WQ0004967_Staff Report_20211119

State of North Carolina
Department of Environmental Quality
Division of Water Resources

Water Quality Permitting
Regional Staff Report

FORM: APSRSR 04-10 Page 1 of 5
November 19, 2021

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0004967
Attn: Chloe Lloyd Regional Login No.:

From: Mikal Willmer & Brett Laverty
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
a. Was a site visit conducted? Yes or
b. Date of site visit: January 26, 2021
c. Site visit conducted by: Mikal Willmer.
d. Inspection report attached? Yes or No In LF.
e. Person contacted: Robert Barr, RPB Systems and their contact information: 828-230-1021
e. Driving directions: Take I-26 E to exit 49A onto US-64 E. Turn right on Sugarloaf Rd. and continue for
approximately 2 miles and turn left onto Jet St. The Office and wastewater pond are at the end of the
road.
f.
II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)

III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
DocuSign Envelope ID: CAB1B0B4-3391-42DF-892C-D1D98398632A
FORM: APSRSR 04-10 Page 2 of 5
ORC: Danielle Hunter Certificate #:SI-1007992 Backup ORC: Robert Barr Certificate #:SI-24262
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? Yes or No
If no, please explain: See inspection report.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or No See inspection report and V below.
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? Yes or No
If yes, please explain: On October 17, 2017, the Asheville Regional Office (ARO) issued a Notice of Violation
(NOV-2017-LV-0672, NOV-2017-LV-0673, NOV-2017-LV-0674, & NOV-2017-LV-0675) to AllJuice Realty,
LLC (AllJuice) for exceeding groundwater standards at monitoring well MW-2. The contaminants of
concern include fecal coliform bacteria, ammonia, iron, and manganese.
A comprehensive site assessment (CSA) was conducted by Alljuice between 2018 and 2020. It was
determined that a failing on-site domestic septic system and industrial wastewater from the spray
irrigation lagoon are responsible for groundwater impacts at MW-2. Wastewater from the failed septic
system is also infiltrating the spray irrigation lagoon via a break in the influent wastewater line.
Unpermitted wastewater discharges from the spray irrigation field are suspected and failed septic system
are intermittently discharging to a stormwater ditch (boundary ditch) connected to a Class C stream
known as Wolfpen creek. Alljuice has replaced the failing domestic septic system and is working towards
replacing the spray irrigation lagoon as well as improving the condition of the spray irrigation field.
The Asheville Regional Office (ARO) is recommending the addition of a surface water monitoring site at
the confluence of the boundary ditch with Wolfpen Creek. Surface water monitoring should include
quarterly sampling for ammonia, BOD, COD, dissolved oxygen, fecal coliform bacteria, nitrate, nitrite, pH,
phosphorus, redox, specific conductivity, temperature, and total Kjeldahl nitrogen (TKN). Because stream
flow within the boundary ditch is intermittent and flashy, Alljuice will need to submit a surface water
monitoring plan to the ARO for approval. The plan should focus on assessing surface water quality during
baseflow and stormwater conditions. The purpose is to investigate potential impacts to Wolf Pen Creek
from unpermitted wastewater discharges along boundary ditch.
5. Is the residuals management plan adequate? Yes or No
If no, please explain: No issues maintaining solids to date.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No
If no, please explain: Yes, according to recent agronomist’s recommendations; however, the dosing schedule
needs to be altered for optimal performance in addition to other corrective measures.
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
A total of 6 groundwater monitoring wells were recently installed near Alljuice’s wastewater lagoon and
spray irrigation field. The ARO recommends adding these new monitoring wells to Attachment C
(Groundwater Monitoring and Limitation) of the permit. The new monitoring wells include MW-5, MW-6,
MW-7, MW-8, MW-9, and MW-10. It is important to note that previous monitoring well MW-1 has been
replaced by MW-5 and MW-9. The ARO recommends removing MW-1 from Attachment C of the permit.
A new site map should be submitted to illustrate the locations of all new surface and groundwater
monitoring sites.
Alljuice is currently collecting groundwater samples using low-flow monitoring techniques to minimize in-
well turbidity. Low-flow monitoring should continue and the sampling criteria be included as foot-note
language on Appendix C of the permit. Laboratory data sheets and field parameters (i.e., temperature,
specific conductivity, dissolved oxygen, pH, redox, and turbidity) should be included with the GW-59
reports.
It was determined that industrial wastewater is impacting groundwater beneath the unlined spray
irrigation lagoon. Raw wastewater entering the lagoon can be characterized by high strength biochemical
oxygen demand (BOD) and chemical oxygen demand (COD) as well as a high concentration of organically-
DocuSign Envelope ID: CAB1B0B4-3391-42DF-892C-D1D98398632A
FORM: APSRSR 04-10 Page 3 of 5
bound nitrogen commonly known as Total Kjeldahl nitrogen (TKN). The ARO is recommending the
addition of BOD, COD, and TKN to the list of groundwater monitoring parameters.
8. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas. Facility was constructed in 1979 before setback limits were
established in 1983. Irrigation site & lagoon would not meet new setbacks as described in permit. Permittee
will need to take this into consideration when the pond is modified.
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain: .
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:
During the last permit cycle, Alljuice was required to replace background monitoring well MW-1. A new
background monitoring well (MW5) was constructed on 11/29/2017. MW-1 should be removed from
Appendix C of the permit. However, MW-1 should not be abandoned until all site assessment activities and
associated groundwater monitoring is complete.
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary):
The ARO will contact Alljuice’s consultant to obtain coordinates and elevations for all groundwater
monitoring wells. BIMS will be updated at a later date.

