20170359 Ver 2_NOV Response_20200819

H z n Hazen and Sawyer
a e 4011 WestChase Boulevard Suite 500
Raleigh, NC 27607 • 919.833.7152
August 21, 2020
Mr. Andrew Moore
North Carolina Department of Environmental Quality
Division of Water Resources
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Response to NOV-2020-SS-0015
DWR Project No. 20170359 v2
Dear Mr. Moore:
On August 5, 2020, the Division of Water Resources (DWR) issued a Notice of Violation (NOV) and
recommendation for enforcement to Grandfather Golf and Country Club (GGCC) for violations of the
stream standard for turbidity and the 401 water quality certification (WQC) conditions of the Loch Dornie
dredging project. The NOV was issued based on observations during a July 30, 2020 site inspection by
Andrew Moore, representing the Asheville Regional Office of DWR. GGCC hereby responds to the
NOV and recommendation for enforcement.
Explanation of the Turbidity Violation.
GGCC believes the turbidity measured downstream of the Loch Dornie spillway on the 30th was the
result of increased turbidity in the lake due to recent, large, and unanticipated rainfall events in the
Linville River watershed. On July 22, 2020 GGCC accepted the Loch Dornie dredge work as
substantially complete. Thereafter, the upper watershed bypass system was removed on July 23. At the
time of removal, the lake was still drawn down approximately 8 feet below normal pool elevation, and all
activities were complete below the normal pool elevation of the lake. The intent was to let the lake
continue to serve as its own settling basin. It was expected to take two weeks or more for normal base
flow and occasional thunderstorms to fill the lake.
A significant rain event occurred on the afternoon of July 23 that dropped 2.5 inches of rain, which
immediately flooded the lake. We do not have a reading of the turbidity of contributing runoff into the
lake at that time. However, qualitatively, GGCC staff noted that the stormwater entering the lake from
offsite and upstream of Station A was muddy.
Additional storms followed, and 5.3 inches of rain were recorded from July 23 through July 26, including
an additional 2.5 inches of rain in approximately one hour on July 26. After the intense storm event of
July 26, the spillway was overflowing. GGCC partially opened the release valve on July 28. It was
evident that the turbidity of flows from the valve were not improving downstream water quality and were
more turbid than flows over the spillway. The valve was closed fully four hours later. Turbidity at
Station B was 62 NTU on the morning of July 29. Another significant rain event occurred the afternoon
hazenandsawyer.com

