WI0100170_Regional Office Physical File Scan Up To 9/22/2022

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
February 24, 2012
Western Carolina University
Joe Walker
3476 Old Cullowhee Rd.
Cullowhee, NC 28723
SUBJECT: Construction Stormwater Permit Compliance Inspection
Western Carolina University (WCU)-Harrill Hall
Jackson County
Dear Mr. Walker:
Dee Freeman
Secretary
RECEIVED
KAR 012012
Asheville Regional Office
A uifer Protection
This letter is in follow-up to the Compliance Inspection conducted on February 8, 2012. The facility was found
to be non -compliant with the Construction Stormwater Permit NCGO 10000.
The Division of Water Quality's (DWQ) Construction Stormwater Permit requires that the site be compliant
with the Division of Land Resources (DLR) approved Erosion and Sedimentation Control Plan. The most
recent inspection by DLR indicated non-compliance. There are several areas that DLR_and DWQ need WCU to
address in order to come into compliance.
The enclosed Site Inspection Reports contain observations and comments to assist you with compliance. The
Site Inspection Report, which indicates the Program Area as Standards/Sediment, relates primarily to the
Geothermal Well Drilling operation and the Site Inspection Report which indicates the Program Area as
Construction SW (NCGO10000), relates primarily to the construction operations at WCU.
The compliance deadline is March 30, 2012.
Please contact me at (828);296-4500 or lines [e-mail], if I can be of any further assistance.
Sincerel ,
Linda Wiggs
Environmental Specialist
Surface Water Protection
Enclosures
cc: Central Files
Asheville Files
DLR ARO _
DW( , -
Lo Dillard a -copy)
Steve Stancill (e-copy)
WCU-Curtis Monteith, Galen May, Joe Walker (e-copy)
SASWPUackson\Stormwater\NCG0l Construction\WCU Harrill Hall\WCU.C1311TRYeb 2012.doc
Location: 2090 U.S. Highway 70, Swannanoa, North Carolina 28778 One
Phone: [phone]\ FAX: [phone] NO)rt�1Ca1'011lla
Internet: www.ncwaterquality.org i :.,
Nlatullallff
An Equal Opportunity 1 Affirmative Action Employer

Site Inspection Report ­ Co-n sirvc_.�, G-'(1_
Site Number: WT000181
Site Name: Western Carolina University Harrill Hall
Site Address:
County: Jackson Region: Asheville
Directions:
Latitude: Longitude:
Site Owner Name: Western Carolina University
Inspection Date: 02/08/12
Reason for Inspection: Complaint
Inspection Type: Site Inspection (non -DOT)
Inspection Contact Person:
Walker, Joe
On -Site Representative(s):
Steve Stancill
Primary Inspector: Linda S Wiggs I-11h/
Secondary Inspector(s):
Facility compliance Status: 0 Compliant
Program Area Construction SW,(NCG010000)
Question Areas:
NCG010000 Permit
■ Not Compliant
Phone:
828-227-7441
Phone: [phone]
Phone: [phone] Ext.4653
Page: 1

Site Number: WT000181 Owner: Western Carolina.University
Inspection Date: 02/08/12 Inspection Type: Site Inspectior (non-bOT) Reason for Visit: Complaint
Inspection Summary:
Construction Operation Overview and Summary for February 8, 2012 Inspection
-Three-Stormwater (SW)-outfalls, two permitted, -one unpermitted bypass. -
*The unpermitted bypass happens during rain events via the current construction entrance across the parking lot to the stream. This
bypass should be redirected to the. basin. If that is not feasible then any bypass flows shall not be sediment laden or discolored. As
discussed during the inspection this area of the construction site would require sufficient temporary groundcover to avoid erosion
during a rain event.
*The permitted SW outfall with the basin is receiving little water at this time of construction. As noted above where feasible
stormwater flows from this area of the construction site should be redirected to the basin for treatment. Again temporary groundcover
in this area should be deployed to avoid water quality standard violations such as elevated stream turbidity.
