NC0063096_Pretreatment_Annual_Report_20220317

Page 1 of 4
The Town of
HOLLY
SPRINGS Department of Water Quality
Town of Holly Springs (NPDES, NC0053096)
March 15, 2022
(An extension of March 15'" was granted on February 11, 2022 by Kristin Litzenberger-
email attached)
GENERAL PROGRAM INFORMATION
• Attached is the Pretreatment Program Info Sheet/EOY Letter (Attachment# 1)
• The HWA was submitted to DWR on 10-30-2017 and approved 02/22/18. The
allocation table attached is representative of our most current approved HWA/AT.
(Attachment # 2)
• The Town of Holly Springs was granted a recension of the land application permit
WQ0019098 in a written letter dated August 29, 2017. The Town did not land apply
sludge in the calendar year 2022.
• The LTMP was submitted to PERCs Unit August 31, 2018 and Approved October
26, 2018,
• Pretreatment Performance Summary with explanations (Attachment 3)
• The IWS was submitted on September 30, 2021 but has not yet been reviewed and
approved. Confirmation of receipt was October 1, 2021(Attachment # 4)
• Unfortunately, our industrial sampling staff was challenged due to the effects of
COVID 19 Brendan Reeser is no longer employed by the Town of Holly Springs. A
replacement has been hired but at start date ha not yet been established.
GENERAL PERMIT INFORMATION
• Town of Holly Springs has two Significant Industrial users(SIUs) one of which is also
a Categorical Industrial User (CIU) Neither has been in SNC during the year 2022.
• The Town of Holly Springs also has 16 Dental Practices that require amalgam
separators Inspections were made at each.
SIU INFORMATION
South Wake Landfill, (IUP # 001) Known as SWLF
• On March 18t", contact was made to George Metcalf, Cliff Manz, and Seth Gundersen in
regards to BOD values reported on the February DMR for the Values appeared to
abnormally low. They too had noticed and contact their contract lab and was told that the
P.O. Box 8 • 150 Treatment Plant Rd •Holly
Springs, NC 27540
•Tel. [phone]
debra. battenCa�hollysorinpsnc.gov

Page 2 of 4
results were accurate. I had SWLF request copies of the laboratory bench sheets of which
were forwarded to me after multiple conversations with the contract lab it was determined
there were some calculation errors. Corrections were made and a corrected DMR report was
received on April 26th. Though the corrected DMR was not received until April it
Was decided not to issue any NOVs as SWLF was doing their best to resolve the issue.
SWLF was given suggestions what to look for in the BOD calculations to make sure the data
submitted with their DMR is most Accurate. (Attachment# 5)
• The Town of Holly Springs conducted its first semiannual monitoring on February 16, 2001 but
failed to analyzed the sample for pH and Temperature within the required 15 minutes of
collection and SWLF had completed its discharge for the day. A sample was collected for pH
and Temperature on February 17, 2021.
• The sample which had been collected for metals on February 16�h did not maintain the pH of
< 2.0 as required for preservation. A replacement sample was collected on March 23, 2021 for
the first semiannual monitoring, but it too would not maintain the pH required. After talking with
the NCDWQ Lab certification, we were told that should the characteristics of the wastestream
be such that and according to policy preservation must be of sufficient concentration so as not
to dilute samples by more than 1 %. If this occurs that it is to be documented and the analysis
run and results reported.
• On May 10, 2021 there was(#1)a pH Violation of 10.99. In addition to the pH violation there
was a second violation for (#2)failure to report. Contact was made to John Robinson of SWLF
and George Metcalf of GFL in regards to the violation. Explanation was given as to the
importance of being familiar with permit limits on analysis that have the 15-minute hold times
such that additional sampling be performed to show compliance has being received as soon
as possible. As the violation went un noticed, recollection was not possible during the
monitoring period. Additional samples were collected and analyzed May 17th and 24th, were
within compliance range indicating compliance once again had been achieved. During the
investigation process, it was also brought to the attention of TOHS the results reported were
from analysis performed by SWLF staff who do not hold certification for those parameters
which was determined to be a third violation of their Pretreatment permit (#3) Reporting results
for compliance monitoring that were performed by a non -certified lab. As a result of the
violations according to the SUO and ERP there was a $500 civil penalty issued and collected
for the referenced violations. (Attachment # 6)
• Seth Gunderson reached out to me about a questionable ammonia result from his lab.
Apparently SWLF had performed process control analysis so as to not discharge a flow at a
high enough concertation to allow for a violation. Is process control result was 1200+ and the
report from the lab was 129 mg/L. after asking his contract lab to confirm the result, the lab
revised the report to a reported value of 1070. Much more plausible with the result from the
process control analysis. (Attachment # 7)
• Communication was made from Seth Gundersen on July 26th that the discharged flows would
be scaled back for the remainder of July based was process control data was indicating the
ammonia values elevated could cause an exceedance of their permit limit. (Attachment # 8)
P.O. Box 8 • 150 Treatment Plant Rd •Holly
Springs, NC 27540
•Tel. [phone]
debra.battenCa
hollvsorinasnc.cov

Page 4 of 4
recommendation going forward is to make sure the data is reviewed as soon as it is available.
(Attachment #18)
• Nilsa sent an email notification of her resignation effective August 13th naming Ellen Lorusso
as contact until her replacement was hired. Robert Resek continues as a contact as well.
(Attachment #19)
• The Annual Pretreatment inspection was scheduled for November 2, 2029 but after multiple
times of rescheduling due to staff shortages in TOHS Environmental compliance the inspection
was finally conducted on December 28th, 2021. (Attachment #20)
• A new pretreatment contact was introducing during the inspection conducted as AnneMarie
Baese. Robert Resek and Ellen Lorusso remain as contacts as well.
• PAR (SNCR- Seqirus) 2021 (Attachment #21)
• Compliance Judgement Forms(Segirus) (Attachment #22)
• Industrial Data Summary Sheets(Segirus) (Attachment #23)
Triangle Truckwash
Though not a SIU there was an inspection conducted at Triangle Truckwash to verify operation
of the Oil Water Separator and a sample was collected to verify removal efficiency. All was in
order. PAR (SNCR- SWLF) 2021 (Attachment #24)
Dental Amalgam Inspections
There a total of 28 dentist practicing in TOHS. Of the 28 practicing in TOHS. As some dentist
practices have shared dental clinics, there were only 16 clinics with amalgam separators and in
accordance to our Sewer Use Ordinance received their Annual Inspections. The attached
summary details the inspection of each practice and the results. All were found in compliance
prior to the year ending. PAR (SNCR- SWLF) 2021 (Attachment #25)
De a C. Batten
E ironmental Compliance Manager/Pretreatment
Utley Creek Water Reclamation/Town of Holly Springs
P.O. Box 8 • 150 Treatment Plant Rd •Holly
Springs, NC 27540
•Tel. [phone]
debra. battenCd)hollvsorincsnc.gov

Page 3 of 4
• Communication was received from Seth Gundersen on August 4th that the SWLF had received
a second ]UP from the City of Lumberton. As such he acknowledged that I would be receiving
additional data as the IUP issued by TOHS requires all data from the Effluent be submitted
with their monthly DMR (Attachment 9)
• Contact was made on August 23, 2021 that TOHS had not received the TTO certification for
the first 6-month compliance period and that as required by the permit TOHS would be
collecting and having the TTOs analyzed. (Attachment # 10)
• Notification was also given that there would be an installation of VFD which would control the
motor to allow specific flow rates. The formal letter was received form Seth Gundersen on
September 1st stating install would take place the week of September 6th, 2021,
(Attachment 11)
• Correspondence was made to Seth Gundersen reminding him to leave fields for flow blank.
Entering the "0" values skews the data calculations for averages. DMR was
corrected, (Attachment 12)
• On October 26th, 2021 meeting request was made to discuss a change of plans for the system
upgrades that had been previously been planned for SWLF Leachate pretreatment. That
meeting was held on November 16th 2021. A reminder that at the end of 2020 plans were
submitted by Katie Jones of Dewberry Engineering. Those plans included the reseeding of the
Leachate storage tank. Initial hope was that they would be able to add a Nitrifiers and operate
the tank in a continual aerations mode until nitrification was established. After multiple
attempts of adding the concentrated sludge and failure to achieve stable nitrification, it was
decided that it would be in the best interest to evaluate another process. At the meeting of this
discussion were representative from TOHS, SWLF, Dewberry Engineering and ROCHEM
Americas. A presentation was given of the new design for a Reverse Osmosis System. Plans
are to be presented for install with competition expected by year end 2022, (Attachment 13)
The Annual pretreatment Inspection for SWLF was completed on November 10th 2021 and
everything was in order. (Attachment #14)
• PAR (SNCR- SWLF) 2021 (Attachment #15)
Compliance Judgement Forms (SWLF) (Attachment #16)
• Industrial Data Summary Sheets (SWLF) (Attachment #17)
Seqirus,
(IUP#002)
• Notification was sent on June 7th of a Chloride violation for the sample collected on May 11th,
2021. The analysis was repeated and an average of three results were used after the EPA
guidance was verified by Diana Yitbarek of NC DWQ. As the report was not reviewed until
June 7th the recollection could not be completed within the same sampling period. However,
arrangements were made and there were samples collected on June 8tn 9th and 10th. All were
well within the permit limits. An investigation was also completed by Seqirus with no findings
of what had caused the violation. As Seqirus creates a means to make sure all sampling of the
permit is scheduled on a routine basis and the sampling is done as soon as possible, the only
P.O. Box 8 • 150 Treatment Plant Rd •Holly
Springs, NC 27540
•Tel. [phone]
debra. battenirD.hollvsorinasnc.aov

PrOreatment P ogram Info 1, Aase
for Program Name Holly Springs
WWiP Name Utley Creek t
Program Approval Date 09/05/2006
Pretreatment Status
Full
Region
RRO
County
Wake
NPDES Number
NCO063096
ATTACHMENT 1
printed on: 1 /18/2022
Stream Information IWC q at 7Q10 98.83
7CN0-FTow cfs / mgd .11 / 0.07
1 Q10 Flow cis / mgd 0.09 / 0.06
Stream Classification C
Basin Number CPF07
Receiving Stream Name Utley Creek
NPDES Effective Date 1/20Last PAR Rec 02/26/2021 PAR Due Date 03/01/2022 mercury
11631
NPDES Expire Date 07//31 /2021 21 Current Fiscal 09/04/2020 required
Year PCI Done
POTW is Primary W WTp TRUE Last Audit on 09/07/2017 Audit Year Next21/22 yes
Designd 6.0000 / Design mgd is SIU permitted 5.00 Permitted SIU flow (mgd) [Pt-SIU)�
WWiPSIU''a ProgramSlUs 2 --��
WWiPCIU's 10 Program CIUs1 HWA LTMP IWS ,,� SUO ERP
date Inactive Date Next Due 05/01/2022
Date Received by DWR _ 12/31/2016 0 1331/2018 09/30/2021 11/08/2012 06/22/2010 '..
Date Approved 02/22/2018 10/26/2018 12/07/2012 08/04/2010
Adopt Date Required
Date Adopted 11/06/2012
Info in this Box from Pt Contacts
Date Date Date
PT Pro Attended Attended Attended
Formal Name a. Prime Phonel ext Fax HWA WksD IDP Wksn PAR Wl<sn
Mr. Seann Byrd
919-577-1090
919-577-2280
[e-mail]
Public Utilities Director
P.O. Box 8 j27540
Ms. Katelyn Tresino
1
11919-577-2273
11
Lab Technician
P.O. Box 8
27540
Debra Batten
1prim
[phone]
4/11/2019
5/24/2016
[e-mail]
Laboratory Manager/Pretreatment
P.O. Box 8
27540
DWR Central Office Contact McGee 6 Miller
DWR Regional Contact Cheng Zhang

DocuSign Envelope ID: 73COD794-1 C74-422B-BF1 E-258E286F6262
ROY COOPER
Govemor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
January 18, 2022
Subject: End of 2021 Pretreatment Mailing
Dear Pretreatment Professionals:
After another complex pretreatment year, we wanted to provide you an update on some issues,
inform you on this year's upcoming workshops and distribute the Pretreatment Program Info
Database sheets.
1. Manufacturers
Register:
The Division now has access to an
online Manufacturers
Register
that can be downloaded
and emailed. POTWs can request a
copy of the register at
any time.
2. Rules U dD ates: This is a reminder that the State Pretreatment rules (.0900) were updated
effective on July 1, 2019. Per 15A NCAC 02H .0917(a), each control authority shall
transmit to the Division copies of all significant industrial user pretreatment permits 30
days prior to the effective date. Please note that approved permit writers can submit the
IUPs at the time of issuance. More details on how to become an approved permit writer can
be found on the Permit Writing Guidance page.
3. E-reporting: EPA postponed the deadline for E-reporting to December 21, 2025. An in-house
program is in development for potential Pretreatment Annual Report (PAR) submission
along with the other required Pretreatment ICIS data elements due in 2025.
4. Municipal Permitting Reorganization: Pretreatment and collection system have moved under
the Municipal Permitting to Advantages of this is to combine the NPDES permit limit
development with the Headworks analysis, to jointly improve NPDES direct discharger and
POTW/SIU disclosure of emerging compounds, and to include Pretreatment staff input when
reviewing limit violations at POTWs.
NPDES Branch
Compliance &
Expediated Permitting
Industrial Permitting
Mun icipal Permitting
supervisor: John Hennessy
Supervisor: Doug Dowden
Supervisor: Michael Montebello
NPDES Municipal Pretreatment Collection
Permitting I Isystems
North Carolina Department of Environmental Quality Division oFWater Resources
D_E � 512 North Salisbury Street 11617 Mall Service Center I Raleigh, North Carolina 27699-1617
919,707,9000

DocuSign Envelope ID: 73COD794-lC74-422B-BF1E-258E286F6262
5. Staff Assignments: Our goals for project review are 30 days for NPs and SN drops and 90
days for ERP, HWA, IWS, LTMP and SUO. This year, we have filled both previously
vacant pretreatment coordinator positions.
a. Keyes McGee: Keyes.Mcgee(cr�,ncdenr.gov, Office Phone: [phone]
b. Charlie Miller: Charlie.Millerna,nedenr.gov, Office Phone: [phone]
Please also feel free to contact Michael Montebello [[e-mail]] or
alternatively Kristin Litzenberger[[e-mail]].
6. Workshops: The following workshops are projected for 2022. The invitations and directions
for these workshops will be posted on the Training nacre once the dates are finalized.
We will send links to register for the events once scheduled. Please register early as
space is typically limited.
a. NCMA Water Quality Compliance Workshop — February 15, 2022
b. Pretreatment Annual Report (PAR) -Projected 4th quarter of 2022
c. Headworks Analysis (HWA) - Projected 4th quarter of 2022
d. Industrial User Permit Writing (NP) - Projected 4" quarter of 2022
All subject to current COVID-19 situation and staffing.
Pretreatment Program Info Database Sheets: Please review your attached program info
sheet(s) and historical SNC sheet(s), if applicable, and make necessary updates to any of the
information presented. Send the corrected sheets back with your PAR, due March 1, 2022,
for calendar year 2021. If all of the information was correct, please indicate that in your
PAR. Especially note the due dates as this may be the only reminder you get. Please note:
a. All pretreatment programs (full and modified) must submit a PPS form with their PAR
per an EPA requirement of the State.
b. Historical SNC sheets only list currently Active SIUs that had SNCs from 2014-2020. V
c. PAR forms are available for download on our website. Vez
8. Email Addresses: The Municipal Permitting Unit often uses email to send out mass
mailings. To In thisane veand cost saving tool, we ask that you keep the Municipal
Unit updated on your current email address as well as which staff member is the "primary"
contact for your POTW - see "prim" field next to staff names on Program Info sheet, and
email field below names. For programs with more staff than the printed sheet can show, a
separate contacts page has been included. Please make any staff changes on that sheet and
return to the Municipal Unit with the PAR.
As always, please contact your pretreatment staff member (as listed above) with any questions or
comments.
Sincerely,
DocuSipnetl by:
�
ksl/EOY2021 CNI,(�,(, 1vl,plA�j,�41,1,1,p
Attachments: Program Info Shcet(s) C484531431644FE...
Historical SNC Shcet(s), if applicable Michael Montebello, Supervisor
Ec: Municipal Permitting Pretreatment Staff Municipal Permitting Unit
Regional Office Pretreatment Staff
Pretreatment Consultants
U.S. EPA, Region 4
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mall Service Center I Raleigh, North Carolina 27699-1617
919,707,9000

ATTACHMENT 2
Workbook Name: Holly Springs_HWA_approved_2017.xis; Worksheet Name: H•PnRlad 3/15/20 Page
a eI f 5
A I B
C
D
E
I F
G
H
J
K
1
Headworks Analysis Spreadsheet Spreadsheet Instructions:
POTW Name: Ho Springs 1) Applicable Values should be entered in the Heavy Bordered Blue cells. The rest of worksheet is
Date: 10/31/M17 protected, password is "2".
POTW NPDES # _> NCo063096 2) Additional pollutants can be added in cells A34 to A42. Note all Pollutant names are linked from
POTW Sludge Permit # _> w o019098 here to other pages in HWA worksheet and also to AT worksheet (i.e., automatically entered into
other pages in HWA worksheet and also AT worksheet from HWA worksheet).
POTW NPDES Permitted Flow(MGD 6 =used in AT only 3) Formulas are discussed in the Comprehensive Guidance HWA Chapter.
POTW Average Flow(MGD)= 1.9033 �usee.a BwA wmwadoas 4) HWA, AT and HASL worksheets are linked. MAHLs, Basis, and Uncontrollable load are
automatically entered into AT from this worksheet.
Uncontrollable Flow(MGD 1.817 5) If red tab notes are not visible, they can be turned on in the'Tools" menu under "options", in the
7Q10 Stream Flow(MGD - 0.07 'View" tab click the "comment indicator only" button.
Stream Classification = Class C
Class of Sludge generated (A, or B) B
Sludge to Digester Flow(MGD kv
Through talc. fm diff t POTW use Design
Sludge to Disposal Flow(MGD flows Criteria
%Solids to Disposal Design Values AverageFlowl Permitted Flow Loading
Sludge Site Area(acres W WTF Influent BOD (mg/1) 390 714.3 226.E
Sludge Site Life(yrs W WTF Influent TSS (mgA) 423.0 7500.0 2379.1 x
W Age of Sludge Site(yrs W TF Influent NH, (mg/)40 166.7 52.9
W
W TF Influent Total N(mgA) 67 62.5 1918 x
Pass -Through Loading Calculations W WTF Influent Total P (mgA) 10 10.0 3.2 x
2
3
4
5
7
8
9
10
11
13
14
15
16
17
18
19
2J0
21
23
Pollutant
NPDES L1Mrr
(mg/I)
Plant Removal
Rare I%)
Removal rate
Source
NPDES Loading
(lbs/day)
Stream
Standard
(mgA)
Stream
Standard Source
Standard
Loading
Obs/day)
Design Criteria
Loading (Ibs/day)
Pass-Thru
Loading
(lbs/day)
Minimum
Pass-Thru
Basis
24
BOD
5
99.3
influent data
111338
19,516
19,516
Design
25
TSS
30
99.6
influentdata
1192051
217167
21,167
Design
26
Ammonia
1
99.4
influent data
22646
2,002
22002
Design
27
Arsenic
45
literature
0.01
Human Health
0.2992
0.2992
Stream Std
28
Cadmium
67
literature
0.00145
dissolved stud
0.0723
0.0723
Stream Sid
29
Chromium
82
literature
0.0111
1.0057
1.0057
Siream Std
30
Copper
93
LTMP
0.0217
dissolved stud
5.1018
5.1018
Stream Std
31
Cyanide
69
litemiure
0.005
NC W S
0.2654
0.2654
Stream Sid
32
Lead
0.0111
61
literature
0.4518
0.4518
NPDES
33
Mercury
99.2
LTMP
0.000012
NC W S
0.02469
0.02469
Stream Sid
34
Molybdenum
29
LTMP
2
human health
46.3587
46.3587
Stream Std
35
Nickel
40
LTMP
0.10^_
dissolved stud
2.7977
2.7977
Stream Std
36
Selenium
50
litemture
0.005
NC WOS
0.1646
0.1646
Stream Std
37
Silver
75
literature
0.00006
NC W S
0.0039
0.0039
Stream Std
38
Zinc
70
LTMP
0.344
dissolved stnd
18,8711
18.8711
Stream Std
39
ITotal Nitrogen
1 5
92
LTMP
99240951
3352468
3352.680
Design
40
ITotal Phos.
1 0,5
95
influent data
158.7352
500.4
500.400
Design
41
Chlorides
4.2
LTMP
230
NC W S
3951,1316
3951,1316
Stream Sid
42
Ortho hos horns
0.27
43
e
44
f
45
46
47
1
Modeled
after:
Chapter 5-HWA Guidance,
Appends 5-A
Revision
Date:
February 2008

