NC0063096_Annual Report_20220317

Page 1 of 4
The Town of.
' !l/ HOLLY
Deparitad nt or Water (Qu lll:y
SPRINGS
Town of Holly Springs (NPDES, NC0063096)
March 15, 2022
(An extension of March 15th 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(SlUs) 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 18th, 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.batten a(�hollyspringsnc.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 16th 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.batten a(�hollyspringsnc.gov

Page 4of4
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, 2021 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(Seqirus) (Attachment #22)
• Industrial Data Summary Sheets(Seqirus) (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 TORS. 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)4Debi a C. Batten
/16-6/ e.tz.----
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.batten anhollyspringsnc.gov

Page 3 of 4
• Communication was received from Seth Gundersen on August 4th that the SWLF had received
a second IUP 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 TORS had not received the TTO certification for
the first 6-month compliance period and that as required by the permit TORS 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 8th 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.batten(c�hollyspringsnc.gov

ATTACHMENT 1
Pretreatment Program Info Database printed on: 1/18/2022
for Program Name Holly Springs r
WWTP Name Utley Creek Stream Information 7 IWC % at 7Q10 98.83
Program Approval Date 09/05/2006 7Z10 Flow cfs / mgd 11 / 0.07
Pretreatment Status 1Q10 Flow cfs / mgd Mg / 0.06
Full Stream Classification C
Region RRO Basin Number CPF07
County Wake Receiving Stream Name Utley Creek J
NPDES Number NC0063096
NPDES Effective Date Last PAR Rec 02/26/2021 PAR Due Date 03/01/2022 mercury
11/01/2017 1631
NPDES Expire Date 07/31/2021 Current Fiscal 09/04/2020 required
Year PCI Done
POTW is Primary WWTP TRUE Last Audit on 09/07/2017 Audit Year Next21/22 yes
Design Flow mgd 6.0000 % Design mgd is SIU permitted 5.00 Permitted SIU flow (mgd) [Pt SIU) .3
WWTP SIU's 2 Program SIUs 2
WWTP CIU's 1 Program CIUs 1 HWA LTMP *; IWS SUO ERP
date Inactive Date Next Due i 05/01/2022 •
— I
•
Date Received by DWR 112/31/2016 I 08/31/2018 09/30/2021 11/08/2012 ' 06/22/2010
... . . . ..... .. . . .. . ... .
Date Approved 02/22/2018 i r 10/26/2018 12/07/2012 08/04/2010
Adopt Date Required
Date Adopted 11/06/2012
r
Info in this Box from PLContacts
Date Date Date
PT_Pro Attended Attended Attended
Formal Name g.Prime Phonel ext Fax HWA Wksp IUP Wksp PAR Wksp
Mr. Seann Byrd I 11919-577-1090 1919-577-2280 II I I I
[e-mail] Public Utilities Director P.O. Box 8 27540
Ms. Katelyn Tresino I 11919-577-2273 I I II I I I
Lab Technician P.O. Box 8 27540
Debra Batten (Prim 11(919)557-2907 1 I II 4/11/2019 15/24/2016 I I ,
[e-mail] Laboratory Manager/Pretreatment P.O. Box 8 27540
J
Pretreatment Related NOVs from DWQ DWR Central Office Contact McGee & Miller
DWR Regional Contact Cheng Zhang
J

DocuSign Envelope ID: 73C0D794-1C74-422B-BF1E-258E286F6262 ,
STATE ':,
ROY COOPER ik. 6reii''':*ril '''
Governor1
ELIZABETH S. BISER 7�
Secretary \ WEaw+van°_ '/"
S. DANIEL SMITH NORTH CAROLINA
Director 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 Updates: 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 Unit. 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.
i
(NPDES Branch
Compliance & Industrial Permitting Municipal Permitting
Expediated Permitting
Supervisor: John Hennessy Supervisor: Doug Dowden Supervisor: Michael Montebello
NPDES Municipal Pretreatment Collection
Permitting systems
North Carolina Department of Environmental Quality I Division of Water Resources
D_E 512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699-1617
NORIH(`PJOLI A
fkpiMront of Environmental Quahi\ �� 919.707.9000

DocuSign Envelope ID: 73C0D794-1C74-422B-BFIE-258E286F6262
5. Staff Assignments: Our goals for project review are 30 days for IUPs and SIU 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: [e-mail], Office Phone: [phone]
b. Charlie Miller: [e-mail], 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 page 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 (IUP) - Projected 4th quarter of 2022
All subject to current COVID-19 situation and staffing.
7. 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. .Y ,
b. Historical SNC sheets only list currently Active SIUs that had SNCs from 2014-2020.
c. PAR forms are available for download on our website. .„,.
8. Email Addresses: The Municipal Permitting Unit often uses email to send out mass
mailings. To make this an effective and 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,
—DocuSigned by:
ksl/EOY 2021 (,(WJ,(,Qtd ilAttAlthilh
Attachments: Program Info Sheet(s) \—C464531431644FE...
Historical SNC Sheet(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
i I'P.1'---D
North Carolina Department of Environmental Quality I Division of Water Resources
E 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh,North Carolina 27699-1617
tIORT11 CAROL
Department 01�i+«ftla. Ity / 919.707.9000

