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Home My WebLink AboutWQ0038087_NOD-PC-2022-1062_20221021ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality October 21, 2022 David Coyle - Environmental Manager Terra Renewal Services, Inc. P.O. Box 1746 Watkinsville, Georgia 30677 SUBJECT: Notice of Deficiency (NOD-2022-PC-0162) 2021 Residuals Annual Report Review Terra Renewal Residuals Land Application Program Permit No. WQ0038087 Wilkes County Dear Mr. Coyle: Division of Water Resources staff Caitlin Caudle completed a review of the 2021 Residuals Annual Report. Additional information was requested on May 10, 2022, and was received on May 24, 2022. An amended report was submitted on May 24, 2022. Ms. Caudle reviewed the amended report on September 19, 2022. This review reflected non-compliance of the subject permit. The following deficiencies were noted: Fields WK-MF-09 and WK-MF-23 were reportedly planted in small grain silage. The Plant Available Nitrogen (PAN) rate for small grain silage reported was 98 lbs/ac. The Realistic Yield Expectation (RYE) data base published by North Carolina State University recommends 95 lbs/ac for small grain silage. The reported PAN applied for WK-MF-09 was 96.89 lbs/ac, and the PAN applied for WK-MF-23 was 97.23 lbs/ac. Per Permit Condition II.11 this is a violation of the subject permit as application rates exceeded agronomic rates. Please provide an explanation for the reported PAN rates within 30 days of receipt of this letter. 2. Per Permit Condition IV.5, an annual representative soil analysis shall be conducted on each field listed in Attachment B that received residuals during the calendar year. The initial review of the 2021 Residuals Annual Report showed that copper, manganese, and acidity were not reported for all fields. In the additional information response Mr. Coyle stated that all soil samples were not analyzed for these parameters. This is a violation of the subject permit. DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�� o�.im, The following items of concern were noted: A. Field WK-MRF-03 reportedly received residuals in December 2020 and January 2021 for corn silage planted in Spring 2021. The 2020 Residuals Annual Report Annual Land Application Field Summary Form (ALAFSF) for this field reported a higher volume, and higher amount of PAN applied, than the 2021 ALAFSF for the month of December. Field WK-MRF-12 reportedly received residuals in December 2020 and January 2021 for corn silage planted in Spring 2021. The 2020 ALAFSF for this field reported a higher volume, and higher amount of PAN applied, than the 2021 ALAFSF for the month of December. Please provide a written explanation for these reporting discrepancy and the reported PAN rates within 30 days of receipt of this Notice. Report Year Field Application Timing Applied PAN ALAFSF PAN Rate 2020 WK-MRF-03 December 2020 131.595 143 Available PAN 11.405 2021 WK-MRF-03 December 2020 102.173 143 2021 WK-MRF-03 January 2021 39.624 143 Total PAN 141.797 2020 WK-MRF-12 December 2020 106.387 187 Available PAN 80.613 2021 WK-MRF-12 December 2020 76.906 187 2021 WK-MRF-12 January 2021 61.878 187 2021 WK-MRF-12 April 2021 31.6 187 Total PAN 173.384 B. Fields WK-MF-13, WK-MF-14, WK-MF-15, WK-MRF-20, and WK-RJ-05 received residuals in the Fall and Winter of 2021 for corn silage to be planted in Spring 2022. The nature of this program requires that all residuals be incorporated into the fields. Mr. Coyle stated that the fields were overseeded with a winter cover crop that was burned down before Spring 2022 planting. Permit Condition I1.13 states that if a field is to be over -seeded or double - cropped, the second crop can receive up to 50 lbs/ac/yr PAN if the second crop is to be harvested or grazed; if the second crop is to be planted for erosion control only and is to be tilled into the soil, then no additional PAN shall be applied. Please be mindful of this permit condition as operations continue. REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NORTH CAROLINA 336.776.9800 onparhnem of EmironmanW 9uallly C. WK-MRF-05 and WK-MRF-06 reportedly received residuals in December 2020 and January 2021. The volumes reported for December in the 2020 Residuals Annual Report to not correspond with the volumes reported in the 2021 Residuals Annual Report for both