WQ0038087_Response to Notice_20231222

DENALI
December 22, 2023
Jennifer Graznak; Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ -WSRO
450 West Haines Mill Road; Suite 300
Winston-Salem, NC 27105
3308 Bernice Avenue
Russellville, Arkansas 72802
479-498-0500
Subject: Response to Notice of Violation (NOV-2023-PC-0609) issued December 14, 2023
Incident No. 202301552
Terra Renewal Services RLAP
Permit No. WQ0038087
Wilkes County
Dear Ms Graznak,
Denali (dba Terra Renewal Services) received the above referenced Notice of Violation (the Notice) via certified
mail on December 21, 2023. Land application associated with this permit has been inactive since December 15,
2023. The following information is being provided, which includes a "Plan of Action", pertaining to the two
violations listed in the Notice.
1) At the time of inspection, the application area in the subject field was not clearly marked. The standing
corn was the result of an attempt by the farmer to "triple crop" this field. A corn silage crop was grown
and harvested earlier in the summer; a second crop was planted but did not mature sufficiently for
harvest. This crop was standing at the time of application. According to the operator, application began
in an area of the field that would not encroach on buffered features with intent on marking buffers after
application had begun. It is standard procedure to mark application areas prior to and during land
application for this operation, as documented in previous compliance inspections by the Department.
Moving forward, we will ensure that all application areas are marked per Permit Condition 11.10.
2) To date, the method for meeting vector attraction reduction requirements of Class-B residuals has been
Option 10.A "Incorporation" under 15A NCAC 02T .1107. Moving forward, to further mitigate potential
for odors and nuisance, the method will be Option 9.A "Injection" under 15A NCAC 02T .1107.
Equipment has been procured that will allow for the liquid residuals to be sub -soil injected to a depth of
+/- 6 inches below the surface. Injection was employed with success when operations began under this
permit in 2015 prior to transitioning to incorporation. The application areas may also be lightly disked at
the farmers' discretion to smooth the surface after injection, but not enough to significantly expose the
residuals. This will be implemented immediately.
Our company and partner farmers take violations very seriously. We understand that operating in compliance
with the permit and in a manner that minimizes impact on the surrounding community is the only way to maintain
a sustainable program. We appreciate your cooperation and timely attention to this matter. If you have any
questions or require additional information, please contact me at 479-747-8192 or david.coyle(d)denaliwater.com.
Sincerely,
��— � e 5�
David C. Coyle; LSS, CCA
Back -Up ORC (WQ0038087)
Senior Environmental Manager— Denali
CC: Luke Mathis, ORC (WQ0038087)
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