ATTACHMENT 2
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Workbook Name: Holly Springs_HWA_approved_2017.xls; Worksheet Name: HWr ed 3/15/20 2, 8 11 PM
A B I C I D I E I F G I H I I J K
1 Headworks Analysis Spreadsheet Spreadsheet Instructions:
2 POTW Name: Holly Springs 1) Applicable Values should be entered in the Heavy Bordered Blue cells. The rest of worksheet is
3 Date: 10/31/2017 protected, password is "2".
4 POTW NPDES # => NC0063096 2) Additional pollutants can be added in cells A34 to A42. Note all Pollutant names are linked from
5 POTW Sludge Permit#=> WQ0019098 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).
7 POTW NPDES Permitted Flow(MGD)= 6 <used in AT only 3) Formulas are discussed in the Comprehensive Guidance HWA Chapter.
8 POTW Average Flow(MGD)= 1.9033 <tisea in HWA calculations 4) HWA, AT and HASL worksheets are linked. MAHLs, Basis, and Uncontrollable load are
automatically entered into AT from this worksheet.
9 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
10 7Q10 Stream Flow(MGD)= 0.07 "view" tab click the "comment indicator only" button.
11 Stream Classification = Class C
13 Class of Sludge generated (A, or B) ' B
ui1UL A LV
14 Sludge to Digestor Flow(MGD)= Through calc. for different POTW use Design
15 Sludge to Disposal Flow(MGD)= 1.606 flows Criteria
16 Sludge
to Disposal 2 Design Values Average Flow Permitted Flow Loadin
dge Site Area(acres)= 76.7 WWTF Influent BOD (mg/I) 390 714.3 226.6 x
18 Sludge Site Life(yrs)= 20 WWTF Influent TSS (mg/1) 423.0 7500.0 2379.1 x
• Age of Sludge Site(yrs)= WWTF Influent NH3 (mg/1) 40 166.7 52.9 x
20 WWTF Influent Total N(mg/1) 67 62.5 19.8 x
21 Pass-Through Loading Calculations WWTF Influent Total P (mg/I) 10 10.0 3.2 x
au cAILL IVlulull Uul
Stream Standard Pass-Thru Minimum
NPDES LIMIT Plant Removal Removal rate NPDES Loading Standard Stream Loading Design Criteria Loading Pass-Thru
23 Pollutant (mg/I) Rate(%) Source (lbs/day) (mg/I) Standard Source (lbs/day) Loading(lbs/day) (lbs/day) Basis
24 BOD 5 99.3 influent data 11,338 19,516 19,516 Design
25 TSS 30 99.6 influent data 119,051 21,167 21,167 Design
• Ammonia 1 99.4 influent data 2,646 2,002 2,002 Design
27 Arsenic 45 literature 0.01 Human Health 0.2992 0.2992 Stream Std
28 Cadmium 67 literature 0.00145 dissolved stnd 0.0723 0.0723 Stream Std
• Chromium 82 literature 0.011 1.0057 1.0057 Stream Std
3030
Copper 93 LTMP 0.0217 dissolved stnd 5.1018 5.1018 Stream Std
Cyanide I 69 literature 0.005 NC WQS 0.2654 0.2654 Stream Std
32 Lead 0.0111 61 literature 0.4518 0.4518 NPDES
33 Mercury 99.2 LIMP _____________0.000012 NC WQS0.02469 0.02469 Stream Std
34 Molybdenum 29 LTMP 2 human health 46.3587 46.3587 Stream Std
35 Nickel 40 LTMP 0.102 dissolved stnd 2.7977 2.7977 Stream Std
36 Selenium 50 literature 0.005 NC WQS 0.1646 0.1646 Stream Std
37 Silver 75 literature 11. NC WQS 0.0039 0.0039
38 Zinc 1 LTMP 0.344 dissolved stnd 18.8711 18.8711 Stream Std
• Total Nitrogen5 92 LTMP 992.0951 . : 1 Design
40 Total Phos. 0.5 95 influent data 158.7352 500.4 500.400 Design
41 Chlorides 4.2 LTMP 230 NC WQS 3951.1316 3951.1316 Stream Std
42 Orthophosphorus 0.27
43 e
44 f
45 a
46 h
47 I
Modeled after: Chapter 5-HWA Guidance, Appendix 5-A
Revision Date: February 2008

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Workbook Name: Holly Springs_HWA_approved_2017.xls ; Worksheet Name: HA/ d 3/15/2022, 8 11 PM
A B C D E F G H I J K
l V
49 Average Influent NH3 (mg/1)
50 Average Anaerobic Digester NH3 (mg/1)
51 Inhibition Loading Calculations only enter when have ANAEROBIC digester
A.S./Nit,/T.F. A.S./Nit,/T.F. A.S./Nit,/T.F. Digestor Minimum Minimum
Primary Primary Inhibition Inhibition Inhibition Inhibition Digestor Inhibition Inhibition
Removal Rate Removal Rate Concentration Concentration Loading Concentration Inhibition Digestor Inhibition Loading Loading
52 Pollutant (%) Source (mg/I) Source (lbs/day) (mg/I) Conc. Source Loading(lbs/day) (lbs/day) Source
1 NI
53 BOD - _
54 TSS
55 Ammonia 480 act sludge 7619.2906 7619.29 AS/Nit/TF ir
56 Arsenic 0.1 act sludge 1.5874 1.5874 AS/Nit/TF ir
57 Cadmium 1 act sludge 15.8735 15.8735 AS/Nit/TF ir
I
58 Chromium 0.394 nitrification 6.2542 6.2542 AS/Nit/TF ir
59 Copper 0.48 nitrification 7.6193 7.6193 AS/Nit/TF ir
60 Cyanide _ 0.1 act sludge _ 1.5874 1.5874 AS/Nit/TF ir
61 Lead 0.5 nitrification 7.9368 7.9368 AS/Nit/TF ir
62 Mercury 0.1 act sludge 1.5874 1.5874 AS/Nit/TF ir
-
63 Molybdenum
I
64 Nickel 0.25 nitrification 3.9684 3.9684 AS/Nit/TF ir
65 Selenium _ _
66 Silver 0.25 act sludge 3.9684 3.9684 AS/Nit/TF ir
67 Zinc 1 nitrification 15.8735 15.8735 AS/Nit/TF ir
68 Total Nitrogen
69 Total Phos.
70 Chlorides
71 Orthophosphorus
72 e
73 f -
74
75 h
76 I
Modeled after: Chapter 5-HWA Guidance, Appendix 5-A
Revision Date: February 2008

Workbook Name: Holly Springs_HWA_approved_2017.xls; Worksheet Name: HW d 3/15/2022a8e11 PM
A B C D E F G H I J K
77
78 Sludge Loading Calculations
Sludge Ceiling Class A Limits Class A Limits Class A Limits Minimum Minimum
Sludge Ceiling Sludge Ceiling Load Cumulative Sludge Cumulative Monthly Monthly Avg. Mon. Avg. Load. - Sludge Sludge
Concentration Load - HASL Calc. - Rate Limit Sludge Loading Average Rate Loading HASL Calc. - Loading Loading
79 Pollutant Limit(mg/kg) (lbs/day) (lbs/day) (lbs/(acre*life)) (lbs/day) Limit(mg/kg) (lbs/day) (lbs/day) (lbs/day) Sorce
80 BOD
81 TSS
82 Ammonia
83 Arsenic 75 44.6468 36 0.8400 41 0.8400 Cumul. Slud
84 Cadmium 85 33.9849 34 0.5328 39 0.5328 Cumul. Slud
85 Chromium
86 Copper 4300 1238.5886 1338 15.1068 1500 15.1068 Cumul. Slud
87 Cyanide
88 Lead 840 368.8850 267 4.5960 300 4.5960 Cumul. Slud
89 Mercury 57 15.3923 15 0.1588 17 0.1588 Cumul. Slud
90 Molybdenum 75 69.2795 69.2795 Sludge Ceilii
91 Nickel 420 281.2748 374 9.8177 420 9.8177 Cumul. Slud
92 Selenium 100 53.5762 89 1.8690 100 1.8690 Cumul. Slud
93 Silver
94 Zinc 7500 2870.1514 2498 37.4708 2800 37.4708 Cumul. Slud
95 Total Nitrogen
96 Total Phos.
97 Chlorides
98 Orthophosphorus
99 e
100 f
101 g
102 h
103 I _
104
Modeled after: Chapter 5-HWA Guidance, Appendix 5-A
Revision Date: February 2008

