WQ0004967_Additional Information Request_20220808

August 8, 2022
MARK HOPPE – MANAGING MEMBER
ALLJUICE REALTY, LLC
ONE WESTBROOK CORPORATE CENTER
WESTCHESTER, ILLINOIS 60514
Subject: Application No. WQ0004967
Additional Information Request
AllJuice WWTF
Wastewater Irrigation System
Henderson County
Dear Mr. Hoppe:
Division of Water Resources’ Central and Regional staff has reviewed the application package
received May 18, 2022. However, additional information is required before the review may be completed.
Please address the items on the attached pages no later than the close of business on September 7, 2022.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant’s responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through Q, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2).

Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with an
electronic response submitted to my attention at: https://edocs.deq.nc.gov/Forms/NonDischarge-Branch-
Submittal-Form-Ver2.

If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Lauren Raup-Plummer, Engineer III
Division of Water Resources
cc: Asheville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Walter Dinicola, PE – Anchor QEA, LLC (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Mark Hoppe
August 8, 2022
Page 2 of 6
A. Cover Letter:
1. No comment.
B. Application Fee:
1. Not applicable.
C. Application (WWIS 06-16):
1. Section IV.4. regarding the status of applicable permits and certifications was left blank. Please
note that the Non-Discharge Branch does not issue permits for stormwater management. Is a
stormwater permit being obtained for the proposed dry detention pond and associated stormwater
features?
2. The wastewater flow table in Section IV.7 lists the wastewater treatment and processing facility
and the on-site septic system. Our understanding is that the on-site septic system processes
domestic wastewater generated at the AllJuice facility, and that this waste stream is separate from
the industrial wastewater treatment process served by the aeration lagoon and this Non-Discharge
permit. Please provide clarification and revise the table to only include wastewater flows through
the non-discharge facility, if necessary.
3. In Section V.1 Wastewater Treatment Facility Design Criteria, the influent and effluent
concentrations are nearly identical. Additionally, these values do not appear to correspond the
“Influent” and “Effluent” samples provided within the lab results portion of the submittal package.
Are the values in the application referring to the influent concentrations entering the aeration lagoon
from the treatment plant and the effluent concentrations exiting the aeration lagoon to the irrigation
fields? Please clarify.
4. Section V.11.a lists a grit chamber as being part of the facility with a plan reference to Sheet C01.
Sheet C01 does not include a callout for the “grit chamber”. Is the grit chamber represented as the
“Wastewater Discharge Sump With Screen” feature called out behind the main AllJuice building?
Additionally, a grit chamber is not currently listed in the existing permit’s facility description
(Permit Version 4.0, issued December 29, 2021), and it is unclear whether the grit chamber is part
of the original treatment facility or a more recent addition. Please provide additional information
regarding the grit chamber.
5. Please address the following questions regarding the aeration lagoon modifications:
a. The proposed volume of the redesigned aeration lagoon is listed at 800,000 gallons in Section
V.11.b. and VI.12 of the application. Does this include both the redesigned aeration lagoon
volume and the dry detention pond volume? Please note that the existing permit lists the
original lagoon as 500,000 gallons for the combined footprint. Please confirm the proposed
aeration lagoon volume and revise, if necessary.
b. Section VI.3 lists that a discharge point in the form of a pipe or spillway is proposed. Is this
referring to the irrigation pump station piping? The provided engineering plans only depict a
spillway on the proposed dry detention pond. Please clarify and/or revise.
Mr. Mark Hoppe
August 8, 2022
Page 3 of 6
c. Section VI.5 indicates that the impoundment is designed to receive surface runoff, is this
referring to the proposed stormwater influent ditch and the dry detention pond? Please clarify.
d. Additionally, the total volume and effective volume values are both listed as 798,355 gallons.
The total volume shall be the volume from the impoundment bottom to the top of berm. The
effective volume shall be the volume between the two-foot freeboard elevation and the: (1)
pump intake pipe elevation; (2) impoundment bottom elevation; or (3) mean seasonable high
water table, whichever is closest to the two foot free board elevation. Please revise.
e. The effective storage time is listed as 2 to 5 days. With a total volume of nearly 800,000 gallons
and an incoming flow of 20,000 gallons per day, it is unclear how only 2 to 5 days of effective
storage are available. Please provide the calculations for the effective storage time.
