WQ0038087_NOD-2020-PC-0194_20200413

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 13, 2020
Mr. David Coyle, Regional Environmental Manager
Terra Renewal Services, Inc.
P.O. Box 1746
Watkinsville, GA 30677
Subject: Notice of Deficiency (NOD-2020-PC-0194)
Terra Renewal RLAP — 2019 Annual Report Review
Land Application of Class B Residuals (Non -Dedicated)
Permit No. WQ0038087
Wilkes County
Dear Mr. Coyle,
The Division of Water Resources (DWR) acknowledges receipt of your 2019 Annual Report for
the subject permit. A review of this report was conducted by DWR staff person Justin Henderson.
Review of the subject Annual Report reflects non-compliance with Permit No. WQ0038087. The
following deficiencies require your attention and action:
1) Failure to clearly demonstrate compliance with the Class B pathogen reduction
requirements in 15A NCAC 02T .1106 (a) and (c) in accordance with Permit Condition II.
(6). Samples collected during the first quarter monitoring period for all applicable source
facilities were received "out of the required temperature" per the included lab reports.
Samples shall be properly collected and maintained to allow for certifiable results to be
obtained and subsequently reported to demonstrate compliance.
2) Failure to conduct the Standard Soils Fertility Analysis (SSFA) for several permitted
application sites on which a residuals land application event occurred during 2019 in
accordance with Permit Condition IV. (5). A list of these permitted sites was submitted in
the explanation of non-compliance submitted with the subject report. While SSFA results
were also submitted for these sites, in the subject report, the analysis was not conducted
within the required monitoring period. Ensure all required future monitoring is conducted
per the frequencies established by the subject permit, and within the required monitoring
periods.
3) Failure to conduct and report separate SSFA results for application sites NC-WK-MRF-
20A and NC-WK-MRF-20B. The subject report included one SSFA result with a Sample
ID of MRF 20. Permit Condition IV. (5) requires that an SSFA be conducted on each land
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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application site listed in Attachment B on which a residuals application event will occur in
the respective calendar year. Included in the subject report were FSF & MFLSF(s) for both
application sites listed above, indicating each site received residuals application during
2019. Ensure SSFA are conducted on each application site listed in Attachment B as
required.
Along with the above described deficiencies the following items of concern also warrant your
attention:
a) The Annual Residual Sampling Summary Form (RSSF), specific to source facility River
Valley Animal Foods — Harmony, NC, reported Arsenic levels of 390 mg/kg for a sample
analyzed on August 26, 2019. Arsenic levels in excess of 75 mg/kg would constitute a
violation of the Ceiling Concentration Limit established in Permit Condition II. (5),
therefore prohibiting any residual application. However, upon review of the included lab
reports for the subject analysis, it was determined that 390 mg/kg was reported for
Aluminum as opposed to Arsenic concentration. It is imperative to ensure accurate data
transcription and reporting is achieved to prevent the possibility of incurring "false"
violations. All Cumulative Pollutant Loading rates that were calculated erroneously
utilizing an Arsenic result of 390 mg/kg shall be revised to accurate reflect the operations
conducted.
b) The RSSF, specific to source facility AdvancePierrre Foods — Claremont, NC, reported a
Molybdenum concentration of <190 mg/kg for a sample analyzed on October 14, 2019.
The Ceiling Concentration Limit for Molybdenum is 75 mg/kg in accordance with Permit
Condition II. (5). To clearly demonstrate compliance with all regulatory limits, the analysis
method utilized shall have a Limit of Quantitation (LOQ) of equal to or less than the
regulatory limits.
c) SSFA results for multiple application fields indicated that zinc accumulation has reached
levels of greater than 2000. Zinc accumulation in soils approaching levels greater than 2000
could be detrimental to crop production. Provided proper sample collection was conducted
and that zinc accumulation results are accurate, consideration should be given to removing
these sites from operations to prevent crop toxicity impacts.
d) The Annual Land Application Certification Form (ACF), submitted with the subject
Annual Report, indicated that 29 fields were utilized for land application during 2019,
however only 28 Field Summary Forms (FSF) and Annual Metals Field Loading Summary
Forms (MFLSF) were submitted with the subject report. Please provide a written
explanation for this discrepancy or submit an FSF and MFLSF for the application site that
was omitted form the subject report.
e) The subject annual report contained Standard Soils Fertility Analyses (SSFA) results
labeled with the following Sample IDs: M12 & 4. It is unclear as to what permitted
application fields these results are representative. Please provide a written clarification
indicating which permitted application sites are associated with the Sample IDs listed
herein.

f) The subject annual report contained two SSFA results labeled with a Sample ID of MF23,
however it is unclear which set of results is representative of permitted application sites
NC-WK-MF-23A and/or NC-WK-MF-23A. Please submit a written response that provides
clarification as to the proper correlation between SSFA results and the permitted
application site.
The Division requests that a written response be submitted within 60-days of receipt of this Notice,
that describes the corrective measures to be implemented, to prevent the reoccurrence of the above
described deficiencies, and that includes all additional information requested herein. An
announced compliance inspection is planned to be scheduled within the next 12 months. If you
have any questions regarding this letter, please contact Justin Henderson or me at [phone].
Sincerely,
D-ocu Siiggned by:
•ti
145B49E225C94EA...
Lon Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
cc: Luke Mathis, ORC- lsmathiskme.com
Laserfiche Files — (electronic copies)

