WQ0038087_Compliance Evaluation Inspection_20191007

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
October 7, 2019
David Coyle, Regional Environmental Manager
Terra Renewal Services, Inc.
P.O. Box 1746
Watkinsville, Georgia 30677
Subject: Compliance Evaluation Inspection
Permit No. WQ0038087
Terra Renewal RLAP
Land Application of Class B Residuals
Wilkes County
Dear Mr. Coyle,
A compliance evaluation inspection has been conducted of the subject residuals land application
program. North Carolina Division of Water Resources, Winston-Salem Regional Office (DWR)
staff member Justin Henderson performed the inspection on October 4, 2019. Jordan Mathis
accompanied Mr. Henderson during this inspection. The inspection reflects compliance with
Permit No. WQ0038087.
Please refer to the enclosed compliance inspection report form for additional observations and
comments. If you have any questions regarding this letter, please contact Justin Henderson or me
at [phone].
Sincerely,
DocuSig ed by:
Z_
ET SMd�
Lo1'4 WIE 5c 4
ssistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: Luke Mathis, ORC- lsmathis(&,gmail.com
Laserfiche Files (Electronic copies)
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NoanacaaouNn ^
o.P.ro�wmm�w�mmviw.i� /� 336.776.9800

Compliance Inspection Report
Permit: WQ0038087
SOC:
County: Wilkes
Region: Winston-Salem
Contact Person: Mike Brooks
Directions to Facility:
Effective: 06/29/18 Expiration: 01/31/21 owner: Terra Renewal Services Inc
Effective: Expiration: Facility: Terra Renewal RLAP
615 Mathis Farm Rd
System Classifications: LA,
Primary ORC: Luke Steven Mathis
Secondary ORC(s):
On -Site Representative(s):
Title:
Related Permits:
NC0005126 Tyson Farms Inc - Tyson Farms, Inc.
Inspection Date: 10/04/2019 Entry Time: 08:45AM
Primary Inspector: Justin L Henderson
Secondary Inspector(s):
Certification: 1003524
Roaring River NC 28669
Phone: [phone]
Phone: [phone]
Exit Time: 09:45AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503 Exempt)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Land Application Site Pathogen and Vector Attraction
Storage Transport
(See attachment summary)
Page 1 of 5

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 10/04/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection reflects compliance with Permit No. W00038087.
Page 2 of 5

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 10/04/2019 Inspection Type : Compliance Evaluation
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?
❑
❑ ❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑ ❑
Are there any GW quality violations?
❑
❑ ❑
Is GW-59A certification form completed for facility?
❑
❑ ❑
Is a copy of current permit on -site?
❑ ❑ ❑
Are current metals and nutrient analysis available?
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
❑ ❑ ❑
a. TCLP analysis?
❑
❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑ ❑
Are PAN balances being maintained?
❑ ❑ ❑
Are PAN balances within permit limits?
❑ ❑ ❑
Has land application equipment been calibrated?
❑
❑ ❑
Are there pH records for alkaline stabilization?
❑
❑ ❑
Are there pH records for the land application site?
❑
❑ ❑
Are nutrient/crop removal practices in place?
❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ ❑
Are hauling records available?
❑ ❑ ❑
Are hauling records maintained and up-to-date?
❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑ ❑ ❑
Comment:
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 3 of 5

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 10/04/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
e. Time/Temp on: ❑ ❑ 0 ❑
Digester (MCRT) ❑
Compost ❑
Class A lime stabilization ❑
f. Volatile Solids Calculations ❑ ❑ 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ 0 ❑
Comment:
Treatment
Yes No NA NE
Check all that apply
Aerobic Digestion
❑
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
❑
Compost
❑
Drying Beds
❑
Other
Comment: I ncorporation/I njection
Sampling Yes No NA NE
Describe sampling:
composite sampling conducted by taking several soil cores throughout application area then mixing up all
cores prior to takinga sample to be analyzed.
Is sampling adequate? 0 ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? ❑ ❑ ❑
Is a copy of the spill control plan in the vehicle? ❑ ❑ ❑
Is the spill control plan satisfactory? ❑ ❑ ❑
Does transport vehicle appear to be maintained? 0 ❑ ❑ ❑
Comment:
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? ❑ ❑ ❑
Is the application site in overall good condition? ❑ ❑ ❑
Is the site free of runoff/ponding? ❑ ❑ ❑
If present, is the application equipment in good operating condition? ❑ ❑ ❑
Are buffers being maintained? ❑ ❑ ❑
Page 4 of 5