Workbook Name: HollyS rin s_HWA a roved_2017.xis• Worksheet Name: HWrr e Paget ofs
p g _ pp f d 3/15/2022, 8:11 PM
A
B
C
D
E
F G H
J
K
Average Influent NH3 (mg/1)
Average Anaerobic Digester NHS (mg/1)
�
Inhibition Loading Calculations only enter when have ANAEROBIC digester
49
50
51
52
Pollutant
Primary
Removal Rate
(%)
Primary
Removal Rate
Source
A.SINUt T.F.
Inhibition
Concentration
(mg/1)
A.S./Nic/P.F.
Inhibition
Concentration
Source
A.S.Miy/T.F.
Inhibition
Loading
(lbs/day)
Digester
Inhibition
Concentration
(mg/1)
Digester
Inhibition
Cone. Source
Digester Inhibition
Loading(lbs/day)
Minimum
Inhibition
Loading
(lbs/day)
:Minimum
Inhibition
Loading
Source
53
BOD
54
TSS
55
Ammonia
480
acts] ud e
7619.2906
761929
AS/NiUTF i
56
Arsenic
0.1
act sludge
1.5874
1.5874
AS/NiUTF i
57
Cadmium
I
act sludge
15.8735
15.8735
AS/Nit/TF i
58
Chromium
0.394
nitrification
6.25421
6.2542
AS/NiUTF i
59
Copper
0,48
nitrification
7.6193
7.6193
AS/Nit/TF i
60
Cyanide
0.1
act sludge
1.5874
1.5874
AS/NiUTF i
61
Lead
05
nitrification
7.9368
7.9368
AS/Nit/TF i
62
Mercury
0.1
act sludge
1,5874
1.5874
,AS/Nit/TF i
63
Molybdenum
64
Nickel
0.25
nitrification
3.9684
3.9684
AS/NiUTF i
65
Selenium
66
Silver
I
0.25
act sludge
3,9684
3.9684
AS/Nit/TF i
67
Zinc
1
nitrification
15,87351
1
15.8735
AS/NiUTF i
68
Total Nitrogen
69
Total Pons.
70
Chlorides
71
Orthophosphorus
72
e
73
f
74
g
75
It
76
I
Modeled
after:
Chapter 5-HWA
Guidance, Appendix 5-A
Revision
Date:
February 2008

Workbook Name: HollyS rin s_HWA a roved_2017.xis• Worksheet Name: HV Page3oi5
p 9 _ p p e d 3/15/2022, 8:11 PM
A
B
C
D
E
F
G
H
I
J
K
77
Sludge Loading Calculations
78
79
Pollutant
Sludge Ceiling
Concentration
Limit(mg/kg)
Sludge Ceiling
Load
(lbs/day)
Sludge Ceiling
Load
- HASL Cale. -
(Ibs/day)
Cumulative Sludge
Rate limit
(Ibs/(acre"Gfe))
Cumulative
Sludge Loading
(lbs/day)
Class A Limits
Monthly
Average state
Limit(mg/kg)
Class A Limits
Monthly Avg.
Loading
(lbs/day)
Class A Limits
Mom Avg. Load -
HASL Cale. -
(lbs/day)
Minimum
Sludge
Loading
(lbs/day)
Minimum
Sludge
Loading
Sorce
80
BOD
81
TSS
82
Ammonia
83
Arsenic
75
44.6468
36
0.8400
41
0.8400
Carnal. Sind
84
Cadmium
85
33.9849
34
0.5328
39
0.5328
Carnal. Stud
85
Chromium
86
Copper
4300
1238.5886
1338
15.1068
1500
15.1068
Cumul. Sind
87
de
88
Lead
840
368.8850
267
4.5960
300
4.5960
Carnal. Slud
89
Mercury
57
15.3923
15
0.1588
17
0.1588
Carnal. Sind
90
Molybdenum
75
692795
69.2795
Sludge Celli
91
Nickel
420
2812748
374
9.8177
420
9.8177
Carnal. Sind
92
Selenium
100
53.5762
89
1.8690
100
1.8690
Carnal. Slud
93
Silver
94
Zinc
7500
2870.1514
2498
37.4708
2800
37.4708
Carnal. Slud
95
Total Nitrogen
96
Total Phos.
97
Chlorides
98
Ortho hos horus
99
e
100
f
101
102
h
103I
104
Motleled
after:
Chapter 5-HWA Guitlance,
Appendix 5-A
Revision
Date:
February 2008

Workbook Name: HollyS rin s_HWA a roved_2017.xis• Worksheet Name: H'ttI /� Page of
p g _ p p •P flied 3/15/2022, 8:11 PM
A
6
C
D
E
F
GI
H
J
K
105
Maximum Allowable
Headworks Loading
Calculations
Minimum
Sludge Loading
Sorce
Cumul. Sludge Loading
Cumul. Sludge Loading
I
Cumul. Sludge Loading
Cumul. Sludge Loading
Cumul. Slud a Loading
Sludge Ceiling
Cumul. Sludge Loading
Cumul. Sludge Loading
Cumul. Sludge Loading
106
Minimum Pass
Through Loading
(lbs/day)
Pass Through
Source
Minimum
Inhibition Loading
(lbs/day)
Minimum
Inhibition Loading
Source
Minimum
Sludge Loading
(Ibs/day)
Maximum
Allowable
Headworks Loading
(lbs/day)
Maximum Allowable
Hendworks Loading
Source
107
BOD
19515.6
Design
19515.6
Design
108
TSS
21166.9
Design
21166.9
Design
109
Ammonia
2001.6
Design
761942906
AS/Nit/TF inhibit
2001.6
Design
110
Arsenic
0.2992
Stream Sod
1.5874
AS/Nit/TF inhibit
0.8400
0.2992
Stream Sod
111
Cadmium
0.0723
Stream Sod
15.8735
AS/NivTF inhibit
0.5328
0.0723
Stream Sod
112
Chromium
1.0057
Stream Sod
6.2542
AS/NiVIF inhibi
1.0057
Stream Sod
113
Copper
5.1018
Stream Std
7.6193
AS/Nit/TF inhibit
15.1068
5.1018
Stream Sod
114
Cyanide
0.2654
Stream Sod
1.5874
AS/NiVPF inhibit
0.2654
Stream Sod
115
Lead
0.4518
NPDES
7.9368
AS/NiVIF inhibit
4.5960
0.4518
NPDES
116
Mercury
0402469
Stream Std
1.5874
AS/Nit/TF inhibit
0.1588
0.02469
Stream Sod
117
Molybdenum
46.3587
Stream Sul
69.2795
46.3587
Stream Sod
118
Nickel
2.7977
Stream Std
3.9684
AS/Nit/IF inhibit
9.8177
2.7977
Stream Std
119
Selenium
0.1646
Stream Std
1.8690
0.1646
Stream Sod
120
Silver
0,0039
Stream Std
3.9684
AS/Nit/TF inhibit
0.0039
Stream Sul
121
Zinc
18.8711
Stream Std
15.8735
AS/NiVTF inhibit
3744708
15.8735
AS/NivTF inhibition
122
Total Nitro en
3352.7
Design
3352.6800.DesiRn
123
Total Phos.
500.4
Design
500.4000
Design
124
Chlorides
3951.1
Stream Sul
3951.1316
Stream Std
125
Ortho hos horns
126
e
127
f
128
129
h
1301
131
Modeletl
after:
Chapter 5-HWA
Guitlance, Appends 5-A
Revision
Date:
February 2008

^ Page 5 of 5
Workbook Name: Holly Springs_HWA_approved_2017.xis; Worksheet Name: HVYrrAed3/15/2022, 8:11 PM
A
B
C
D
E
F
G
H
I
J
K
132
Maximum Allowable
Industrial Loadin
Calculations
Design vs. Pass-
Thru Warning
133
134
Pollutant
Allowable
Headworks Loading
Obs/day)
MAHL Basis
Check to Use HASL
Calm (x)
Uncontrollable
Concentration
(mg/I)
Uncontrollable
Source
Uncontrollable
Load Obs/day)
Allowable
Industrial Load
Obs/day)
135
BOD
19515.6000
Design
295
mass balance
4470.3651
150452349
136
TSS
21166.9200
Design
288
mass balance
4364.2886
16802.6314
137
Ammonia
2001.6000
Design
34
mass balance
5152285
1486.3715
138
Arsenic
0.2992
Stream Std
0.005
mass balance
0.0758
0.2235
139
Cadmium
0.0723
Stream Std
0,003
literature
0.0455
0.0269
140
Chromium
1.0057
Stream Std
N/A
0.05
literature
0.7577
0.2480
141
Copper
5.1018
Stream Std
0.061RBPJ
alance
0,9244
4.1774
142
Cyanide
0.2654
Stream Std
N/A
0.002alance
0.0303
0.2351
143
Lead
0.4518
NPDES
0.0074ific
0.1121
0.3396
144
Mercury
0.02469
Stream Std
0.0003re
0.00455
0.02014
145
Molybdenum
46.3597
Stream Std
0.0048alance
0.0727
46.2859
146
Nickel
2.7977
Stream Std
0.0081alance
0.1227
2.6750
147
Selenium
0.1646
Stream Std
0.0055t
0.0833
0.0812
148
Silver
0.0039
Stream Std
N/A
00.0000
0.0039
149Zinc
15.8735
AS/Nit/TF inhibition
0.175re
2.6519
132216
150
Total Nitrogen
3352.6800
Design
57.7
mass balance
874.3731
2478.3069
151
Total Phos.
500.4000
Design
8,07
mass balance
1222910
378.1090
152
Chlorides
3951.1316
Stream Std
76.7
mass balance
11622949
2788.8367
153
Orthophosphoms
154
e
155
f
156
g
157
h
158I
Modeled
after.
Chapter 5-HWA
Guidance, Appentliz 5-A
Revision
Date:
February 2008

POPN�
NPDEa
IUP
Count
10
Workbook Name : Holly Springs_HWA_approved_2017.xis, Worksheet Name: AT Printed: 3/15/2022, 8:12 PM
Page 1 of 4
Allocation Table
Headworks last approved:
Allocation Table uptlatetl:
Permits last modified:
Holly Springs
NCO063096
INDUSTRY NAMES
V=a HsimphWdy)
02/22/18
06/12/18
01/01/18
Industry
Permit
number
Pipe
number
Spreadsheet Instructions:
1) Applicable Values should be entered in the Heavy Bordered cells. Rest of vrorksheet is protected, password is
„r,
2) Formulas are discussed in the Comprehensive Guidance, Chapter 6, Section C.
3) HWA and AT worksheets in this workbook are linked. Pollutant Names, MAHLs, Basis, and Uncontrollable load
in this AT worksheet are automatically entered from the HWA spreadsheet. This includes pollutant names in
columns AT through BK
FLOW BOD TSS
Type Renewal Modification Date Permit Limits Permit Limits Permit Limits
of Effective Effective Permit Conc. Load Conc. Load
Industry Date Date Expires MGD gal/day mPA lbs/da m lbs/da
South Wake Landfill
0001
0001
Landfill
01/01/14
1
12/31/18MR
418.00
ovartis Se irus
0002
0002
Pharm
01/01/18
12/31/23
Column Totals =>
418
Basis=>
MARL from HWA (lm/day) => NPDES
Uncontrollable Loading (lbs/day) =>
Total Allowable for Industry (MAIL) abs/day) =>
Total Permitted to Industry (lbs/day) =>
MAIL, left (lbs/day) =>
Percent Allow. Ind. (MAIL) still available (%) =>
Percent MAHI, still available (%) =>
5 Percent MAHI. (lbs/dav) =>
HWA.AT
Revised:November 2005

�-S•Su`E
NPDESF
IUP
Count
1
2
3
4
5
6
7
8
9
10
Workbook Name : Holly Springs_HWA_approved_2017.xis, Worksheet Name: AT Printed: 3/15/2022, 8:12 PM
Page 2 of 4
Allncatinn Tahle
Headworks last approved:
Allocation Table updated:
Permits last modified:
02/22/18
06/12/18
01/01/18
Holly Springs
NCO063096
Industry
INDUSTRY NAMES Pemilt
trj� list wnbxuay) number
Pipe
number
Ammonia
Permit Limits
Arsenic
Permit Limits
Cadmium
Permit Limits
Chromium
Permit Limits
Copper
Permit Limits
Cyanide
Permit Limits
Conc. Load
m lbs/da
Conc. Load
m lbs/day
Cone. Load
mPA lbs/da
Cone. Load
MR/1 lbs/da
Cone. Load
m lbs/day
Cone. Load
ma Ibs/da
South Wake Landfill
0001
0001
77.00
32.00
ovartis Seqirus
0002
0002
0.0300
0.0626
Column Totals =>
32
0.0000
0.0000
0,0000
0.0 000
0.0626
Basis=>
MAHL from HWA (lbs/day) =>
Uncontrollable Loading (Ibs/day) =>
Total Allowable for Industry (MAIL) (lbs/day) =>
Total Permitted to Industry (lbs/day) =>
MAIL left (lbs/day) =>
Percent Allow. Ind. (MAIL) still available (%) =>
Percent MABL still available (%) =>
5 Percent MAHI. flhs/davl =>
Design
Stream
Std
Stream
Std
Stream
Std
Stream
Std
Stream
Std
2001.60
0.2992
0.0723
1.0057
5.1018
0.26'
515,23
0.0758
0.0455
0,7577
0.9244
0.03f
1486.37
0.2235
0.0269
0.2480
4.1774
0.23'_
32.00
0.0000
0.0000
0.0000
0.0000
0.061
1454.37
0.2235
0.0269
0.2480
4.1774
0.172
97.8 %
100.0 %
100.0 %
100.0 %
100.0 %
714'
72.7 %
74.7 %
37.1 %
24.7 %
81.9 %
65.0 '
inn nu
n m in
n nn14
n ncna
n acci
n ni .
HWA.AT
Revised:November 2005

POTW=
NPOESIk:
NP
Count
1
2
3
4
5
6
7
8
9
10
Workbook Name : Holly Springs_HWA_approved_2017.xis, Worksheet Name: AT Printed: 3/15/2022, 8:12 PM
Page 3 of 4
Allocation Table
Headworks last approved:
Allocation Table updated:
Permits last motlitied:
02/22/18
06/12/18
01/01/18
Holly Springs
NCO063096
Industry
INDUSTRY NAMES Permit
(pl fivalphbe dy) number
Pipe
number
Lead
Permit Limits
Mercury
Permit Limits
Molybdenum
Permit Limits
Nickel
Permit Limits
Selenium
Permit Limits
Cone. Load
m Ibs/da
Cone. Load
m lbs/day
Cone. Load
mRA lbs/da
Conc. Load
m /I lbs/dav
Cone. Load
m9rA lbs/da
South Wake Landfill
0001
0001
ovartis Se ims
0002
0002
40:0:0;00
Column Totals =>
0.0000
0.00000
1 0,00001
1 0.0000
Basis=>
MAUL from HWA (lbs/day) =>
Uncontrollable Loading (Ibs/day) =>
Total Allowable for Industry (MAIL) (lbs/day) =>
Total Permitted to Industry (lbs/day) =>
MAIL left (lbs/day) =>
Percent Allow. Ind. (MAIL) still available (%) =>
Percent MARL still available (%) =>
5 Percent MAHL (Ibs/dav) =>
HWA.AT
Revised:November 2005
Stream
105.2 % 180.6 % 199.8 % 190.6 % 149.4

POTW='
NPOESC'
NP
Count
1
7
4
5
6
7
8
9
10
Workbook Name : Holly Springs_HWA_approved_2017.xis, Worksheet Name: AT Printed: 3/15/2022, 8:12 PM
Page 4 of 4
Allocation Table
Headworks last approved:
Allocation Table updated:
Permits last m(
02/22/18
06/12/18
01/01/18
Holly Springs
NCO063096
Industry
INDUSTRY NAMES Permit
cn=list mpnobmdy, number
Pipe
number
Silver
Permit Limits
Zinc
Permit Limits
Total Nitrogen
Permit Limits
Total Phos.
Permit Limits
Chlorides
Permit Limits
Cone. Load
m lbs/da
Cone. Load
m Ibs/da
Cone. Load
m /l lbs/day
Cone. Load
MEA lbs/dav
Cone. Load
m2A Ibs/da
South Wake Landfill
0001
0001
544.00
227.00
Novartis Se irus
0002
0002
56.00
2450.00
Column Totals=>
0.0000
0.0000
227.0
1 56.00
2450.00
Basis=>
MARL from HWA (lbs/day) =>
Uncontrollable Loading (Ibs/day) =>
Total Allowable for Industry (MAN) (lbs/day) =>
Total Permitted to Industry (Ibs/day) =>
MAIL left (Ibs/day) =>
Percent Allow. Ind. (MAIL) still available (%) =>
Percent MARL still available (%) =>
HWA.AT
Revised:November 2005
AS/Nif/TF
0.0039
13.2216
2251.i1
322.11
338.
100.0
100.0 %
83.3 %
67.1 %
64.4 %
1 8.6

ATTACHMENT 3
Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1.
Pretreatment Town Name: Town of Holly Springs
2.
"Primary" NPDES Number NC00 63096
or Non_Discharge Permit # if applicable =>
WQ0032289
3,
PAR Begin Date, please enter 01/01/2021
3.
=>
1/1/2021
4,
PAR End Date, please enter 12/31/2021
4.
=>
12/31/2021
5.
Total number of SIUs, includes CIUs
5.
=>
2
6.
Number of CIUs
6.
=>
1
7.
Number of SIUs with no IUP, or with an expired IUP
7.
=>
0
8.
Number of SIUs not inspected by POTW
8.
=>
0
9.
Number of SIUs not sampled by POTW
9.
=>
0
10.
Number of SIUs in SNC due to IUP Limit violations
10,
=>
2
11,
Number of SIUs in SNC due to Reporting violations
It,
=>
1
12,
Number of SIUs in SNC due to violation of a Compliance Schedule, CO,
AO or similar
12.
=>
0
13.
Number of CIUs in SNC
13.
=>
0
14.
Number of SIUs included in Public Notice
14.
=>
0
15
Total number of SIUs on a compliance schedule, CO, AO or
similar
15,
=>
0
16.
Number ofNOVs, NNCs or similar assesed to SIUs
16,
=>
2
17,
Number of Civil Penalties assessed to SIUs
IT
=>
1
18.
Number of Criminal Penalties assessed to SIUs
18.
=>
0
19,
Total Amount of Civil Penalties Collected
19, =>
$
500
20.
Number of IUs from which penalties collected
20,
=>
1
Notes:
AO Administrative Order IUP Industrial User Pretreatment Permit
Cal Categorical Industrial User NNC Notice of Non -Compliance
POTW
SIU
Publicly Owned Treatment Works
Significant Industrial User
CO Consent Order NOV Notice of Violation
SNC
Significant
Non -Compliance
al Industrial User PAR Pretreatment Annual Report
revised 1/2018: PAR PPS 2018

Pretreatment Performance Summary (PPS) -Explanations
Line # 5. Number of SIUs permitted and/or discharged during PAR year. Discuss new or dropped
SIUs in narrative.
Line # 12. A SIU is in SNC if they fail to meet a compliance schedule milestone within 90 days of
the scheduled date for starting construction, completing construction or attaining final
compliance; if progress reports required by the compliance schedule are over 45 days late; or
there are violations of any interim limits meeting the chronic or TRC definition of SNC.
Line # 15. This is the total number of industries on a compliance schedule as part of an
enforcement action during the reporting period. If the compliance schedule was entered into in
July 2016, it would be counted on the PPS form in 2016 and 2017 and subsequent PARs until
the schedule is completed or expires. These schedules are issued outside of, or separate from,
the IUP. If an industry is on a compliance schedule that is part of an IUP, this is not included in
the PAR. This type of compliance schedule is not considered an enforcement action that
includes stipulated penalties, and it should therefore not be included.
Lines # 16,17,18,19, 20. are based on number of events during PAR year, and do not include events
occurring after PAR year.
Line # 19. Total amount of Civil Penalties collected: This is the actual amount in fines that was
collected from the industries during this twelve month period. This can include collection of
penalties assessed during prior reporting periods.
Line # 20. Number of SIUs from which penalties collected. This is the total number of industries that
actually paid penalties during the year.

