WQ0004967_Renewal Application_20211004

Initial Review
Reviewer Thornburg, Nathaniel D
Is this submittal an application? (Excluding additional information.)*
r Yes r No
Permit Number (IR)* WQ0004967
Applicant/Permittee AIIJuice Realty, LLC
Applicant/Permittee Address 1 Westbrook Corp Ctr # 330, Westchester, IL 60154
Is the owner in BIMS? r Yes r No Is the facility in BIMS? r Yes r No
Owner Type Organization
Facility Name AIIJuice WWTF
County Henderson
Fee Category Major Fee Amount $0
Is this a complete
application?*
r Yes r No Complete App Date 10/04/2021
Signature Authority
Signature Authority Title
Signature Authority Email
Document Type (if non -application)
Email Notifications
Does this need review bythe hydrogeologist?* r Yes r No
Regional Office
CO Reviewer
Admin Reviewer
Below list any additional email address that need notification about a new project.
Email Address
Comments to be added to email notfication
Comments for Admin
Comments for RO

Comments for Reviewer
Comments for Applicant

Submittal Form
Project Contact Information
Rease provide information on the person to be contacted by N B Staff regarding electibnittal, confirmation of receipt, other
.......................................................... electronic surece, aner correspondence.
_ -
Name * All Juice Realty, LLC
Email Address*
[e-mail]
Project Information
........ ......... ....................................................................................................................................... .
Application/Document Type* r New (Fee Req ui red)
r Modification - Major (Fee Required)
r Renewal with Major Modification (Fee
Required)
r Annual Report
r Additional Information
r Other
Phone Number*
8288205434
O Modification - Minor
G Renewal
C GW-59, NDMR, NDMLR, NDAR-1,
NDAR-2
r Residual Annual Report
r Change of Ownership
We no longer accept these monitoring reports through this portal. Please click on the link below and it will take you to the correct form.
https://edocs.deq.nc.gov/Forms/NonDischarge_Monitoring_Report
Permit Type:*
r Wastewater Irrigation
r High -Rate Infiltration
r Other Wastewater
r Reclaimed Water
r Closed -Loop Recycle
r Residuals
r Single -Family Residence Wastewater
r Other
Irrigation
Permit Number:*
WO0004967
Fbs Current Existing permt number
Applicant/Permittee *
AIIJuice Realty, LLC
Applicant/Permittee Address*
1 Westbrook Corp Ctr # 330, Westchester, IL 60154
Facility Name *
AIIJuice WWTF
Please provide comments/notes
on your current submittal below.
At this time, paper copies are no longer required. If you have any questions about what is required, please contact Nathaniel Thornburg
at [e-mail].
Please attach all information required or requested for this submittal to be reviewed here.*
(Application Form Engineering Rans, Specifications, Calculations, Rc.)
All Juice (WQ0004967) Wastewater Irrigation System - 11.82MB
Renewal 10-4-2021. pdf
toload only 1 FLFdocurrent (less than 250 M3). Multiple docurrents mist be combined into one R7Ffile unless file is larger than
upload linit.
* V By checking this box, I acknowledge that I understand the application will not be
accepted for pre -review until the fee (if required) has been received by the Non -
Discharge Branch. Application fees must be submitted by check or money order
and made payable to the North Carolina Department of Environmental Quality
(NCDEQ). I also confirm that the uploaded document is a single PDF with all parts
of the application in correct order (as specified by the application).
Mail payment to:
NCDEQ — Division of Water Resources
Attn: Non -Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Signature
01f11t1zak&

Submission Date 10/4/2021

Attachment I
Compliance Schedules from Section 1 of the 2017 Response Actions
Permit
1.The Asheville Regional Office shall approve theThe report, “Notice of Violation and
monitoring well MW-1 replacement prior toNotice of Intent to Enforce Response
installation, and the monitoring well shall be installed(Anchor QEA, June 2018) was submitted
within 90 days of the effective date of this permit. Thein response this Compliance Schedule.
regional office shall be notified at least 48 hours prior
to the construction of any monitoring well, and such
Page 2 of the report details the response
notification to the regional supervisor shall be made
actions and describes the installation of a
from 8:00 a.m. until 5:00 p.m. on Monday through
new monitoring well to replace MW-1
Friday, excluding State Holidays. The monitoring well
shall be constructed such that the water level in the
monitoring well is never above or below the screened
(open) portion of the well at any time during the year,
and in accordance with 15A NCAC 02C .0108. The
general location and name for each monitoring well is
marked on Figure 1. \[15ANCAC 02C .0108, 02T
.0108(b)(2\]
2.Within 60 days of completion of the monitoring well,The report, “Notice of Violation and
the Permittee shall submit two original copies of a siteNotice of Intent to Enforce Response
map with a scale no greater than I-inch equals 100 feet;(Anchor QEA, June 2018) was submitted
however, special provisions may be granted upon priorin response this Compliance Schedule.
approval for large properties. At a minimum, the map
shall include the following information:
The figures and tables of the report
a.The location and identity of each monitoring
provides the information requested in
well.
Compliance Schedule No. 2.
b.The location of major components of the waste
disposal system.
c.The location of property boundaries within 500
feet of the disposal areas.
d.The latitude and longitude of the established
horizontal control monument.
e.The elevation of the top of the well casing (i.e.,
measuring point) relative to a common datum.
f.The depth of water below the measuring point at
the time the measuring point is established.
g.The location of compliance and review
boundaries.
h.The date the map is prepared and/or revised.

June 2018
AllJuice – 352 Jet Street, Hendersonville, North Carolina
Notice of Violation and Notice of Intent to
Enforce Response
Permit Number WQ0004967
Prepared for AllJuice

TABLE OF CONTENTS
1Introduction ................................................................................................................................ 1
1.1Background............................................................................................................................................................ 1
1.1.1Permit Modification Letter............................................................................................................... 1
1.1.2 Notice of Violation and Notice of Intent to Enforce .............................................................. 1
1.1.3 Response Actions ................................................................................................................................ 2
1.2 Report Purpose .................................................................................................................................................... 3
2Site Investigation....................................................................................................................... 4
2.1 Monitoring Well Installation and Well Development ............................................................................ 4
2.2 Groundwater Sample Collection ................................................................................................................... 5
2.3 Treatment Pond Sampling ............................................................................................................................... 6
2.4 Ditch Water Sampling ....................................................................................................................................... 7
2.5 Influent and Effluent Sampling ...................................................................................................................... 8
2.6 Limited Site Receptor Survey .......................................................................................................................... 8
2.7 Sampling Results ................................................................................................................................................. 8
2.7.1 Field Parameter Data .......................................................................................................................... 8
2.7.2 Groundwater Sample Results .......................................................................................................... 9
2.7.3 Treatment Pond, Influent and Effluent, and Ditch Sample Results .................................. 9
2.8 Comparison of Results ................................................................................................................................... 10
3Receptor Survey Results ......................................................................................................... 12
4 Hydrogeologic Setting........................................................................................................... 13
5Discussion .................................................................................................................................. 14
6Conclusions and Recommendations ................................................................................... 18
6.1 Cause ..................................................................................................................................................................... 18
6.2 Significance and Extent .................................................................................................................................. 18
6.3 Corrective Action .............................................................................................................................................. 18
7References ................................................................................................................................ 20
Notice of Violation and
Notice of Intent to Enforce Responsei June 2018

FIGURES
Figure 1 Site Location Map
Figure 2 Site Features Map
Figure 3 Sample Location Map
Figure 4 Estimated Groundwater Elevation Map with Estimated Groundwater Flow
Velocity
Figure 5 Location of Water Supply Wells Within 1,500 feet of the Site
Figure 6 Sample Results from December 2017
Figure 7 Sample Results from April 2018
Figure 8 pH Trends for MW-1, MW-2, and MW-3
Figure 9 Summary of Wastewater Interaction with Groundwater
Figure 10 Annual Average Effluent Concentration for Ammonia
TABLES
Table 1 Well Construction
Table 2 Field Parameter Measurement Prior to Sample Collection
Table 3 List of Analytical Methods
Table 4 Groundwater Elevation
Table 5 Groundwater Analytical Results Summary
Table 6 Treatment Pond, Effluent, Influent and Ditch Water Analytical Results Summary
APPENDICES
Appendix A DEQ Correspondences
Appendix B James & James Environmental Pond Investigation
Appendix C Boring Logs and Well Construction Records
Appendix D Well Development Records
Appendix E Field Sampling Forms
Appendix F Analytical Results
Notice of Violation and
Notice of Intent to Enforce Responseii June 2018

ABBREVIATIONS
µg/L micrograms per liter
2L groundwater standards 15A North Carolina Administrative Code 02L .0202 groundwater standards
AllJuice AllJuice Realty, LLC
Anchor QEAAnchor QEA of North Carolina, PLLC
DEQ North Carolina Department of Environmental Quality
James & JamesJames & James Environmental
LiDAR light detection and ranging
NOV-NIENotice of Violation and Notice of Intent to Enforce
NTU nephelometric turbidity unit
ORP oxidation reduction potential
Pace Pace Analytical Services, LLC
PVC polyvinyl chloride
siteAllJuice Realty, LLC, juice bottling facility at 352 Jet Street in Hendersonville,
North Carolina
VOC volatile organic compound
Notice of Violation and
Notice of Intent to Enforce Responseiii June 2018

1Introduction
AllJuice Realty, LLC (AllJuice), operates a juice bottling facility located at 352 Jet Street in
Hendersonville, North Carolina (the site). The non-sanitary wastewater generated from the facility is
conveyed to a treatment pond. The wastewater is aerated in the treatment pond. Following aeration,
the wastewater is sprayed onto adjacent fields when conditions allow. The North Carolina
Department of Environmental Quality (DEQ) authorizes the treatment and land application of the
wastewater under Permit Number WQ0004967. This permit is in effect from April 27, 2017, to
March 31, 2022. As a condition of the permit, groundwater samples are collected from monitoring
wells MW-1, MW-2, and MW-3 three times per year and submitted for laboratory analysis. A site
location map is shown in Figure 1. Operation, monitoring, and maintenance of the treatment and
land application system, including compliance sample collection, is performed by AllJuice’s licensed
operator in responsible charge, James & James Environmental (James & James).
1.1Background
1.1.1Permit Modification Letter
On April 27, 2017, AllJuice received a permit modification letter (Permit Number WQ0004967) from
the DEQ’s Division of Water Resources. As part of the permit modification, DEQ requested existing
background monitoring well MW-1 be replaced due to historically low water levels or dry conditions
in the well. In addition, the DEQ cited in its letter 2016 and 2017 analytical results from compliance
monitoring samples collected from monitoring well MW-2, which had concentrations of total iron,
total manganese, and ammonia greater than the Title 15A Subchapter 02L .0202 of the
North Carolina Administrative Code (2L groundwater standards).
1.1.2Notice of Violation and Notice of Intent to Enforce
The DEQ issued a Notice of Violation and Notice of Intent to Enforce (NOV-NIE) on October 15, 2017
(DEQ 2017). The NOV-NIE requirements are summarized as follows:
Violation 1 – Permit Condition Violation (NOV-2017-PC-0649): The existing background
monitoring well MW-1 is often dry. As part of the April 2017 permit, the following conditions
were outlined and not completed:
Replace the background monitoring well by July 2017.
Update the site map with the location of the new background well.
Violation 2 – Violation of 2L groundwater standards (NOV-2017-LV-0672, NOV-2017-LV-0673,
NOV-2017-LV-0674, and NOV-2017-LV-0675): Analytical results of compliance monitoring
samples collected from monitoring well MW-2 indicate concentrations of total iron, total
manganese, and ammonia that exceed their respective 2L groundwater standards.
Notice of Violation and
Notice of Intent to Enforce Response1 June 2018