Monitoring Well Latitude Longitude
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
12. Has a review of all self-monitoring data been conducted (e.g., NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review: No limits on NDMR. Exceedances in MWs near
unlined pond and previous onsite leach field and hits for nitrates in MW3 .
13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain: Addition of a new surface water monitoring site and 6 new groundwater monitoring
wells. Submit quarterly surface monitoring proposal to regional office for approval. Remove monitoring
well MW-1 from Appendix C of the permit. Addition of BOD, COD, and TKN to the list of groundwater
monitoring parameters. Submit new site map showing all groundwater and surface water monitoring
locations.
14. Check all that apply:
No compliance issues Current enforcement action(s) Currently under JOC
Notice(s) of violation Currently under SOC Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain:
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FORM: APSRSR 04-10 Page 4 of 5
2. List any items that you would like Non-Discharge Central Office to obtain through an additional information
request:
Item Reason

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
Removal of monitoring
well MW-1 from Appendix
C of the permit
Monitoring well MW-1 does not function as a background monitoring well and
is located within the compliance boundary. MW-1 was replaced by monitoring
wells MW-5 and MW-9. ARO requests MW-1 not be abandoned until the site
assessment and associated groundwater monitoring is complete.
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
Addition of a new surface
water monitoring site at the
confluence of the boundary
ditch with Wolfpen Creek.
The comprehensive site assessment indicates unpermitted wastewater
discharges to the boundary ditch from a failed septic system and the spray
irrigation field. Surface water monitoring should include quarterly sampling for
ammonia, BOD, COD, dissolved oxygen, fecal coliform bacteria, nitrate, nitrite,
pH, phosphorus, redox, specific conductivity, temperature, and total Kjeldahl
nitrogen (TKN). Alljuice should submit a surface water sampling proposal to
monitor both base flow and stormwater conditions in the boundary ditch.
Addition of 6 new
groundwater monitoring
wells
6 new groundwater monitoring wells were previously constructed during the
comprehensive site assessment. Monitoring wells should be included on the
Appendix C of the permit. ARO will obtain well coordinates and elevations
from the consultant.
Low flow groundwater
monitoring
Alljuice should continue to collect groundwater samples using low-flow
sampling techniques to minimize in-well turbidity. ARO recommends including
this on foot-note language in Appendix C of the permit. All field parameters
should be included with the GW-59 reports.
Addition of BOD, COD,
and TKN to list of
groundwater monitoring
parameters
Raw industrial wastewater entering the spray irrigation lagoon can be
characterized by high strength biochemical oxygen demand (BOD) and
chemical oxygen demand (COD) as well as a high concentration of organically-
bound nitrogen commonly known as total Kjeldahl nitrogen (TKN). The
comprehensive site assessment indicates industrial wastewater is impacting
groundwater beneath the lagoon and may be entering the boundary ditch via the
spray irrigation field.
Submit new site map Create a site map depicting the new surface water monitoring site and the
addition of 6 new groundwater monitoring wells.
5. Recommendation: Hold, pending receipt and review of additional information by regional office
Hold, pending review of draft permit by regional office
Issue upon receipt of needed additional information
Issue
Deny (Please state reasons: )

DocuSign Envelope ID: CAB1B0B4-3391-42DF-892C-D1D98398632A
FORM: APSRSR 04-10 Page 5 of 5
6. Signature of report preparer:

Signature of WQROS regional supervisor:

Date:

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Reference Brett’s comments above. Facility has been unable to properly maintain the intended crop (fescue) on
the irrigation site. Significant weeds and bare patches covered the field in January 2021, limiting the assimilative
capacity of the intended irrigation site and increasing the potential for run off and oversaturation. ESP results
from the annual soil fertility analysis vary significantly from year to year. Some soil borings indicate ESP is within
appropriate levels for the field; however, the agronomists report, indicates certain portions of the field require
amendment based on the elevated ESP levels. Field remedial work is currently being carried out (soil amendment,
reseeding and weed removal). The current irrigation cycle may be oversaturating the field and it is recommended
this be adjusted to improve crop and soil performance. As mentioned above, MW-3 appears to be downgradient of
the new leach field for the onsite septic system and may be impacting nitrate numbers within the well.
Recommended the facility ensure annual soil fertility analyses are representative of the entire field. ESP
differences suggest the current sampling protocol for the annual soil fertility analysis may not be representative.

DocuSign Envelope ID: CAB1B0B4-3391-42DF-892C-D1D98398632A
11/19/2021