WQ0038087_Notice of Deficiency_20230105

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
January 5, 2023
CERTIFIED MAIL No. 7020 3160 0002 0860 9268
RETURN RECEIPT REQUESTED
David Coyle, Environmental Manager
Terra Renewal Services, Inc.
P.O. Box 1746
Watkinsville, Georgia 30677
SUBJECT: Notice of Deficiency (NOD-2022-PC-0205)
Incident No. 202201861
Terra Renewal RLAP
Permit No. WQ0038087
Wilkes County
Dear Mr. Coyle:
On December 21, 2022, Division of Water Resources staff in Central Office were notified
of odor complaints from residents around permitted land application fields. This
notification relayed that Luke Mathis, ORC, had been contacted and provided information
that residuals from Tyson were being land applied. Further investigation by Winston
Salem Regional Office staff found that residuals from the storage tanks were being land
applied to the fields immediately surrounding the storage tanks.
Per Permit Condition 111.3 "the Permittee shall notify the Winston Salem Regional Office
(WSRO)... at least one business day in advance of conducting any land application
activity. Notification shall include the anticipated application date, time, and field name as
listed in Attachment B." The Winston Salem Regional Office was not notified of these land
application activities. Moving forward, WSRO must be notified of any land application
activities where residuals are hauled from the storage tanks.
Please provide the following information within thirty (30) days of receipt of this
Notice:
1. The volume of residuals and the sources stored in the storage tanks for the 2021
calendar year, as well as freeboard records for both tanks. Per Footnote 7 in the
most recent Attachment A, residuals from any approved residual source may
be temporarily stored in the storage tanks, but the volume entered into the
storage tank must be subtracted from that source's permitted dry tonnage.
D North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
Moan caaouNn 336.776.9800
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2. The Field Summary Forms for the fields that were applied on during this application
event.
3. A Plan of Action to address odor complaints as this is the second instance of an
odor complaint associated with land application activities. Per Permit Condition
111.10.b, Class B residuals shall not be land applied if the application causes
nuisance conditions.
If you have any questions please contact me or Caitlin Caudle at the letterhead address
and phone number, or by email at Ion. snider(c-)_ncdenr.gov or caitlin.caudle(a-)_ncdenr.gov.
Sincerely,
DocuSiTgned by:
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Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
Cc: Wilkes County Environmental Health (electronic coy)
Luke Mathis, ORC (electronic copy)
D North Carolina Department of Environmental Quality I Division of Water Resources
✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
NORTH CAROLINA 336.776.9800
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