1.1.3Response Actions
Anchor QEA of North Carolina, PLLC (Anchor QEA), completed several activities in response to the
NOV-NIE. The requirements DEQ listed in the NOV-NIE and the response actions taken by
Anchor QEA on behalf of AllJuice are as follows:
1.Provide an explanation for why the permit condition requiring a new background monitoring
well was not fulfilled.
a.A statement to address this requirement was provided in the Work Plan to Address the
Requirements of the Notice of Violation and Notice of Intent to Enforce (Anchor QEA 2017),
dated November 15, 2017.
2.Identify a new background monitoring well location and provide an updated site map showing
its location.
a.The new background monitoring well location was identified, the well was installed, and
on December 5, 2017, Anchor QEA emailed documentation to the DEQ (Appendix A).
Additionally, representatives of AllJuice and Anchor QEA presented the updated site map
to DEQ during a meeting held at the DEQ, Asheville Regional Office on February 27, 2018.
The updated site map is shown in Figure 2.
3.Implement low-flow sampling to reduce turbidity to less than 10 nephelometric turbidity units
(NTUs) at the time of sample collection.
a.Anchor QEA performed low-flow sampling at the site and achieved less than 10 NTUs at
each groundwater sampling location. Anchor QEA informed James & James of the low-
flow requirement for compliance monitoring, and James & James intends to perform
future compliance monitoring using low-flow sampling methods.
4.Assess the cause, significance, and extent of the violation of the 2L groundwater standards and
submit the results of the investigation along with a plan and proposed schedule for corrective
action.
a.Anchor QEA has assessed the cause, significance, and extent of the 2L groundwater
standard violations. The remaining sections of this report address this action.
5.Assess the conditions within the wastewater irrigation pond to determine whether a buildup of
organic solids and low dissolved oxygen conditions are contributing to the groundwater
violations.
a.James & James performed this work in September 2017, and the results of its
investigation are provided in Appendix B. Anchor QEA also assessed the pond and
confirmed the findings of James & James. Anchor QEA and AllJuice presented these data
to DEQ during the February 27, 2018 meeting and have provided these data in this report
as well.
6.Perform a limited water receptor survey to determine whether water supply wells exist in the
immediate vicinity of the wastewater irrigation pond.
Notice of Violation and
Notice of Intent to Enforce Response2 June 2018

a.Anchor QEA completed a limited receptor survey and presented the results to DEQ during
the February 27, 2018 meeting. The results of the receptor survey are also included in this
report.
1.2Report Purpose
On behalf of AllJuice, Anchor QEA has completed a series of assessment activities. Anchor QEA
performed the activities to assess the cause of violations of 2L groundwater standards observed in
the samples collected from monitoring well MW-2. Assessment activities included the installation of
two monitoring wells (one new and one replacement), low-flow sampling of on-site monitoring wells,
collection of samples from the wastewater treatment pond, and collection of water samples from the
drainage ditch located east of the pond.
Anchor QEA identified potential sources that may be responsible for the impacts to on-site
groundwater. Those potential sources were presented to the DEQ in a meeting held at the DEQ,
Asheville Regional Office on February 27, 2018. The potential sources include the on-site treatment
pond, the spray irrigation field, and the septic drain field, which is associated with a separate system
for sanitary wastewater treatment and disposal permitted by the Henderson County Health
Department. The purpose of this report is to summarize and consider the historical data and data
collected during recent assessment activities with respect to the potential source areas identified on
site. A description of the scope of services performed, methods used, and summary of the results is
provided in the following sections.
Notice of Violation and
Notice of Intent to Enforce Response3 June 2018

2Site Investigation
Work activities were completed in general accordance with the Work Plan to Address the
Requirements of the Notice of Violation and Notice of Intent to Enforce (Anchor QEA 2017), dated
November 15, 2017, and approved by DEQ on December 5, 2017, by email. The completed scope of
work involved the installation of two additional groundwater monitoring wells and the sampling of
the site’s groundwater monitoring wells, wastewater present in the treatment pond, influent to the
treatment pond, effluent from the treatment pond, and water present in a ditch located between the
treatment pond and the on-site septic drain field (Figure 3). Anchor QEA also completed a limited
receptor survey to identify water supply wells near the site.
In addition to the work performed by Anchor QEA, James & James performed an assessment of the
treatment pond in September 2017. James & James collected 12 samples from the bottom of the
treatment pond and measured the depth of the accumulated solids. These results are provided in
Appendix B.
Anchor QEA designed the 2017 Work Plan to Address the Requirements of the Notice of Violation and
Notice of Intent to Enforce to assess the potential sources of the violations of the 2L groundwater
standards observed in samples collected from monitoring well MW-2. At the time Anchor QEA wrote
the work plan, the potential source areas included the treatment pond, the spray field, and the septic
drain field, which is associated with a separate system for sanitary wastewater treatment and disposal
permitted by the Henderson County Health Department. During site investigations, Anchor QEA
identified a fourth potential source area: the drainage ditch between the septic drain field and the
treatment pond. This ditch receives stormwater runoff from the spray irrigation fields and conveys it
off-site to a tributary to Wolfpen Creek. During a November 2017 site visit, Anchor QEA noticed a
breach in the eastern bank of the drainage ditch. This breach was located at the northern end of the
septic drain field. Anchor QEA modified the work plan to evaluate the ditch as well.
2.1Monitoring Well Installation and Well Development
On October 25, 2017, Anchor QEA provided the DEQ with a letter describing the proposed location
and construction details of the new background monitoring well to be installed as a replacement for
the current background monitoring well, MW-1. On October 31, 2017, Bret Laverty with the DEQ sent
an email to Anchor QEA agreeing with the chosen well location, provided that it is outside of the
influence of the spray irrigation system.
Anchor QEA oversaw the installation of the new background monitoring well, MW-5, on
November 28 and 29, 2017. Additionally, a monitoring well (MW-6) was installed in between the
treatment pond and the septic system leach field on April 2, 2018. The monitoring wells were
installed by South Atlantic Environmental Drilling and Construction Company, Inc., a North Carolina-
Notice of Violation and
Notice of Intent to Enforce Response4 June 2018

licensed drilling company. Monitoring wells MW-5 and MW-6 locations are shown in Figure 2, and
well construction information is included in Table 1.
Monitoring well MW-5 was installed using hollow-stem auger and air hammer drilling technology.
Monitoring well MW-6 was installed using hollow-stem auger drilling techniques only. The
monitoring wells were constructed with 2-inch-diameter Schedule 40 polyvinyl chloride (PVC) well
materials. A 0.01-inch machine-slotted PVC screen was set to a depth perceived, at the time of
installation, to intersect the water table at each well location. No. 2 filter sand was then used to fill
the annular space between the well screen and the borehole to a depth of approximately 2 feet
above the top of the well screen. Approximately 3 feet of hydrated bentonite pellets were placed
above the filter sand. A cement grout mixture was used to fill the annular space to within 1 foot of
the ground surface. Both wells were completed with approximately 3 feet of riser aboveground and
protected with an outer steel vault with a hinged, lockable lid. Boring logs and well construction
records are provided in Appendix C.
After installation, MW-5 and MW-6 were developed using the surge-and-bail method and purged
using a submersible Whale pump. Approximately 85 gallons of water were purged from monitoring
well MW-5, and approximately 255 gallons of water were purged from monitoring well MW-6.
Additionally, monitoring wells MW-1 (former background well), MW-2, and MW-3 were redeveloped
using a Waterra pump. While development was performed, the surge block on the Waterra pump
was positioned in different depth intervals of the screen, starting at the bottom of the well and
moving up, until the surge block had been applied to the entire screened interval. Each well was
developed for up to 4 hours. Well development logs are provided in Appendix D.
2.2Groundwater Sample Collection
After well installation and well development were complete, Anchor QEA waited for a period of time
(<7 days) to allow equilibrium conditions to return. Anchor QEA returned to the site on the following
dates, measured depth to groundwater in the wells, and collected groundwater samples:
1
MW-3, and MW-5
December 13 and 14, 2017, for monitoring wells MW-1, MW-2,
April 5, 2018, for monitoring wells MW-2, MW-5, and MW-6
Quality control samples were collected during the December 2017 and April 2018 sampling event
and included a duplicate sample, trip blank, and equipment blank.
Low-flow sampling techniques were utilized to reduce turbidity in groundwater samples. A peristaltic
pump was used to purge and collect samples from monitoring wells MW-2, MW-3, and MW-6. , A
1
On January 12, 2018, Anchor QEA returned to the site to resample monitoring well MW-2 for nitrate-nitrite due to laboratory
mishandling.
Notice of Violation and
Notice of Intent to Enforce Response5 June 2018

bladder pump was used to purge and collect samples from monitoring wells MW-1 and MW-5 due
to deeper water table depths
Prior to purging, groundwater levels were measured using a water level meter. Groundwater samples
were collected after field parameters had stabilized (Appendix E). Field parameters (pH, temperature,
dissolved oxygen, specific conductance, and oxidation reduction potential \[ORP\]) were measured
approximately every 3 minutes with a calibrated YSI 556 multiparameter water quality meter.
Turbidity was also measured using a turbidity meter. Parameters were considered stabilized after
three consecutive readings were within the following ranges:
pH: ±0.1 unit
Specific conductivity: ±3%
Temperature, dissolved oxygen, and turbidity: ±10%
ORP: ±10 millivolts
Turbidity: <10 NTUs (if practical)
The final field parameter readings for each collected sample are presented in Table 2. Samples were
transferred to laboratory-provided sample containers and placed in a cooler on ice for delivery to the
laboratory.
Anchor QEA had Pace Analytical Services, LLC (Pace), a North Carolina-certified laboratory, analyze
the groundwater samples collected on December 13 and 14, 2017, and April 5, 2018, for the
constituents listed in Table 3.
The groundwater depth measurements, summarized in Table 4, were used to develop groundwater
elevation map for the site (Figure 4). Groundwater elevation contours are approximate. They were
developed based on ground surface elevations provided by the North Carolina Flood Plain Mapping
2
project, measuring the aboveground stickup of the monitoring well casing and calculating the top-
of-casing elevation for each well. The groundwater elevation was then determined by subtracting the
depth to groundwater from the top-of-casing elevation. Depth to groundwater was measured each
time a monitoring well was sampled. Figure 4 provides the estimated groundwater elevation for the
data collected in December 2017.
2.3Treatment Pond Sampling
To supplement the work performed by James & James to assess ammonia in the treatment pond,
Anchor QEA collected samples from the treatment pond as follows (the locations of these samples
are shown in Figure 3):
December 21, 2017
2
The North Carolina Flood Plain Mapping project provided light detection and ranging data (LiDAR) for the state, resulting in a high-
resolution elevation model. The data are provided through NC OneMap’s 2-Foot Statewide Elevation Contour dataset.
Notice of Violation and
Notice of Intent to Enforce Response6 June 2018

0.5 foot below pond surface: Pond 1-A, Pond 2-A, and Pond 3-A
3 feet below pond surface: Pond 1-B, Pond 2-B, and Pond 3-B
At pond surface: Pond-FC
April 5, 2018
At pond surface: Pond-1
Samples were collected with a peristaltic pump, polyethylene tubing (new tubing for each sample), a
weight, and a guide line. The guide line was used to position the two lengths of tubing in the center
of the treatment pond, and a weight was used to position the openings of each tube near the
bottom of the pond or just below the surface, depending on whether it was a deep or shallow
sample. The fecal coliform sample and the sample collected on April 5, 2018, was collected using a
dedicated plastic container that was properly cleaned in between collected samples. The samples
were transferred to laboratory-provided containers and placed in a cooler on ice for delivery to the
laboratory. Field parameters were also measured for these sample locations and are included in
Table 2. Anchor QEA had Pace analyze the treatment pond samples collected in December 2017 and
April 2018 for the constituents shown in Table 3.
2.4Ditch Water Sampling
Anchor QEA collected samples from the ditch that lies between the treatment pond and the site’s
septic drain field as follows (the locations of these samples are shown in the attached Figure 3):
December 21, 2017
North end of the ditch: D-1
South end of the ditch: D-2
April 26, 2018
North end of the ditch: D-1.2
South end of the ditch: D-2.2
Ditch at the property boundary: D-3
Downstream of the breach in the ditch bank: D-4
Samples were collected in the same manner as the treatment pond samples and then were
transferred to laboratory-provided containers and placed in a cooler on ice for delivery to the
laboratory. Field parameters were measured for these sample locations and are provided in Table 2.
Anchor QEA had Pace analyze the ditch water samples for the constituents shown in Table 3.
Notice of Violation and
Notice of Intent to Enforce Response7 June 2018

