WQ0030998_Staff Report_20240903

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

August 29, 2024

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, and 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: 08/28/2024_
b. Site visit conducted by: C. Coburn, T. Benson, G. Kegley
c. Inspection report attached? Yes or No
d. Person contacted: Bob Branch and their contact information: Bob Branch 336-312-9007
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? Yes or 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:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
Docusign Envelope ID: 7CDA266B-1E31-4265-9A96-F74D8C253033Docusign Envelope ID: 4E788D50-C5A0-4B61-976E-44BFF81B9F1FDocusign Envelope ID: 581834EF-4A1E-482D-A05F-E6FAF3F9FE8ADocusign Envelope ID: A3D188D4-BD74-482D-9E8C-CFC7AB626E7D
FORM: WQROSSR 04-14 Page 2 of 5
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? Yes No 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 No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes 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: 17 sources, 1,304
maximum dry tons per year total, 26 fields with 299.03 net acres for application.

Proposed modifications: Addition of 4 new application fields for additional 97.21 acres. This will
bring the total acres available for land application to 396.24 acres.

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:
Docusign Envelope ID: 7CDA266B-1E31-4265-9A96-F74D8C253033Docusign Envelope ID: 4E788D50-C5A0-4B61-976E-44BFF81B9F1FDocusign Envelope ID: 581834EF-4A1E-482D-A05F-E6FAF3F9FE8ADocusign Envelope ID: A3D188D4-BD74-482D-9E8C-CFC7AB626E7D
FORM: WQROSSR 04-14 Page 3 of 5
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
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
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 2023 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):

Docusign Envelope ID: 7CDA266B-1E31-4265-9A96-F74D8C253033Docusign Envelope ID: 4E788D50-C5A0-4B61-976E-44BFF81B9F1FDocusign Envelope ID: 581834EF-4A1E-482D-A05F-E6FAF3F9FE8ADocusign Envelope ID: A3D188D4-BD74-482D-9E8C-CFC7AB626E7D
FORM: WQROSSR 04-14 Page 4 of 5
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
See Section V Comments Field 12 should not be used until another site visit from WiRO staff is
conducted when soil work and site preparation are completed.

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: )
6. Signature of report preparer:
Signature of regional supervisor:
Date:

Docusign Envelope ID: 7CDA266B-1E31-4265-9A96-F74D8C253033
8/29/2024
Docusign Envelope ID: 4E788D50-C5A0-4B61-976E-44BFF81B9F1F
8/30/2024
Docusign Envelope ID: 581834EF-4A1E-482D-A05F-E6FAF3F9FE8A
8/30/2024
Docusign Envelope ID: A3D188D4-BD74-482D-9E8C-CFC7AB626E7D
8/30/2024
FORM: WQROSSR 04-14 Page 5 of 5
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

The permittee proposes to add the following new application fields to the permit:

 Todd Thigpen Farm, Field TT-1
 Todd Thigpen Farm, Field TT-2
 Eric Smith Property, Field 11
 Eric Smith Property, Field 12

This will bring the total net acres available for land application to 396.24 acres.

On August 28, 2024, WiRO staff visited the properties containing the four fields proposed to be added to
the permit. 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.

Observation of the proposed application fields TT-1 & TT-2 showed they were well maintained and should
be well suited for the proposed residuals application activities.

Both Fields 11 & 12 on the Eric Smith property need extensive soil work and site preparation prior to
being ready for land application of residuals with Field 11 requiring less work than Field 12. Field 12
appeared to be marginal based on a thick, dark organic layer on the surface with a shallow water table 14-
16 inches below ground surface. WiRO staff and Mr. Bob Branch discussed the feasibility of approving
Field 12 conditionally upon another WiRO staff visit after the soil work and site preparation are
completed. (Erick: Could you please discuss with Nathaniel if the conditional approval of Field 12 is
feasible or not?)

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 with conditional approval of Field 12.

Docusign Envelope ID: 7CDA266B-1E31-4265-9A96-F74D8C253033Docusign Envelope ID: 4E788D50-C5A0-4B61-976E-44BFF81B9F1FDocusign Envelope ID: 581834EF-4A1E-482D-A05F-E6FAF3F9FE8ADocusign Envelope ID: A3D188D4-BD74-482D-9E8C-CFC7AB626E7D