WQ0001048_Compliance Report_20190717

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CMSD
POST OFFICE BOX 477
GRIFTON, NORTH CAROLINA 28530
CHARLES M. SMITHWICK, JR.
DISTRICT MANAGER
July 17, 2019
Mr. Randy Sipe, P.G., Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
943 Washington Square Mall
Washington, NC 27889
Re: Groundwater Standard Exceedances
Permit No: WQ0001048
Dear Mr. Sipe:
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As per our telephone conversations and a response to the certified letter received by this office dated
April 24, 2019, 1 am providing the following report concerning the Groundwater Standard Exceedance on
CMSD's Biosolids Land Application Sites.
This report was completed by Groundwater Management Associates, Inc. (GMA, Greenville, NC) and
presents the results of GMS's evaluations.
Please advise if you have questions or comments.
Sinc 1 ,
Charles M. Smithwick, Jr. Ir
District Manager, CMSD
Enclosure

GMA
OROUNDWATEI MANAGEMENT ASSOCIATES. INC.
July 12, 2019
Mr. Chuck Smithwick
District Manager
Contentnea Metropolitan Sewerage District
PO Box 477
Grifton, NC 28530
4300 Sapphire Court, Suite 100
Greenville, North Carolina 27834
Telephone [phone]
www.amo-nc.com
Re: Report of Groundwater Evaluation, Contentnea Metropolitan Sewerage District Residuals Land
Application Sites, Grifton, North Carolina
Dear Chuck,
Groundwater Management Associates, Inc. (GMA) is pleased to provide this summary report of a
groundwater evaluation conducted at the Contentnea Metropolitan Sewerage District (CMSD) residuals
land application sites. On March 28, 2011, the North Carolina Department of Environmental Quality
(NCDEQ) issued a Notice of Regulatory Requirements (NORR) to CMSD. The NORR cited groundwater
quality standard exceedances in monitoring wells associated with the residual solids land application
areas under Permit No. WQ0001048. Of particular concern to the NCDEQ were reported values of
chromium in some monitoring well samples. CMSD responded with a letter in June of 2011 that
described a variety of conditions that were believed to have affected the water -quality results, and
CMSD asserted that the elevated chromium was not related to the land application of biosolids.
On April 24, 2019, the NCDEQ issued a letter to CMSD citing the continued exceedance of groundwater
quality standards in the monitoring wells based upon the 2018 Annual Report dated March 11, 2019.
The NCDEQ requested that CMSD fulfill the requirements of the original NORR of March 28, 2011.
CMSD contracted GMA to evaluate the hydrogeologic setting of the site and to evaluate the possibility
that detected concentrations of chromium may be naturally occurring. This letter report presents the
results of GMA's evaluations.
Background Information and Hydrogeoloeic Setting
The CMSD wastewater treatment plant (WWTP) is at 900 Wiley Gaskins Road, east of the Town of
Grifton, North Carolina. The WWTP provides treatment of sewage from the Towns of Grifton, Ayden,
and Winterville. The treatment process generates residual solids that are land applied to five areas

