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Home My WebLink AboutWQ0038087_NOD-2024-PC-0120_20240718ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality July 18, 2024 Delivered electronically via email to: David. coyle denaliewater.com David C. Coyle, Environmental Manager Terra Renewal Services, Inc. P.O. Box 1746 Watkinsville, GA 30667 SUBJECT: Notice of Deficiency (NOD-2024-PC-0120) 2023 Residuals Annual Report Terra Renewal Services RLAP Permit No. WQ0038087 Wilkes County Dear Mr. Coyle: On May 21, 2024, Division of Water Resources staff Caitlin Williams completed a review of the 2023 residuals annual report for the abovementioned facility, submitted March 1, 2024. This review reflected non-compliance with the subject permit, and the provided annual report is considered incomplete. On May 23, 2024, Mrs. Williams requested the following information be provided by June 7, 2024. To date, the requested information has not been provided- 1 . The field summary forms including AdvancePierre list the incorrect nitrogen values for two fields. Please provide corrected field summary forms for WK-MF-16 and W K-RJ-5. 2. The Residual Source Summary Form for Tyson Wilkesboro reports an incorrect value for lead for the 3/2/23 sample event. As a result, the field summary forms also have incorrect lead values. Please provide a corrected RSSF, and field summary forms for WK-MF-9, 10, 11, 17, YK-DM-5, and YK-WK-DM-8. 3. Several of the land application field summary forms have portions of the form blacked out. Please provide complete land application field summary forms for WK-MF-11, WK-MRF-5, 14, and 21. 4. The field summary form for WK-MRF-15 lists the incorrect landowner. Please provide corrected field summary forms. 5. The certification forms list 62 fields in the permit, but there are 63 permitted fields. Please provide a corrected copy of the certification form. 6. Please provide an explanation for the September sampling event as ammonia, mercury, phosphorus, pH, and PAN were not reported in the lab results. Was this just a partial sampling event for nutrient and metals while TCLP was collected? D North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 Moan caaouNn 336.776.9800 oep.m.m or em�nmen� Qualm 7. Please provide the freeboard records for the storage tanks, and all information required in Permit Condition IV.11. Staff calculated 442.97 dry tons were applied from Mathis -1 Storage Facility during April and October. Based on the records provided in the 2023 annual report, there is no way to determine the dry tons from individual sources stored in the storage tanks. Attachment A Footnote 9 of the subject permit states "the Permittee shall subtract any residuals placed into this storage structure from the Division - approved residual source's maximum dry tonnage per year." Staff calculated the total number of dry tons applied from Tyson — Wilkesboro as 1, 631 dry tons, and the Division approved maximum dry tonnage for Tyson — Wilkesboro is 2,000 dry tons. The dry tons of residuals from Tyson — Wilkesboro stored in Mathis — 1 could potentially cause non-compliance with the subject permit as the maximum allowable dry tonnage (2, 000 dry tons) is reduced by the dry tons stored in Mathis —1. Provide the requested additional information within fifteen (15) days of receipt of this Notice. The following deficiencies were noted: 1. Land application activities were reported for fields WK-MF-09, WK-MF-10, WK- MF-11, and WK-MF-15 in September and October 2023. A review of available records shows that the only land application notification for these fields was provided on March 17, 2024. Land application activities did occur at other fields between the time of notification and land application activities. Please be reminded that you are required to notify the Winston Salem Regional Office of all scheduled land application. Notification is also required if land application is not continuous and the most recent notification was more than one month prior to the commencement of activities. The requirements of an application notification can be found in Permit Condition 111.3. 