WQ0038087_Review of 2020 Annual Report_20210401

DocuSign Envelope ID: B1822FCE-7B01-4D3E-81A6-C6F2A421A815
ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 1, 2021
Mr. David C. Coyle, Environmental Manager
Terra Renewal Services, Inc.
P.O. Box 1746
Watkinsville, Georgia 30677
Subject: Review of the 2020 Annual Report
Terra Renewal Services, Residuals Land Application Program
Permit No. WQ0038087
Wilkes County
Dear Mr. Coyle:
Staff of the North Carolina Division of Water Resources Winston-Salem Regional Office
(DWR) has completed a review of the 2020 Annual Report for the subject facility. This review
was completed by DWR staff person Patrick Mitchell. Review of the subject report reflects
compliance with the Permit No. WQ0038087. However, the items below noted during this
review require your attention and action.
• The residuals analysis results dated May 19, 2020 for source facility AdvancePierre
Foods reported a Sodium Adsorption Ratio (SAR) of 10.2. Please be reminded that
Permit Condition I1.14. requires that prior to the land application of residuals
containing a SAR of 10.0 or higher the conditions contained in Condition I1.14. shall
be met. Land application of residuals with a SAR of 10.0 or greater can have impacts on
soil permeability and crop health. Please closely review future residuals results prior
to land application events to ensure residuals meet all permit limits and take any
actions required by the permit for residuals that do not meet these limits.
• All land application field loadings for year 2020 were reported as being conducted within
the permitted agronomic limits However, some of the fields were reported as being
loaded at or near the maximum limit. While reporting carryover Nitrogen loading is
currently not required, please keep this in mind and adjust agronomic loading
accordingly to prevent potentially overloading fields. The Division will review these
fields in more detail to determine if additional monitoring is necessary.
Our office appreciates your attention to the above listed items of concern. A routine compliance
inspection is planned to be scheduled within this inspection calendar year.
_1121,..„E\93
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

DocuSign Envelope ID: B1822FCE-7B01-4D3E-81A6-C6F2A421A815
Please refer to the enclosed compliance inspection report form for additional observations and
comments. If you have any questions regarding this letter, please contact Patrick Mitchell or
me at the letterhead phone number or address, or by email at [e-mail] or
lon. [e-mail].
Sincerely,
,—DocuSigned by:�
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by
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Lon 1. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc: Compliance Inspection Report
cc:
Mr. Luke Mathis, ORC (Electronic Copy)
Wilkes County Environmental Health (Electronic Copy)
Laserfiche File WQ0038087
WSRO Electronic Files
Page 2 of 2

Compliance Inspection Report
Permit: WQ0038087 Effective: 02/04/21 Expiration: 11/30/27 Owner : Terra Renewal Services Inc
SOC: Effective: Expiration: Facility: Terra Renewal Services RLAP
County: Wilkes 615 Mathis Farm Rd
Region: Winston-Salem
Contact Person: Mike Brooks
Directions to Facility:
System Classifications: LA,
Primary ORC: David Clayton Coyle
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Roaring River NC 28669
Title: Phone: [phone]
Certification: 995723 Phone: [phone]
NC0005126 Tyson Farms Inc - Tyson Farms, Inc.
Inspection Date: 04/01/2021 Entry Time 08:OOAM Exit Time: 11:OOAM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
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:
II Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)

Permit: WQ0038087 Owner- Facility:Terra Renewal Services Inc
Inspection Date: 04/01/2021 Inspection Type : Annual Report Review
Reason for Visit: Routine
Inspection Summary:
On April 1, 2021, WSRO staff conducted a review of the subject facility's 2020 Annual Report. No site visit was made as part
of this inspection event. The report reflects compliance with the subject permit. However, the items listed below require
attention.
• The residuals analysis dated 5/19/2020 for source facility AdvancePierre Foods reported a SAR of 10.2. This is slightly
above the permit max limit of 10.0. It should be noted that all other sampling results showed values below the limit. Request
Permittee keep an eye on SAR levels and take necessary actions if levels continue to be 10 or greater in order to meet
requirements in Permit Condition 11.14.
• The reported agronomic loading to fields used in year2020 was within agronomic limits. However, some fields were very
close to the max limit. Recommend closely reviewing these fields for proper vegetative cover and operations to prevent
potential impacts to groundwater and/or surface waters.
• The previous inspector no longer works for the Division, it is unknown if notifications were made to this inspector prior to
land application events. Remind Permittee to be sure to notify WSRO before land app. events.
Other notes from this review are listed below.
- Reported only three of the permitted sources (Tyson Wilkes and Harmony, and AdvancePierre Foods) were active in year
2020.
- Sampling was completed at required frequency for each of the sources utilized and the sampling results suggests that
regulatory limits for metals, TCLP and pathogen reduction were all met in year 2020.
- Soil test results along with lime amendment reporting suggests proper soil health is being maintained at the land
application fields.
A routine inspection is planned for this inspection year.