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Home My WebLink AboutWQ0038087_Notice of Deficiency_20230815ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality August 15, 2023 Delivered electronically via email to: David.coyle _denaliwater.com David Coyle, Environmental Manager Terra Renewal Services, Inc. P.O. Box 1746 Watkinsville, GA 30677 SUBJECT: Notice of Deficiency (NOD-2023-PC-0218) 2022 Annual Report Review Terra Renewal RLAP Permit No. WQ0038087 Wilkes County Dear Mr. Coyle: On August 10, 2023, Division of Water Resources staff Caitlin Caudle completed a review of the 2022 Annual Report. The following deficiency was noted: A. Land application activities were reported for WK-YF-01, 03, 04, 05, and 07 in October and November of 2022. A review of available records shows that the only land application notification for these fields was provided on May 13, 2022. Land application activities did occur at other fields between the time of notification and land application activities. Moving forward, notify the Winston Salem Regional Office of all scheduled land application if land application is not continuous and the most recent notification was more than one month prior to the commencement of activities. The minimum information of an application notification can be found in Permit Condition 111.3. 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 and phone number, or by email at lon.snider(o-)_deg.nc.gov or Caitlin.caudle(d-)_deg.nc.gov. Sincerely, Docu S�igTned by: 145B49E225C94EA... 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) Jordan Mathis, (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: 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: 08/10/2023 Entry Time 08:OOAM Exit Time: 04:OOPM Primary Inspector: Caitlin a//u,,@,,I4llll€F'si9nedby: �II'I� Phone: 336-776-9699 Secondary Inspector(s): ( ruv' lAD& 8B834968199D49D_ 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 Storage (See attachment summary) Page 1 of 4 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 08/10/2023 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: On August 10, 2023, Division of Water Resources staff Caitlin Caudle completed a review of the 2022 Annual Report. The following deficiency was noted: A. Land application activities were reported for WK-YF-01, 03, 04, 05, and 07 in October and November of 2022. A review o available records shows that the only land application notification for these fields was provided on May 13, 2022. Land application activities did occur at other fields between the time of notification and land application activities. Moving forward, notify the Winston Salem Regional Office of all scheduled land application if land application is not continuous and the most recent notification was more than one month prior to the commencement of activities. The minimum information of an application notification can be found in Permit Condition 111.3. Other observations: • Lime was applied to all fields that were land applied on. • Fields WK-MF-14, WK-MRF-6, WK-MRF-3, WK-MRF-5 reported carryover from 2021 when application events occurred continuously. • Fields WK-MRD-6, WK-MRF-3, WK-MRF-5, WK-MRF-12, WK-CH-3, WK-CH-4, WK-DM-6 all received chicken litter. • Fields that were double cropped only received 50 Ibs PAN/ac. • A review of available records shows that WSRO staff were not notified of the land application events that took place in November 2022 at fields MRF-3, MRF-5, MRF-6, and MRF-12. This failure to notify was addressed in NOD-2022-PC-0205. Advance Pierre • A total of 13.3855 dry tons were applied. • TCLP and annual sampling was completed on 12/27/2022. River Valley Ingredients • A total of 434.8027 tons were land applied. Of that volume, 87 tons were put in Mathis Storage. • Quarterly sampling was completed on 3/22/2022, 6/6/2022, 10/3/2022, and12/27/2022. TCLP was completed on 12/27/2022. • PAN was reported as 48,815 mg/kg. Staff calculated PAN as 48,950 mg/kg. • SAR was reported as 1.9. Staff calculated PAN as 2.56. • pH for Q1 and Q4 was 5.5 and 5.1, respectively. Mathis Storage • A total of 212 tons were stored in the storage tanks. A total of 178.8631 dry tons were land applied. • Quarterly sampling was completed on 3/22/2022, 6/6/2022, 10/3/2022, and 12/27/2022. TCLP was completed on 12/27/2022. • PAN was reported as 172,020 mg/kg. Staff calculated PAN as 172,200 mg/kg. • Cadmium was reported as <2.9 mg/kg. The provided lab report shows cadmium was <2.0 mg/kg. • pH for Q1, Q2, and Q4 was 5.1, 5.2, and 5.1, respectively. Tyson Wilkes • A total of 760.5938 tons were land applied. Of that volume, 125 tons were put in Mathis Storage. • Quarterly sampling was completed on 3/22/2022, 6/16/2022, 10/3/2022, 12/27/2022. TCLP was completed on 12/27/2022. • PAN was reported as 28,988 mg/kg. Staff calculated PAN as 29,051 mg/kg. • SAR was reported as 2.4. Staff calculated SAR as 2.57. • pH for Q1, Q2, Q3, and Q4 was 4.9, 3.9, 4.6, and 4.4, respectively. • The Q2 fecal maximum was reported as 1,546 MPN/mL. Lab analysis show 1,563 MPN/mL as the maximum value. Page 2 of 4 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 08/10/2023 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? 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: 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 3 of 4 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 08/10/2023 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 4 of 4