WQ0037555_NOD2021PC0520_RESP_WellPlan_20220131

January 27, 2022
Privileged and Confidential | Attorney Work Product | Prepared at Request of Counsel
Anchor QEA of North Carolina , PLLC
231 Haywood Street Asheville, North Carolina 28801
828.281.3350
A:\Projects\Trillium Links\Text\2022-027-Trillium Links-NOD Response.docx
Brett Laverty
North Carolina Department of Environmental Quality
Water Quality Regional Operations
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Re: Monitoring Well Plan Notice of Deficiency NOD -2021-PC-0520 Trillium Links & Village W astewater Treatment Plant Cashiers , North Carolina
Dear Mr. Laverty:
Anchor QEA of North Carolina, PLLC (Anchor QEA), on behalf of Trillium Links & Village (Trillium), is
submitting this monitoring well plan to address the deficiencies identified in the Notice of Deficiency
(NOD) received through email by Trillium on November 29, 2021.
The NOD identified the following deficiencies:
1. Failure to submit a new monitoring well plan and associated documentation within 90 days of
permit issuance.
a. Part I.3 requires that within 90 days of the effective date of this permit, the Permittee shall
submit a new monitoring well plan for monitoring wells MW-1C, MW-2C, and MW-3C to
be located near Basin C to the Asheville Regional Office.
b. This submittal shall include a site map, an engineer’s statement for the basis of design for
the proposed monitoring well locations, and the proposed well construction parameters
for the installation of three new monitoring wells to replace MW -2, MW-3, and MW-4.
c. The Asheville Regional Office shall approve monitoring wells MW -1C, MW-2C, and
MW-3C prior to installation, and the monitoring wells shall be installed within 180 days of
the effective date of this permit.
d. The Asheville Regional Office shall be notified at least two bus iness days in advance of
construction of any monitoring well.
e. The monitoring wells shall be constructed such that the water level in the well is never
above or below the screened portion of the well, and in accordance with
15A NCAC 02C.0108 [15A NCAC 02C.0108, 02T.0108(b)(1)(B)].
January 27, 2022 Page 2
2. Failure to submit a final operation and maintenance plan within 30 days of permit issuance.
a. Part I.7 requires that within 30 days of the effective date of this permit, a Final Operation
and Maintenance Plan meeting the requirements of 15A NCAC 02T.0707(a) shall be
submitted for review.
This letter addresses the requirements related to the monitoring well plan (see I tem 1). In accordance
with the Required Corrective Actions listed in the NOD, Anchor QEA, on behalf of Trillium, has prepared
a monitoring well plan consisting of the following components:
• Site Map with new well locations
• Statement for basis of the well placement
• Proposed well construction
The details of the monitoring well plan are provided below. Also, discussed b elow are the well
abandonment requirements specified in the August 13, 2021, High Rate Infiltration System (HRIS),
Permit No. WQ0037555.
Monitoring Well Plan
Proposed Well Locations and Justification
The HRIS is positioned on the side of a steep northeast facing slope. Overland flow from precipitation
events will drain toward the northwest until it discharges to the northeast-trending drainage feature
that runs toward Lake Glenville. A portion of water from precipitation events will infiltrate the soil, and
the unsaturated regolith and will migrate downward until it intersects with the water table. At that
point the water will migrate from areas of high hydraulic head (higher groundwater elevation) to areas
of low hydraulic head (lower groundwater elevations) either through porous media (e.g.,
unconsolidated materials) or through fractured bedrock.
The existing monitoring well network (MW-2, MW-3, and MW-4) is shown on Figure 1. These wells
have historically been dry and are only installed to a depth of approximately 20 feet below ground
surface. These wells will be abandoned and replaced by three new wells : MW-1C; MW-2C; and MW-3C.
Documentation of the construction of these wells is not available; therefore, Anchor QEA does not
know what the subsurface conditions were like at the time of drilling for these monitoring wells. Review
of the hydrogeologic report submitted for the permit approval application1 provided data on the
depth to bedrock and groundwater depth from a boring located approximately 500 feet southwest of
the infiltration gallery. According to the report, depth to bedrock is approximately 5 1 feet below
ground surface, and the water table is approximately 49 feet below ground surface. Anchor QEA also

