WQ0030998_Staff Report_20231215

DocuSign Envelope ID: 024A9A83-5805-46OF-84E6-OF05E892D65A
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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
December 13, 2023
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: Triple S Farms WQ0030998
Attn: Erick Saunders Facility name: Triple S Farms & Cleaning Inc.
From: Chad Coburn, Tyler Benson
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 gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
a. Date of site visit: N/A
b. Site visit conducted by:
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: and their contact information:
a. Driving directions: I-40 to exit 373 - Hwy 903, head East, turn right onto Leonard Rich Road, gated entrance on
n ght.
FORM: WQROSSR 04-14 Page 1 of 5

DocuSign Envelope ID: 024A9A83-5805-46OF-84E6-OF05E892D65A
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, 26 fields with 299.03 net acres for application .
Proposed modifications: Addition of Webb Creek WWTP, NC0089877, 80 dry tons per year, and
North Topsail WWTP, WQ0005849, 70 dry tons per year for 1304 maximum dry tons per 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 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 ❑ 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:
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DocuSign Envelope ID: 024A9A83-5805-46OF-84E6-OF05E892D65A
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 necessary):
Monitoring Well
Latitude
Longitude
C
C
C
C
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 ❑ No
Please summarize any findings resulting from this review: The 2022 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):
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DocuSign Envelope ID: 024A9A83-5805-46OF-84E6-OF05E892D65A
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: ) t—DocuSigned by: DocuSigned by:
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14 Page 4 of 5

DocuSign Envelope ID: 024A9A83-5805-46OF-84E6-OF05E892D65A
The permittee proposes to add the following new application sources to the permit:
• Webb Creek WWTP NC0089877, Onslow County, 80 Dry Tons
• North Topsail WWTP WQ0005849, Onslow County, 70 Dry Tons
In 2022, they only applied a total of 600.21 dry tons, utilizing 139.9 acres of land
application fields (before the addition of the new fields from the previous permit
modification). The total net acres available for land application currently is 299.03 acres.
Acreage required using the 5 year maximum adjusted PAN concentration is 291.05 acres.
Total PAN available for V and 2nd crops is 92071.63 pounds. Pounds of PAN per year (5
year maximum adjusted) is 58209.84 pounds.
Previous annual reports indicate currently permitted field's loading rates for metals and
PAN along with cumulative pollutant loading rates have been 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 two additional sources for the application of residuals.
FORM: WQROSSR 04-14 Page 5 of 5