2.5Influent and EffluentSampling
Influent and effluent to the treatment pond were sampled at the following locations:
A sample of the influent to the treatment pond (INF) was collected on December 21, 2017.
The sample was collected prior to discharge into the treatment pond, where the wastewater
discharge exits the facility (Figure 3).
A sample of the effluent from the treatment pond (EFF) was obtained on December 21, 2017,
by collecting effluent in the spray field during active spraying. The sample was collected
midway up the hill as shown in Figure 3. This sample represents the effluent that infiltrates the
spray field. Anchor QEA had Pace analyze the influent and effluent samples for the
constituents shown in Table 3.
2.6Limited Site Receptor Survey
As required in the NOV-NIE, Anchor QEA performed a limited site receptor survey to identify
potential receptors located within 1,500 feet of the site. In December 2017 and January 2018,
Anchor QEA contacted the Henderson County Department of Public Health and reviewed septic
system permits (which often identify the location of a supply wells relative to a septic system) and
new water supply well permits. Anchor QEA also contacted the City of Hendersonville Water and
Sewer Authority and provided a list of addresses for the adjacent property owners and asked to
verify the addresses that were connected to a municipal water supply. Anchor QEA then compiled
this data into a GIS database and created a map identifying known well locations. On January 22,
2018, Anchor QEA performed a drive-by assessment of the properties within 1,500 feet of the site to
verify whether a well was present and then updated its GIS database accordingly. Figure 5 provides
the results of the limited site receptor survey performed by Anchor QEA in December 2017 and
January 2018.
2.7SamplingResults
December 2017 and April 2018 sample analytical results are summarized in the following
subsections. Field parameter data collected during these events is provided in Table 2, and the
analytical results are summarized in Tables 5 and 6. Figures 6 and 7 display the sample analytical
results on a map of the site features. Laboratory analytical reports are included in Appendix F. There
were many analytes that were analyzed as part of this investigation, and these are provided in
Tables 4 and 5; however, the field parameter and analytical results discussed in the following sections
provide insight into the 2L groundwater violations observed at monitoring well MW-2.
2.7.1Field Parameter Data
Field parameters were measured for each sample collected during the December 2017 and
April 2018 sampling events. The field parameter data for the groundwater samples varies significantly
Notice of Violation and
Notice of Intent to Enforce Response8 June 2018

between monitoring wells (Table 2). The parameters with the most significant differences are
summarized as follows:
Specific conductance measures the potential conductance for a water sample. Higher specific
conductance measurements indicate a greater concentration of dissolved constituents.
Specific conductivity measurements of groundwater from monitoring wells MW-2 and MW-6
were higher than those from monitoring wells MW-1, MW-3, and MW-5.
Dissolved oxygen measurements indicate the concentration of the oxygen in a water sample.
Dissolved oxygen measurement of groundwater from monitoring wells MW-2 and MW-6 are
less than those from monitoring wells MW-1, MW-3, and MW-5.
ORP measures the tendency for chemical constituents to acquire electrons and thereby be
reduced. High ORP values indicate aerobic conditions, and low ORP values indicate anaerobic
conditions. ORP measurements from monitoring wells MW-2 and MW-6 were much lower
than those observed from monitoring wells MW-1, MW-3, and MW-5.
2.7.2Groundwater Sample Results
Table 5 presents the groundwater analytical results and a summary of the groundwater results in
relation to the 2L groundwater standards as follows:
Monitoring well MW-2 – Analytical results confirmed detections in MW-2 of ammonia, iron,
and manganese at concentrations that exceed the 2L groundwater standards. MW-2 also had
low detections of volatile organic compounds that were below the 2L groundwater standards.
Monitoring well MW-6 – Results for the sample collected from the new monitoring well,
MW-6, indicated detections of nitrate, iron, and manganese that exceed their respective
2L groundwater standard. Ammonia was also detected at concentrations that were just below
the 2L groundwater standard.
Monitoring wells MW-1, MW-2, and MW-5 – pH (refer to Table 2) was outside of the range
provided in the 2L groundwater standard.
Monitoring well MW-3 – Results for this monitoring well did not exceed any 2L groundwater
standards.
2.7.3Treatment Pond, Influent and Effluent, and Ditch Sample Results
The treatment pond was sampled by James & James in September 2017 at 12 locations from the
bottom of the treatment pond. The samples were analyzed for ammonia and pH. The ammonia
concentrations ranged from 194 micrograms per liter (µg/L) to 6,990 µg/L, and pH ranged from 2.0
to 2.7.
The treatment pond, influent, and effluent samples collected by Anchor QEA had detections for the
following constituents: nitrogen compounds (non-detect for ammonia), iron, manganese, sodium,
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Notice of Intent to Enforce Response9 June 2018

calcium, magnesium, potassium, phosphorus, chloride, total dissolved solids, total suspended solids,
biological oxygen demand, and chemical oxygen demand (Table 6).
As the treatment pond is designed and permitted to accept untreated influent and treat it to levels
that are acceptable for land application, these detections are expected and will fluctuate dependent
on the nature of the influent conveyed to the treatment pond. Likewise, the effluent pumped from
the treatment pond and sprayed onto the field had similar constituent detections as the treatment
pond samples.
Stormwater runoff from precipitation events may mobilize accumulated constituents applied to the
spray fields and convey these constituents to the drainage ditch that lies between the treatment
pond and the septic drain field. The samples of the water collected from the ditch also exhibit similar
constituent detections as the treatment pond and effluent, with the exception that the ditch water
had concentrations of ammonia (Table 6).
2.8Comparison of Results
Noted differences in constituent concentrations among the treatment pond samples, the influent
and effluent samples, the ditch samples, and groundwater samples include the following:
Ammonia
Ammonia was not detected above the method detection limit of 50 µg/L in the
treatment pond, influent, or effluent samples collected by Anchor QEA, suggesting that
the pond is maintained in an aerobic state and that aeration is effectively treating the
wastewater.
Ammonia was detected in monitoring wells MW-2 and MW-6 and Ditch Samples D-1,
D-2, and D-4.
Nitrate was detected at concentrations less than the 2L groundwater standard at groundwater
monitoring wells MW-1, MW-2, MW-3, and MW-5 and was not detected above the method
detection limit of 50 µg/L or 10 µg/L for the treatment pond samples, the ditch samples, and
groundwater monitoring well MW-6.
Phosphorus was detected at estimated concentrations in the groundwater samples from
monitoring wells MW-1, MW-2, MW-3, and MW-5 (and at less than 25 µg/L at MW-6) and is
generally up to 2 orders of magnitude higher in the influent, effluent, and treatment pond
samples and 1 to 2 orders of magnitude higher in the ditch water samples compared to the
well samples.
On average, pH in the treatment pond and effluent samples was about 3.8. The pH was
generally higher for the influent, groundwater, and ditch water samples.
Notice of Violation and
Notice of Intent to Enforce Response10 June 2018

Alkalinity was measured in samples collected from the treatment pond, the ditch, and
monitoring wells MW-2, MW-5, and MW-6. Alkalinity was highest in the sample from
monitoring well MW-2 and lowest in the sample from monitoring well MW-6.
Volatile organic compounds (VOCs) were only detected in monitoring well MW-2 and at
concentrations below the 2L groundwater standards.
In addition to comparing the results of samples collected from different locations, Anchor QEA
compared the change in pH over time in samples collected from monitoring wells MW-1 (the former
background well), MW-3, and MW-2. These data suggest an increasing trend for pH in monitoring
well MW-2 and a steady trend for pH in monitoring wells MW-1 and MW-3 (Figure 8).
Notice of Violation and
Notice of Intent to Enforce Response11 June 2018

3Receptor Survey Results
The results of the receptor survey are presented in Figure 5, whichshows the locations of identified
receptors along with the owner name and address.
Anchor QEA identified several private water supply wells near the site; however, most wells are in an
upgradient or crossgradient direction from the site. One water supply well was identified adjacent to
the site toward the southwest. This water supply well is located at approximately 580 feet from the
treatment pond and across the western tributary to Wolfpen Creek.
Notice of Violation and
Notice of Intent to Enforce Response12 June 2018

4Hydrogeologic Setting
The AllJuice facility is positioned on top of a northwest-trending topographic ridge that is bound the
northeast and southwest by small tributaries of Wolfpen Creek. The treatment pond is positioned on
the southwestern side of the ridge, and the spray fields are upgradient from the treatment pond. The
wastewater effluent from the treatment pond is spray-applied to the spray fields and infiltrates into
the soils and ultimately to the groundwater table. The ridge, as anticipated, creates a groundwater
divide.
Anchor QEA’s depth-to-groundwater measurements indicate a relatively deep groundwater table
underneath the spray fields (up to 50 feet belowground at monitoring well MW-5) and a shallower
groundwater table in the vicinity of the treatment pond (about 18 feet belowground at monitoring
well MW-2).
Anchor QEA’s interpretation of the groundwater elevation contours for the site are provided in
Figure 4 and show the interpreted groundwater flow directions to the southwest and northeast.
Anchor QEA also estimated groundwater flow velocity. Groundwater flow velocity is calculated by
multiplying the horizontal hydraulic conductivity with the horizontal hydraulic gradient and dividing
the product by the effective porosity. To estimate the groundwater flow velocity, Anchor QEA used
the following parameters:
Horizontal hydraulic gradient, based on the groundwater flow lines i and i shown on Figure
12
4.
Horizontal hydraulic conductivity, based on hydraulic conductivity values reported in the Bent
Creek Hydrogeological Investigation Report (North Carolina Division of Water Quality, 2011)
of 0.2 to 3 feet per day. To refine these values, Anchor QEA referred to recent work performed
at another site located in Transylvania County and in a similar geologic setting. At this site, K
values ranged from 0.5 to 1.62 feet per day. In Anchor QEA’s opinion, these values seem more
reasonable.
Effective porosity, assumed to be 0.3 based on observation of fine sand and silt observed in
boreholes advanced on site during the installation of monitoring wells MW-5 and MW-6.
Anchor QEA estimates the average groundwater flow velocity at the site to be between 10.4 and
49.5 feet per year. In areas of the site where the hydraulic gradient is steeper, the groundwater flow
velocity will be faster; in locations near the septic drain field and treatment pond, the gradient is less
steep, so the groundwater velocity in this area will be slower.
Notice of Violation and
Notice of Intent to Enforce Response13 June 2018

5Discussion
One of the goals of this investigation was to determine the cause of the 2L groundwater standard
violations in samples collected from monitoring well MW-2. This section of the report describes the
collected data and presents lines of evidence that suggest that the treatment pond is not the primary
source for the 2L groundwater standard violations in samples collected from monitoring well MW-2.
To assist in this discussion, a conceptual cross section was developed that identifies the treatment
system flow diagram and potential inputs to the groundwater at the site (Figure 9). The cross section
shows the positions of monitoring well MW-2, the treatment pond, the drainage ditch, monitoring
well MW-6, and the septic drain field. The cross section is oriented east to west and parallels the
interpreted groundwater flow path from the septic drain field to monitoring well MW-2.
Monitoring Well Locations Relative to Potential Source Areas
Monitoring well MW-2 has been used as a compliance monitoring well since the site was permitted
for land application of treated wastewater. The current NOV-NIE was issued based on iron,
manganese, and ammonia concentrations in sampled groundwater from monitoring well MW-2 that
exceed the 2L groundwater standards.
Monitoring well MW-2 is positioned downgradient from the treatment pond, and the ditch is located
between the treatment pond and the septic drain field (Figure 4 and Figure 9). Monitoring wells MW-
1, MW-3, and MW-5 are positioned to the west, east, and north of the spray application field. MW-5
is a new background monitoring well that has been installed to replace the former background
monitoring well, MW-1. Monitoring wells MW-1 and MW-3 are located in positions where
groundwater flow from the spray applications areas will migrate past these wells, and they provide
opportunity to evaluate the performance of the spray application area. The newest well, MW-6, is
located on the western side of a groundwater divide and is between the septic drain field and the
ditch, both of which are upgradient of the treatment pond. Groundwater elevation data suggest that
a flow path from the spray irrigation field to monitoring well MW-2 is unlikely to exist (Figure 4).
Therefore, the spray irrigation field is an unlikely source for the 2L groundwater standard violations
observed in samples collected from monitoring well MW-2.
A direct groundwater flow path exists from the septic drain field past monitoring well MW-6 and
past the ditch and treatment pond to monitoring well MW-2. This flow path is depicted in Figure 9.
Monitoring well MW-2 is screened approximately 25 feet below the water table, downgradient of the
treatment pond, and monitoring well MW-6 is screened at the top of the water table, downgradient
and adjacent to the septic drain field. The geochemistry between these two locations is distinct from
the other monitoring wells on site and indicates impacts from the failed septic system. Both
monitoring wells MW-2 and MW-6 have low dissolved oxygen and high dissolved solids compared
to the other monitoring wells. The alkalinity in monitoring well MW-2 is more than 20 times that
Notice of Violation and
Notice of Intent to Enforce Response14 June 2018