Page 4 of 5
Workbook Name: Holly Springs_HWA approved_2017.xls; Worksheet Name: HVgAed 3/15/20 2, 8:11 PM
A B I C D I E I F G H I I J K
105 Maximum Allowable Headworks Loading Calculations
Maximum
Minimum Pass Minimum Minimum Minimum Minimum Allowable Maximum Allowable
Through Loading Pass Through Inhibition Loading Inhibition Loading Sludge Loading Sludge Loading Headworks Loading Headworks Loading
106 (lbs/day) Source (lbs/day) Source (lbs/day) Sorce (lbs/day) Source
107 BOD 19515.6 Design 19515.6 Design
108 TSS 21166.9 Design 21166.9 Design
109 Ammonia 2001.6 Design 7619.2906 AS/Nit/TF inhibiti 2001.6 Design
110 Arsenic 0.2992 Stream Std 1.5874 AS/Nit/TF inhibiti 0.8400 Cumul. Sludge Loading 0.2992 Stream Std
111 Cadmium 0.0723 Stream Std 15.8735 AS/Nit/TF inhibiti 0.5328 Cumul. Sludge Loading 0.0723 Stream Std
112 Chromium 1.0057 Stream Std 6.2542 AS/Nit/TF inhibiti I 1.0057 Stream Std
113 Copper 5.1018 Stream Std 7.6193 AS/Nit/TF inhibiti 15.1068 Cumul. Sludge Loading 5.1018 Stream Std
114 Cyanide 0.2654 Stream Std 1.5874 AS/Nit/TF inhibiti I 0.2654 Stream Std
115 Lead 0.4518 NPDES 7.9368 AS/Nit/TF inhibiti 4.5960 Cumul. Sludge Loading 0.4518 NPDES
116 Mercury 0.02469 Stream Std 1.5874 AS/Nit/TF inhibiti 0.1588 Cumul. Sludge Loading 0.02469 Stream Std
117 Molybdenum 46.3587 Stream Std 69.2795 Sludge Ceiling I 46.3587 Stream Std
118 Nickel 2.7977 Stream Std 3.9684 AS/Nit/TF inhibiti 9.8177 Cumul. Sludge Loading 2.7977 Stream Std
119 Selenium 0.1646 Stream Std 1.8690 Cumul. Sludge Loading 0.1646 Stream Std
120 Silver 0.0039 Stream Std 3.9684 AS/Nit/TF inhibiti I 0.0039 Stream Std
121 Zinc 18.8711 Stream Std 15.8735 AS/Nit/TF inhibiti 37.4708 Cumul. Sludge Loading 15.8735 AS/Nit/TF inhibition
122 Total Nitrogen 3352.7 Design 3352.6800 Design
123 Total Phos. 500.4 Design 500.4000 Design
124 Chlorides 3951.1 Stream Std 3951.1316 Stream Std
125 Orthophosphorus
126 e
127 f
128 g
129 h
130 I
131
Modeled after: Chapter 5-HWA Guidance, Appendix 5-A
Revision Date: February 2008

Workbook Name: Holly Springs_HWA_approved_2017.xls; Worksheet Name: HWd 3/15/2022a8e11 PM
A B I C I D I E F I G I H I I I J K
132
133 Maximum Allowable Industrial Loadings Calculations
Maximum Maximum
Allowable Uncontrollable Allowable
Headworks Loading Check to Use HASL Concentration Uncontrollable Uncontrollable Industrial Load Design vs. Pass-
134 Pollutant (lbs/day) MAHL Basis Calcs (x) (mg/l) Source Load (lbs/day) (lbs/day) Thru Warning
135 BOD 19515.6000 Design 295 mass balance 4470.3651 15045.2349
136 TSS 21166.9200 Design 288 mass balance 4364.2886 16802.6314
137 Ammonia 2001.6000 Design 34 mass balance 515.2285 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 l 0.061 mass balance 0.9244 4.1774
142 Cyanide 0.2654 Stream Std N/A 0.002 mass balance 0.0303 0.2351
143 Lead 0.4518 NPDES 0.0074 site speitic 0.1121 0.3396
144 Mercury 0.02469 Stream Std 0.0003 literature 0.00455 0.02014
145 Molybdenum 46.3587 Stream Std 0.0048 mass balance 0.0727 46.2859
146 Nickel 2.7977 Stream Std 0.0081 mass balance 0.1227 2.6750
147 Selenium 0.1646 Stream Std 0.0055 Influent _ 0.0833 0.0812
148 Silver 0.0039 Stream Std N/A 0 BPJ 0.0000 0.0039
149 Zinc 15.8735 AS/Nit/TF inhibition 0.175 literature 2.6519 13.2216
150 Total Nitrogen 3352.6800 Design 57.7 mass balance 874.3731 2478.3069
151 Total Phos. 500.4000 Design 8.07 mass balance 122.2910 378.1090
152 Chlorides 3951.1316 Stream Std 76.7 mass balance 1162.2949 2788.8367
153 Orthophosphorus
154 e
155 f
156 g
157 h
158 I
Modeled after: Chapter 5-HWA Guidance, Appendix 5-A
Revision Date: February 2008

Workbook Name : Holly Springs_HWA approved_2017.x1s, Worksheet Name: AT Printed: 3/15/2022, 8:12 PM
Page 1 of 4
Allocation Table Spreadsheet Instructions:
Headworks last approved: 02/22/18 1) Applicable Values should be entered in the Heavy Bordered cells. Rest of worksheet is protected, password is
Allocation Table updated: 06/12/18
2) Formulas are discussed in the Comprehensive Guidance, Chapter 6, Section C.
Permits last modified: 01/01/18 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.
Pores Holly Springs
NPDES > NC0063096
FLOW BOD TSS
Industry Type Renewal Modification Date Permit Limits Permit Limits Permit Limits
'UP INDUSTRY NAMES Permit Pipe of Effective Effective Permit Conc. Load Conc. Load
Count (please list alphabcticly) number number Industry Date Date Expires MGD gal/day moll lbs/da mg/1 lbs/da
1 South Wake Landfill 0001 0001 Landfill 01/01/14 12/31/18 0.0500 50,000 272.00 418.00
2 Novartis Seqirus 0002 0002 Pharm 01/01/18 12/31/23 0.25001 250,000 1355.00
4
5
6
7
8
imi
ii
10
Column Totals => 1 0.30001 300,0001 1 16271 418
Basis=> NPDES Design Design
MAUL from HWA (lbs/day) => NPDES Permitted Flow=> 6.0000 19516 21167
Uncontrollable Loading (lbs/day) _> 1.8170 4470 4364
Total Allowable for Industry (MAIL) (lbs/day) => 4.1830 15045 16803
Total Permitted to Industry (lbs/day) _> 0.3000 1627 418
MAIL left (lbs/day) => 3.8830 13418 16385
Percent Allow. Ind. (MAIL) still available (%) => 92.8 % 89.2 % 97.5 %
Percent MARL still available (%) _> 64.7 % 68.8 % 77.4 %
5 Percent MAHL (lbs/day) _> 0.3000 976 1058
HWA.AT
Revised:November 2005

Workbook Name : Holly Springs_HWA approved_2017.xls, Worksheet Name: AT Printed: 3/15/2022, 8:12 PM
Page 2 of 4
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 06/12/18
Permits last modified: 01/01/18
Poiw=> Holly Springs
NPDES#✓=> NC0063096
Ammonia Arsenic Cadmium Chromium Copper Cyanide
Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits
RIP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load
Count (please list alphabcticly) number number mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/I lbs/day mg/1 lbs/day mg/1 lbs/day
1 South Wake Landfill 0001 0001 77.00 32.00
2 NovartisSegirus 0002 0002 0.0300 0.0626
4
5
6
7
8
9
10
Column Totals => 1 321 ( 0.00001 , 0.00001 I 0.0000.1 1 0.0000, 0.0626
Stream Stream Stream Stream Stream
Basis=> Design Std Std Std Std Std
MAHL from HWA (lbs/day) => 2001.60 0.2992 0.0723 1.0057 5.1018 0.2654
Uncontrollable Loading (lbs/day) => 515.23 _ 0.0758 0.0455 0.7577 0.9244 0.0303
Total Allowable for Industry (MAIL) (lbs/day) _> 1486.37 _ 0.2235 _ 0.0269 0.2480 4.1774 0.2351
Total Permitted to Industry (lbs/day) => _ 32.00 0.0000 0.0000 0.0000 0.0000 0.0626
MAIL left (lbs/day) => 1454.37 0.2235 0.0269 _ 0.2480 4.1774 0.1726
Percent Allow. Ind. (MAIL) still available (%) _> 97.8 % 100.0 % 100.0 % 100.0 % _ 100.0 % 73.4 %
Percent MARL still available (%) => 72.7 % 74.7 % 37.1 % 24.7 % 81.9 % 65.0 %
5 Percent MAHL (lbs/day) => 100.08 0.0150 0.0036 0.0503 0.2551 0.0133
HWA.AT
Revised:November 2005

