WQ0014756_Staff Report_20220909

RE ,
September 9, 2022
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00014576
Attn: Alys Hannum Facility name: Trinity American WWTF
From: Caitlin Caudle
Winston-Salem 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.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 03/09/2022
b. Site visit conducted by: C. Caudle
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Jeff Wyatt and their contact information: [e-mail]
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
The system is adequate for the treatment of domestic wastewater.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
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
5. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
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
MW2
35.8684
-79.9106
12. 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: Chronic violations for high flows.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
FORM: WQROSSR 04-14 Page 1 of 2

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.)
The most recent NOV NOI for high flows is attached.
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?
There have been chronic issues with high flow events. The facility has taken efforts to install low flow devices in
some buildings and automatic shut offs in some areas. A mobile restroom has also been purchased to reduce flows
to the WWTF.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
® Yes ❑No❑N/A
If yes, please explain: A definite plan of action to reduce flow, increase the capacity of the WWTF, or connect to
city sewer should be made.
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
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
Attachment L -Setback
Setback waivers were not included in the permit application. Based on the last
waivers
permit there are several waivers.
Plan of Action to return
flows to compliance
Provide the check list mentioned in provided engineer document.
3. 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-,
aned by:
4. Signature of report preparer:
Signature of regional supervisor:
Date: 9/12/2022
L-o.,,, T.
145B49E225C94EA...
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
In communications with Mr. Drye, he has installed low flow features in some buildings and shut off valves on the
water meters when high flows are registered. A mobile restroom has also been purchased and placed on the property
to lessen the burden on the WWTF.
Multiple NOV NOIs have been issued for the chronic high flows. The most recent NOV NOI is attached.
The most recent inspection report is attached.
FORM: WQROSSR 04-14 Page 2 of 2

Compliance Inspection Report
Permit: WQ0014756 Effective: 09/01/17 Expiration: 08/31/22 Owner: Trinity American Corporation
SOC: Effective: Expiration: Facility: Trinity American Corporation WWTF
County: Randolph 5275 Glenola Industrial Dr
Region: Winston-Salem
Archdale NC 27263
Contact Person: Eric M Drye Title: President Phone: [phone]
Directions to Facility:
System Classifications: SI,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 02/22/2022
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Certification:
Phone:
Entry Time 10:05AM Exit Time: 12:15PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wastewater Irrigation
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent Miscellaneous Questions
Treatment Flow Measurement -Water Treatment Treatment Filters
Use Records
Record Keeping End Use -Irrigation Treatment Disinfection
Treatment Flow Measurement Storage Wells
(See attachment summary)
Page 1 of 7