observed in samples from monitoring well MW-6, suggesting that denitrification is not occurring in
monitoring well MW-2. The high concentrations of ammonia, iron and manganese in monitoring well
MW-2 suggest the following:
1.Ammonia is not fully undergoing denitrification and concentrations of ammonia are entering
the groundwater table and migrating downstream to monitoring well MW-2.
2.Denitrifying bacteria are active in some areas of the ammonia plume and are obtaining oxygen
through reduction of manganese and iron oxides, resulting in elevated concentrations of these
elements that are migrating downstream to monitoring well MW-2.
Ditch East of the Treatment Pond
Stormwater runoff from the spray irrigation fields is conveyed to a tributary of Wolfpen Creek by the
ditch located to the east of the treatment pond. The ditch runs generally north to south and has a
shallow gradient, which results in accumulation of stagnant water in some locations. It is possible
that stormwater runoff mixes with sprayed effluent and carries wastewater constituents to the ditch.
Additionally, Anchor QEA identified a breach in the ditch’s eastern embankment, located near the
northern end of the septic drain field (Figure 2). This discovery was communicated to AllJuice in
November 2017. AllJuice had the septic system evaluated and determined that it was not functioning
correctly. Since December 2017, AllJuice has been removing its septic waste by a pump-and-haul
service and has contracted a septic installation company to assist with the installation of a new septic
system.
The ditch represents a potential source for the concentrations observed in monitoring well MW-2.
3
Samples collected from the ditch confirmed the presence of ammonia (range of detections 58 J to
4,100 µg/L). If the failed septic system contributed to the ammonia detected in the samples collected
from the ditch, then the ditch may have contributed to the ammonia concentrations detected in
samples collected from monitoring well MW-2.
Treatment Pond
The treatment pond is reportedly unlined; however, historical ammonia concentrations analyzed
from effluent compliance samples suggest that ammonia has been well managed by the treatment
pond (Figure 10). The best historical record of the potential ammonia concentrations in the pond is
from the historical compliance data for the pond effluent. There was a period from 2006 to 2011
where effluent concentrations of ammonia where elevated. Since 2011, ammonia effluent
concentrations have been below laboratory reporting limits or have ranged upwards of 10 milligrams
3
A “J” value in a laboratory analytical report indicates that the result is estimated because it was detected at a concentration that lies
between the laboratory’s method detection limit and it practical quantitation limit.
Notice of Violation and
Notice of Intent to Enforce Response15 June 2018

per liter (or 10,000 µg/L, to compare to the results in Tables 5 and 6). These are similar to the non-
detect results obtained through analysis of Anchor QEA’s treatment pond samples.
As an unlined pond, it is anticipated that it is leaky; however, given the high concentration of
ammonia observed in monitoring well MW-2, it seems unlikely that the source of the ammonia is the
treatment pond. Even if the pond leaked ammonia during the period from 2006 to 2011, when
effluent concentrations were high, the impacts from the potential leak would most likely have
migrated past monitoring well MW-2 based on the estimated groundwater flow velocities provided
in Figure 4. Factoring in natural attenuation effects (such as adsorption, dispersion, and dissolution),
it is unlikely that the treatment pond is causing the elevated concentrations at monitoring
well MW-2.
Septic System
After Anchor QEA observed the breach in the drainage ditch embankment, an investigation of the
septic system was performed. Anchor QEA discovered that the septic system required repair in 1999
due to poor performance. Part of the repair included burying the drain lines in the leach field deeper.
In a properly functioning septic system, organic nitrogen excreted by humans flows in wastewater
into the septic tank. The organic nitrogen in the wastewater is converted to ammonia by micro-
organisms in the septic tank. Ammonia is the primary form of nitrogen in wastewater leaving the
septic tank (Seiler 1996; EPA 2002). In the presence of oxygen, indigenous bacteria in the unsaturated
zone will transform the ammonia in the wastewater into nitrate. Anchor QEA believes that burying
the drain lines deeper reduced the availability of oxygen, which resulted in ammonia not being
reduced to nitrite and nitrate. Ammonia in the wastewater likely passed through the unsaturated
zone and infiltrated into the groundwater causing ammonia to exceed the 2L groundwater
standards. The lack of oxygen beneath the septic drain lines may also promote denitrifying bacteria
to begin using manganese and iron oxides for their oxygen source during the denitrification process,
thus mobilizing manganese and iron in the process. Manganese is highest in monitoring well MW-6,
suggesting that denitrification is occurring in this location through the respiration of manganese
oxides. The order of reactions for respiration of denitrifying microbes is aerobic respiration,
denitrification, manganese reduction, iron reduction, then sulfate reduction (Seiler 1996).
Lines of Evidence to Suggest the Septic Field Source is the Primary Contributor to the 2L
Groundwater Standard Violations in Groundwater from Monitoring Well MW-2
1.Monitoring well MW-2 had high concentrations of ammonia (28,800 µg/L), iron (640 to
16,700 µg/L), and manganese (8,460 µg/L).
2.Based on recently collected data, ammonia concentrations in pond samples are not typically
greater than 7,000 µg/L; iron concentrations are generally less than 4,500 µg/L, and manganese
concentrations are generally less than 57 µg/L.
Notice of Violation and
Notice of Intent to Enforce Response16 June 2018

3.Historical effluent data from 2001 to 2017 suggests that the aeration of the pond appropriately
treats ammonia, reducing its concentration to less than laboratory reporting limits or trace
amounts.
4.Historical groundwater monitoring data indicates that VOCs have been observed in monitoring
well MW-2 in the past, and recent samples show VOCs to be present in trace amounts less than
the 2L groundwater standards. This suggests potential influence from the septic system, since
the facility sinks and the trace amounts of VOCs present in household chemicals placed into
them drain to the septic system.
5.Ammonia concentrations in the downstream ditch sample collected in December 2017 were
about 4,500 µg/L and non-detect in upstream ditch samples, suggesting that septic effluent may
have affected the water in the ditch.
6.Ammonia concentrations in the April 2018 downstream ditch sample and the sample collected
at the ditch embankment breach were 190 and 110 µg/L, respectively. This represents greater
than an order of magnitude reduction since December 2017, when the septic system wastewater
began to be managed by pump and haul to off-site treatment.
7.Dissolved oxygen, pH, phosphorus, and ammonia are significantly different in the pond samples
as compared to samples from monitoring well MW-2. If the pond was very leaky, constituent
concentrations would likely be similar.
8.Other site monitoring wells show influence from spray application of wastewater, but samples
from those wells do not have ammonia concentrations like monitoring well MW-2.
9.The newly installed monitoring well, MW-6, located adjacent to the downgradient side of the
septic drain field, was sampled in April 2018, and concentrations of ammonia were detected.
Septic systems are designed to convert ammonia to nitrogen through biologic activity, and if
they are not functioning correctly, ammonia will go untreated and potentially impact
groundwater.
10.Pure ammonia is caustic, with pH of 11. Continued input of ammonia into the groundwater
system may increase groundwater pH; the pH in samples from monitoring well MW-2 have been
increasing for many years, and the pH in samples from monitoring well MW-1, which is
upgradient of the pond, has remained relatively the same over the same time period.
Notice of Violation and
Notice of Intent to Enforce Response17 June 2018

6Conclusions and Recommendations
The DEQ requested that AllJuice assess the cause, significance, and extent of the violation of the 2L
groundwater standards and submit the results of the investigation along with a plan and proposed
schedule for corrective action.
6.1Cause
Based on the data presented in this report, Anchor QEA believes that the 2L groundwater standard
violations observed in the samples collected from monitoring well MW-2 are due to an improperly
functioning septic system.
6.2Significance and Extent
The source area for the elevated concentrations has been identified as a failed septic drain field,
which lies on a groundwater migration pathway flowing from east to west. By applying an
understanding of groundwater movement, Anchor QEA surmises that the extent of impacts to
groundwater are very likely limited to the area between the septic drain field (area of recharge) and
the tributary of Wolfpen Creek (area of discharge).
6.3Corrective Action
AllJuice is having the on-site septic system drain field replaced (anticipated completion is late
August, 2018) and has mitigated the potential impact of the septic system on the groundwater
resource by pumping and hauling its sanitary wastewater to an off-site sanitary wastewater facility.
Since taking these actions, concentrations of ammonia observed in ditch water samples have
reduced significantly. Furthermore, the nearest water supply well is more than 500 feet from
monitoring well MW-2 and separated from the septic system source area by the tributary of Wolfpen
Creek. Natural attenuation factors will reduce the impacts quickly in the downgradient direction of
the septic system now that the drain field is being replaced. In the opinion of Anchor QEA, corrective
action is likely complete.
Additional monitoring wells are not required to further define the extent. Groundwater samples
should be collected from monitoring wells MW-2 and MW-6 routinely as required by the permit to
monitor the change in groundwater conditions now that the septic system has been replaced.
Anchor QEA recommends the following actions:
1.Include the collection of groundwater samples from monitoring wells MW-5 and MW-6 with the
sampling schedule defined in the 2017 permit for monitoring wells MW-1, MW-2, and MW-3.
During low-flow sampling, do not collect groundwater samples for analysis until the
groundwater extracted from the wells has a turbidity of 10 NTUs and field parameters
(temperature, dissolved oxygen, ORP, pH, and specific conductivity) have stabilized.
Notice of Violation and
Notice of Intent to Enforce Response18 June 2018

2.Continue pumping and hauling septic waste until new septic systems is installed and then
abandon the existing septic field.
3.Continue operation of the wastewater treatment pond in accordance with the permit conditions.
4.Hire a company specializing in wastewater spray irrigation to evaluate the treatment system, and
spray fields to optimize the treatment system and spray application operation.
Notice of Violation and
Notice of Intent to Enforce Response19 June 2018

7References
Anchor QEA (Anchor QEA of North Carolina, PLLC), 2017. Work Plan to Address the Requirements of
the Notice of Violation and Notice of Intent to Enforce. Prepared for Mr. Brett Laverty, North
Carolina Department of Environmental Quality, November 15, 2017.
North Carolina Department of Environmental Quality, 2017. Notice of Violation and Notice of Intent to
Enforce. October 10, 2017, Permit No. WQ0004967
North Carolina Department of Environmental Quality, 2017. Permit No. WQ0004967, AllJuice WWTF,
Wastewater Irrigation System, Henderson County. April 27, 2017.
North Carolina Division of Water Quality, 2011. Hydrogeology and Water Quality at Bent Creek
Research Station, Buncombe County, North Carolina, 2002-2009.
EPA (U.S. Environmental Protection Agency), 2002. Onsite Wastewater Treatment Systems Manual.
EPA/625/R-00/008. Office of Water, Office of Research and Development. February 2002.
Seiler, R.L., 1996. Methods for Identifying Sources of Nitrogen Contamination of Ground Water in
Valleys in Washoe County, Nevada. Open File Report 96-461. U.S. Geological Survey.
Prepared in cooperation with the Washoe County Department of Comprehensive Planning.
Carson City, Nevada. 1996.
Notice of Violation and
Notice of Intent to Enforce Response20 June 2018

Figures

SOURCES:
LEGEND:
1.Basemap: US Geological Survey Topographic Maps,
Site Boundary
Hendersonville Quadrangle, 1997.
\[
2.Site Boundary: Henderson County GIS, 2016
04,000
Feet
Publish Date: 2018/05/29, 4:49 PM | User: cpippin
Filepath: A:\\GIS_Projects\\AllJuice\\MXD\\ReportFigures\\AQ_Fig01_AllJuice_SiteLocationMap.mxd
Figure 1
Site Location Map
Notice of Violation and Notice of Intent to Enforce Response
AllJuice Realty, LLC, Hendersonville, North Carolina

2
2
0
0
MW-5 (Background)
!
U
MW-3
!
U
MW-1 (Former Background)
!
U
Ditch Embankment
Treatment Pond
Breach
Plant Wastewater Discharge
#*
Sump with Screen
kj
Aerator

MW-6
Location
!U
kj
MW-2
!U
AllJuice
Facility
Pump House for Treatment Pond
Effluent Transfer to Spray Field
Ditch
Above Ground Storage
Tank with Containing Wall
Former Well House
SOURCES:
LEGEND:
1. Aerial Imagery: NC OneMap, 2015
Spray Field Application Area
Monitoring Well Location
2. Topographic Contours: NCDOT Lidar, 2007
!U
Site Boundary
Stream
%
Drainage Ditch
Topographic Contours (2-Foot Interval)
Aerated Lagoon
Former Well House
\[
Septic System and Drain Field
0300
Site Building
Feet
Publish Date: 2018/06/01, 11:50 AM | User: cpippin
Filepath: A:\\GIS_Projects\\AllJuice\\MXD\\ReportFigures\\AQ_Fig02_AllJuice_SiteFeaturesMap.mxd
Figure 2
Site Features Map
Notice of Violation and Notice of Intent to Enforce Response
AllJuice Realty, LLC, Hendersonville, North Carolina

2
2
0
0
MW-5 (Background)
!
U
Effluent (EFF)
MW-3
!
U
MW-1 (Former Background)
!
U
Ditch Embankment
Treatment Pond
Breach
D-1
!(
Plant Wastewater Discharge
3-A, B
!(
#*
Sump with Screen
Pond 1 & Pond FC
!(
D-4
!(
kj
Aerator
2-A, B
!(

MW-6
Location
!U
kj
Influent (INF)
MW-2
!U
AllJuice
1-A, B
!(
Facility
D-2
!(
Pump House for Treatment Pond
Effluent Transfer to Spray Field
Ditch
Above Ground Storage
Tank with Containing Wall
Former Well House
D-3
!(
SOURCES:
LEGEND:
1.Aerial Imagery: NC OneMap, 2015
Aerated Lagoon
Monitoring Well Location
2.Topographic Contours: NCDOT Lidar, 2007
!U
Former Well House
Ditch Sample Location
!(
Septic System and Drain Field
!(Lagoon Sample Location
Site Building
Effluent (EFF)
"
T
Spray Field Application Area
Influent (INF)
"
T
Site Boundary
Stream
\[
%
Drainage Ditch
0300
Topographic Contours (2-Foot Interval)
Feet
Publish Date: 2018/06/01, 10:53 AM | User: cpippin
Filepath: A:\\GIS_Projects\\AllJuice\\MXD\\ReportFigures\\AQ_Fig03_AllJuice_SampleLocationMap.mxd
Figure 3
Sample Location Map
Notice of Violation and Notice of Intent to Enforce Response
AllJuice Realty, LLC, Hendersonville, North Carolina