Workbook Name : Holly Springs_HWA approved_2017.xls, Worksheet Name: AT Printed: 3/15/2022, 8:12 PM
Page 3 of 4
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 06/12/18
Permits last modified: 01/01/18
Pow/. Holly Springs
NPDES4> NC0063096
Lead Mercury Molybdenum Nickel Selenium
Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load
Count (please list alphabcticly) number number mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/I lbs/day mg/I lbs/day
1 South Wake Landfill 0001 0001 LI
2 NovartisSegirus 0002 0002
3
4
5
6
7
- .
8 0
9
10
Column Totals => 1 0.00001 0.000000 0.00001 0.0000 1 0.0000
Stream
Basis=> NPDES Stream Std Stream Std Std Stream Std
MAHL from HWA (lbs/day) => 0.4518 0.024686 46.3587 2.7977 0.1646
Uncontrollable Loading (lbs/day) => 0.1121 0.004546 0.0727 0.1227 0.0833
Total Allowable for Industry (MAIL) (lbs/day) _> 0.3396 0.020140 46.2859 _ 2.6750 0.0812
Total Permitted to Industry (lbs/day) => 0.0000 0.000000 0.0000 0.0000 0.0000
MAIL left (lbs/day) => 0.3396 0.020140 46.2859 _ 2.6750 0.0812
Percent Allow. Ind. (MAIL) still available (%) _> 100.0 % 100.0 % 100.0 % 100.0 % 100.0 %
Percent MARL still available (%) _> 75.2 % 81.6 % 99.8 % 95.6 % 49.4 %
5 Percent MARL (lbs/day) => 0.0226 0.001234 2.3179 0.1399 0.0082
HWA.AT
Revised:November 2005

Workbook Name : Holly Springs_HWA_approved_2017.xls, Worksheet Name: AT Printed: 3/15/2022, 8:12 PM
Page 4 of 4
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 06/12/18
Permits last modified: 01/01/18
Poiw=> Holly Springs
NPDES#=> NC0063096
Silver Zinc Total Nitrogen Total Phos. Chlorides
Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load
Count I (pIcasc list alphabcticly) number number mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/I lbs/day mg/1 lbs/day
1 South Wake Landfill 0001 0001 544.00 227.00
2 Novartis_Segirus 0002 0002 56.00 2450.00
ii
5
6
7
8
9
10
Column Totals => I 0.0000 0.0000 1 227.00 56.00 I 2450.00
AS/Nit/TF
Basis=> Stream Std inhibition Design Design Stream Std
MARL from HWA (lbs/day) => 0.0039 15.8735 I 3352.68 500.40 3951.13
Uncontrollable Loading (lbs/day) => 0.0000 2.6519 874.3731 122.29 1162.29
Total Allowable for Industry (MAIL) (lbs/day) => 0.0039 13.2216 2478.31 378.11 2788.84
Total Permitted to Industry (lbs/day) => 0.0000 0.0000 227.00 56.00 2450.00
MAIL left (lbs/day) => 0.0039 13.2216 2251.31 322.11 338.84
Percent Allow. Ind. (MAIL) still available (%) _> 100.0 % 100.0 % 90.8 % 85.2 % 12.1 %
Percent MAHL still available (%) _> 100.0 % 83.3 % 67.1 % 64.4 % 8.6 %
5 Percent MAHL (lbs/day) _> 0.0002 0.7937 167.63 25.0200 197.5566
HWA.AT
Revised:November 2005

ATTACHMENT 3
Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name: Town of Holly Springs
2. "Primary" NPDES Number NCOO 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 11 . => 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 of NOVs, NNCs or similar assesed to SIUs 16. => 2
17. Number of Civil Penalties assessed to SIUs 17. _> 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
Foot Notes: AO Administrative Order IUP Industrial User Pretreatment Permit POTW Publicly Owned Treatment Works
CIU Categorical Industrial User NNC Notice of Non-Compliance SIU Significant Industrial User
CO Consent Order NOV Notice of Violation SNC Significant Non-Compliance
IU Industrial User PAR Pretreatment Annual Report
revised 1/2018: PAR PPS 2018

Pretreatment Performance Summary
( PPS) = Exjlanatjons
Line # 5. Number of SlUs permitted and/or discharged during PAR year. Discuss new or dropped
SlUs 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]
,.- othinq•Co ps■ e
IC,
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,
WebEx, or other web-based calling services.
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 [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
1

provided by your office. The other tab is for the Business that were survey based on information provided TORS
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 8IHolly Springs, NC 27540
Office: [phone] I Cell: [phone]
Town Website: hollyspingsnc.gov
Ado
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: his email originated from outside of the organization, Do not click links or oper ''
you recognize the sender and know the content i safe. •
. -
2

Debra Batten ATTAC H M ENT 5
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,
The BOD data for both the 15th and 22"d, 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: (919) 557-2907 Cell: (919) 524-2509 1
Town Website: www.hollyspringsnc.us
1

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 I Equipment Operator
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
I [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 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, 2021 4:04 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 8 I Holly Springs, NC 27540
Office: (919) 557-2907 I Cell: (919) 524-2509
Town Website: www.hollyspringsnc.us
1

P
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
CAUTION: :.:em r .O iginat:ed frori o 5'14 - the organization. Do not click links or open
recognize the sender and know the content is safe.
2