ATTACHMENT 4
Debra Batten
From: Litzenberger, Kristin S <[e-mail]>
Sent: Friday, October 1, 2021 10:04 AM
To: Debra Batten; Montebello, Michael J
Subject: --[EXTERNAL]--RE: [External] NPDES NC 0063096 Industrial Waste Survey 2021
Hi Debra,
Acknowledging receipt of the IWS submittal for the Town of Holly Springs.
We will let you know if we have any questions or concerns during our review.
Thanks,
Kristin Litzenberger (she/her/hers)
Environmental Specialist
Municipal Permitting Unit
Division of Water Resources
Department of Environmental Quality
919-707-3699
[e-mail]
Please note that during this unusual time, I am unfortunately not available via my regular telephone number. The best way to
reach me is via email.
If you would like speak with me on a call, please contact me via email to schedule an internet call, such as using Teams, Zoom,
Web Ex, or other web -based calling services.
Email correspondence
to and from
this address is subject to
the North Carolina Public Records Law and maybe disclosed to third
parties.
From: Debra Batten (mailto:[e-mail]]
Sent: Thursday, September 30, 2021 1:35 PM
To: Litzenberger, Kristin S <[e-mail]>; Montebello, Michael J
<[e-mail]>
Subject: [External] NPDES NC 0063096 Industrial Waste Survey 2021
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Kristin,
Please
find attached in the attached documents the
IWS
Summary
and
Tables as
required for
the
Town of Holly Springs
for the
year 2021. Note that the Excel Spread sheet
has
two tabs.
The
first is the
information
for
the MR Listing

provided by your office. The other tab is for the Business that were survey based on information provided TOHS
Permitting and utilities departments.
Should you have any questions, please do not hesitate to contact me.
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 81Holly Springs, NC 27540
Office: [phone] i Cell: [phone]
Town Website: hollyspingsnc.gov
Town of Holly Springs emails are switching to
.gov addresses.
Please make
sure to update my contact
information to [e-mail]
before Jan.
31, 2022.
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
CAUTION:

Debra Batten
From: Debra Batten
Sent: Thursday, March 18, 2021 4:04 PM
To: George Metcalf; Clifford Manz
Cc: Seth Gundersen
Subject: BOD 02/15/21 and 02/22/2021 Effluent Values
Importance: High
George/Seth,
ATTACHMENT 5
The BOD data for both the 15th and 22nd1 look suspiciously low. I understand that GFL has already questioned the data,
but I would like to review the data. Would you please contact t the contract lab and request copies of the bench sheets
associated with this data and email to me to review?
Respectifully,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 8 1 Holly Springs, NC 27540
Office: [phone] ) Cell: [phone]
Town Website: www.hollvspringsnc.us

Debra Batten
From: Clifford Manz <[e-mail]>
Sent: Tuesday, March 23, 2021 11:26 AM
To: Debra Batten; George Metcalf
Cc: Seth Gundersen
Subject: --[EXTERNAL]--RE: BOD 02/15/21 and 02/22/2021 Effluent Values
Attachments: Bench Sheet 22nd.pdf; Bench Sheet 15th.pdf
Debra,
Attached you will find the Bench sheets per your request.
Thank you,
Clifford Manz � Equipment Operator
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
1 [e-mail] I www.gfenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.
From: Debra Batten<[e-mail]>
Sent: Thursday, March 18, 20214:04 pM
To: George Metcalf <[e-mail]>; Clifford Manz <[e-mail]>
Cc: Seth Gundersen <[e-mail]>
Subject: BOD 02/15/21 and 02/22/2021 Effluent Values
Importance: High
CAUTION: This email
originated
from outside of the
organization. Do not click links or open attachments unless you recognize the
sender and know the
content is
safe.
George/Seth,
The BOD data for both the 15th and 22nd, look suspiciously low. I understand that GFL has already questioned the data,
but I would like to review the data. Would you please contact t the contract lab and request copies of the bench sheets
associated with this data and email to me to review?
Respectifully,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 81 Holly Springs, NC 27540
Office: [phone] ( Cell: [phone]
Town Website: www.hollvsuringsnc.us

Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).

/Z Prep Log Report
Batch Information: EDEN51299BODANALYTICAL—RR Template Version: F-CAR4431-Rev.02 (29May2020)
Anaysis Method -
Sample
sM 52108-2011
Analyzed By
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Cal DateTme
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Sun, 7 Mar 2027 7 7;43:46 -0500

�ce�� Prep Log Report
3atch Information: EDEN51171BOD FINAL
Template Version: F-CAR4I 031-Rev.02 (29May2020)
Analysis Method
SM 5210&2011
Analyzed By
DAw
Instrument
95FDNJ
Cal DateTme -
02rzrrm2i 13:39:42:5Ds
Meter Pres.-(mBar)
30.54
Meter Temp(C)
23n1
Probe 10 - -'
s5To90
Inwbator -
Incubator 2
Init. DO (mglL)
8A8
- t - ( 9[L)
SCFaotor m
3.0o
Vol of Seed per
Sam le mL
5
Reviewed By -
AMi
Reviewed By Date
D2m M tD:14
Batch Notes -- -:
95vm
Sample Information:
m .
O.
t
E_-
E
W
ErC
V
_ 0.0-0.
0
O-O
0 o
00_
ca
L^
521OBWEDN
BLANK
3164827
Y
02212021
2
158534221 3001300
8.5518.56
8.4718,54
0.0810.02
0.0810.02
0,05
8.22
13:37:47
15853315
02/212021
158530541
g.54 1 g.52 12.91
1 3.43 15.63
1 5.09 1
231.50 1
i210BWEDN
CS
164828
Y
13:40:25
3
158530591 61616
8.54
2.77
204.501
224.83
15853387
515-
238.50
0221/1)21
15853046 1
8,52 18.47 17.44
1 3.87 1
*1.08 1 4.60
NA 11.13 1
i210BWEDN
CF
164829
Y
3
15853073 1 6 1 24 1 36
1.00
13:42:53
8.39
3.32
1 5.07
0.85
013:57?311
8.4 I51
N I N 1
321OBWEDN
S
2522209001
Y
3
15853080 0.5 1 1 13
59.00
B2
86I9136
*1.04 1
MOM
•
•
Non, 22 Mar 2021 13:14:24 -0400

Debra Batten
From: Seth Gundersen <[e-mail]>
Sent: Thursday, July 29, 2021 2:40 PM
To: Debra Batten
Subject: --[EXTERNAL]--FW: Ammonia Result 7/26 Sampling
Attachments: 92551643_frc.pdf
This looks much more plausible... 1070 MG/L
Seth Gundersen � Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext, 31523 1 C [phone] 1 [e-mail] I www.aflenv.com
ATTACHMENT 7
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.
From: Kristi Prater <[e-mail]>
Sent: Thursday, July 29, 20211:02 PM
To: Seth Gundersen <[e-mail]>
Subject: RE: Ammonia Result 7/26 Sampling
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Please see attached. The re -run confirmed your historical data. I'm so sorry for any confusion this may have caused.
Sincerely,
Kristi
Kristi Prater
Project Manager
205 East Meadow Road, Suite A Eden, NC 27288
0: [phone] F: [phone]
Emergency Response Line 877-859-7778
pacelabs.com
_. aceAnalytical

From: Seth Gundersen <seth.gundersen(cDgflenv.com>
Sent: Thursday, July 29, 2021 11:41 AM
To: Kristi Prater <[e-mail]>
Subject: RE: Ammonia Result 7/26 Sampling
CAUTION: This email originated from outside Pace Analytical. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Great, Thank You
Seth Gundersen � Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 315231 C [phone] 1 seth.cundersenOmflenv.com I www.aflenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.
From: Kristi Prater <[e-mail]>
Sent: Thursday, July 29, 2021 11:35 AM
To: Seth Gundersen <[e-mail]>
Subject: RE: Ammonia Result 7/26 Sampling
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Yes sir, the lab re -run this. The final report has not came out just yet. I will get that to you after lunch.
Krist
Project Manager
205 East Meadow Road, Suite A Eden, NC 27288
0: [phone] F: [phone]
Emergency Response Line 877-859-7778
pacelabs.com
(�aceAfldlyllc;dl
From: Seth Gundersen <[e-mail]>
Sent: Thursday, July 29, 2021 10:41 AM
To: Kristi Prater <[e-mail]>
Subject: Ammonia Result 7/26 Sampling

CAUTION: This email originated from outside Pace Analytical. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Good Morning Kristi
Have you found any additional information for this sample/result from Monday? I'm cutting my discharge back
significantly so I don't overshoot our limit.
Seth
Seth Gundersen � Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, INC, 27539
T [phone] Ext. 315231 C [phone] 1 seth.aundersenOmflenv.com I www.aflenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.
NOTICE-- The contents of this email and any attachments may contain confidential, privileged, and/or legally
protected information and are for the sole use of the addressee(s). Any review or distribution by others is strictly
prohibited. If you are not the intended recipient, please contact the sender immediately and delete any copies.
Please consider the environment before printing this email
NOTICE-- The contents of this email and any attachments may contain confidential, privileged, and/or legally
protected information and are for the sole use of the addressee(s). Any review or distribution by others is strictly
prohibited. If you are not the intended recipient, please contact the sender immediately and delete any copies.
�j Please consider the environment before printing this email

aceAnalydcal
www.pacelabsxom
July 29, 2021
George Metcalf
GFL
RE: Project: Weekly Ammonia?/26
Pace Project No.: 92551643
Dear George Metcalf:
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Hunlersville, NC 28078
[phone]
Enclosed are the analytical results for samples) received by the laboratory on July 26, 2021. The results relate only to the
samples included in this report. Results reported herein conform to the applicable TNI/NELAC Standards and the
laboratory's Quality Manual, where applicable, unless otherwise noted in the body of the report.
The test results provided in this final report were generated by each of the following laboratories within the Pace Network:
• Pace Analytical Services - Eden
Rerun ammonia &rerun confirmed historical data. Revised report 7/28/21 KP
If you have any questions concerning this report, please feel free to contact me
Sincerely,
Terri Page for
Kristi Prater
[e-mail]
[phone]
Project Coordinator
Enclosures
cc: Seth Gundersen, GFL
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
out the written consent or Pace Analytical Services, LLC. Page 1 of 11

aceAnalytical
www.pacelabs.com
Project: Weekly Ammonia 7/26
Pace Project No.: 92551643
Pace Analytical Services, LLC
9800 Kinsey Ave. Suite 100
Hunlersville, NC 28078
(704)B75-9092
Pace Analytical Services Eden
205 East Meadow Road Suite A, Eden, NC 27288
North Carolina Drinking Water Certification #: 37738
CERTIFICATIONS
North Carolina Wastewater Certification #: 633
UrginiaNELAP Certification #: 460025
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
out the written consent of Pace Analytical Services, LLC. Page 2 of 11

aceAnalXical
www.pacelabs.com
SAMPLE ANALYTE COUNT
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Hunlersville, NC 28078
[phone]
Project: WeeklyAmmonia 7/26
Pace Project No.: 92551643
Analytes
Lab ID Sample ID Method Analysts Reported Laboratory
92551643001 Effluent EPA 350.1 Rev 2.01993 SRS 1 PASI-E
PASI-E = Pace Analytical Services - Eden
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC. Page 3 of 11

aceAnalytical
www.pacelabs.com
Project: Weekly Ammonia 7/26
Pace Project No.: 92551643
Sample: Effluent
Parameters
350.1 Ammonia EDN
Nitrogen, Ammonia
Pace Analytical Services, LLC
9800 Kincey Ave. SOile 100
Huntersvllle, NC 2807a
[phone]
ANALYTICAL RESULTS
Lab ID:
92551643001
Collected:
07/26/21
09:40
Received:
07l26/21 13:35
Matrix: Water
Results
Units
Report
Limit
DF
Prepared
Analyzed
CAS No.
Qual
Analytical Method: EPA 350.1 Rev 2.0 1993
Pace Analytical Services -Eden
1070 mg/L 15.0 150
REPORT OF LABORATORY ANALYSIS
Thls report shall not be reproduced, except in full,
without the wdtlen consent of Pace Analytical Services, LLC.
07/28/21 15:51 7664-41-7
Date: 07/29/2021 12:57 PM
Page 4 of 11

aceAnalytical
www.pacelabs.00m
QUALITY CONTROL DATA
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
(704)e75-9092
Project: Weekly Ammonia 7l26
Pace Project No.: 92551643
QC Batch: 636361
Analysis Method:
EPA 350.1 Rev 2.0 1993
QC Batch Method: EPA 350.1 Rev 2.0 1993
Analysis Description:
350.1 Ammonia, EDN
Laboratory:
Pace Analytical Services -Eden
Associated Lab Samples: 92551643001
METHOD BLANK: 3341238
Matrix: Water
Associated Lab Samples: 92551643001
Blank Reporting
Parameter Units
Result Limit
Analyzed Qualifiers
Nitrogen,Ammonia mg/L
ND 0.10
07/28/2111:06
LABORATORY CONTROL SAMPLE: 3341239
Spike LCS
LCS %Rec
Parameter Units
Conc. Result
%Rec Limits Qualifiers
Nitrogen, Ammonia mg/L
5 5.0
101 90-110
MATRIX SPIKE &MATRIX SPIKE DUPLICATE: 3341240 3341241
MS MSD
92551917001
Spike Spike MS
MSD MS MSD %Rec
Parameter Units Result
Conc. Conc. Result
Result %Rec %Rec Limits RPD Qual
Nitrogen,Ammonia mglL
5.1 4.9 4
Results presented an this page are In iha units Indicafetl by the "Units" column ezcept where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 07/29/2021 12:57 PM without the written consent of Pace Analytical Services, LLC.
Page 5 of 11

aceAnalytical
www.pacelabsxom
QUALIFIERS
Project: Weekly Ammonia 7/26
Pace Project No.: 92551643
DEFINITIONS
DF -Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
TNTC - Too Numerous To Count
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL -Adjusted Method Detection Limit.
Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
PQL -Practical Quantitation Limit.
RL - Reporting Limit - The lowest concentration value that meets project requirements for quantitative data with known precision and
bIse for a specific analyte in a specific matrix.
S - Surrogate
1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) -Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
Acid preservation may not be appropriate for 2 Chloroethylvinyl ether.
A separate vial preserved to a pH of 4-5 is recommended in SW846 Chapter 4 for the analysis of Acrolein and Acrylonitrile by EPA
Method 8260.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270, The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI -The NELAC Institute,
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Dale: 07/29/2021 12:57 PM out the written consent of Pace Analytical Services, LLC. Page 6 of 11

aceAnalytical
www.pacelabs.cam
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Pace Analytical Services, LLC
9900 Kincey Ave. Sulte 100
Huntersville, NC 28078
(704)a75-9092
Project: WeeklyAmmonia 7/26
Pace Project No.: 92551643
Analytical
Lab ID Sample ID QC Batch Method QC Batch Analytical Method Batch
92561643001 Effluent EPA 350.1 Rev 2.01993 636361
Date: 07/29/2021 12:57 PM
REPORT OF LABORATORY ANALYSIS
This repod shall not be reprotluced, except in full,
without the wdden consent of Pace Analytical Services, LLC.
Page 7 of 11

Laboratory remVing samples:
Asheville ❑ Eden[] Greenwood Q Nwdtemille Q Ralelghl Medlall[OW11411 AdanUO Kemersvpid0
Cod �. WOW 92551643
C FL E IVI v; tog we 4a1 Frolect A
Cour(er. d EX UPS USPS ❑GienC 1111111111111111111111
❑Commerdai Pace Clfter:— 92551643
CustodySalPramcnt? []Yes PNo Seals Initial? []Yes No L, /? Iz
_ � Dandlnleab PenoneardnNa COMrrdt��/
PaddrillMaterhl: LJ9ubbImWrap QdWhhleBags [fNane Odter Dyeo[]fgo uO,aen?
Thermometer / RwNet Blue ONoro
[,f lR Gun N: f�d®y � Typo of Ice:
Corecdon Factor.
Cooler Tgmp: % Add/Subtract ('C)._OtO Tempootddbe above(reednBto GC
gmr
npfarano?tempaRerd.Sa'moi mke,PmBng Prarass
Coolerremp Corrected (' 6" ! harbe
USDA Regulated Sod((fI/A, watarsample)
rwr maa.�rra�nra.mura NrcthanrcR�'Wstei<CA h .orLlySC(check maasf,L,41�}am„�ksul@mSsfmm rf - source Qntermdortalfy,__�
es No
-- twemannn
Chain of 94ody Present?
s
No
NIA
L
Samples krW within Hord lime?
Yes
No
NIA
Z
Short NaldTtme Analysts (An hcl?
es
No
WA
3.
Bush Turn Around Time Mquested7
Yd
No
NA
4-
SuBtdentvolum?
ma
ELNo
N/A
5.
Cnrmct Comatners Used?
�jYas
ONO
ON/A
fare Contalners Used?
v
No
WA
Containers kftct?
ridya,
rimo
❑ A
7,
IlLmlvad artafy0cSam lesFieldFiltered7
Cya
QNo
A
e.
Sample labels Match CDC?
[]No
❑N/A
B•
,. / 1
VV
-includes Uate/Rme/10/Ana Matrix:
Headspace In VOA &Is (>5-6nm)7
es
No
NIA
f0.
Trip Blank Present?
❑Yes
ONO.
WNIA
11,
Trip Blank Seals Resent?
es
ONO
WA
W MMeraf9/SAMPLE DISCREPANCY
Person contacted:
Date/lime:
FN:d Dara RegWted? QYes UNo
i
Project Manager SCURF Review:
Proleet Manager SRP Review:
Pag� 8 f 11
i

Z
�Lae" nwimPWOfb"NP14and/ordaMorhry�,��vm �_ �+mcmam4raeNolaw I
rs
VW471d¢nd vkhfiMeacmpbr�unnca for preservatllon pm* W0# 6 92551643
rempks, .
'^M1rc40tlandGraay;ORO PM: KPD Due Date: 07/28/21
"BottOmf0ifOfbpaytopg � � * ` CLIENT: 92-GFLENV
number of bathes
F 13
s a
Adjustment Log for Preserved Sam
t Day preaervatlon djurted lime prerare
adjuMd
to Whenever there 6 a d&mpanry aNacdn¢ Nosh CwIW compltanw wmplea, a wPY
t othald, Inmrwct prnervetka, out a/temp, InmrtectmnnNen.
addM
i
i
I
i

�AnaiXtW"
Sample Receiving Non -Conformance Form (NCF)
v °i e r Q7(,, AHIx Workorder/Login Label Here or List Pace
r t < r r l Workorder Number or MTJL Log -in Number
sy q. X , i s e« •..i{ i . :: „? ,,>� n ,"f; Here
1. If Chain -of -Custody (COC) Is not recelved: contact client and if necessary, fill out a COG and Indicate that it was filled out by
lab personnel Note Issues on this NCF
3. Sam le
ante rit Issues: check
a Ilcable
issues below and add
details
where
a ro riots:
Samples: Condition needs to be brought to
Samples: Past holding time
lab ersonnel's attention details below
Preservatlon: Improper
Temperature: not within acceptance criteria (typically
Samples: Not laid filtered
Containers: Broken or compromised
0.6C
Samples: Insufficient volume
received
Containers: Incorrect
Temperature: Samples arrived frozen
Samples: Cooler damaged or
compromised
Custody Seals: Missing or compromised on
samples, trip blanks or coolers
vials received with improper heads ace
Samples: contain chlodne or
sulfides
Packinq Material: InsufficlenNlm ro er
Other:
Commenta/Detalls:
4. If Sam les not
Sample ID:
Preserved by:
Sample ID: VpElyt4w
Preserved b :
reserved
n�
ro
erl and Sam le Recelvin ad usta
Dete/Tlme: Z: fn
Initial and Final H:
DateMme: f?L A I Z :VM
Initial and Final H:
H
atltl tletalls below:
AmounU a res added: .2 ll
Lot ft of pres added:
Amountll a res added: l'i
Lot k of res added: 7 Z
i
dr 5F!
C t' '
Sample ID:
DataMme:
Amount(type
pres added:
Preserved by:
Initial and Final H:
I
Lot 0 of pres
added:
F-ALL-C-011-rev.00, O5Ju12018
Page 11 6f 11

Debra Batten
From: Debra Batten
Sent: Wednesday, June 30, 2021 1:54 PM
To: John Roberson
Cc: Seth Gundersen; George Metcalf
Subject: June 2021 NOV
Attachments: SWL pH & Reporting Violation 062001.pdf
Importance: High
Mr. Roberson,
ATTACHMENT 6
Please find attached
the NOV as issued in regards
to
the violations
of your Industrial user permit. If you have and
questions and or concerns
please do not
hesitate
to
contact me. A
hard copy will follow.
Regards,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 811-lolly Springs, NC 27540
Office: [phone] 1 Cell: [phone]
Town Website: www.hollvsorinasnc.us

