WQ0005910_Response to Notice_20190517

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fhe Groundwater Experts
May 17, 2019
Mr. Brian Conner, O.R.C.
Avoca, LLC
PO Box 129
841 Avoca Farm Road
Merry Hill, NC 27957
4300 Sapphire Court, Suite 100
Greenville, North Carolina 27834
Telephone: [phone]
www.ama-nc.com
Apex and Gree
y' 6'
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RE: Avoca, LLC Wastewater Irrigation System Evaluation and Notice of Violation Response, Merry
Hill, Bertie County, NC
Dear Brian,
This letter presents GMA's hydrogeologic evaluation of the Avoca wastewater irrigation system (Figure
1). The wastewater irrigation system operated by Avoca, under Permit No. WQ0005910, includes
approximately 33 acres of spray irrigation areas that are permitted to receive up to 50,000 gallons per
day of treated wastewater. Avoca monitors groundwater levels and groundwater quality using 5
existing monitoring wells (MW -4, MW -5, MW -7, MWB, and MW9/6R). In November of 2018, Avoca
received a Notice of Violation (NOV) from the NC Division of Environmental Quality (NCDEQ) citing
exceedances of the 15A NCAC 2L groundwater standards in compliance monitoring wells. Specifically,
elevated ammonia concentrations have been detected in well MW -8, and elevated nitrate -nitrogen has
been detected at MW4 (Figure 1). The NCDEQ has cited Avoca in the past with similar notices, but
Avoca provided supplemental information to NCDEQ that indicated that these exceedances likely were
not related to the spray irrigation activities. However, the most recent NOV (November 27, 2018) sent
to Avoca requests predictive calculations or modeling to demonstrate that compliance with the permit
boundary can be met.
Avoca contacted GMA to request hydrogeological consulting assistance at the site. GMA's scope of
work included the following:
• GMA reviewed available soil science and/or hydrogeologic description documents prepared to
support the original wastewater irrigation permit for the facility.
• GMA reviewed well construction records (where available) for monitoring wells at the facility.
• GMA reviewed water -level and water -quality data reports over the past two years.
• A GMA Hydrogeologist visited the Avoca facility to become familiar with the wastewater
treatment plant, the sprayfields, and the monitoring well locations.
GMA'
fhe Groundwater Experts
May 17, 2019
Mr. Brian Conner, O.R.C.
Avoca, LLC
PO Box 129
841 Avoca Farm Road
Merry Hill, NC 27957
4300 Sapphire Court, Suite 100
Greenville, North Carolina 27834
Telephone: [phone]
www.ama-nc.com
Apex and Gree
y' 6'
%•. ` `"s:?, . X19
RE: Avoca, LLC Wastewater Irrigation System Evaluation and Notice of Violation Response, Merry
Hill, Bertie County, NC
Dear Brian,
This letter presents GMA's hydrogeologic evaluation of the Avoca wastewater irrigation system (Figure
1). The wastewater irrigation system operated by Avoca, under Permit No. WQ0005910, includes
approximately 33 acres of spray irrigation areas that are permitted to receive up to 50,000 gallons per
day of treated wastewater. Avoca monitors groundwater levels and groundwater quality using 5
existing monitoring wells (MW -4, MW -5, MW -7, MWB, and MW9/6R). In November of 2018, Avoca
received a Notice of Violation (NOV) from the NC Division of Environmental Quality (NCDEQ) citing
exceedances of the 15A NCAC 2L groundwater standards in compliance monitoring wells. Specifically,
elevated ammonia concentrations have been detected in well MW -8, and elevated nitrate -nitrogen has
been detected at MW4 (Figure 1). The NCDEQ has cited Avoca in the past with similar notices, but
Avoca provided supplemental information to NCDEQ that indicated that these exceedances likely were
not related to the spray irrigation activities. However, the most recent NOV (November 27, 2018) sent
to Avoca requests predictive calculations or modeling to demonstrate that compliance with the permit
boundary can be met.
Avoca contacted GMA to request hydrogeological consulting assistance at the site. GMA's scope of
work included the following:
• GMA reviewed available soil science and/or hydrogeologic description documents prepared to
support the original wastewater irrigation permit for the facility.
• GMA reviewed well construction records (where available) for monitoring wells at the facility.
• GMA reviewed water -level and water -quality data reports over the past two years.
• A GMA Hydrogeologist visited the Avoca facility to become familiar with the wastewater
treatment plant, the sprayfields, and the monitoring well locations.