D. Property Ownership Documentation:
1. No comment.
E. Soil Evaluation:
1. Not applicable.
F. Agronomist Evaluation:
1. No comment.
G. Hydrogeologic Report:
1. Not applicable.
H. Water Balance:
1. The provided water balance does not appear to meet the requirements of 15A NCAC 02T .0504(k)
and the Non-Discharge Branch “Water Balance Calculation Policy” guidance document. Please
provide a water balance that meets these requirements, and please provide calculated values
indicating the number of days of storage required – and provided – using the existing irrigation
system and proposed redesigned aeration lagoon parameters.
I. Engineering Plans:
1. Engineering plans must be signed, sealed, and dated by a North Carolina licensed Professional
Engineer in good standing. Additionally, the plans shall represent a completed design and not be
labelled with preliminary phrases (e.g, FOR REVIEW ONLY, NOT FOR CONSTRUCTION,
etc.). However, the plans may be labeled with the phrase: FINAL DESIGN – NOT RELEASD
FOR CONSTRUCTION. Please review and revise the engineering plans to meet the requirements
of G.S. 89C and 15A NCAC 02T .0504(c)(1).
2. The provided plan sheets did not depict the 15A NCAC 02T .0506(b) setback requirements. Please
revise.
Mr. Mark Hoppe
August 8, 2022
Page 4 of 6
3. Sheet C01 depicts three “pond aerator” features within the existing footprint that appear to be
unchanged throughout the Plan Set. The application and existing permit indicate that there are only
two pond aerators installed. Please review and revise the plan sheets, showing both the existing
aeration lagoon configuration and the proposed configuration for the aerators in the redesigned
aeration lagoon.
4. On Sheet C02, the damaged lagoon influent pipe is proposed to be replaced with the alignment
modified to better suit the redesigned aeration lagoon. A profile view of the proposed pipe
realignment was not provided, and it is unclear what method of abandonment/removal is being
proposed for the existing pipe. If the existing pipe is to be cut and capped, then this should be
clearly depicted within the plans. Please review and revise as needed, providing a profile view and
appropriate details for the aeration lagoon influent pipe repairs and modifications.
5. Please provide detail drawings of the aeration lagoon influent pipe inlet structure and outlet
structure. A call-out on Sheet C02 indicates that the outlet structure is to be preserved; however, it
is unclear what elevation the current outlet is set at and where that is relative to the redesigned
aeration lagoon geometry. No information was provided for the realigned inlet piping and
associated structure. Please provide a detail drawing, the designed inlet elevation, and any material
requirements or energy dissipation measures that are proposed for the redesigned aeration lagoon’s
inlet structure.
6. Sheet C04 depicts the proposed grading cross-sections for the dry detention pond and the
redesigned aeration lagoon. The cross-sections for the proposed aeration lagoon include a call-out
for the excavation of sludge and 6” of soil from the existing lagoon bottom. In the depicted
footprint for the dry detention pond (Cross-section C-C’), it is only indicated that the contractor
shall fill to proposed grade with suitable soil. Sludge and contact material (the upper 6” of soil
from the existing lagoon bottom) are to be excavated from the entirety of the existing aeration
lagoon footprint. Please revise, or otherwise clarify, that this material is to be removed throughout
the project extents.
7. The proposed freeboard elevations were not depicted on the plan view or cross-sections for the
redesigned aeration lagoon. Pursuant to 15A NCAC 02T .0505(d), all open-atmosphere treatment
lagoons and ponds and open-atmosphere storage units shall have at least two feet of freeboard.
Please revise and clearly depict the designed freeboard elevations.
8. The proposed construction areas are adjacent to several of the existing monitoring wells. Please
include notes on the plans regarding protection of the monitoring wells and any other nearby
structures that are to remain.
J. Specifications:
1. Engineering specifications must be signed, sealed, and dated by a North Carolina licensed
Professional Engineer in good standing. Please review and revise. [G.S. 89C, 15A NCAC 02T
.0504(c)(2)]
2. Specifications were not provided regarding the sludge stockpile requirements. Will the sludge
stockpile area include a liner to prevent leachate infiltrating the subsurface? Will precipitation be
directed away from the sludge stockpile area to reduce possible migration of potential contaminants
of concern into the facility’s stormwater management system? Please provide additional
information.
Mr. Mark Hoppe
August 8, 2022
Page 5 of 6
3. Within Section 21 23 10, Subpart 3.02 Pond Excavation lists that the Contractor shall construct the
ponds and berms (Item C) prior to excavating sludge and contact soils from the treatment lagoon
area (Item D). Please review and revise.
