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HomeMy WebLinkAboutWQ0038087_More Information Received_20190917 (2) 9/6/2019 Troy Doby; Engineer Non-Discharge Permitting Unit Water Quality Permitting Section Division of Water Resources North Carolina Department of Environmental Quality 1617 Mail Service Center Raleigh, NC 27699-1617 RE: Revisions to Storage Facility Proposal for Permit Modification – WQ0038087 Dear Mr. Doby, Terra Renewal Services is respectfully submitting the enclosed information pertaining to revisions regarding the proposed “Mathis-1” storage facility at the Myers Dairy in Wilkes County related to the modification of Permit # WQ0038087. This is a revision of the information originally submitted in the application package that was received by your office on June 25, 2019 and pertains to Section 5, “Storage Facility Information”. Details regarding the revision and the status of on-going activities are provided on the first two pages of this submittal. The Operation & Maintenance Plan has been revised based on the new pond selection and now includes sections pertaining to “Access Contol” and “Groundwater Monitoring”. The engineer reports will be forwarded to you upon receipt as the tasks are completed. The remainder of the information in the original application package (Section 5) that was gathered from the Nutrient Management Plan for the Myers Dairy is unchanged. As you review this information, please contact me if you have any questions, require additional information, or notice any action items that need to be addressed. I can be reached at david.coyle@terrarenewal.com or 479-747-8192. Thank you very much for your cooperation and assistance. Sincerely, David C. Coyle Environmental Manager cc: Patrick Mitchell; NC DEQ DWR Winston-Salem Regional Office East Region Environmental Office P.O. Box 1746 Watkinsville, GA 30677 phone 479.747.8192 Page 1 of 2 Proposal for Storage of Food Processing Residuals in support of NC Land Application Permit # WQ0038087 Permittee: Terra Renewal Services, Inc Wilkes County, NC REVISION: 9/6/2019 General: Terra Renewal Services, Inc. (TRS) is proposing to repurpose an existing storage pond at the Myers Dairy in Wilkes County, NC for storing food processing residuals that would otherwise be directly land applied from approved sources under Permit # WQ0038087. This storage is necessary for times when land application is precluded (inclement weather, adverse field conditions, during growing seasons, etc.), since the residuals are generated daily and the facilities do not have capacity for on-site storage. The storage structure is located at 3933 Bethel Rd, Jonesville, NC in Wilkes County. It consists of one earthen pond with a clay liner that was designed and constructed to support the animal feeding operation (AFO), which operates under Permit # AWC970004. The pond was constructed prior to 1993 (based on aerial images) and has a storage capacity of +/- 2.2 MG with 24” of freeboard. It is understood that this structure will have to be isolated from the existing wastewater system for the AFO, which will continue to operate at a smaller scale. A request for rescission of the structure from the AFO permit will be submitted at the direction of the NC DEQ Winston Salem Regional Office (WSRO). Contents (9/6/19): It was proposed in the original permit application that Pond #3 be converted for storage of residuals. Upon further assessment, it was determined that it is necessary (at this time) for Ponds #2 & #3 to remain as part of the AFO wastewater system to keep the dairy operational. The engineering report provided with the original permit application, along with all other data that is specific to the utilization of Pond #3, is now irrelevant. New data is provided with this submittal that gives information pertaining to the use of Pond #1. The following are provided with applicable revisions: 1. Maps  Topographic Location Map  Facility Location Map  Site Map 2. Diagram of System & Proposed Changes 3. Volume Calculations & Design Specifications from Myers Dairy NMP – November 2016 4. Revised Operation & Maintenance Plan (includes additions of Access Control & Groundwater Monitoring Plan) Page 2 of 2 Site Modifications: To keep the existing AFO system functional and to isolate Pond #1, the follow modifications are proposed: 1) Locate and abandon (prevent the flow from) the pipes that transfer wastewater from the Sand Lane and Pond #4 (flush water return pond). 