Mr. Conner
Page 2
• GMA measured the water -level depth and total depth at each monitoring well. Measurements
were made using an electronic water -level meter. GMA also inspected the well heads for
damage to well casings and/or the grout seal, and we collected photographs of the conditions at
each monitoring well.
• GMA observed surrounding land use and documented activities on nearby properties that may
affect groundwater quality.
• GMA reviewed top of well casing elevation survey data and well location data provided by Avoca
for each monitoring well.
GMA has prepared the following letter report describing the hydrogeologic conditions of the site. We
prepared updated equipotential maps of the water table surface, and we have described the estimated
hydraulic position (up -gradient, side -gradient, or down -gradient) of monitoring wells MW4 and MW8
relative to the locations of active spray irrigation fields. We also present our opinions on the possible
sources of the reported ammonia and nitrate concentrations.
Investigation Results
Site Visit and Well inspection
GMA reviewed available well construction data, water -level and water -quality documents, and survey
data for each monitoring well located at the site. GMA collected additional wastewater treatment plant
and sprayfield information, and we collected a "snap -shot' of monitoring well water levels during a site
visit on February 27, 2019. No well records for monitoring wells MW4, M W5, or MW6R/9 were
available or supplied to GMA. Well construction data for these wells was determined from a
combination of well tag information and by measuring the well depths with a water -level meter during
the site visit. The monitoring wells at the Avoca wastewater irrigation site are less than 25 feet in depth,
and they are screened into the Surficial Aquifer. No well construction issues were noted in the well
construction records, notes, or from site visit observations that would indicate compromised well
integrity. The existing wells appear to be in good working condition and have effective grout seals at the
land surface.
Historical Water Level Data Evaluation
GMA compiled hydrographs (Figure 2) of recorded water levels for each monitoring well at the site from
the past three years. These hydrographs establish the normal seasonal water -level fluctuations for the
monitoring well network. Water -level data are included as an attachment.
The monitoring well hydrographs reveal significant differences in seasonal water -level fluctuations for
some wells. For instance, monitoring wells MW7 and MWS experienced a larger drop in water levels
during summer of 2017 than occurred in MW4 and MW5 during the same time period. GMA believes