& ir Prep Log Report
Batch Information: EDEN51299BODANALYTICAL_RR Template Version: F-CAR-I-031-Rev.02 (29May2020)
Analysis Method SM 5210B-2011 Analyzed By MWF Instrument 95EDN3 Cal Date/Time 03/07/2021 11:31:56:165
Meter Pres. (mBar) 30.39 Meter Temp (C) 22.93 Probe ID ssro64 Incubator
Incubator 2 Init. DO (mg/L) 8.48 Vol of Seed per
( g ) SC Factor(mg/L) 0.65 Sample (mL) 6
Reviewed By Reviewed By Date Batch Notes 95w11
Sample Information:
m - _ l_ Li
1� a. m z cE 0E QE mE 6E U n
a. cn o o m Ro Oo co Oo Coo m3 o
a
C3 . E C m Z 0 o 0 3 Q _ 00 0 ? mm CO 0
c co 0 _ m ao = n pis zn mo a o u.
5210BWEDN BLANK 3171041 Y 03/07/2021 2 15867338 I 3001300 8.24 I 8.3 8.2 I 8.29 0.04 I 0.01 0.04I0.01 0.03 8.1
11:35:55 15867335
03/07/2021 15867348 8.24 8.2913.33 3.34 14.91 14.95 213.00 I
5210BWEDN LCS 3171042 Y 11:36:54 3 15867357I 6 I 6 I 6 g131 3I25 5.06 215.00I 216.17
15867351 220.50
03/07/202115867322 8.27 18.24 17.21 15.23 I *1.06 13.01 NA 10.75 I
5210BWEDN SCF 3171043 Y 11:38:17 3 15867346 I 6 124 136 g 18 4.91 3.27 0.55 0.65
15867343
03/07/20211586734921 8.28 18.28 17.66 17.55 I *0.62 1 NA ! NA I
5210BWEDN PS 92523361001 Y 11:43:11 3 158673 5867311I 0.5 I 1 13 8.31 7.26 *0.73 40.00 40.00 8.12 B2
n vs
as0
a
z I- Q-
E
5 CD"al co
CD TS
CC -cs
Q.
v E C co E
a CI) J C U)
5210BWEDN BLANK 3171041 No
5210BWEDN LCS 3171042 Yes
5210BWEDN SCF 3171043 Yes
5210BWEDN PS 92523361001 Yes
Sun, 7 Mar 2021 11:43:46 -0500

ceAnaiytical. Prep LogReport
3atch Information: EDEN51171BOD_FINAL Template Version: F-CAR-I-031-Rev.02 (29May2020)
Analysis Method SM 5210B-2011 Analyzed By DAW Instrument 9SEDNJ Cal Daternme 02/21/2021 13:31:42:508
Meter Pres. (mBar) 30.54 Meter Temp (C) 23.41 Probe ID 95T080 Incubator
Incubator 2 Init. DO m !L 8.4aVol of Seed per
( g ) SC Factor (mg/L) 1.00Sample (mL) 6
Reviewed By AMI Reviewed By Date 02l2212021 10:14 Batch Notes 95W11
Sample Information:
o 0 E 16 -d m _J d
o. 0 c - a.J m -L m m a o
m
a Q t o f m E a E a E . (5E v o
m ~ E o a O o. tz 0
❑ o - o - - Oo ❑ o Oo 0o O U •..
m � .. ❑ � �. ❑ :.
m to
E .o c = = - � os o = 0 � mm m
v 03 03 0 6 o oc ❑ sr.
a -3 02/2 /2021 15853422 E� u_ ❑ ❑ m ❑ Q E
5210BWEDN BLANK 3164827 Y 13:37:47 2 15853 22 300 J 300 8.55 J 8.56 8.47 18.54 0.08 J 0.02 0.08 J 0.02 0.05 8.22
15853054 I 231.50 I
5210BWEDN LCS 3164828 Y 02/21/202113:40:25 3 15853059 I 6 J 6 16 8.54 J 8.45212.91 I 3.43 5.630I �09 204.50 j 224.83
15853387 238.50
02/21/2021 15853046 8.52 18.47 17.44 13.87 I *1.08 14.60 NA 11.15 1
5210BWEDN SCF 3164829 Y 13:42:53 3 15853073 I 6 ] 24 136 8.39 3.32 5.07 0.85 1.00
1111MME NM. 0 ilai 0 9111111911rMair ME 1.
MM. ill II Ur 9 191.1111111141111111111. GIB ID
IIIIII II 111. II In OM MI
1• 11 AIMED I 111. I 11MEP SIM a
iiim ammo • Mr o al
5210BWEDN PS 92522209001 Y 02/21/202113:531 3 15853080 1 0.5 1 1 13 8.4$J 8.5 J 7.46 J.5 9�36 J 1.*i.�4 J NA I NA 59.00 I 59.00 B2
• OOP s IN
! MI
i 111.1111 • II
vion, 22 Mar 2021 13:14:24 -0400

ATTACHMENT 7
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 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.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.
From: Kristi Prater <[e-mail]>
Sent: Thursday, July 29, 2021 1:02 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
IIIIIIIIIIIIIIIIIME.AMR
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
1

From: Seth Gundersen <[e-mail]>
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 I Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 I C [phone] I seth.qundersenqflenv.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 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.
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
ace Analytical'
From: Seth Gundersen <[e-mail]>
Sent: Thursday, July 29, 2021 10:41 AM
To: Kristi Prater <[e-mail]>
Subject: Ammonia Result 7/26 Sampling
2

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 I Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 I C [phone] I seth.gundersenqflenv.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 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
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3

Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
_ aceAr�aly�ical Huntersville, NC 28078
www.pacelabs.com [phone]
July 29, 2021
George Metcalf
GFL
RE: Project: Weekly Ammonia 7/26
Pace Project No.: 92551643
Dear George Metcalf:
Enclosed are the analytical results for sample(s) 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,
t, __A),),i -Pay_
Terri Page for
Kristi Prater
[e-mail]
[phone]
Project Coordinator
Enclosures
cc: Seth Gundersen, GFL
24( w REPORT OF LABORATORY ANALYSIS
TNI / This report shall not be reproduced, except in full,
/y/ without the written consent of Pace Analytical Services, LLC. Page 1 of 11

(.r Pace Analytical Services, LLC
iceAnalytical®® 9800 Kincey Ave. Suite 100
Huntersville, NC 28078
www.pacelabs.com
[phone]
CERTIFICATIONS
Project: Weekly Ammonia 7/26
Pace Project No.: 92551643
Pace Analytical Services Eden
205 East Meadow Road Suite A, Eden, NC 27288 North Carolina Wastewater Certification #: 633
North Carolina Drinking Water Certification #: 37738 Virginia/VELAP Certification #: 460025
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC. Page 2 of 11

(lir Pace Analytical Services, LLC
iceAnalytical®® 9800 Kincey Ave. Suite 100
Huntersville, NC 28078
www.pacelabs.com [phone]
SAMPLE ANALYTE COUNT
Project: Weekly Ammonia 7/26
Pace Project No.: 92551643
Analytes
Lab ID Sample ID Method Analysts Reported Laboratory
92551643001 Effluent EPA 350.1 Rev 2.0 1993 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

Pace Analytical Services, LLC
9800 Kincey Ave. Suite 100
aceAnaly�ical Huntersville, NC 28078
www.pacelabs.com
[phone]
ANALYTICAL RESULTS
Project: Weekly Ammonia 7/26
Pace Project No.: 92551643
Sample: Effluent Lab ID: 92551643001 Collected: 07/26/21 09:40 Received: 07/26/21 13:35 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
350.1 Ammonia EDN Analytical Method: EPA 350.1 Rev 2.0 1993
Pace Analytical Services - Eden
Nitrogen, Ammonia 1070 mg/L 15.0 150 07/28/21 15:51 7664-41-7
•
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 4 of 11

(g Pace Analytical Services, LLC
aceAnalytical ceAnatytical® 9800 Kincey Ave. Suite 100
Huntersville, NC 28078
www.pacelabs.com
[phone]
QUALITY CONTROL DATA
Project: Weekly Ammonia 7/26
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 07/28/21 11:06
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 mg/L 5.1 4.9 4
Results presented on this page are in the units indicated by the"Units" column except 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

