WQ0031672_Review of Annual Report_20220610

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
June 10, 2022
CERTIFIED MAIL # 7020 1810 0001 2074 8027
RETURN RECIPT REQUESTED
Mr. JP Woodrum, Operations Manager
Alltech, Inc.
11761 NC 770 E
Eden, North Carolina 27288
SUBJECT: Notice of Violation (NOV-2022-LA-0001)
2021 Annual Report Review
Alltech Inc. — Eden Facility
Distribution of Class A Industrial Byproduct Residuals
Permit No. WQ0031672
Rockingham County
Dear Mr. Woodrum:
The Division of Water Resources (DWR) acknowledges receipt of your 2021 Annual Report for the
subject permit. A review of this report conducted by DWR staff person Jim Gonsiewski generally
reflects compliance with Permit Number WQ0031672. However, the following violation was noted:
The Annual Report was submitted on May 9, 2022. Permit Condition IV.7 states that the Annual
Report shall be submitted every year by March 1. Remedial actions, if not already implemented,
should be taken to correct this deficiency. If this occurs again, the Division of Water Resources may
pursue enforcement actions.
It is our understanding that consideration is being given to request rescission of this permit. Until the
recission is submitted and approved, you are required to submit an Annual Report yearly.
OEE QWIRT/I CN X INA
Oeperbneld of EnWrwnafl OWwr
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

If you or your staff have any questions concerning this letter, please contact me or Jim Gonsiewski
at [phone] or via email at [e-mail].
Sincerely,
E-04,DoeuSigned bty:
'Tby:
145849E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
encl: Compliance Inspection Report
cc: Rockingham County Environmental Health (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
1:1E
Dew.Do.,r or En*OT4 nal w.r� /"'
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit:WQ0031672 Effective: 01/31/17 Expiration: 12/31/21 Owner: Alltech Inc
SOC: Effective: Expiration: Facility: Alltech- Eden Facility
County: Rockingham 11761 Hwy 770 E
Region: Winston-Salem
Eden NC 27288
Contact Person:J P Woodrum Title: Phone:[phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 06/08/2022 Entry Time 10:15AM Exit Time: 11:30AM
Primary Inspector:Jim J Gonsiewski Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids(503 Exempt)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WO0031672 Owner-Facility:Alltech Inc
Inspection Date: 06/08/2022 Inspection Type :Annual Report Review Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources(DWR) received the 2021 Annual Report for the subject permit. A review of this report
conducted by DWR staff person Jim Gonsiewski generally reflects compliance with Permit Number W00031672. However,
the following violation was noted:
The Annual Report was submitted on May 9, 2022. Permit Condition IV.7 states that the Annual Report shall be submitted
every year by March 1. Remedial actions, if not already implemented, should be taken to correct this deficiency. If this
occurs again, the Division of Water Resources may pursue additional enforcement actions.
It is our understanding that consideration is being given to request rescission of this permit. Until that recission is submitted
and approved, submittal of Annual Reports are required yearly.
Page 2 of 3

Permit: WQ0031672 Owner-Facility:Alltech Inc
Inspection Date: 06/08/2022 Inspection Type:Annual Report Review Reason for Visit: Routine
Type Yes No NA NE
Land Application ❑
Distribution and Marketing ❑
Page 3 of 3

Annual Report Review Class A Distribution Permit No. WQOO at 6-1.- ---
Reporting Period:
Permit Details:
• Is 503? j ]Yes [ilo
• Class or❑B?
• Maximum Dry Tons Per YearQ
• Number of acres permitted: --",
• Number of fields in permit: .---
• Counties that land is permitted for: ...�.�
• Monitoring Frequency for TCLP: elv\�e_ ,s,_,� gym;-{-C
bd
• Monitoring Frequency for Residuals Analysis: t�a�vni k
• Monitoring Frequency for Pathogen &Vector Attraction Reduction: f\,Aa�b
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form ____
• Was a certification form submitted? 1Ys ❑�,Noo
• Was distribution conducted during the reported period? [Yes L�rao
• How many dry tons were produced and distributed?;
• Were the distributions within the permitted amount?fV j [Yes ENo
• Were recipients information listed? J
• Did it indicate compliance? Nr Bps 1 INo
• Was form complete? Dies No
• Was it signed by the appropriate people? I INo
2. Motoring
• ): e the analyses conducted at the required frequency? ]Yes No
• Was ., analyses taken for each source that was distributed? ❑Yes ❑No
• Were the • etals analyses reported on the Residual Sampling Summary Form? ❑Yes No
• Were the resb s reported in mg/kg? ❑Yes nNo
• Were the pH's 6., •r greater for each residual sample? "Yes No
• Were the heavy metaithin ceiling concentration permit limits? ['Yes ❑No
o Were the lab analyst ttached? nYes ❑No
• Were all the required parameter sted? [Yes nNo
• Was TCLP analysis conducted? [Yes ❑No
• Were the TLCP contaminants within regu story limits? LIYes ❑No
• Was a corrosivity, ignitability, and reactivity analysis conducted? _Yes ❑No