The Totem of
HOLLY
SPRINGS
June 29, 2021
Mr. John W. Roberson
South Wake County Landfill
P.O. Box 550
Raleigh, NC 27602
CERTIFIED MAII,
RETURN RECEIPT REQUESTED
Subject: Notice of Violations)
Utilities and infrastructure
Water Resources
Sewer Discharge Permit No. (IUP) 001
Doar Mr. Roberson,
This letter serves as a Notice of Violation for exceeding the pH limit as stated in IUP (Industrial
User Permit) #002 issued April 1, 2019 to South Wake Landfill. The permitted "daily limit" for
pH of 5.5-10.0 SU, is not to be exceeded. (See IUP, Part 1, Section F for Effluent Limits and
Monitoring Requirements.) The pH value of the sample collected and analyzed and reported on
May 10, 2021 as reported on the Daily Monitoring Report (DMR) was 10.99 SU. This value
exceeds the upper end of the acceptable range of the user's industrial permit.
In addition to the pH violation, a reporting violation is also being issued for failure to report as
required in lUP Part II Section A.2 "Reporting." As the analysis was analyzed at the facility due
to the 15-minute hold time, had we been notified immediately about the exceedance; additional
samples could have been collected and analyzed to bring the Daily Max Limit back in range. As
the Town of Holly Springs was not notified of the violation, collection of additional samples to
show compliance were not taken. Sampling was conducted again May 17, 2021 which yielded a
pH result of 6.3 SU. There was another sample collected on May 241h with a reported pH value
of 6.0 SU. Both of these results were within the permitted range.
The pH violation was apparent when the DMR was received on June 10, 2021. South Wake
Landfill was notified immediately. Because the violation went unnoticed, no additional
sampling was requested by the controlling authority as the permitting period had expired.
It is the industry's responsibility to maintain compliance with all effluent limits, to review the
permit, and be familiar of all requirements of the permit. In addition to the pH limit

violation(#1), and the failure to report the violation(#2), it was also determined that the pH and
temperature analysis have been analyzed and reported by South Wake Landfill staff though they
do not hold field lab certification for these parameters. This is another violation(#3). Part II C.
of the industrial user permit reads "All compliance monitoring must be performed by a
laboratory certified by the state of North Carolina Department of Water Resources for the
specific pararneter(s) being analyzed."
As the permitting authority of this permit approved by the NC State DWQ, I am required to
issue this Notice of Violation(s) within 30 days of the date of notification or July 10, 2021. In
addition to the Notice of Violations listed above, as referenced in the Sewer Use Ordinance
section 16-239 and the Enforcement Response Plan of Town of Holly Springs approved by NC
DWQ, there could be a penalty assessed up to $25,000. It has been decided the penalty is
$500.00 based on the following considerations:
1. Magnitude of the violations)
2. Duration of the violation(s)
3. Number of Resulting Violation(s)
4. Possible Effects on POTW Collections System
5. Possible Effects on the POTW
If you do not currently have a copy of the Sewer Use Ordinance or the Enforcement Response
Plan please let me know and I will send one to you via email.
If you have any questions please contact me at [phone],
Si r ly,
ebra Bat e �p�'✓
E vironmental Compliance Manager
Utilities and Infrastructure, Town of Holly Springs
Cc: Seann Byrd, Water Resources Director
George Metcalf, GFL

Debra Batten
From: Debra Batten
Sent: Friday, July 2, 2021 9:44 AM
To: John Roberson; Seth Gundersen
Cc: George Metcalf
Subject: SWL NOV Required Response 06252021.docx
Attachments: SWL NOV Required Response 06252021.docx
Importance: High
John,
Please find attached
an explanation of actions to betaken in regards to the Notice
of Violations)
that were sent to you
via email yesterday.
If you have any questions and or concerns please contact me
via email and
I will respond as quickly
as is possible.
Kindness Regards,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 811-Iolly Springs, NC 27540
Office: [phone] i Cell: [phone] 1
Town Website: www.hollvspringsnc.us

The Town of
HOLLY
SPRINGS
July 1, 2021
Mr. John W. Roberson
South Wake County Landfill
P.O. Box 550
Raleigh, NC 27602
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Utilities and Infrastructure
Water Resources
Subject: Actions Required in response to the Violations) Issued on June 29, 2021
Sewer Discharge Permit No. (IUP) 001
Dear Mr. Roberson,
As a result of the violations issued on June 29, 2021 the following actions are required:
1. Failure to notify POTW of limits violation within 24 hours of becoming aware of violation. Within 30
days of receipt of the violation notice from the Town of Holly Springs, S WL must conduct a preliminary
investigation into the cause of failure to report and actions taken to prevent a repeat of the failure to
report.
2. Exceeding a Permit limit requires collection of one repeat sample per in addition to permit required
monitoring to take place as soon as is possible. If the result of repeated analysis is within limits not
additional sampling is required. If the limits are exceeded the Town of Holly Springs is to be notified
as soon as is possible and additional sampling and analysis is to continue until the results are determined
to be within the permit limits. The results are to be reported, along with any additional actions take to
bring the parameter of interest to compliance status, within 30 of the receipt of the notice of violation
from the Town of Holly Springs.
3. Failure to sample and analyze per 40 CFR 136. Part II, 3 and Part 11 C. of the industrial user permit.
Effective immediately upon receipt of this violation SWL must maintain all documentation showing that
all analysis include field analysis are performed by a technician employed by a certified lab until which
time it is decided they or their contracted vendor (GFL) certify with the state of NC for performing field
lab analysis.
Utilities and Infrastructure, Town of Holly Springs
Cc: Seann Byrd, Water Resources Director
George Metcalf, GFL

Debra Batten
From: Levesque, Kevin <[e-mail]>
Sent: Thursday, July 29, 2021 10:33 AM
To: Debra Batten
Cc: George Metcalf; Seth Gundersen; John Roberson; Jones, Katie L.
Subject: --[EXTERNAL]--Response Letter for Notice of Violation - South Wake Landfill
Attachments: NOV Response Letter - South Wake Landfill.pdf
Debra,
On behalf of GFL Environmental, Inc (GFL), Dewberry is submitting the attached letter for the response to the Notice of
Violation (NOV) letter sent by the Town of Holly Springs to the South Wake Landfill dated June 29, 2021 and subsequent
letter sent by the Town of Holly Springs to the South Wake Landfill dated July 1, 2021 summarizing the actions required
in response to the NOV, The July 1, 2021 letter requires that South Wake Landfill conduct a preliminary investigation
into the cause of failure to report and actions taken to prevent a repeat of the failure. GFL has prepared the attached
response letter as the operator of the landfill. The results of the preliminary investigation of the cause of the failure to
report and actions taken to prevent a repeat of the failure by GFL are summarized in the attached response letter.
A hard copy of the attached letter will be mailed to your attention today.
Please contact George Metcalf or me with any questions.
Thank you,
Kevin Levesque, PE
Senior Project Manager
Water Market Segment
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
D 919.746,9624 C 919,758,0054
® Dewberry
www.dewberry.com
Visit Dewberry's website at www.dewberrv.com If you've received this email even though it's intended for someone

South Wake Landfill 1 6330 Old Smithfield Rd. I Apex, NC 27539
July 28, 2021
Ms. Debra Batten
Environmental Compliance Manager
Utilities and Infrastructure, Town of Holly Springs
128 S. Main Street
Holly Springs, NC 27540
Reference: IUP o01- Response to Notice of Violation Dated June 29, 2021
South Wake Landfill
6330 Old Smithfield Road, Apex, North Carolina 27539
Dear Ms. Batten:
This letter has been prepared in response to the Notice of Violations (NOV) letter sent by the
Town of Holly Springs to the South Wake Landfill dated June 29, 2021 and subsequent letter
sent by the Town of Holly Springs to the South Wake Landfill dated July 1, 2021 summarizing
the actions required in response to the NOV. The July 1, 2021 letter requires that South Wake
Landfill conduct a preliminary investigation into the cause of failure to report and actions taken
to prevent a repeat of the failure. GFL has prepared this letter as the operator of the landfill.
The results of the preliminary investigation of the cause of the failure to report and actions
taken to prevent a repeat of the failure by GFL are summarized below.
BACKGROUND INFORMATION
On May 10, 2o2i a sample of the discharge wastewater was collected and pH was measured by
a GFL operator. The operator measured the pH using a benchtop pH meter and recorded the
pH value of io.99 standard units (S.U.) on a field log sheet. A GFL operator also entered the
pH value of io.99 S.U. into a Microsoft® Excel spreadsheet that is used by GFL to track
operating data and sample collection data for the Leachate Wastewater Collection and
Discharge System. The data in the spreadsheet is also used to prepare the monthly Discharge
Monitoring Reports (DMRs) that are submitted to the Town of Holly Springs.
CAUSE OF THE FAILURE TO REPORT
Based on conversations with the GFL operator that measured and recorded the pH value of
10.99 S.U. and the GFL employee that prepared the monthly DMR, GFL management has
concluded that the GFL operator did not check the measured and recorded value of io.99 S.U.
against the limits of 5.5 -10.o S.U. for pH in the Industrial User Pretreatment (IUP) Permit.
Also, the GFL employee that prepared the DMR did not check the recorded value of io.99 S.U.
against the pH limits in IUP Permit during preparation of the DMR prior to submission to the
Town of Holly Springs.

GF
e n v I r_e_n.m en, -a i South Wake Landfill 6330 0ld Smithfield Rd. Apex, NC 27539
ACTIONS TAKEN TO PREVENT A REPEAT OF THE FAILURE
GFL has contracted Pace Analytical to perform the measurement and recording of pH of the
discharge wastewater in order to comply with the requirement in the permit to analyze permit
pollutants in accordance with 40 Code of Federal Regulations (CFR) Part 136. GFL has revised
the field log sheet used for recording the measured pH of the discharge wastewater to include
the limits of 5.5 - 10.0 S.U. for pH in IUP Permit for reference by Pace Analytical and GFL
when recording the measured pH. GFL has also revised the spreadsheet that is used by GFL to
track operating data and sample collection data by automatically color coding the data entered
into the spreadsheet using conditional formatting to alert GFL of a pH exceedance outside of
the acceptable 5.5 - 10.0 S.U. range. GFL will implement a two-step review process for all
DMRs submitted to the Town of Holly Springs. The first reviewer will be the preparer of the
DMR and the second reviewer will be a member of the GFL management team. GFL will
conduct a training in August 2021 for personnel involved in the operation, sample collection,
field measurement, and reporting for the Leachate Wastewater Collection and Discharge
System at the South Wake Landfill.
Sincerely,
George Metcalf
GFL Environmental, Inc.
cc: Seth Gundersen, GFL Environmental, Inc.
Katie Jones, PE, Dewberry Engineers, Inc.
Kevin Levesque, PE, Dewberry Engineers, Inc.

The Town of
HOLLY
SPRINGS
June 29, 2021
Mr. John W. Roberson
South wake County Landfill
P.O. Box 550
Raleigh NC, 27602
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Utilities and Infrastructure
Water Resources
Subject: Notice of Violations)
Sewer Discharge Permit No. (IUP) 001
Dear: Roberson,
This letter serves as a Notice of Violation for exceeding the pH limit as stated in
IUP(Industrial User Permit) #002 issued April 1, 2019 to South Wake Landfill. The
daily limits for pH not to be exceed a pH below or above the range of
5.5 — 10.0 SU.(See ]UP, Part 1, Section F for the Effluent Limits and Monitoring
Requirements.) The pH value of the sample collected and analyzed and reported on May
10, 2021 on the Daily Monitoring Report was 10.99 SU. This value exceeds the upper
end of the acceptable range of the industrial users permitted pH range. In addition to the
pH violation, there is also a reporting violation being issued for failure to report. South
Wake also failed to report the permit violation as required in IUP Part II Section A.2
"Reporting" . This analysis was analyzed at the facility due to the 15-minute hold time.
Had we been notified immediately about the exceedance; additional sample could have
been collected and analyzed to bring the Daily Max limit back in range.
As the pH was not noted to be non -compliant, additional samples were not collected.
The Daily Monitoring Report for the month of May was received on June 10, 2021. That
is when the pH violation was apparent and South Wake Landfill was notified. Because
the violation went unnoticed, no additional sampling was requested. Sampling was
conducted again May 17, 2021 which yielded a pH result of 6.3 SU. There was another
sample collected on May 24t` with a reported pH value of 6.0 SU. Both of these results
were within the permitted range.

It is the industry's responsibility to maintain compliance with all effluent limits, to review
the permit, and be familiar of all requirements of the permit. In addition to the pH limit
violation(#1), and the failure to report the violation(#2), it was also determined that the
pH and temperature analysis have been analyzed and reported by South Wake Landfill
staff though they do not hold field lab certification for these parameters as required by
Part 11 C. of the industrial user permit. "All compliance monitoring must be performed by
a laboratory certified by the state of North Carolina Department of Water Resources for
the specific parameter(s) being analyzed." Which is another violation (0).
As the permitting authority of this permit approved by the NC State DWQ, I am required
to issue this Notice of Violation(s) within 30 days of the date of notification or July 10,
2021. In addition to the Notice of Violations listed above, as referenced in the Sewer
Use Ordnance section 16-239 and the Enforcement Response Plan of Town of Holly
Springs approved by NC DWQ, there could be a penalty assessed up to $25,000. It has
been decided that a penalty of only $500.00 will be based on the following
considerations:
1. Magnitude of the violations)
2. Duration of the violation(s)
3. Number of Resulting Violation(s)
4. Possible Effects on POTW Collections System
5. Possible Effects on the POTW
If you do not currently have a copy of the Sewer Use Ordinance or the Enforcement
Response Plan please let me know and I will send one to you vial email.
If you have any questions please contact me at [phone].
�ntal Compliance Manager
and Infrastructure, Town of Holly Springs
Cc: Seann Byrd, Water Resources Director
George Metcalf, GFL

Debra Batten
ATTACHMENT a
From: Seth Gundersen <[e-mail]>
Sent: Monday, July 26, 2021 10:53 AM
To: Debra Batten
Subject: --[EXTERNAL]--Discharge Reduction
Debbie,
We have scaled back our discharge based on some higher Ammonia results. We'll be sending about 800-850 GPD so you
won't see much from us this week.
Seth
Seth Gundersen � Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 1 C [phone] 1 [e-mail] I www.-qflenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.

Debra Batten
From:
Sent:
To:
Cc:
Subject:
Good Afternoon Debbie,
Seth Gundersen <[e-mail]>
Wednesday, August 4, 2021 4:14 PM
Debra Batten
George Metcalf, 'Levesque, Kevin'
[EXTERNAL] --New Pump!
I wanted to give you aheads-up on a few different items.
ATTACHMENT 9
First, We have ordered a VFD pump and controller so that we can finally accommodate asemi-continuous flow to your
plant.
Second, We received an IUP from the Town of Lumberton. This will require some information sharing going forward but
we can get that worked out.
I'm heading out of town for the weekend so you won't hear from me for the rest of the week.
Have a great weekend
Seth
Seth Gundersen � Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 1 C [phone] 1 [e-mail] I www.aflenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.

Debra Batten
From: Seth Gundersen <[e-mail]>
Sent: Wednesday, August 4, 2021 10:15 PM
To: Debra Batten
Cc: George Metcalf, Levesque, Kevin
Subject: Re: --[EXTERNAL]--New Pump!
Beverly Allen is the Compliance Manager down there
Have a good weekend
Seth
Sent from my iPhone
Seth Gundersen I Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 1 C [phone] 1 [e-mail] I www.gflenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed ar
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please no
the sender and erase this email message immediately.
On Aug 4, 2021, at 4:26 PM, Debra Batten <[e-mail]> wrote:
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless
you recognize the sender and know the content is safe.
Seth,
Who is the Pretreatment Coordinator with Lumberton in the event I should have any questions?
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 811dolly Springs, NC 27540
Office: [phone] 1 Cell: [phone] 1
Town Website: hollvspingsnc.gov
<image001.png>
Town of
Holly Springs emails are switching
to
.gov addresses. Please
make sure
to update my
contact
information to [e-mail]
before Jan.
31, 2022.

From: Seth Gundersen <[e-mail]>
Sent: Wednesday, August 4, 20214:14 PM
To: Debra Batten <[e-mail]>
Cc: George Metcalf<[e-mail]>;'Levesque, Kevin' <[e-mail]>
Subject: --[EXTERNAL]--New Pump!
Good Afternoon Debbie,
wanted to give you aheads-up on a few different items.
First, We have ordered a VFD pump and controller so that we can finally accommodate asemi-
continuous flow to your plant.
Second, We received an IUP from the Town of Lumberton. This will require some information sharing
going forward but we can get that worked out.
I'm heading out of town for the weekend so you won't hear from me for the rest of the week.
Have a great weekend
Seth
Seth Gundersen 1 Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 1 C [phone] 1 seth.gundersenOmflenv.com I www.gflenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed ar
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please no
the sender and erase this email message immediately.
• 's email oribinated frorn outside of the. ar�;al7ization. Da not click links of
the sender and know the content is sale.
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-11.

Debra Batten
From: Debra Batten
Sent: Thursday, August 12, 2021 11:20 AM
To: Seth Gundersen
Cc: 'Levesque, Kevin'; '[e-mail]'
Subject: RE: --[EXTERNAL]--DMR Question
I will need to know that information but if you would prefer to send in a separate report as Lumberton may not need
that information on their DMR I believe that would be acceptable.
Kindest Regards,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 811-Ioliy Springs, NC 27540
Office: [phone] 1 Cell: [phone] 1
Town Website: hollvspingsnc.gov
e,
Town of Holly Springs emails are switching to .gov addresses. Please make sure to update my contact
information to debra.baffen4hollyspringsnc.gov before Jan. 31, 2022,
From: Seth Gundersen <[e-mail]>
Sent: Thursday, August 12, 20219:43 AM
To: Debra Batten <[e-mail]>
Cc:'Levesque, Kevin'<[e-mail]>;'[e-mail]' <[e-mail]>
Subject: --[EXTERNAL]--DMR Question
Good Morning Debbie,
As you know, we are reconstructing our analytical sheet and creating aDMR-generator for Lumberton in addition to
yours. Part of that project involves purging information that is not needed since we'll be adding additional information
to both DMRs. We noticed a column on your DMR called "Sludge Wasted." Is this information that you require on the
DMR or can we remove the column?
Seth
Seth Gundersen � Operations Supervisor I
GFL Environmental

6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 1 C [phone] 1 seth.cundersen(ftfienv.com I www.aflenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.

ATTACHMENT 10
Debra Batten
From: Debra Batten
Sent: Monday, August 23, 2021 1:36 PM
To: Seth Gundersen; Jones, Katie L.; [e-mail]
Cc: John Roberson; George Metcalf; Seann Byrd
Subject: TTO Certification
Importance: High
Mr. Roberson,
As
the certification
option was not exercised for the first 6
month
monitoring period of January to June 2021 the Town
of
Holly springs will
be collecting samples and monitoring
for the
TTO as listed in 40CFR 401,15,
The permit reads as follows:
"Total Toxic Organics (TTO) Certification
In lieu of monitoring for TTO, the permittee may, upon submitting to the Control Authority one sample
showing TTO compliance and a toxic organic management plan, make the following certification every six
months:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the
permit limitation for total toxic organics (TTO), I certify that, to the best of my knowledge, no dumping
of concentrated toxic organics into the wastewaters has occurred since filing of the last monitoring
report. I further certify that this facility is implementing the toxic organic management plan submitted
to the Control Authority."
At a minimum, the certification statements are due by June 15th of each year covering the January through
June six month period, and December 15�h of each year covering the July through December six month
reporting period. If the certification is not submitted for both periods within 5 days of the respective due
dates, the Town of Holly Springs shall collect TTO samples before December 31 and the permittee will be
billed for the cost of the TTO sampling and analysis."
Total Toxic Organics, is the sum of the concentrations of the toxic organic compounds listed in 40 CFR 401.15 that are
found in the permittee's process discharge at a concentration greater than 0.01 mg/I. Provided this concentration limit is
not exceeded you may return to the certification option as written. Any Questions please contact me at 919-557-2907,
Regards,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 811-lolly Springs, NC 27540
Office: [phone] 1 Cell: [phone] 1
Town Website: holivspinclsnc.gov
ej

Town of Holly Springs emails are switching to .gov addresses. Please make sure to update my contact
information to [e-mail] before Jan. 31, 2022.

ATTACHMENT 1 1
Debra Batten
From: Seth Gundersen <[e-mail]>
Sent: Wednesday, September 1, 2021 2:31 PM
To: Debra Batten
Cc: George Metcalf; 'John Roberson'; Roy Baldwin
Subject: RE: --[EXTERNAL]--VFD Pump Controller
Attachments: VFD Request to HS WWTP.pdf
In the
interest of being expedient
and precise,
I have asked Dewberry to stand down from this install request. It appears
that I
confused everybody when I
asked them
to handle this communication.
Attached is our letter requesting the upgrade I was speaking with you about on the phone earlier.
I do
not have
a serial
number for the drive at this time. If that is a piece of information you need, I will have to send it to
you
once the
vendor
installs the unit.
Please advise,
Seth
Seth Gundersen i Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 i C [phone] i [e-mail] i www.cifenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.
From: Debra Batten <[e-mail]>
Sent: Wednesday, September 1, 2021 11:14 AM
To: Seth Gundersen <[e-mail]>
Cc: George Metcalf <[e-mail]>; 'John Roberson' <[e-mail]>
Subject: RE: --[EXTERNAL]--VFD Pump Controller
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless our the
sender and know the content is safe.
If you would please include this request on
Letter Head and
email it as an attachment. Alen be sure that the letter is
Cc: to all involved. I have talked again with
Kevin in the last
half hour and he
too maybe working on a letter which would
include the Manufacture, model and serial
number of what
is being installed
which I told would be fine.
I have also requested other info. I will forward to you and Katie the email I sent to him.
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs

PO Box 81Holly Springs, INC 27540
Office: [phone] 1 Cell: [phone]
Town Website: hollyspingsnc.gov
Town of Holly Springs
emails are switching to
.gov addresses.
Please make
sure to update my contact
information to [e-mail]
before Jan.
31, 2022,
From: Seth Gundersen <[e-mail]>
Sent: Wednesday, September 1, 2021 11:09 AM
To: Debra Batten <[e-mail]>
Cc: George Metcalf <[e-mail]>; 'John Roberson' <John. Roberson@wa kegov.com>
Subject: --[EXTERNAL]--VFD Pump Controller
Debbie,
Per our
phone
conversation
I wanted to let you know that we intend on installing a VFD controller on our Transfer Pump
that we
use to
discharge into your system. We are not going to be changing anything in the system other than the
manner
in which
the motor
for our transfer pump is activated.
I have been advised that all of the parts for this project have come in and my vendor is ready to install.
Can
we schedule the
install of the VFD Controller next week? Does this email satisfy your
requirements as prescribed in
the
IUP?
Thank You,
Seth
Seth Gundersen � Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 1 C [phone] I seth.gundersencd)- env.com www.gflenv.com
Confidentiality Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).