* The permitted SW outfall with the underground piped conveyance system is receiving most of the SW flows from the construction
site. There are several issues with this outfall: run-on, lack of treatment or maintenance and housekeeping.
**During rain events storm flows drain directly onto the construction site from the upper roads. These flows should not be allowed to
drain onto the construction site. The site was not approved to treat these flows.. Western Carolina University should evaluate this
situation and consider diversion options to keep these flows off the construction site.
**The stormwater conveyance system is discharging stormflows that will likely violate water quality standards. Representatives have
been advised to monitor this outfalls SW discharge for turbidity levels. And to take appropriate actions on the site to obtain a SW
.discharge that will not violate water quality standards. Items mentioned during inspection to improve the discharge were to add
temporary groundcover where feasible (cover stock piles, spread sufficient straw on bare areas, etc), continue using the waddle and
check dams in concert with the inlet stone protections, but these devices need to be installed and maintained for their optimum
effectiveness. Also other contaminants having access to the stormwater conveyance system were noted, particularly concrete and/or
bentonite. These products have a high pH that could alter the receiving streams pH and cannot be discharged thru this conveyance.
Monitoring the outfalls turbidity levels will assist in determining if actions initiated have improved SW discharge from the site.
Because the site is already deploying chemicals in association with thageothermal well drilling activity it is preferred that the
construction activities not use chemicals. But, if all items mentioned above are not sufficient to avoid violating water quality standards
then it may be necessary to consider the use of chemicals for the construction area. However, chemicals are not to be used for the
construction area without prior discussion and approval from the inspector; Linda Wiggs 828-296-4500.
Page: 2

f . I
C 13Yl57c'Jnk_'
Site Number: WT000181 Owner: Western Carolina University
Inspection Date: 02/08/12 Inspection Type: Site Inspection (non -DOT) Reason for Visit: Complaint
NCG010000 Permit
Yes No NA NE
# Is this inspection related to a DLR/delegated program inspection?
❑ Q Q
If Yes, what was the DLR/delegated program inspection date?
01/31/2012
Is the site following its E&SC Plan as per DLR or delegated program?
Q 0 ❑ ❑
Is the site maintaining their E&SC measures as per DLR or delegated program?
Q E Q 11
Is a copy of the approved E&SC plan on site?
Q Q n
Is a rain gauge present on -site or is MPE in use for the site?
❑ Cl ❑
Is rain gauge data or MPE data recorded?
Q O Q
Are inspection records complete?
00 0
Is the site compliant with other conditions of the NCG010000 permit?
❑ 0 0 0
Comment: DWQ inspection records are being filled out, but on an old form. Contractor
was given new form and informed how to fill it out more thoroughly, as well as where to
evaluate the discharge. The new form has the proper notification requirements to DWQ
if non -compliant situations occur.
Most of the site drains to an old underground SW system with several inlets. Basic inlet
protection has been established with some added measures including waddles prior to
a sediment storage area and check dams. There was undercutting and a lack of
connectivity at some of the waddles rendering them less effective. Also evident at the
inlet area by the dumpsters was concrete or bentonite residue. Based on conditions
during the inspection a discharge from this SW system would likely violate water quality
standards. See inspection summary for more information.
