WQ0037555_More Information Requested_20150722

KNEW
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
RUSTY CULBRETH — MANAGER
TRILLIUM LINKS & VILLAGE, LLC
1 T PJLLIUM CENTER
CASHIERS, NC 28717
Dear Mr, Culbreth:
Donald R. van der Vaart
Secretary
July 22, 2015
Subject: Application No. WQ0037555
Additional Information Request 92
Trillium Links & Village WWTP
Jackson County
Division of Water Resources' Central and Regional staff has reviewed the additional information
response received May 27, 2015. However, additional information and some clarifications are required
before the review may be completed. Please address the items on the attached .pages no later than the
close of business on August 24, 2015.
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 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 three copses
submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Chonticha McDaniel
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)
Edwin E. Andrew, PG — Edwin Andrews and Associates, Inc (Electronic Copy)
Permit Application File WQ0037555
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: 91M07-64M4 Intemet: hthillyortalmdenr.orglwela Mo
An Equal Opporturty l kTirmaGv._• Aclien Employer— Made in park with recycled paper

Mr. Rusty Culbreth
July 22, 2015
Page 2 of 4
A. Applicatio_n_:
1. The response letter indicates that each infiltration basin will be constructed in phases. Please
provide a timeline for all phases of construction.
2. The application form still indicates that the applicant intends to comply with the high -rate
infiltration policy (page 13, items VI11.5.) for setback reduction. However, the response letter
states that there are no residences within 400 feet of the disposal and no property lines within 200
feet of disposal. In addition, Table V1I1.3. shows distances from infiltration system to residences
to be 200 feet and to property line at 52 feet, please clarify or amend the form to show the
corrected information. Please note that the proposed high -rate infiltration system is not
considered to be a true conjunctive system since the discharge permitted flow under the NPDES
permit (NC0059200) will not cover 100% of the total treatment capacity (i.e. permitted discharge
flow will remain at 40,000 GPD where treatment capacity will increase to 104,000 GPD and the
high -rate system is needed in order to add more disposal capacity and match the new treatment
capacity)
3. Page 5 -item V.1 I(c), please provide information for method of effluent disinfection.
Please provide information regarding number of UV banks, number of lamps per bank, and
maximum disinfection capacity on page 5 under table V. I Le.
4. The application still . indicates that public access to infiltration basin is restricted due to the
Development being fenced (page 9, item VII.S.). However, the response letter states that signage
will be used as warnings at the site, please clarify. Please note that fencing is highly
recommended since the basins will be located just above the road.
B. Soil Evaluation:
None.
C. Hydrogeolo i'c Report:
1. (Original item#5) Table 4; Water Level Data:
The revised Table 4R has two columns with the same label - Water Depth (feet). We believe one
of the columns should be labeled Well Depth and one should be labeled Depth to Water. Please
correct the table and resubmit. Also, please indicate whether the depth to water measured from
the top of casing or land surface.
2. (Original Item##7) Section 3.4; Page 3-2:
According to LeGrand, the groundwater system in the mountain region is a two-part system
comprised of regolith and underlying bedrock. The regolith is the principal storage reservoir for
the underlying bedrock facture system and is comprised of the soil horizon, saprolite, and the
transition zone.
According to U.S. Geological Survey Water -Resources Investigations Report 02-4105, the
transition zone has been identified as a potential conduit for rapid ground -water flow. The high
permeability of the transition zone probably is the result of incomplete weathering in the lower
regolith_ The transition zone consists of partially weathered bedrock and Iesser amounts of
saprolite_ Chemical alteration of the bedrock has progressed to a stage of mineral expansion and
extensive fracture development in the crystalline rock, yet it has not progressed so far that
formation of clays and other weathering by-products has been sufficient to clog the fractures. The

Mr. Rusty Culbreth
July 22, 2015
Page 3 of
presence of a zone of high permeability on top of the bedrock may create a zone of increased
ground -water flow in the ground -water system. The transition zone also may serve as a conduit
for rapid movement of contaminants to nearby wells, or to streams with channels that are cut into
or through the transition zone.
It's our concern that if the transition zone intersects the road cut along North Norton Road and
that infiltrated wastewater will short-circuit and create a discharge point along the road cut
instead of moving down to groundwater aquifers or flow to Native surface water as a typical high -
rate infiltration system is intended for. Our concern is based on the existence of a highly
permeable transition zone (25 ft./day) beneath the project site and the fact that competent rock
and groundwater seepage is visible along the road cut, which is approximately 200 feet down
gradient from the infiltration basins.
Please explain whether more study/investigation will be conducted prior to construction of the
infiltration facility to ensure that there is no potential for short-circuit and discharge along the
road cut. If no additional study is proposed, please explain what remediation/corrective actions
will be put in place if short-circuit and discharge occur after the system is constructed and
operated.
3. (Original Item #8 & #11) Section 3-5; page 3-2 and 3-3:
Please provide a detailed discussion on how transmissivity (38.4 f(z/day) and hydraulic
conductivity (25.63 ft/day) were calculated using the time -recharge method.
D. Engineering Plans:
1. (Original Item #4) flan sheet C-306 and site map:
The map has no legend and the property boundary is hard to follow, please amend the plan to
include map legend and clearly depict the property boundary.
The new monitoring well locations are acceptable. We will require that you contact the Asheville
Regional Office prior to well installation so that a regional inspector can be on -site to observe the
well installation. Once the monitoring wells are installed you will have 90 days to survey the
wells and develop a site map_ Information contained on the site map should include the following
information: infiltration basins (both as -built and proposed), waste boundary, review boundary,
compliance boundary, property boundaries, contour lines, roads, streams, and monitoring wells.
Each monitoring well should have a text box displaying the well identifier, well coordinates, well
depth, water level, and measuring point (height of casing above land surface). You will be
required to provide the Asheville Regional Office with a draft site map for approval.
The hydrogeologic report indicated safety issues with drilling monitoring wells on the steep
slopes surrounding the project area. Please explain how you propose to construct the compliance
monitoring well.
E. Engineering Design Documents:
Please note that contacting Mr. Kuhne was required as a courtesy to NCDOT because the project
is located near a state road. A slope stability analysis will need to be conducted by a licensed
geotechnical engineer prior to construction. The geotechnical engineer will need to calculate a
factor of safety, determine a critical ground water level with regards to slope stability at each
down gradient monitoring well, provide a schedule for groundwater level monitoring, and
establish protocols for continuing and discounting the land application of wastewater with regards
to groundwater levels.

Mr. Rusty Culbreth
July 22, 2015
Page 4 of 4
F. Site Map:
See item D.1. above.
G. Operation & Maintenance Plan:
1. Please expand the plan to include information regarding operations of infiltration basins and
proposed conjunctive reclaimed water utilization at the golf course.
The proposed utilization of reclaimed water at the golf course requires
H. Residuals_Management Plan:
1. Please update the residuals acceptance letter from the Town of Franklin WWTP to include
residuals from Jackson County, current version only accepts residuals from Macon. County.
The mentioned letter has not been received, please submit the updated letter.
1. Operational Agreements:
1. The submitted agreement is signed by Freddie Boan, however, the signature authority's name
indicated on the application form (page 1, item, I.3.) is Rusty Culbreth. If there is a change in
personnel (since both of them are shown as manager), please update the application form to
reflect the corrected name.