2) Locate and abandon (prevent the flow to) the pipes that transfer wastewater from Pond #1 to Ponds #2 & #3 (the lower ponds). The modifications listed above are what are anticipated based on available documents showing design of the system, visual inspection of the surface features by TRS, and conversation with the dairy operator. These could and will change as necessary during the process. The pond designations above coincide with those provided in the design documents. A diagram (derived from the design documents) showing the existing system with proposed appurtenances to be modified is provided with this submittal. A copy of the engineer drawings from the Myers Dairy NMP were provided with the original permit application. Plans / In-Progress:  As of this submittal, BREC (engineering firm) has visited the site and performed an initial inspection of the outside structure of Pond #1. Their comments were specific to the north and northwest corner of the dam, which contains woody vegetation. This vegetation will be cleared, and BREC will perform a follow up inspection and issue a report. The report will be provided as part of the permit application upon receipt and the Winston-Salem Regional Office (WSRO) will be notified for their own inspection.  Cleanout of the pond is in progress. Once complete both BREC and the WSRO will perform an inspection of the interior pond and liner. A final report will be issued by BREC and provided as part of the permit application.  Two monitoring well installation “areas” have been identified, one upgradient and one downgradient of Pond #1. The downgradient well will reside between the pond and the residential well on the adjacent property. TRS is working with a well contractor and the WSRO to ensure that the wells are properly placed and installed to the correct depths. Preliminary (background) groundwater sample results from the downgradient well will be provided as part of the permit application once available.  The landowner, Landview Properties (Mathis), is working with the WSRO to complete the necessary steps for modification of the AFO permit (AWC970004) relative to the loss of Pond #1 and adjustments that must be made to the dairy wastewater system. Information and documentation related to all items listed above will be provided as they become available. 1) MAPS (Revision: 9/6/19) "MATHIS-1" STORAGEFACILITYBETHEL RDN R IV E R R ID G E R D Y AD KI N R I V E R to YADKIN RIVERUNNAMED TRIBUTARY YADKIN COUNTY WILKES COUNTY SWAN CREEK RDPERMITTEE: TERRA RENEWAL SERVICES, INC"MATHIS-1" Residuals Storage FacilityTOPOGRAPHIC LOCATION MAPQUADRANGLE:RONDAWILKES COUNTY, NCNSCALE:1 inch = 1000 feetPERMIT #: WQ0038087Produced: 5/31/19Revised: 8/27/19 (changed proposed pond for storage) ReTenrREalwAYADKIN RIVERB ETHEL R D "MATHIS-1" STORAGEFACILITYN RIVER RIDGE RD S RIVER RIDGE RDAFO SYSTEM PONDSAFO WASTEWATER IRRIGATION FIELDSWILKES COUNTY YADKIN COUNTY to YADKIN RIVERUNNAMED TRIBUTARY WILKES COUNTY YADKIN COUNTY SCALE:1 inch = 800 feet FACILITY LOCATION (CENTER OF LAGOON) Latitude: 36° 13' 14.22" N; Longitude: 80° 52' 47.74" W County: WilkesAddress: 3933 Bethel Rd, Jonesville, NC Landowner: Landview Properties, LLCPermittee: Terra Renewal Services, IncSTORAGE FACILITY LOCATION MAPPERMIT #: WQ0038087Produced: 5/31/19DWELLINGSTREAM / SURFACE WATER(DASHED-BLUE)(SOLID-WHITE)PROPERTY BOUNDARIESRevised: 8/27/19 (changed proposed pond for storage) ReTenrREalwABETHEL RDAFO SYSTEM PONDSAFO SYSTEM PONDS"MATHIS-1" STORAGEFACILITYAFO WASTEWATER IRRIGATION FIELDSAFO SYSTEM PONDto YADKIN RIVERUNNAMED TRIBUTARY WILKES COUNTY YADKIN COUNTY FREESTALL BARNSINGRESS / EGRESS I N GRE S S / EGRESSDWELLINGSTREAM / SURFACE WATER(DASHED-BLUE)(SOLID-WHITE)PROPERTY BOUNDARIESCONVEYANCE / DRAINAGE FEATURE FACILITY LOCATION (CENTER OF LAGOON) Latitude: 36° 13' 14.22" N; Longitude: 80° 52' 47.74" W County: WilkesAddress: 3933 Bethel Rd, Jonesville, NC Landowner: Landview Properties, LLCPermittee: Terra Renewal Services, IncSTORAGE FACILITY SITE MAPPERMIT #: WQ0038087Produced: 5/31/19Revised: 8/27/19 (changed proposed pond for storage)WELL 2) DIAGRAM OF SYSTEM & PROPOSED CHANGES (Revision: 9/6/19) 257'200'2.3:1Depth: 12.4'POND #1:to be converted to"MATHIS-1" STORAGE FACILITYFLOATING PUMPFLUSH WATER RETURN PIPECROSSOVERPIPESAND LANEPOND #2POND #4POND #3PIPEPIPEPIPEPIPEPIPEFLUSH DITCHFLOATING PUMPPIPEELECTRIC100'157'2.3:1TOP OF STRUCTUREBOTTOM OF STRUCTURE100 FT STORAGE FACILITY BUFFER(from inner rim of pond)PROPERTY CORNER(approximate)PROPERTY LINE(approximate)PROPERTY LINE(approximate)RESIDENTIAL (POTABLE) WELLDWELLING @ 8436 BETHEL RDCOMPLIANCE BOUNDARY(from rim of pond)COMPLIANCE BOUNDARY(from rim of pond)COMPLIANCE BOUDARY(from rim of pond)50'50'+/- 104'+/- 121'250' 125'REVIEW BOUNDARY(from rim of pond)REVIEW BOUNDARY(from rim of pond)INGRESS / EGRESSINGRESS / EGRESSPROPOSED GATE WITH SIGNAGEFREESTALL BARNSDIAGRAM OF EXISTING WASTEWATER SYSTEM & PROPOSED CHANGES (August 2019)- Estimated based on "System Plan View" produced by the North Carolina NRCS Area 1 Office obtained as part of the Nutrient Management Plan for Myers Dairy, Inc - November 2016 and site evaluation by Terra Renewal - 2019 (actual configuration may vary). Pond #'s coincide with design & NMP.