Page: 3

Site Inspection Report
Site Number: WT000181
Site Name: Western Carolina University Harrill Hall
Site Address:
County: Jackson Region: Asheville
Directions:
Latitude: Longitude:
Site Owner Name: Western Carolina University
Inspection Date: 02/08/12
Reason for Inspection: Complaint
Inspection Type: Site Inspection (non -DOT)
Inspection Contact Person: Phone:
On -Site Representative(s):
Lon Dillard Phone: [phone]
Primary Inspector: Linda S Wiggs" Phone: [phone] Ext.4653
Secondary Inspector(s):
Facility compliance Status: [I Compliant M Not Compliant
Program Area Standards/Sediment
Question Areas:
Unpermittable Activities
Page: 1

Site Number: WT000181 Owner: Western Carolina University
Inspection Date: 02/08/12 Inspection Type: Site Inspection (non -DOT) Reason for Visit: Complaint
Inspection Summary:
Geothermal Well Installation Overview and Summary for February 8, 2012 Inspection
The geothermal well drilling operation required a water treatment system to avoid a discharge to the receiving stream that would
violate water quality standards. As noted in an email between the inspector (Linda Wiggs) and the driller (Lon Dillard), the water
treatment system consisted of a 8" pipe from a rig diverter to a 1 st stage 12 yard container for initial settling of heavy particles, then
another 8"pipe carrying water to the 2nd stage 12 yard container which would have a filter bag for further particulate removal. The
next phase of the system introduces NC approved chemicals to help settle out the remaining fines. The chemical being used is an
Applied Polymer System (APS) log product inserted in a log train attached to the second container. From the floc log train the water
would flow toa 20'x10' final clarifying area. The clarifying area would consist of a bottom layer of filter clothe topped with jute matting
and perimeter and interior series of straw wattles wrapped with a BSRF silt fence material. This clarifying area will be located on an
old basketball court. Water should then flow overland in a non concentrated manner to the stream.
*The driller was also instructed by the inspector to not use any chemicals beyond the floc log train so there would be sufficient area to
allow the chemical to bind with the suspended particles and settle out. If there is not sufficient area for this settling process then there
could be a discharge of these chemicals to the stream which would not be acceptable.
*Other items discussed with the driller regarding the water treatment system were the residual disposal and stream
observations/monitoring.
**He was told to designate an area where any residuals/waste from the drilling operation will go before he began and to be prepared
to deploy any necessary erosion control around this area, especially the settled fines if they require drying time.
**He was told to clear a path for access to the stream, if necessary. If the stream was overgrown with weeds he was instructed to
weed eat a path for access upstream of the discharge area and downstream of the discharge in order to make daily observations to
make sure stream impacts were not occurring.
** Finally he was told to have a turbidity meter onsite to make sure the discharge was compliant with turbidity standards.
For the most part all of this was done however there are some areas that need improvement and the driller is re-evaluating the water
treatment system to maintain compliance with water quality standards.
*Areas noted above that need improvement are the final clarifying area for settling out the particulates and having the turbidity meter
onsite.
**There were signs of a bypass around the final clarifying area near the upper end of the basketball court by the adjacent driveway. It
is unclear why this bypass occurred, but it needs to be eliminated. The clarifying area did not appear to be constructed as originally
indicated or simply was not large enough. The clarifying area should have sufficient hold time associated with it so the water can be
still to allow for the final settling. The driller has to be creative in order to make the most of this area to achieve compliance but also
avoid damage to the basketball court. Discussed during the inspection was laying plastic over a berm of sufficient size and material to
create a stilling basin.
**It was explained that the turbidity meter needed to be onsite and how to use the turbidity meter in order to determine compliance
with water quality standards. Upstream observations/readings can be performed at the upstream culvert. Downstream
observations/reading can be performed —20-50 feet downstream of where the drilling operation discharge enters the stream. It should
also be noted that drilling cannot take place during rain events. The water treatment system for the drilling operation is not sufficiently
size to accept any additional water from a rain event. What falls into the canisters or the clarifying area during a rain event is ok, but
no run-on should be allowed into this system.
The driller encountered a geologic formation that required him to re-evaluate the chemicals being used to settle the particulates.
Liquid chemicals (Cape Fear products) will be introduced at the, head of the system in the 1 st canister. The driller has been told not
to use the APS and Cape Fear chemicals in conjunction without discussing this with the inspector first. If the chemicals are to be
used at the head of the system then the floc log train should be detached and vice versa.
Ancillary drilling and construction waste need to be managed in a manner that will not pollute the environment.