2200
i
2
i
1

0
0
2
2
0
8
1
2
%
0
8
1
2

pH vs. Time
В͵Љ
Б͵Љ
А͵Љ
Џ͵Љ
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Ѝ͵Љ
Ќ͵Љ
ЊВБЋЊВБЏЊВВЊЊВВЏЋЉЉЊЋЉЉЏЋЉЊЊЋЉЊЏЋЉЋЊ
a‘ΏЊa‘ΏЋa‘ΏЌ
pH in MW-2 has been increasing since around 1997
pH in MW-1 and MW-3 has remained relatively constant
Treatment pond receives citrus wastewater and has acidic pH
MW-2 pH would be expected to become more acidic if influenced by the treatment pond
Pure ammonia is caustic with pH of 11, continued input of ammonia into the groundwater
system from the failed septic system may increase groundwater pH. The pH in samples from
MW-2 have been increasing for many years, and the pH in samples from MW-1 and MW-3
which are upgradient of the lagoon, have remained relatively the same over the same time
period.
Filepath: A:\\Projects\\AllJuice\\Reports\\Figures\\Figure 8 pH MW-1 MW-2 Trend_resived.docx
Figure 8
pH Trends for MW-1, MW-2, and MW-3
Notice of Violation and Notice of Intent to Enforce Response
AllJuice Realty, LLC, Hendersonville, North Carolina

9
Figure
2 should
e, North Carolina

-
AllJuice Realty, LLC, Hendersonvill
Summary of Wastewater Interaction with Groundwater
Notice of Violation and Notice of Intent to Enforce Response
volatilizes to the atmosphere in the septic tank and drain lines.

3

). The NH
3

unctioning appropriately and allowed discharge of ammonia to the groundwater
) to nitrogen (N), N then volatilizes through continued aeration. The remaining
3
2 are a result from leakage from the treatment lagoon, then samples from MW
-
he septic field. Testing of water from the ditch suggests that the water is from the septic
d agronomic uptake.
) to ammonia (NH
4
) to nitrate (NO
3
mples from MW
a

tion of ditch water into soils may impact groundwater quality.

er from ditch.
2.6.
--

during Site investigation, Anchor QEA noticed a breach in the ditch embankment near the northern end of t

–
is reduced through denitrification processes to nitrogen gas (N) . Anchor QEA believes that the septic drain field was not f

3
section.docx
-
receives sanitary wastewater effluent from septic tank, within the septic tank bacteria work to convert ammonium (NH
receives influent (2) from juice plant, treats effluent through aeration and bioreaction to breakdown ammonia (NH

receives storm water runoff from spray fields and septic effluent (7). Infiltra–
–

–
receives effluent from treatment pond by spraying on to fields and assimilates remaining wastes through evapotranspiration an

Figure 9 cross
\\
–
Archive
h infiltration (6) and to the ditch through lateral migration (7).
\\
Figures
\\
Influent from juice plant enters pond through discharge pipe from facility. Treatment Pond waste water is discharged to spray field. Spray field Drainage ditch Septic Drainfield Once
in the drainlines, infiltration of the septic waste proceeds into the soils, during this process the remaining NH4 is converted to nitrite (NO2) and then to nitrate (NO3). As the septic
waste further infiltrates the soil column and groundwater system as NOthrougInfiltration of septic effluent into soils. Septic effluent discharged to ditch drainfield based on ammonia
content. Assumed flow path of infiltration from treatment lagoon. If the observed concentrations of ammonia, iron, and manganese in sbe low in ammonia, high in dissolved oxygen, have
a pH that is low, and have higher concentrations of phosphorus. Assumed flow path from infiltration of watAssumed flow path from infiltration of septic effluent.Screened interval of
monitoring well MWScreened interval of monitoring well MWDowngradient stream (discharge point for shallow groundwater).
Reports
\\
1.2.3.4.5.6.7.8.9.10.11.12.13.
AllJuice
P:\\
Filepath:

Filepath: P:\\AllJuice\\Reports\\Figures\\Figure X Ammonia.docx
Figure 10
Annual Average Effluent Concentration for Ammonia
Notice of Violation and Notice of Intent to Enforce Response
AllJuice Realty, LLC, Hendersonville, North Carolina

Tables

Table 1
Well Construction
Construction Details
Casing DiameterBoring Depth Screen Interval Screen Length
Monitoring Installation
(inches)(ft-bgs)(ft-bgs)(feet)
WellDate
MW-103/01/198725045 to 505
40 to 455
MW-203/01/1987245
MW-303/01/198722520 to 255
Abandoned
MW-406/19/2008
MW-511/29/201728560 to 8020
23 to 3815
MW-604/02/2018238
Notes:
Construction Details obtained from a table of well construction details provided by the North Carolina Department of Environmental Quality
for monitoring wells MW-1, MW-2, MW-3, and MW-4. Construction details for monitoring wells MW-5 and MW-6 are based on the boring
log and well construction forms provided in Appendix C.
ft-bgs: feet below ground surface
Notice of Violation and Notice of Intent to Enforce Response
Page 1 of 1
AllJuice Realty, LLC, Hendersonville, North Carolina

Table 2
Field Parameter Measurement Prior to Sample Collection
Aproximate Sample Specific
Depth Collection Temperature Conductivity DO ORP Turbidity
Name(ft-bls)Date(°C)(µ S/cm)(mg/L)pH (SU)(mV)(NTU)
MW-1 4612/13/1713.0061.66.964.81459.37.0
4312/14/178.50651.01.196.6118.59.60
MW-2
4301/12/1814.50642.00.666.5021.14.13
4304/05/1818.60635.02.136.93131.03.13
MW-3 2312/13/175.4061.65.855.04292.18.0
7212/13/1711.3044.29.605.23417.08.2
MW-5
7504/05/1813.3071.010.926.33314.93.1
MW-6 3404/05/1814.90279.80.365.10122.06.28
Lagoon 1-A 0.512/21/179.80585.06.203.94--OR
Lagoon 1-B 312/21/179.24565.06.353.91--OR
Lagoon 2-A 0.512/21/179.40572.07.613.88--992
Lagoon 2-B 312/21/179.46577.06.303.86--997
Lagoon 3-A 0.512/21/179.16579.06.793.87--OR
Lagoon 3-B 312/21/179.16580.05.953.85--OR
INF Surface12/21/1729.37133.05.056.53--97.5
EFF Surface12/21/179.18550.09.913.95--980.0
D-1 Surface12/21/177.86337.03.145.58--OR
D-1.2 Surface04/24/1814.20402.53.776.55117.3315.00
D-2 Surface12/21/177.88300.04.016.40--92.0
D-2.2 Surface04/26/1814.8257.57.156.6085.9238.0
D-3 Surface04/26/1813.7091.36.016.36175.696.3
D-4 Surface04/26/1814.80403.73.006.87195.7279.0
Pond-FC Surface12/14/172.22536.06.064.48283.0850.0
Pond-1 Surface04/05/1819.10515.97.597.78196.4601.0
Notes:
--: indicates that the ORP probe did not calibrate correctly and no measurement was taken
µS/cm: microsiemens per centimeter
DO: dissolved oxygen
feet-bls: feet below land surface
mg/L: milligrams per liter
mV: millivolts
NA: not applicable
NTU: nephelometric turbidity units
OR: over range
ORP: oxidation reduction potential
SU: Standard Unit
Notice of Violation and Notice of Intent to Enforce Response
Page 1 of 1
AllJuice Realty, LLC, Hendersonville, North Carolina

xxxxx
------
----
Page 1 of 1
Ditch
04/28/2018
xxxxx
----------
MW-6
04/05/2018
MW-2, MW-5,
xxxxx
----------
Effluent
xxxxx
----------
Influent
Sample Dates
Sample Points
xxxxx
----------
12/21/2017
Ditch
1
xxxxx
--------
x
Pond
Treatment
1
xxxxxx
------
x
12/14/2017
MW-3, MW-5
MW-1, MW-2,
12/13/2017 and
pH by SM 4500
Analytical Suite
SM 2540D, respectively
EPA Method 200.7/6010
VOCs by EPA Method 8260
Alkalinity by EPA Method 2320B
Total dissolved solids by SM 2540C
Fecal coliform bacteria by SM 9222D
phosphorous) by EPA Methods 350.1, 353.2, 351.2, and 365.1
Metals (iron, manganese, and sodium) by EPA Method 200.7/6010
Total dissolved solids and total suspended solids by SM 2540C and
Nutrients (ammonia, nitrate, nitrite, total Kjeldahl nitrogen, and total
SM 2320B, SM 5210B, and EPA Method 410.4/SM 5220D, respectively
Other (sulfate, chloride, alkalinity, BOD, and COD) by EPA Method 300.0,
Metals (iron, manganese, calcium, magnesium, potassium, and sodium) by
Notes:1.MW-2 and one sample from treatment lagoon analyzed for fecal coliform.--: indicates a specific analysis was not used at a specific sample pointEPA: U.S. Environmental Protection
AgencySM: Standard MethodVOC: volatile organic compoundx: indicates a sample point was analyzed for a particular constituent
Table 3List of Analytical Methods Notice of Violation and Notice of Intent to Enforce ResponseAllJuice Realty, LLC, Hendersonville, North Carolina

Table 4
Groundwater Elevation
Depth to Ground Surface Top of Casing Groundwater
Monitoring Installation Water Stickup ElevationElevationElevation
WellDate(ft-btoc)(ft-ags)(ft-msl)(ft-msl)(ft-msl)
MW-1Dec-1746.011.662,1992,200.662,154.65
16.211.762,1752,176.762,160.55
MW-2Dec-17
MW-2Jan-1816.071.762,1752,176.762,160.69
15.601.762,1752,176.762,161.16
MW-2Apr-18
MW-3Dec-1717.121.422,1742,175.422,158.30
52.572.372,2182,220.372,167.80
MW-5Dec-17
MW-5Apr-1851.902.372,2182,220.372,168.47
25.932.622,1852,187.622,161.69
MW-6Apr-18
Notes:
Ground surface elevation at each well location is based on the digital elevation model developed by the North Carolina Floodplain Mapping
program.
Groundwater elevation calculated using the depth to water below the top of casing and the height of the casing above ground surface.
ft-ags: feet above ground surface
ft-bgs: feet below ground surface
ft-btoc: feet below top of casing
ft-msl: feet above mean sea level
Notice of Violation and Notice of Intent to Enforce Response
Page 1 of 1
AllJuice Realty, LLC, Hendersonville, North Carolina

Page 1 of1
NANANANA
408<25
20 J
440 J
1,3001,3002,2801,3502,800
MW-6
3950 J
23,10023,10023,10024,90020,30029,00012,30012,100
157,000
04/05/2018
NANANANANANA
<50<10<10<10<10
<2.5
EB-1
<250<500
<25.0<0.96<0.26<0.23
<5,000<2,000<0.025
<25,000<12,500
12/13/2017
929292
NANANANA
874
<50<10<25
76.829.9
<250<500
7,4004,600
<2,000
37,00027,200
3,530 J2,760 J
<12,500
04/05/2018
MW-5
848484
NANANANANANA
<50<10 129
25 J
22.7
<250
<0.96<0.26<0.23 4,800
<2,000
29,000
2,740 J
<12,500
12/13/2017
NANANANANANA
<50<10
32 J
65.624.9
<250
5,2005,2005,200<0.96<0.26<0.23
MW-3
<2,000
11,60048,00010,000
<12,500
12/13/2017
NANANANANANANANANANANANANANANANANA
1,4607,6201,5701,920
14,300
75,400
DUP-1 (2)
04/05/2018
COD: chemical oxygen demandJ value indicates a constituent was detected above the associated method detection limit but below the associated practical quantitation level (PQL).mL: milliliterNA:
a particular constituent was not analyzedTDS: total dissolved solidsTKN: total Kjeldahl nitrogen Total nitrogen: the sum of TKN and Nitrate-Nitrite. Anchor QEA calculated the total
nitrogen values for groundwater samples.VOC: volatile organic compound
25
NANANANA
420440
<50
610 J
1,5107,6901,5701,910
32,60030,14529,70014,00012,70025,100
73,000
213,000294,000
21,000 J
04/05/2018
MW-2
23
NANANANANA
<10<10
31 J
0.0 J1.9 J
6,5708,090<0.23
0.35 J
<2,000
30,70034,22334,20072,00025,100
217,000
24,000 J
12/14/2017
91
NANANANANANA
<50
<10
32 J
13.5
<250 2400
2,4002,400<0.96<0.26<0.23 5,800
DUP-1<2,000
41,000
4,930 J
<12,500
12/13/2017
NANANANANANA
<50<10 126<25
14.5
<250
<0.96<0.26<0.23
2,3002,3002,3005,800
MW-1
<2,000
53,000
4,960 J
<12,500
12/13/2017
----------------------
50
300600500
Sample ID
1,0004,000
1,500*
10,000
250,000500,000250,000
Sample Date 1/100 mL
2L Standards
µg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/L
Units
(CFU/100 mL)
NitrateNitriteNO2 plus NO3IronManganeseSodiumCalciumMagnesiumPotassium2-ButanoneTolueneo-Xylene
: indicates a constituent exceeded the North Carolina Administrative Code (NCAC) Title 15A, Subchapter 02L .0202 Groundwater Quality Standards (2L Standards), effective April 1, 2013

