WQ0004967_CEI_NOV2021PC0157_RESP_20210331

March 31, 2021

Anchor QEA of North Carolina, PLLC 231 Haywood Street Asheville, North Carolina
A:\Projects\AllJuice\2021-0323_NOV Response\AllJuice - Response to NOV 2021-0331.docx
Sent via email: [e-mail]

Landon Davidson
North Carolina Division of Water Resources
Water Quality Regional Operations
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Re: Response to Requirements of the March 1, 2021 Notice of Violation AllJuice Realty, LLC, 352 Jet Street Hendersonville, North Carolina Permit No. WQ0004967
Dear Mr. Davidson,
Anchor QEA of North Carolina, PLLC, on behalf of AllJuice Realty, LLC (AllJuice), is submitting this
response to the Notice of Violation (NOV) dated March 1, 2021, and received by AllJuice Realty, LLC
(AllJuice), on March 16, 2021. The NOV is based on the January 26, 2021 inspection performed by the
North Carolina Division of Water Resources (DWR), which identified numerous weeds and
moisture-tolerant grasses present in the irrigation field. This observation was found to be
non-compliant with wastewater irrigation system permit (Permit No. WQ0004967) condition III
(Operation and Maintenance Requirements) paragraph 3, requiring that a suitable year-round
vegetative cover shall be maintained at all times.
In addition to the condition of the irrigation field, the NOV also noted a potential compliance issue
related to the influent pipe that conveys wastewater from the AllJuice facility to the wastewater
storage pond.
In response to these non-compliance issues, a summary of the corrective actions currently underway
and a schedule of implementation is provided below.
Background
The following correspondence provides the background for compliance issues identified by DWR,
the assessments that have been completed to evaluate the compliance issues, and the corrective
measures that AllJuice is currently pursuing:
• October 2017 – DWR, Notice of Violation and Intent to Enforce
• June 2018 – Anchor QEA, Notice of Violation and Intent to Enforce Response
March 31, 2021 Page 2
• March 2019 – DWR, Review of the Notice of Violation and Notice of Intent to Enforce Response Report and Required Corrective Action Measures
• April 2020 – Anchor QEA, Corrective Action Assessment Report (CAAR)
• September 2020 – Anchor QEA, Off-Site Assessment and Pipe Inspection Results
The April 2020 and September 2020 reports, submitted by Anchor QEA, on behalf of AllJuice,
describe assessment activities that were performed to determine appropriate corrective actions.
Permit Condition III-3
In response to the violation of permit condition III-3, the April 2020 CAAR recommended the
following activities to improve the assimilative capacity of the irrigation fields:
• Remove weeds and reestablish the fescue cover crop.
• Initiate a maintenance program where mowing and mowed-crop removal are routinely performed.
• Apply gypsum or similar soil amendment to break the sodium binding in the soils.
• Alternate wetting and drying application periods in the field to promote better microbial
activity and root growth.
• Consider planting trees along the perimeter of the field to develop a deep root system to enhance treatment.
Anchor QEA is implementing the recommended activities for the irrigation fields. Actions that have
been completed or will complete in 2021 include the following:
• November 2020 – Soil samples were collected from the irrigation fields to determine the required volume of gypsum to apply to fields.
• January to February 2021 – A gypsum vendor has been identified that can supply the volume required for soil treatment and deliver it to the site in April 2021.
• April 2021 – Apply a selective herbicide to the application fields.
• May 2021 – Amend soil with first application of gypsum, allowing adequate adsorption period in between applications.
• June to August 2021 – Initiate a more aggressive crop/grass cutting, harvest and removal program for application fields.
• August to September 2021 – Reseed application fields with Tall Fescue grass.
• September to October 2021 – Apply selective herbicide to the application fields (may be spot application).
• November 2021 – Amend soil with second application of gypsum.
• March to April 2022 – Reseed application fields with Tall Fescue grass (if needed).
• May 2022 – Amend soil with final application of gypsum.