fields. There is no concern for over application for either field. D. PAN for WK-YK-YF-05 was reported as 120 lb/ac. This field has the county line for Wilkes and Yadkin running through it. The RYE lists PAN for FcC2 in Wilkes County as 80 lb/ac for small grain silage. The same soil type in Yadkin County (Fairview sandy clay loam, 8-15% slopes, moderately eroded) has a map unit of FdC2. The RYE lists 80 lb/ac for small grain silage for this map unit. There is no concern for over application. Please be mindful of this updated application rate. Please provide justification if 120 lbs/ac is used again. E. PAN for MF-10 for small grain silage was reported as 98 lbs/ac in the Executive Summary. The RYE lists PAN for small grain silage as 95 lbs/ac for FcB2. Please be mindful of this updated application rate. Please provide justification if 98 lbs/ac is used again. F. PAN for MF-13 and RJ-07 for corn silage was reported as 214 lb/ac in the Executive Summary. The RYE database lists PAN for corn silage as 207 lb/ac for Fc132. Please be mindful of this updated application rate. Please provide justification if 214 lbs/ac is used again. G. The sampling event for Mathis Storage on 8/26 molybdenum was reported as <160 mg/kg, the ceiling concentration for manganese is 75 mg/kg. No residuals were applied from the storage tank. Moving forward, be sure that the laboratory method used has a reporting limit below the ceiling concentration. Please refer to the enclosed inspection report for additional comments and observations. Be mindful of the requested response in Item 1 and Item A. If you have any questions, please contact me or Caitlin Caudle at the letterhead address or phone number, or by email at lon.snider@ncdenr.gov or caitlin.caudleOncdenr.gov. Sincerely, EDocuSiTG gned by: LOti 1 . Jn Jtr 945B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ - WSRO Enc: Inspection Report Cc: Luke Mathis, ORC (electronic copy) Wilkes County Environmental Health (electronic copy) Laserfiche File WQ0038087 WSRO Electronic Files North Carolina Department of Environmental Quality I Division of Water Resources D �� Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NCRTH CARCLINA ^ 336.776.9800 0_p Mo Emimnmen quay Compliance Inspection Report Permit: WQ0038087 Effective: 04/25/22 Expiration: 11/30/27 Owner : Terra Renewal Services Inc SOC: Effective: Expiration: Facility: Terra Renewal Services Class B Residuals Proi, County: Wilkes 615 Mathis Farm Rd Region: Winston-Salem Roaring River NC 28669 Contact Person: Mike Brooks Title: Phone: 479-668-4036 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: WQ0001077 Innospec Active Chemicals LLC - Innospec Active Chemicals - Salisbury WWTF NC0006548 Wayne Farms LLC - Dobson Plant NC0005126 Tyson Farms Inc - Harmony Rendering Plant Inspection Date: 09/19/2022 Entry Time 08:OOAM Exit Time: 04:30PM Primary Inspector: Caitlin Caudle E68B834968199D49D... Do��s'y�ed by: Phone: 336-776-9699 Secondary Inspector(s): UV, l�D& 10/21/2022 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 Record Keeping Sampling Pathogen and Vector Attraction (See attachment summary) Page 1 of 5 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 09/19/2022 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: Division of Water Resources staff Caitlin Caudle completed a review of the 2021 Residuals Annual Report. Additional information was requested on May 10, 2022, and was received on May 24, 2022. An amended report was submitted on May 24, 2022. Ms. Caudle reviewed the amended report on September 19, 2022. This review reflected non-compliance of the subject permit. The following deficiencies were noted: 1. Fields WK-MF-09 and WK-MF-23 were reportedly planted in small grain silage. The Plant Available Nitrogen (PAN) rate for small grain silage reported was 98 Ibs/ac. The Realistic Yield Expectation (RYE) data base published by North Carolina State University recommends 95 Ibs/ac for small grain silage. The reported PAN applied for WK-MF-09 was 96.89 Ibs/ac, and the PAN applied for WK-MF-23 was 97.23 Ibs/ac. Per Permit Condition 11.11 this is a violation of the subject permit as application rates exceeded agronomic rates. Please provide an explanation for the reported PAN rates. 