WQ0038087_Staff Report_20200908

DocuSign Envelope ID: C8258C63-68E1-450E-9503-A09F81178F6B
DE
September 8, 2020
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00038087
Attn: Ranveer Kates Facility name: Terra Renewal RLAP
From: Patrick Mitchell
Winston-Salem 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.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: September 2, 2020
b. Site visit conducted by: P. Mitchell and J. Henderson
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: David Coyle and their contact information: (479) 747 - 8192
e. Driving directions: See file.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes ❑ No ® NE
Explain: The majority of land application fields could not be evaluated due to standing corn crops. Small portions
that were observed appeared to be maintained and assimilating wastes.
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 ❑ No ® NE
Explain: Again, majority of fields could not be reviewed in detail due to standing corn crops. No obvious changes
were noted from the reconnaissance review.
Is the residuals management plan adequate? ® Yes or ❑ No
Note: Permitted annual dry tonnage will continue to be ,greater than what the permitted land application sites will
accommodate. Application indicates land application in South Carolina and the proposed new storage facilities
under this permit will be utilized to accommodate shortage in disposal acreage.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
Note: There were a number of existingland and application fields that are being modified due to the elimination of old
property line buffers. These areas could not be evaluated due to standing corn crops in fields. The WSRO will
need to review these new areas during future compliance inspections.
9. Are there any setback conflicts for proposed storage? ❑ Yes or ® No
10. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
11. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
FORM: WQROSSR 04-14 Pagel of 3

DocuSign Envelope ID: C8258C63-68E1-450E-9503-A09F81178F6B
12. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
13. Has a review of all self -monitoring data been conducted (e.g., Annual Reports)? ® Yes or ❑ No
14. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
15. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑Yes®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Frac Tank notes and
Keep the permit notes and footnote on Frac Tanks in the renewed permit due to
footnote.
shortage of acreage and 100% row crop fields.
Records on rainfall
Recommend adding a condition or footnote for the new storage facilities.
discharges from secondary
Maintain records (date, time, estimated volume, etc.) for rainfall discharges
containment.
from the secondary containment.
Storage Records
Recommend adding records requirement for new storage units (e.g. freeboard,
rainfall, etc.).
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
❑ DenX (Please state reasons: )
o uSigned by:
6. Signature of report preparers DoauSigned by:
Signature of regional supervi a548MCO265c47A... Luti 't
Date: September 8, 2020
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
5"Jt'
145B49E225C94EA._.
On September 2, 2020 WSRO staff conducted site visits to the proposed new storage facilities and to existing land
application fields with proposed modifications (e.g. removal of old property line buffers) for a review associated with
an application for permit renewal and modification. None of the residuals source facilities were visited during this
review. Below is a summary of notes from the review.
• The subject permittee continues to have insufficient land application acreage to support the permitted annual
dry tons based upon submitted PAN concentrations in residuals. The permittee has provided plan to utilize a
SCDHEC Permit for land application and storage, along with the proposed new storage facilities to be covered
under this permit as the alternative means to accommodate insufficient acreage in this permit.
• Recommend that the permit notes and footnote concerning Frac Tanks remain in the renewed permit due to
100% of permitted land being row crop and the shortage of acreage in the permit.
FORM: WQROSSR 04-14 Page 2 of 3

DocuSign Envelope ID: C8258C63-68E1-450E-9503-A09F81178F6B
• The proposed new storage facilities appear to be adequate and the proposed location also appears to be suitable
based upon information provided in the application.
• The proposed new storage facilities include a secondary containment berm with a locked manual valve to
release rainfall from the structure. Recommend that the new permit include a condition that they track releases
from this secondary containment structure in order to track the prevention of any release of residuals. Also
recommend that weekly freeboard, rainfall, etc. be tracked for the proposed storage units.
• A total of 13 sites include land application fields with modified site maps (mainly old property line buffers that
have been removed). These sites could not be reviewed due to standing corn crops present in fields. These fields
will need to be reviewed by WSRO staff during compliance inspections. See "WQ0038087 Field Notes
20200902" for a list of the subject sites and modifications.
FORM: WQROSSR 04-14 Page 3 of 3

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: 09/02/2002 Entry Time 10:OOAM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Exit Time: 02:OOPM
Phone: [phone]
Justin L Henderson
Reason for Inspection: Other Inspection Type: Reconnaissance
Permit Inspection Type: Land Application of Residual Solids (503 Exempt)
Facility Status: ❑ Compliant ❑ Not Compliant Neither
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 09/02/2002 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On September 2, 2020 WSRO staff conducted site visits to the proposed new storage facilities and to existing land
application fields with proposed modifications (e.g. removal of old property line buffers) for a review associated with an
application for permit renewal and modification. None of the residuals source facilities were visited during this review. See
Staff Report dated 9/08/2020 for details from the review.
Of note for future compliance inspections listed below.
• The subject permittee continues to have insufficient land application acreage to support the permitted annual dry tons
based upon submitted PAN concentrations in residuals. The permittee has provided plan to utilize a SCDHEC Permit for
land application and storage, along with the proposed new storage facilities to be covered under this permit as the alternative
means to accommodate insufficient acreage in this permit.
• Recommend that the permit notes and footnote concerning Frac Tanks remain in the renewed permit due to 100% of
permitted land being row crop and the shortage of acreage in the permit.
• The proposed new storage facilities include a secondary containment berm with a locked manual valve to release rainfall
from the structure. Recommend that the new permit include a condition that they track releases from this secondary
containment structure in order to track the prevention of any release of residuals. Also recommend that weekly freeboard,
rainfall, etc. be tracked for the proposed storage units.
• A total of 13 sites include land application fields with modified site maps (mainly old property line buffers that have been
removed). These sites could not be reviewed due to standing corn crops present in fields. These fields will need to be
reviewed by WSRO staff during compliance inspections. See "WQ0038087 Field Notes 20200902" for a list of the subject
sites and modifications.
Page 2 of 3