3. Pathogen a. Vector Attraction Reduction
• Was a signe copy of the Pathogen and Vector Attraction Reduction Form submitted? UYes ❑No
• Did the form in 'date the period of coverage, the residual class, and the pathogen reduction alternative
and the vector att ction reduction option used? nYes No
• Was the appropriate ocumentation to show pathogen and vector attraction reduction included in the
report? Yes ❑No
• Was pathogen and vector ttraction reduction demonstrated according to 40 CFR Part 503?❑Yes0No
Class A Pathogen Review
To be Class A, residuals shall me Neither fecal Coliform density or salmonella density.
nFecal Coliform density
• Was the sampling conducted at the required frequency? ❑Yes I JNo
• Were multiple samples taken? ❑Yes ❑No
• Was each sample less than 1000 MPN/gram of total solids? ❑Yes ❑No
OR
nSalmonella density
• Was the sampling conducted at the required frequency? ❑Yes No
• Were multiple samples taken? ]Yes I No
• Was each sample less than 3 MPN/4 grams of total solids? ❑Yes I]No
To be Class A, residuals shall meet one of the following alternatives:
❑Alternative 1 —Time/Temperature
• Were the residuals maintained for correct time and temperature? ❑Yes No
• Were logs submitted showing time and temperature? ❑Yes ❑No
• Were temperatures within range for complete time period? ❑Yes El No
nAlternative 2 —Alkaline Treatment
• Were logs submitted showing time and temperature? ['Yes I )No
• Was the pH raised to 12 or greater and maintained for 72 hours or longer? (_IYes nNo
• Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater?
UYes I 1No
• Were logs submitted showing time and pH? ❑Yes No
• Was the temperature corrected to 25°C (77°F)? (_IYes El No
Alternative 5 — Process To Further Reduce Pathogens
f IPFRP Composting
• • Were the within-vessel method or static aerated pile methods used? nYes nNo
• Was the residuals temperature maintained at 55°C (131°F) or higher for three consecutive days or
longer in the within-vessel method or static aerated pile method? Yes ❑No
OR
• Was the windrow composting method used? UYes ❑No
• Was the residuals temperature maintained at 55°C or higher for 15 consecutive days or longer in the
windrow method, and the windrow turned a minimum of five times during this time? UYes No
nPFRP Heat Drying
• Was the residuals dried by direct or indirect contact with hot gases and the moisture content of
residuals reduced to 10% or lower? I-Yes ❑No
• Did the temperature of the residuals or the of the wet bulb temperature of the gas in contact with the
residuals as the residuals leave the dryer exceed 80°C (176°F)? nYes nNo

Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency? LUYes UNo
nOption 1 —38% Volatile Solids Reduction
• Was there 38% reduction? ❑Yes ❑No
• Were lab sheets/calculations in report? ❑Yes No
• Was the reduction on volatile solids (not total solids)? ❑Yes UNo
• Were the samples taken at beginning of digestion process and before application (Inspection)?
Elves ❑No
• Were calculations correct? Oyes ❑No
nOption 2 —40-Day Bench Scale Test
• Were residuals from anaerobically digested treatment (Inspection)? ❑Yes PiNo
• Were residuals anaerobically digested in lab? ❑Yes ❑No
• Was the test run for 40 days? ❑Yes I INo
• Was the test done between 30°C (86°F) and 37°C (99°F)? Eves ❑No
• Was the reduction of on volatile solids (not total solids)? Dyes ❑No
• Was the reduction less than 17%? ❑Yes ❑No
Were lab sheets/calculations in report? ❑Yes ❑No
• Were calculations correct? ❑Yes ❑No
nOption 3 —30-Day Bench Scale Test
• Were residuals from aerobically digested treatment (Inspection)? ❑Yes ❑No
• Were residuals aerobically digested in lab? Dyes ❑No
• Were residuals 2% or less total solids? ❑Yes ['No
• If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent?
[Ives ❑No
Was the test run for 30 days? ❑Yes ❑No
• Was the test done at 20°C (68°F)? Oyes ❑No
• Was the reduction of on volatile solids (not total solids)? Oyes ❑No
• Was the reduction less than 15%? Oyes ❑No
Were lab sheets/calculations in report? Dyes ❑No
Were calculations correct? ❑Yes ❑No
nOption 4—Specific Oxygen Uptake Rate(SOUR)
Were residuals form aerobically digested treatment (Inspection)? ❑Yes ❑No
Were residuals 2% or less total solids (dry weight basis) (not diluted)? Oyes nNo
Was the test done between 10°C (50°F) and 30°C (86°F)? Dyes ❑No
• Was the temperature corrected to 20°C (68°F)? Dyes ❑No
• Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total residual solids (dry
weight basis)? ['Yes ❑No
Was the sampling holding time two hours? Dyes ❑No
• Was the test started within 15 minutes of sampling or aeration maintained? Oyes ❑No
nOption 5— 14-Day Aerobic Process
Were the residuals from aerobically digested treatment(Inspection)? Elves ❑No
• Were the residuals treated for 14 days? Oyes ❑No
• Was the residuals temperature higher than 40°C(104°F) for a 14-day period? ❑Yes ❑No
• Was the average residuals temperature higher than 45°C (113°F)? [Yes ❑No

(Option 6—Alkaline Stabilization
• Was the pH of the residuals raised to 12 or higher by the addition of alkali? ❑Yes ❑No
• Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
EYes ❑No
• Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours without the
addition of more alkali? ❑Yes ❑No
• Was the pH corrected to 25°C(77°F)? ❑Yes ❑No
❑Option 7—Drying of Stabilized Residuals
• Does the residuals contain any unstabilized residuals? ❑Yes ❑No
• Were the residuals mixed with any other materials? ❑Yes ❑No
• Were the residuals dried up to 75% total solids? ❑Yes ❑No
nOption 8 —Drvinu of Unstabilized Residuals
• Were the residuals mixed with any other materials? Yes ❑No
• Were the residuals dried to 90% total solids? I Yes ❑No
nOption 9—Injection
• Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
❑Yes ❑No
• Was injection done on pasture or hay field? [Dies ❑No
• Was injection done at time that crop was growing? ❑Yes ❑No
• If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? ❑Yes ❑No
4. General
• Was the report in the proper format? L�'if‘ ❑No
• Was the annual report complete? [Yes ❑No
• Was the report submitted on time? ['Yes O 'o
Pollutant Ceiling Below Cumulative Below ( !
Concentration Limit Pollutant Limit
Loading Rate
Arsenic 75 41
Cadmium 85 39
Copper 4300 1500
Lead 840 300
Mercury 57 17
Molybdenum 75 N/A
Nickel 420 420
Selenium 100 100
Zinc 7500 2800

TCLP
Parameter J Below Parameter Below Parameter Below
Limit Limit Limit
Arsenic(5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0)
Benzene(0.5) 1,1-Dichloroethylene (0.7) Pyridine (5.0)
Cadmium (1.0) 2,4-Dinitrotoluene (0.13) Selenium (5.0)
Carbon tetrachloride (0.5) Endrin (0.02) Silver (5.0)
Chlorodane(0.03) Hepatachlor (and its Tetrachloroethylene (0.7)
epoxide) (0.008)
Chlorobenzene (100.0) Hexachlorobenzene (0.13) Toxaphene (0.5)
Chloroform (6.0) Hexachlorobutadiene (0.5) Trichloroethylene (0.5)
Chromium (5.0) Hexachloroethane (3.0) 2,4,5-Trichlorophenol
(400.0)
m-Cresol (200.0) Lead (5.0) 2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0) Lindane (0.4) 2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0) Mercury (0.2) Vinyl Chloride (0.2)
Cresol (200.0) Methoxychlor (10.0)
2,4-D (10.0) Methyl ethyl Ketone (200.0)
Residuals Analysis
Parameter Analyzed For Parameter Analyzed For Parameter i Analyzed For
Aluminum Mercury Potassium
Ammonia- Molybdenum Selenium
Nitrogen
Arsenic Nickel Sodium
Cadmium , Nitrate- SAR
Nitrite
Nitrogen
Calcium % TS TKN
Copper pH Zinc
Lead Phosphorus
Magnesium PAN