Constituents
indicates that a constituent was detected above the method detection limit
: Upon confirmation with the laboratory, this value is considered non-detect.
indicates that pH readings were taken from field measurements
Fecal ColiformAmmonia NitrogenTotal NitrogenTKNNitrogenSulfateMetalsVOCs Low LevelTDSBODCODPhosphorusChlorideAlkalinity
Notes:Bold:*: indicates that a 2L Standard is not established for a particular constituent and the interim maximum allowable concentration (IMAC) value was used--: indicates that a particular
standard has not been established for a certain constituentµg/L: micrograms per liter 0.0 J 1/100 mL: 1 CFU per 100 millilitersBOD: biological oxygen demand CFU: colony forming units

Table 5Groundwater Analytical Results Summary Notice of Violation and Notice of Intent to Enforce ResponseAllJuice Realty, LLC, Hendersonville, North Carolina

Page 1 of 1
46
NANANANANA
110<10 140180
D-4
6.87†
750 J
8,7003,7903,100
28,70028,70053,90010,10046,40039,100
Breach
700,000654,000127,000
1,440,000
04/26/2018
Embankment
30
NANANANANA
<10 808330
D-3
<5017 J
53.5
6.36†
940 J
1,2001,2005,9003,000
Ditch8,100
12,50031,700
4,660 J
563,000105,000
<125,000
Boundary
04/26/2018
31
NANANANANA
190<10 780
12 J
6.60†
560 J
4,0004,0007,5101,790
D-2.28,7801,790
34,00028,50084,60021,200
265,000263,000106,000
04/26/2018
South Ditch
NANANANANANANA
6.3 NANA
<50<50 165560
D-2<50
6,200
4,1006,2008,820
28,20059,00069,200
31,300
268,000212,000
12/21/2017
29
NANA
NANANA
<10 130174
58 J
6.55†920 J
3,6001,700
5,3409,770
D-1.2
13,70013,70052,90045,200
39,800
670,000391,000
106,000
1,260,000
04/26/2018
North Ditch
NANANA
5.8 NANANANANANA
<50<50<50 337
<50
D-1
4,600
34,700
34,70021,80030,00026,500
333,000
272,000792,000
1,510,000
12/21/2017
NANANA
3.8 NANANANANANA
EFF<50<50
<50<50
89.4
4,400
Pond 6,960
41,400
41,40077,10061,400
890,000
Effluent
1,300,0001,650,0004,860,000
12/21/2017
NANA
6.0 NANA 7.9 NANANANANA
220220450
INF<50<50 496
Pond 1,3001,1009,7009,500
16,100
518,000
Influent
1,060,0001,080,000
12/21/2017
40
NANANANANA
210
<50<10
36.2
<500
7.78†
2,6603,7101,6702,000
16,61016,40069,80058,70053,600
Pond-1
490,000614,000107,000
2,340,000
04/05/2018
3.8 NANANANANANANANANA
<50<50<50<50
62.2
4,6403,600
30,80030,80075,90061,100
1,500,0001,100,0001,640,0004,280,000
Lagoon 3-B
12/21/2017
NANANANANANANANANA
3.8
<50<50<50<50
60.5
3,7703,600
30,60030,60077,90060,600
1,610,0001,160,0001,530,0004,300,000
Lagoon 3-A
12/21/2017
NANANANANANANANANA
3.8
<50<50<50<50
58.7
4,0603,900
36,00036,00072,20060,600
1,400,0001,220,0001,470,0004,130,000
Lagoon 2-B
12/21/2017
mL: milliliterNA: a particular constituent was not analyzedTDS: total dissolved solidsTKN: total Kjeldahl nitrogen by EPA Method 351.2Total nitrogen: the sum of TKN and Nitrate-Nitrite.
Anchor QEA calculated the total nitrogen values for groundwater samples.TSS: total suspended solidsVOC: volatile organic compound
Pond
NANANANANANANANANA
3.8
<50<50<50<50
60.2
3,900
4,250
28,80028,80076,80058,800
1,080,0001,580,0001,560,0004,130,000
Lagoon 2-A12/21/2017
NANANANANANANA
3.8 NANA
<50<50<50
<50
64.3
3,600
4,860
30,90030,90078,300
62,100
1,280,0001,540,0001,580,0003,160,000
Lagoon 1-B
12/21/2017
esults
R
NANANANANANA
3.8 NANANA
<50<50<50
<50
59.4
3,900
4,240
32,60032,60073,900
60,600
920,000
1,350,0001,660,0002,950,000
nalytical
Lagoon 1-A12/21/2017
A
ater
NANANANANANANANANANANANANANANANA
NANANANANANANANA
W
29.0
Pond-FC
12/14/2017
itch
D
nd
a
Sample ID
µg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/L
µg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/L
Units
Sample Date
nfluent
(CFU/100 mL)
Standard Units
I
Sample Location
ffluent,
E
NitrateNitriteNO2 plus NO3MagnesiumPotassium2-Butanone
IronManganeseSodiumCalciumTolueneo-Xylene
Constituents
6
indicates that a constituent was detected above the method detection limit
indicates that pH readings were taken from field measurements
g/L: micrograms per liter
ummary
pHFecal ColiformAmmonia NitrogenTotal NitrogenTKNNitrogenSulfateMetalsVOCs Low LevelTDSTSSBODCODPhosphorusChlorideAlkalinity
Notes:Bold: µ BOD: biological oxygen demandCFU: colony forming unitsCOD: chemical oxygen demandJ value indicates a constituent was detected above the associated method detection limit
but below the associated practical quantitation level (PQL)
TableTreatment Pond,S Notice of Violation and Notice of Intent to Enforce ResponseAllJuice Realty, LLC, Hendersonville, North Carolina

Attachment J – Civil Penalties and Violations
Notice of Violations issues since 2017 Permit and Response Actions
Summary of Requirements
The DEQ issued a Notice of Violation and Notice of Intent The following reports were submitted in
to Enforce (NOV-NIE) on October 15, 2017. The NOV-NIE response to this NOV:
requirements are summarized as follows:
Notice of Violation and Notice of
Violation 1 – Permit Condition Violation (NOV-2017-Intent to Enforce Response, (Anchor
PC-0649): The existing background monitoring wellQEA, June 2018)
MW-1 is often dry. As part of the April 2017 permit, the
following conditions were outlined and not completed:
Replace the background monitoring well by July
2017.
Update the site map with the location of the new
background well.
Violation 2 – Violation of 2L groundwater standards
(NOV-2017-LV-0672, NOV-2017-LV-0673, NOV-2017-
LV-0674, and NOV-2017-LV-0675): Analytical results of
compliance monitoring samples collected from
monitoring well MW-2 indicate concentrations of total
iron, total manganese, and ammonia that exceed their
respective 2L groundwater standards.
The DEQ issued the“Review of the Notice of Violation and The following reports were submitted in
Notice of Intent to Enforce Response Report and Required response to outlined corrective
Corrective Action Measures” letter dated March 5, 2019. measures:
This notice required the following corrective measures:
Corrective Action Assessment
Report, (Anchor QEA, April 2020)
Off-Site Stream Assessment and Pipe
1.Assess the process wastewater (irrigation) lagoon
Inspection Results, (Anchor QEA,
and determine a course of action to permanently
September 9, 2020)
abate the wastewater discharges responsible for
exceedances of the groundwater standards at MW-
2.Submit a plan to assess the extent of groundwater
impacts on an adjoining private parcel immediately
west of the lagoon. Determine whether these
groundwater impacts pose a risk to nearby
Wolfpen Creek.
3.Install four additional groundwater monitoring
wells in support of the compliance monitoring
surrounding the lagoon and the spray irrigation
field. These wells will be added to the compliance
schedule for sampling wells in March, July, and
November of each year for the groundwater
parameters listed in the permit.

Notice of Violations issues since 2017 Permit and Response Actions
Summary of Requirements
4. Submit a plan to assess the boundary ditch to
evaluate the relative contributions of process
and/or domestic wastewater entering the ditch and
determine a course of action to permanently abate
all wastewater discharges. The plan should include
a regular monitoring schedule at the confluence of
the boundary ditch with Wolfpen Creek with a goal
of assessing baseflow conditions and periods of
storm runoff. Monitoring parameters will include
fecal coliform bacteria, boron, chloride, BOD,
chemical oxygen demand (COD), total suspended
solids (TSS), total nitrogen, ammonia, nitrate,
nitrite, TKN, and phosphorus.
5. Conduct an agronomic study of the spray irrigation
field, evaluate its capacity to assimilate process
wastewater and to treat and assimilate nitrogen,
determine why elevated concentrations of nitrate
are present in some downgradient wells, evaluate
the cover crop, and submit a plan to inhibit weed
growth.

The DEQ issued a Notice of Violation (NOV) dated March 1, The following reports were submitted in
2021. The NOV is based on the January 26, 2021 inspection response to this NOV:
performed by the North Carolina Division of Water
Response to Requirements of the
Resources (DWR), which identified numerous weeds and
March 1, 2021, Notice of Violation
moisture-tolerant grasses present in the irrigation field. This
(Anchor QEA, March 31, 2021)
observation was found to be non-compliant with
Summary of Sodium Concentration
wastewater irrigation system permit (Permit No.
Data (Anchor QEA, June 25, 2021)
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.

Review of the Notice of Violation and Notice of Intent to
Enforce Response Report and Required Corrective Action Measures

Notice of Violation and Notice of Intent to Enforce
Notice of
Violation and Notice of Intent to Enforce Response.

ie
×
=
i
i

5.2.1Groundwater Conditions Around the Treatment Pond

5.2.2Groundwater Concentrations at Compliance Boundary Wells

Notice of Violation and Notice of
Intent to Enforce Response.
Permit No. WQ0004967, AllJuice
WWTF, Wastewater Irrigation System, Henderson County
Notice of Violation and Notice of Intent to Enforce.
.
.

Review of the Notice of Violation and Notice of Intent to Enforce Response Report and
Required Corrective Action Measures.
Hydrogeology and Water Quality at Bent Creek
Research Station, Buncombe County, North Carolina, 2002-2009.
Onsite Wastewater Treatment Systems Manual.
Determining Hydraulic Conductivity Using
Pumping Data from Low-Flow Sampling,

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Anchor QEA of North Carolina, PLLC
231 Haywood Street
Asheville, North Carolina 28801
828.281.3350
September 9, 2020
Brett Laverty
Hydrogeologist – Asheville Regional Office
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
2090 US Highway 70
Swannanoa, NC 28778
Re: Off-Site Stream Assessment and Pipe Inspection Results
AllJuice Facility
352 Jet Street
Hendersonville, North Carolina 28792
Dear Brett,
This letter summarizes Anchor QEA’s findings and conclusions based on an off-site stream
assessment and pipe inspection performed at the AllJuice Realty, LLC (AllJuice), facility in
Hendersonville, NC. The pipe inspection was performed on February 25, 2020; its purpose was to
evaluate the source for fecal coliform found in the wastewater treatment system’s irrigation holding
pond. The off-site stream assessment was performed on June 23, 2020. Anchor QEA collected off-site
stream data to evaluate potential off-site impacts from groundwater with elevated ammonia and
metal concentrations. This work was completed to fulfill two of the recommendations listed in the
Corrective Action Assessment Report, which was submitted to the North Carolina Department of
Environmental Quality (DEQ) in April 2020 in response to DEQ’s March 5, 2019 letter regarding:
Review of the Notice of Violation and Notice of Intent to Enforce Response Report and Required
Corrective Action Measures (DEQ 2019). The information below outlines the process and findings of
this work.
Pipe Inspection
AllJuice contracted directly with Summey Plumbing to perform an inspection of the pipe that
conveys wastewater from the facility to the irrigation pond. A pipe camera was routed through the
pipe and recorded its integrity. Observation of the video indicated a pipe repair zone at the
approximate vicinity of the former septic tank. The video shows a section of green PVC pipe that has
been damaged with an outer black corrugated plastic pipe (Figure 1). Sample resulted presented in
the CAAR, showed that water entering the wastewater conveyance pipe is free of fecal coliform
bacteria; however, samples collected from discharge into the irrigation pond show elevated
concentrations of fecal coliform. The repaired section of pipe and its proximity to the former septic
\\\\ASHEVILLE1\\Asheville\\Projects\\AllJuice\\190305 - Request for CAP from DEQ\\Surface Water Sampling\\Memorandum\\Working Documents\\Senior Review\\2020-0714-AllJuice-
Off Site Stream Assessment and Pipe Inspection.docx