(fr Pace Analytical Services, LLC
_ P ®
9800 Kincey Ave. Suite 100
aceAnalytical Huntersville, NC 28078
www.pacelabs.com [phone]
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.
PQL - Practical Quantitation Limit.
RL - Reporting Limit - The lowest concentration value that meets project requirements for quantitative data with known precision and
bias 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,
Date: 07/29/2021 12:57 PM without the written consent of Pace Analytical Services, LLC. Page 6 of 11

(Iir Pace Analytical Services, LLC
J2( ®
9800 Kincey Ave. Suite 100
aceAnalyticalHuntersville, NC 28078
www.pacelabs.com [phone]
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project: Weekly Ammonia 7/26
Pace Project No.: 92551643
Analytical
Lab ID Sample ID QC Batch Method QC Batch Analytical Method Batch
92551643001 Effluent EPA 350.1 Rev 2.0 1993 636361
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 7 of 11

umant Narr�: Ooatmt� d:October 7>�,2020
•
OocSample Condition t( J _ ______Ntiof 2 -----_
r• Document No.:
Issuing "
FEAR-C�•�33-t r.07 Paco Carolnas QuatltY mice
laboratory reeving samples: •
Asheville ❑ EdenD Greenwood ❑ Huntersvilte ❑ Rateig d Medranlcsville❑ Atlanta❑ KernerstrilleO
tc Cnr Name. • �J®n : 92551643
11C'J'1 rScSi J; co, ri, ,, V /f r/ ke ✓ / ..� ( Project 0.
Cooler: d tx UPS LISPS QGIent Il I III 111 III II 11111 III
0 Commercialce ❑Other, • 92551643
Custody Seal Present? OYes Vo Seals Intact? Des JE o [Pi , "����f
Orte`liniEfals Perron Examining Content:
Packing Material; ❑Bubble Wrap ' []Rubble Bags Done NjfOther 9lokricaITissue Frozen?
Des ❑No 120/A
Thermometer: �Slet ❑Blue ❑Nona
D IR Gun ID: q
(1d� Typo ofice:p-' Correction Factor ,�c�
Cooler Temp: 6 ' '. Add/Subtract ('C) i% ` Temp ouSdbe above freelingto GC
•
allProcies out of temp criteria.Samples on ices cooling process
Cooler Temp Corrected (° • 6 .. -5 has begun
USDA Regulated Soli( A, water sample) •
A
_—D►dc n—tpppairf n ehnarIlara►it1n rune.uatliin.tlte.ClrlitedStIto= t-�NX.,or,SC.(checkmaps):., Qk(. sal nrtefromgorelpsource(Internattoroily, �, .-- : . ._ . 1
Y
❑Yes No _ _ Tr clung +nr aad➢tsertaxtco es
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___------
CoroenturDtrepan
Chain of Custody Present? afies QNo ON/A L
Samples Arrrlred within Hold Time? es Duo ON/A 2 i I
Short Hold Tlme Analysis (A72 hr.)? ( es QNo Q A _ 3. •
Rush Turn Around Time Requested?. ❑Yea ®No QN(A 4- - - : I
Sufficient Volume? WYes QNo ON/A 5. I i
Correct Containers Used? WYas ONO QN/A `
• -pace Containers Used? • 0as NI No ON/A ••
. • i 1 .
Containers intact?' gYes ON4 ON/A 7• - •
1
Dissolved analysts:Samples Field Filtered? 11Yes QNa gti/A _ 9- --- "
I ,
Sample LaheL9 Match CDC? rrc Do ON/A 9.
i
`,� / •
-Includes Date/rime/ID/Analysts Max:tri _ ' „ , ,
Hee• •ace in VOA Vials (>5-6mm)? (les [ayo N/A 10. i
Trip Blank Present? ❑ 11.Yes Duo MN/A
T . clank Gusted Seals Present? QYes
Fir d Data Requited? Dyes ONO
COMMENTS/SAME DISCREPANCY
Lot ID.ofsplit containers:• •
CLIENT'NOTIFICATION/RESOLUTION
• i
•
I i
.._ . ! j !
. i
Person contacted: Oatefrlme: ++
I
iTI+r1�-r Ttt'�r.-•ter I��Yfti>�TT+'rJ�.�A. 1 1• .v IYt t•I►.i1V.A•W-116�� I
:t C 1.1t If•R1ttYJ..a.iK^r-.t}' �
•
Project Manager SCURF Review: \? (r )
{ `
1V—V_ 1 Date.
Project Manager SRF Review:

. CHAIN-OF-CUSTODY / Analytical Request Document
/'%ems
The Chain-of-Custodvinoctursz•Ny is a LEGAL DOCUMENT.AN relevant fields must be completed accurately.
Submitting a sample via this chain of custody constitutes acknowiedgment and acceptance of the Pace Terms and Conditions found at https://info.pacelabs.cornihubfs/pas-standard-terms.pctt.
Section A Section B Section C I
Required Client}ntenmatiorx Required Project information: invoice information: Page : 1 Of 1
Company. GFL ENVIRONMF_NTAL Report To: Mmdr Oakley Attention: .
Address: 6330OLD SMI.7HFIELD RD Copy To: .Company Name: l
Apex.NC 27539 Address: s
Email: maxine.00kleyeggfienv.com Purchase Order C: Pace Quote: I
Phone: [phone] IFax Project Name: WEEKLY LEACI-lATE Pace Protect Manager: krisii.PretcxgPacelahs-com. ••.47I4 r '1.o ii�",w'. -A'^
Requested Due Date: Project#: Pace Profile#: 13456 I NC
•
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SAMPLE ID sad s>_ e START END
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Sample ids must be unique n,�,,, ,� o a ors, c µ ^�
tri os o r m s I 47, 3z
1 DATE TIME DATE TINE : P R _ = 2 Z i O : - .. cc
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PRINT Name of SAMPLER- v'
22 SIGNATURE of SAMPLER .11 DATE Signed: r]jn/ _��e a 3 r S 2 v, q
t.
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ristnt Mama: • - Document Ortobel%ran
�, , r. SdztrDocutt�tt Namsafe Pit 2 ail
want(kthoriSTA
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c top half of box N pH and/or&chlorination is
verified and whie theaueptance range far preservation proms W0# le 92551643
samples. •
8070FLI4VOA,Carom.Tcodandsr �� PM : KPD Due Date : 07/28/21
•
'°BOA half of box Is to list number of bottles )/8015(water
WigCLIENT : 92—GFLENV '
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Samp(Q ID Type of Preservative p
pH upon receipt Date preservation adjusted Time presorvatfort '1►1°3/Of P111-41Yative let 4 i
°dJ d aided • ; 1
•
, I
re: Me-never there Cs a discrepancy1
affecting North Carolina compliance samples, a copy of this form wf l be rent to the North Carnm1(OnCartificatian OHka p.a i
i
t of hold, incorrect presentative,out of temp,incorrect contxlners.
i
1.NT/•- ..n YI{7 Y-TifY../�1^ J'. I., I 1n� . .- .. .. .. ... . ... .. • ♦- •, ,
Page `I0of11