2. Per Permit Condition IV.5, an annual representative soil analysis shall be conducted on each field listed in Attachment B that received residuals during the calendar year. The initial review of the 2021 Residuals Annual Report showed that copper, manganese, and acidity were not reported for all fields. In the additional information response Mr. Coyle stated that all soil samples were not analyzed for these parameters. This is a violation of the subject permit. The following items of concern were noted: A. Field WK-MRF-03 reportedly received residuals in December 2020 and January 2021 for corn silage planted in Spring 2021. The 2020 Residuals Annual Report Annual Land Application Field Summary Form (ALAFSF) for this field reported a higher volume, and higher amount of PAN applied, than the 2021 ALAFSF for the month of December. Field WK-MRF-12 reportedly received residuals in December 2020 and January 2021 for corn silage planted in Spring 2021. The 2020 ALAFSF for this field reported a higher volume, and higher amount of PAN applied, than the 2021 ALAFSF for the month of December. Please provide a written explanation for these reporting discrepancy and the reported PAN rates within 30 days of receipt of this Notice. Report Year Field Application Timing Applied PAN ALAFSF PAN Rate 2020 WK-MRF-03 December 2020 131.595143 Available PAN 11.405 2021 WK-MRF-03 December 2020 102.173143 2021 WK-MRF-03 January 2021 39.624 143 Total PAN 141.797 2020 WK-MRF-12 December 2020 106.387187 Available PAN 80.613 2021 WK-MRF-12 December 2020 76.906 187 2021 WK-MRF-12 January 2021 61.878 187 2021 WK-MRF-12 April 2021 31.6 187 Total PAN 173.384 B. Fields WK-MF-13 , WK-MF-14 , WK-MF-15 , WK-MRF-20 , and WK-RJ-05 received residuals in the Fall and Winter of 2021 for corn silage to be planted in Spring 2022. The nature of this program requires that all residuals be incorporated into the fields. Mr. Coyle stated that the fields were overseeded with a winter cover crop that was burned down before Spring 2022 planting. Permit Condition 11.13 states that if a field is to be over -seeded or double -cropped, the second crop can receive up to 50 Ibs/ac/yr PAN if the second crop is to be harvested or grazed; if the second crop is to be planted for erosion control only and is to be tilled into the soil, then no additional PAN shall be applied. Please be mindful of this permit condition as operations continue. C. WK-MRF-05 and WK-MRF-06 reportedly received residuals in December 2020 and January 2021. The volumes reported for December in the 2020 Residuals Annual Report to not correspond with the volumes reported in the 2021 Residuals Annual Report for both fields. There is no concern for over application for either field. Page 2 of 5 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 09/19/2022 Inspection Type: Annual Report Review Reason for Visit: Routine D. PAN for WK-YK-YF-05 was reported as 120 Ib/ac. This field has the county line for Wilkes and Yadkin running through it. The RYE lists PAN for FcC2 in Wilkes County as 80 Ib/ac for small grain silage. The same soil type in Yadkin County (Fairview sandy clay loam, 8-15% slopes, moderately eroded) has a map unit of FdC2. The RYE lists 80 Ib/ac for small grain silage for this map unit. There is no concern for over application. Please be mindful of this updated application rate. Please provide justification if 120 Ibs/ac is used again. E. PAN for MF-10 for small grain silage was reported as 98 Ibs/ac in the Executive Summary. The RYE lists PAN for small grain silage as 95 Ibs/ac for FcB2. Please be mindful of this updated application rate. Please provide justification if 98 Ibs/ac is used again F. PAN for MF-13 and RJ-07 for corn silage was reported as 214 Ib/ac in the Executive Summary. The RYE database lists PAN for corn silage as 207 Ib/ac for FcB2. Please be mindful of this updated application rate. Please provide justification if 214 Ibs/ac is used again G. The sampling event for Mathis Storage on 8/26 molybdenum was reported as <160 mg/kg, the ceiling concentration for manganese is 75 mg/kg. No residuals were applied from the storage tank. Moving forward, be sure that the laboratory method used has a reporting limit below the ceiling concentration. Other observations: • All residuals are incorporated to satisfy vector requirements. Fecal coliform was used for pathogen requirements. • Residuals applications were not reported from the storage unit, Brakebush