20100857 Ver 1_The Facts wwtp biosolids_20180309

Strickland, Bev
From: Steve Tedder <[e-mail]>
Sent: Friday, March 09, 2018 5:36 PM
To: Merritt, Katie
Cc: Templeton, Mike; Higgins, Karen; Hawhee, Jim; Gannon, Rich
Subject: [External] RE: Butler's Branch
Attachments: Appx-B CAP Final + Revised Attachment2.pdf
External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
ort S am.
Katie,
During out discussions on Wednesday we talked about the Neuse rules and the possibility of nutrient credits and
whether they had to be in the HUC of a discharge or could they possibly be downstream of the HUC. I personally think
being able to develop credits or purchase credits from banks within or downstream of a discharge makes good
sense. Even applying the zones of delivery for credits just as the loading were developed makes sense as well for the
discharge offset credits. In the case below you had approved 122,742 lbs. This bank is in the 100% zone in Craven
County. Seems if these were being applied to n credits in the Raleigh area (50% zone) they would and should actually
equate to 245,484 lbs end of pipe.
AS I did a little more digging on the bank you mentioned below, if actually appears to be a precedent for allowing N
offset credits to be established outside the HUC and farther downstream in the Neuse. This bank was established as
part of the Corrective Action Plan for the Raleigh Biosolids site that had excess nutrients leaching into the
Neuse. Raleigh was allowed to establish the N offset bank further downstream in the basin to utilize the offset credits to
apply to their collective loading reductions from the site near the Neuse WWTP. Check pp 2 (d) in the attachment. This
was approved as part of the variance by the EMC in 2009 and 2014.
Just wanted to pass this along in case you were unaware of the origin of this bank. I had this foggy tidbit stuck way back
in the memory relating to the Variance that came to the EMC in 2014. Did some digging and amazingly there was fact to
the fog. O
Appreciate you pulling the group together for discussions this week. I think that if we could have a couple more of those
discussions we could come up with a logical way to handle the discharge credits offsets and handle other issued like the
200% and 30 years and do so without too many negative vibes like the meeting held on this subject the week
before. Appreciate Karen, Jim and Rich joining the discussions.
Thanks
Tedder
From: Merritt, Katie [mailto:[e-mail]]
Sent: Wednesday, March 07, 2018 4:51 PM
To: Patrick Smith; Steve Tedder
Subject: Butler's Branch
As discussed, here are links to some documents we have in our electronic file on Butler's Branch Mitigation Site.

https://edocs.deg.nc.gov/WaterResources/0/doc/139634/Pagel.aspx
https://edocs.deg.nc.gov/WaterResources/0/doc/139642/PageI.aspx
https://edocs.deg.nc.gov/WaterResources/0/doc/250471/PageI.aspx
Thank You,
Katie
Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
401 & Buffer Permitting Unit
North Carolina Department of Environmental Quality
Work: 919-807-6371
Website: http://Portal.ncdenr.org/web/wq/401bufferpermitting
512 N. Salisbury Street, Raleigh, NC 27620
1617 Mail Service Center. Raleiah. NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Virus -free. www.avq.com

