D) Continue the test for a period of one hour or longer. (b) Public, Industrial, and Irrigation Wells. Every industrial or irrigation well and, if required by rule adopted by the Commission for Public Health, every well serving a public water supply system upon completion shall be tested for capacity by the following or equivalent method: (1) The water level in the well to be pumped and in all observation wells shall be measured and recorded prior to starting the test. (2) The well shall be tested by a pump of sufficient size and lift capacity to test the yield of the well, consistent with the well diameter and purpose. (3) The pump shall be equipped with throttling devices to reduce the discharge rate to approximately 25 percent of the maximum capacity of the pump. (4) The test shall be conducted for a period of 24 hours or longer without interruption and, except for wells constructed in Coastal Plain aquifers, shall be continued for a period of four hours or longer after the pumping water level stabilizes. (5) The pump discharge shall be set at a constant rate or rates that can be maintained throughout the testing period. If the well is tested at two or more pumping rates (a step-drawdown test), pumping at each pumping rate shall continue to the point that the pumping water level declines no more than 0.1 feet per hour for a period of four hours or more for each pumping rate, except for wells constructed to Coastal Plain aquifers. In wells constructed in Coastal Plain aquifers, pumping at each pumping rate shall continue for four hours or longer. (6) The pump discharge rate shall be measured by an orifice meter, flowmeter, weir, or equivalent metering device. The metering device used shall have a calibration accuracy within plus or minus five percent of a known standard. (7) The discharge rate of the pump and time shall be measured and recorded at intervals of 10 minutes or less during the first two hours of the pumping period for each pumping rate. If the pumping rate is constant after the first two hours of pumping, discharge measurements and recording may be made at longer time intervals not to exceed one hour. (8) The water level in each well and time shall be measured and recorded at intervals of five minutes or less during the first hour of pumping and at intervals of 10 minutes or less during the second hour of pumping. After the second hour of pumping, the water level in each well shall be measured at such intervals that the lowering of the pumping water level does not exceed three inches between measurements. (9) A reference point for water level measurements shall be selected and recorded for the pumping well and each observation well to be measured during the test. All water level measurements shall be made from the selected reference points, which shall be permanently marked. (10) All water level measurements shall be made with a steel or electric tape or equivalent measuring device. (11) All water level measurements shall be made within an accuracy of plus or minus one inch or to 0.1 foot. (12) After the completion of the pumping period, measurements of the water level recovery rate in the pumped well shall be made in the same manner as the drawdown for a period of two hours or greater. History Note: Authority G.S. 87-87; 87-88; Eff. February 1, 1976; Amended Eff. September 1, 2009, April 1, 2001; December 1, 1992; September 1, 1984; April 20, 1978; Readopted Eff. September 1, 2019. Legend Megasite Boundary Permit Pad Area -41-0- Pad Buffers 0 Feet 1,200 F)1 CONFIDENTIAL GREENSBORO-RANDOLPH MEGASITE North Carolina, U.S.A. September 2021 PAD BUFFER MAP CREENSBORO RANDOLPH