September 9, 2020
Page 2
system suggests that this is the source for the fecal coliform observed in the irrigation pond. The
location of the repaired pipe is shown in Figure 2.
Surface Water Sampling
The off-site tributary to Wolfpen Creekreceives stormwater flow from the AllJuice facility,conveyed
by an incised drainage ditch. The drainage ditch discharges into the tributary upstream from a small
farm pond (Figure 2). The triburtary is dammed in two locations, forming two farm ponds. The
upstream pond, which is surrounded by an orchard, appears to be located near the headwater spring
that feeds into the tributary. Approximately 320 feet downstream from this pond is the outfall for the
drainage ditch conveying stormwater from the AllJuice facility. Approximately 90 feet downstream
from the outfall is a second farm pond, which discharges into the tributary and flows northwest for
approximately 1,700 feet to the confluence with Wolfpen Creek. The tributary transects property
owned by Michael Brown, part of which is an active cattle farm.
The tributary to Wolfpen Creek is the groundwater discharge zone for the valley it defines. The goal
of the surface water sampling program is to evaluate the potential impacts to surface water quality
from groundwater migrating from the western boundary of the AllJuice facility. Anchor QEA referred
to the groundwater potentiometric surface map, provided in the CAAR, to identify surface water
sampling locations. Three locations were selected from areas of the tributary that were more likely to
be under the influence of groundwater flow contributions from the AllJuice facility based on
potential groundwater flow lines. Three other locations were selected from the upstream tributary
reach that connects the two farm ponds; one sample was collected downstream of the stormwater
ditch outfall and two samples were collected upstream of the stormwater ditch outfall. A final sample
was collected from the drainage ditch prior to where it discharges to the tributary. See Figure 2 for
the sample locations.
With the assistance of Brett Laverty with DEQ, Anchor QEA contacted the adjacent property owner,
Mr. Michael Brown, and obtained permission to enter his property to collect the surface water
samples.
On the afternoon of June 23, 2020, Anchor QEA staff mobilized to site to collect six samples
(SS-1 to SS-6) from the Brown property and one sample from the ditch located on AllJuice property
(DITCH-6). All off-site sample locations were collected as grab samples from the flowing tributary.
DITCH-6, the on-site location, was collected from a stagnant pool of water within the ditch because
the ditch was not flowing at the time of collection.
Parameters were collected for each sample using a YSI Pro Plus Multiparameter instrument. All grab
samples were placed in laboratory bottles, immediately stored on ice, and dropped off at Pace
Analytical, a North Carolina certified lab, later that day for analysis. A field duplicate sample was
collected at location SS-2 to serve as a quality control sample. All samples were submitted for

September 9, 2020
Page 3
analysis of ammonia, Total Kjeldahl Nitrogen, nitrate/nitrite, phosphorus, total alkalinity, sulfate,
chloride, calcium, iron, magnesium, manganese, potassium, sodium and fecal coliform. Analytical
results and field parameters are summarized in Table 1. Field forms and an equipment calibration log
are included in Attachment 1.
Analysis Summary
The stream samples have been grouped into two groups. Group 1 includes sample locations that are
positioned upgradient of the potential discharge of groundwater from the AllJuice facility (SS-1,
SS-2, and SS-3). Group 2 includes sample locations that are positioned in the zone of potential
groundwater discharge from the AllJuice facility (SS-4, SS-5, and SS-6).
In general, the data from Group 1 and Group 2 are very similar. The constituents that show an
increase in concentration from Group 1 to Group 2 include the following: total alkalinity, sulfate,
chloride, calcium, iron, manganese, phosphorus, sodium, and fecal coliform. Ammonia and
nitrate/nitrite are more concentrated in the Group 1 (upstream) samples than in the Group 2
(downstream) samples.
Groundwater at the AllJuice facility exceeds 2L standards, defined in 15A NCAC 2L (DEQ 2018), for
ammonia, iron, and manganese. The June 2019 sampling event data (reported in the CAAR) is
included in Table 1 for the western boundary compliance monitoring wells (MW-2, MW-7, and MW-
9) at the AllJuice facility.
Figure 3 displays Stiff diagrams (also shown mapped on Figure 2) that show the milliequivalent
concentrations of major cation and anion groups, which can be used to evaluate the change in water
quality as water migrates from areas of recharge to discharge. Groundwater data from June 2019
along with the June 2020 stream sample data were used to create the Stiff diagrams. Based on the
collected data, the major ions with the highest concentrations in groundwater at the AllJuice facility
are alkalinity (bicarbonate), sodium (combined with potassium on the Stiff diagram), and chloride.
These constituents are most concentrated in the ditch sample, in monitoring well MW-2, and to a
lesser extent in MW-9 (Figure 3). The Stiff diagrams show that alkalinity in stream water is slightly
elevated in the Group 2 samples compared to the Group 1 samples. This difference in alkalinity
concentrations may indicate an influence from the groundwater source; however, this argument is
weakened by the lack of groundwater influence on sodium, potassium, and chloride concentrations.
These constituents are more elevated in the groundwater samples and show little variation from the
upstream (Group 1) samples to the downstream (Group 2) samples. Group 2 stream samples
represent discharge locations for groundwater migrating from the western boundary of the AllJuice
facility. As such, Group 2 stream samples do not show a significant major ion geochemical influence
from groundwater originating from the AllJuice facility.

September 9, 2020
Page 4
The groundwater constituents that exceed the 2L standards at the AllJuice facility (ammonia, iron,
and manganese) are shown below with the ranges detected in Group 1 and Group 2 samples:
Iron Manganese Ammonia
(µg/L) (µg/L) (mg/L)
Group or Well
Group 1(upstream) 810 to 1,180132 to 154 0.11 to 0.14
Group 2 (downstream) 1,330 to 1,510 256 to 482 0.070 U to 0.097 J
MW-2 7,280 9,080 29.1
MW-7133 300 0.050 U
MW-9 455 40.90.050 U
Notes:
Bold indicates a 2L Groundwater Standard is exceeded.
µg/L: micrograms per liter
mg/L: milligrams per liter
J: estimated value
U: non detected above method detection limit
Based on these observations, metal concentrations from MW-2 may be influencing the tributary
chemistry; however, ammonia concentrations from MW-2 are not.
The sample collected from the stagnant pool of water from the drainage ditch shows similar
constituent detections as past samples from the ditch; however, they appear more concentrated. This
1
may be due to evaporative effects following the last rain. Sample SS-3 was collected downstream
from the drainage ditch and is very similar to the upstream concentrations in SS-1 and SS-2.
Therefore, the drainage ditch sample provides an understanding of constituents that may enter the
stream during significant rain events. SS-4, collected immediately downstream of the pond overflow
pipe, has slightly elevated constituent concentrations compared to Group 1 samples, suggesting that
input from the drainage ditch does not have a lasting influence on the pond water quality (Table 1).
Conclusion
The February 25, 2020, video pipe inspection identified a section of the wastewater discharge pipe
that had been repaired in the past. The repaired section of pipe is located near the former septic
drain field. The repaired section of pipe does not appear watertight. Anchor QEA recommends
having this section of pipe repaired to prevent meteoric water from entering the wastewater pipe
and introducing fecal coliform.
On June 23, 2020, six stream samples were collected from locations along the tributary to Wolfpen
Creek. Three samples were collected upstream (Group 1) from the zone of groundwater discharge
from the property boundary. Three samples were collected (Group 2) within the zone of groundwater

1
Review of daily rain events from Henderson County (https://www.ncdc.noaa.gov/cdo-
web/datasets/GHCND/stations/GHCND:USC00313976/detail) indicate that the last rain event preceding the sampling event
occurred on June 19.

September 9, 2020
Page 5
discharge. The stream sample results were compared to groundwater data from property boundary
wells collected from June 2019. The Group 2 sample results, on the whole, displayed slightly higher
concentration than the upstream Group 1 sample results. Groundwater concentrations of iron and
manganese observed from well MW-2 may be influencing iron and manganese concentrations in
Group 2. Ammonia is not negatively impacting the stream due to groundwater migration from the
AllJuice facility.
Feel free to call me at 828-771-0378 and email me at [e-mail] you have any
questions.
Sincerely,
Chuck Pippin, PG
Senior Managing Geologist
cc: AllJuice Realty, LLC
Attachments
Table 1 Analytical Summary
Figure 1 Image of Pipe Repair
Figure 2 Off-Site Sample Locations
Figure 3 Stiff Diagrams for Major Cations and Anions
Attachment 1 Field Forms and Calibration Log
Attachment 2 Laboratory Analytical Report

September 9, 2020
Page 6
References
Anchor QEA (Anchor QEA of North Carolina, PLLC), April 2020, Corrective Action Assessment Report.
Prepared for AllJuice Realty, LLC.
DEQ, 2018. “Groundwater Protection Compliance Standards – Constituents List”. Last modified
October 15, 2018. Available at:
https://edocs.deq.nc.gov/WasteManagement/0/edoc/1257181/SWS_EnviroMonitoring_Const
ituents_List.pdf?searchid=13f8efb1-ee11-485a-b03f-718f2287b271.
DEQ, 2019. Letter to AllJuice Realty, LLC. Regarding: Review of the Notice of Violation and Notice of
Intent to Enforce Response Report and Required Corrective Action Measures. March 5, 2019.

Table

July 2020
Page 1 of 1
9.51.8
231
18.60.896.1464.8
0.32
235
1145
-15.5
0.041
3,5002,710
35,80012,20013,30035,600
DITCH-6141,000246,000
6/23/2020
Ditch Sample
On-Site Drainage
17
389
21.27.0075.56.3226.8
0.600.6923.0
SS-6
164.7
0.0502,270
1,3004,7005,3401,5106,370
0.097 J
3,040 U
6/23/2020
14
482
21.46.7374.26.3310.5
0.5724.1
SS-5
156.1
0.0582,270
0.28 J
1,3004,7005,0201,5106,680
0.079 J
3,040 U
Group 2
6/23/2020
43
256
23.07.2757.76.5613.8
0.890.2620.1
SS-4
140.8
740 J
0.0842,640
Within Zone of Groundwater
3,8003,8201,330
4,850 J
0.070 U3,040 U
Discharge From AllJuice Facility
6/23/2020
300144
19.46.5755.96.247.63
0.120.7014.3
SS-3989
136.9 780 J
0.47 J
2,9003,5401,210
0.032 J3,510 J
3,040 U
6/23/2020
Off-Site Stream Samples
390132
19.76.6948.56.2310.1
0.110.5312.1
810
SS-2
152.3
780 J
0.49 J
2,7003,2001,180
3,150 J
0.025 U3,040 U
Group 1
6/23/2020
AllJuice Facility
Upstream of Potential
240154
21.15.8149.56.2912.5
0.140.520.2912.7
SS-1
126.6 970 J
0.0721,180
Groundwater Discharge from 2,5003,4401,280
3,060 J
3,040 U
6/23/2020
50
NENENENENENENENENENENENE
1,000
Water
NC 2B 6.0-9.0
230,000
Surface
Standard
455
15.86.379.870.10
35.740.9
11.92162.7193.8
4,700100.0924.0
0.25 U
MW-9 40,000
0.033 J1,480 J
0.050 U
6,960.0
30,400.0
6/26/2019
2.37.0
300
16.15.2585.84.240.00
700 J1.0 U
230.9
133.0
0.25 U
MW-7
14,200
2,810 J
0.050 U0.025 U 2,260.01,380.09,620.0
6/26/2019
Compliance Wells
Property Boundary
614
287
19.00.6019.30.00
6.2729.125.00.39
1.0 U
1,200
770 J
7,2809,080
MW-2
27,900
0.025 U 1,850.0
13,300.074,200.0
6/26/2019
50
NENENENE1.5NENENENENENENENE
300
250,000250,000
6.5 to 8.5
Standard
NC2L Groundwater
°C
SU
mV
NTUµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/Lµg/L
mg/Lmg/Lmg/Lmg/Lmg/Lmg/L
Units
µS/cm
CFU/100mL
pH
DO
Iron
ORP
Sulfate
Sodium
Calcium
Chloride
Turbidity
Potassium
Parameter
MagnesiumManganese
Temperature
Phosphorous
Nitrate/Nitrite
Alkalinity, Total
Fecal Coliforms
Nitrogen, Ammonia
Specific Conductivity
Nitrogen, Kjeldahl Total
Metals
Anions
Nutrients
values indicate a detected analytical result. Field parameters are not bolded, since they are measured in the field.