Permit: WQ0038087 Owner - Facility: Terra Renewal Services Inc
Inspection Date: 10/04/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment:
❑❑■❑
❑ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑❑■❑
■❑❑❑
❑❑■❑
❑❑■❑
❑❑■❑
❑❑■❑
❑❑■❑
❑❑■❑
❑❑❑■
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 5 of 5

North Cat ohna Department of Environmentai Vuartry
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS B RESIDUALS LAND APPLICATION
General Information
Facility Name: terra J et,4 .9G-Q 1IZILIR
Permit No.: WOOD 336
Owner: 7g s'ra
Plant ORC Name: Lt)lte jnoais.
LA ORC / Contract Company: 11-ji' A CoW 1 e_
Other Contact(s):
Facility Location (address, gps or directions):
County: W 0 Kea
Permit Issuance Date: a /2
Permit Expiration Date: 1.131 /
Telephone No.: 7i3L)qgq -
Telephone No.: 7ci
Telephone No.: ?, !A L9.
2
Reason for Inspection
OUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary) j (� 'S ¢ (. t'.
Z,t t �ecbbely mwerNrs.c&& 1~ ales c}ed So r%v 63C6 ,ry., '}o Suc�txe 42-o o r
Coc krC.vtrlttl p� c�rvvrA-/suffice. '02.0 S+C- dCJdS
2.5 Its 4- Cet irr� (M. Cer`Frt his _ 3ca a�dket rqy Its
Z, L 12 \'A'Xvc^Q5 si c 11 reed Gv�a i3 p��4ege reAvCfior� re$vtrrner�s ce�.e a A ole
2, l Rest"dvcAs 51 u,11 be I'rjected jp tvae l V2ciu� ", &X-hon Ak(� VeS
r\ Eck 1 J c card, //
�c bi�c Utz �eeY der c� �i Loci � P1C � `3Z' � k3cticc supply -Z� loo J, R61,4 7 fib' /
yu��cse FlZ� `� Sa` i ualereiat(S -'1 ZS Welts lvo j &?�edrec� OulGrc� 2� j
Sw,• n-,rr� 1�Cls lUt Cif �S �i 15 l /
2,1 Lct,,d e^: sy be 0,-cd'14 lrc flrecL �nbr Z dvrern� evea.{
Z, 10 P3N Jo} 26Ceedo_c3
2, 11 0� ^ q?t0ce-b0% -)v ?c,3u"C- PitrS 6y 2.5 50 1
2.12 ;,,tile, cNCr-seaAeA ov &uble seedecL '7 ZTaGriAN @ 5�1bs
2_,13 Mu5-� ab)`ic% k,ti..Pl2rrat�a f$rpr vret��dlZnS n1�C5/LsS,e{z fvr re451Ave,QS L-A) SAS. iIC7
Z, Ic1 C(3 Z.S® Frcrr. bile— cr `jZy ►try r71L
Z, Z L 1 rc c n1Cg a1c §c 1Fv Tabe5 duc"trn e-ve 145 Use -Cc-
le
ejl c �l rv4 2Xceed 4 �r5: y� objecV;anGbO&r5 G[Cvr �� usck�¢- 51ti0.1 l
e e c 5-t,
Is a follow-up inspection necessary? ❑ Yes ❑ No
Primary Inspector: �%&6LZ
Date of Inspection:
Secondary Inspector:
(�
Entry Time: •^r
fb01��`i�y�
Exit Time: ck 1
.k\