Permit: WQ0014756 Owner -Facility: Trinity American Corporation
Inspection Date: 02/22/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On March 9, 2022, Division of Water Resources staff Caitlin Caudle conducted a scheduled compliance inspection. Jeff
Wyatt, ORC, of Geoscience and Technology was present during the entire inspection. A review of records, treatment
facilities, irrigation fields, and the monitoring well was completed. Irrigation was not viewed in operation due to the weather
conditions. This review reflected compliance with the subject permit.
The following items of concern were noted:
A. At the time of inspection, a PVC line had been installed from the storage tank to the irrigation pumps. Mr. Wyatt stated
that there was a clog in the original underground line that has yet to be repaired. No treatment units are being bypassed by
this PVC line. As this temporary PVC line is installed the storage tank must remain partially open. Please repair the original
line from the storage tank to the irrigation pumps as soon as possible. Permit Condition 111.1 states that the facility be
properly operated and maintained at all times.
B. To date, a permit renewal application has not been submitted. Per Permit Condition 1.1 a permit renewal application
must be submitted 6 months before the expiration of the current permit. Please submit a permit renewal application as soon
as possible. Failure to do so before the current permit expires is a violation of the subject permit.
C. Per Permit Condition 111.6 irrigation equipment shall be calibrated once per permit cycle. At the time of inspection, the
system had not been calibrated yet. Ms. Caudle discussed how to calibrate the system with Mr. Wyatt. Please calibrate the
system as soon as possible.
D. A lid on the septic tank closest to the treatment facility was broken. Please replace or repair the lid as soon as
possible.
Since the last inspection, influent has been reported using water meter records. There have been chronic issues with high
flows at this facility which are being addressed separately from this inspection. Mr. Wyatt stated the water meters record all
water usage at the facility including overground water usage from garden hoses. Mr. Wyatt said there is now someone that
comes by multiple times a week to monitor water usage at the facility. A water shut-off device has been installed on the
water meter supplying the two buildings with the highest usage. The shut off device must manually be turned back on, and
uses water pressure and a timer to shut off water if the pressure drops for a certain amount of time. Mr. Wyatt stated that
the additional monitoring and shut off device has cut water usage in half.
Mr. Wyatt stated that the Permittees have contracted an engineer to determine whether it is possible to expand the system,
and the possibility of connecting to municipal utilities. Ms. Caudle advised that the permit must still be renewed if
connecting to municipal utilities, as the system will be operated until final connections are made and a valid permit must be
maintained until the system is decommissioned.
The most recent Notice of Intent to Enforce and Civil Penalty Assessments were discussed.
Other observations:
• No pump and haul activities were recorded in the maintenance log since the last inspection.
• The small tree was removed from the sand filter.
• Suction pumps are present not pressure pumps.
• Mr. Wyatt is still operating the system using one pump instead of alternating the pumps.
• The control panel switches the irrigation zones every 90 minutes, rotating between Zones 2-7. If the float is up 220
gallons will be irrigated during that cycle.
• The sand filter is dosed every 60 minutes. If the float is up 200 gallons will be dosed.
• The system is automated and sends a daily irrigation file to the ORC.
• No residuals were removed from the system since the last inspection.
• The Winston Salem Regional Office phone number was added to the Spill Plan. The emergency reporting number was
listed.
• MW2 was in good condition.
• The 2021 soils analysis was reviewed. A lime amendment was still recommended. Mr. Wyatt stated that some lime was
applied last year but he is not sure of how much. The drip zones were established in a naturally forested area, and as a
result may have a lower pH. The wastewater being applied is not high strength and does not pose any concern to
Page 2 of 7

Permit: WQ0014756 Owner -Facility: Trinity American Corporation
Inspection Date: 02/22/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
significantly impacting the soil. Please continue to monitor the pH in the drip zones.
• Zinc in Z3 was 59. Sampling error could have caused the spike in Zn levels in 2020.
• The septic tank next to the Lane office building has an audible high water alarm.
• The septic tank next to the back building has an alarm wired into the building but there is no test button.
• All septic tanks are float controlled with pumps.
• The septic tank pumps do not have back up power.
• Per the O&M plan the septic tanks are checked twice a year and pumped as needed.
• Mr. Wyatt stated that 40% of the sand filter dose goes back to the septic tank and 60% goes to the chlorine contact
chamber.
• Based on field observations, the splitter box appeared to have many fine particles in it. As effluent was draining from the
sand filter there was a visible plume of fine particles being disturbed. Mr. Wyatt stated that the splitter box has never been
pumped.
• Flow was viewed through the contact chamber. There was obvious flow through the chlorine contact chamber, not a
trickle as seen in other tablet chlorinators. Based on the amount of flow viewed and the fecal results for the past few years,
there may not be adequate detention time to properly chlorinate the wastewater. Staff will continue to monitor the fecal
results.
• The storage tank will send a call out to the ORC when the high water alarm is triggered.
The rain sensor is on the roof of the pump house.
Page 3 of 7