i
r -ceAnaIical •
rJ 01.'JW(1006r.xmlo
1' Sample Receiving Non-Conformance Form (NCF)
�y 21 1v�,t. :.�P :�♦. :t
i:{'- ;.i:Tt.V;; '. i .1 ,f 7 �. ley{••i�1lvl,�i}�.li�.•:f 1i:•FJ.�o t - 1;1 •;: •;:,•�•t$: '�4yh ::cvleM...<:• • •� ±�P .11 rO ' 1v' 4 % Affix Workorder/Login Label Here or List Pace
,•« ��.. �• •� .t 4 ♦• ,l�::"sG�..:'i •� 4 1� i.YT•:l''f{ V �F�� 7 ••lt�♦� •' " ` • t ^ �' "` . "�` Workorder Number or �ATJL Log-in Number
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1 . If Chain-of-Custody (COC) is not received: contact client and if necessary, fill out a COC and indicate that it was filled out by
lab personnel. Note Issues on this NCF.
_2. If COC is incomplete, check applicable issues below and add details where appropriate:
Collection date/time missing or Analyses or analytes: missing or Samples listed on COC do not match samples
Incorrect ' clarification needed received (missing, additional, etc.)
Sample IDs on COC do not . .
match sample labels Required trip blanks were not received Required signatures are missing
Comments/Details/Other Issues not listed above:
•
3. Sample Integrity Issues: check applicable issues below and add details where appropriate:•f
Samples: Condition needs to be brought to -
Samples: Past holding time lab personnel's attention (details below) Preservation: Improper
Temperature: not within acceptance criteria (typically
Samples: Not field filtered Containers: Broken or compromised 0-6C)
Samples: Insufficient volume
received Containers: Incorrect Temperature: Samples arrived frozen
Samples: Cooler damaged or Custody Seals: Missing or compromised on
compromised samples, trip blanks or coolers Vials received with improper headspace
Samples: contain chlorine or
sulfides Packing Material: Insufficient/improper Other:
Comments/Details:
4. If Samples not preserved properly and Sam le Receiving adjusts pH, add details below: I I
Sample ID: 'F- 1Ven Date/Time:7 z641 Z=/& f� Amounl/type Ares added: 1. Fel G- 1�17 59L1
Preserved by: (Ia G Initial and Final pH: kb 4` / 1 ' _ Lot # ofpres added: (� �7 Z I �� C7 -
Sample ID: V 1 v � Date/Time: 7/2 b/Z I Z.. :f( f m Amount/type ores added: it2- mL tJ7 S8il
Preserved by: 4 tylejt, F. Initial and Final pH: 4I• ( 7/ / Lot # of pres added: 0 6 0- Z 1 - q C C-, 1
Amount/type pres added:
Sample ID: Date/Time:
Preserved by: Initial and Final pH:
Lot # ofpres added:
5. Client Contact: if client is contacted for any issue listed above, fill In details below:
Client: Contacted per:
PM Initials: Date/Time: —
Client Comments/Instructions:
f
.
.
•
F-ALL-C-01 1 -rev.00, 05Ju1201 8
Page11lf11
1

Debra Batten ATTACHM ENT 6
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,
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 8IHolly Springs, NC 27540
Office: [phone] I Cell: [phone] 1
Town Website: www.hollyspringsnc.us
.
___99
gly )
1
1
1

The Town of •
. f f H L LY Utilities and Infrastructure
Water Resources
SPRINGS
June 29, 2021
Mr. John W. Roberson
South Wake County Landfill
P.D. Box 550
Raleigh, NC 27602
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Subject: Notice of Violation(s)
Sewer Discharge Permit No. (IUP) 001
Dear 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 IUP 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 24th 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 parameter(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 violation(s)
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 er 1y, /
,7
_44. 401 _d--/•---"
ebra Batte •
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 be taken in regards to the Notice of Violation(s) 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 8IHolly Springs, NC 27540
Office: [phone] I Cell: [phone]
Town Website: www.hollyspringsnc.us
b. l
`lat3y
1

The Town of
HOLLY
IN izieyjf
Utilities and Infrastructure
SPRINGS
41/1"...,401
Water Resources
July 1 , 2021
Mr. John W. Roberson
South Wake County Landfill
P.O. Box 550
Raleigh, NC 27602
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Subject: Actions Required in response to the Violation(s) 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, SWL 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 II 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.
Si rely,
1 br /Batten
Environmental Compliance Manager
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
l) 919.746.9624 C 919.758.0054
Dewberry.
www.dewberry.com
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for someone
else, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
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•
' 0
- --) f;
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- --
environmental
- - - South Wake Landfill I 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 2754o
Reference: IUP ooi - Response to Notice of Violation Dated June 29, 2021
South Wake Landfill
633o 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, 2021 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 10.99 standard units (S.U.) on a field log sheet. A GFL operator also entered the
pH value of 10.99 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 10.99 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 10.99 S.U.
against the pH limits in IUP Permit during preparation of the DMR prior to submission to the
Town of Holly Springs.

environmental South Wake Landfill I 6330 Old Smithfield Rd. I 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 4o 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.o 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 — io.o 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,
t ee_ 9 IC)
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 Utilities and Infrastructure
1,1 Water Resources
SPRINGS
June 29, 2021
Mr. John W. Roberson
South wake County Landfill
P.O. Box 550
Raleigh NC, 27602
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Subject: Notice of Violation(s)
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 IUP, 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 24th 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), a.nd 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 II 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 (#3).
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 violation(s)
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].
Si c r- ly,
D bra IASIO ;;/(-
En ironmental Compliance Manager
Utilities and Infrastructure, Town of Holly Springs
Cc: Seann Byrd, Water Resources Director
George Metcalf, GFL

ATTACHMENT 8
Debra Batten
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 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.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.
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.
1

ATTACHMENT 9
Debra Batten
From: Seth Gundersen <[e-mail]>
Sent: Wednesday, August 4, 2021 4:14 PM
To: Debra Batten
Cc: George Metcalf; 'Levesque, Kevin'
Subject: --[EXTERNAL]--New Pump!
Good Afternoon Debbie,
I wanted to give you a heads-up on a few different items.
First, We have ordered a VFD pump and controller so that we can finally accommodate a semi-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 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.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.
-- - -
CAUTION: his en-iail onJnu ed from outside of '1 iE' hrg>;ini bUion. 'Do not r. lick links or-open
01'. el ? , .,^ c .. ,� ,( j'b l� .o q � ,,: w ' i9o. li[) t ..,'tj . hTh ' a. � �...';
i.
1

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 I C [phone] I [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 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 8IHolly Springs, NC 27540
Office: [phone] f Cell: [phone]
Town Website: hollyspingsnc.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.
1

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,
I wanted to give you a heads-up on a few different items.
First, We have ordered a VFD pump and controller so that we can finally accommodate a semi-
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 I Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 I C [phone] I seth.qundersenqflenv.com 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 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.
CAUTION..: his email originated from outside of the organization. Do not click links or
., .1 .hments unless you recognize tl .,ender and know the content is safe.
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
CAUTION: ail originated from outside of the organization . Do not click links or open
4a mitts unless you recognize the sender and know the content is safe.
2

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 8IHolly Springs, NC 27540
Office: [phone] I Cell: [phone]
Town Website: hollyspingsnc.gov
1 y ( ''
0
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: Thursday, August 12, 2021 9:43 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 a DMR-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 1 Operations Supervisor I
GFL Environmental
I
1

6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 I C [phone] I seth.gundersen(a�gflenv.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 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.
CAUTION: ; . : it originated from outside of the organization. Do not click links or open
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2