, '[GREEN [GREEN FOR LIFE
environmenoa
September 1, 2021
Ms. Debra Batten
Environmental Compliance Manager
Utilities and Infrastructure, Town of Holly Springs
128 S. Main Street
Holly Springs, NC 27540
Dear Ms. Batten,
3301 Benson Drive, Suite 601 I Raleigh, NC 27609
South Wake Landfill would like to notify you of our intent to install a Variable Frequency Drive controller
on our effluent transfer pump motor. This VFD will control the motor to allow specific flow rates
ultimately to provide us with the mechanical capacity to provide your plant with a continuous discharge
as mentioned on the cover letter of our most recent IUP.
This will be a DURAPuIse GS20X Series AC controller and it will be installed by Pump One Environmental.
Pending you approval we would like to proceed with the installation next week (September 6, 2021)
Thank You,
Seth C. Gundersen
CC: George Metcalf, John Roberson, Roy Baldwin

The Town of
HOLLYS
SPRINGS
September 30,2021
Mr. Seth Gunderson
GFL Environmental
3301 Benson Drive , Suite 601
Raleigh, NC 27609
Re: Approval for installation of VFD Controller
Mr. Gunderson,
Water Resources
Environmental Compliance
Thank you for contacting me in advance of the install of the Variable Frequency Drive (VFD) controller on our
effluent transfer pump motor. It is understood that the VFD will control the motor allowing specific flow rates
ultimately to provide South Wake Landfill (S WL) with the mechanical capacity to provide our plant with a
continuous discharge for the wastewater coming to us from this facility.
I see no reason at this time for you to not move forward with the install. I have contacted Seann Byrd to see if
he has interest in observing the install. It is my understanding that the contractors have contacted you and
have plans to completed this installation on Monday October 4th,2021. Once you hear a more definite time
frame please be in contact so I can let him know when he or the TOHS staff should be at the facility to
observe.
If you have any questions please contact me via email at the address below.
Kinde Regards,
De atte
vlronme al Cp pli nce Manager
W r Resources/ Town of Holly Springs
PO Box 811-Iolly Springs, NC 27540
[e-mail]
Cc: Mr. Seann Byrd
Mr. Seth Gundersen
Mr, George Metcalf
Mr. John Roberson, Wake County
Mr. Roy Baldwin, Wake County
File

Debra Batten
From: Debra Batten
Sent: Friday, September 3, 2021 6:20 PM
To: Seth Gundersen; George Metcalf
Cc: Jones, Katie L.
Subject: July DMR
Seth,
ATTACHMENT 12
Entering the surcharge data I noticed you had entered "0" on the days there was no discharge. These should be left
with no entry. When you enter "0" it skus the averages for the monthly average flow. I will be on vacation until
September 13th. Touch base with me then and we will get this resolved.
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box BIHolly Springs, NC 27540
Office: [phone] 1 Cell: [phone]
Town Website: hollyspingsnc.gov
Town of Holly Springs emails are switching to .gov addresses. Please make sure to update my contact
information to dera, [e-mail] before Jan. 31, 2022.

The Town of Utilities and Infrastructure
HOLLY water Resources
Environmental Compliance
SPRINGS
ATTACHMENT 14
SIU Inspection Form
Name of Industry: South Wake Landfill IUP # 001
Address of Industry: 6530 Old Smithfield Rd NP Expiration Date: o 12/31/2023
Industry
Representatives:
Seth Gundersen
Title:
Operations Suhervisor
Maxine Oakley
Title:
Office
Coordinator
POTW Representatives:
Debra
C. Batten
Title:
Environmental Comnliance
Manaeer
Katelvn
Tresino
Title:
Laboratory Technician
Date of Inspection: 11/10/21 Time of Inspection: 2:30 am/�
Purpose of Inspection: Annual ✓ Other (Describe)
POTW to which IU discharges Town of Holly Shrines NPDES # 0063096
Is SIU currently in SNC? NO If yes, for what?
PART I -INITIAL INTERVIEW
Has anything changed since the last inspection or IUP application in the following:
COMMENTS
Product
Raw materials used
Manufacturing processes
Categorical, if applicable
Production rate
W WTP. Number of emDlovees 15
Number of shifts
YES/NO
YES/NO
YES/NO
YES/NO
YES/NO
15,000/dav,13,000 is puma and haul to Lumberton
YES / NO One shift — 6:30 am — 5:00 pm
Comments:
PART II - PLANT TOUR - Visit all areas where wastewater is generated or where there are
drains to the POTW.
Plant Tour Section A - PRODUCTION AND STORAGE AREAS
W
1. Are there floor drains in the production areal YES / NO Where do they go? Secondary Containment
eoes to Stormwater.
2. Are production areas diked, contained, or otherwise constructed in such a way as to prevent harm to the W TP,
especially from spills or slugs? YES / NO Comments:
3. Are there floor drains in the storage area? YES / NO Where do they go?
4. Are storage tanks and areas diked, contained, or otherwise constructed in such a way as to prevent harm to the
W WTP, especially from spills or slugs? YES / NO Comments:
5. Are process and storage tanks and pipes labeled? YES / NO:
6. How are off -spec raw materials, and products disposed oP?
Pumn and Haul or Sludee back to landfill
Title: SIU Inspection Form
File name: Y:UJepartments\Utilities &Infrastructure\Water Resources\ Lab--Pretreatment\Pretreatment\Pretreatment
ProgramUnspections\S WL1S WLlnspection 111021.rtf
Revision data: November 16,2021
Page 1
5. Are process and storage tanks and pipes labeled? YES / NO:
6. How are off -spec raw materials, and products disposed oP?
Pumn and Haul or Sludee back to landfill
Title: SIU Inspection Form
File name: Y:UJepartments\Utilities &Infrastructure\Water Resources\ Lab--Pretreatment\Pretreatment\Pretreatment
ProgramUnspections\S WL1S WLlnspection 111021.rtf
Revision data: November 16,2021
Page 1

The Town of
HOLLY
SPRINGS
Utilities and Infrastructure
Water Resources
Environmental Compliance
SIU Inspection Form
7. When is the production area cleaned? As needed according to rain events
Is the wastewater from cleaning the production area discharged to
the POTWY
YES
/ NO
What non -process wastewaters are discharged to
POTW7
All discharge
going
to POTW are from
leachate and condensate
PART II -Plant Tour Section B -PRETREATMENT SYSTEM
Ask the operator to describe pretreatment system.
1. Does operator seem knowledgeable about the system? YES / NO
Comments:
2. Are all units operational? YES / NO Plant is still not operating as it was in 2018 prior to hurricane. A
meeting has been previously been scheduled for 11/15/2021 To discuss change in previously discussed
Ammonia Stripping Treatment to Reverse Osmosis Treatment.
3. How often does operator/maintenance person check system? Daily
4. Is there an operator for each shift? YES / NO Mike Heffron (Grade II Collections System Certification)
5. How and when is sludge disposed of? Solids are brought back to landfill about 4000 gallons every 3
months, or when BOD concentration elevates. This may arrant larger quantity to be sent back to the
landfill.
6. Is there a schedule for preventative maintenance? YES / NO Daily compliance calendar still in place
�, I Comments:
PART II -Plant Tour Section C -SAMPLING POINTS) AND FLOW MEASUREMENT
(Collect a sample if desired.)
1. Does an outside lab complete sampling? YES / NO If yes, name of lab. Pace Analytical Laboratories
2. If industry completes sampling, ask the industry representative to describe sampling procedures.
Comments: N/A
3. Is flow measurement equipment operational? YES / NO Comments: A continuous monitoring flow
meter was installed as requested during last year's inspection. Resettable meters should not be used.
4. Is there a calibration log for the flow meter? YES / NO Comments: Smith Gardner Engineering
provided calibration certifications dated June 2021 and October 2021
Comments:
PART III -EXIT INTERVIEW
Review monitoring records and other SN records required by IUP.
1. Are files well organized? YES / NO Comments:
2. Are sample collection / chain -of -custody forms filled out properly? YES / NO
Comments: It has been recommended that SWL have traceability references fm
3. Dc results in files agree with reports sent to POTW7 YES / NO
Comments:
Title: SN Inspection Fortn -
File name: Y:\Departments\Utilities &Infrastructure\Water Resources\_Lab--Pretreatment\Pretreetment\Pretreatment
ProgramUnspectiousVS WL\S WLInspection111021.rtf
Revision data: November 16,2021 Page 2

The Town of
HOLLY
�-� SPRINGS
Utilities and Infrastructure
Water Resources
Environmental Compliance
SIU Inspection Form
4. Who has authority to shut down production should a spill or slug discharge occur?
5. How does SIU inform employees of whom to call at POTW in case of spilUslug? Initial training, Signs are
posted throughout the facilitv(down in office due to office upgrades) and procedures reviewed during annual
training.
If slug/spill plan is already required by POTW, review procedures.
6. Is SILT implementing slug/spill plan? YES / NO Comments: Updated 2020. In place
Comments:
INSPECTION RESULTS
Slug/Spill Control Plan Needed? YES / NO
Comments, Required or Recommended Actions: Updated by Seth Gundersen 2020 No requirements or
recommendations at this time.
Signature of Inspectors)
Staff Present: Seth Gundersen -Operations Supervisor and Maxine Oakley —Office Coor.
Title: SIU Inspection Form
File name; Y:\Departments\Utilities & Infrastmcture\Water Resources\_Lab--Pretreatment\Pretreatment\Pretreatment
ProgmmW spections\S WL\S WLInspection 111021.rtF
Revision data: November 16,2021

ATTACHMENT 13
Debra Batten
From: Debra Batten
Sent: Tuesday, October 26, 2021 3:41 PM
To: Terry Foster; Seann Byrd; Casey Denton
Subject: FW: --[EXTERNAL]--Meeting Request
Importance: High
There will be a meeting on November 16`h with South Wake Landfill to discuss a change In their plans for treatment. You
should get an invitation from George Metcalf as he is the one requesting the meeting. Please reserve time from 1:00 to
2:00 for discussion. See email below.
Though it is not spelled
out in the
email, it is
my understanding
that they
are looking at going to the RO treatment with
the Emerging Pollutant
Concerns,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 81Holly Springs, NC 27540
Office: [phone] [ Cell: [phone]
Town Website: hollyspingsnc.gov
Vt
Town of Holly Springs emails are switching fo .gov addresses. Please make sure to update my contact
information to [e-mail] before Jan. 31, 2022.
From: George Metcalf <[e-mail]>
Sent: Tuesday, October 26, 2021 12:57 PM
To: Debra Batten <[e-mail]>
Cc: Travis Hitchcock <[e-mail]>; Bryan Wuester <[e-mail]>
Subject: --[EXTERNAL]--Meeting Request
Debra,
Hope you are doing well. Per our conversation South Wale LF has request a meeting on November 16`h @ 1:OOpm to
discuss the implementation options for leachate pre-treatment. Attendees will include myself, Travis Hitchcock RVP GFL
Environmental, Bryan Wuester Regional Landfill Manager and a representative from RoChem. A calendar invite has been
sent out. Please feel free to contact me when any questions or request prior to the meeting, Thanks
George Metcalf I Landfill General Manager II
GFL Environmental

6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 315211 C 919-604-2273 1 georce.metcalfOciflenv.com I w .aflenv.com
Confidentiality Nolice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.

Debra Batten
From: George Metcalf <[e-mail]>
Sent: Tuesday, October 26, 2021 12:33 PM
To: Debra Batten
Subject: --[EXTERNAL]--Meeting
Debra would you be available for a meeting on November 16th at 1:OOpm to discuss the upgrades we'd like to implement
at South Wake Landfill?
George Metcalf � Landfill General Manager II
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 315211 C 919-604-2273 1 [e-mail] I www.oflenv.com
Confidentially Notice: This email message (including attachments, if any) is intended for the use of the individual or entity to which it is addressed and
may contain information that is privileged, proprietary, confidential and exempt from disclosure. If you are not the intended recipient, you are notified
that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
the sender and erase this email message immediately.

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Industry Name:
South Wake
Land Fill
[UP #/Pipe #
001
Reporting
1/1/2021
Period:
6l30/2021
Detection Level
(DL) entered
1/2 Detection X
Level (DL) entered
Sample
Sample Date Type-
P=POTW, I-
i��„�rN
Permit Limit
TRC Limit
ATTACHMENT 16
1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
specific changes, an then reinstate protection again.
2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5.
(Note use second option only when detection level at or below limit)
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
'Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
Chronic or TRC SNC
Daily Flow Violation Type
MGD
0.050
0.060 Optional'
Req TRC
1 /4/2021
Total
I
0.007
1/11/2021
1
0.008
021
1
0.007
021
1
0.008
oz1
1
0.005
021
I
0.005
12/15/2021
0.006
021
P
0.006
021
P
0.006
021
1
0,008
3/l/2021
1
0.006
3/8/2021
I
0.005
3/15/2021
0.005
3/22/2021
I
0.004
3/23/2021
0.004
3/29/2021
1
0.002
4/5/2021
0.002
4/12/2021
0.004
4/19/2021
1
0.004
4/26/2021
1
0,003
5/3/2021
1
0.003
5/10/2021
1
0.002
5/18/2021
1
0.002
5/26/2021
1
0.004
6/1/2021
1
0,004
6f7/2021
1
0.004
6/14/2021
1
0.005
6/21 /2021
0.005
6/29/2021
0.007
Average of Column
Samples 26 0 0
Violations' 0.0
%TRC Violations 0.0
'SNC? NO
Daily
Concentration Violation Type
Mg/L
Rea TRC
Violations 0.0
TRC Violations 0.0
SNC? NO
Daily
Concentration Violation Type
Mg/L
Rea TRC
violations 0.0
TRC Violations 0.0
SNC? NO
Daily
Concentration Violation Type
Mg/L
Rea TRC
%Violations 0.0
TRC Violations 0.0
SNC? NO

1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
specific changes, an then reinstate protection again.
2) For data reported as "Below Detection" choose either to enter detection level or 112 detection level and mark choice in cell B5.
(Note use second option only when detection level at or below limit)
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
`Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
"` TRC doesn't a t H
Daily
Concentration Violation Type
Ml
10.00
Reg TRC
8.20
8.40
8,30
6.70
6.00
5.97
7.40
8.16
7.33
7.50
6.52
7.40
7.50
8.44
7.60
7.30
8.20
7.00
6,90
6.50
10.99
5.91
7.10
8.30
8.30
8.30
23
Violations 4.3
TRC Violations N/A
SNC? No
Daily
Concentration Violation Type
Mg/L
Reg TRC
violations o.o %
TRC Violations o.0
SNC? NO
Daily
Concentration Violation Type
MglL
Reg TRC
Violations
TRC Violations
SNC?
Daily
Concentration Violation Type
MgJL
Reg TRC
violations o.o %
TRC Violations 0.0
SNC? NO
Data entry in blue bordered cells
pecifc changes, an then reinstate
For data reported as "Below Deta
Vote use second option only when
IOTE - Spreadsheet corrected Fet
Chronic (>=66%) and TRC (�
Daily
Concentration Violation Type
Mg/L
0
Rea TRC
Violations 0.0
TRC Violations 0.0
SNC? NO

only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
protection again.
action" choose either to enter detection level or 112 detection level and mark choice in cell B5.
detection level at or below limit)
> 09 to properly assess TRC violations using "equal to or greater than'.
>=33%) SNC definitions use term "pollutant " so technically not required to apply to flow.
:1773=.
Daily
Concentration Violation Type
Mg/L
0
0
Rea TRC
Violations 0.0
TRC Violations 0.0
aNlr.
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
Violations 0.0
TRC Violations 0.0
7Daily7
on
Rea TRC
Violations 0.0
TRC Violations 0.0 %
SNC? NO SNC? NO SNC? NO
1) Data
entry in blue bordered cells only. All other cells protected. Passspecific changes, an then reinstate protection again.
2) For data reported as "Below Detection" choose either to enter detect
(Note use second option only when detection level at or below limit)
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violatio
'Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "F
Daily
Concentration Violation Type
Mg/L
Rea TRC
Violations 0.0 °/,
TRC Violations 0.0
SNC? NO
Daily
Concentration Violation Type
Mg/L
Rea TRC
Violations 0.0
TRC Violations 0.0
SNC? NO

.word 3. Strongly Recommend only unprotect to make
:ion level or 1/2 detection level and mark choice in cell B6.
ns using "equal to or greater than".
tollutant," so technically not required to apply to flow.
Violations 0.0
TRC Volations 0.0
SNC? NO
=HRNr
Dairy
Concentration Violation Type
Mg/L
Reg TRC
Violations
TRC Violations
SNC?
Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only
ecifc changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and r
ate use second option only when detection level at or below limit)
)TE . Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
ow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not requirec
Daily
Concentration Violation Type
Mg/L
0
Rea TRC
Violations
TRC Violations
SNC?
Daily
Concentration Violation Type
Mg/L
0
Rea TRC
Violations
TRC Violations
SNC ?
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
Violations 0.0
TRC Violations 0.0
SNC? NO

Industry Name:
South wake
Land Fill
[UP #/Pipe #
001
Reporting
7/1 /2021
Period:
12/31 /2021
Detection Level
DL) entered
112 Detection
X
Level(DL) entered
Sample
Sample Date
Type-
P=POTW, I-
InAilefiv
Permit Limit
TRC Limit
1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
specific changes, an then reinstate protection again.
2) For data reported as "Below Detection" choose either to enter detection level or 1 /2 detection level and mark choice in cell B5.
(Note use second option only when detection level at or below limit)
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
'Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
Daily
Daily
Daily
Daily Flow Violation Type Concentration
Violation Type Concentration
Violation Type Concentration Violation Type
MGD
Mg/L
Mg/L
Mg/L
0.050
0.060 Optional'
Rea TRC
Rea TRC
Rea TRC Rea TRC
8/2/2021
I
0.003
8/9/2021
1
0.003
8/16/2021
0.004
8/23/2021
1
0.003
8/30/2021
1
0.002
8/31/2021
P
0.005
9/1/2021
A
0,005
9/7/2021
0.005
9/13/2021
1
0,002
9/20/2021
1
0.002
9/27/2021
1
0.002
10/4/2021
1
0.004
10/11/2021
1
0.003
10/18/2021
1
0.003
10/25/2021
I
0.004
12/6/2021
1
0.003
12/13/2021
1
0.002
12/20/2021
1
0.002
12/27/2021
1
0.002
Average of Column
i ocai aampies
Violations' 0.0
%TRC Violations 0.0
'SNC? NO
t8 0 0
Violations 0.0
TRC Violations 0.0
SNC? NO
Violations 0.0
TRC Violations 0.0
SNC? NO
Violations 0.0
TRC Violations 0.0
SNC? NO

Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
pecific changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5.
Vote use second option only when detection level at or below limit)
TOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
°low : Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
Daily
Concentration
Mg/L
8.30
8.30
8.40
8.31
8.20
8.07
8.00
8.00
8.00
7.95
T80
7.98
8.00
8.10
8.40
8.60
8.20
7.80
813
18 0
Violations 0.0
TRC Violations
SNC?
TIIR.71R
Daily
Concentration Violation Type
Mg/L
Reg TRC
Violations 0.0
TRC Violations 0.0 °/o
SNC? NO
Daily
Concentration Violation Type
Mg/L
Reg TRC
Violations 0.0
TRC Violations 0.0
SNC? NO
Daily lVolationType
centration
Mg/L
Rea TRC
Violations 0.0
TRC Violations 0.0
SNC? NO
Data entry in blue bordered cells
�cifc changes, an then reinstate
For data reported as "Below Data
ate use second option only when
1TE -Spreadsheet corrected Fet
ow: Chronic (>=66%) and TRC (
Daily
Concentration Violati7Type
Mg/L
Reg TRC
Violations 0.0
TRC Violations 0.0
SNC? NO

only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
protection again.
action" choose either to enter detection level or 112 detection level and mark choice in cell B5.
detection level at or below limit)
109 to properly assess TRC violations using "equal to or greater than".
>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
�PPFF
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
violations o.o
TRC Violations 0.0
Daily
Concentration Violation Type
Mg/L
0
0
Reg TRC
Violations 0.0
TRC Violations 0.0
Daily
Concentration Violation Type
Mg/L
0
0
Reg TRC
Violations 0.0
TRC Violations 0.0
SNC? NO SNC? NO SNC? NO
Dat
entry in blue bordered cells only. All other cells protected. Pass
pecific changes, an then reinstate protection again.
For data reported as 'Below Detection" choose either to enter detect
Vote use second option only when detection level at or below limit)
TOTE - Spreadsheet corrected Feb 09 to properly assess TRC violatio
=low: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "F
Daily
Concentration Violation Type
Mgt]
0
0
Reg TRC
NO
Violations 0.0
TRC Violations 0.0
SNC?
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
%Violations 0.0
TRC Violations 0.0
SNC? NO

word 3. Strongly Recommend only unprotect to make
on level or 1/2 detection level and mark choice in cell B5.
ns using "equal to or greater than".
tollutant," so technically not required to apply to flow.
Daily
Concentration Violation Type
Mg/L
Rea TRC
°/, Violations 0.0
TRC Violations 0.0
SNC? NO
>HENf
Daily
Concentration Violation Type
Mg/L
0
Rea TRC
Violations
TRC Violations
SNC?
Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only
pecific changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and r
Vote use second option only when detection level at or below limit)
TOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than'.
=low: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not requires
Daily
Concentration Violation Type
Mg/L
Rea TRC
Violations
TRC Violations
SNC?
Daily
Concentration Uolatlon Type
Mg/L
0
Reg TRC
Violations 0.0
TRC Violations 0.0
SNC? NO
entmdon
ation Type
Reg TRC
violations o.o
TRC Violations 0.0
SNC? NO

ATTACHMENT 17
Pretreatment Annual Report (PAR)
Industrial Data Summary Form (IDSF)
Use separate forms for each industry/pipe
Enter BDL values as < (value)
* Total # of samples =>
* Maximum (mg/1) =>
* or Maximum (lb/d) =>
* Average (mg/1) =>
* or Average Loading (lb/d) =>
% violatiions,(chronic SNC is >= 66%) =>
%TRC violations, (SNC is x 33 %) =>
* Total # of samples =>
* Maximum (ug/l) =>
* or Maximum (lb/d) =>
* or Average (mg/1) =>
* or Average Loading (lb/d) =>
%violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Maximum (lb/d) =>
* or Average (mg/1) =>
* or Average Loading (lb/d) =>
%violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
Control Authority,
Town Name
=>
Town of Holly Springs
Industry NameW
W TP Name
=>
Utley Creek WRF
NP #
NPDES #
=>
NCO063096
Pipe #
1st 6 months, dates
=>
l/l/2021 6/30/2021
2nd 6 months, dates
=>
7/1/2021 12/31/2021
South Wake Landfill
001
001
Flow, mgd
BOD (mg/L)
TSS (mg/L)
Ammonia (mg/L)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
144
143
27
27
27
27
27
27
0,0080
0.0070
996
22630
5,550
708
1,490
L850
62.3
50A
231.6
20.8
45.1
52.2
0,0045
0.0029
319.37
796.37
593.10
350,41
838,37
1,280.22
12.68
18.82
23.61
8.57
27,92
32,00
Arsenic kupLj
Cadmium (ug/L)
Chromium (uglI)
COD
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
0
6
3
7
3
7
N/A
100.0
<10.0
10.00
330.0
470
MONITOR ONLY
Copper (ug/L)
Cyanide (mg/L)
Lead (ug/L)
Mercury (ng/L)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
3
7
2
6
3
7
1
2
<100.00
50,00
0,0430
0,0380
<25,00
119600,00
<200.00
<2,000.00
MONITOR ONLY
tsuL => uetow Detection Limit mg/1=> milligrams per liter
POTW must enter at least one of these RJP => Industrial User Permit 16/d => pounds per day
four rows, Please indicate how averages were calculated SNC => Significant Non -Compliance mgd => million gallons per day
Avg period could be month, Qtr, or 6-month & if BDL, 1/2BDL, or zero values used. TRC => Technical Review Criteria W WTP => wastewater treatment plant

Pretreatment Annual Report (PAR)
Industrial Data Summary Form (IDSF)
Use separate forms for each industry/pipe
Enter BDL values as < (value)
* Total # of samples =>
* Maximum (mg/1) =>
* or Maximum (lb/d) =>
* Average (mg/1) =>
* or Average Loading (lb/d) =>
%violations,(chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Maximum (ib/d) =>
* or _ Average (mg/1) =>
* or Average Loading (lb/d) =>
% violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Minimum (lb/d) =>
* or _ Average (mg/1) =>
* or Average Loading (lb/d) =>
%violations, (chronic SNC is >= 660/0 =>
% TRC violations, (SNC is >= 33 %) =>
Control Authority,
Town Name => Town of Holly Springs Industry Name
W WTP Name => Utley Creek WRP NP #
NPDES # => NCO063096
1st 6 months, dates => 1/1/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
South Wake Landfill
001
001
Nickel (ug/L)
1 st 6 months 2nd 6 months
Selenium (ug/L)
1st 6 months 2nd 6 months
Silver (ug/L)
1 st 6 months 2nd 6 months
Zinc (ug/L)
1 st 6 months 2nd 6 months
2
7
N/A
0
2
2
7
200
280
<8.00
670
870
Molybdenum u /L
1st 6 months 2nd 6 months
Total Phosphorus (mg/L)
1st 6 months 2nd 6 months
Total Nitrogen (mg/L)
1st 6 months 2nd 6 months
Oil and Grease (mg/L)
1st 6 months 2nd 6 months
1
2
27.0
27.0
27
27
1
3
45.0
63A
61.0
12.7
1,760.2
2,220.2
<5.0
<5.0
88.3
77.9
13.07
9,74
1,104.7
1,493.0
42.1
37A
MONITOR ONLY
MONITOR ONLY
pH (S.I. units)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
28
27
10.99
8.60
5.91
7.80
nc,vw uc,cuwu imur mg/1 => milligrams per liter
* POTW must enter at least one of these IUP => Industrial User Permit lb/d —� pounds per day
four rows, Please indicate how averages were calculated SNC => Significant Non -Compliance mgd => million gallons per day
Avg period could be month, Qtr, or 6-month & if BDL, 1/2BDL, or zero values used. TRC => Technical Review Criteria W WTP => wastewater treatment plant

ATTACHMENT 18
Town of Holly Springs
Utilities and Infrastructure
Water Resources
Industrial
Pretreatment Program
Industrial Self -Monitoring Permit Violation(s) Notification
Industry Name: Seqims, Inc. Date: 07-Jun-2021
Industry Representative: Nilsa M. Serrano Time: 14:04
Representative's Phone #: [phone] Permit #: IUP-002
aJ As Part II 2. bJ of this facility's Sewer Discharge Permit, If the sampling performed by the permittee indicates
a violation or the permittee has missed a required sampling event, the permittee shall notify the Town of Holly
Springs within 24 hours of becoming aware of the violation. The permittee shall also repeat the sampling and
analysis and submit the results of the repeat analysis to the Town of Holly Springs within 30 days after
becoming aware of the violation unless notified by the Town of Holly Springs that such repeat analysis is not
required. All monitoring reports are due no later than the 30th day following the sampling event.
I am submitting this notification to the Town of Holly Springs so that my facility will be in compliance with this requirement.
The discharge limits that were exceeded are detailed in the table below.
Date Sampled
Parameter
Result
Permit
Limit
Units
Date Results Received
Date Results Reviewed
11-May-2021
Chloride
2,935,2
3,800
lbs/day
Date reported read:
Date reported read:
(monthly
06/07/2021
06/07/2021
average)
2,450
(monthly
average
limit
Industry Representative's Signature:
Email Immediately to: Debra Batten
Pretreatment Coordinator
Town of Holly Springs
[e-mail]
Please
contact me immediately a! [phone] to verify This ernai! hoc been received. !flan not able to take ymn call, please leave o messnge an my voice mail. Yon wt!! be
contacted as quickly as possible to discuss the reported violation, and to determine the appropriate coarse ofaclion.
Failure to properly notify the Town of Holly Springs within 24 hours of becoming aware of a violation will result in the issuance of a Notice of Violation according to the
Enforcement Response Plan and appropriate action will be taken.

The Town of
HOLD
SPRINGS
June 25, 2021
Mrs. Nilsa M. Serrano
EHS Specialist
Seqirus — A CSL Company
475 Green Oaks Parkway
Holly Springs, NC 27540, USA
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Utilities and Infrastructure
Water Resources
Subject: Notice of Violation
Sewer Discharge Permit No. (IUP) 002
Dear: Nilsa Serrano -Ortiz
This letter serves as a Notice of Violation for failure to meet the monthly average
limit for Chloride for the Month of May 2021. As stated in IUP(Industrial User
Permit) #002 issued December 17,2019 for Seqirus the "Monthly Average Permit
Limit' requirement for Chlorides 2450 lbs./day. See IUP, Part 1, Section F for the
Effluent Limits and Monitoring Requirements. The information provided by your
contract lab of result of 2750 mg/L Chlorides, when converted to lbs./day using the
daily flow of 0.128 MGD, calculates to be 2935.2 lbs./day discharged. Your
allowed Monthly Average limit is 24501bs./day
As the permitting authority of this permit approved by the NC State DWQ, I am
required to issue this Notice of Violation within 30 days of the date of notification
or July 6, 2021. As a result of the violation Seqirus would have been required to
conduct additional sampling until return of their permitted limit for the monthly
period of May,2021. It is my understanding; the report was complete on May 20th
but was not received by your office until May 26tr'. As you were out of the office
when the report was received notification was not made to Holly Springs until your

return. As the review of the report did not occur until June Tli° the month of May
had come to an end leaving no opportunity to bring the monthly average back in
compliance.
As a result of the violation instructions were to immediately arrange for
recollection for Chloride only. Not only was the required additional sample
collected on June 8', but samples were also on June 9" and 101. The results were
823(883 lbs./day), 1870(1685 lbs./day) and 41.3 (40.6 lbs./day). These results
indicate that as of those dates, Seqirus to be in back in compliance with the
Chloride Limit. If Seqirus remains in compliance for the daily and monthly
average limits for the month of June no additional action will be required.
An internal investigation was conducted for the 24-hour period of May 10�h thru
May 11" within each operational area. Nothing was found to cause the atypical
result. The normal operational task, that could have contributed to the result, were
also reviewed. There was only one task found to have been performed. That task
occurred on May 11" involved a manufacturing line cleaning with a buffer
containing a low molarity of NaCl. However, the quantity used of the buffer when
calculated in itself would have only contributed 300 lb. of chloride and was
determined not to be cause of the exceedance.
It is the industry's responsibility to maintain compliance with all effluent limits, to
review the permit, and be aware all requirements of the permit. Seqirus made full
effort and immediately to actions necessary to return to compliance and for that the
town of Holly Springs is greatly appreciative. Once the final June DMR is
received, and it is determined there have been no additional limits violations for
Chlorides, notification will be sent stating that Seqirus has returned to full
compliance of their permit.
As Segirus creates means, to make sure all sampling requirements of the permit are
scheduled Maio 1W basis, and the sampling as scheduled as early as is possible
during the required schedule, the only recommendation going forward is to review
data as soon as it is made available. Most commercial laboratories have
availability of obtaining results online long before results would be received by
mail. Reviewing the results early enough allows for additional sampling which
could have resulted in lowering the monthly average values with in limit of
compliance before the month's end.

In addition to the Notice of Violation, as referenced in the Sewer Use Ordnance
section 16-239 and the Enforcement Response Plan of Town of Holly Springs
approved by NC DWQ, there could be a penalty assessed up to $25,000. It has
been decided that no penalty will be issued based on the following considerations:
1. Magnitude of the violation
2. Duration of the violation
3. Effects on receiving waters
4. Effects on the POTW
5. Quick response and actions taken
6. Compliance History by Seqirus for the limits of this particular pollutant of
concern.
If you do not currently have a copy of the Sewer Use Ordinance or the
Enforcement Response Plan please let me know and I will sed on to you vial email.
If you have any questions please contact me at [phone].
Si e ely,
a att
En ironmental Compliance Manager
Utilities and Infrastructure, Town of Holly Springs
Cc: Seann Byrd, Water Resources Director
Robert Resek, EHS Director

NC Department of Environmental Quality/ Division of Water Resources
Mailing:1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 North Salisbury Street, Raleigh. NC 27604
`Please check with the appropriate staff before visiting our offices, as we maybe able to handle your requests by phone or email.
We can also be avalfable via Microsoft Teams or other web -based calling services If requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Debra Batten <[e-mail]>
Sent: Friday, June 18, 20212:13 PM
To: Litzenberger, Kristin S <[e-mail]>
Subject: [External] Violation
Importance: High
CAUTION: External email, Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Kristin,
One of my industrial users has exceeded their monthly average for Chloride. The questioned the lab data and had the
analysis repeated They lab repeated the analysis and the second result was lover. Are they allowed to submit and
amended DMR with the average result of the two?
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 8 1 Holly Springs, NC 27540
Office: [phone] [ Cell: [phone]
Town Website: www.hollys»ringsnc.us
r
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).

�., D F. Q$/x
*Please check with the appropriate staff before owttng our offices, as we may be able to handle your requests by phone or email.
We can also be available via Microsoft Teams or other web -based calling services if requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Debra Batten<debra.batten(aDhollvsprinesnc.aov>
Sent: Tuesday, June 22, 2021 10:40
To: Yitbarek, Diana <diana.vitbarek(@ncdenr.gov>
Subject: RE: --[EXTERNAL]--Chlorides - Holly Springs Fw: [External] Violation
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam,
Hi Diana,
Thank you for getting back with me. There result on the 11 of May was 275011� and based on the flow provided for
that day the lbs./day calculate to be 2935 lbs./day(within the daily max, limit of 3800 lbs./day), and a monthly average
2766 lbs./day(which exceeds the monthly average limit of 2450 lbs./day.
They had the lab repeat the analysis and the repeat yielded a result of 2350 mg/L which calculates with the flow data
provided to be 2509lbs./day again within the daily max. limit of 3800 lbs./day) and the monthly average would calculate
to be 2364 lbs./day which would be within the monthly average limit of 2450 lbs./day.
I have reviewed both sets of results and the accompanying QC and the original result had excellent QC recoveries as
well as MS(101 % Recovery),MSD(101% Recovery) and %u RPD of the sample spiked with a 07b RPD. (In this case the
sample in question was the sample spiked.)
The repeat also had excellent QC and as well as MS(108% Recovery)/MSD(110 %Recovery) recoveries and a 0 %RPD on
one spiked sample.
and the other Spike in the run the MS(220% Recovery)/MSD(25 % Recovery) with. ? 7% RPD Reported)? I must add I
have done calculations on my own and I believe the lab reported there recoveries in correctly. My calculations do show
the 7% RPD but the results of MS(108% recovery) and the MSD(101 % Recovery). I have not talked with the lab and am
only using the data provided with the DMR report for my calculations. With that being said the both of the MS/MSD
analyses were analyzed using a different sample.
I in my professional opinion with the first sample being analyzed first and the excellent QC including spiked values of the
actual sample, I believe this data should in the very least be used and not left out of the equation. The repeats were
analyzed 27-28 days later and though based on my calculations of the second spike calculations are within range, I do
not have access to the actual bench sheets and the lab had the second spike of not having acceptable recovery on the
MSD of that sample. With that in mind if I go by what the lab reported I would disregard that result all together. But if I
go by MY review of the data other that is being analyzed 27-28 days later, the results would be considered good
data. There is no hold time stated for Chlorides, only that it should be analyzed as soon as is possible.
PLEASE NOTE*

I received the Monthly DMR yesterday and these values may change. It appears they used incorrect flow data to
calculate the lbs./day so I will have to verify if it was an error in the date in the foot note, or if they actually used flow
data from an incorrect date.
f you would like to discuss with your team, I will be talking with the Industry about the flow data. And we can connect
later today.
Thank you,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 8 1 Holly Springs, NC 27540
Office: [phone] [ Cell: [phone]
Town Website: www.hollyspringsnc.us
From: Yitbarek, Diana <diana.yitbarekCa)ncdenr.eov>
Sent: Tuesday, June 22, 20216:23 AM
To: Debra Batten<[e-mail]>
Subject: --[EXTERNAL]--Chlorides - Holly Springs Fw: [External] Violation
Good morning, Debra
I see Novartis has a Monthly Average (MA) limit of 2450 Ibs/day and a Daily Maximum of 3800 Ibs/day for
chlorides. What was exceedancer
I will discuss this with the team today and get back to you.
Best,
-Diana
Diana Yitbarek (she/her)
Engineer
T:919-707-9130
[e-mail]
NPDES Municipal Permitting Unit

Debra Batten
From: Debra Batten
Sent: Wednesday, June 23, 2021 2:05 PM
To: Yitbarek, Diana
Cc: Folley, Dana
Subject: RE: --[EXTERNAL]--Chlorides - Holly Springs Fw: [External] Violation
Diana,
Thank you and dana for your assistance. It is very much appreciated. Se may responses to your questions and
comments.
The first sample was taken on 5/11/2021, and the repeats were analyzed 27-28 days later. You are
right; there is no hold time stated for Chlorides.
a. To clarify: When was the repeat sample taken? The second result was the same sample
just analyzed on a later date. Or the SIU took a sample and had it analyzed, then the SIU
asked their lab to run it again? There was not a second sample taken to the lab, the analysis
was repeated on the same sample the first result was analyzed on.
EPA guidance says that it is ok to average the values as long as they are taken within the same Z4
hr.-sampling period for a daily maximum calculation and within the same calendar month for the
monthly average calculation (40 CFR 5 122.2).
i. Any results that are run on the same physical sample that are deemed valid are
averaged together to calculate one result that is them used for
compliance judgement. I believe this answers my question.
ii. I did not see any language in the IUP regarding averaging results. Please double-
check to make sure that there is not language against it.
iii. Dana, included here, suggested to see questions 9-10 of the memo PAR Workshop
Questions. Discussion and Addendum (January 2012).
2. I understand that you have concerns about the 5/11/2021 sample spiked, and I could not follow
what happened to the second sample. If you believe the lab reported incorrectly. Please follow up
with the lab. This was only a concern of the repeat analysis bat as it was not the actual sample that
was used for the MS an MSD and there was a second ME/MSD in the sample analysis batch, I will
not exclude the data and an average of the results will be used for compliance judgement.
From: Yitbarek, Diana <[e-mail]>
Sent: Wednesday, June 23, 2021 1:18 PM
To: Debra Batten <[e-mail]>
Cc: Folley, Dana <[e-mail]>
Subject: --[EXTERNAL]--Chlorides - Holly Springs Fw: [External] Violation
Hi Debra,
Thank you for the information provided.
1. The first sample was taken on 5/11/2021, and the repeats were analyzed 27-28 days later. You are
right; there is no hold time stated for Chlorides.

a. To clarify: When was the repeat sample taken? The second result was the same sample
just analyzed on a later date. Or the SIU took a sample and had it analyzed, then the SIU
asked their lab to run it again? There was not a second sample taken to the lab, the analysis
was repeated on the same sample the first result was analyzed on.
EPA guidance says that it is ok to average the values as long as they are taken within the same 24
hr.-sampling period for a daily maximum calculation and within the same calendar month for the
monthly average calculation (40 CFR 5 122.2).
i. Any results that are run on the same physical sample that are deemed valid are
averaged together to calculate one result that is them used for
compliance judgement. I believe this answers my question.
ii. I did not see any language in the IUP regarding averaging results. Please double-
check to make sure that there is not language against it.
iii. Dana, included here, suggested to see questions 9-10 of the memo PAR Workshop
Questions Discussion and Addendum (January 20121.
2. I understand that you have concerns about the S/11/2021 sample spiked, and I could not follow
what happened to the second sample. If you believe the lab reported incorrectly. Please follow up
with the lab. This was only a concern of the repeat analysis bat as it was not the actual sample that
was used for the MS an MSD and there was a second ME/MSD in the sample analysis batch, I will
not exclude the data and an average of the results will be used for compliance judgement.
Please let us know if you have any questions,
Best,
-Diana
Diana Yitbarek (she/her)
Engineer
T:919-707-9130
d i a n a.vitbarek@ ncden r.eov
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing:1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 North Salisbury Street, Raleigh, NC 27604

Debra Batten
ATTACHMENT 19
From: [e-mail]
Sent: Monday, August 2, 2021 3:24 PM
To: Debra Batten
Cc: [e-mail]; [e-mail]
Subject: --[EXTERNAL]--RE: Sampling
Hi Ms. Debra,
Thanks for letting us know. August Sampling is schedule to start on next Monday from the 9`h to the 12`h. the 9`h is only
to start the machine.
This is my last week with Seqirus. Moving forward you can contact Ellen Lorusso or Robert Rezek for any need.
Here Ellen information:
Phone: [phone]
Email: Ellen. LorussoCa)cslbeh ri ng.co m
Have a great afternoon,
Nilsa
From: Debra Batten <[e-mail]>
Sent: Monday, August 2, 20213:08 PM
To: Serrano -Ortiz, Nilsa US/HSP <[e-mail]>
Subject: [EXT] Sampling
Importance: High
EXTERNAL: This email originated from outside of the organization. Do not click any links or open any attachments
unless you trust the sender and know the content is safe.
Nilsa,
any
share with me your sampling schedule for this month? I would like to set up for semiannual testing this month.
Regards,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 81Holly Springs, NC 27540
Office: [phone] 1 Cell: [phone] 1
Town Website: hollvspingsnc.gov
1

Town of Holly Springs
emails are switching to
.gov addresses.
Please make
sure to update my contact
information to [e-mail]
before Jan.
31, 2022,
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
This email, including any attachments, is confidential and contains proprietary content and may be legally privileged. This
transmission is intended only for the designated recipient(s), and any duplication or distribution, in any form or part, without the
written consent of the sender is strictly prohibited. Any confidentiality or privilege is not waived or lost if this email has been sent
to you by mistake, in which case you should not read, copy, adapt, use or disclose this message. If you've received this email by
mistake, please delete the message, disregard its contents and notify the sender of the mistake. Any personal information in this
email must be handled in accordance with applicable privacy laws.