1 Soils, Hydrogeologic and Agronomic Investigation, Reclaimed Water – Drip Irrigation Site, Trillium Development, Jackson County, N.C.,
Edwin Andrews and Associates, P.C., August 2014.
January 27, 2022 Page 3
reviewed a geotechnical report 2 prepared by Kessel Engineering Group (Kessel; January 2016). The
Kessel report described the installation of the two boring s located on the upgradient side of the
infiltration gallery where auger refusal (generally considered top of bedrock) was encountered between
13.5 and 16.5 feet below ground surface and groundwater stabilized between 11 and 13 feet below
ground surface.
Based on the review of the historical data, depth to bedrock is variable; the true depth to groundwater
across the infiltration gallery is unknown; and downgradient from where existing wells MW-2 and MW-
3 are located , groundwater is greater than 20 feet below ground surface.
Anchor QEA visited the Site on January 12, 2022, and evaluated potential new well locations with
regard to accessibility, the potential compliance boundary, and the likely direction of groundwater
flow. Based on that field visit, Anchor QEA recommends that the two downgradient monitoring wells
MW-2C and MW-3C be installed along the road at the base of the hill (Figure 1). The reasons for the
selection of these locations is due to the following concerns :
• The steep slope leading up to the existing well locations MW-2 and MW-3 makes access
difficult.
• The new mo nitoring wells will have to be installed to a deeper depth and may intersect
bedrock. Bedrock drilling requires more tooling and support than drilling through
unconsolidated regolith. These requirements result in a larger area for drilling equipment,
which is difficult to create on steep slopes.
• These locations are in line with the likely groundwater flow direction from the HRIS, assuming
that groundwater surface is a subdued expression of the topography.
For proposed well location MW -1C, access is not an issue. The well will be installed in the general
vicinity of the former well MW-4 and will represent the background monitoring well.
Figure 1 shows the proposed locations. The downgradient well locations are positioned where a wide
median occurs adjacent to the road. Traffic control would be required to shut down a lane to allow for
safe work conditions. Underground utilities may also be present along the road and would require a
location service to identify their locations. The proposed well locations are also positioned in areas
where overhead electrical lines are present; however, there appears to be sufficient distance to allow
safe erection of the drilling mast. A site visit with the chosen well driller will be performed prior to
installation of the new wells to ensure drill rig safety and access . There may also be requirements
related to right-of-way agreements with North Carolina Department of Transportation.
Anchor QEA will also review the existing well locations, MW-2 and MW-3, with a drilling contractor and
will rely on their opinion with regards to best locations for installation of the new monitoring wells.

2 Report of Geotechnical Exploration and Slope Stability Analyses, Trillium Links WWTP Slopes, Kessel Engineering Group, January 2016
January 27, 2022 Page 4
Decommission Former Wells MW-2, MW-3, and MW-4
The existing wells MW-2, MW-3 and MW-4 will be abandoned in accordance with Title 15A North
Caro lina Administrative Code, Subchapter 2C, Well Construction rules. The work will be performed by a
licensed well driller, and the well abandonment forms will be provided to the North Carolina
Department of Environmental Quality (DEQ) as required by the well construction rules.
Well Construction
Provided that DEQ agrees with the proposed locations for the new monitoring wells, Anchor QEA will
proceed with contracting a licensed well driller to perform the installation. It is anticipated that the well
borings will be advanced into bedrock. Anchor QEA will explore different drilling options for advancing
the borings; however, the anticipated depth for each boring is planned for 100 feet below ground
surface or the first productive fracture interval, whichever is reached first. The wells will be constructed
of 2-inch-diameter, schedule 40 polyvinyl chloride (PVC) risers and screens. The screens with have 0.01 -
inch slots and will have an appropriately sized filter pack (sand) between the screened interval and the
borehole wall. Sand will extend above the screened interval and will be separated from the grout by a
bentonite seal of 3 to 5 feet. The grout will extend from the ground surface to the top of the bentonite.
The well head will be finished with a 2-foot-by-2-foot concrete pad with either a protective steel casing
with locking lid or an 8 -inch manhole with bolted cover.
A survey will be performed to determine the top of casing elevations and ground surface elevations.
Closing
On behalf of Trillium, Anchor QEA appreciates DEQ’s review of the proposed well locations and is
prepared to answer additional questions should they arise. Once Anchor QEA receives concurrence
with the well locations from DEQ, we will begin work to schedule their installation.
Sincerely,