Residuals Generating Facility
Was the residuals generating facility inspected? ❑ Yes 0 No
Residuals Storage:
Describe storage:
Number of days/weeks/months of storage:
Residuals Sampling:
Y
N
NA
NE
Is sampling adequate and representative? \ dt's
❑
❑
❑
❑
Describe Sampling:
Transport Vehicle: i
Y V
N
NA
NE
Is transport occurring at time of inspection?
0
❑
❑
❑
n Are necessary records (i.e. permit & spill plan) present in vehicle? ID of observed vehicle(s):
❑/❑
❑
❑
S14 N Record Keeping and Reporting Information:
Y
N
NA
NE
a Is current permit and prior annual reports available upon request?
❑
❑
El
❑
Has the facility been free of public complaints for the last 12 mont t. �� �c 02 .�X
0/
El
El
El
analysis conducted and results available? Frequency? /yr or El1/permit cycle
❑
❑
❑
❑
Residuals metals and nutrient analysis conducted? Frequency? : (See permit for frequency)
❑
❑
❑
❑
Nutrient and metals loading calculations? (to determine most limiting parameter)
❑
❑
❑
Do lab sheets support data reported on Residuals Analysis Summary?
Are PAN balance records available and within permit limits?
/1:1
El
Are there nutrient (crop) removal practices in place?
L�rj,/
❑
El
El
Are hauling records available? (gal and/or tons hauled during calendar year to date)
ffd
❑
❑
❑
Are field loading records available?
[
❑
❑
❑
Are field inspections conducted and are records available?
0
❑
❑
❑
Are soil sample results available? r ,A,)K'
❑
❑
❑
❑
Did soil results call for lime amendment? If so, are there records of application?
❑
❑
❑
❑
Soil results indicate that Cu & Zn indices are <3,000 (ideally <2,000)?
❑
❑
❑
❑
Soil results indicate Na <0.5 meq/100 cm3, and Exchangeable Sodium Percentage (ESP) <15%?
❑
❑
❑
❑
Does the permit require groundwater monitoring?
❑
0�
Are groundwater lab results present?
❑
❑ ❑
There are no 2L GW standard violations indicated in the lab results?
❑
❑
[❑
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction:
2h Alternative was used to demonstrate compliance?
:Alternative 1 Fecal Coliform Density
❑ Alternative 2 Process to Significantly Reduce Pathogens (5 options)
❑ Alternative 3 Use of Equivalent to RSRP (Not commonly used - See White House Manual)
If Alternative 2 was used, select which Optio as utilized and complete the section below.
❑ Option 1 - Aerobic Digestion
Y
N
NA
NE
Are logs present showing time and temper e?
❑
❑
❑
❑
Was the time & temp. between 40 days at 68' 0°C) and 60 days at 59' F 5°C)?
❑
❑
❑
❑
❑ Option 2 - Air Drying
❑ Option 3 - Anaerobic Digestion
Are logs present showing time and temperature?
❑
❑
❑
❑
Was the time & temp. between 15 days at 95° F— 131° F (35°— and
60 days at >68' F (20' C)?
❑
❑
❑
❑
❑ Option 4 — Composting (Not commonly used - See White Hou a Manual)
❑ Option 5 - Lime Stabilization
Are logs present showing time and temperature?
❑
❑
❑
❑
Was the pH raised to >12 after two his of contac
❑
❑
❑
Was the temperature corrected to 25' C (77' F by calculation, NOT auto correct)?
❑
❑
❑
❑
Page 2 of 4

