WQ0038087_Compliance Evaluation Inspection_20230403

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
April 3, 2023
David Coyle, Environmental Manager
David. coyle(a)denaIiewater.com
Terra Renewal Services, Inc.
P.O. Box 1746
Watkinsville, GA 30677
SUBJECT: Compliance Evaluation Inspection
Terra Renewal Services RLAP
Permit No. WQ0038087
Wilkes County
Dear Mr. Coyle:
On March 21, 2023, Division of Water Resources staff Caitlin Caudle completed a routine
compliance inspection. David Coyle, Project Manager, and Jordan Mathis, Farm Owner,
were present during the entire inspection. A review of records, application fields,
application activities, and storage structures was completed. This review reflected
compliance with the subject permit.
Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact me or Caitlin Caudle at the letterhead address
or phone number, or by email at lon.snider(a�ncdenr.gov or Caitlin.caudle(c)_ncdenr.gov.
Sincerely,
Docu Siiggned by:
Loti l . JMAts'
1.49E225C94EA...
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)
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�nmen� Qualm

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: [phone]
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: 03/21/2023 Entry Time 01:OOPM Exit Time: 03:30PM
Primary Inspector: Caitlin a_gBIgisigned by: Phone: [phone]
Secondary Inspector(s): L±8B834968199D49D...b'
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling
Land Application Site Pathogen and Vector Attraction Storage
Transport
(See attachment summary)
Page 1 of 7

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 03/21/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On March 21, 2023, Division of Water Resources staff Caitlin Caudle completed a routine compliance inspection. David
Coyle, Project Manager, and Jordan Mathis, Farm Owner, were present during the entire inspection. A review of records,
application fields, application activities, and storage structures was completed. This review reflected compliance with the
subject permit.
Tyson — Wilkesboro and Tyson — Harmony were actively being applied. Mr. Coyle stated that these two sources are applied
daily because of the type of pre-treatment at the sources. Tyson — Harmony and Tyson — Wilkesboro have dissolved air
floatation units and polymers to remove solids. Tyson — Wilkesboro is connected to Wilkesboro's collection system and
Tyson — Harmony has an individual NPDES permit. The storage tank for DAF biosolids have approximately one day of
storage and daily hauling is needed.
Ms. Caudle requested storage tank inspection logs be provided by March 28, 2023. This has not been received to date.
M F-17
The field had been completed by the time of this inspection. Buffer flags were removed as they damage harvest equipment.
There were no biosolids visible on the surface and no evidence of ponding or runoff at lower elevations of the field The entire
field was not spread, see map in event file.
M F-09
The field was being actively applied at the time of inspection. Buffer flags were visible, and application was occurring within
the application area. All buffers were appropriate. Application was even and no ponding or runoff was visible. There was
evidence of past incorporation. A stand of wheat was present prior to application as a cover crop.
Other observations:
• AdvancePierre is land applied monthly.
• AdvancePierre is also connected to a municipality for final treatment.
• Fecal, nutrients, and metals analysis from the last quarter of 2022 were sent and reviewed. The first quarter of 2023 has
been sent off for analysis but results have not been received yet. Mr. Coyle stated nutrient values are fairly consistent.
• The general operation of land application is land apply, disc it under, land apply, disc it under. All material will be
incorporated by the end of the day, and within six hours of application. Only one driver is in a field at one time. Allowing for
biosolids to be incorporated while waiting on tankers to arrive.
• A frac tank is used as a staging unit. Tankers will off load into the frac tank, and the spreader will load from the frac tank.
• A 501b nitrogen credit are applied for cover crops.
• Because Tyson — Wilkesboro and Tyson — Harmony are applied daily, a deduction system is used to document PAN
rates. The total PAN for the field is calculated by multiplying the total usable acreage of a filed by the application rate (acres
x lb PAN/acre = lb PAN). As tanker drivers arrive at a field, they complete a digital ticket to track the load; and the spreader
driver documents the load on his field loading sheet. With each load the PAN is deducted from the total lb PAN available in
the field.
• Afield may be covered several times based on the available nitrogen remaining in the field. Application is done at a rate
which prevent ponding and runoff, not to apply all PAN with a single pass.
• Mathis Farms also accepts material from Weyerhaeuser (W00042203). Mr. Mathis stated that the Weyerhaeuser and
Terra Renewal material do not overlap in an application year.
• Both storage tanks were almost to the maximum storage volume (9ft). Mr. Coyle stated they are planning to clean out
the tanks when weather allows and will send a notification.
• The storage tanks have an external staff gauge with a float, and an internal staff gauge with marking for back up.
• The storage tanks can hold approximately one month of biosolids. The DAF tanks at source facilities have about one
day of storage.
• Mr. Coyle samples source facilities quarterly based on past operations.
• There was an odor complaint within the last 12 months. The odor complaint was documented with NOD-2022-PC-0205.
Mr. Coyle stated they are planning to add biological material to the storage tank to promote additional digestion. There are
no plans to manage odors at the fields as weather heavily impacts the odors during application.
Page 2 of 7

