WQ0030998_Staff Report_20220208

DocuSign Envelope ID: 31B30231-A6C4-43A4-914F-18B1C883B148
Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
February 8, 2022
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: Triple S Farms WQ0030998
Attn: Erick Saunders
From: Geoff Kegley
Wilmington Regional Office
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? ® Yes or ❑ No
a. Date of site visit: 2/3/2022
b. Site visit conducted by:
c. Inspection report attached? ['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 or continue to JB Stroud road and field 9 and 10 are on the 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 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? n Yes or n 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:
�. 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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DocuSign Envelope ID: 31B30231-A6C4-43A4-914F-18B1C883B148
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? n Yes n No n 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 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 Ti 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: 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 ❑ No
If no, please explain:
Description of existing facilities: Class B residuals land application program: 10 sources, 939
maximum dry tons per year total, 9 fields with 130.1 net acres for application.
Proposed modifications:Addition of two new sources: Town of Maysville with 15 dry tons/year and Town of
Bridgeton with 5 dry tons/year for a total of 959 dry tons/year. Slight modification of acreage for all
fields and one new land application field: Field 10 with 12.8 net acres for a new total of 148.5 acres
available for land application.
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 ❑ 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.)? ❑ 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 ❑ No
If no, please explain:
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DocuSign Envelope ID: 31B30231-A6C4-43A4-914F-18B1C883B148
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? n Yes or ® No
If yes, attach a map showing conflict areas.
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:
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
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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:
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
Application requests a decrease in TCLP sampling to once per permit cycle. No TCLP
exceedances have been observed, regional offices support this request.
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
n 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? ❑ Yes ❑ 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 ❑No®N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):
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DocuSign Envelope ID: 31B30231-A6C4-43A4-914F-18B1C883B148
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
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
5. Recommendation:
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
❑ Deny (Please state reasons: ) p-DocuSigned by:
2/8/2022
6. Signature of report preparer:
Signature of regional supervisor:
Date:
DocuSigned by:
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
-0017E2515D3B417...
FORM: WQROSSR 04-14
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DocuSign Envelope ID: 31B30231-A6C4-43A4-914F-18B1C883B148
The permittee proposes to add two new sources to their permit for a new net total of 959
dry tons/year. New sources are Town of Maysville with 15 dry tons/year and Town of
Bridgeton with 5 dry tons/year. The permittee is also requesting a decrease in sampling
frequency of TCLP analyses for both of these sources to once per permit cycle. The WiRO
and WaRO offices support approval of this request.
In addition, the permittee is requesting the addition of 12.8 acres in new field #10 and
modifications of existing field acreages due to site changes to bring the total permitted land
application fields to 148.5 net acres.
On February 3, 2022, Geoff Kegley performed a site visit to the new land application field
#10. No apparent setback issues were observed. The soils are mapped as mostly Norfolk
soils which have adequate separation to the SHWT, in addition to well -maintained
perimeter ditches to aid in lowering the water table. The new field appears well
maintained and should be a good receiver site for land application. Picture of field 10
attached below.
Previous annual reports indicate field loading rates for metals and PAN are being
calculated, along with cumulative pollutant loading rates which are consistently compliant.
After review of the submitted permit application, site maps, soils report, agronomist
report, residuals analysis and PAN loading rates, the WiRO has no objection to permitting
the additional sources of residuals, modification to the acreage of existing fields, and the
addition of field 10.
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DocuSign Envelope ID: 31B30231-A6C4-43A4-914F-18B1C883B148
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