WQ0008764_Monitoring Wells_20070808

Nutter & Associates, Inc.
August 8, 2007
Yancy D. Helton
WP Home
P.O. Box 388
Wagram, North Carolina 28396
Subject: Monitoring. Results, LAM Monitoring Wells, WP Home Land, Application
System. Permit No. WQ0008764. Project No. 95-004.
Dear Mr. Helton:
Nutter & Associates has received from WP Home water quality data for the land application
monitoring (LAM) well system for the period July 2001 through March 2007. The LAM wells
monitor ground water quality in the vicinity of WP Home's biosolids (sludge) land application
system (LAS). The data provided to Nutter & Associates have.also been provided by WP
Home to the North Carolina Department of Environment and Natural Resources in
compliance reports submitted following monitoring conducted in March, July and November
of each year: We have reviewed the data provided by WP Home, particularly with respect to
trends in ground water nitrate -nitrogen.
Table 1 shows nitrate -nitrogen concentrations in the LAM wells since July 2001. Figure 1
shows trends in nitrate -nitrogen concentration over the same period. Figure 2 shows the
location of the LAM wells. Biosolids application to Bermudagrass-planted fields 26-70 was
discontinued in 1997. Biosolids application to fields 1-25 (forested fields) was discontinued
in 1994 and biosolids application to fields 71-90 (Bermudagrass fields) wasdiscontinued in
1996. WP Home's LAS has been inactive since 1996 and will remain inactive.
These data indicate that ground water nitrate -nitrogen has decreased throughout the entire
mod -application system and is now below 10 mg/L at all LAM wells except one. The sole
exception is well LAM-3 (located east of inactive application fields 26-70) where ground
water nitrate-N was 14.1 mg/L in March 2007 (Figure 1, Table 1). Ground water nitrate -
nitrogen concentrations at LAM-3 have been gradually decreasing since November 2003
(Figure 1) and are expected to continue to decrease over the long term.
360 Hawthorne Lane, Athens, GA 30606
(706) 35H-7925 Fox (706) 35y 7928
nutterinccom

Mr. Yancy Helton
WP Home
August 8, 2007
Page 2
LAM-3 is located down gradient of fields 26-70, and ground water flow from well LAM-3 is
generally toward WP Home's property east of Airbase Road (Figure 2). LAM-3 is not a
compliance boundary well, but is instead bounded to the east and west by properties owned
by WP Home. As has been documented in the past (e.g., Eleventh Supplement, Phase
2Ground Water Quality Assessment, and previous supplements), a ground water divide
prevents shallow ground water flow from LAM-3 toward WP Home's property line and
compliance boundary, located to the south. Ground water quality at the compliance
boundary south of LAM-3 was monitored by a temporary well (Well I=) through March 2005;
ground water nitrate -nitrogen has remained well below 10 mg/L at Well E. In February
2006, NCDENR approved a request to change ground water monitoring at the LAS,
including suspension of monitoring at the temporary wells (including Well E).
Ground water nitrate -nitrogen concentrations have decreased substantially in the vicinity of
the LAS. With LAS operations discontinued, land -applied biosolids are no longer a source
for nitrogen leaching to ground water. Application fields will continue to be managed with
the current coastal Bermudagrass and planted pine cover crops, and these crops will
continue to remove nitrogen from application field soils and minimize the potential for
nitrogen to leach to ground water.
Proposed Action: Discontinuation of LAM Ground Water Monitoring
Biosolids land application has been discontinued at the site, and ground water nitrate -
nitrogen has been reduced to below 10 mg/L at most locations across the LAS, including all
compliance boundary wells. Land application at the site will'not resume. Nutter &
Associates recommends discontinuing ground water monitoring at the LAM well network. If
no additional data are required by NCDENR from the LAM wells after one year, Nutter &
Associates recommends that the LAM wells be plugged and abandoned in accordance with
North Carolina regulations. As noted above, NCDENR has already approved suspension of
monitoring at wells A through G2; these wells should be plugged and abandoned at the
same time as the LAM wells. WP Home should consult with NCDENR to gain approval
before implementing proposed changes in the monitoring program, including well
abandonment.