Mr. Smithwick
Page 2
(Figure 1). CMSD monitors six monitoring wells (MW9, MW10, MW14, MW15, MW17 and MW18) in
accordance with the land application permit (Figures 1 and 2).
The CMSD land application sites lie in the North Carolina Coastal Plain, a broad, generally flat region that
is underlain by marine, estuarine, and fluvial sediments deposited along the North American continental
margin. These sediments range in age from Late Cretaceous to Recent. The mapped Coastal Plain
sediments exposed near Grifton are from the Late Cretaceous age Peedee Formation (NCGS, 1985). The
Peedee Formation is a fossiliferous dark green to black marine clay unit interbedded with calcareous
sandstone and olive gray sands. Locally, the fossiliferous sandy limestone of the Rocky Point Member
may occur near the top of the Peedee Formation. Outcrops of Peedee Formation, including some sandy
limestone typical of the Rocky Point Member, occur along Contentnea Creek south and west of the
CMSD facility.
The land surface at the CMSD land application sites exhibits a fluvial terrace topography. Quaternary
sands, deposited by the ancestral Neuse River and/or Contentnea Creek, underlie the fluvial terrace
region. Lidar data of the site vicinity (Figure 3) clearly illustrate the fluvial terrace topography
encompassing the CMSD facilities. Braid bars, remnant stream channels, and flood plain areas occur
within the terraces. Within the upper (northern) reaches of the fluvial terraces, Carolina Bay pocosins
are also evident. The fluvial terrace deposits lie unconformably above the Peedee Formation, and they
comprise the Surficial Aquifer sediments. In this setting, Surficial Aquifer groundwater generally flows
from upland recharge areas (in the north) to the regional discharge area (Contentnea Creek) south of
the CMSD facilities.
Field Monitoring Event —June 11, 2019
A GMA geologist visited the site on June 11, 2019 to observe, document, and participate in sampling of
six monitoring wells near the residuals land application sites. Figure 1 shows the locations of residuals
land application sites and monitoring wells. CMSD contracted with a registered land surveyor (Spruill
and Associates) to establish the locations and top of casing elevations for the three newest wells
(MW15, MW17, and MW18), as casing elevations for these wells were not previously established. Table
1 presents details of well construction, well locations, casing elevations, and water -level measurements
collected on 6/11/19.
CMSD personnel conducted the monitoring well sampling using standard methods with a disposable
bailer. CMSD person nel.purged 5 gallons from each well before sample collection. GMA measured
turbidity of the last bail of purge water using a calibrated Hach 2100Q Portable Turbidimeter. Table 2
presents the turbidity measurement from each monitoring well at the end of purging. CMSD filled
laboratory containers from the bailer following completion of purging of each well. It should be noted
that CMSD implemented a redevelopment program for their monitoring well network after receiving the
April 24, 2019 letter from NCDEQ. The redevelopment program entailed repeated bailing of the wells to
remove sediment and to reduce turbidity. The redevelopment program preceded the June 11, 2019

Mr. Smithwick
Page 3
sampling event. CMSD staff reported that turbidity was notably reduced by the redevelopment
program.
CMSD selected two monitoring wells (MW10 and MW14) for additional sampling evaluations by GMA.
These two wells have a history of elevated chromium concentrations. GMA used a peristaltic pump to
purge wells MW10 and MW14 using a low -flow rate. We monitored pH, conductivity, dissolved oxygen
(DO), oxidation-reduction potential (ORP), and temperature using a YSI Professional Plus multi -
parameter meter and a flow -through cell. Field turbidity was monitored from the effluent of the pump
using the Hach 2100Q Turbidimeter. Low -flow purging was continued until turbidity was <10 NTU and
other field parameters stabilized. The YSI meter was calibrated on 6/10/19, and the calibration record is
included as an attachment.
GMA expected that low -flow sampling could achieve a lower turbidity prior to sample collection than
the bailing method that CMSD normally uses. Low turbidity is important for metals analyses because
naturally occurring metals in the sediments can leach from sediment particles into the laboratory
bottles. Laboratory protocol for metals analyses requires the use of a nitric acid preservative in the
sample containers. In high -turbidity samples, the nitric acid can leach metals into solution from
sediment particles, thereby resulting in elevated concentrations in the laboratory analyses. Reducing
turbidity to less than 10 NTU was a goal for the low -flow sampling methods, as 10 NTU is a common
threshold for metals sampling. For example, Gibbons & Sara (1993) found no statistical difference
between filtered and unfiltered samples for metals when turbidity is <10 NTU.
Table 2 presents the turbidity results for wells MW10 and MW14 from the flow -flow sampling method.
The low -flow sampling method achieved a significant reduction in turbidity. Table 3 presents the
stabilized field water -quality parameters for low -flow sampling of MW10 and MW14. Once stabilization
criteria were met, CMSD collected water samples for chromium and copper analyses.
Water Table Mapping and Groundwater Flow Direction
Knowing the top of well casing elevations, GMA calculated the water table elevation at each monitoring
well using water depth measurements from 6/11/19. Table 1 presents the water table elevations.
Figure 2 presents a contour map of the water table elevation based upon the monitoring well data
collected on 6/11/19. The water table surface across the land application sites ranges in -elevation from
26.8 feet above mean sea level (MSL) to 17.47 feet MSL, and it slopes from the north toward the south
at an average hydraulic gradient of 0.0026 ft/ft. Wells MW14 and MW17 are upgradient of all land
application sites. Wells MW9, MW10, and MW15 are in downgradient locations within the wellfield.
Groundwater flow from the land application areas is directed toward Contentnea Creek, which is the
local groundwater discharge boundary for the site.