- System components featured in Red will be altered (cut off) to isolate "Mathis-1" from the remaining AFO system. - The Compliance Boundary is established at either 250 ft from the rim of the storage structure or 50 ft within the property boundary, whichever is closest to the rim of the structure. The Review Boundary is established midway between the Compliance Boundary and the rim of the structure.ReTenrREalwAPROPOSEDDOWNSLOPE MONITORING WELL AREAPROPOSED UPSLOPE MONITORING WELL AREAPOLE BARN 3) VOLUME CALCULATIONS & DESIGN SPECS FROM NMP (Revision: 9/6/19) AT (MAX LIQUID LEVEL)AM (HALF of DEPTH)AB (BOTTOM)SLOPE = 2.3:1257' x 157'200' x 100'248' x 148'224' x 124'SLOPE = 2.3:12.0'12.4'10.4'2.3'1.0'V = D/6 (AT + (4 x AM) + AB)V = VolumeD = DepthAT = Top AreaAM = Middle AreaAB = Bottom AreaV = 10.4'6 ((248' x 148') + (4 x (224' x 124')) + (200' x 100'))V = 292,135 cubic ftV = 292,135 cu ft x 7.48 gal/cu ftV = 2,185,170 gallonsMaximum Volume of Pond #1 with 2 feet of Freeboard:VOLUME CALCULATION for POND # 1(based on dimensions given in NMP for Myers Dairy - November 2016) ReTenrREalwAMATHIS-1 Storage Facility; Terra Renewal RLAP; Permit # WQ0038087; 2019 4) REVISED O&M PLAN (Revision: 9/6/19) Page 1 of 6 OPERATION AND MAINTENANCE PLAN for STORAGE OF FOOD PROCESSING RESIDUALS NC DEQ DWR Permit #: WQ0038087 3933 Bethel Rd Jonesville, NC 28642 WILKES COUNTY I. OVERVIEW: Terra Renewal provides residuals management services to food processing facilities in North Carolina. The residuals, which are derived from the wastewater pretreatment systems at the generating facilities, are land applied for beneficial use as a soil amendment to permitted farm sites pursuant to permit No. WQ0038087. These residuals are generated year-round, on a daily basis. Storage is necessary to maintain a program which does not require diversion of residuals to other sites during times when land application is precluded (inclement weather, adverse field conditions, when growing assimilative crops, etc.) To this end, Terra Renewal will utilize an existing storage pond (hereafter referred to as “the facility”) that was originally designed and constructed to support the Myers Dairy at 3933 Bethel Rd, Jonesville, NC in Wilkes County. This dairy operates under NC DEQ DWR AFO Permit # AWC970004. The pond to be utilized is the one at the upper elevation adjacent to and west of the free stall barns. This pond is designated as “Pond # 1” in the Nutrient Management Plan (NMP) for the Myers Dairy dated November 2016. The coordinate location of the facility is Latitude: 36º 13’ 14.22” N; Longitude: 80º 52’ 47.74” W. The dimensions are listed below: Overall (Total) Dimensions: - Length at Top: 257 ft - Width at Top: 157 ft - Length at Base: 200 ft - Width at Base: 100 ft - Slope: 2.3 : 1 - Depth at base: 12.4 ft - Volume: 369,046 cu ft or 2,760,467 gallons Liquid Capacity Dimensions with 24 inches (2 feet) of Freeboard: - Length at Max Liquid Level: 248 ft - Width at Max Liquid Level: 148 ft - Length at Base: 200 ft - Width at Base: 100 ft - Slope: 2.3 : 1 - Depth of Liquid: 10.4 ft - Volume: 292,135 cu ft or 2,185,170 gallons * Dimensions are based on data provided in the NMP for the Myers Dairy – November 2016. The pond is not square or symmetrical, so dimensions represent the best fit average of the structure. ** 24 inches of freeboard is based on NC DEQ DWR specifications. This structure is located over 100 ft from the nearest well (not including monitoring wells). The closest residence is approximately 345 ft to the southwest at 8436 Bethel Rd, Jonesboro, NC. Page 2 of 6 II. ASSIGNMENTS: The facility will be disconnected from the existing waste management system for the animal feeding operation (AFO) which will continue to operate. The facility will be rescinded from the existing AFO permit and incorporated into Permit # WQ0038087 as a storage option to support the land application program. The permittee is Terra Renewal Services, Inc. (TRS). The landowner is Landview Properties, LLC. LJC Environmental, LLC (LJC) will conduct operations and maintenance of the facility as a contractor with oversight from TRS. TRS, as the permittee, assumes responsibility for compliance with the permit and management of the facility. TRS assumes no responsibility for issues relating to the management, operations, structures, or premises of the animal feeding operation or compliance / non-compliance with the AFO permit (AWC970004). III. RESIDUALS TRACKING & SAMPLING: Only residuals sources that are listed