Vector Attraction Reduction: Non -Discharge ("ompliance lospection Report
Select which Option was used to d
tio1 - 38% Volatile Solids emonstrate compliance and complete answer associated questions.
Opn Reduction
Are lab results and calculations present?
a ,theJeduetion on volatile solids (not total solids)? Y N
e samples collected at correct locations? ❑ ❑ (beg' ing of digestion process & before land application) ❑ ❑
Wash a a>38%reduction? ❑ ❑
❑ Option 2 - 40-Da Bench Scale Test
Were residu om anaerobic digestion?
Are lab results calculations present?
Was the test anaer ically digested in lab, and test run for 40 days?
Was the test done bet een 30°C (86°F) and 370C (99°F)?
Was the reduction of on olatile solids (not total solids)?
Was he reduction less ha 17%?
❑ Option 3 - 30-Day Bench Scale Te
Were residuals from aerobic di stion?
Are lab results and calculations pr ent?
Were residuals 2% or less total soli
If not 2% total solids, was the,
with unchlorinated effluent? est ran a sample diluted to 2%
Was he test run for 30 days?
Was he test done at 20°C (680F)?
Was the reduction of on volatile solids (not tot Was the reduction less than 15%? olids)?
❑ Option 4 - Specific Oxygen Uptake Rate (SOUR Test)
Were residuals form aerobic digestion?
Were residuals <2% total solids (dry weight basis) (no ted ?
Was he test done between 10°C (50°F) and 30°C (g F ) Was the temperature corrected ling holding . to 20°C (68°F)? )?
Was he tesWas the trstaz started within 15mi u es of sa Was the SOUR equal to or less than 1.5 tng or aeration mai
total residual solids m of oxygen per hour per
(dry weight basis)?
❑ Option 5 - 14-Day Aerobic Process
Were he residuals from aerobic
Was the average residuals temp
Were the residuals treated f
than 40°C (104°F) for the t or 4
' 4
❑ Option 6 - Alkaline Sta
Was the pH of the
Without addition o
Did the pH of res'
without the d ' io
Was the pH aneci
❑ Option 7 -
The r
U
tature higher than 45°C (113°F)?
days and temperature maintained higher
Period?
s uals raised to >12 and maintained for tw ore alkali? o hours
als remain at>11.5 an additional twenty-two hours
Of more alkali?
I to 25°C (77°F) (by calculation, NOT auto correct)?
ury g of Stabilized Residuals
e ' uals do not contain unstabilized residuals?
e residuals mixed with any other materials? the residuals dried >75% total solids?
5118 - Drying of Unstabilized Residuals
Were the residuals mixed with any other materials?
Were the residuals dried >90% total solids?
❑ Option 9/10 —Injection/ Incorporation of Residuals (Not commonly used -
Lpe_� b /_ GEC'
Page 3 of 4
NA NE
❑ ❑
❑
Y
❑
❑
N
❑
0
NA NE
El
❑ ❑
0 ❑
Y
❑
❑
0
❑
0
❑
NE
❑
❑
❑
❑
❑
❑
Q
❑
0
❑
1?
of
❑
❑
N
❑
❑
❑
NA
❑
�
❑
NE
❑
0
❑
❑
❑
❑
❑
N
❑
❑
NA
❑
❑
NE
❑
❑
\ED
❑
❑
❑
N NA NE
❑ ❑ ❑
Y N
0 El
❑ ❑
See White House Manual)
El
11
NA
NA