d
North Carolina Department of Envirolvnent and Natural Resources
Division of Nater Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 2, 2010
CERTIFIED MAIL.
RETURN RECEIPT REQUESTED
Mr. J. Russell Allen, City Manager
City of Raleigh
222 West Hargett Street
P.O. Box 590
Raleigh; NC 27602
SUBJECT: Corrective Action Plan (CAP) Final Approval
Neuse River Wastewater Treatment Plant
Inc # 86472; Non -Discharge Permit # W00001730
Wake County
Dear Mr. Russell:
On June 26, 2009, the City of Raleigh applied for a variance to certain State groundwater rules located in Title
15A, North Carolina Administrative Code, Subchapter 2L,.0100 (15A NCAC 2L) for the purpose of
implementing a Corrective Action Plan (CAP) meeting the requirements of 15A NCAC 2L.0106. Corrective
action measures proposed in the variance application included the implementation of a natural attenuation plan
with monitoring, continued implementation of the groundwater recovery system located at Mial Plantation and
Baucom Roads, installation of subsurface flow wetlands and riparian buffer restoration efforts along a segment of
Butler's Branch in Craven County. On January 14, 2010, the Environmental Management Commission (EMC)
signed the "Final Decision Granting Variance" (Variance) in the matter of the "Petition for Variance from Ground
Water Regulations 15A NCAC 2L .0107(k)(3)(a) and 15A NCAC 2L.01060) by the City of Raleigh, North
Carolina." This ruling ordered, in part, that:
Raleigh's request for a variance is GRANTED, pursuant to N.C.G.S. § 143-215.3(e) and 15A
NCAC 2L .0113, as a variance to rules 15A NCAC 2L .0106 and 2L .0107 to allow the
implementation of the corrective action plan utilizing natural attenuation with groundwater
containment with conditions...
Based upon a review of the final Variance decision of the EMC, information submitted in the CAP, and after
considering any public comments and the Raleigh Regional Office recommendations, I am hereby granting final
1617 Mail Sefvice Center, Raleigh, North Carolina 27699-1617
I..ocation• 512 N Salisbury St Raleigh, North Carolina 27604 i�7one 1,,t
Phone! 919-807-6300 \ FAX [phone] \Customer Service: 1-877-623-6748 1'y %{�`tr '.-In' �.Xlcl
Internet: www ncweterqualilv.mg �p7fg'7�g/�4�9iil
.An Fnnal nnnnrhmity \ Affirmative. Action Run9nver (j VV 61FS�dX b&d at�

Neuse River Wastewater Treatment Plant
September 2, 2010
Page 2 of 3
approval to implement the CAP. This approval is contingent upon the conditions specified in the Variance, which
are briefly summarized as follows:
a. Implementation of the Total Nitrogen debit to the facility's nitrogen loading allocation cap (682,483
pounds) under the Neuse NSW management strategy established in the NPDES Permit No.
NC0029033.
b. Continued operation of the active corrective action system, designed to remediate Nitrate — Nitrogen
contaminated groundwater near the intersection of Mial Plantation Rd and Baucom Rd. until such
time as DWQ determines that restoration of groundwater has occurred to the level of the standards
for Nitrate - Nitrogen, referenced at 15A NCAC 2L.0202,
C. Complete installation and operation of the subsurface flow (SSF) constructed wetlands as proposed
in the report titled "Proposed Subsurface Flow Constructed Wetlands, Neuse River Wastewater
Treatment Plant, Raleigh, NC," received January 23, 2009, and as modified or otherwise approved
by the DWQ.
d. Implementation of the agreed upon riparian buffer restoration work associated with Butler's Branch
in Craven County, as approved by the DWQ.
e. Implementation of a groundwater and surface water monitoring plan in accordance with and at the
locations and frequency specified by the DWQ in Attachment 2. Any proposed changes to the
monitoring plan shall be submitted with justification to the DWQ for approval.
f Installation of additional monitor wells as specified in Attachment 2 and replacement of monitoring
points determined to be insufficient because they routinely do not have sufficient groundwater to
enable collection of a sample.
g. DWQ will continue to work with the City of Raleigh to identify private well owners in the area
south of Beddingfield Creek and west of Mial Plantation Road/Shotwell Road for additional
sampling.
h. Every five years, the effectiveness of the overall remediation strategy shall be evaluated to determine
if new or additional treatment technologies exist that could be implemented cost-effectively while
maintaining safety of human health and the environment. The five-year evaluation shall be reported
to the DWQ Raleigh Regional Office APS one year prior to expiration of Non -discharge Permit No.
W0001730. The first report shall be due March 31, 2014. The DWQ will report results of the five
year evaluation to the Commission every five years beginning in 2014.
Specific monitoring and reporting requirements are further detailed in Attachment 2 which may be
modified by DWQ as necessary to implement the variance.
Upon implementing the measures specified in the variance approval, you may be required to perform additional
monitoring, conduct additional site assessment activities, assess the performance of the ongoing corrective action,
and/or evaluate the technological and economical feasibility of implementing a new technology at the subject site.
You are required by 15A NCAC 2L .0114(c) to notify all interested parties, as specified in paragraph (b) of that
rule, that approval of the CAP was granted by the Director. Notification is required by certified mail and must be
made within 30 days of receipt of the Director's decision.