Mr. Conner
Page 3
that the water levels in wells MW7 and MW8 are strongly influenced by the water level in Black Walnut
Swamp. Black Walnut Swamp is a non -tidal second -order stream that serves as a local groundwater
discharge area for the water table aquifer. A drop in water level in Black Walnut Swamp during
abnormally dry periods would lead to a corresponding watertable drop in areas close to the creek, such
as occurs at MW7 and MW8. In contrast, MW4 and MWS lie close to Salmon Creek, a 3rd order tidal
creek that essentially maintains a
constant water elevation. This constant head discharge area prevents significant seasonal variation in
the watertable in areas adjacent to Salmon Creek.
Water Table Mapping and Groundwater Flow Evaluation
To understand the detections of groundwater quality standard exceedances at MW4 and MW8, it is
imperative to understand the groundwater flow direction(s) at the site. GMA reviewed top of well
casing elevation survey data provided by Avoca for each monitoring well. We then utilized the static
water -level depth data collected on February 27, 2019, to prepare an equipotential map (water table
elevation contour map) (Figures 3). Survey and water -level data are included as an attachment. The
February 27, 2019, equipotential map indicates that the groundwaterflow direction across the
sprayfield property is toward the northeast. However, correlation of water levels between monitoring
wells does not considerthe effects of local groundwater discharge features (Black Walnut Swamp and
Salmon Creek). The water -level data collected from the monitoring wells only represents the extreme
northern and southern portions of the sprayfields in areas close to discharge features (streams).
The USGS topographic map (Figure 4) depicts a topographic high along State Road 1502 (Avoca Farm
Road). This high represents the local drainage basin divide separating the Salmon Creek and Black
Walnut Swamp drainages. In the North Carolina Coastal Plain, drainage basin divides often correspond
to groundwater flow divides forthe Surficial Aquifer. High grounds are areas of enhanced recharge, and
groundwater flow patterns in the Surficial Aquifer will flow from areas of recharge to local surface water
features that serve as discharge areas. GMA anticipates that groundwater south of SR 1502 flows south-
southeast toward Black Walnut Swamp. Similarly, groundwater north of SR 1502 flows toward the north
and east toward Salmon Creek. Unfortunately, there are no upgradient monitoring wells in the
monitoring well network to provide watertable elevation data near the divide. GMA utilized the
groundwater elevation data available from the existing 5 wells, and we prepared a watertable elevation
map utilizing only those 5 data points (Figure 3). Figure 5 depicts a general northeastern groundwater
direction. GMA believes that Figure 5 reasonably illustrates groundwater flow forthe area north of SR
1502. The three monitoring wells in that area (MW4, MW5, and MW6R/9) allow for local triangulation
to depict the gradient and direction of groundwater flow in the Surficial Aquifer in the vicinity of
Sprayfield 4. However, only two monitoring wells (MW7 and MW8) occur south of SR 1502. These two
wells, when correlated to the other three monitoring wells, indicate a northeastern groundwater flow
direction. This flow direction is inconsistent with Black Walnut Swamp being a local discharge area. The
USGS topographic map indicates that Black Walnut Swamp has an average elevation of approximately 3
to 4 feet above mean sea level. This is more than 6 feet lower elevation than the measured watertable

Mr. Conner
Page 4
at well MW8. Clearly, the water table elevations at MW7 and MW8 are higher than the average
elevation of Black Walnut Swamp, so groundwater in the vicinity of Sprayfield 5 would flow to the south-
southeast toward the swamp. However, the local vector and gradient of groundwater flow from
Sprayfield 5 toward Black Walnut Swamp cannot be determined without an upgradient monitoring well
near Sprayfield 5.
Water Quality Data Review
GMA reviewed historical and recent water -quality data (see attached) supplied by Avoca from the five
monitoring wells at the facility. Periodic exceedances of nitrate and ammonia have occurred in some of
the wells. Nitrate has been the persistent constituent detected in well MW4 at concentrations
exceeding the groundwater quality standards. However, well MW4 is across a permanent stream
(unnamed tributary to Salmon Creek). The stream is a groundwater discharge boundary that has lower
elevation than the water table monitored at MW4. Thus, MW4 is not within the groundwater flow
system associated with Sprayfield 4. Rather, MW4 is downgradient of the agricultural field to the south-
southeast. In contrast, well MWS occurs downgradient of Sprayfield 4, and MW5 is within the local
groundwater flow system associated with that sprayfield. Well MW5 does not exhibit nitrate
concentrations above the groundwater quality standard. It is apparent that the groundwater quality
monitored in well MW4 is not representative of conditions associated with wastewater irrigation at
Sprayfield 4. More likely, the occurrence of elevated nitrate observed at MW4 is a background
condition associated with farming activities south and southeast of well MW4.
Samples collected from well MW8 have periodically contained ammonia at concentrations exceeding
the "Interim Maximum Allowable Concentration' (IMAC) listed in the North Carolina Groundwater
Quality Standards (15A NCAC 02L). Although the effluent ammonia concentration (average of 0.16
mg/L) in wastewater applied to Sprayfield 5 is well below the IMAC (1.5 mg/L), the effluent does contain
elevated Total Kjeldahl Nitrogen (TKN) (average of 28.4 mg/L). TKN includes ammonia plus organic
nitrogen that can biodegrade in the soil to form ammonia. So, there is a potential that the elevated
ammonia at well MW8 could be related to wastewater application at Sprayfield 5. However, intensive
farming, including application of fertilizers, occurs on open fields north and west (upgradient) of
Sprayfield 5. Because there is no local monitoring well immediately upgradient of Sprayfield 5, the
background concentration of ammonia is unknown. A new upgradient monitoringwell is needed
northwest of Sprayfield 5 to better determine the local groundwater flow direction and to evaluate the
background concentrations of constituents of concern. Without this additional information, the source
of the elevated ammonia in well MW8 cannot be determined.