The driller was advised to adequately protect wellheads and boreholes to prevent migration of surface contaminants into the borehole
and/or annular space of incomplete injection wells. The recommended approach is to complete (ie, grout and cap) each injection well
before moving to the next well location. An alternate approach is to provide ample wellhead or borehole protection by building a soil
berm or sandbagging around each wellhead/borehole to divert surface contaminants from entering the borehole. The loops and any
open casing or annular space should be sealed until the well is completed. Other methods may also be used to divert surface
contaminants away from the well until well construction is complete.
Turbidity Samples Results:
Drilling operation discharge-996 NTU
Upstream of discharge-9 NTU
Downstream of discharge-30 NTU
Page: 2

a c .
Site Number: WT000181 Owner: western Carolina University V
Inspection Date: 02/08/12 Inspection Type: Site Inspection (non -DOT) Reason for Visit: Complaint
Unpermittable Activities
# Note: This section should be completed only if the impact is unpermittable (eg. Sediment, draining wetlands,
etc.).
Is stream(s) free of unpermittable impacts?
Is wetland(s) free of unpermittable impacts?
Is open water(s) free of unpermittable impacts?
Are other standards being met (turbidity, pH, etc.) in all surface waters onsite?
Are surface waters on the site free of.illegal discharges?
Comment: Minor sediment impacts are present in the receiving stream.
Turbidity violations were ocurring due to drilling operations and will likely occur during
rain events from both operations if added measures are not put in place. See summary.
Both operations (construction and drilling) had bypass situations that will need to cease
or be manage to avoid stream violations.
Page: 3

ED
Perrnit Nurnber W10100170
g Central Files: APS_ SWP_
/4 �OIl1 09/12/11
Permit Tracking Slip
Program Category `� ° F Q_
Project Type
`"``'a mot = " ^--�
Ground Water ;r_';.=:.:.--.,.,..
_ ,Status
Active
New Project
Permit Type
Version
Permit Classification
Injection Water Only GSHP Well System (5QW)
1.00
Individual
Primary Reviewer.
Permit Contact
Affiliation
michael.rogers
Lon Dillard
Driller Well
Coastal SW Rule
PO Box 580
Blairsville
GA 30514
Permitted Flow
Facility
Facility Name Major/Minor Region
Western Carolina University 5QW Minor Asheville
Location Address County
554 Central Dr Jackson
Cullowhee NC 28723 ' Facility Contact Affiliation
'7=I -
Owner Name
Owner Type
State of North Carolina
Government - State
Owner Affiliation
Joe Walker
Western Carolina University
Cullowhee NC 28723
Dates/Events
Scheduled
Orig Issue App Received Draft Initiated issuance
Public Notice Issue Effective Expiration
09/12/11 09/07/11
09/12/11 09/12/11
Regulated Activities
Heat Pump Injection
University/College
Outfall NULL
Waterbody Name Stream Index Number Current Class Subbasin

WIPA
NCDEHR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
09/13/2011
Joe Walker, PE
Western Carolina University
3476 Cullowhee Rd.
Cullowhee, NC 28723
Subject: Acknowledgement of Intent to Construct Type 5QW Injection Well System
Permit No. WI0100170
554 Central Dr.
Cullowhee, NC 28723
Dear Mr. Walker:
Dee Freeman
Secretary
On 09/07/2011, the Aquifer Protection Section (APS) received notification of your intent to construct a closed -loop water -only
geothermal injection well system for the operation of a ground -source heat pump located at the address referenced above. An
individual permit is not required for the construction and operation of this type of geothermal injection well system as long as the
following conditions are met:
1. The injection well system contains only potable water,
2. The injection "well. system is constructed in accordance with well construction standards specified in North
Carolina Administrative Code Title 15A Section 2C Subchapter .0213, and
3. The required notification form and associated maps have been completely and accurately submitted.
Failure to comply with all of these conditions constitutes a violation of the North Carolina Well Construction Act and North Carolina
Administrative Code Title 15A Section 2C Subchapter :0211(u)(2). Additionally, you should contact the Jackson County Health
Department as they may have additional requirements for this type of system. Noncompliance with applicable state, county, or
municipal rules and regulations may result in the assessment of civil penalties.