Field Parameters
Parameter Group
Other Water Quality
Notes:Bold J: a laboratory data qualifier used for parameters detected at estimated concentrations above the MDL but below the MRLU: a laboratory data qualifier used for parameters not
detected at concentrations above the MDLµg/L: micrograms per literµS/cm: microsiemens per centimeterCFU/100 mL: coliform forming units per 100 millilitersDO: dissolved oxygenmg/L: milligrams
per litermV: millivoltNA: not analyzedNC2B: surface water standard per North Carolina Administrative Code, Title 15A: Department of Environmental Quality, Subchapter 2B – Surface Water
and Wetland Standards (last amended in September 2017), or the standard obtained from the EPA Nationally Recommended Water Quality Criteria for Aquatic Life and Human Health.NC2L: Subchapter
2L – Groundwater Classifications and Standards, Department of Environmental Quality (Amended April 1, 2013). Groundwater standard from North Carolina Administrative Code, Title 15A.NTU:
nephelometric turbidity unitORP: oxidation-reduction potentialSU: standard unitNE: not established
Table 1Analytical Summary Off-Site Stream Assessment and Pipe Inspection ResultsAllJuice Facility

Figures

Captured image of pipe video inspection showing a pipe repair in the vicinity of the former septic system drain
field. This repair in the pipe would allow water to seep in during storm events and would explain the fecal
coliform issues in the pond.
Filepath: A:\\Projects\\AllJuice\\190305 - Request for CAP from DEQ\\Surface Water Sampling\\Memorandum\\Working Documents\\Figure1.docx
Figure 1
Image of Pipe Repair
AllJuice Realty, LLC

nions
A
Figure

d
an
s
AllJuice
n
atio
C
ajor
M
or
f
iagrams
D
Stiff

Figure 2.docx
\\
Working Documents
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Memorandum
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Surface Water Sampling
\\
Request for CAP from DEQ
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igure 1 for Stiff Diagrams plotted on map.
F 190305
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AllJuice
: See \\
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A:

Anchor QEA of North Carolina, PLLC
231 Haywood Street
Asheville, North Carolina
March 31, 2021
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
A:\\Projects\\AllJuice\\2021-0323_NOV Response\\AllJuice - Response to NOV 2021-0331.docx

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
1
storage pond. 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

1
Figure
Notice of Violation
AllJuice Realty, LLC
Influent Pipe Repair Location

Response to Requirements of the March 1, 2021
the damaged area of the pipe. The pipe appears intact
g the implementation of the pond design, this section of the influent pipe will be
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 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. Durinrepaired.
Pipe Repair Location.docx
-
Figure 1
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0323_NOV Response
-
2021
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AllJuice
\\
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Asheville
\\
asheville1
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Filepath:

Table

Page 1 of 1
March 2021
June
May
2022
QRT2
April
March
2022
QRT1
February
January
December
2021
QRT 4
November
October
September
2021
QRT 3
August
July
June
May
2021
QRT 2
April
March
2021
QRT 1
February
January
Task Description
Existing Pipe SchematicExisting Conditions and Topographic SurveyDesign DevelopmentFinal DesignPre-Application MeetingPreliminary Operation and Maintenance ManualWastewater Irrigation
Systems Permit SubmittalBid Document DevelopmentBid Solicitation and AdvertisementBid Review and Contractor SelectionIrrigation Field ImprovementsPre-ConstructionSite Preparation and
Bypass Set-UpConstruction (Sludge Removal and Stockpile)Construction (Pond Modifications)Engineer’s Certification of CompletionCommissioningCloseout
Table 1General Project Schedule
Pond Modification Project Scope of WorkAllJuice Facility, Hendersonville, North Carolina

Anchor QEA of North Carolina, PLLC
231 Haywood Street
Asheville, North Carolina
June 25, 2021
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: Summary of Sodium Concentration Data
1
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,
On June 1, 2021, myself, and Sara Stavinoha (Anchor QEA of North Carolina, PLLC), Kristina Armbrust
(AllJuice Realty, LLC), and Bret Laverty and Mikal Willmer (North Carolina Department of
Environmental Quality (DEQ)) attended a conference call to discuss the repaired effluent pipe that
conveys wastewater from the AllJuice facility to the holding pond. The pipe is thought to have been
damaged and repaired in 1999 during a septic system maintenance project. The potential for
wastewater to exit the pipe and flow along bedding material to discharge into the stormwater ditch
was discussed during the call. DEQ expressed the concern that a sample of water from the Ditch 6
sample location had elevated sodium concentrations, which is indicative of wastewater. DEQ also
questioned the potential of this sodium concentration to be related to wastewater escaping the
repaired section of pipe. Anchor QEA agreed to summarize the site information with regards to
observed sodium concentrations (Figure 1).
In general, sodium concentrations in sampled media are summarized below:
Wastewater from the facility ranges from 16,100 to 18,500 µg/L.
The wastewater in the pond and applied to the fields is more concentrated, ranging from
69,800 to 85,000 µg/L.
Concentrations measured in the Ditch 6 location have ranged from a low of 7,630 µg/L to a
high of 246,000 µg/L.

1
This letter is a follow up response to the March 1, 2021 Notice of Violation. The original response was submitted on March 31,
2021 (Response to Requirements of the March 1, 2021 Notice of Violation, Anchor QEA, March 31, 2021).
A:\\Projects\\AllJuice\\2021-0323_NOV Response\\2021-0625-AllJuice - Sodium Concentration Summary Response to NOV 2021-0607.docx

June 25, 2021
Page 2
Concentrations observed at locations between Ditch 6 and theapplication fields range from
20,900 to 53,900 µg/L.
Regarding DEQ’s assertion of the potential for wastewater to be discharged from the repaired
section of the wastewater pipe, Anchor QEA provides the following observations:
The pipe inspection video shows the bottom half of the wastewater pipe to be undamaged in
the area of the repair. Discharge through the pipe is relatively constant during production
and is below the damaged portion of the pipe; therefore, a full-pipe scenario, that would
result in a leak is unlikely.
The anomalous sodium concentration observed at Ditch 6 is higher in concentration than any
other sample collected on site and more than 10 times the concentration of the influent
wastewater.
Anchor QEA has not observed water flowing into the ditch at the location where the
wastewater pipe spans the ditch.
Groundwater measured at temporary well TW-3 on June 14, 2019, had relatively low sodium
concentrations (7,420 µg/L), suggesting that the pipe is not attributing to a wastewater
release to subsurface soils and ultimately to groundwater.
Sampling at ditch location D-6 has occurred on three occasions
o On October 21, 2019 water was flowing at the D-6 location. Sodium concentration
was 13,600 µg/L
o On October 31, 2019 water was flowing at the D-6 location. Sodium concentration
was 7,630 µg/L
o On June 23, 2020 water was stagnated at D-6 location. Sodium concentration was
246,000 µg/L
During periods of flow at the Ditch 6 location, sodium results are relatively similar; however, the
concentration from the stagnated pool was much more concentrated, likely due to evaporative
effects.
Given the anomalous concentration observed from ditch sample (D-6) collected on June 23, 2021,
Anchor QEA recommends closely inspecting the wastewater pipe where it spans the ditch to observe
potential flow from pipe bedding material into the ditch and resampling location Ditch-6 following a
rain event.
Planned improvements to the application fields, will include rerouting the wastewater pipe, to
discharge plant effluent to the northern portion of the modified wastewater storage pond and the

June 25, 2021
Page 3
addition of a stormwater retention pond to prevent overland flow from the application fields
entering the drainage ditch. These design elements will effectively mitigate impacts from possible
leakage from the repaired section of effluent piping and from stormwater flow from the application
fields to off-site receiving streams. On behalf of AllJuice, Anchor QEA is requesting that the DEQ
allow AllJuice to postpone the pipe repair, until construction of the storage pond modification is
started.
Should the DWR have questions or concerns, please do not hesitate to contact me by email or phone
(828.771.0378).
Sincerely,
Chuck Pippin, PG, RSM
Managing Geologist
cc: Kristina Armbrust, [e-mail]
Rob Howell, Anchor QEA, Principal
Mikal Willmer, Water Quality Regional Operations Section
Brett Laverty, Water Quality Regional Operations Section
Attachments
Figure 1 Sodium Results for Facility Sample Locations

MW-5
!
U
MW-8
!
U
POND-EFF
12/21/2017: 77,100 µg/L
7/10/2019: 78,000 µg/L
#*
POND-EFF
DITCH-1-GRAB
MW-1
!
U
MW-3
!
9/16/2019: 96,500 µg/L
U
MW-9
!
U
DITCH-1-G
10/21/2019: 52,700 µg/L
DITCH-2
10/31/2019: 20,300 µg/L
9/30/2019: 20,900 µg/L
DITCH-1
DITCH-2-G
MW-10
!
U
10/21/2019: 21,300 µg/L
10/21/2019: 28,200 µg/L
10/31/2019: 6,430 µg/L
Transducer 1
"
J
#
*
DITCH-1
PLANT-EFF
Outfall 1 - Roof Drain
MW-7
!
U
7/10/2019: 18,500 µg/L
TW-1
TW-2
!
U!
U
POND
"
)
#
*
DITCH-2
k
j
MW-6
POND
!
U
DITCH-3
7/10/2019: 85,300 µg/L
#
*
TW-4
!
U
POND-S
"
)
PLANT-EFF
MW-2POND-INF
!
U
7/10/2019: 82,500 µg/L
"
)
"
J
POND-INF
TW-3
!
U
Transducer 2
12/21/2017: 16,100 µg/LDITCH-3
7/10/2019: 17,100 µg/L9/30/2019: 24,700 µg/L
DITCH-4
#
*
DITCH 3-G
10/31/2019: 13,600 µg/L
Ditch
Outfall 2 - Roof Drain
DITCH-4
9/30/2019: 24,300 µg/L
2160
DITCH-6
#
*
DITCH-6-G
10/21/2019: 13,600 µg/L
2180
10/31/2019: 7,630 µg/L
DITCH-6
6/23/2020: 246,000 µg/L
NOTES:
LEGEND:
1.Aerial imagery from U.S. Department of Agriculture
Site BoundaryTopographic Contours (2-Foot Interval)Facility Sample Locations
National Aerial Imagery Program, 2018
2.Topographic contours from North Carolina Department of
Spray Irrigation Field Application AreaDitch Analysis Sample LocationInfluent to Treatment Pond
#"
*)
Transportation Lidar, 2007
3.Outfall 2 - This outfall is a roof drain for the facility. It also
Former Well HouseSeptic System Embankment BreachPlant Effluent to Sump
"
k)
j
#*accommodates the drainage from the pressure relief valve for
Former Septic FieldPond Effluent
"Transducer Locationthe closed loop pipe chiller used for pasteurization. In the
J
past, the pressure relief valve was stuck open and allowed city
New Septic Drain FieldTreatment Pond
Groundwater Sample Locations
"
)
water to drain to outfall.
Site Building
Monitoring Well
!
U
Aerated Irrigation Lagoon
Temporary Well
!
U
\[
Drainage Ditch
%
0150
Drainage to Outfall
Feet
Streams
Publish Date: 2021/06/17, 2:48 PM | User: alesueur
Filepath: \\\\orcas\\gis\\Jobs\\AllJuice_1762\\MXD\\2021_06_SodiumData\\AQ_FigX_AllJuice_SodiumResults.mxd
Figure
Sodium Results for Facility Sample Locations
AllJuice Realty, LLC, Hendersonville, North Carolina

Attachment K – Industrial Wastewater
The wastewater composition in Section III, Item 5 of the permit renewal form is described as 100%
industrial wastewater. The nature of the wastewater has not changed since the last permit issuance in
2017.
The manufacturing process can be described as follows:
1. Juice concentrate is mixed with water within the facility manufacturing process and is bottled and
packaged for distribution.
2. Wastewater is captured on the production line and floor drains and is conveyed to an outside pH
neutralization sump.
3. From the sump, wastewater is conveyed underground by gravity flow to a storage pond where it is
mixed and aerated.
4. Effluent from the storage pond is pump to the irrigation fields where it is applied to ground surface
by sprinklers where treatment is provided by plant uptake.
A more detailed description is provided on page 3 of the Corrective Action Assessment Report (Anchor
QEA, April 2020).
The list of chemicals used in the process for cleaning and pH control includes the following:
Oakite CIP
Oakite Fisan-LC55
Oakite detergent sanitizer
Oakite Sanitizer 1
Oakite DZL
Oakite Circhlor Plus
Fisan LC Degreaser
Oakite CFC
Oakite Liquid Bactericide
Magrabar Defoamer SPI-244
Caustic for pH control

The facility utilizes clean in place technology.