WQ0041136_NOVNOI2022LV0250_0251_0252_0253_RESP_20220429

April 29, 2022

NC Department of Environmental Quality
Asheville Regional Office
Division of Water Resources
2090 US Highway
Swannanoa, NC 28778

Attention: Landon Davidson, Regional Supervisor

Regarding: Cervini Farms of NC Inc. – WQ0041136
NOV-2022-LV-0250

Dear Mr. Davidson:

Brooks Engineering Associates (BEA), on behalf of Cervini Farms, Inc., is responding the
Notice of Violation for the above referenced wastewater treatment facility. This response
includes actions taken from previous NOV’s along with the intended remedial courses of action.

Due to prior NOV’s BEA visited the facility in December of 2021 and January of 2022 to review
to operation of the wastewater treatment system. Recommendations changes to the operational
settings were made to include increasing the equalization time, increased recirculation time and
looking at influent conditions. Influent conditions were evaluated in January and February.
There were some maintenance practices at the greenhouse facility identified that could have been
negatively impacting the influent water quality to a degree that the effluent quality would be
impacted. As a result of those recommendations, under-the-sink grease traps have been installed,
and irrigation water equipment maintenance/cleaning practices in the greenhouses have been
amended. The results of these actions are not represented in the November and December
sampling for which the NOV is issued.

Additionally, on March 9, 2022 BEA contacted staff at the Non-Discharge Branch to inquire
about possibly re-permitting the system as a Type 1 reclaimed system as opposed to the Type 2
system as the irrigation water does not directly come in to contact with the consumable products.
It appears the effluent requirements for a Type 1 system could be readily met. On April 12, 2022
we received a response that this would not be considered.

The owners of the facility are currently looking at other possible re-permitting or permit
amendment options. The high level of treatment required by the permit does not appear to be
consistent with the end use of the treated wastewater. The treated wastewater is discharged in to
the irrigation water recycling tank where it is combined with irrigation system effluent to be
recycled. The recycled irrigation water is filtered, disinfected and has nutrients added as part of
the recycling process. As the treated effluent comprises less than 5% of the total irrigation water
utilized at the hydroponic growing facility, and as there is no potential for groundwater
contamination from the treated wastewater (as it is not land applied), the ownership would like to
request technical assistance from NCDEQ as to how the system could be re-permitted so that the
permit limits reflect reasonable requirements for health and environmental safety with the
intended reuse. Ownership is also looking at the potential for a land application system but
available land at the site is limited.

In the meantime, the following steps are being taken to bring the system in to compliance with
the current permit.
1. Confirm operational settings for equalization and recirculation at the treatment system.
2. Review the monthly sampling results for recent and future events to evaluate the efficacy
of changes identified above.
3. Take influent samples from the pump station at the bunkhouse and at the WWTP. BEA
recommends three sampling events. Samples should be taken for BOD5, Ammonia at
each location, FOG at the bunkhouse, and bactericides at the WWTP.
4. Based on the sampling results make recommendations for any additional treatment
measures (grease traps? Additional aeration?) and implement.
5. Concurrently evaluate alternate permitting options.

The time frame for completing these measures is estimated to be three months.

We appreciate your oversight of this wastewater permit. Please call or email with any concerns
or comments.

Sincerely,
Brooks Engineering Associates, PA

Mark C. Brooks, P.E.