Please contact Mike Rogers at [phone] or Michael.Rogers(cr�,ncdenngov if you have any questions.
S cerely,
for Deb a atts
Supervis
cc: Asheville Regional -Office - APS__)
t APS Central Files - Permit No. WI0100170
Jackson County Health Dept.
Lon Dillard (Byers Well Drilling, Inc., P.O. Box 580, Blairsville, GA 30514)
Anthony Barnette (W.E. Bolton, P.O. Box 8609, Asheville, NC 28114)
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 One
Phone: [phone] \ FAX 1: 919-715-0588; FAX 2: 919-715-6048 \ Customer Service: 1-877-623-6748 7oI'1 1 c�1'c3AIIIa
Internet: www.nmaterauality.org 1� f
G
An ,.qual Opportunity 1 Affirmative Action Employer _ e

NORTH CAROLINA DEPARTMENT OF BNV'IRONMI✓NT AWD NA•i1 ntAf, er71.Zn1 urrn.c
NOWIICATION OTC` INTUGNT TO CONSTRUCT OR OPMATL� INJ'1uCTION WE, LLS
In Amordanco With the Provisions of I SA NCAC 02C .0200
CLOSE' D-LOOP WATER -ONLY GEOTHERMAL IN,iECTYON 'WELLS
Time wells Circulate potablo wntsr only as part of a geothermal heating and cooling systom.
These wolfs are "parmittad' by rule" and do not require an individual permit when they are constructed in
accordonco with the rules of 1 SA NCAC 02C ,0200 and this Notice is submitted prior to construction.
Print ar *Pe ht ormat/on and Nlail to the Address wr the Last Paige.
DATE: August 22, 2011 PERW & NO, - - .... - (to be filled in by D'WQ)
A. STATUS Or WELL OWNER (choose one)
Non. -Government: Individual Residence—.— 13usiness/Organization
Government: State X Municipal County Huderal
B. WELL O'VVNER —1 or individual resideneos, list e—owner on property deed, For all others, state name of
entity Md name of person delegated authority to sign on behalf of the: business or agency:
The State of North Carolina titrogggil Western Carolina Uniyan&ity
Mailing Address: 3476 Old CallowheeRoad
City: Cullowhee-._ State: NC_, Gip Code: 28723 County: Jackson
Day Tele No.: [phone] Cell No.: NA
EMAIL Address: [e-mail]1 Fay No.: MOM 227-7198
C. LOCATION OF'R']CLL SITE — Where the injection wells are physically located:
(1) Parcel identification Number (PIN) otwell site:____ 7559-23-1452 ^County:
(2) Physical Address (if different than mailing address):
City: Cullowhee State:NC Gip Code: 28723
D, WE, LL DRII,Iti,,= INFORMATION
Well Drilling Conlraotor l,4 Name: Byers .Well I]rilllne Inc
NC Well Thrilling Contractor Certification No.: 3131
Company Name: Bars rill'rn Inc.
Contact Pt rson,L I,on llillard EMAIL Address Idillatd rr brmg1pc net .
Address; POEgg _58o
City: tflairsvillcs ___ Gip Code: 30514 State:. CrA County: Union
Office Tele lqo.: [phone] _ Cell No,: ____(706) 781-4582 Ftnc No y NA
GPU/UIC SQW Nolifrcntion (Revlsed 3/18/2011)
Page 1
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60
E, SEAT PUMP COMMACMR INFORMATION (if different than driller) CIO
rn
CorupanyNanie;svc.rrnrJ
Contact Person- _.Mt#I, Address:
Address: 11aa :Eue- �, ���►„� �fst-a 1='•E7� $a+yc 43�v�1 CIS UZ)
City: "ca16.6 r. Zip Code: .$IDS- State: J�C.Cotn2ty: _f5tAVkC-z2 a
Uffice'1'eleNa.; ��,-_29 - 3�21 Cell No.: 5 4-0% 1
V. Wll LL CONSTRUCT)ION DATA
(1) Number of borings to be constructed*: 100 Depth of each boring (feet): 450 feet
* V existh S wOler strppJy wells Ivill he uNed then pr-ovide the itifor„ralion br ilcanr (4) below.