Permit: WQ0014756
Inspection Date: 02/22/2022
Owner -Facility: Trinity American Corporation
Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Yes No NA NE
Reuse (Quality)
❑
Lagoon Spray, LR
❑
Infiltration System
❑
Single Family Spray, LR
❑
Activated Sludge Spray, LR
❑
Activated Sludge Spray, HR
❑
Recycle/Reuse
❑
Single Family Drip
❑
Activated Sludge Drip, LR
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? 0 ❑ ❑ ❑
Do all treatment units appear to be operational? (if no, note below.) ❑ ❑ ❑
Comment: The irrigation system was not viewed in operation due to the weather.
Treatment Flow Measurement -Influent
Yes No NA NE
Is flowmeter calibrated annually?
❑
❑ 0 ❑
Is flowmeter operating properly?
❑ ❑ ❑
Does flowmeter monitor continuously?
❑ ❑ ❑
Does flowmeter record flow?
❑ ❑ ❑
Does flowmeter appear to monitor accurately?
❑ ❑ ❑
Comment: Flow is measured by water meters.
Treatment Flow Measurement -Water Use Records Yes No NA NE
Is water use metered? 0 ❑ ❑ ❑
Are the daily average values properly calculated? 0 ❑ ❑ ❑
Comment:
Treatment Flow Measurement -Effluent Yes No NA NE
Is flowmeter calibrated annually? ❑ ❑ ❑
Is flowmeter operating properly? ❑ ❑ ❑
Does flowmeter monitor continuously? ❑ ❑ ❑
Does flowmeter record flow? ❑ ❑ ❑
Does flowmeter appear to monitor accurately? 0 ❑ ❑ ❑
Comment: Flow meter on irrigation system is only calibrated once per permit cycle.
Treatment Filters Yes No NA NE
Is the filter media present? 0 ❑ ❑ ❑
Page 4 of 7

Permit: WQ0014756 Owner -Facility: Trinity American Corporation
Inspection Date: 02/22/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is the filter media the correct size and type? 0 ❑ ❑ ❑
Is the air scour operational? ❑ ❑ 0 ❑
Is the scouring acceptable? ❑ ❑ 0 ❑
Is the clear well free of excessive solids? ❑ ❑ 0 ❑
Is the mud well free of excessive solids and filter media? ❑ ❑ 0 ❑
Does backwashing frequency appear adequate? ❑ ❑ 0 ❑
Comment: Sand filter.
Treatment Disinfection
Yes No NA NE
Is the system working?
❑
0 ❑ ❑
Do the fecal coliform results indicate proper disinfection?
❑
❑ ❑
Is there adequate detention time (>=30 minutes)?
❑
❑ ❑
Is the system properly maintained?
❑ ❑ ❑
If gas, does the cylinder storage appear safe?
❑
❑ ❑
Is the fan in the chlorine feed room and storage area operable?
❑
❑ ❑
Is the chlorinator accessible?
❑ ❑ ❑
If tablets, are tablets present?
❑ ❑ ❑
Are the tablets the proper size and type?
❑ ❑ ❑
Is contact chamber free of sludge, solids, and growth?
❑ ❑ ❑
If UV, are extra UV bulbs available?
❑
❑ ❑
If UV, is the UV intensity adequate?
❑
❑ ❑
# Is it a dual feed system?
❑
❑ ❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
❑
❑ ❑
If yes, then is there a Risk Management Plan on site?
❑
❑ ❑
If yes, then what is the EPA twelve digit ID Number? (1 000-- )
If yes, then when was the RMP last updated?
Comment: The fecal results for the past two nears are >2k MPN. When the chlorinator was viewed in
operation there was a steady flow through the contact chamber, not a slow trickle.
Record Keeping
Yes No NA NE
Is a copy of current permit available?
❑ ❑ ❑
Are monitoring reports present: NDMR?
❑ ❑ ❑
NDAR?
❑ ❑ ❑
Are flow rates less than of permitted flow?
❑
❑ ❑
Are flow rates less than of permitted flow?
❑
❑ ❑
Are application rates adhered to?
❑ ❑ ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
❑ ❑ ❑
Are all samples analyzed for all required parameters?
❑ ❑ ❑
Page 5 of 7

