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Home My WebLink AboutWQ0031762_Notice of Violation_20230718ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality July 18, 2023 Certified Mail No. 7019 1120 0001 5505 1831 RETURN RECEIPT REQUESTED JP Woodrum, Operations Manager Alltech, Inc. 11761 NC 770 East Eden, NC 27288 SUBJECT: Notice of Violation (NOV-2023-PC-0394) Compliance Evaluation Inspection and Annual Report Review Permit No. WQ0031672 Rockingham County Dear Mr. Woodrum: On July 17, 2023, Division of Water Resources (DWR) staff Caitlin Caudle completed a routine compliance inspection and review of the 2022 Residuals Annual Report. You were present during the entire inspection. A review of records, production facilities, and storage facilities was completed. This review reflected non-compliance with the subject permit. The following violation was noted: 1. Per Permit Condition IV.7 an annual report detailing all land application activities must be submitted by March 1st following the reporting year. At the time of inspection, the 2022 Residual Annual Report had not been submitted. Please submit the annual report within fifteen (15) days of receipt of this Notice. The following item of concern was noted: • DWR contact information was not listed in the Spill Plan. Ms. Caudle recommended including this information in the Spill Plan for any spills or bypasses related to the production, distribution, or application of residuals. Please refer to the enclosed inspection report for additional comments and observations from the compliance inspection. If you have any questions, please contact me or Caitlin Caudle at the letterhead address and phone number, or by email at or Caitlin.caudle(a-)-deg.nc.gov. Sincerely, DocuSigned by: OD2D3CE3F161416... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Rockingham 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: 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: 336-635-5190 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 07/17/2023 Entry Time 10:OOAM Primary Inspector: Caitlin C //'±8BV,80C.Signe/d by: I'� Secondary Inspector(s): (l�D&968199D49D... Certification: Phone: Exit Time: 10:50AM Phone: 336-776-9699 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Distribution of Residual Solids (503 Exempt) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping Storage (See attachment summary) Page 1 of 3 Permit: WQ0031672 Owner - Facility:Alltech Inc Inspection Date: 07/17/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: On July 17, 2023, Division of Water Resources (DWR) staff Caitlin Caudle conducted a routine compliance inspection. JP Woodrum, Operations Manager, was present during the entire inspection. A review of records, production facilities, and storage facilities was completed. This review mostly reflected compliance with the subject permit. The following item of concern was noted: • DWR contact information was not listed in the Spill Plan. Ms. Caudle recommended including this information in the Spill Plan for any spills or bypasses related to the production, distribution, or application of residuals. Other observations: • Offloaded ❑ Deactivated ❑ Evaporation ❑ Batch Tank ❑ Drier ❑ Bag House ❑ Bagged final product. • This facility processes spent brewers yeast into animal feed and ethanol. • The facility is no longer receiving the material that was creating residuals. This material was screened with a Sweco as it was offloaded, and screenings were funneled into 55 gallon drums before being spread. • Mr. Woodrum has sent some information to Hall Environmental for the permit renewal application. • Zebra is used to dispose of any fouled product. • The permit, operation and maintenance plan, spill plan, and emergency management plan were on site. Ms. Caudle sent the most recent requirements for required plans to Mr. Woodrum on 7/17/2023. • The plant has regular PMs that are completed and recorded by maintenance staff. The plant is automated to a certain extent and will alarm when needed, such as high levels in storage silos. • There are currently no storage structures for biosolids as none are being produced. Mr. Woodrum stated that if any biosolids that are produced, land application equipment can be acquired. • Current operations have multiple silos and bins with containment areas around them. Mr. Woodrum stated that he does not foresee land applying from these silos. The containment areas have valves to allow for the release of rainwater to stormwater ditches or to the city WWTP. • The bagged product is sold under different product names, but all labels have brewers yeast as the only ingredient with a minimum of 40% crude protein. • The 2022 Residuals Annual Report has not been submitted to date. This will be addressed in separate correspondence. • Please review the permit thoroughly before distributing any residuals. Page 2 of 3 Permit: WQ0031672 Owner - Facility:Alltech Inc Inspection Date: 07/17/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Land Application ❑ Distribution and Marketing 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? ❑ ❑ 0 ❑ 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: Page 3 of 3