Neuse River Wastewater Treatment Plaut
September 2, 2010
Page 3 of 3
Pursuant to 15A NCAC 2L .0110 and the Variance, you are required to implement a monitoring plan as follows:
1. Groundwater monitoring shall be conducted three times a year during March, July, and November.
2. Surface water monitoring shall be conducted three times a year during March, July, and November.
An annual report must be submitted to the APS RRO on or before the last day of January detailing the
groundwater and surface water monitoring conducted during March, July, and November of the
previous year.
Additional monitoring requirements are specified by DWQ in Attachment 2 of the Variance. As noted in the
Variance, any proposed changes to the monitoring plan shall be submitted to DWQ for approval. On April 29,
2010, AECOM North Carolina, on behalf of the City of Raleigh, proposed changes to the groundwater and
surface water monitoring locations in the Corrective Action Plan Monitoring Network. After reviewing these
changes, DWQ approved some of the changes in a letter dated June 14, 2010. A revised version of Attachment 2
of the Variance that includes these approved modifications is attached to this letter for reference.
Failure to adhere to the requirements of the Variance, CAP, and this approval letter may be considered to be a
violation of the rules, subject to possible enforcement action by the Division.
If you have any questions, please contact Jay Zimmerman of the Raleigh Regional Office at 919-791-4200.
Sincerely,
Coleen H. Supns--
cc: John Robert Carman, Public Utilities Director, City of Raleigh
Tim Woody, Reuse Superintendent, City of Raleigh
Ted Bush, Aquifer Protection Section Chief
Jay Zimmerman, Raleigh Regional Aquifer Protection Supervisor
Steve Levitas, Kilpatrick Stockton, L.L.P.
RRO, APS file

REVISED Attachment 2
This is a revised version of the Variance Attachment 2 based on changes to the Corrective Action
monitoring network approved by DWQ in a letter dated June 14, 2010. Monitoring locations and
text that have been removed from the plan are stricken through (for example """"_.�.I-10-71-).
Additions to this document are underlined (for example "Up to three').
Reporting Requirements
• An annual report will be submitted on or before the last business day of January of each
year, summarizing and interpreting the data collected the previous year (preceding March,
July, and November). The initial report shall be due January 31, 2010.
• Each annual report shall summarize and interpret the data from the sampling events,
discuss the status and provide recommendations regarding monitored natural attenuation,
the pump and treat system, the subsurface flow wetlands, and the offsite riparian buffer
restoration activities.
• The annual monitoring report should be based on the monitoring report template from the
DWQ guidance document Groundwater Section Guidelines for the Investigation and
Remediation of Soil and Groundwater, July 2000.
- The report shall include a table of current groundwater and surface water sampling data
for each sampling event, a table of groundwater elevations for each sampling event, a
map of corresponding groundwater elevations at each event, a map of nitrate as nitrogen
concentrations for each event, and a table compiling historical nitrate as nitrogen
concentrations.
- Each annual report shall also include a summary table of the well construction
specifications of all monitoring wells in the monitoring plan. The table shall include the
following information: installation date, total depth, well diameter, casing and screen
length, and depth of screened interval.
• Three copies of each annual report shall be sent to the DWQ - Aquifer Protection Section,
Raleigh Regional Office.
• Results of subsurface flow wetlands monitoring shall be submitted quarterly for the first year
and each year thereafter as part of the annual report.
Groundwater Monitoring Schedule and Parameters
• Groundwater monitoring shall be conducted three times a year during the months of March,
July, and November.