Chuck Pippin, PG, RSM
Senior Managing Geologist
cc: Julie Babcock, Trillium Links & Villages
Attachments
Figure 1 Proposed New Well Locations
@A
@A
@A
@A
@A @A
MW-4
MW-3
MW-2
MW-1C
MW-3C
MW-2C
Publish Date: 2022/01/24, 11:59 AM | User: cpippinFilepath: Q:\Jobs\Trillium\Figure 1.mxd
[0 150
Feet
LEGEND:
Power Pole
@A Existing Well to be Abandoned
@A Proposed New Well
High Rate Infiltration System
Potential Compliance Boundary
(50 feet from Property Line)
Compliance Boundary
(250 feet from Infiltration Gallery)
Access Road
Drainage
Overland Flow Direction
Power Transmission Line
Contours: 20' Interval
Jackson County Parcels
Figure 1Propose New Well Locations
Trillium Links & Village
Approximate locaiton of
boring from the Edwin
Andrews and Associates (2014)
hydrogeologic report.
Approximate locaiton of
borings from the Kessel
Engineering Group (2016).
If review by well driller determines
that locations MW-2 and MW-3 are
better for installation of the new
wells, then these locations will be
used for MW-2C and MW-3C.
From:Willmer, Mikal
To:Robert Barr; Julie Babcock
Cc:Laverty, Brett; Chuck Pippin; Robert Cork
Subject:RE: [External] Extension for O & M Manual Submission
Date:Monday, January 31, 2022 8:29:00 AM
Attachments:image002.png
image004.png
image005.png
Bob,

Thank you for the update, I’ll update permitting with the status and make a note in the file.

Julie,

Brett forwarded me the Well Plan this morning submitted by Anchor QEA on January 27th. We will
review and update the file.

Mikal Willmer (she/her)
Environmental Specialist II – Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ – Division of Water Resources

828 296 4686 office
828 989 7675 mobile
828-299-7043 fax
[e-mail]

2090 U.S. Hwy. 70
Swannanoa, N.C. 28778

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental
Quality has adjusted operations to protect the health and safety of the staff and public. Many employees
are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office
locations are limiting public access to appointments only. Please check with the appropriate staff before
visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your
patience as we continue to serve the public during this challenging time.

From: Robert Barr <[e-mail]>
Sent: Monday, January 31, 2022 8:20 AM
To: Willmer, Mikal <[e-mail]>; Julie Babcock <[e-mail]>
Cc: Laverty, Brett <[e-mail]>; Robert Barr <[e-mail]>
Subject: RE: [External] Extension for O & M Manual Submission

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.

Mikal- We have been awaiting a response from the manufacturer of the WWTP for O&M
information.

I will forward what I have to date but have no control over design engineer and manufacturer design
information or O&M specifics and can not guess their intensions with this design. The manuals at
the conex are printed in German.

Bob

From: Willmer, Mikal <[e-mail]>
Sent: Monday, January 31, 2022 7:09 AM
To: Julie Babcock <[e-mail]>
Cc: Laverty, Brett <[e-mail]>; Robert Barr <[e-mail]>
Subject: RE: [External] Extension for O & M Manual Submission

Good Morning Julie,

The extension for the O&M Plan requested by Trillium in December was due on January 28th.
Additionally, the well plan was also due on the 28th. The Asheville Regional Office is requesting an
update on the progress of compliance schedule items. Failure to meet permit compliance schedules
may result in additional enforcement action.

As a reminder, Trillium is also required to close out the existing wells within 180 days of permit
issuance.

If you have any questions or wish to discuss further, please contact Brett Laverty or me.

Regards,

Mikal Willmer (she/her)
Environmental Specialist II – Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ – Division of Water Resources

828 296 4686 office
828 989 7675 mobile
828-299-7043 fax
[e-mail]

2090 U.S. Hwy. 70
Swannanoa, N.C. 28778

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental
Quality has adjusted operations to protect the health and safety of the staff and public. Many employees
are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office
locations are limiting public access to appointments only. Please check with the appropriate staff before
visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your
patience as we continue to serve the public during this challenging time.

From: Julie Babcock <[e-mail]>
Sent: Thursday, December 23, 2021 12:17 PM
To: Willmer, Mikal <[e-mail]>; Laverty, Brett <[e-mail]>
Cc: Robert Barr <[e-mail]>
Subject: [External] Extension for O & M Manual Submission

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.

Good Afternoon Mikal,

First and foremost, Happy Holidays! I am emailing you to request an extension to submit our O&M
manual. With the upcoming holidays and the spike in Covid Cases, we would like to ask for an
additional 15-30 days to submit the plan. Please let me know if this is acceptable.

Thank you,

Julie Babcock
POA Assistant Manager
828.743.6161