(2) Type of tubing to be used (steel, PVC, etc): _________iJDP8
(3) Well casing, if the i veli(s) Nvill use casing then provide the lyre (steel, PVC, etc.), diammetnr, ,
and ex ant of casing Appearing above grgtind; NA
(4). Grout (material surrounding well casing and/or piping):
(a) Orout type: Cement Bentonite** Other (specify) Thermally Enhanced Bentonim
ny selecting aa�uunilr �rou6 u vnrivacc h Hereby requested to IYA NCAC 2C .0213(d)(1)(A), wllicll ngulres u ccmCill typr gout.
(b) Grout depth of tubing (reference to land surfaao); from-0— to 450 (Feet)
If well has casing, indicate grout depth; from to (feet)
G. WELL LOCATIONS— Maps must be scaled or otherWise accurately indicate distances and orientations of
features located within 1000 feet of tine injection Well(s). Label all features 4learlyspnc incltWeg worth arrow,,
(1) Attach a site -specific map showing the locations of the follorving;
* Proposed injection wells Buildings * Property boundaries
a Surface water bodies * Water supply wells
* SepNc tanks and associated spray irrigation sites, drawl fields, or repair areas
Existing or potential sources of groundwater contamination
(2) Attach a topographic map of the area exh-Ading 1/4 mile from the injcctloii well site that indicates the
facility's location and the reap aatno,
NOI In most cases, all aerial pkatograpla of the property parcel slrowirrg property 1111es and structures catr be
oblalared and daivideaded from the applicable courtly GIs lvebslte. 7)rpicalip, rite praperly.cau be srarckerl by
olVller Halite or llfklrcxs. Tire locatlaa of !ke ►yells lrr relallon to property borrudarks, kuases, septle Yanks, ather
hells, etc. call then he ftrmvn lrr by luuul, �ilso, a Payer, crru be selected diolvkrg topagraplr/c contours or
elevarlon rlalrr.
GPU/U1C 5Q11r Notification (Revised 3/1 s/2011)
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H. C)t;12"1' FICATION (to be signed as required below or by that person's authorized agent)
ISA NCAC 02C .021 I(b) requires that all pe►alit applications shall be signed as follows: "� o
1. for a corporation: by a responsible corporate officer; . o
2. for a partnership or sole proprietorship: by a general partner or the proprietor, tespeotivoly; ens 3, for a municipality or a state, federal, or other public agency: by either a Principal executive y
officer Or raiil(ing publicly elected official;
4. for all others: by the well owner (wliich means all persons listed on the grotaerty deed),
If an nuthmvzed agent is sigidug on behalf of the applicant, than supply a letter signed by tite
applicant that itantes and atttborizes their agent to sign this Application all their behalf;
"I hereby certify, under penalty of law, that I have personally examined and am familiar with the information
submitted in this document and all attachments thereto and that, based on my inquiry of those individuals
iuwiediately responsible for obtaining said hiforination, I believe that the information is true, accurate and
conipiete. I am aware that there are significant penalties, including t4 possibility of fines and imprisonment,
for submitting, false information, I agree to construct, operate, nnaintairl, repair, and If applicable, abandon the
injection well and all related appul-tenances in accordance with the approved specifications and conditions of
the Parntit."
Sign f of Property Owner/Applic it
Joe Walker, LAP
Associate'VC Facilities Management
Print or Type Full Name
Signature of Property Owner/Applicant
Print or Type Full Name
Signature of Authorized Agent, if any
Print or Type Full Nama
Submit the c:ornplete application package to:
D'WQ Aquifer Protection Section
1636 Matil Service Center
Raleigli, NC 2709-1636
Telt phone [phone]
C)PUNIC SQW Notification (Revised 311812011)
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