CORPUD CAP Approval Memo
08/27/2010
Page 2 of 2
Current regulations at 15A NCAC 2L .0100 require a permitted facility to undertake corrective action
using "best available technology," to cleanup and restore contaminated groundwater that results from the
permitted activity when the contaminated groundwater migrates or can be predicted to migrate beyond an
established compliance boundary.
On June 26, 2009, the City of Raleigh applied for a variance to certain State groundwater rules for the
purpose of implementing a natural attenuation CAP. On January 14, 2010, the Environmental
Management Commission (EMC) signed the "Final Decision Granting Variance" (Variance) in the matter
of the "Petition for Variance from Ground Water Regulations 15A NCAC 2L .0107(k)(3)(a) and 15A
NCAC 2L.01060) by the City of Raleigh, North Carolina." This ruling ordered, in part, that:
Raleigh's request for a variance is GRANTED, pursuant to N.C.G.S. § 143-215.3(e) and
15A NCAC 2L.01 13, as a variance to rules 15A NCAC 2L.0106 and 2L.0107 to allow
the implementation of the corrective action plan utilizing natural attenuation with
groundwater containment with conditions...
The variance was necessary in order to allow the City of Raleigh to implement the proposed corrective
action alternatives. Monitoring and reporting requirements for groundwater and surface water specified
by the EMC are described in Attachment 2 of the Variance. The Variance allows for modification of the
monitoring network, provided that any proposed changes to the monitoring plan shall be submitted to
DWQ for approval. Since approval of the Variance by the EMC, the RRO has been negotiating changes
to the monitoring plan with the City of Raleigh. Final approval of the modified monitoring plan needed to
implement the CAP was granted on June 14, 2010. The modifications approved consist of removing
wells from the network that were abandoned or destroyed prior to the variance, correcting names for
wells, changing the location of some shallow wells and replacement of some wells with deeper wells.
History:
• The City of Raleigh began land applying biosolids on the designated fields in or around 1980,
under a permit issued by the DWQ (Permit No. WQ0001730). Groundwater monitoring required
under Permit No. W00001730 revealed concentrations of nitrate that exceed State groundwater
quality standards beyond the permitted compliance boundary.
• A Comprehensive Site Assessment (CSA) for the area affected by the nitrate contamination was
submitted on December 31, 2002.
• In order to address certain deficiencies in the original CSA, a Supplemental Site Assessment
report was prepared and submitted on September 13, 2003.
• A CAP was submitted on February 8, 2005 and a revised CAP was subsequently submitted on
December 1, 2005.
The RRO, on behalf of the Aquifer Protection Section, recommends approval to implement the revised
CAP.
Enclosures
cc: RRO file
APS LAU

REVISED Attachment 2 con't
• For each monitoring event, the water level in each monitoring well in the required monitoring
network will be measured and recorded prior to purging.
During each monitoring event, each of these wells will be sampled and analyzed for the
following parameters: temperature, pH, specific conductivity, dissolved oxygen, and nitrate -
nitrogen.
Corrective Action Groundwater Monitoring Network
• Include the compliance wells in Permit No. WQ0001730 in the corrective action monitoring.
- These wells are MW -13, MW -20, MW -22, MW -41, MW -42A, MW -44, MW -45, MW- 46,
MW -47, MW -48, MW -49, MW -50, MW -51, MW -52, MW -53, and MW -54.
- The permit compliance sampling schedule is the same as the recommended monitoring
schedule (March, July, and November of each year).
• Continue sampling and monitoring the existing groundwater monitoring wells shown in
Figure 1 the Groundwater Corrective Action Variance Application (June 26, 2009).
- All "active monitoring wells" listed on Figure 1: TW -1, TW -2, � 9,T- 11 TW- 14, TW -
16, TW -18, TW 24 TW -25, TW -30, TW-30.1,T`x-� W 31,Tr-"�'. 31 r TW -32 max, zT..-2A, "V-
33, TW -34, Ta" zee TW 36, TW 37 TW -45A, TW 642, MW -100, MW -101, MW -101 D,
MW -102, MW -103, MW -104, MW -105, MW -105D, MW -106, "'�a':.x-.'.-107, MW -108, MW -
109, MW -110, MW -111, MW -111D, MW -112, MW -113D, MW114, MW -115, MW -116,
N'a".�. W, MW -121, MW -122, MW -122D, MW -123D, MW -124D, MW -125D, MW -126D,
MW -127, MW -201, MW -202, MW -203, GP -1, GP -3, GP -5, GP -8, GP -9, GP -10, GP -12,
Gly, GP -21, and GP -22.
- Replace monitoring wells in this network that are chronically dry with deeper wells. Use
existing water level information to plan replacement well depths such that well would not
be expected to be dry under typical seasonal conditions.
- After reviewing the "Remediation and Non-compliance Well Data" received on August 31,
2009, DWQ identified several "active monitoring wells" as chronically dry such that water
quality parameters could not be collected. For this review, "chronically dry" was defined
as the well being listed as "dry" three or more times during the time period from January
2007 through July 2009 on a sampling schedule three times each year (March, July, and
November). These wells are TWA, TW -2, TW -14, TW -16, TW 31A, TW -45A, MW -104,
MW -121, MW434A-MW-124D, GP -1, GP -3, GP -5, GP -8, GP -10, GP -12, and GP -22.
- Specifically, it is recommended that monitoring wells MW -121, MW -104, and GP -3 be
replaced with wells screened in partially weathered rock or bedrock.
• The existing wells at the site are predominantly shallow and screened in saprolite. To
address concerns about the nitrate impacts to deeper groundwater in the partially weathered
Page 2 of 4