Permit: WQ0014756 Owner -Facility: Trinity American Corporation
Inspection Date: 02/22/2022 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Are there any 2L GW quality violations?
❑
0 ❑ ❑
Is GW-59A certification form completed for facility?
0
❑ ❑ ❑
Is effluent sampled for same parameters as GW?
❑
0 ❑ ❑
Do effluent concentrations exceed GW standards?
❑
0 ❑ ❑
Are annual soil reports available?
0
❑ ❑ ❑
# Are PAN records required?
❑
❑ 0 ❑
# Did last soil report indicate a need for lime?
0
❑ ❑ ❑
If so, has it been applied?
0
❑ ❑ ❑
Are operational logs present?
0
❑ ❑ ❑
Are lab sheets available for review?
0
❑ ❑ ❑
Do lab sheets support data reported on NDMR?
0
❑ ❑ ❑
Do lab sheets support data reported on GW-59s?
0
❑ ❑ ❑
Are Operational and Maintenance records present?
0
❑ ❑ ❑
Were Operational and Maintenance records complete?
0
❑ ❑ ❑
Has permittee been free of public complaints in last 12 months?
0
❑ ❑ ❑
Is a copy of the SOC readily available?
❑
❑ 0 ❑
No treatment units bypassed since last inspection?
0
❑ ❑ ❑
Comment: Flow rates have not been below permitted flow. Effluent is not analyzed
for VOCs.
End Use -Irrigation
Yes No NA NE
Are buffers adequate?
0
❑ ❑ ❑
Is the cover crop type specified in permit?
❑ ❑ ❑
Is the crop cover acceptable?
❑ ❑ ❑
Is the site condition adequate?
❑ ❑ ❑
Is the site free of runoff / ponding?
❑ ❑ ❑
Is the acreage specified in the permit being utilized?
❑ ❑ ❑
Is the application equipment present?
❑ ❑ ❑
Is the application equipment operational?
❑ ❑ ❑
Is the disposal field free of limiting slopes?
❑ ❑ ❑
Is access restricted and/or signs posted during active site use?
❑ ❑ ❑
Are any supply wells within the CB?
❑
❑ ❑
Are any supply wells within 250' of the CB?
❑
❑ ❑
How close is the closest water supply well?
❑
❑ ❑
Is municipal water available in the area?
❑
❑ ❑
# Info only: Does the permit call for monitoring wells?
❑ ❑ ❑
Are GW monitoring wells located properly w/ respect to RB and CB?
❑ ❑ ❑
Are GW monitoring wells properly constructed, including screened interval?
❑ ❑ ❑
Page 6 of 7

Permit: WQ0014756 Owner -Facility: Trinity American Corporation
Inspection Date: 02/22/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Are monitoring wells damaged?
Comment: Monitoring well was in good shape.
❑■❑❑
Page 7 of 7

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7020 3160 0002 0860 7839
Return Receipt Requested
Eric M Drye
Trinity American Corporation
601 Old Thomasville Rd
High Point, NC 27260
NORTH CAROLINA
Environmental Quality
July 19, 2022
SUBJECT: NOTICE OF VIOLATION & NOTICE OF INTENT TO ENFORCE
Tracking Number: NOV-2022-LV-0479
Permit No. WQ0014756
Trinity American Corporation WWTF
Randolph County
Dear Permittee:
A review of the March 2022 Non -Discharge Monitoring Report (NDMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
001 Flow, in conduit or thru 3/31/2022 800 968 Monthly Average Exceeded
treatment plant (50050)
Remedial actions, if not already implemented, should be taken to correct any noted problems. The Division of
Water Resources may pursue enforcement actions for this and any additional violations. If the violations are of a
continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial
construction activities, then you may wish to consider applying for a Special Order by Consent (SOC).
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9860

If you have any questions concerning this matter or to apply for an SOC, please contact Caitlin Caudle of the
Winston-Salem Regional Office at 336-776-9800.
Sincerely,
DocuSiTgned by:
%A. l . c%,,1 tf
1451349E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Cc: Jeff Wyatt, ORC (electronic copy)
Laserfiche File WQ0014756
WSRO Electronic Files
WQS Winston-Salem Regional Office - Enforcement File
NON -DISCHARGE Compliance/Enforcement Unit - Enforcement File
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9860