Debra Batten
From: Debra Batten
Sent: Monday, August 2, 2021 3:33 PM
To: [e-mail]
Cc: [e-mail]; [e-mail]
Subject: RE: --[EXTERNAL]--RE: Sampling
Ms. Lorusso,
Welcome to
your new
position with Seqirus.
I look forward to working with
you in your
new
roll. I
look forward to
meeting you.
If there
is ever anything I can
assis you with please feel fee to
contact me.
And
Again
welcome.
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 811-1olly Springs, NC 27540
Office: [phone] [ Cell: [phone]
Town Website: hollvspingsnc.gov
Town of Holly
Springs
emails are switching to
.gov addresses.
Please make
sure to update my contact
information to
[e-mail]
before Jan.
31, 2022.
From: [e-mail] <[e-mail]>
Sent: Monday, August 2, 2021 3:27 PM
To: Debra Batten <[e-mail]>
Cc: [e-mail]; [e-mail]
Subject: RE: --[EXTERNAL]--RE: Sampling
Hi Ms. Debra.
The primary contact will be Ellen.
Nilsa
From: Debra Batten <[e-mail]>
Sent: Monday, August 2, 20213:25 PM
To: Serrano -Ortiz, Nilsa US/HSP <[e-mail]>
Cc: Rezek, Robert US/HSP <Bob.Rezek(@Seairus.com>; Lorusso, Ellen US/KOP <[e-mail]>
Subject: [EXT] RE: --[EXTERNAL]--RE: Sampling
EXTERNAL: This email originated from outside of the organization. Do not click any links or open any attachments
unless you trust the sender and know the content is safe.
t

Mr. Resek will be the primary contact?
From: [e-mail]<[e-mail]>
Sent: Monday, August 2, 20213:24 PM
To: Debra Batten <debra, batten @hollysprinesnc.¢ov>
Cc: Bob.Rezek@Segirus,com; EIIen.Lorusso@cslbehring,com
Subject: --[EXTERNAL]--RE: Sampling
Hi Ms. Debra,
Thanks
for
letting us know. August
Sampling is schedule
to start on next Monday from the 9`h to the 12`". the 9`^ is only
to start
the
machine.
This is my last week with Seqirus. Moving forward you can contact Ellen Lorusso or Robert Rezek for any need.
Here Ellen information:
Phone: [phone]
Email: [e-mail]
Have a great afternoon,
Nilsa
From: Debra Batten <[e-mail]>
Sent: Monday, August 2, 2021 3:08 PM
To: Serrano -Ortiz, Nilsa US/HSP <[e-mail]>
Subject: [EXT] Sampling
Importance: High
EXTERNAL: This email originated from outside of the organization. Do not click any links or open any attachments
unless you trust the sender and know the content is safe.
Nilsa,
Can you share with me your sampling schedule for this month? I would like to set up for semiannual testing this month.
Regards,
Debra Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 81Holly Springs, NC 27540
Office: [phone] [ Cell: [phone]
Town Website: hollvspingsnc.gov

Town of Holly Springs emails are switching to .gov addresses. Please make sure to update my contact
information to [e-mail] before Jan. 31, 2022.
Warning: This email is subject to disclosure under the or Carolina Public Records Law (NCGS 132-1).
This email, including any attachments, is confidential and contains proprietary content and maybe legally privileged. This
transmission is intended only for the designated recipient(s), and any duplication or distribution, in any form or part, without the
written consent of the sender is strictly prohibited. Any confidentiality or privilege is not waived or lost if this email has been sent
to you by mistake, in which case you should not read, copy, adapt, use or disclose this message. If you've received this email by
mistake, please delete the message, disregard its contents and notify the sender of the mistake. Any personal information in this
email must be handled in accordance with applicable privacy laws.
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).

ATTACHMENT 20
e
Town of Holly Springs
kkk
Water Resources
Environmental Compliance
SIU Inspection Form
Name of Industry:
Address of Industry: 475 Green Oaks Parkway IUP Expiration date: 12/31/2022
Industry Representatives: Ellen LoRusso Title: Senior EHS Specialist
Robert Rezek Title: EHS Director
POTW Representatives: Debra, H. Batten Title: Env. Comp. Mgr.
Easton Rains Title: Lab Analyst (12/30/2021)
Date Of Inspection: 12/28/2021 Time Of Inspection: 10:00 am/pm
Purpose of Inspection: Annual x Other (Describe) FOG 12/30/202110:27
POTW to which IU discharges Town of Holly Springs NPDES # 0063096
Is SIU currently in SNC? If yes, for what?
* Inspection ended at pm on
• PART I = INITIAL INTERVIEW
Has anything changed since the last inspection or IUP application in the following:
COMMENTS
Product: YES / NO Flu vaccine (MF59, Flucelvax, Gluad, HHS Monobulks)
Raw materials used YES / NO Phosphate buffer/ Saline buffers, Nitrogen based
growth media, Assay Reagents, Infectious (influenza) Cultures, Cell Cultures and
Cleaning agents
Manufacturing processes Categorical, if applicable: YES / NO 439.17 & 439.47
Production Rate/ Flow Increase: Yes / No There was an increase in production rate
from 4.6 batches per week in 2020 to 5.3 batches in 2021. A comparison in annual
DMRs shows an increase in average daily flow rate from month to month.
Number of employees: YES / NO There are currently 750 employees.
Tile: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020 Page 1

a�
Town of Holly Springs
„i Water Resources
Environmental Compliance
Number
of Shifts:
There
are 4
crews working
12-hour
shifts
each.
Two shifts
on and
two shifts
off. Pilot
Plant and
administrative is first shift
only.
PART II - PLANT TOUR -
Plant Tour Section A - PRODUCTION AND STORAGE AREAS
1. Are there floor drains in the production area? YES / NO Where do they go? All production
waste (Infectious) goes through Thermal Deactivation. (Non- Infectious and Formulated Fill/Finish
waste streams) pass through the Equalization tank and the pH ad'lustment tank prior to effluent
discharge. Large discharge events are recorded and validated by EHS via Discharge Approval Request
Forms,
2. Are production areas diked, contained, or otherwise constructed in such a way as to prevent harm
to the WWTP, especially from spills or slugs? YES/NO Comments: All drains in the production area
are closed and/or protected from spills with either containment or berms. In the event of a spill,
employees know to call security who activates the spill plan.
3. Are there floor drains in the storage area? YES/NO Where do they go? All areas with wet
chemicals are contained with dikes, and berms. Chemical storage areas also have containment pits
available to collect any spill that may occur, at which time Triumvirate Environmental would be
contacted to collect the material as waste and decontaminate the area.
4. Are storage tanks and areas diked, contained, or otherwise constructed in such a way as to prevent
harm to the WWTP, especially from spills or slugs? YES/NO Comments:
5. Are process and storage tanks and pipes labeled? YES / NO
6. How are off -spec raw materials, and products disposed of? Disposed of by Triumvirate
Environmental,
7. When is the production area cleaned? Daily by staff and floors cleaned by contractors weekly. A
cleaning schedule and cleaning SOP was made available for review.
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020 Page 2

"�� �. Town of Holly Springs
�� Water Resources
Environmental Compliance
8. Is the wastewater from cleaning the production area discharged to the POTW? YES/NO
The wastewater discharge from cleaning procedures goes through the treatment system prior to
release to the WWTP.
9. What non -process wastewaters are discharged to POTW? Bailer Blowdown. Lab sinks, Water
treatment Chemicals, Cooling Tower blowdown Cafeteria (after passing through grease interceptor)
The "Pilot Plant", waste after passing through pH adjustment tank also is discharged to the POTW
PART II - Plant Tour Section B - PRETREATMENT SYSTEM
Ask the operator to describe pretreatment system.
1. Does operator seem knowledgeable about the system? YES / NO
Comments:
2. Are all units operational? YES / NO
3. How often does operator/maintenance person check system? Visual Inspections are completed
daily and calibration events are conducted quarterly. Equipment Maintenance and Calibration Records
are stored electronically in the SAP system and all work orders recorded for the last year will be
prepared in anticipation of this inspection
4. Is there an operator for each shift? YES / NO comments: Staffed 24-7
5. How and when is sludge disposed of? N/A
6. Is there a schedule for preventative maintenance? YES / NO
Comments: PM Schedule is maintained electronically in SAP see note above
PART II - Plant Tour Section C - SAMPLING POINT(S) AND FLOW MEASUREMENT
Title: SIU Inspection Form
File name; COMP.INSP
Revision date: October 2, 2020 Page 3

�(
Town of Holly Springs
ko� } Water Resources
% Environmental Compliance
1. Does an outside
lab complete sampling?
YES / NO If yes, name Of
Lab: Pace Analytical
Labs
completes monthly
sampling events these are conducted in conjunction
with
TOHS sampling
events
every 6 months as possible
but data from split
samples is not used
for compliance
monitorig.
2. If industry completes sampling, ask the industry representative to describe sampling procedures.
Comments: N/A
3. Is flow measurement equipment operational? YES / NO Comments: Flow data was available for
review during inspection
4. Is there a calibration log for the flow meter? YES / NO Comments: Stored in SAP Copy of
calibration record was available for review during inspection.
PART III - EXIT INTERVIEW
Review monitoring records and other SIU records required by IUP.
1. Are files well organized? YES / NO Comments:
2. Are sample collection / chain -of -custody forms filled out properly? YES/NO Comments: Sent
with DMRs
3. Do results in files agree with reports sent to POTW? YES / NO Comments:
4. Who has authority to shut down production should a spill or slug discharge occur? All operators are
trained to stop discharge flow and contact security in the event of a spill or slug discharge. There is a
written spill plan procedure that is followed for these events.
S. How does SIU inform employees of whom to call at POTW in case of spill/slug? Signage is posted
throughout the plant that references internal spill procedures Every spill kit is equipped with a quick
reference guide to spill procedures Spill response training is conducted at the time of hire and
refreshed annually.
(If
slug/spill
plan is already required
by POTW, review procedures).
A slug/spill
plan
is maintained
by
the
SIU and is reviewed annually and
updated whenever changes are
needed.
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020 Page 4

Town of Holly Springs
Water Resources
Environmental Compliance
6. Is SIU implementing slug/spill plan? YES / NO
Comments:
INSPECTION RESULTS
Slug/Spill Control Plan Needed? YES/NO
Comments, Required or Recommended Actions:
Inspectors)
Title: SIU Inspection Form
File name: COMP.INSP
Date: % -v
Date: %2 30 21
Revision date: October 2, 2020 Page 5

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Industry Name:
segrius
IUP #/Pipe #
002
Reporting
1/1/2021
Period:
6/30/2021
Detection Level
(DL) entered
112 Detection X
Level(DL) entered
Sample Type -
Sample Date P=POTW, I -
Industry
ATTACHMENT 22
Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
pecific changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detection level or 112 detection level and mark choice in cell B5.
Vote use second option only when detection level at or below limit)
IOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
=low: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
Chronic or TRC SNC
•
Daily Flow violation Type
MGD
Permit Limit 0.250
TRC Limit 0.300 Optional*
Req TRC
1/1212021
I
0.096000
1 /13/2021
I
0.071000
2110/2021
1
0.091000
2111 /2021
1
0.094000
2/12/2021
1
0.116000
3/9/2021
1
0.121000
3/10/2021
1
0.124000
3/11 /2021
1
0.101000
4/13/2021
1
0.102000
4/14/2021
1
0.134000
4/15/2021
1
0.126000
5/11/2021
1
0.106000
6/12/2021
1
0.117000
5/13/2021
1
0.135000
6/8/2021
P
0.111000
6/9/2021
1
0.122000
6/10/2021
1
0.115000
6/15/2021
1
0.124000
6/16/2021
I
1
E0.1250006/17/2021
erage of Column
Total Samples
20
Violations
0.0
TRC Violation<.
0.0
Daily
Concentration violation Type
Mg/L
2,033
2,440
Reg TRC
192.0
104.0
159.0
209.0
496.0
193.0
319.0
266.0
418.0
1010.0
43.2
346.0
796.0
513.0
332.4
872.0
680.0
1270.0
456.6
Violations
0.0
TRC Violations
0.0
Daily
Concentration violation Type
Mg/L
0
0
Reg TRC
Violations 0.0
TRC Violations 0.0
7RIr'
Daily
Concentration violation Type
Mg/L
3,800
4,560
Reg TRC
Violations 11.0
TRC Violations 0.0
'SNC ? NO
SNC? NO
SNC ? NO
k L:,n3,,s

`Chloride limit is 2450 lbs/da

1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
specific changes, an then reinstate protection again.
2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5.
(Note use second option only when detection level at or below limit)
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
"Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
"`oH: TRC (>=33%) SNC definition specifically exempts pH.
""TRC doesn't a I t H
M
Violation Type
10.000
Reg TRC
7.60
7.90
7.60
7.10
7.90
8.10
7.90
8.20
8.20
7.60
7.40
8.30
7.80
7.80
7.81
8.30
7.50
7.60
7.90
7.40
7.80
20 0
Violations 0.0
°-fe-TR6-Vielatiea3s
Daily
Concentration Violation Type
Mg/L
0
0
Reg TRC
7 0 0
Violations 0.0
TRC Violations 0.0
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
Violations
0.0
TRC
Violations
0.0
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
Violations
0.0
TRC
Violations
0.0
1) Data entry in blue bordered cells
specific changes, an then reinstate
2) For data reported as "Below Deb
(Note use second option only when
NOTE - Spreadsheet corrected Fat
`Flow: Chronic (>=66%) and TRC (:
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
Violations
0.0
TRC
Violations
0.0
SNC? SNC? NO SNC? NO
SNC? NO
SNC? NO

y. When calculated based on flow is 2935.2 Ibs/day

only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
protection again.
action" choose either to enter detection level or 1/2 detection level and mark choice in cell B6.
detection level at or below limit)
09 to properly assess TRC violations using "equal to or greater than".
>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
Violations
0.0
%TRC
Violations
0.0
Daily
Concentration Violation Type
Mg/L
Reg TRC
Violations
%TRC Violations
Daily
Concentration Violation Type
Mg/L
Rep TRC
°/
Violations
0.0
TRC
Violations
0.0
Data entry in blue bordered cells only. All other cells protected. Pass
pecific changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detect
Jote use second option only when detection level at or below limit)
TOTE - Spreadsheet corrected Feb 09 to properly assess TRC violatio
=low: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "F
TRC (>=33%) SNC definition specifically exemots oH.
Daily
Concentration Violation Type
Mg L
Reg TRC
Violations
0.0
%TRC
Violations
0.0
• :•
Daily
Concentration Violation Type
Mg/L
Rep TRC
Violations
TRC Violations
SNC ? NO SNC ? NO
SNC ?
SNC ? NO
SNC ?

sword 3. Strongly Recommend only unprotect to make
on level or 1/2 detection level and mark choice in cell B6.
ns using "equal to or greater than"
pollutant," so technically not required to apply to flow.
Violations
0.0
%TRC
Violations
0.0
�HFNC
Daily
Concentration Violation Type
Mg/L
Reg TRC
Violations
%TRC Violations
Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only
ecific changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detection level or 112 detection level and r
ote use second option only when detection level at or below limit)
)TE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
ow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not requirec
TRC (>=33%) SNC definition specifically exempts pH.
Daily
Concentration Viola7Type
Mg/L
Rea TRC
%Violations
0.0
%TRC
Violations
0.0
Daily
Concentration Violation Type
Mg/L
Reg TRC
2 0 0
Violations 0.0
TRC Violations 0.0
Daily
Concentration Violation Type
Mg/L
Reg TRC
%Violations
0.0
TRC
Violations
0.0
SNC? NO SNC? SNC? NO
SNC? NO
SNC ? NO

Industry Name Seqrius 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
UP #/Pipe * 002 speck changes, an then reinstate protection again.
Reporting 7/1/2021 2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5.
Period 1Z31/2021 (Note use second option only when detection level at or below limit)
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
Detection Level *Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
(DL) entered "pH:
Le TRC (>=33% SNC definition specifically exempts H.
Detection X
Level (DL) entered Chronic or TRC SNC
=rVlolaton
Sample Type-
P=POTW, I-
Industry
Permit Limit 0.250
TRC Limit 0.300 Optional'
Rr+n TRr.
L
7/7/2021
I
0.103000
7/8/2021
1
0.105000
7/9/2021
1
0.111000
7/14/2021
1
0.111000
8/10/2021
1
0,135000
8/11 /2021
1
0.113000
8/12/2021
1
0.130000
8/25/2021
P
0.108000
9/8/2021
I
1
0.111000
9/9/2021
1
0.099000
9/10/2021
1
0.088000
10/5/2021
1
0.074000
10/6/2021
1
0.120000
10/7/2021
1
0.105000
11/9/2021
1
0.043000
11 /10/2021
1
0.054000
12/7/2021
1
0.052000
12/8/2021
i
0.062000
,verage of Column
r 0.095778
l oral samples
Violations 0.0
TRC Violation: 0.0
'SNC ? NO
3�r
Daily
Concentration Violation Type
Mg/L
2,033
2,440
Reg TRC
728.0
898.0
80.5
224.0
837.0
873.0
727.0
410.0
335.0
208.0
258.0
335.0
1720.0
612.0
12.0
0.0
11.0
486.4
7Daily Violation Type
0
Rep TRC
Violations
0.0
%
°/
Violations
0.0
TRC Violations
0.0
%
%TRC
Violations
0.0
SNC? NO
SNC? NO
Daily
Concentration Violation Type
Mg/L
3,800
4,560
Reg TRC
7 0 0
%Violations 0.0
TRC Violations 0.0 %
SNC ? NO

Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unpro= to make
pecific changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5.
Vote use second option only when detection level at or below limit)
IOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
"nH- TRC (>=33%1 SING definition specifically exempts PH.
"TRC doesn't a I t H
Daily
Concentration Violation Type
Mg/L
10.000
Reg TRC
7.60
7.30
6.90
7.20
8.30
7.40
7.80
7.97
7.60
8.50
7.20
7.00
720
8.60
7.03
6.95
6.40
6.80
7.43
Daily
Concentration Volation Type
Mg/L
0
Reg TRC
Violations
Daily
Concentration Volation Type
Mg/L
Reg TRC
%Violations
TRC Violations
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
%Violations 0.0
%TRC Violations 0.0
Data entry in blue bordered cells
ecific changes, an then reinstate
For data reported as "Below Deb
ote use second option only when
)TE -Spreadsheet corrected Fet
ow: Chronic (>=66%) and TRC (
WIL
.O
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
%Violations
Data entry in blue bordered cells
ecific changes, an then reinstate
For data reported as "Below Deb
ote use second option only when
)TE -Spreadsheet corrected Fet
ow: Chronic (>=66%) and TRC (
WIL
.O
Daily
Concentration Violation Type
Mg/L
0
Reg TRC
%Violations
0.0
TRC
Violations
0.0
SNC? SNC? NO SNC? SNC? NO
SNC? NO

only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
protection again.
action" choose either to enter detection level or 1/2 detection level and mark choice in cell B5.
detection level at or below limit)
109 to properly assess TRC violations using "equal to or greater than".
>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow.
%Violations
0.0
%TRC
Violations
0.0
Violations
TRC Violations
Daily
Concentration Violation Type
Mg/L
Reg TRC
%Violations
0.0
%TRC
Violations
0.0
Data entry in blue bordered cells only. All other cells protected. Pass
eciflc changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detect
ote use second option only when detection level at or below limit)
)TE - Spreadsheet corrected Feb 09 to properly assess TRC violatio
low: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "F
Daily
Concentration Violation Type
Mg/L
Reg TRC
Violations
0.0
%TRC
Violations
0.0
Daily
Concentration Violation Type
Mg/L
Reg TRC
Violations
TRC Violations
SNC? NO SNC ? SNC ? NO
SNC ? NO
SNC ?