Non -Discharge ('ompliance Inspection Report
Land ADDlieation Sites) f (ease list Site ID(s) below.
0 es ❑ No
Were application site(s) inspected. I so, p
Application Site ID(s): t� - )
Is application occurring at the time of inspection? If no, note the date of the last event:—
Weat er Conditions: Overcast ❑ Stormy
® unny
❑ Partly Cloudy El Cloudy ❑
❑ No
eeze ❑ Calm
❑ Win (wind direction: ) Cloudburst
(If applicable, precipitation measurement:)
❑ Drizzle S ❑Rain o Precipitation ❑ No
Is there a rain gauge onsite? es11
Weather Notes (i.e. Significant Changes, Forecasts, etc): n t`'
60-80 >80 2 ,r✓etcs
Temp.<32 ❑ 32 - 40 ❑ 40 - 60 ❑ /
1z�
Was the Division notified of the application event(❑s)? No
I t `r M f � _ 1
fbsl f1c 1-e
application? yes W tl l Z IUs / flY, t'.
Permit and Spill Plan onsite during asp n [ :,.,,t,t n Cake ❑Other
licationObSOIVations: L. q A ApplicationSitc-FieldID(s): lbs/ac
i l� PAN Requirement:
Application Site -Field ID(s): 5 (� lbs/ac Intended Crop:
Intended Crop: 5
`( C:C"n PAN Requirement Application Rate(gallons/acre):
—�1 � I e L
Application Rate (gallons/acre): .C%�
PJ .�rtMLn' Nutrient Content: Yes No
Nutrient Content Z Application occurring at time of visit: ❑ ❑
Application occurring at time of visit: es ❑ No Application Method: ❑ Surface [I Incorp/Inlection
Surface co[p/tj.ctmn visit: ❑ Yes Cl No ❑ N/A
Application Method: ❑ tncorporation/Injection during
co[poratiodlnjection during visit: ❑Yes ❑ NO❑,CN/A Vegetative Buffer description: []No,, ❑Grass ❑Crop ❑ Shrub
YnS
Vegetative Buffer description: ❑None ❑Grass (�rop ❑ Shrub
❑Tree ❑ Other
❑Tree ❑ Other--4-Ay 14,,k �.� Current Field Conditions: ❑ pasture
CurrennField Conditions: 1S'� Bare ❑ Stubble ❑ Planted cm
` �,fGti +' ❑Pasture �C. ❑
[],*a ❑Smbble ❑ Planted�t Soil Condition, Sir
Soil Co ditiom ❑ Dry ❑ Moist ❑ Wet ❑ ❑ Snow -Covered
❑ ❑Moist ❑Wet ❑ Saturated ❑ Not -Frozen ❑ Frost ❑ Frozen >18%
l� Slope: ❑ 0-3T, ❑ 3-6% ❑ 6-10% ❑ 10-18% ❑
Cl Not -Frozen ❑ Frost ❑Frozen ❑ Snow -Covered Moderate ❑Strong
l�-V%� 6-10% ❑ 10-18% Cl >19% Odor. ❑ None ❑ Mild ❑
Slope: ❑ 0-3% Few ❑ Many ❑ Excessive
ClOdorNo er © Id ❑ Moderate ❑ Strong Vectors:. ❑ None ❑
Vectors:
Von
Few ❑ Many ❑ Excessive Y N NA E
Vectors: L. one � � NA NE Application Details: ❑ ❑ 0 ❑
Y ❑ ❑ Application areas clearly marked?
Application Details: - rj A ❑ ❑ ❑ ❑ ❑ ❑
Application areas clearly marked? �ip1 Application within authorized area?
❑� ❑ ❑ Application method appropriate? Cl ❑ ❑ ❑
13
Application within authorized area? ❑ ❑ Application is even (no pending)?
Application method appropriate? ❑. ❑ ❑ 0 ❑ ❑ ❑ ❑
Application is even (no r o appropriate?
Sufficient setbacks from wells/residences? ❑
❑ ❑ 0 ❑ Sufficient setbacks from surface waters? ❑
Sufficient setbacks from wells/residences? Slopes >10% avoided (Surface App.) ? ❑ ❑ ❑
Sufficient setbacks from surface waters? ❑ Slopes >18% avoided (Incorp/Inject) ? ❑
Slopes >10% avoided (Surfacc App) ? ❑ Cl ❑ Cl moors /Injection within time -frame? 0 Q ❑
Slopes >18% avoided (Inco[p/Inject) ? ❑ ❑ ❑ Biosolids visible on surface?
within time-frame9 , 4-'r fi Lr ❑ ❑ ❑ N NA NE
Incorp./Inlecnon c-
Biosolids visible on surface?
❑
NA NE
y6y
Site Restrictions resent?
is restricted / Signage p
❑ 0 0
Public access
Grazing restrictions are met?
0
Transfer of biosolids is in permitted area?
,�
No evidence of shallow GW?
restrictions?
Ia�V,U�
Sufficient timing for harvest
NA NE
Off Site Transport
(� 110
Tracking is prevented?
Bm,ofids ran -off is prevented?
Windblown biosolids prevented?
❑
�
Vegetative buffers exist?
Site Restrictions resent?
is restricted / Signage p
Y
❑
❑
❑
❑
❑
Cl
❑
Public access
Crazing restrictions are met?
in area?
�
❑
❑
11
.Transfer of biosolids is permitted
of shallow GW?
❑
❑
❑
❑
No evidence
Sufficient timing for harvest restrictions?
N
NA
Off site
Y
O
Is prevented?
Tracking is prevented?
mn-off is prevented?
0
O
0
0
IBiosolids
Windblownbiosolids prevented?
❑
Cl
❑ ❑
Vegetative buffers exist?
Page 4 of 4
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