4. Within Section 33 05 05 – Buried Piping Installation, it is unclear whether the proposed piping will
be color-coded to indicate that the installed utility is wastewater (or stormwater). Please clarify
and revise.
5. On Page 4 of Section 33 05 05 – Buried Piping Installation the Pipe Leak Test subpart mentions
that hydrostatic testing is to be performed; however, the leakage formula, allowable limits, or
method standard were not provided. Will leakage for polyvinyl chloride (PVC) pipe be in
accordance with AWWA C605 “Underground Installation of Polyvinyl Chloride (PVC) and
Molecularly Oriented Polyvinyl Chloride (PVCO) Pressure Pipe and Fittings” or a comparable
standard? Please provide the leakage formula, and revise or clarify this section as needed.
K. Engineering Calculations:
1. Engineering design calculations must be signed, sealed, and dated by a North Carolina licensed
Professional Engineer in good standing. Please review and revise. [G.S. 89C, 15A NCAC 02T
.0504(c)(3)]
2. Proof of concept calculations were provided for the redesigned aeration lagoon volumes which
utilized a square base assumption. A second set of calculations went into finer detail for the dry
detention pond using what appears to be a trapezoidal prism concept. The bottom of the redesigned
aeration lagoon appears to be more suited to a trapezoidal base. It is unclear whether a final
designed aeration lagoon volume was determined. Is there a reason that techniques such as GIS or
CAD modelling were not used to produce a final aeration lagoon volume? Please provide the final
designed lagoon volume that corresponds to the Engineering Plan Set.
L. Site Map:
1. Please update “Figure 2, Site Features and Sample Locations” to include the surface water
monitoring station. This is a requirement of the existing permit Condition I.2.
M. Power Reliability Plan:
1. Not applicable.
N. Operation & Maintenance Plan:
1. The provided section discussing maintenance of the irrigation fields was brief, referencing a plan
developed by Nutter and Associates, Inc. Is this plan the document titled “Vegetation Management
Guidelines” that was attached to the “Agronomic Evaluation” by Nutter and Associates, Inc. dated
October 2019? If so, please incorporate this document into the Operation and Maintenance Plan
document.

Mr. Mark Hoppe
August 8, 2022
Page 6 of 6
O. Residuals Management Plan:
1. The Section titled “Residuals Disposal Plan” indicates that accumulated sediment and residuals in
the aeration lagoon have not been removed during the 30+ years of facility operation. The proposed
permit modifications will require the removal of the accumulated sediment and residuals from the
pond; however, the procedure outlined in the Engineering Plans and Specifications differ from the
procedure described within this section. The Residuals Management Plan specifies that a baffled
roll-off with removable tarp be brought on-site to remove sediment that is suctioned from the pond.
This is appropriate for conditions where the lagoon has not been dewatered; however, the
Specifications indicate that the pond is to be dewatered prior to removal of sludge and contact soils.
The removal activities proposed for the modifications should also be reflected in the Residuals
Management Plan. Please provide a section within the Residuals Management Plan that addresses
residuals management during the construction of the redesigned aeration lagoon and dry detention
pond.
P. Additional Documentation:
 Existing Permit:
1. No comment.
 Floodway Regulation Compliance:
1. No comment.
 Wastewater Chemical Analysis:
1. No comment.
Q. Recommendations: (Response not required)
1. Regional Office staff noted that historical irrigation field maintenance has impacted soil fertility.
This was corroborated in the October 2019 “Agronomic Evaluation” by Nutter & Associates, Inc.
The current Operation & Maintenance Plan (O&M Plan) language mentions replanting, weeding,
and mowing the irrigation fields on a cycling rotation. However, our staff recommends that a plan
be established to harvest the cut hay from the fields in order to remove nutrient loads from the
cuttings and maximize the irrigation fields’ assimilative capacity for long-term wastewater
disposal. Please consider revising the O&M Plan to include removal of the cut hay.
2. The proposed dry detention pond features a stormwater influent ditch with overland flow entering
the pond. It was unclear whether any energy dissipation measures are being proposed for the
detention pond inlet trench and stormwater ditch features, and the proximity of these features to the
aeration lagoon are a concern. Non-Discharge Branch staff recommend that the Permittee consider
an alternative subgrade inlet design to minimize erosion potential in areas adjacent to the
redesigned aeration lagoon and the engineered pond liner anchor trench.