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 03/21/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
• The 2022 AR has not been reviewed to date. The 2021 AR showed no concerns with Cu, Zn, or Na.
Page 3 of 7

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 03/21/2023 Inspection Type: Compliance Evaluation
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?
0
❑ ❑ ❑
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?
0
❑ ❑ ❑
Are hauling records maintained and up-to-date?
0
❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
❑
0 ❑ ❑
Has application occurred during Seasonal Restriction window?
0
❑ ❑ ❑
Comment: See NOD-2022-PC-0205.
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 7

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 03/21/2023 Inspection Type: Compliance Evaluation 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 Yes No NA NE
Describe sampling:
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? 0 ❑ ❑ ❑
Is a copy of the spill control plan in the vehicle? ❑ ❑ ❑
Is the spill control plan satisfactory? ❑ ❑ ❑
Does transport vehicle appear to be maintained? 0 ❑ ❑ ❑
Comment:
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? 0 ❑ ❑ ❑
Is the application site in overall good condition? ❑ ❑ ❑
Is the site free of runoff/ponding? ❑ ❑ ❑
If present, is the application equipment in good operating condition? ❑ ❑ ❑
Are buffers being maintained? ❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application
❑
❑ ❑
18% for subsurface application
❑ ❑ ❑
Are there access restrictions and/or signs?
❑
❑ ❑
Is the application site free of odors or vectors?
❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑
❑ ❑
For incorporation?
❑ ❑ ❑
Does permit require monitoring wells?
❑
❑ ❑
Have required MWs been installed?
❑
❑ ❑
Are MWs properly located w/ respect to RB and CB?
❑
❑ ❑
Page 5 of 7

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 03/21/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Are MWs properly constructed (including screened interval)? ❑ ❑ 0 ❑
Is the surrounding area served by public water? ❑ ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? ❑ ❑ 0 ❑
Are soil types consistent w/ Soil Scientist report/evaluation? 0 ❑ ❑ ❑
Is the water table greater than 173' bls. ❑ ❑ ❑
Is application occurring at the time of the inspection? 0 ❑ ❑ ❑
Comment:
STORAGE TANK 2
Storage
Yes No NA NE
Storage Type?
Aboveground
storage tank
Storage amount?
11
Feet
Is storage aerated or mixed?
NONE
If aeration is present, is it adequate?
❑
❑ ❑
If present, are diffusers cleaned regularly?
❑
❑ ❑
Is influent structure acceptable?
❑
❑ 0 ❑
Are banks/berms free of seepage and erosion?
❑ ❑ ❑
Are banks/berms free of excessive vegetation?
❑ ❑ ❑
Is lagoon lined?
❑
❑ ❑
Liner Type
Is liner acceptable?
❑ ❑ ❑
Are baffles/curtains acceptable?
❑
❑ 0 ❑
Does the lagoon have a freeboard marker?
❑
❑ 0 ❑
Required freeboard?
2
Feet
Feet
Actual freeboard?
9
Is there suitable grassed vegetation?
M
❑ ❑ ❑
Is the vegetation maintained?
0
❑ ❑ ❑
Is the area free of excessive weeds and/or woody species?
❑
❑ 0 ❑
Is the area free from signs of overflow?
0
❑ ❑ ❑
Is storage free of excessive solids build-up?
0
❑ ❑ ❑
Are aerators/mixers acceptable?
❑
❑ 0 ❑
Is residuals loading area maintained?
0
❑ ❑ ❑
Is there a Spill Control Plan?
0
❑ ❑ ❑
Comment:
Page 6 of 7

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 03/21/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
STORAGE TANK 1
Storage
Storage Type?
Storage amount?
Is storage aerated or mixed?
If aeration is present, is it adequate?
If present, are diffusers cleaned regularly?
Is influent structure acceptable?
Are banks/berms free of seepage and erosion?
Are banks/berms free of excessive vegetation?
Is lagoon lined?
Liner Type
Is liner acceptable?
Are baffles/curtains acceptable?
Does the lagoon have a freeboard marker?
Required freeboard?
Actual freeboard?
Is there suitable grassed vegetation?
Is the vegetation maintained?
Is the area free of excessive weeds and/or woody species?
Is the area free from signs of overflow?
Is storage free of excessive solids build-up?
Are aerators/mixers acceptable?
Is residuals loading area maintained?
Is there a Spill Control Plan?
Comment:
Yes No NA NE
Aboveground
storage tank
11
Feet
NONE
❑❑■❑
❑❑■❑
❑❑■❑
■❑❑❑
■❑❑❑
❑❑■❑
■❑❑❑
❑❑■❑
2
Feet
Feet
9
■❑❑❑
❑❑■❑
■❑❑❑
■❑❑❑
Page 7 of 7