WQ0001048_NORR-2011-0098 Response_20190424

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CMSD
POST OFFICE BOX 477
GRIFTON, NORTH CAROLINA 28530
CHARLES M. SMITHWICK, JR.
DISTRICT MANAGER
June 28, 2011
Mr. Allen Clark
North Carolina Division of Water Quality
943 Washington Square Mall
Washington, NC 27889
Re: Notice of Regulatory Requirements
NORR No. NORR-2011-0098
Contentnea Metropolitan Sewerage District
Permit No. WQ0001048
Dear Mr. Clark:
JUN 2 8 2011
The CMSD is in receipt ofNCWDQ's letter dated March 28, 2011 which addresses the above
mentioned Notice of Regulatory Requirements. I would like to point out some facts concerning
the detection of chromium in our test wells.
1) All test wells were replaced in June 2001. The first "hit"(100 ug/I in Well #14) was in
June 2001. This was explained by an employee accidentally dropping a bailer in the well
during a sampling event and retrieving it with a piece of wire. The well was re -tested in
August 2001 and reported a result of <5ug/l. A written explanation was sent to WARD
explaining this incident.
2) The area surrounding Well #14 was used by FEMA after Hurricane Floyd (1999)
as a temporary trailer park to house individuals who lost their homes during the
flood. After the trailers were removed, this area was restored to its original
condition; however, the rocks and soil used for making the roads was
stockpiled on site.
3) There is an old industrial warehouse to the west of our test well. The CMSD has
no records or history of the past/present operations from this facility.
4) It should be noted that the chromium levels from our monitoring results from 2001 to
2005 only exceeded 9ug/l on two (2) occasions and these were reported to NCDWQ.
In your letter, a graph and chart was provided showing results from Wells 99, #10, #14, #15, 417
and #18. Well 917 was installed due to the reclassification of our Land Application Spray Fields
# 10, # 11 and # 12. These fields were removed from our Land Application Permit in 2004 and
have not received any biosolids since that time. These fields have been reclassified for Spray
Irrigation use only and have been used for that purpose only. It should be noted that the results
from Well # 17 have varied from 18 ug/l to 47 ug/l during the entire life/history of this well. This
well is located on the CMSD property boundary and is under a pine tree.

Well #18 was installed as a replacement for Well #13 when it was determined by Mr. Robert
Tankard that Well 913 was not installed properly. The first four (4) test results for #18 vary from
21 ug/I to 72 ug/l. It is our opinion that this well may be experiencing high readings due to
possible "contamination" during the installation process.
The CMSD understands that the chromium levels are elevated, but we can offer no explanation
why the "background" or "up gradient" wells (914 and #17) are elevated. The elevated results
are coming from wells that are normally thought of as "control" wells as they are located on the
property boundary and are thought to monitor the water that is coming from upstream. It is our
opinion that if these wells are experiencing elevated levels, the source could be upstream and
actually not caused by our land application practices. In addition, our sludge monitoring reports
do not indicate any elevated chromium levels in the sludge that is being land applied.
It is also understood that the prior 2L Standard for chromium was 50 ug/1 and was lowered to 10
ug/l in 2010. The CMSD recognizes the fact that groundwater can be contaminated with the
Land Application of biosolids. With that in mind, the CMSD is proceeding with dewatering
alternatives in our Phase 2 Wastewater Treatment Plant Improvements Project. We intend on
dewatering our sludge and removing if from site and final disposal will be by either landfilling or
composting. It is our intention to stop the land application of biosolids on CMSD property. This
project has been funded by the USDA-RD and a Preliminary Engineering Report (PER) and
Environmental Report (ER) have been prepared and submitted to USDA-RD for approval.
Approval of the PER was issued on March 30, 2010 and the approval of the ER was issued on
January 29, 2010. Our current schedule for this $14.95 million project is as follows:
Task
Date
I. Initiate Phase 2 Design
November 2010
2. Submit Plans and Specifications to CG&L
and USDA-RD for Review/ Approval
April 2011
3. Receive Authorization to Construct
July 2011
4. Advertise Project
August 2011
5. Receive Bids
September 2011
6. Award Contract, Issue Contract Documents
Hold Pre -Construction Conference and Start
Construction
7. Complete Construction
8. Project Close -Out
February 2012
May 2013
June 2013
If you have any questions or comments about the information that has been provided, please
advise.
Sincerely,
Charles M. Smithwick, Jr.
District Manager, CMSD
JUN 2 8 201