Permit: WO0038087
Inspection Date: 09/02/2002
Type
Distribution and Marketing
Land Application
Owner - Facility: Terra Renewal Services Inc
Inspection Type : Reconnaissance Reason for Visit: Other
Yes No NA NE
Page 3 of 3

Mitchell, Patrick
From: David Coyle <[e-mail]>
Sent: Thursday, September 3, 2020 4:48 PM
To: Mitchell, Patrick
Subject: [External] RE: [EXT]Terra Renewal Permit Mod & Renewal (WQ0038087)
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
�[e-mail]
Patrick,
Answers to your questions are as follows:
1) The residuals analysis presented in the permit application for the Mathis-1 source were simply a hand mixture of
aliquots from the other active sources in the permit. In other words, we pulled grab samples for tankers coming
to the field on the same day and them mixed them in a container at a ratio that is indicative of the volume that
is typically land applied from each source (S parts Wilkesboro, 4 parts Harmony, 1 part Hunter Dairy, 1/10 part
Advance). I realize the N numbers on that sample were high, its was likely just the result of getting an unusually
high load at the field from either Wilkesboro or Harmony at the time and day we pulled the samples and mixed
them. I don't believe its indicative of the what the final Mathis-1 product will be on a regular basis because
there is no scientific reason for why that the concentration would increase just based on mixing them
together. We could redo it to confirm, but its all I have at the time so its what was submitted.
2) The residuals from the Mathis-1 facility will be sampled just prior to land application after thorough mixing (i.e.
the loads from each source will be comingled in the storage tanks, the loads will be pulled out of the storage
tanks and placed on a tanker, samples will be pulled from the blended product as they are loaded from the tank
or onto the spreading equipment in the field).
3) Public access to the storage site will be restricted via signage, which is address in Section VII of the O&M Plan for
the storage facility.
4) We currently have two frac tanks that are part of that operation. They are moved from field to field as the
operation moves. They are emptied between moves, but that really only involves pumping out any sludge that
is in the tanks and spreading it and is done at the land app site. It does not involve cleaning them out with
additional water or chemicals. We rarely, if ever, "clean out" the frac tanks. If we did, it would require someone
entering the tank (confined space) and using a pressure washer to blast the inner contents off the walls. The
wash water would likely be mixed with sludge and land applied. If there is a hiatus in the spreading (long
weather or cropping break), the frac tanks are emptied and kept on a permitted site. To my knowledge, there is
no specific location that is used for "cleaning" frac tanks. I can write a brief insert into the O&M plan that
addresses this and submit it.
Thanks for following up on this so quick. Call me if you want to discuss or if there is any other info that you need.
David Coyle
Environmental Manager
P.O. Box 1746, Watkinsville, GA 30677
Cell 479-747-8192
[e-mail]

Dena
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From: Mitchell, Patrick <Patrick.Mitchel [e-mail]>
Sent: Thursday, September 3, 2020 9:08 AM
To: David Coyle <[e-mail]>
Subject: [EXT]Terra Renewal Permit Mod & Renewal (WQ0038087)
David,
I was in the Wilkes County area yesterday. I made site visits to the fields with proposed modifications (changes mainly
due to old property line buffers going away) and a site visit to the proposed site for the new storage facilities. All of the
fields still had standing corn present so I was unable to review those. For the modified fields, I am going to recommend
proceeding with the permit and the inspector can review these during land application events as applicable. I did have a
few questions that I wanted to run by you, listed below.
1. How were the residuals sample results included in the application package for the proposed new storage
facilities (Mathis-1) generated?
2. How and when will residuals from the new Mathis-1 storage facility be sampled (e.g. just prior to land
application after thoroughly mixing)?
3. How will public access be restricted to the proposed new Mathis-1 storage site?
4. Are Frac Tanks still being cleaned out at times between uses, for storage, for moving, etc.? If so, how and where
is this being conducted? I think you were made aware, but we have had numerous complaints from multiple
sources downstream of the Mathis base operations. To date, we have been unable to determine the exact
source when the complaints come in. To cover you guys, I highly recommend including these Frac Tank cleaning
operations in the O&M Plan as to how and where it is to be done and contained to prevent discharge to surface
waters.
I apologize if some of the answers to the questions above are in the application package. Sorry if I overlooked them.
Once I have your responses on the items above, I will finish my staff report and send it on to Ranveer in our central
office.
Thanks,
Patrick
Patrick L. Mitchell, REHS, LSS
Soil Scientist
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environmental Quality
Phone: [phone]
Mobile: [phone]

Fax: [phone]
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
N-1c.'. -
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