550007_Request Final Approval_20240821

August 21, 2024
To: Christine B. Lawson,
Engineer
Animal Feeding Operations
Mooresville Regional Office
Division of Water Resources, NCDEQ
450 W. Hanes Mill Rd, Suite 300
Raleigh, North Carolina 27105
Subject: Request for Final Approval
Application No. ADC550007
Beam Dairy
Lincoln County
Dear Christine,
SRNG-Beam, LLC is requesting final approval of the remaining unapproved scope of the SRNG-Beam
project as shown in the attached as -built drawings, written certification, and other supporting details
and photos.
On 7/29/2024 NCDEQ made a site visit with the Farm owner and SRNG representatives to inspect the
installation against the final as -built drawings. The following items were raised by NCDEQ on
7/31/2024. We respectfully submit below, responses to the individual requests:
1. Regarding the previously submitted as -built drawings — please provide clarification
that all structures were built as designed. Any deviations from the previously
submitted designs will need to be updated and new as -built documentation submitted.
SRNG-Beam previously submitted an as -built drawing package including S000 - S401 R3 for
the digester scope which reflects the engineer certified as -built condition of the digester
structure. Additionally, drawings G1-00735-01 and SP100 were also submitted which include
the flare, piping, and other appurtenances. These items were installed per design, without
modification, so these revisions serve as the as-builts. These drawings were reviewed by
NCDEQ, and SRNG-Beam was granted partial approval to continue testing of the digester.
There have been no modifications and there are no as -built drawing updates for this
previously submitted and approved scope.
2. DWR will need language for both of the waste ponds in the digester project footprint to
show that the structures have been restored to previous built design prior to digester
construction, please compare to the design in the CAWMP. This includes the areas of
construction for the valves located in the spillway, P-1 and piping, P-2 and piping, and
the anti -seep collar drawing — effluent and piping.
The attached AYES as -built drawings dated 8/13/2024 call out elevations, including existing
waste pond elevations and the elevations of newly installed structures. The elevations and
volumes of the waste pond dams were not changed and were restored their original
condition. As stated on the as -built drawing, all work conforms to NC standards and specs

for the work shown on the drawings.
3. The valves installed in the spillway of the WSP by Barn 100 (WSP containing P-1 and
P-2) are not shown on the as -built drawings. Please update or identify where the
design for the valves is.
The valves are shown on the AYES as -built drawing dated 8/13/2024 in enlarged detail P-1 &
P-2 on Sheet 1. AYES has added "As Built" to detail.
4. Anti -seep collar— effluent structure is at ground surface however, the as -built drawing
has a design that is at a lower elevation — please explain and/or modify the as -built
drawing.
AYES as -built drawing dated 8/13/2024 Sheet 1 has been updated to show the as -built
conditions of the anti -seep collar concrete detail. The revised detail shows the top of
concrete at ground surface.
5. Please address the pipe length for the effluent discharging into the waste pond.
Effluent discharge has the potential to erode the dike wall and clay liner if not properly
installed (a BMP pipe extension may be advised).
Please see Exhibit 1 for photos of pipe extensions as recommended by NCDEQ to ensure
proper discharge into the pond, which eliminates any potential of erosion of the dike wall and
clay liner.
6. The as -built drawings show the effluent discharge pipe dead -ends under the calf huts
and is not connected to the digester. Mr. Hertz explained this will be addressed and/or
amended on the as -built drawings and will be provided.
AYES as -built drawing dated 8/13/2024 Sheet 1 `INFLOW ANIT-SEEP COLLAR LOCATION
PLAN' has been updated to show the as -built conditions of the effluent line from P-8 to the
waste lagoon discharge point.
7. To the south-west corner of Barn 100, the stormwater collection storage container was
not effectively operating. It appears there was damage to the PVC pipe at the bottom of
the stormwater collection storage container had an extended line draining away from
the waste pond structure into the ravine. This results in the overland flow of
stormwater causing erosion of the embankment. The ground was bare without
vegetation, proximal to P-1 and SS piping. Please address and/or fix any potential
damages to the waste pond structure.
The Barn 100 stormwater collection system's operational issues are being addressed by the
farm owner. This system is not part of the scope of the digester permit.
The farm owner has contacted Sam Bingham to assist with this issue. In the meantime, the
farm owner is in process of having a temporary PVC line installed to divert flow and will install
a permanent PVC line to transfer the water away from the waste structure per engineering
recommendations. The farm owner will restore surface conditions, seed, and straw the area
once the permanent line is in place.
8. Within the "P-1 and P-2 Area Plan" there is a stormwater drop inlet that is not shown
on the as-builts. The drop inlet is located between the two barns. Proximal to the inlet
is a high traffic area with feed, bedding, waste piles; this creates a potential for

