WQ0037555_Additional Information Request_20210222

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
FREDDIE BOAN — MANAGER
TRILLIUM LINKS & VILLAGE, LLC
ONE TRILLIUM CENTER
CASHIERS, NORTH CAROLINA 28717
Dear Mr. Boan:
NORTH CAROLINA
Environmental Quality
February 22, 2021
Subject: Application No. WQ0037555
Additional Information Request
Trillium Links & Village WWTP
High -Rate Infiltration
Jackson County
Division of Water Resources' Central and Regional staff has reviewed the application package
received December 12, 2020. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on March 24,
2021.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through Q, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with an
electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3660 or Lauren.Plummer(ancdenr.gov. Thank you for your cooperation.
[Sinc
DocuSig E?d by:
�Q.IA/�RJn. �((.1A,P— I Qa1vWLVNR/�r
li�I'lummer, Engineer III
Division of Water Resources
cc: Asheville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Robert G. Burgin, Jr., PE — Burgin Engineering, Inc. (Electronic Copy)
Permit Application File WQ0037555
D North Carolina Department of Environmental Quality Division of Water Resources
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512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
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Department f Environmental Quality /`� 919.707.9000

Mr. Freddie Boan
February 22, 2021
Page 2 of 6
A. Overall Submittal Package:
On December 1, 2020 a renewal application was submitted to the Non -Discharge Branch with the
application signed by Mr. Freddie Boan and dated November 30, 2020. A second application, for
a minor modification, was submitted to the Non -Discharge Branch with the application signed by
Mr. Rusty Culbreth and dated December 3, 2014. Upon receipt of the modification, the renewal
application was returned. Unfortunately, the submitted modification package appears to be
outdated and the information within suggests major modifications to the permit including the
construction of additional high -rate infiltration basins and facilities for conjunctive use spray
irrigation at the existing golf course. If these major modifications are being proposed, please
address all of the following comments. If a different set of modifications is being proposed,
please provide us with the appropriate minor modification submittal package including all of the
necessary information and documents as outlined on the HRIS 06-16 application form and also
respond to the comments regarding the Existing Permit found in Section Q below.
B. Cover Letter/Engineer's Report:
The submitted documentation is dated 2014 and it is appears that a portion of the modifications
listed therein were approved with the previous application. The proposed 104,000 gallon per day
(GPD) wastewater treatment facility is listed in the existing permit, and Phase I of this facility and
one high -rate infiltration basin (Basin C) appears to have been constructed. Phase I proposed
adding 40,000 GPD of infiltration capacity in addition to the 40,000 GPD permitted through the
NPDES permit. Our records indicate that only the 17,533 GPD high -rate infiltration basin
identified as "Basin C" has been constructed; additionally, it is unclear whether any portion of
Phase II has been constructed. The previous permit issued in 2017 removed the previously
proposed additional infiltration basins and conjunctive use spray irrigation on the existing golf
course was not mentioned in the previous permits.
2. It appears that the goal of the modification is to add two infiltration basins in addition to discharge
facilities to allow the conjunctive use spray irrigation at the existing golf course (based on what is
not listed in the existing permit). Please clarify what modifications are being proposed for review.
3. The cover letter indicates that sludge will be wasted directly from the membrane tank into sludge
tanks. The size of the sludge tanks was not provided; however, the cover letter indicates that the
tanks are sufficiently sized for 30 days of sludge storage. Additionally, it is unclear how these
solids are disposed of Please provide additional information regarding sludge handling and
disposal including the size of the existing sludge storage tanks.
C. Application Fee:
Based on what was submitted, it appears that the capacity to the infiltration basins is being increased
which is a Major Modification. If this is not what is being proposed, please clearly define the
modification and indicate whether it is minor or major. Please submit the appropriate fee if it is a
major modification.

Mr. Freddie Boan
February 22, 2021
Page 3 of 6
D. Application:
The provided application is dated 2014 and uses the old application template. It includes outdated
information, for example we understand that wells MW-1, MW-2, and MW-3 have been installed.
Please provide a new application using the most recent template (HRIS 06-16) and current
information.
The application was signed by SC Culbreth in 2014; however, Item L3 lists Mr. Rusty Culbreth as
the signature authority. Please confirm that SC Culbreth and Rusty Culbreth are the same
individual, and that Mr. Culbreth is still affiliated with Trillium Links & Village, LLC. Please note
that the business registration information recorded by the Secretary of State lists SC Culbreth, Jr.
as the Manager; however, other documentation indicates that a Mr. Freddie Boan is the Manager
of Trillium Links & Village, LLC. Please update the application form to reflect the correct name
and associated signature for the current manager of Trillium Links & Village, LLC.
E. Property Ownership Documentation:
1. No comment.
F. Soil Evaluation:
1. No comment.
G. Agronomist Evaluation:
1. No comment.
H. Hydro2eolo2ic Report:
1. Per the Hydrogeologic report, the test wells encountered groundwater at a depth of more than 40
feet. Well records were not provided for MW-1, MW-2, and MW-3 and it is unclear if these wells
were drilled to an appropriate depth for sampling. Non -discharge staff have noted that the drilled
wells have been dry during previous site visits.
2. Are Basins A, B, and D being resubmitted? Basin C was constructed in a modified form (per a
2016 modification request reducing the infiltration area from 20,081 square feet to 13,487 square
feet or 0.31 acres), but we understand that the other basins (A, B, and D) were not constructed and
were stricken from a previous version of the permit.
Table 4, Water Level Data does not have labelled columns. Please provide column labels.

