WQ0030998_Staff Report_20221028

DocuSign Envelope ID: 69E65AA5-F9C5-4080-9220-05C78C50F2E1
State of North Carolina
®r- Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
October 28, 2022
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Erick Saunders
From: Geoff Kegley
Wilmin on 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 gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
a. Date of site visit:
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. Afe the tfeatment faeilifies
for- the t-fpe disposal
system? El Yes or- El No
new adeqttate
•
of waste a -ad
3. Are depth to
table, the
El Yes [z-1 No El N
site eendifiens (soils,
wa4er- ete) eensistent with
s4mi4ed r-epot4s?
if no, please
4. Do the
the 1'
ells, ete.)? E] Yes E] No
pla-as a -ad site triap represent
aettial site (pr-epef�y
ifno, please explaiw
FORM: WQROSSR 04-14 Pagel of 5

DocuSign Envelope ID: 69E65AA5-F9C5-4080-9220-05C78C50F2E1
i
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, 959
maximum dry tons per year total, 9 fields with 147.4 net acres for application.
Proposed modifications: Addition of three new sources: Swansboro WWTP with 110 dry
tons/year, Summerhouse WRF with 35 dry tons/year, and Northwest Regional WRF with 50 dry
tons/year for a total of 1,154 dry tons/year.
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.) See Narrative below.
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 ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
FORM: WQROSSR 04-14 Page 2 of 5

DocuSign Envelope ID: 69E65AA5-F9C5-4080-9220-05C78C50F2E1
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ 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 necessarv):
Monitoring Well
Latitude
Longitude
0 / //
0 I II
0 / lI
0 I II
0 / //
0 I II
0 / lI
0 I II
0 / 11
0 I //
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: The 2021 annual report was deemed compliant.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
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.)
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?
❑ Yes ❑No®N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14 Page 3 of 5

DocuSign Envelope ID: 69E65AA5-F9C5-4080-9220-05C78C50F2E1
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
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
® Issue
❑ Deny (Please state reasons: D'Signed by:
6. Signature of report preparers
Signature of regional supervisor: -TO"
Date: 10/28/2022 7F141E73MF3456
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Q # k =d'-=d 10/28/2022
FORM: WQROSSR 04-14 Page 4 of 5

DocuSign Envelope ID: 69E65AA5-F9C5-4080-9220-05C78C50F2E1
The Dermittee proposes to add three new sources: Swansboro WWTP with 110 d
tons/year, Summerhouse WRF with 35 dry tons/year, and Northwest Regional WRF with 50
dry tons/year for a total of 1,154 dry tons/year.
Previous annual resorts indicate field loadine rates for metals and PAN are bei
calculated, along with cumulative pollutant loading rates which are consistently compliant.
Prior site visits and inspections have shown the residuals land application program is well
managed.
An expedited review of the permit application and permit issuance is requested, as the
facilities are in need of hauling sludge to maintain treatment plant efficiency and
compliance with effluent limits.
The laboratory analytical results were well within limits for the three new sources, however
were completed in 2021. Updated analyses should be completed for these sources prior to
land application to ensure the reaulatory limits are met.
After review of the submitted permit application, the WiRO has no objection to permitting
the additional sources of residuals.
FORM: WQROSSR 04-14 Page 5 of 5