Mr. Smithwick
Page 4
Water Quality Laboratory Results
CMSD arranged all laboratory analyses for sample collected on June 11, 2019. Samples collected by
bailer were analyzed by Environmentl for fecal coliform bacteria, ammonia nitrogen, nitrate nitrogen,
total organic carbon, total dissolved residue, total chromium, copper, conductivity, and phosphate.
Samples collected by low -flow purging from wells MW10 and MW14 were analyzed for total chromium
and copper. A copy of the laboratory results are attached. Table 4 presents a comparison of chromium,
copper and turbidity analyses from well MW10 and MW14 based upon sampling method. As is
demonstrated by the data, turbidity in samples collected after low -flow purging was lower than the
bailed samples. The chromium and copper concentrations of samples collected from MW10 and MW14
by the low -flow method were less than the detection limits for these analytes. Chromium was reported
at a concentration of 7 µg/L in the bailed sample from MW14, but copper was less than the detection
limit in that same sample. Both chromium and copper were below the detection limits in the bailed
sample from MW10.
Chromium was also detected in samples collected by CMSD from MW15 and MW17, both at a
concentration of 5 µg/L. It is notable that well MW15 also had the highest turbidity after bailing of any
of the monitoring wells sampled. None of the chromium detections exceeded the 15A NCAC 02L
groundwater quality standard (10 µg/L) in any of the wells sampled on June 11, 2019. It is reiterated
here that CMSD implemented a redevelopment program for their monitoring well network after
receiving the April 24, 2019 letter from NCDEQ. The redevelopment program entailed repeated bailing
of the wells to remove sediment and to reduce turbidity. Although some wells still produce elevated
turbidity following purging, the lack of exceedance of the chromium groundwater quality standard in
any well during the June 11, 2019 sampling event suggests that the redevelopment program has been
effective at reducing elevated metals resulting from excessive turbidity.
Conclusions and Recommendations
GMA offers the following conclusions from this evaluation:
• Groundwater in the surficial aquifer at the CMSD site flows from the north toward the south
under and average hydraulic gradient of 0.0026 ft/ft.
• Wells MW14 and MW17 are hydraulically upgradient of all of CMSD's residuals land application
sites.
• The water -quality associated with samples from upgradient wells MW14 and MW17 represent
groundwater conditions from off -site upgradient areas (and/or from sediment in the aquifer at
those wells) and would not be related to residuals land application activities downgradient of
those wells.
• Low -flow sampling performed at wells MW10 (downgradient) and MW14 (upgradient)
demonstrates that the bailing method results in higher turbidity than the low -flow sampling
method. This study also provides evidence that higher turbidity samples are associated with
higher reported concentrations of chromium in the samples.

Mr. Smithwick
Page 5
• Redevelopment of the monitoring wells by CMSD appears to have reduced turbidity in the wells
to the point that chromium concentrations did not exceed the groundwater standards in the
most recent sampling event.
• GMA concludes that historical reports of chromium concentrations exceeding the groundwater
standards in the monitoring wells at the facility were most likely associated with excessive
turbidity. As such, these chromium detections would be naturally occurring in the aquifer
materials. The June 11, 2019 sampling results do not indicate the presence of groundwater
contamination by metals (such as chromium) associated with residuals land application areas.
Report Certification
This groundwater evaluation report was prepared by Groundwater Management Associates, Inc., a
professional corporation licensed to practice geology (#C-121) and engineering (#C-0854) in North
Carolina. I, James K. Holley, am a NC licensed geologist employed by GMA, and I do certify that the
information contained in this report is correct and accurate to the best of my knowledge.
Groundwater Management A t?, teA".Z •.,�
p1 s
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James K. Holley, P.G. C S~
Senior Hydrogeologist �•.,�9�� iOG�o��,��.•
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References:
Gibbons, R.D. and M.N. Sara, 1993, "Statistical Comparison of Metals Concentrations in Filtered and
Unfiltered Ground -Water Samples, in Ground Water Sampling", A Workshop Summary: Dallas,
Texas. November 30 - December 2, 1993. U.S. EPA Office of Research and Development,
EPA/600/R-94/205, pp. 54-58.
North Carolina Geological Survey, 1985, "Geologic Map of North Carolina", 1 sheet.