2. Nutrient and metal sampling for Tyson Harmony Rendering Plant (River Valley Ingredients) was completed on 3/2/2023, 5/18/2023, 9/19/2023, 11/28/2023, 12/12/2023. Nutrient and metal sampling for Tyson — Wilkesboro was completed on 3/2/2023, 5/16/2023, 9/19/2023, 11/28/2023, and 12/12/2023. Staff calculations show that each source facility produced enough dry tons to require sampling once per quarter or four times a year. A review of field summary forms shows that residuals from Tyson Harmony Rendering Plant and Tyson — Wilkesboro were applied every quarter. The 9/19/2023 sample event for both facilities did not include ammonia, mercury, pH, phosphorus and PAN. Per Permit Condition IV.3, the residuals for each source generating facility shall be analyzed at the frequency specified in Attachment A and shall include specific parameters including those listed above. Based on the information provided in the report, Tyson Harmony Rendering Plant and Tyson — Wilkesboro were not sampled for all parameters included in Permit Condition IV.3. NORTH CARCLINAD ��R o.o+ro..m m EnNmnmenfnl n..i� North Carolina Department of Environmental Quality 1 Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 336.776.9800 The following item of concern was noted: A. Fields NC-WK-MF-13, WK-MF-17, and NC-YK-YF-03 reported zinc levels exceeding the North Carolina soil index value of 2,000. Continue to monitor the zinc levels in these fields as index values exceeding 2,000 can impact crop health. Please refer to the enclosed inspection report for additional comments and observations. If you have any questions, please contact Caitlin Williams at the letterhead address and phone number, or by email at caitlin.williams(a deg.nc.gov. Sincerely, DocuSigned by: OD2D3CE3F1 B7456_. Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Quality, NCDEQ — WSRO Enc: Inspection Report Cc: Wilkes County Environmental Health (electronic copy) Yadkin County Environmental Health (electronic copy) Luke Mathis (electronic copy) Jordan Mathis (electronic copy) D North Carolina Department of Environmental Quality I Division of Water Resources ✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly Compliance Inspection Report Permit: WQ0038087 Effective: 10/10/23 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: Todd Mathes Title: Phone: 972-996-7548 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0006548 Wayne Farms LLC - Dobson Plant NC0005126 Tyson Farms Inc - Harmony Rendering Plant Inspection Date: 07/15/2024 Entry Time 09:OOAM Primary Inspector: Caitlin I L(±v, lar��Signed by: Secondary Inspector(s): Rwms 968199D49D... Exit Time: 04:OOPM Phone: 336-776-9699 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 (See attachment summary) Page 1 of 5 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 07/15/2024 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: On May 21, 2024, Division of Water Resources staff Caitlin Williams completed a review of the 2023 residuals annual report submitted March 1, 2024. This review reflected non-compliance with the subject permit and the provided annual report was incomplete. On May 23, 2024, Mrs. Williams requested the following information be provided by June 7, 2024. To date the requested information has not been provided: 1. The field summary forms including AdvancePierre list the incorrect nitrogen values for two fields. Please provide corrected field summary forms for WK-MF-16 and WK-RJ-5. 2. The Residual Source Summary Form for Tyson Wilkesboro reports an incorrect value for lead for the 3/2/23 sample event. As a result, the field summary forms also have incorrect lead values. Please provide a corrected RSSF, and field summary forms for WK-MF-9, 10, 11, 17, YK-DM-5, and YK-WK-DM-8. 3. Several of the land application field summary forms have portions of the form blacked out. Please provide complete land application field summary forms for WK-MF-11, WK-MRF-5, 14, and 21. 4. The field summary form for WK-MRF-15 lists the incorrect landowner. Please provide corrected field summary forms. 5. The certification forms list 62 fields in the permit, but there are 63 permitted fields. Please provide a corrected copy of the certification form. 6. Please provide an explanation for the September sampling event. Was this just a partial sampling event for nutrient and metals while TCLP was collected? 7. Please provide the freeboard records for the storage tank, and all information required in Permit Condition IV.11. Staff calculated 442.97 dry tons were applied from Mathis -1 Storage Facility during April and October. Based on the records provided in the 2023 annual report, there is no way to determine the dry tons from individual sources stored in the storage tanks. Attachment A Footnote 9 states "the Permittee shall subtract any residuals placed into this storage structure from the Division -approved residual source's maximum dry tonnage per year." Staff calculated the total number of dry tons applied from Tyson — Wilkesboro as 1,631 dry tons, and the Division approved maximum dry tonnage for Tyson — Wilkesboro is 2,000 dry tons. The dry tons of residuals from Tyson — Wilkesboro stored in Mathis —1 could potentially cause non-compliance with the subject permit as the maximum allowable dry tonnage (2,000 dry tons) is reduced by the dry tons stored in Mathis — 1. Provide the requested additional information within fifteen (15) days of receipt of this Notice. The following deficiency was noted: 1. Land application activities were reported for fields WK-MF-09, WK-MF-10, WK-MF-11, and WK-MF-15 in September and October 2023. A review of available records shows that the only land application notification for these fields was provided on March 17, 2024. 