conveyance of waste. While the drop inlet is not shown on the provided drawings, the
Stormwater Discharge (SD) Existing (Ex) 10" HDPE line travels in the same flow path is
shown. This SD Ex pipe leads to "Install Drop Clean Out & 20 LF of 10" HDPE Pipe @
0.5% slope" and "Install 5'(w)x8'(I)x1'(d) Rip Rap Dissipator Use 6" D50 stone". During
the site visit the new 20 LF HDPE pipe and Rip -Rap Dissipator were not yet installed.
Please address and/or install as designed.
The stormwater system shown on AYES as -built drawing has been revised to clarify that the
stormwater system shown is farm owner scope, not SRNG-Beam digester permit scope. The
drawing details work for the farm owner to achieve proper drainage of the farm's stormwater
system across the SRNG manure pipeline and into the adjacent ravine.
The farm owner has contacted Sam Bingham to assist with this issue. After the site visit, the
farm owner moved all the objects in that area along with cleaning up of all the debris. The
farm owner has also implemented a protocol for the area to be cleaned of all spilled and
tracked feed twice daily.
9. There was a water tank observed in proximity to the Biogas Unit where an onsite
representative stated it was used to cool the engine. Please describe the purpose, use,
how the liquid is disposed of, etc.
The purpose of this tote is to capture process condensate from the Biogas Upgrading
System. Small amounts of condensate are generated through the upgrading process and will
be captured in this tote. It is expected that the tote will fill over the course of several
weeks/months. SRNG-Beam operators will routinely check the level of the tote and transfer
the contents from the tote to the waste pond.
10. Onsite representatives mentioned a descriptive letter written by Aiken & Yelle
regarding the as -built drawings provided 7/26/24. Please note that no such letter or
engineering certification form has been received.
Please see attached Engineer's Certification letter from AYES.
11. Other outstanding items previously noted are the calf but waste and silage leachate.
DWR understands Mr. Beam is working with Sam Bingham, PE, to address these
concerns.
The farm owner is working with Sam Bingham to address these issues. The farm owner also
contacted local soil and water and NRCS. The farm owner filled out an application to apply
for funds to help cover the expense of construction on both issues. Currently the farm owner
is awaiting the engineering plan and the securing of funds.
NCDEQ has also raised the following items outside of the written list. SRNG wishes to address these
items:
I. How often we will clean the level sensor at MRP (Pit 5)
SRNG-Beam operators will clean and check the Pit 5 level sensor (and other instruments) daily
which work orders will be monitored by O&M management via FIN software. In the case of
sensor interference or failure, a low/high level or loss of signal alarm will be sent to SRNG-
Beam Operators via the site's VTSCADA alert system. The alert system is programmed for on -
site HMI, text message, email, and phone call escalating alarm notifications as described in the
following item. Pit 5 also has a high level overflow line to gravity transfer high level waste to Pit
8 to be transferred to the waste pond.

II. How the alert system works for MRP
All process instruments are tested and connected to VTSCADA during commissioning before
operation.
The VTSCADA Alert System works as follows:
1. Alerts are configured within VTScada and viewed within VTScada
2. Critical Alerts are viewed within VTScada.
Also, Critical Alerts do trigger an email and text (via vtext service) to plant operators
3. If Critical Alerts are NOT "Acknowledged" as follows:
- By a plant operator at the Plant; or,
- Remotely from email / text notice
4. Then, a phone call is triggered from the Twilio server that is configured.
Note: If the email / text service goes down, yet VTScada is operational and syncing with
VTScada on -premise with VTScada in Azure, then a phone call alert is triggered.
5. If the communication between VTScada on -premise and VTScada Azure is broken, then
an alert is triggered to notify Sustain RNG's IT Team to review the VTScada system and
troubleshoot the reason for NO Sync with VTScada. Also, the troubleshooting includes
checking if Critical Alerts are occurring but alerts are NOT sent out. If such is occurring,
then support is provided to correct the issue.
III. Mesh over the storm water drain to prevent rocks from falling in
Mesh has been installed over stormwater drains as requested by NCDEQ. See Exhibit 2 for
photo.
IV. Flags or chain around valves to prevent damage by mower
Stakes and flags being installed around the valves as requested by NCDEQ. See Exhibit 3
showing photo of temporary flagging. SRNG-Beam plans to install permanent flagging/barriers
to prevent damage to valve boxes.
V. Confined space sign at effluent pit
Confined Space Signage has been installed as requested by NCDEQ. See Exhibit 4 for
photo.
Respectfully,
SRNG-Beam, LLC

Exhibit 1
Pipe extensions as recommended by NCDEQ
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Exhibit 2
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