Mr. Conner
Page 5
Conclusions and Interpretations
Based upon GMA's evaluations of the Avoca, LLC wastewater irrigation system, we make the following
conclusions:
• Wastewater irrigation occur on two separate spray fields. Sprayfield 4 lies within the Salmon
Creek drainage basin, and Sprayfield 5lies within the Black Walnut Swamp drainage basin. The
drainage basin divide occurs near SR1502 (Avoca Farm Road).
• Groundwater in the Surficial Aquifer on the north side of SR1502 flows northeast toward Salmon
Creek, and groundwater flow on the south side of SR1502 flows south-southeast toward Black
Walnut Swamp.
• Well MWS, placed downgradient of Sprayfield 4, does not exhibit exceedances of the
groundwater quality standards for nitrate or ammonia, indicating that local wastewater
application at Sprayfield 4 is not a source of groundwater standards exceedances for those
constituents.
• Well MW4 has a history of groundwater standard exceedances for nitrate. This well lies across
an unnamed tributary of Salmon Creek from Sprayfield 4. The unnamed tributary is a
groundwater discharge area for the Surficial Aquifer. Therefore, MW4 is not within the same
local groundwater system as Sprayfield 4. Elevated nitrate concentrations observed at MW4 are
more likely associated with farming activities on immediately adjacent properties to the south.
GMA's opinion is that the groundwater quality conditions exhibited by MW4 are a background
condition that is not associated with wastewater application at Sprayfield 4.
• Sprayfield 5 has two local monitoring wells (MW7 and MW8) that lie side gradient and
downgradient (respectively) from Sprayfield 5. However, Sprayfield 5lacks a local upgradient
monitoring well to constrain the direction and gradient of groundwater flow in the area.
Furthermore, without a local upgradient monitoring well northwest of Sprayfield 5, GMA cannot
determine the background concentrations of constituents of concern. Without this information,
we cannot determine if the reported ammonia concentrations at MW8 are associated with
wastewater application to Sprayfield 5 or if the ammonia is related to background conditions
associated with farming activities north and west of Sprayfield 5.
GMA recommends the following activities to help address requirements of the November 27, 2018 NOV:
• Construct one new monitoring well on the north-northwest side of Sprayfield 5. This
monitoring well will serve as a local upgradient well to constrain the local groundwater flow
direction and gradient and to establish the background water -quality conditions in the area.
• Survey the location and elevation of the top of the well casingforthe new monitoring well.
• Conduct an updated monitoring event to include water level measurements and water -quality
sampling of all wells. Utilize the new monitoring data to refine the groundwater flow
understanding as well as to determine the background water -quality near Sprayfield 5.

Mr. Conner
Page 6
If background monitoring near Sprayfield 5 indicates that the ammonia at MW8 is associated
with wastewater irrigation activities, then steps should be taken to improve water treatment to
reduce TKN in the effluent before the effluent is land applied.
GMA appreciates the opportunity to provide consulting services to Avoca. If requested, we will be
happy to assist with monitoring well construction and further evaluation to address the requirements of
the November 2018 NOV.
Please contact me with any questions that you may have.
Sincerely,
Groundwater Management
SEAL ;p
Kelley A. mith,P.G. � 2355.
Project Hydrogeologist :7C _ C
CC: John Wise, P.E. —GMA 1, NA
James K, Holley, P.G. - GMA °°°�s°,�„f`PO�i
ZAGMA\162501 Avoca Farms -Merry Hill\REPORT\Avoca NOV Evaluation 20190430.dccx

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