WQ0004967_STFRPT_20220711

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 6

July 11, 2022

To: NPDES Unit Non-Discharge Unit Application No.: WQ0004967
Attn: Lauren Plummer Facility name: AllJuice

From: Melanie Kemp, Brett Laverty & Mikal Willmer
Asheville Regional Office

Note: This form has been adapted from the non-discharge facility staff report to document the review of both non-
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.

I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: June 29, 2022
b. Site visit conducted by: Melanie Kemp, Brett Laverty & Mikal Willmer
c. Inspection report attached? Yes or No In LF
d. Person contacted: Chuck Pippin, Anchor QEA and their contact information: 828.989.6241
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.
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
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:
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FORM: WQROSSR 04-14 Page 2 of 6
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)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
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:
Description of existing facilities
Proposed flow:
Current permitted flow:
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership, etc
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or No
If no, please explain: Site conditions have improved and should continue to improve if AllJuice allows
adequate rest time for the irrigation zones and implements crop removal practices.
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 March 2, 2021, the Asheville Regional Office (ARO) issued a Notice of Violation
(NOV-2021-PC-0157) to AllJuice Realty, LLC (AllJuice) for end use-irrigation violations after a January
26, 2021 site inspection related to numerous weeds and moisture-tolerant grasses being present in the
irrigation field (Permit Condition III.3). This NOV also noted a potential compliance issue related to the
damaged influent pipe that conveys wastewater from AllJuice facility to the wastewater storage lagoon.
On March 31, 2021, Anchor QEA submitted a response to the NOV, outlining recommendations to
improve the assimilative capacity of the irrigation fields by removing weeds, cutting and removing crop
yields, applying gypsum (or similar) to break sodium-binding in soils, alternate wetting/drying application
periods to promote better microbial activity and root growth, and planting trees along the field perimeter
to develop deep root systems to enhance treatment. A schedule of activities, completed and recommended,
was provided in this letter.
On May 16, 2022, Anchor QEA submitted application for a minor modification of the Wastewater
Irrigation System WWIS 06-16. In this application, related to NOV-NIE issued in October 15, 2017,
Anchor QEA redesigned the storage pond to include a liner and designed a new stormwater retention pond
to collect site run-off.
A permit renewal for the facility was issued effective April 1, 2022 outlining the following modifications:
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FORM: WQROSSR 04-14 Page 3 of 6
 Addition of quarterly surface water monitoring, beginning with July 2022
o Locations to be approved by submitting figure no later than June 30, 2022.
o Location to be labeled “PPI-002”
 Updated setback language
 Testing and calibrating all metering equipment annually
 Updated general permit language
 Removal of MW-1 and addition of MW-5 through MW-10, added BOD, COD, and TKN
and a footnote requiring low-flow sampling techniques. It is important to note that
monotirng wells MW-6 and MW-10 are
5. Is the residuals management plan adequate? Yes or No
If no, please explain: Draft Residual Management Plan included in recent permit modification request
(5/18/22
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No
If no, please explain: Based on the previous agronomist reports, there is adequate acreage to assimilate
their current permitted flows, so long as the cover crop continues to be maintained and excess nitrogen is
removed from the field via cutting, bailing, and removal. The irrigation schedule in the O&M Plan
(included in the modification application) should continue to be followed.
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas. No setbacks within current permit due to original issuance date. The
field and pond would not meet current setback requirements in 02T.
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:

DocuSign Envelope ID: 3032EEB3-89AD-4D1E-8B79-7EE0A59987E3
FORM: WQROSSR 04-14 Page 4 of 6
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary):
Monitoring Well Latitude Longitude
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
Has a review of all self-monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review:
Permit violations
 GW exceedances:
o March 2021: Fe in MW-2, MW-3, and MW-9; Mn in MW-2, MW-3; NH3 in MW-2;
pH for all
o July 2021: Fe MW-3, MW-4, MW-9; Mn in all; NH3 in MW-2; NO in MW-2; pH in
all but MW-2
o November 2021: FE in MW-2, MW-3, MW-5, MW-8, and MW-9; Mn in all; NH3 in
MW-2; pH in all but MW-2
o March 2022: Fe MW2, MW3, MW7, and MW8; Mn in MW2, MW3, MW7, and
MW8; NH3 in MW2; N03 in MW2; pH in all but MW-2
Soil Fertility Analysis and most recent NDMR data appeared to be in compliance. ESP was 5.9 in 2021.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain:
13. 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.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
15. Possible toxic impacts to surface waters:
16. Pretreatment Program (POTWs only):

DocuSign Envelope ID: 3032EEB3-89AD-4D1E-8B79-7EE0A59987E3
FORM: WQROSSR 04-14 Page 5 of 6
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non-Discharge Unit 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
Surface Water Monitoring
Attachment A requires the permittee to conduct quarterly surface water
monitoring at the confluence of an onsite ephemeral stream. Footnote 2 requires
upstream and downstream monitoring in the receiving stream (Wolfpen Creek)
if the ephemeral stream is dry. The ARO recommends removing the
requirement to sample upstream/downstream if the ephemeral stream is dry.
The permittee will still be required to monitor PPI-002 on a quarterly basis.

4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
Site Map
Section I.2 of the permit requires completion of site map within 30 days of
establishing the surface water monitoring site PPI-002. The ARO recommends
delaying the site map until the new wastewater lagoon and stormwater basin are
completed.

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: )

6. Signature of report preparers:

Signature of regional supervisor:

Date:

DocuSign Envelope ID: 3032EEB3-89AD-4D1E-8B79-7EE0A59987E3
7/13/2022
FORM: WQROSSR 04-14 Page 6 of 6
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
It is highly recommended the permittee implement or explore crop removal options more thoroughly. The health of the
fescue will suffer long-term if thatch is left on the field, which combined with irrigation schedules led to proliferation of
moisture tolerant weeds.
Facility is converting part of the existing lagoon into a stormwater retention pond. The ARO Hydrogeologist is not
currently requesting closure of this portion of the lagoon based on the extensive sight work and data currently available
for the previous ground water impacts. Some soils will be removed as part of the modification and construction process.
Inspectors did have questions regarding the pipe elevation within the stormwater pond that appears would allow a
continuous discharge; however, stormwater features are outside of the scope of non-discharge permitting since this is not
considered a waste storage or treatment structure for the system.

DocuSign Envelope ID: 3032EEB3-89AD-4D1E-8B79-7EE0A59987E3