Compliance Inspection Report
Permit: WQ0038087 Effective: 03/16/20 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: David Clayton Coyle
Secondary ORC(s):
On -Site Representative(s):
Certification: 995723 Phone: [phone]
Related Permits:
NC0005126 Tyson Farms Inc - Tyson Farms, Inc.
Inspection Date: 04/08/2020 Entry Time 08:OOAM
Primary Inspector: Justin L Henderson
Secondary Inspector(s):
Exit Time: 04:OOPM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Annual Report Review
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 4

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 04/08/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) acknowledges receipt of your 2019 Annual Report for the subject permit. A review of
this report was conducted by DWR staff person Justin Henderson. Review of the subject Annual Report reflects
non-compliance with Permit No. WQ0038087. The following deficiencies require your attention and action:
1) Failure to clearly demonstrate compliance with the Class B pathogen reduction requirements in 15A NCAC 02T .1106 (a)
and (c) in accordance with Permit Condition II. (6). Samples collected during the first quarter monitoring period for all
applicable source facilities were received "out of the required temperature" per the included lab reports. Samples shall be
properly collected and maintained to allow for certifiable results to be obtained and subsequently reported to demonstrate
compliance.
2) Failure to conduct the Standard Soils Fertility Analysis (SSFA) for several permitted application sites on which a
residuals land application event occurred during 2019 in accordance with Permit Condition IV. (5). A list of these permitted
sites was submitted in the explanation of non-compliance submitted with the subject report. While SSFA results were also
submitted for these sites, in the subject report, the analysis was not conducted within the required monitoring period.
Ensure all required future monitoring is conducted per the frequencies established by the subject permit, and within the
required monitoring periods.
3) Failure to conduct and report separate SSFA results for application sites NC-WK-MRF-20A and NC-WK-MRF-20B. The
subject report included one SSFA result with a Sample ID of MRF 20. Permit Condition IV. (5) requires that an SSFA be
conducted on each land application site listed in Attachment B on which a residuals application event will occur in the
respective calendar year. Included in the subject report were FSF & MFLSF(s) for both application sites listed above,
indicating each site received residuals application during 2019. Ensure SSFA are conducted on each application site listed
in Attachment B as required.
Along with the above described deficiencies the following items of concern also warrant your attention:
a) The Annual Residual Sampling Summary Form (RSSF), specific to source facility River Valley Animal Foods —
Harmony, NC, reported Arsenic levels of 390 mg/kg for a sample analyzed on August 26, 2019. Arsenic levels in excess of
75 mg/kg would constitute a violation of the Ceiling Concentration Limit established in Permit Condition II. (5), therefore
prohibiting any residual application. However, upon review of the included lab reports for the subject analysis, it was
determined that 390 mg/kg was reported for Aluminum as opposed to Arsenic concentration. It is imperative to ensure
accurate data transcription and reporting is achieved to prevent the possibility of incurring "false" violations. All Cumulative
Pollutant Loading rates that were calculated erroneously utilizing an Arsenic result of 390 mg/kg shall be revised to accurate
reflect the operations conducted.
b) The RSSF, specific to source facility AdvancePierrre Foods — Claremont, NC, reported a Molybdenum concentration of
<190 mg/kg for a sample analyzed on October 14, 2019. The Ceiling Concentration Limit for Molybdenum is 75 mg/kg in
accordance with Permit Condition II. (5). To clearly demonstrate compliance with all regulatory limits, the analysis method
utilized shall have a Limit of Quantitation (LOQ) of equal to or less than the regulatory limits.
c) SSFA results for multiple application fields indicated that zinc accumulation has reached levels of greater than 2000.
Zinc accumulation in soils approaching levels greater than 2000 could be detrimental to crop production. Provided proper
sample collection was conducted and that zinc accumulation results are accurate, consideration should be given to
removing these sites from operations to prevent crop toxicity impacts.
d) The Annual Land Application Certification Form (ACF), submitted with the subject Annual Report, indicated that 29 fields
were utilized for land application during 2019, however only 28 Field Summary Forms (FSF) and Annual Metals Field Loading
Summary Forms (MFLSF) were submitted with the subject report. Please provide a written explanation for this discrepancy
or submit an FSF and MFLSF for the application site that was omitted form the subject report.
e) The subject annual report contained Standard Soils Fertility Analyses (SSFA) results labeled with the following Sample
Page 2 of 4

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 04/08/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
IDs: M12 & 4. It is unclear as to what permitted application fields these results are representative. Please provide a written
clarification indicating which permitted application sites are associated with the Sample IDs listed herein.
f) The subject annual report contained two SSFA results labeled with a Sample ID of M1723, however it is unclear which set
of results is representative of permitted application sites NC-WK-MF-23A and/or NC-WK-MF-23A. Please submit a written
response that provides clarification as to the proper correlation between SSFA results and the permitted application site.
The Division requests that a written response be submitted within 60-days of receipt of this Notice, that describes the
corrective measures to be implemented, to prevent the reoccurrence of the above described deficiencies, and that includes
all additional information requested herein. An announced compliance inspection is planned to be scheduled within the next
12 months. If you have any questions regarding this letter, please contact Justin Henderson or me at [phone].
Page 3 of 4

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 04/08/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Page 4 of 4