WQ0030998_Staff Report_20230110

DocuSign Envelope ID: 35D83361-39DD-42E8-B9FC-EA600406BAA8
Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
January 10, 2023
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: Triple S Farms WQ0030998
Attn: Cord Anthony Facility name: Triple S Farms & Cleaning Inc.
From: Geoff Kegley
Wilmington 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.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 1/5/2023
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.
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: 35D83361-39DD-42E8-B9FC-EA600406BAA8
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: 15 sources, 1,154
maximum dry tons per year total, 9 fields with 147.4 net acres for application.
Proposed modifications: Addition of 17 new application fields for additional 151.62 acres. This will
bring the total acres available for land application to 299.02.
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 in section V. 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 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? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
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DocuSign Envelope ID: 35D83361-39DD-42E8-B9FC-EA600406BAA8
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 n 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
O ,
„
0
I
I,
O ,
,I
0
I
I,
O ,
„
0
I
I,
O ,
„
0
I
I,
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„
0
,
„
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) n Currently under JOC
❑ Notice(s) of violation ❑ 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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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: ) 1-DocuSigned by:
6. Signature of report preparer:
1/10/2023
'-0017E2515D3B417...
Signature of regional supervisor: DocuSigned by
Date: 1/10/2023 Mtt4e114 S44.6A
E3ABA14AC7DC434...
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14
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The permittee proposes to add the following new application fields to the permit:
• Jonathan Smith Farm, Fields JS-1 through JS-4
• Lonnie Thigpen Farm, Field LT-1
• Scott Thigpen Farm, Fields ST-1 and ST-2
• Mike Williams Farm, Fields MW-1 though MW-9
This will bring the total net acres available for land application to 299.02 acres.
On January 5, 2023, a site visit to all the proposed fields was conducted. Buffer setbacks
shown on the maps were verified in the field. Depth to the SHWT was spot checked and
confirmed to be >12 inches and matched the reported soil series for all fields, with one
exception. A portion of Field JS-2 at the Jonathan Smith Farm was deemed marginal due to
a shallow water table and it was decided to remove this section of the field. One new
house with a water supply well that was under construction was observed near the Scott
Thigpen farm and this was added to the buffer setback maps. On January 9, 2023, Bob
Branch sent modified maps and application forms to depict these changes (see attached).
Observation of the application fields showed they were well maintained and should be well
suited for the proposed residuals application activities.
Previous annual reports indicate currently permitted field's loading rates for metals and
PAN are being 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.
After review of the submitted permit application, the WiRO has no objection to permitting
the additional land for the application of residuals.
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