in “Attachment A – Approved Residuals Sources” of permit WQ0030387 will be stored at the facility. The comingled residuals will be designated as “Mathis-1” in Attachment A as an individual source and managed, as such, based on the sampling, tracking, and reporting requirements of the permit. Sampling will be performed at the frequency listed in the table below (from Attachment A of the permit): Dry Tons Applied Monitoring Frequency (short tons per year) (Established in 40 CFR 503 and 15A NCAC 02T .1111) < 319 1 / Year => 319 - < 1,650 1 / Quarter (4 times per year) => 1,650 - < 16,500 1 / 60 Days (6 times per year) => 16,500 1 / Month (12 times per year) * Monitoring frequencies are based on actual dry tons applied per year. This table will be followed for testing of metals and nutrients as stipulated under permit Condition IV.3 as well as pathogen reduction (based on seven set fecal coliform density test). TCLP, ignitability, reactivity, and corrosivity will be tested annually. The amount of dry tons from “Mathis-1” and the amount directly land applied from each source will be tracked separately and sampled at the appropriate frequency according to the table above, these amounts will be provided in the annual report. A storage log will be kept. When a load is placed into storage, that load terminates at the facility and becomes “Mathis-1”. When pulled from storage, a load will be designated as “Mathis-1” on the field logs and land applied based on the Plant Available Nitrogen (PAN) concentration from analysis of the comingled material. These residuals are being stored and not generated; thus, the number of dry tons land applied annually is a “zero sum” situation between what is stored and generated. Since the need for storage is dynamic and changes based on weather and crop rotations, then the number of dry tons applied from storage will also change from year to year. A maximum annual dry ton limit may be set for “Mathis-1” by deducting dry tons from other sources, but this number is simply a forecast. The maximum dry tons per year for “Mathis- 1” should be adjustable based on need. Therefore, the maximum dry tons per year for a single source that is typically designated in Attachment A of the permit is not applicable (N/A). Page 3 of 6 When loads are put into storage, the dry ton amount for that load should be deducted from the maximum dry tons per year for the generating source. When the number approaches zero, then the maximum annual dry ton limit for that generating source has been reached and additional loads from that generator may not be directly land applied under this permit. However, the loads that were placed in storage may be land applied. Both the dry tons directly applied and applied from storage will be tracked. At no time, should the dry tons applied annually, stored or applied directly, exceed the total maximum dry tons per year for all sources listed in Attachment A of the permit. Residuals residing in the facility at the end of the calendar year will be counted toward the total dry tons allowed for land application in the following year (by accounting). IV. OPERATIONS: Residuals will be transported to the facility in sealed tanker trucks equipped with vacuum/pressure pumps and 4-inch steel reinforced umbilical hoses. Residuals will be offloaded directly into the facility via gravity flow or vacuum pump. A staff gauge will be installed and maintained in the pond to measure and monitor freeboard. No less than 24 inches (2 feet) of freeboard will be maintained in the pond. Freeboard will be measured and documented on a weekly basis and after each rainfall event exceeding 1.0 inch within 24 hours. A permanent rain gauge will be installed on site. When freeboard approaches 24 inches from the rim of the structure (full storage), loads will be removed and land applied under the conditions of the permit. The residuals will remain in the facility until land application sites are available. In the event the facility reaches full storage and sites are not available for land application under permit WQ0038087, the residuals will be removed and hauled to permitted sites in South Carolina for land application. Removal of residuals should be initiated prior to the liquid level reaching the “full storage” level marker on the staff gauge. Prior to removal, the stored residuals will be slurried with an agitator (hog) pump system powered by a tractor and PTO. Residuals may be pumped from the bottom of the pond without agitation, so as not to disturb the surface, but only during times when odor is an issue. Agitation (mixing) will be required to achieve full cleanout of the facility using conventional methods. The residuals will be loaded onto sealed tanker trucks using 