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. 2. Nutrient and metal sampling for Tyson Harmony Rendering Plant (River Valley Ingredients) was completed on 3/2/2023, 5/18/2023, 9/19/2023, 11/28/2023, 12/12/2023. Nutrient and metal sampling for Tyson — Wilkesboro was completed on 3/2/2023, 5/16/2023, 9/19/2023, 11/28/2023, and 12/12/2023. Staff calculations show that each source facility produced enough dry tons to require sampling once per quarter or four times a year. A review of field summary forms shows that residuals from Tyson Harmony Rendering Plant and Tyson — Wilkesboro were applied every quarter. The 9/19/2023 sample event for both facilities did not include ammonia, mercury, pH, phosphorus and PAN. Per Permit Condition IV.3, the residuals for each source generating facility shall be analyzed at the frequency specified in Attachment A, and shall include specific parameters including those listed above. Based on the information above, Tyson Harmony Rendering Plant and Tyson — Wilkesboro were not sampled for all parameters included in Permit Condition IV.3. Page 2 of 5 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 07/15/2024 Inspection Type: Annual Report Review Reason for Visit: Routine The following item of concern was noted: A. Fields NC-WK-MF-13, WK-MF-17, and NC-YK-YF-03 reported zinc levels exceeding the North Carolina soil index value of 2,000. Continue to monitor the zinc levels in these fields as index values exceeding 2,000 can impact crop health. Other observations: • Advance Pierre (32.5 tons) o Fecal samples were collected on 2/28/2023. o Nutrient, metal, and TCLP samples were collected on 9/21/2023. • Tyson Danville (58.902 tons) o Fecal samples were collected on 12/7/2023. o Nutrient and metals samples were collected on 11/28/2023 and 12/7/2023. TCLP sampled were collected 11/28/2023. o Staff calculated SAR as 1.3 compared to the reported 1.5. • Tyson Harmony (652 tons) o Fecal samples were collected 3/23/2023, 4/18/2023, 9/14/2023, 11/30/2023. Staff calculated the geometric mean for the 11 /30/2023 samples event as 21,131 compared to the reported 21,230. o Nutrient and metals samples were collected on 3/2/23, 5/18/2023, 9/19/2023, 11/28/2023, and 12/12/2023. For the 5/18/2024 sample event, NH3 and TKN reported values were from the second analysis at the laboratory. For the 9/19/2023 sample event, ammonia, mercury, pH, phosphorus, and PAN were not reported. For the 11/28/2023 sample event, selenium was reported incorrectly on the RSSF. For the 12/12/2023 sample event, %TS was reported incorrectly on the RSSF and the incorrect value was used to calculate SAR. Staff calculated SAR as 1.5 for the 12/12/2023 sample event. o TCLP sample was collected on 9/19/2023. • Mathis Storage (442.97 tons) o Fecal samples were collected 2/28/2023, 4/20/2023, 9/19/2023, 12/7/2023. Staff determined the minimum value for the 9/19/2023 sample event was 2,954 not the reported 2,959. Staff determined the minimum value for the 12/7/2023 sample event was 155,945 not the reported 182,119. o Nutrient and metal samples were collected 3/2/2023, 5/18/2023, 9/19/2023, 11/28/2023, and 12/7/2023. For the 9/19/2023 sample event, ammonia, mercury, pH, phosphorus, and PAN were not reported. o TCLP sample was collected 9/9/2023. • Tyson Wilkesboro (1,631 tons) o Fecal samples were collected 3/2/2023, 5/16/2023, 9/2/2023, 11/30/2023. Staff calculated the geometric mean for the 11/30/2023 sample event as 4,486 not the reported 4,446. Staff determined the minimum value for the 9/12/2023 sample event was 1,439 not the reported 1,471. o Nutrient and metal samples were collected on 3/2/2023, 5/16/2023, 9/19/2023, 11/28/2023, and 12/12/2023. For the 9/19/2023 sample event, ammonia, mercury, pH, phosphorus, and PAN were not reported. For the 3/2/2023 sample event, lead was reported incorrectly on the RSSF form and the field summary forms. o TCLP sample was collected 9/19/2023. Page 3 of 5 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 07/15/2024 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? ❑ ❑ 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? ❑ ❑ ❑ 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: See summa 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 4 of 5 Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc Inspection Date: 07/15/2024 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: See summary. ❑ ❑ ❑ ❑ El ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE Page 5 of 5