Brothers, or Hunter Farms. • Advance Pierre (-13 tons in 2021) o TCLP is required annually and was sampled on 11/30. o PVR was required annually and completed on 2/4 and 6/10. o Metals and nutrients are required annually and sampled on 2/4, 6/10, and 11/30. pH on 2/4 was 4.5, pH on 6/10 is 5.5, and pH on 11/30 was 4.3. o Nickel was reported incorrectly on the RSSF as <18 mg/kg, lab results show 34 mg/kg. An amended RSSF was provided. o PAN was reported on RSSF as 20,627 mg/kg. Staff calculated PAN as 4,016 mg/kg. o Volumes are not listed on CH-01, MF-09, MF-10, MF-11, MF-13, MF-15, MRF-03, YF-03, YF-04, and YF-05 but data is included on the FSFs. Mr. Coyle stated that no residuals were applied for volumes listed as 0. o TKN, NH3, and NO3+NO2 were reported incorrectly on CH-01, CH-03, CH-04, MF-09, MF-10, MF-11, MF-13, MF-14, MRF-20, and YF-03. This was corrected on the amended report. • Tyson Harmony (--738.822 tons in 2021) o TCLP is required annually and was sampled on 11/30. o PVR was required quarterly and completed each quarter. o Metals and nutrients were required annually and sampled on 1/28, 6/1, 9/2, and 11/30. pH on 6/1 was 5.9, pH on 5.7, and pH on 11/30 was 5.8. • Mathis Storage o TCLP is required annually and was sampled on 11/30. o PVR was completed on 8/26 and 10/12 o Metals and nutrients analysis was sampled on 8/26, 9/23, and 12/28. pH was 5.0 on 8/26 and 9/23, and 5.4 on 12/8. • Tyson Wilkesboro (--684 tons in 2021) o TCLP is required annually and was sampled on 11/30. o PVR was required quarterly and completed each quarter on 1/28, 6/1, 8/26, and 11/30. o Metals and nutrients analysis was required quarterly and sampled on 1/28, 6/1, 8/26, and 11/30. pH on 1/28 was 3.9, on 6/1 was 5.8, on 8/26 was 4.1, and on 11/30 was 4.5. o PAN was reported on RSSF as 24,721 mg/kg. Staff calculated PAN as 25,721 mg/kg. • CH-03, CH-04, MRF-05, MRF-06, MRF-12, RJ-05, and RJ-07 received poultry litter as a supplemental nitrogen source. • Zinc was greater than 1,500 for the following fields: CH-01, CH-03, MF-09, MF-14, MRF-03, MRF-20, YF-01, YF-03, YF-04, and YK-05. Page 3 of 5 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 09/19/2022 Inspection Type: Annual Report Review Reason for Visit: Routine Type Yes No NA NE Distribution and Marketing ❑ Land Application Record Keeping Yes No NA NE Is GW monitoring being conducted, if required? ❑ ❑ 0 ❑ Are GW samples from all MWs sampled for all required parameters? ❑ ❑ 0 ❑ Are there any GW quality violations? ❑ ❑ 0 ❑ Is GW-59A certification form completed for facility? ❑ ❑ 0 ❑ Is a copy of current permit on -site? ❑ ❑ ❑ Are current metals and nutrient analysis available? 0 ❑ ❑ ❑ Are nutrient and metal loading calculating most limiting parameters? 0 ❑ ❑ ❑ a. TCLP analysis? 0 ❑ ❑ ❑ b. SSFA (Standard Soil Fertility Analysis)? 0 ❑ ❑ ❑ Are PAN balances being maintained? 0 ❑ ❑ ❑ Are PAN balances within permit limits? ❑ 0 ❑ ❑ Has land application equipment been calibrated? ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ ❑ 0 ❑ Are there pH records for the land application site? 0 ❑ ❑ ❑ Are nutrient/crop removal practices in place? 0 ❑ ❑ ❑ Do lab sheets support data reported on Residual Analysis Summary? 0 ❑ ❑ ❑ Are hauling records available? ❑ ❑ ❑ Are hauling records maintained and up-to-date? ❑ ❑ ❑ # Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ ❑ Has application occurred during Seasonal Restriction window? 0 ❑ ❑ ❑ Comment: See summa Pathogen and Vector Attraction Yes No NA NE a. Fecal coliform SM 9221 E (Class A or B) 0 ❑ ❑ ❑ Class A, all test must be <1000 MPN/dry gram ❑ Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram ❑ Fecal coliform SM 9222 D (Class B only) ❑ ❑ ❑ Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram b. pH records for alkaline stabilization (Class A) ❑ ❑ ❑ ❑ c. pH records for alkaline stabilization (Class B) ❑ ❑ ❑ ❑ Temperature corrected ❑ d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ ❑ ❑ Page 4 of 5 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 09/19/2022 Inspection Type: Annual Report Review Reason for Visit: Routine e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench -top Aerobic/Anaerobic digestion results Comment: Sampling Describe sampling: Is sampling adequate? Is sampling representative? Comment: ❑ ❑ ❑ ❑ El ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE Page 5 of 5