4-inch steel reinforced umbilical hoses and transported to permitted sites where they will be land applied based on the conditions of the permit. V. MAINTENANCE: Vegetation on the dams should be inspected periodically and reseeded as needed to maintain a vigorous stand. The dams should be mowed at least annually to prevent woody growth. Mowing operations must take place only when the soil of the dam is dry, and vegetation should not be mowed to a height of less than four (4) inches at any time. Any evidence of sloughling or erosion on the dams should be repaired immediately in a manner and using equipment that will not result in additional damage or stress to the structure. Vegetation should be reestablished on any areas of disturbance. Any evidence of seepage should be reported to the Winston-Salem Regional Office of the NC DEQ upon discovery. Ingress, egress, and loading areas should be properly maintained with gravel and vegetation to cover and reinforce soil and embankments. These areas should be constructed and maintained in a manner that diverts surface water and runoff away from the facility. Eroded areas should be repaired by backfilling, grading, and establishing cover. Page 4 of 6 VI. SPILL PREVENTION AND RESPONSE: This plan should be implemented in the event that residuals are spilled, leak, overflow, or run off site. Do not wait until a release reaches surface waters or leaves the property to consider that there is a problem. Make every effort to ensure that this does not happen. This plan will be posted and made accessible at the site for all employees and contractors at the facility. - For Spill Prevention, personnel shall take the following steps: o Ensure truck drivers and operators watch trailer & equipment while loading/unloading. o Ensure that hose connections, valves, and fittings are properly secured while loading/unloading. o Ensure container hatches/lids are closed and secured while transporting. o Inspect container hatches, lids, hoses, and fittings and replace or repair as necessary. o Ensure that loading/unloading operations are conducted to minimize spillage. - For Spill Response, personnel shall take the following steps: o Identify the source of the spill/discharge and attempt to curtail or stop the flow. o Immediately contact your supervisor. Explain the situation as thoroughly as possible. This will allow them to assess the situation and take appropriate action. o Familiarize yourself with the nearby terrain. If possible, try to contain the material or prevent it from flowing further or entering surface waters. o If you are able to contain the spill/discharge, attempt to vacuum up or collect the excess material before it can be absorbed into the ground, and/or prevent additional run-off. o If the spill/discharge was large enough to require a site visit from your supervisor, do not leave the area and do not remove or change any equipment. This will allow your supervisor to determine the correct cause of the incident. o When all clean-up procedures have been completed, apply a cover of ag lime to the area to deter odor and insect problems. o A TRS Environmental Manager will notify the regulatory authorities of the spill/discharge. Response equipment and supplies (backhoe/front loader, hay bales, shovels, powdered lime, tractor and disk) should be kept readily available for spill response. VII. ACCESS CONTROLS: Signage will be posted in a clearly visible and conspicuous manner at locations where public access would be most likely. The signs will be constructed of weather resistant materials, have a minimum area of three (3) square feet, and will indicate the activities conducted at the facility (e.g. “Storage of Class-B Residuals), permit number, and name and contact information (including the Permittee and Sub-Contractor phone numbers). Traditional “No Trespassing” signs will be posted along the property boundaries in the vicinity of the facility. A gate will be installed and maintained along the gravel access road that connects the facility to the two lower ponds (Ponds #2 & #3) that remain part of the AFO (Dairy) wastewater system. A sign will be attached to the gate stating that these ponds are for “Dairy Waste Only”. The intent of this gate and sign is to prevent inadvertent offloading or mixing of the residuals for the TRS permit (WQ0038087) with the wastewater from the existing dairy operation (AFO Permit # AWC970004). This gate is to remain closed, Page 5 of 6 with the sign clearly visible to oncoming vehicles, except during active maintenance or access associated with the dairy (AFO) operation. VIII. GROUNDWATER MONITORING: Two groundwater monitoring wells will be installed within 250’ of the rim of the pond (between the Compliance