Mr. Freddie Boan
February 22, 2021
Page 4 of 6
L Water Balance:
It is unclear whether the provided water balance is representative of current conditions. A spray
irrigation area of 0.973 acres was used in the provided balance and it is our understanding that the
Basin C geometry was modified. Also, the Phase I membrane bioreactor units have been installed
per our records, and it is unclear how this treatment unit has impacted nutrient loading. How has
the effluent nutrient concentrations changed and is this reflected? Please provide an updated water
balance appropriate for the current proposed facility, storage, and infiltration configuration and
capacity.
J. EnaineerinE Plans:
The cover letter and application indicated that engineering plans were to be included in the
submittal; however, the uploaded submittal did not include these plans. Please provide plans that
meet the requirements of 15A NCAC 02T .0704(c) for our review.
K. Specifications:
1. The cover letter and application indicated that specifications were to be included in the submittal;
however, the uploaded submittal did not include these specifications. Please provide specifications
that meet the requirements of 15A NCAC 02T .0704(c) for our review.
L. En2ineerin2 Calculations:
Numerous calculations were provided for treatment units that have previously been installed.
Please update the calculations section to only include calculations necessary for the proposed
modifications.
M. Site May:
1. A site map delineating the storage, treatment, and discharge areas was not provided.
N. Power Reliability Plant:
1. No comment.
O. Operation & Maintenance Plan:
1. The cover letter and application indicated that an Operation and Maintenance Plan was to be
included in the submittal; however, the uploaded submittal did not include this document. Please
provide an Operation and Maintenance Plan that meet the requirements of 15A NCAC 02T .0707
for our review.

Mr. Freddie Boan
February 22, 2021
Page 5 of 6
P. Residuals Management Plan:
1. The cover letter and application indicated that a Residuals Management Plan was to be included in
the submittal; however, the uploaded submittal did not include this document. Please provide a
Residuals Management Plan that meets the requirements of 15A 02T .07040) and .0708 for our
review.
Q. Additional Documentation:
➢ Certificate of Public Convenience and Necessity:
1. Not applicable.
➢ Existing Permit:
The existing non -discharge permit dated July 28, 2017 has numerous components proposed for
construction. The certification sent to the NPDES Unit in 2016 does not match what was
proposed for the Non -Discharge Branch permit, and the non -discharge portion of the facility
was not included in that certification. Clarify what has been installed at this facility, indicate
what is proposed for installation, and identify any components previously permitted that should
be removed based on current plans, as necessary. Additionally, a signed certification letter
needs to be provided for the non -discharge portion of the facility that is in operation.
2. It is unclear what the current facility capacity is in gallons per day (GPD). The previous non -
discharge permit indicated that the 17,533 GPD high -rate infiltration facility was installed and
in operation with a 104,000 GPD wastewater facility (we believe this value includes both Phase
I and Phase II of the wastewater treatment facility construction), but we have not received any
documentation of Phase II being completed and certified. The current National Pollutant
Discharge Elimination System (NPDES) permit issuance letter dated May 4, 2018 indicates
that the facility is rated at 40,000 GPD for their discharge. Please clarify the current, in
operation, capacity (and specify the non -discharge capacity, NPDES capacity, and treatment
plant capacity) and the proposed capacity for non -discharge and the treatment plant facilities
after construction of the modifications.
3. The monitoring well MW-4 has not been installed per our records and the site visit performed
by Non -Discharge staff. Additionally, well records have not been provided for wells MW-1,
MW-2, and MW-3. We understand that these three wells have been constructed. Please
provide us with the necessary documentation for the monitoring wells.
4. Basin C was vegetated upon the most recent site visit, and the high -rate infiltration basin was
not permitted for vegetation. It is unclear how the vegetation has impacted the capacity of the
infiltration basin.
➢ Final Environmental Document:
1. Not applicable.
➢ Floodway Regulation Compliance:
1. Not applicable.

Mr. Freddie Boan
February 22, 2021
Page 6 of 6
➢ Operational Agreements:
1. The operational agreement included within the modification submittal was not fully executed.
Please provide an executed copy of Form: HOA 11-17.
➢ Threatened or Endangered Aquatic Species Documentation:
1. No comment.
➢ Wastewater Chemical Analysis:
1. Not applicable.

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