Mr. Yancy Helton
WP Home
August 8, 2007
Page 3
If you have any questions regarding this matter or need further assistance, please let us
know.
Sincerely,
NUTTER & ASSOCIATES, INC.
Dennis B. O'Connell, Ph.D.
Project Scientist
cc: Eddie Lanier. WP Home

Table 1. Ground water nitrate -nitrogen concentrations, July 2001 through March 2007, LAM monitoring well network, WP Home land
application system, Wagram, North Carolina.
Location
LAM1 LAM-7 LAM-8 LAM-2 LAM-3 LAM-4 LAM-6 LAM-9 LAM-10 LAM-12 LAM-13 LAM-14 LAM-15
Date -COMP
mg/L
July 2001
17.4
25.7
9.1
<0.5
<0.5
<0.5
<0.5
14.7
<0.5
<0.5
14.2
1.1
2.2
November 2001
21
33
17.9
< 0.1
< 0.1
< 0.1
< 0.1
15
0.7
0.4
23.2
1.3
3
March 2002
25.2
19.5
7.8
< 0.1
< 0.1
< 0.1
< 0.1
16.9
< 0.5
< 0.5
17.1
1.7
2.1
July 2002
18.8 `
30
7.7
< 0.5
< 0.5
< 0.5
< 0.5
16
0.5
< 0.5
20.8
2.8
3
November 2002
35.6
29.8
11.7
< 0.5
< 0.5
< 0.5
< 0.5
13.6
< 0.5
< 0.5
15.1
5.1
2.2
March 2003
16.8
30
10.7
< 0.5
< 0.5
< 0.5
< 0.5
21.8
< 0.5
< 0.5
12.4
3.8
3.2
July2003
17.4
17.7
3
<0.5
<0.5
<0.5
<0.5
21
0.6
<0.5
10.8
0.6
2.7
November 2003
17.8
17.9
19.3
< 0.5
< 0.5
< 0.5
< 0.5
20.4
1.3
< 0.5
15.5
1.9
3.1
March 2004
25
19.5
15.9
< 0.5
< 0.5
< 0.5
< 0.5
9.5
1
< 0.5
13.4
2.3
2.5
July 2004
19.9
12.4
13.2
1.2
<0.5
<0.5
<0.5
7.5
<0.5
<0.5
5.2
1.2
1.5
November 2004
19.7
13.7
15.9
3.1
< 0.5
0.9
< 0.5
9.4
1.7
0.6
3.1
2.4
1.6
March 2005
18.6
15.3
9.2
1.9
< 0.5
< 0.5
< 0.5
12.9
0.8
0.6
12
2.1
2.3
July 2005
20.1
13.4
12.3
0.9
< 0.5
< 0.5
< 0.5
7.7
0.5
0.6
8.7
1.8
1.9
November 2005
7.7
6.7
7.5
2.1
< 0.5
< 0.5
< 0.5
8.5
0.7
< 0.5
10.9
2.5
1.9
March 2006
16.6
10.3
15.2
ND
ND
ND
ND
9
ND
0.6
4.8
1.4
2.6
July 2006
12.6
7.2
9.2
ND
ND
ND
ND
5
ND
< 0.5
6
0.7
1.8
November 2006
4.2
8.2
9
< 0.5
< 0.5
< 0.5
< 0.5
7.3
< 0.5
< 0.5
5.8
2.4
2.6
March 2007 1
5.5
7.9
14.1
1 ND
ND
ND
ND
5.3
ND
0.8
3.7
1.5
2.4
NU - Noaata.

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s
Ilitrate-lliu oT-�en LAM W ells, W P Home LAP.
—LAMI-COMP
—LAM2
LAM3
_LAMC
_LAME
—LAMT
—LAM8
—LAMB
—LAM10
—LAM12
—LAMI3
—LAM16
—LAM16
V
7AI 901 3102 7102 11102 3103 7103 1103 3104 7104 W04 31cs 7105 1106 3106 7106 11106 3107
Oax
I Figure 1. Trend in nitrate -nitrogen, LAM monitoring wells, WP Home Land Application I Nutter & Associates, Inc.
System, Wagram, North Carolina.
Environmental Consultants

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LAM 15',`�
LAM1,�,,.�-
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Figure 2. Locations of LAM monitoring wells, WP Home Land Application System, Nutter & Associates, Inc.
Wagram, North Carolina.
Environmental Consultants