Boundary and Review Boundary or at the Compliance Boundary). One well will be located upgradient of the pond and one well will be located downgradient of the pond. The location of the wells will be determined by TRS, a consulting engineer, the NC DEQ DWR Winston-Salem Regional Office, and the well contractor based on evaluation of site characteristics, accessibility, and maintenance / protection requirements. The depth will be determined by the well contractor based on depth to groundwater and bedrock. A sign will be posted at each well providing the well identification number, depth, and diameter. Groundwater samples will be collected using the following protocol: 1) Record the well ID number, total well depth from top of casing, well diameter, time, date, air temperature during sampling, and person performing the sampling. A data log will be provided. 2) Make sure that the lid is locked and inspect the well and casing for damage, signs of tampering, or issues that require maintenance. Record observations & comments. 3) Prepare the sample bottles with proper labels. Set the bottles in an area where they are easily accessible and not exposed to any contaminants. Use only sterile, plastic, lab grade containers. Perform calibration on field instruments and record data where necessary. 4) Open the well cap. Using an electronic water level measuring device, measure the depth to the top of the groundwater level in the well and record the depth from the top of the casing. Clean (rinse) any part of the device that comes in contact with the groundwater using deionized water before and after use. 5) Purge the well using a bailer that is dedicated to that well or a new disposable bailer. If using a dedicated bailer, rinse with deionized water before and after each use. Purge the well three times until dry, allowing sufficient time between purges for the water level to recover (well to fill back up). If the well cannot be purged dry, then purge the well continuously for ten minutes three times, allowing thirty minutes between purges. 6) After the final purge, and once the water level in the well has recovered, rinse the bailer with deionized water, retrieve a water sample from the well, decant (pour out) the upper half of the sample in the bailer, and use the remainder of the water in the bailer to fill the sample containers. Repeat as necessary. 7) Conduct and record any field measurements. Parameters that require field testing are pH, specific conductance, redox potential, and water temperature. Refer to the permit for required testing parameters. 8) Seal the remainder of the containers and place them in a cooler with ice. Return the bailer to the well (if dedicated), lock the well cap, and make sure the area is secure. 9) Insure the samples stay cold (4 deg C) during transport / hold time and until received at the lab. A TRS Environmental Manager will coordinate laboratory receipt and documentation. Groundwater monitoring will be conducted three times per year, in March, July, & November. Testing parameters and reporting will be based on the requirements of the permit (as established by the NC DEQ DWR). Page 6 of 6 IX. INSPECTIONS: TRS and its subcontractors shall provide adequate inspection and maintenance to ensure proper operation of the facility and shall be in accordance with the approved O&M Plan. Any duly authorized Division (NC DEQ) representative may, upon presentation of credentials, enter and inspect any property, premises, or place on or related to the facility (as it relates to permit WQ0038087) at any reasonable time for the purpose of determining compliance with the permit; may inspect or copy any records required to be maintained under the terms and conditions of the permit, and may collect groundwater, surface water, or leachate samples. X. NONCOMPLIANCE NOTIFICATION: TRS shall report by telephone to the Winston-Salem Regional Office, telephone number 336-776-9800, as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first knowledge of the occurrence of any spill / discharge of residuals to surface waters or any other noncompliance as defined by this O&M Plan and the terms and conditions of the permit. Any emergency requiring immediate reporting (e.g. discharges to surface waters, imminent failure or overflow of the storage structure, etc.) outside of normal business hours shall be reported to the Division’s Emergency Response personnel at telephone number 800-662-7956, 800-858-0368, or 919-733-3300. Persons reporting such occurrences by telephone shall also file a written report in letter form within five days following first knowledge of the occurrence. This report shall outline the actions taken or proposed to be taken to ensure that the problem does not recur.