WQ0030998_Staff Report_20210302

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Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
March 2, 2021
To: n NPDES Unit ® Non -Discharge Unit
Attn: Erick Saunders
From: Geoff Kegley
Wilmington Regional Office
Application No.: Triple S Farms WQ0030998
Facility name: Triple S Farms & Cleaning Inc.
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? n Yes or ® No
a. Date of site visit:
b. Site visit conducted by:
c. Inspection report attached? n Yes or ® No
d. Person contacted: Bob Branch and their contact information: (336) 510- 0340
a. Driving directions: I-40 to exit 373 - Hwy 903, head East, turn right onto Leonard Rich Road, gated entrance on
right.
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 shcct to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Arc the new treatment facilities adequate for the type of waste and disposal system? n Yes or n No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? n Yes n No n N/A
If no, please explain:
'I. Do the plans and site map represent the actual site (property lines, wells, etc.)? n Yes n No n N/A
If no, please explain:
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5. Is the proposed residuals management plan adequate? n Ycs n No n N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? n Yes n No n N/A
If no, please explain:
7. Arc there any setback conflicts for proposed treatment, storage and disposal sites? n Yes or n No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? n Ycs n No n N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? n Yes n No n 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: Eric Smith Certificate #: 23352 Backup ORC: Bob Branch Certificate #:15676
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or n No
If no, please explain:
Description of existing facilities: Class B residuals land application program: 10 sources, 707
maximum dry tons per year total, 9 fields with 130.1 net acres for application.
Proposed flow: n/a
Current permitted flow: n/a
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 n No
If no, please explain:
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.)? n Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or n No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or n No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? n Yes n 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? n Yes or ® No
If yes, attach a map showing conflict areas.
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9. Is the description of the facilities as written in the existing permit correct? ® Yes or n No
If no, please explain:
10. Were monitoring wells properly constructed and located? n Yes n No ® N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? n Yes n No Z N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or n No
Please summarize any findings resulting from this review:
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
Application requests a decrease in TCLP sampling to one per permit cycle for all sources except
for Wallace and Clayton. No TCLP exceedances have been observed, regional office supports
this requests.
13. Are there any permit changes needed in order to address ongoing BIMS violations? n Yes or ® No
If yes, please explain:
14. Check all that apply:
® No compliance issues n Current enforcement action(s) n Currently under JOC
❑ Notice(s) of violation n Currently under SOC n 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? n Yes n No ® N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
nYes nNoZN/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):
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IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? n Yes or Z 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
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
5. Recommendation: n Hold, pending receipt and review of additional information by regional office
n Hold, pending review of draft permit by regional office
n Issue upon receipt of needed additional information
® Issue
n Deny (Please state reasons: ) ,—DocuSigned by:
3/2/2021
6. Signature of report preparer:
Signature of regional supervisor:
Date: 3/3/2021
,—DocuSigned by:
Moults 5M.a
`— E3ABA14AC7DC434...
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
`—0017E2515D3B417...
The permittee proposes to decrease the maximum dry tons per year for three sources and
increase the maximum for four sources, for a new net total of 939 dry tons/year.
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In 2019, only 262.65 total dry tons were land applied. This was well below the 707 dry
tons/year currently permitted. Field loading rates for metals and PAN are being calculated,
along with cumulative pollutant loading rates which are all compliant.
After review of the submitted permit application, previous annual reports, residuals
analysis of the sources and PAN loading rates, the WiRO has no objection to renewal of the
permit and the proposed modifications.
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