:word 3. Strongly Recommend only unprotect to make
on level or 1/2 detection level and mark choice in cell B5.
ns using "equal to or greater than".
pollutant," so technically not required to apply to flow.
Daily
Concentration Volation Type
Mntr
Rea TRC
Violations
0.0
%TRC
Violations
0.0
THEN(
Daily
Concentration Volation Type
Mg/L
Reg TRC
Violations
TRC Violations
Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only
pecific changes, an then reinstate protection again.
For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and r
Vote use second option only when detection level at or below limit)
TOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than'.
=low: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not requires
Daily
Concentration Volation Type
Mg/L
Reg TRC
Daily
Concentration Violation Type
Mg/L
Reg TRC
0 0 0 0 0 0
%Violations % %Violations
%TRC Violations % %TRC Violations
Daily
Concentration Volation Type
Mg/L
Rep TRC
%Violations
0.0
TRC
Violations
0.0
SNC? NO SNC? SNC?
SNC ?
SNC ? NO

Pretreatment Annual Report (PAR)
Industrial Data Summary Form (IDSF)
Use separate forms for each industry/pipe
Enter BDL values as < (value)
* Total # of samples =>
* Maximum (mg/1) =>
* or Maximum (lb/d) =>
* Average (mg/1) =>
* or Average Loading (lb/d) =>
% violations,(chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Maximum (lb/d) =>
* or _ Average (mg/1) =>
* or Average Loading (lb/d) =>
%violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Maximum (lb/d) =>
* or. Average (mg/1) =>
* or Average Loading (lb/d) =>
%violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
Control Authority,
Town Name => Town of Holly Springs
W W TP Name => Utley Creek WRF
NPDES # => NCO063096
1st 6 months, dates => 1/l/2021 6/30/2021
2nd 6 months, dates => 7/l/2021 12/31/2021
ATTACHMENT 23
Industry Name Seginw
[UP # 002
Pipe # -�� 00 )
Flow, mgd
BOD (mg/L)
TSS (mg/L)
Ammonia (mg/L)
1 st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
181
183
18
17
7
7
7
7
0.157000
0,139000
11270
12720
36.2
17.3
6.8
3.9
1,300.9
19834.7
0,103746
0.075295
456.6
486A
18.9
10.0
3.210
1.890
450.5
439.2
MONITOR ONLY
Arsenic qLur,,Ly
admium (ug/L)
Chromium (ug/L)
Chlorides (mg/L)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
2
0
2
1
2
1
9
7
<10.0
<1.000
<0.200
7.6
9.4
2550
464
25721.7
426.4
737
203
722.9
162.8
MONITOR ONLY
Copper (ug/L)
BDL =>
Cyanide (mg/L)
Lead (ug/L)
Mercury
1 st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
I st 6 months
2nd 6 months
2
1
2
2
2
1
7
6
11.0
9.1
<0.0100
<0.0080
<5.0
<5.0
200.0
36.0
38.5
8.6
MONITOR ONLY
tsetow Detection Detection mgil => milligrams per liter
* POTW must enter at least one of these IUP=> Industrial User Permit Ib/d => pounds per day
four rows, Please indicate how averages were calculated SNC => Significant Non -Compliance mgd => million gallons per day
Avg period could be month, Qtr, or 6-month & if BDL, 1/2BDL, or zero values used. TRC y Technical Review Criteria W WTP y wastewater treatment plant

Pretreatment Annual Report (PAR)
Industrial Data Summary Form (IDSF)
Use separate forms for each industry/pipe
Enter BDL values as < (value)
* Total # of samples =>
* Maximum (mg/1) =>
* or Maximum (lb/d) =>
* Average (mg/1) =>
* or Average Loading (lb/d) =>
% violations,(chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Maximum (Ib/d) =>
* or Average (mg/1) =>
* or Average Loading Ob/d) _>
% violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Maximum (lb/d) =>
* or Average (mg/1) =>
* or Average Loading (lb/d) =>
%violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
Control Authority,
Town Name => Town of Holly Springs
W TP Name => Utley Creek WRF
NPDES # => NCO063096
1st 6 months, dates => 1/l/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
Indus
:..
Nickel (ug/L)
Selenium (ug/L)
Silver (ug/L)
Zinc (ug/L)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
2
1
2
0
2
0
2
1
<5.0
6.7
<10.0
<5.0
10.7
13.8
MONITOR ONLY
Total Nitro en m
Total Phosphorus (mg/L)
pH (s.u)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
7
7
7
7
20
18
38
35
8,30
8,60
24.4
28.2
7.10
6.40
22,66
16.03
12.7
14.9
MONITOR ONLY
Benzene (ug/L)
Chlorobenzene (ug/L)
Chloroform (ug/L)
1,2 Dichloroethane
1 st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
1 at 6 months
2nd 6 months
1 at 6 months
2nd 6 months
2
1
2
1
2
1
2
1
<5.0
<40.0
<10.0
<80.0
<10.0
<20.0
<5.0
<80.0
<5.7
<20.0
BllL —� Below Detection Limit mgR => milligrams per liter
* POTW must enter at least one of these RJP => Industrial User Permit Ib/d => pounds per day
four rows, Please indicate how averages were calculated SNC => Significant Non -Compliance mgd => million gallons per day
Avg period could be month, Qtr, or 6-month & if BDL, 1/2BDL, or zero values used. TRC y Technical Review Criteria W W'IP => wastewater treatment plant

Pretreatment Annual Report (PAR)
Industrial Data Summary Form (IDSF)
Use separate forms for each industry/pipe
Enter BDL values as < (value)
* Total # of samples =>
* Maximum (mg/1) =>
* or Maximum (lb/d) =>
* Average (mg/1) =>
* or Average Loading (lb/d) =>
% violations,(chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Maximum (lb/d) =>
* or Average (mg/1) =>
* or Average Loading (lb/d) =>
% violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is x 33 %) =>
* Total # of samples =>
* Maximum (ug/1) =>
* or Maximum (lb/d) =>
* or. Average (mg/1) =>
* or Average Loading (Ib/d) _>
%violations, (chronic SNC is >= 66%) _>
%TRC violations, (SNC is>=33 %)=>
Control Authority,
Town Name => Town of Holly Springs Industry Name
W WTP Name => Utley Creek WRF IUP #
INPDES # => NC0063096
1st 6 months, dates => 1/1/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
Seqirus
002
Methylene Chloride (ug/L)
Toluene (ug/L)
Acetone (ug/L)
Xylene ug/L)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
2
1
2
1
2
1
2
1
<10.0
<80.0
<5.0
<40.0
3,480.0
6,710.0
<100.0
<120.0
a-Methyl-2-pentanone (ug/L)
Isobutyralhyde (ug/L)
n-Amyl acetate (ug/L)
n-Butyl acetate (ug/L)
1 at 6 months
2nd 6 months
1st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1
0
1
0
1
0
1
0
<50.0
<50.0
<50.0
<25.0
MONITOR ONLY
Ethyl acetate (ug/L)
Isopropyl acetate (ug/L)
Methyl formate (ug/L)
Isopropyl ether (ug/L)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
2
1
1
0
1
0
1
0
<500.0
<45000.0
<50.0
<500.0
<25.0
MONITOR ONLY
iSUL=> isetow ue[ecnon Lmu[ mg/1 => milligrams per liter
* POTW must enter at least one of these IUP => Industrial User Permit Ib/d => pounds per day
four rows, Please indicate how averages were calculated SNC y Sigaificant Non -Compliance mgd => million gallons per day
Avg period could be month, Qtr, or 6-month & if BDL , 1/2BDL, or zero values used. TRC => Technical Review Criteria W WTP => wastewater treatment plant

Pretreatment Annual Report (PAR)
Industrial Data Summary Form (IDSF)
Use separate forms for each industry/pipe
Enter BDL values as < (value)
* Total # of samples
=>
* Maximum (mg/1)
_>
* or Maximum (lb/d)
_>
* Average (mg/1)
_>
* or Average Loading (lb/d)
_>
% violations,(chronic SNC is >= 66%)
_>
%TRC violations, (SNC is >= 33 %)
_>
* Total # of samples =>
* Maximum (ug/1) _>
* or Maximum (lb/d) _>
* or Average (mg/1) _>
* or Average Loading (lb/d) _>
%violations, (chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) _>
* Total # of samples =>
* Maximum (ug/1) _>
* or Maximum (lb/d) _>
* or _ Average (mg/1) _>
* or Average Loading (lb/d) _>
% violations, (chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) _>
Control Authority,
T4own Name => Town of Holly Springs Industry Name Se rus
W W TP Name => Utley Creek WRF IUP # 002
INPDES # _> NCO063096
1st 6 months, dates => 1/1/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
Tetrahydrofuran (ug/L)
Heptane (ug/L)
Hexane (ug/L)
Di
o-chlorobenzene (ug/L)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
2
1
1
0
1
0
1
0
<250.0
<2,000.0
<50.0
<50.0
<5.0
MONITOR ONLY
Dieth 1 amine (ug/L)
Triethyl amine (ug/L)
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1st 6 months
2nd 6 months
1
0
1
0
<50,000.0
<50,000
MONITOR ONLY
1 st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
1 st 6 months
2nd 6 months
1st 6 months
2nd 6 months
uuL —� rsetow DetectionLimit mg/1 —� milligrams per liter
* POTW must enter at least one of these IDP => Industrial User Permit 16/d => pounds per day
four rows, Please indicate how averages were calculated SNC => Significant Non -Compliance mgd y million gallons per day
Avg period could be month, Qtr, or &month & if BDL, 1/2BDL, or zero values used. TRC => Technical Review Criteria W WTP => wastewater treatment plant

ATTACHMENT 24
Town of Holly Springs
Water Resources
Environmental Compliance
SIU Inspection Form
Name of Industry: Triangle Truck Wash
Address of Industry: 104 Thomas Mill Rd. IUP Expiration date: N/A
Industry Representatives: Morris Purdy Title: President
Brandon Creech Title: General Manager
POTW Representatives: Debra, H. Batten Title: Env. Comp. Mgr.
Brendan Reeser Title: Reclaim Coor./FOG Mgr.
Date of Inspection: 08/25/2021 Time of Inspection: 3:45 am/pm
Purpose of Inspection: Annual X Other (Describe) FOG
POTW to which IU discharges Town of Holly Springs NPDES # 0063096
Is SIU currently in SNC? If yes, for what?
PART I -INITIAL INTERVIEW
Has anything changed since the last inspection or IUP application in the following:
COMMENTS
Product: YES / NO Truck/Tanker Wash for food grade products.(Interior and Exterior)
Raw materials used YES/NO Alkaline —Tank wash cleaner and Alkaline all-purpose
Manufacturing processes Categorical, if applicable: YES/ NO
Production Rate/ Flow Increase: Yes / No
Number of employees: YES / NO There are currently 4 employees.
Number of Shifts: There is one working 8- 10-hour shift.
PART II - PLANT TOUR -
Plant Tour Section A - PRODUCTION AND STORAGE AREAS
Title: SIU Inspection Form
Filename: COMP.INSP
Revision date: October 2, 2020 Page 1

e6% Town of Holly Springs
Water Resources
Environmental Compliance
1. Are
there
floor drains in the
production area
YES/ NO
Where dO they
go? All go through the
cooling
tank
then to the sanitary
Sewer.
2.
Are
production areas
diked, contained, or
otherwise
constructed in such a way as to prevent harm
to
the
WWTP, especially
from spills or slugs?
YES/NO
Comments:
3. Are there floor drains in the storage area? YES/NO
4. Are storage tanks and areas diked, contained, or otherwise constructed in such a way as to prevent
harm to the WWTP, especially from spills or slugs? YES/NO Comments:
S. Are process and storage tanks and pipes labeled? YES / NO Recommended labeling of lines
6. How are off -spec raw materials, and products disposed of? Valley Proteins Fayetteville NC 919-483-
0473
7. When is the production area cleaned? Daily
8. Is the wastewater from cleaning the production area discharged to the POTW? YES / NO
The wastewater discharge from cleaning procedures goes through the oil water separator prior to
discharge.
9. What non -process wastewaters are discharged to POTW? Boiler Blowdown. Water treatment
Chemicals(Alkaline), Cooling tower blowdown, discharge from oil and water separator.
PART II - Plant Tour Section B - PRETREATMENT SYSTEM
Ask the operator to describe pretreatment system.
1. Does operator seem knowledgeable about the system? YES / NO
Comments:
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020 Page 2

Town of Holly Springs
Water Resources
Environmental Compliance
2. Are all units operational? YES / NO
3. How often does operator/maintenance person check system? Visual Inspections are completed
daily
4. Is there an operator for each shift? YES / NO
5. How and when is sludge disposed of? N/A
6. Is there a schedule for preventative maintenance? YES / NO
Comments: PM Schedule is maintained electronically in SAP, see note above.
PART II = Plant Tour Section C - SAMPLING POINT(S) AND FLOW MEASUREMENT
1. Does an outside lab complete sampling? YES / NO If yes, name of Lab: Pace Analytical Labs
completes monthly sampling events these are conducted in conjunction with TOHS sampling events
every 6 months as possible but data from split samples is not used for compliance monitoring
2. If industry completes sampling, ask the industry representative to describe sampling procedures.
Comments: N/A
3. Is flow measurement equipment operational? YES / NO Comments: Flow data was available for
review during inspection
4. Is there a calibration log for the flow meter? YES/NO Comments: Stored in SAP Copy of
calibration record was available for review during inspection.
PART III -EXIT INTERVIEW
Review monitoring records and other SIU records required by IUP.
1. Are files well organized? YES / NO Comments:
Title: SIU Inspection form
File name: COMP.INSP
Revision date: October 2, 2020 Page 3

Town of Holly Springs
Water Resources
Environmental Compliance
2. Are sample collection
/
chain -of -custody forms filled
out properly?
YES/NO Comments: Sent
with DMRs
3. Do results in files agree with reports sent to POTW? YES / NO Comments:
4. Who has authority to shut down production should a spill or slug discharge occur? All operators are
trained to stop discharge flow and contact security in the event of a spill or slug discharge. There is a
written spill plan procedure that is followed for these events.
5. How does SIU inform employees of whom to call at POTW incase of spill/slug? Signage is posted
throughout the plant that references internal spill procedures. Every spill kit is equipped with a quick
reference guide to spill procedures Spill response training is conducted at the time of hire and
refreshed annually.
(If slug/spill plan is already required by POTW, review procedures).
6. Is SIU implementing slug/spill plan? YES / NO
Comments:
INSPECTION RESULTS
Slug/Spill Control Plan Needed? YES / NO
Comments, Required or Recommended Actions:
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020 Page 4

ATTACHMENT 25
Summary
There a total of 28 dentist practicing in TOHS. Of the 28 practicing in TOHS. As some dentist practices have shared dental clinics, there were
only 16 clinics with amalgam separators to be inspected.
Dentist
First
Follow up
Inspection
Compliance
Reason for Non -Compliance
Course of Action
Inspection
Compliance
Practice
Date
Date
Avert
6/16/21
Yes
N/A
N/A
N/A
N/A
Ferry
Family
Dentistry
Axial
4/4/2021
No
Failure to provide documentation of (1), (2), (3)
Follow up inspection was
4/30/2021
Yes
Dental
and (4)*.
scheduled within 60 days
of the first inspection.
Campbell
5/12/2021
Yes
N/A
N/A
N/A
N/A
and
Farrelly
Cosmetic
Dentistry
Guanga
6/17/2021
No
Documentation of the visual weekly inspection
Follow up inspection was
7/8/2021
Yes
Family
was started at the time of the first inspection.
scheduled within 60 days
Dentistry
The date of the last filter change did not
of the first inspection.
comply what is written in the Solmetex Hg5
Amalgam Separator user manual. At the time of
inspection, we had not yet received the "One-
time Compliance Report for Dental
Dischargers"
Holly
9/23/21
Yes
N/A
N/A
N/A
N/A
Springs
Family
Dentistry
Klooster
10/13/2021
No
Updates needed to be made to required
Follow up inspection
12/20/21
Yes
Family
documents (1), (2), (3) and (4)*. Amalgam
scheduled within 60 days
Dentistry
Storage Buckets used to collect loose amalgam
of the first inspection.**

which collects in the chairside traps had not yet
been purchased.
Keisha B.
10/7/2021
No
Further research needed to be done on the
Follow up inspection
12/14/2021
Yes
Davis
LibertyBoss Amalgam Separator which the
scheduled within 60 days
practice switch to 9/15/2021. Updates needed
of the first inspection.**
to be made to required documents (1), (2), (3)
and (4)*. Amalgam Storage Buckets used to
collect loose amalgam which collects in the
chairside traps had not yet been purchased.
Main
9/30/2021
No
Further research needed to be done on the
Follow up inspection
11/22/2021
Yes
Street
DRNA BU10 Amalgam Separator. Updates
scheduled within 60 days.
Family
needed to be made to required documents (1),
Dentistry
(2), (3) and (4)*. Amalgam Storage Buckets
used to collect loose amalgam which collects in
the chairside traps had not yet been purchased.
"One-time Compliance Report for Dental
Dischargers" was missing wet signature.
Defective pressure gauges caused the vacuum
pumps to read at a pressure higher than
acceptable for the DRNA BU10 Amalgam
Separator,
Signature
6/16/2021
No
Visual inspections were being done on a
Another copy of the visual
N/A- Visual
Yes
Family
monthly basis but are required to be done on a
inspection form was sent
Weekly
Dentistry
weekly basis according to the Solmetex Hg5
in three weeks' time
Inspection
Amalgam Separator manual.
showing that Signature
Log was sent
Family Dentistry had
7/13/2021
established a weekly
via email.
visual inspection of the
amalgam separator.
Smile and
5/12/2021
Yes
N/A
N/A
N/A
N/A
Shine
Dental
Studio

Sninski
7/29/2021
Yes
N/A
N/A
N/A
N/A
and
Schmitt
Family
Dentistry
Spring
6/15/2021
No
The weekly visual inspection was started at the
Another copy of the visual
N/A -The
Yes
Smiles
time of the inspection. At the time of the
inspection form was sent
letter from
Dentistry
inspection the solids collector change was past
in three weeks' time
the service
due according to the Solmetex NXT Hg5
(7/7/2021) showing that
technician
manual.
Spring Smiles Dentistry
was sent via
had established a weekly
email
visual inspection of the
6/16/21.The
amalgam separator. A
visual weekly
letter on the amalgam
inspection
separator service
form was
technician's letter head
sent via
was sent via email stating
email
the reason the solids
7/7/2021.
collector wasn't changed
in accordance with the
Solmetex NXT Hg5 manual
(Covid-19 pandemic
closures).
Spring
7/15/2021
No
Failure to provide documentation of (1), (2), (3)
Follow up inspection
11/30/2021
Yes
Village
and (4)*. Amalgam Storage Buckets used to
within 60 days of the first
Dentistry
collect loose amalgam which collects in the
inspection.**
chairside traps had not yet been purchased.
Sunset
8/16/2021
No
Failure to provide documentation of (1), (2), (3)
Follow up inspection
11/1872021
Yes
Ridge
and (4)*.
within 60 days of the first
Dentistry
inspection.**
The
8/19/2021
Yes
N/A
N/A
N/A
N/A
Smiling
Turtle

Twin Leaf
8/26/2021
No
Failure to provide documentation of (1), (2), (3)
Follow up inspection
11/29/2021
Yes
Dentistry
and (4)*. Amalgam Storage Buckets used to
within 60 days of the first
collect loose amalgam which collects in the
inspection.**
chairside traps had not yet been purchased.
see "Required Information for Compliance According to CFR 441.50" section
"`Follow up inspection was scheduled past 60 days grace period because TOHS staff shortages due to illnesses occurring during the
Covid19 pandemic.
Required Information for Compliance According to CFR 441.50:
(1) Documentation of the date, persons) conducting the inspection, and results of each inspection of the amalgam separators) or
equivalent device(s), and a summary of follow-up actions, if needed.
(2) Documentation of amalgam retaining container or equivalent container replacement (including the date, as applicable).
(3)
Documentation of all
dates that collected dental amalgam is picked up
or
shipped
for proper disposal in accordance with 40 CFR
261.5(g)(3),
and the name of the permitted or licensed treatment, storage
or
disposal
facility receiving the
amalgam retaining containers.
(4) Documentation of any repair or replacement of an amalgam separator or equivalent device, including the date, persons) making the
repair or replacement, and a description of the repair or replacement (including make and model).
(5) Dischargers or an agent or representative of the dental discharger must maintain and make available for inspection in either physical or
electronic form the manufacturers operating manual for the current device."