Hazen
Mr. Moore, DWR
August 21, 2020
of July 29 (1.5 inches). Photos were taken of obviously turbid flows upstream of Station A (see attached
photos). The next day, Andrew Moore conducted his site inspection and collected water samples. By the
time of the site inspection, turbidity at Station A had dropped back down to 2.4 NTU's, but Station B
below the dam had increased from 62 to 75 NTU's.
GGCC representatives have historically observed muddy water in the upstream segments of the Linville
River entering Loch Dornie via culverts conveying flows from offsite lands. Subsequent to Mr. Moore's
site visit, GGCC has documented turbidity flows into Loch Dornie, and the August 12 measurements after
2.25-inch rainfall are indicative of the rainfall events leading up to July 30 (see attached chart). As can be
seen, there were turbidity readings in excess of 200 NTUs in Linville River upstream of the Station A.
The same storm event resulted in stormwater flows from the west side of Highway 105 that exceeded 300
NTUs prior to entering Loch Dornie. As the chart demonstrates, upstream waters appear to clear their
sediment load and return to baseline turbidity levels within a matter of hours after the end of a rain event.
Therefore, upstream turbidity measurements or observations that occur more than a few hours after the
end of a rainfall do not reflect the turbidity during and immediately after storm conditions. The
suspended sediment load from the portion of the watershed that is offsite and upstream of Loch Dornie
collects in the lake, which acts a sink to protect downstream water quality. When the water surface
elevation of Loch Dornie reaches or exceeds the spillway elevation, the turbid water flows freely over the
spillway and on downstream in Linville River without the time necessary for settling having elapsed.
While a portion of the sediment load probably does originate from the work just completed in Loch
Dornie, it is also clear that a significant amount, if not the substantial majority, of sediment is transported
to the lake via stormwater flows that originate offsite.
2. GGCC Corrective Actions.
GGCC initiated corrective actions after discussions with Mr. Moore on July 30. Corrective actions
include expediting preparation of the disturbed areas for seeding and sod installation, installation of silt
fencing on the bare soil islands, and ordering a new turbidity curtain. By August 3, bare soils along the
lake shore and islands were stabilized either by sodding or installing silt fence until sod or other
stabilization could be established. A turbidity curtain was ordered by GGCC for placement above the
spillway channel. Also, by August 3, turbidity at Station B had been reduced to 50 NTU (33 percent
reduction). Over the course of the week, the Station B turbidity was reduced by half to 25 NTU on
August 10. The turbidity curtain was delivered and installed on August 13, and the turbidity readings
continue to decline, with a reading of 8.93 NTU's at station B on August 19.
Moderate fluctuations and continued overall reductions in turbidity measurements at Station B suggest
that the high turbidity peaks from repeated storm events are being absorbed by and settling in the lake.
The lake is again protecting water quality in Linville River downstream of the lake.
In addition, GGCC has measured significant turbid water contributions that are coming into the Linville
River below the dam/Station B during storm events. This should be considered with respect to
downstream (Linville) observations, complaints, and measurements. As an example, on August 8, Station
B was recorded as 43.2 NTU while 128 NTU was recorded further downstream following a 2-inch rain
event on August 7. Therefore, a significant portion of the flow and the turbidity in the Linville River at
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Hazen
Mr. Moore, DWR
August 21, 2020
this location originates offsite below Station B and are conveyed via culverts under Highway 105 directly
into the river.
3. Turbidity Measurements.
Daily turbidity readings at station B have been reported to DWR since July 30. A summary of the
readings from July 30 through August 19 is attached for reference. Daily readings will continue to be
collected and reported until five days in a row are in compliance, as stated in the NOV letter.
In summary, the events leading up to July 30, 2020 turbidity release over the Lake Dorme spillway were
1) unexpected and 2) substantially the result of sediment entering the Linville River upstream of Lake
Dornie and not within the control of GGCC. However, GGCC has acted quickly in implementing
measures trying to minimize future turbidity exceedences. If you have any questions, please reach out to
Alan Shuping at [phone], ext. 127 or by email at [e-mail].
Very truly yours,
Keven Arrance
Senior Principal Scientist
cc: Amanda Jones — US Army Corps of Engineers
Andrea Leslie — North Carolina Wildlife Resources Commission
Stan Aiken — Division of Energy, Mineral and Land Resources
Avery County Planning
Alan Shuping — Grandfather Golf and Country Club
Page 3 of 3
hazenandsawyer.com

Daily Turbidity Log (2020)
Grandfather Golf and Country Club
Date
I Station B
I Leaving Property
31-Jul
68.8
46.1
1-Aug
65
2-Aug
55
38
3-Aug
50
35
4-Aug
46
34
5-Aug
39
27
6-Aug
36
24
7-Aug
33
23
8-Aug
31
22
9-Aug
29
17
10-Aug
25
15
11-Aug
22
14
12-Aug
18.9
12.7
13-Aug
20.9
11.7
14-Aug
20.9
10.5
15-Aug
19.2
9.3
16-Aug
17-Aug
13.3
9.75
18-Aug
11.4
7.23
19-Aug
8.93
5.4
* - No reading taken.

Rainfall -Related Turbidity Readings
Grandfather Golf and Country Club
Date
8/12/2020
Rainfall Total
2.25 in
Immediately After Rain
Before Rain
Downstream Property Boundary
-
12.7
Station B
28.4
18.9
Station A
248
4.5
Upstream Property Boundary
229
-
Hwy 105 Culvert Outlet
327
-

GG&CC - 7/29 Rain Event
Aju I
00 ft".,
a9
F'
Linville River crossing fwy 17 above lake
Grassy Creek above lake

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•rr l k• L:
trr , i !�"ti ;'3'�.4`t •ram ,� ` �' "� '�_ �,�r"!.

GG&CC - 7/29 Rain Event
Turbid flows above lake