WQ0038087_Complaint Investigation_20200316

DocuSign Envelope ID: 3DO9DOB6-CFCO-4879-B633-842OA72C4B7D
ROY COOPER
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Governor
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MICHAEL S. REGAN
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Secretary
S. DANIEL SMITH
NORTH CAROLINA
Director
Environmental Quality
March 16, 2020
CERTIFIED MAIL 70181130 0000 1612 7253
RETURN RECEIPT REQUESTED
David Coyle, Regional Environmental Manager
Terra Renewal Services, Inc.
P.O. Box 1746
Watkinsville, Georgia 30677
Subject: Complaint Investigation — Request for Information
Terra Renewal - Class B RLAP
Permit No. WQ0038087
Wilkes County
Dear Mr. Coyle,
On March 10, 2020, staff of the North Carolina Division of Water Resources Winston-Salem
Regional Office (Division) conducted a complaint investigation of the subject residuals land
application program. This investigation occurred as result of an anonymous complaint alleging
nuisance odor conditions and residuals/waste runoff with discharge to surface waters from land
application activities located near address 3938 Bethel Rd., Jonesville, NC. This is the location of
the previously proposed residuals storage site, Pond #1 (Mathis-1). It should be noted that
Mathis-1 is not permitted for residuals storage under the subject permit and is currently permitted
by the Division's Animal Feeding Operation (AFO). The AFO permit prohibits other waste from
being placed in this storage structure. Mr. Luke Mathis, ORC, was present during the investigation.
During the investigation, evidence was observed of two distinctly different (i.e. differing in color,
consistency, and odor) residuals or waste products that do not appear to be produced by the dairy
cattle operation currently permitted by the Division's AFO unit. These residuals or waste products
were found to be present adjacent to and located in Mathis-1. When asked about the source of these
two distinct residuals or waste products, Mr. Mathis indicated that the primary product observed
during the investigation was agricultural processing residues from beverage processing at New
Belgium Brewing located in Asheville, NC. Mr. Mathis indicated that the other product observed
during the investigation was Class B residuals from the Tyson Farms, Wilkesboro source facility,
and that this product was present only due to spillage of residuals residues previously transported
in equipment.
Additional information is warranted to determine what violations, if any, have occurred. Please
provide the residuals tracking records for every approved residuals source facility listed in
the currently permitted Attachment A for the period of January 24, 2020 through March 10,
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

DocuSign Envelope ID: 3DO9DOB6-CFCO-4879-B633-842OA72C4B7D
2020, within ten (10) days of receipt of this letter. These records should include, but not be
limited to the following:
• The number of loads of residuals and volumes that Terra Renewal picked up from each
source facility during the requested time period, including date of pick up;
• The destination (e.g. SC permitted storage, SC land application, NC land application, other)
of each residuals load and volumes for each source facility during the requested time period,
including dates of destination; and
If residuals source(s) destinations included NC land application, please provide the
Site -Field Number(s) and the field loading records associated with these land application
events for each source facility.
Our office appreciates your attention to the above listed items. Please take actions necessary to
provide the information requested within the timeframe provided. If you have any questions
regarding this letter, please contact Patrick Mitchell or me at the letterhead address or phone
number, or by email at patrick.mitchellkncdenr.gov or Ion. sniderkncdenr. gov.
Sincerely,
Docu&gned by:
t.Jn. � ' 5"Jc
on 1..g�nider; Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: Wilkes County Environmental Health (Electronic copy)
Laserfiche Files (Electronic copy)
WSRO Files (Electronic copy)
Page 2 of 2

Compliance Inspection Report
Permit: WQ0038087 Effective: 06/29/18 Expiration: 01/31/21 Owner : Terra Renewal Services Inc
SOC: Effective: Expiration: Facility: Terra Renewal RLAP
County: Wilkes 615 Mathis Farm Rd
Region: Winston-Salem
Roaring River NC 28669
Contact Person: Mike Brooks Title: Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Luke Steven Mathis Certification: 1003524 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0005126 Tyson Farms Inc - Tyson Farms, Inc.
Inspection Date: 03/10/2020 Entry Time 08:30AM Exit Time: 12:30PM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Rebecca D Chandler
Reason for Inspection: Complaint Inspection Type: Complaint
Permit Inspection Type: Land Application of Residual Solids (503 Exempt)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 03/10/2020 Inspection Type: Complaint Reason for Visit: Complaint
Inspection Summary:
On March 10, 2020 WSRO staff conducted a complaint investigation of the subject facility. This investigation included two
site visits:
1- Source facility Hunter Farms
2- Proposed residuals storage facility "Mathis-1"
On March 9, 2020 WSRO staff from the AFO Unit investigated the Mathis-1 (i.e. former Myers Dairy) and determined that
the waste in question was not generated from the Permitted AFO facility. There were two distinct waste products found at
the site. Nearby land application sites were also investigated. The potential violations are listed at the bottom of this
summary. See photos in file.
March 10, 2020 Investigation Findings:
Hunter Farms source facility -
Representatives indicated that they have not had residuals hauled by the Permittee within the last 45 days or more.
Mathis-1 (i.e. former Myers Dairy) site -
Mr. Luke Mathis, ORC, accompanied staff on this portion of the investigation. The two wastes or residuals products were
observed in the storage pond and on the ground around the storage pond. Most likely in the loading/unloading areas.
- There was a very strong odor present at the time of investigation that resembled the Tyson residuals.
- Some of the residuals present on the ground around the storage pond and in the storage pond resembled the Tyson
residuals.
- The other residuals present on the ground and in the storage pond had a strawberry odor and was very different in
consistency vs the other residuals and cattle waste present from the AFO.
When questioned about the two wastes, Mr. Mathis indicated that the primary waste was from agricultural processing
residues from beverage processing at New Belgium Brewing located in Asheville, NC. He indicated that the other wastes
were residuals from the Tyson, Wilkesboro source facility. Mr. Mathis indicated that the Tyson residuals were only present
due to spillage of residues previously transported in equipment.
Residuals on the ground and in an unapproved storage structure is a violation of the subject permit.
Based on the quantity of Tyson residuals on the ground, the observation of residuals that appear to be from Tyson in the
storage pond, and the unknown wastes (similar to other sources in the subject permit), additional information is being
requested to determine what other violations may have occurred.
The following violations may have also occurred, should the requested records not clearly demonstrate otherwise:
• Waste runoff and discharge to surface waters was documented by AFO staff on 3/09/2020.
• Waste land application was documented by AFO staff on 3/09/2020 to non -permitted fields.
• Waste land applied was not injected or incorporated as required in the subject permit
• The land application field was not flagged for the appropriate buffer nor were required buffers maintained
• There was no crops present or planted in the application areas.
• No notification was made to the WSRO for this land application event.
• Public access was not restricted to this land application site.
• Unapproved storage may have occurred, if residuals tracking records for all source facilities can not be provided and/or do
not clearly demonstrate that no storage in this unpermitted structure has occurred.
If records demonstrate compliance, the violations (those applicable) that are listed above will be addressed through the AFO
Unit's permit.
Follow-up may be needed.
Page 2 of 3

Permit: WQ0038087
Inspection Date: 03/10/2020
Type
Distribution and Marketing
Land Application
Owner - Facility: Terra Renewal Services Inc
Inspection Type: Complaint Reason for Visit: Complaint
Yes No NA NE
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