REVISED Attachment 2 con't
rock and bedrock aquifers, the installation of additional deep wells is recommended in
several locations.
- Install a deep well screened in partially weathered rock south of Field 60, near or
adjacent to existing well MW -48.
- Install a deep well screened in bedrock near or adjacent to existing well MW -112.
- Install a pair of deep wells screened 1) in partially weathered rock and 2) in bedrock
along the western edge of Field 74 at a point approximately halfway between existing
wells MW -122 and MW -49.
• Severn! Un to three private residential wells in the housing development located south-
southeast of Field 201 will be sampled and analyzed with other monitoring samples, for uu
to three monitoring events. The City of Raleigh will work with the regional office staff to
identify private well owners in the area south of Beddingfield Creek and west of Mial
Plantation Road/Shotwell Road. These monitoring data will be included as part of the
annual monitoring report.
• After reviewing the well construction for the wells in the network (as described in Reporting
Requirements), DWQ will work with the City to eliminate potentially redundant sampling
locations. NOTE: This is specifically in reference to the large number of TW wells such as in
Field 602.
Groundwater Monitoring Well Construction Requirements
• All monitoring wells installed should be screened with 10 feet to 20 feet of screen across
water -bearing fractures or units at discrete intervals. From this time forward, deep wells will
not be installed with open boreholes.
• Where wells are installed in pairs (such as deep and shallow), the wells in the cluster should
be screened at discrete intervals to avoid overlapping zones.
• Existing water level information should be used to plan well depths to avoid chronically dry
wells.
• In accordance with 15A NCAC 2C .0102, all temporary wells must be converted to
permanent monitoring wells within seven days of completion or they shall be abandoned.
Surface Water Monitoring Schedule, Locations, and Parameters
• Surface water monitoring will be conducted three times a year during the months of March,
July, and November.
• Surface water monitoring will be conducted as the surface water locations shown and
identified in Figure 1 of the Groundwater Corrective Action Variance Application (June 26,
Page 3 of 4

REVISED Attachment 2 con't
2009). These locations include: SW -1, SW -2, SW -3, SW -4, SW -5, SW 6, SW -7, SW -8, SW -
9, SW 10, SW 11, SW 12, SW 13, SW 1e SW -15, SW -16, SW- 17, SW -1S, SW -19, SW -
20, SW -21, SW -22, SW -23, SW -24, SW -25, SW -26, SW -27, SW -AU, SW -AD, SW -BU, SW -
BD, SW -CU, SW -CD, SW -DU, SW -DD, SW -EU, and SW -ED.
• During each monitoring event, each of the surface water monitoring locations will be
sampled and analyzed for the following parameters: temperature, pH, specific conductivity,
dissolved oxygen and nitrate -nitrogen.
Subsurface Flow Wetland Monitoring
The subsurface flow wetlands will be monitored as specified in the monitoring plan presented in
Section 3.1 of the Proposed Subsurface Flow Constructed Wetlands, Neuse River Wastewater
Treatment Plant, Raleigh, NC (December 2008), or as otherwise approved by the DWQ Raleigh
Regional Office. These monitoring data will be included as part of the annual monitoring
re ort.
Page 4 of 4