March 31, 2021 Page 3
Influent Line to Wastewater Storage Pond
The influent line to the wastewater storage pond was assessed using a pipe camera on February 25,
2020, to evaluate the source for fecal coliform found in the wastewater treatment system irrigation
storage pond1. As described in the September 2020 Off-Site Assessment and Pipe Inspection Results,
the pipe camera identified a section of pipe that had been repaired in the past. The location of the
repair is in the vicinity of the former septic system and is the likely source of the fecal coliform
detected in the storage pond. The excavation noted by the DWR inspector was related to an existing
conditions survey performed during the week of January 5, 2021, which used air-knife excavating to
expose buried piping around the storage pond. This excavation was not related to assessment or
repair of the influent pipe.
The damaged section of piping is believed to have occurred in 1999, based on a Henderson County
septic system repair permit, which describes the wastewater line as being in close proximity to the
septic drain field.
Review of the pipe camera video shows the damaged section of piping occurring on the top half of
the pipe; the bottom half appears to be intact (Figure 1). This suggests that meteoric water from
precipitation events may enter the pipe (and introduce fecal coliform); however, the wastewater from
the plant does not appear to rise to the level of the repaired section of the pipe (Figure 1).
Anchor QEA has initiated the design process for modifying the storage pond and installing a pond
liner. As part of this process, the influent pipe will be repaired and rerouted to accommodate the
new pond design. Anchor QEA requests that the pipe repair be deferred until the construction phase
of the project, which is estimated for 2022.
Presently Anchor QEA has completed an existing conditions survey to document the surface
elevation, bathymetry, and elevations and directions of sub-surface pipes and utilities around the
pond. Anchor QEA is currently working on the pond modification design.
Closing
On behalf of AllJuice, Anchor QEA appreciates the DWR’s time and consideration as we work through
these compliance issues. Work is moving forward with regard to the pond modification design, which
will address the influent pipe repair. Our engineering team will be reaching out to the DWR in
April 2021 to schedule a pre-application meeting to discuss our proposed pond modification design.
Afterward our team will be working on the final design and permitting. We anticipate assisting
AllJuice with contractor selection for design implementation in early 2022. Between now and late fall
2021, we will be working on irrigation field improvements. Attachment 1 provides a general schedule

1 Assessment performed in response to the requirements set forth in the March 5, 2019 Notice of Violation and Notice of Intent to Enforce Response Report and Required Corrective Action Measures, North Carolina Division of Water Resources
March 31, 2021 Page 4
for the planned activities. Should the DWR have questions or concerns, please do not hesitate to
contact me by email or phone [phone]).
Sincerely,

Chuck Pippin, PG, RSM
Managing Geologist
cc: Kristina Armbrust, [e-mail]
Rob Howell, Anchor QEA, Principal
Mikal Willmer, Water Quality Regional Operations Section
Attachments
Figure 1 Influent Pipe Repair Location
Table 1 General Project Schedule
Figure
Figure 1 Influent Pipe Repair Location
Response to Requirements of the March 1, 2021 Notice of Violation AllJuice Realty, LLC
Filepath: \\asheville1\Asheville\Projects\AllJuice\2021-0323_NOV Response\Figure 1 - Pipe Repair Location.docx
Image of repaired section of Influent Pipe. Image has been rotated 35 degrees to
horizontal. Dashed yellow line shows the high water mark in the pipe. Dashed blue line shows the level of the wastewater on February 8, 2020.
The high water mark is below the damaged area of the pipe. The pipe appears intact
below this area and does not allow wastewater to discharge to subsurface soils. Meteoric water from precipitation event does have the opportunity to enter the pipe through the repaired section.
During the implementation of the pond design, this section of the influent pipe will be
repaired.
Table
Table 1
General Project Schedule
January February March April May June July August September October November December January February March April May June
Existing Pipe Schematic
Existing Conditions and
Topographic Survey
Design Development
Final Design
Pre-Application Meeting
Preliminary Operation and
Maintenance Manual
Wastewater Irrigation
Systems Permit Submittal
Bid Document Development
Bid Solicitation and
Advertisement
Bid Review and Contractor
Selection
Irrigation Field Improvements
Pre-Construction
Site Preparation and Bypass
Set-Up
Construction (Sludge
Removal and Stockpile)
Construction (Pond
Modifications)
Engineer’s Certification of
Completion
Commissioning
Closeout
2022
QRT2
2021
QRT 4
2022
QRT1Task Description
2021
QRT 1
2021
QRT 2
2021
QRT 3
Pond Modification Project Scope of Work
AllJuice Facility, Hendersonville, North Carolina
Page 1 of 1
March 2021