Table 1. CMSD Monitoring Well Data 162601
Well
Name
Total
Depth
(Feet)
North (M)
East (M)
North (F)
East (F)
Latitude
Longitude
TOC
Elev.
DTW
(6/11/19)
WT Elev.
(6/11/19)
MW9
8
179,461.84
753,424.06
588,785.59
2,471,863.78
35.3574601°
-077.4173231°
20.67
3.2
17.47
MW10
8
179,724.98
753,156.93
589,648.91
2,470,987.38
35.3598702°
-077.4202161°
21.09
2.1
18.99
MW14.
13
180,785.39
753,467.55
593,127.93
2,472,006.49
35.3693833°
-077.4166123°
34.9
8.25
26.65
MW15
6.75
179,705.42
754,148.87
589,584.74
2,474,241.79
35.3595511°
-077.4093055°
21.9
2.31
19.59
MW17
8
180,585.42
753,696.80
592,471.86
2,472,758.61
35.3675479°
-077.4141248°
31.1
4.3
26.8
MW18
10
180,319.31
753,344.33
591,598.79
2,471,602.21
35.3652001°
-077.4180500°
30.41
5.34
25.07
Coordinates and Elevations Surveyed by Spruill and Associates, Inc. - Greenville, NC
(M) - Meters
(F) - Feet
TOC - Top of Casing of the Well
North and East = NC State Plane Coordinates
Elev. - Elevation in Feet
DTW - Depth to Water Measured in Feet Relative to the Top of the Well Casing

Table 2. Field Turbidity Data during Sampling - 6/11/19
Well Number
Static Water Level*
Turbidity (Bailing)**
Turbidity (Pumping)
MW9
3.20 feet
5.96 NTU
NA
MW10
2.10 feet
25.0 NTU
7.68 NTU
MW14
8.25 feet
64.7 NTU
2.21 NTU
MW15
2.31 feet
91.6 NTU
NA
MW17
4.30 feet
4.27 NTU
NA
MW18
5.34 feet
55.5 NTU
NA
* All water level depths were measured from the top of the well casing.
** Turbidity samples were taken from the last bailer after purging 5 gallons from the well.
NA - Not Applicable
Table 3. Field Water -Quality Parameters from Low -Flow Sampling
Parameter
MW10
MW14
Dissolved Oxygen (mg/L)
2.86
5.47
pH (standard units)
5.31
5.57
Oxidation -Reduction Potential (mv)
96.4
87.7
Conductivity (PS/cm)
50.5
33.7
Temperature (°C)
21.2
18.1
Water -quality results are for stabilized readings from a YSI meter using a flow -through cell.
Table 4. Comparison of Chromium and Copper Concentrations by Sample Methods.
Parameter
MW10
MW14
Bailing
Low -Flow
Bailing
Low -Flow
Chromium (µg/L)
<5
<5
7
<5
Copper(µg/L)
<10
<10
<10
<10
Turbidity (NTU)
25.0
7.68
64.7
2.21
NTU - Nephelometric Turbidity Units

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Attachments:
YSI Meter Calibration Record
Laboratory Reports from Environmentl

YSI CALIBRATION. LOG
C MA
Date/Time: &A // � Technician:
Instrument Serial Nurif 13y9,7-i Software Revision:fi. Cable Model Num:
Temperature Reading ;Z 0 C Temperature Accurate: N
DO Sensor in use: olaro rap i 'Galvanic Sensor notated. in Sensor menu? Y R
DO membrane changed? Y(P
Color of Membrane Color notated in Sensor menu?Y N .
Record the following calibration values:
pH
Buffer open
Post cal value.
Ad
Pre Cal value.
pH mV value
Acce table mV Range
date
of last std
pH:' 7
.-.
Range 0 mV ± 50 mV
s"`
-7, --
H 4
Range +165 to +180 from 7
buffer mV value
'r�.!
Ll , o t
pH 10
t
Range -165 to -180from 7
buffer mV value
La . 0 t
NOTE: See pH Cal tips section for additional information. Span between pH 4. and 7 and 7 and 10 mV values
should be z 165 to 180 mV. 177 is the ideal distance or 59 mV per pH unit.
Pre Cal After Cal
Conductivity /3 6' zjg/ - 1 "/0
ORP M. v
DO True Barometric Pressure �s�•S
Record the following diagnostic, numbers after calibration, by viewing the .glp file and reading the
values for the day's calibration:
Conductivity Cal Cell Constant _(9, Range 5.0 +/ 1.0 acceptable.
DO Sensor Value (uA) � 3 (Membrane dependent, see DO Cal Tips)
pH Slope (z 55 to 60 mV/pH, 59 ideal)
pH Slope % of ideal 00
Hach Turbidi'meter:
20' NTU value: N A
800 NTU value:
Comments:
100 NTU value:
10 NTU Verification Std value:

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CMBD (SLUDGE & WELLS ACCT)
CONTENTNSA METRO. SEWAGE DIET.
MS. RENEE PRIDGEN
P.O. BOX 477
GRIFTON ,NC 28530
ID#: 416
DATE COLLECTEDt 06/11/19
DATE REPORTED t 07/08/19
REVIEWED BY:
Well #9
Well #10
Well #14
Well #15
Well #17
Analysis
Method
PARANIMRS
Date Analyst
Code
Fecal Collrorm (Ml?), /100 Mis
<1
1
4
10
<1
06/11/19
MAR
9222D-06
Ahmnonia Nitrogen as N, mg11
0.99
<0.04
<0.04
0.38
<0.04
06/13/19
DTL
350.1 112-93
Nitrate Nitrogen as N, :ng/l
0.15
0.55
0.29
0.19
0.48
06/12/19
AICS
353.2 112-93
Total Organic Carbon, mg/1
7.82
3.89
2.42
9.22
1.73
06/13/19
SEl
531OC-11
Total Dissolved Residue, mg1l
46
- 30
35
126
47
06/13/19
I(DS
2540C-11
Total Chromium, ug/l
<5.0
<5.0
7
5
5
06/13/19
LFJ
EPA200.7
Copper, ::g/1
<10
<10
<W
<10
<10
06/13/19
LFJ
EPA200.7
Conductivity (at 25c), uMhos/cm
65.0
55.0
35.9
137
38.9
06/17/19
JMS
2510B-11
Total Ortho-Phosphate as P, mg/1
0.07
0.06
0.06
0.04
0.16
06/12/19
KDS
450OPE-11
0

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FORM YS PLEASE -READ. Instructions for.completing this.form. on ilia reve[se Side. Grab maple in the blocks above for each parameter requested.N _. 0
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CMSD (SLUDGE & WELLS ACCT)
CONTENTNEA METRO. SEWAGE DIET,
NO. RENEE PRIDGEN
P.O. BOX 477
GRIFTON ,NC 28530
Well #18
Analysis
Method
PARAMEMERS
Date
Analyst
Code
Fecal Collform (MF), /100 Mls
> 600
06/11/19
MAR
9222D-06
Ammonia Nitrogen as N, mg/l
<0.04
06/13/19
DTL
350.1 R2-93
Nitrate Nitrogen as N, mg/1
0.05
06/12/19
AKS
353.2 R2-93
Total Organic Carbon, mg/1
7.92
06/13/19
SEJ
531OC-11
Total Dissolved Residue, mg/1
108.
06/13/19
I(DS
2540C-11
Total Chromium, ugh
<S.0
06/13/19
LFJ
EPA200.7
Copper, ug/i
<10
06/13/19
LFJ
EPA200.7
Conductivity (at 25c), uMhos/cm
151
06/17/19
JMS
2S10D-11
Total Ortho-Phosphate as P, mg/1
0.02
06/12/19
KDS
450OPE-11
ID# t 416
DATE COLLECTEDi 06/11/19
DATE REPORTED t 07/08/19
REVIEWED BYt

Environment 1, inc.
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CMSD (SLUDGE & WELLS ACCT)
CONTENTNEA METRO. SEWAGE DIST.
MS. RENEE PRIDGEN
P.O. BOX 477
GRtFTON ,NC 28530
PARAMETERS
Total Chromium, ugll
Copper, ugA
Well #10 Well #14
ID#: 416 Y
DATE COLLECTED: 06/11/19
DATE REPORTED : 07/08/19
REVIEWED BYt
Analysts Method
Date Analyst Code
<5.0 <U 06/13/19 LFJ EPA200.7
<10 <10 06/13/19 LFJ EPA200.7
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