ATTACHMENT i 0
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 15th 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 8IHolly Springs, NC 27540
Office: [phone] I Cell: [phone]
Qler
Town Website: hollyspingsnc.gov
r
1
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.
2

ATTACHMENT i 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.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.
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 you recognize the
sender and know the content is safe.
If you would please include this request on Letter Head and email it as an attachment. Also, 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
1

PO Box 8IHolly 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.
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' <[e-mail]>
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 I Operations Supervisor I
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31523 I C [phone] I seth.gundersen(c gflenv.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 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.
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.
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
2

CAUTION: I his email originated from outside of the organization. Do not click links or open
N. is unless you recognize the sender and know the content is safe.
3

•
ii
GREEN FOR LIFE
environmental 3301 Benson Drive, Suite 601 I Raleigh, NC 27609
I
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,
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 GS2OX 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
Water Resources
H 4 L L Y S Environmental Compliance
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,
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 (SWL) 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.
Kindeyst Regards,
De f ' atten
vironmental Compliance Manager
Wter Resources/ Town of Holly Springs
PO Box 8IHolly 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

ATTACHMENT y 2
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,
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 8IHolly 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.

Utilities and Infrastructure
The Town of
Water Resources
's HOLLY
Environmental Compliance
`--- SPRINGS 4
SIU Inspection Form ATTACHMENT y
Name of Industry: South Wake Landfill IUP # 001
Address of Industry: 6530 Old Smithfield Rd IUP Expiration Date: , 12/31/2023
Apex, NC 27539
Industry Representatives: Seth Gundersen Title: Operations Supervisor
Maxine Oakley Title: Office Coordinator
POTW Representatives: Debra C. Batten Title: Environmental Compliance Manager
Katelyn Tresino Title: Laboratory Technician
Date of Inspection: 11/10/21 Time of Inspection: 2:30 am/pm
Purpose of Inspection: Annual ✓ Other (Describe)
POTW to which IU discharges Town of Holly Springs NPDES # 0063096
Is SN 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 YES / NO
Raw materials used YES / NO
Manufacturing processes YES / NO N/A
Categorical, if applicable YES / NO
Production rate YES / NO 15,000/day, 13,000 is pump and haul to Lumberton
WWTP. Number of employees 15
Number of shifts 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
1. Are there floor drains in the production area? YES / NO Where do they go? Secondary Containment
goes to Stormwater.
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 Where do they go? N/A
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? Pump and Haul or Sludge back to landfill
•
Title: SIU Inspection Form
File name: Y:\Departments\Utilities & Infrastructure\Water Resources\_Lab--Pretreatment\Pretreatment\Pretreatment
Program\Inspections\SWL\SWLInspection 111021.rtf
Revision data: November 16,2021 Page 1

Utilities and Infrastructure
e The Town of
Water Resources
HOLLY Environmental Compliance
p-- SPRINGS
SIU Inspection Form
7. When is the production area cleaned? As needed according to rain events
8. Is the wastewater from cleaning the production area discharged to the POTW? YES / NO
9. What non-process wastewaters are discharged to POTW? All discharge going to POTW are from
leachate and condensate
Comments:
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
Comments:
PART II - Plant Tour Section C - SAMPLING POINT(S) 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 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: It has been recommended that SWL have traceability references for calibration for field
equipment included from the contract lab for all compliance data analyzed at time of collection. This can be
included on the final lab report.
3. Do results in files agree with reports sent to POTW? YES / NO
Comments:
Title: SIU Inspection Form
File name: Y:\Departments\Utilities & Infrastructure\Water Resources\ Lab--Pretreatment\Pretreatment\Pretreatment
Program\Inspections\SWL\SWLlnspection111021.rtf •
Revision data: November 16,2021 Page 2

The Town of
Utilities and Infrastructure
Water Resources
HOLLY SPRINGS 1 Compliance
'
ance
Environmental
SIU Inspection Form
4. Who has authority to shut down production should a spill or slug discharge occur?
George Metcalf/ General Manager, Seth Gundersen/ Operations Manager, and Mike Heffron/
Operator
5. How does SIU inform employees of whom to call at POTW in case of spill/slug? Initial training, Signs are
posted throughout the facility(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 SIU 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.
r
Signature of Inspectors) 46400 tf .7 Date: //-1.7
J
,21
Date: , t
Staff Present: Seth Gundersen - Operations Supervisor and Maxine Oakley — Office Coor.
Title: SIU Inspection Form
File name: Y:\Departments\Utilities & Infrastructure\Water Resources\ Lab--Pretreatment\Pretreatment\Pretreatment
Program\Inspections\S WL\S WLlnspection 111021.rtf
Revision data: November 16,2021 Page 3

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ATTACHMENT 1 3
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 16th 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 8IHolly Springs, NC 27540
Office: [phone] I Cell: [phone]
Town Website: h©Ilvspingsnc.gov
Q61°H#
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: 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 Wake LF has request a meeting on November 16th @ 1:00pm 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
1

6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31521 I C 919-604-2273 I george.metcalf c(Dgflenv.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 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.
•
•
CAUTION: his email originated from outside of the organization. Do notdick links or open
is unless you recognize the sender and know the content is safe.
2

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 1:00pm to discuss the upgrades we'd like to implement
at South Wake Landfill?
George Metcalf I Landfill General Manager II
GFL Environmental
6330 Old Smithfield Road, Apex, NC, 27539
T [phone] Ext. 31521 I C 919-604-2273 I [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 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.
This email originated from outside o_f, the organization. Do not dick links or open
attachments unless you recognize the sender and know the content is safe.
i

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ATTACHMENT 16
Industry Name: South Wake
Land Fill 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
IUP #/Pipe # 001 specific changes, an then reinstate protection again.
Reporting 1/1/2021 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: 6/30/2021 (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: TRC (>=33%) SNC definition specifically exempts pH.
1/2 Detection X *Not Required to apply
Level (DL) entered Chronic or TRC SNC
FLOW BOD TSS Oil & Grease
Sample Daily Daily Daily
Type- Daily Flow
Sample Date MGD Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
P=POTW, I Mg/L Mg/L Mg/L
Inrii ictry
Permit Limit 0.050
TRC Limit 0.060 Optional*
Reg TRC Reg TRC Reg TRC Reg TRC
1/4/2021 I 0.007 63 70
1/11/2021 I 0.008 118 51
1/18/2021 I 0.007 798 1500
1/25/2021 I 0.008 996 1410
2/1/2021 I 0.005 344 5550
2/8/2021 I 0.005 204 76
2/15/2021 i 0.006 59 206
2/16/2021 P 0.006 59 120
2/17/2021 P 0.008
2/22/2021 I 0.008 58 164
3/1/2021 I 0.006 205 86
3/8/2021 I 0.005 996 254
3/15/2021 I 0.005 716 408
3/22/2021 I 0.004 870 747
3/23/2021 p 0.004
3/29/2021 I 0.002 693 540
4/5/2021 I 0.002 388 428 <5.0
4/12/2021 I 0.004 447 327
4/19/2021 I 0.004 192 302
4/26/2021 I 0.003 366 2080
5/3/2021 I 0.003 310 656
5/10/2021 I 0.002 109 99
5/18/2021 I 0.002
5/26/2021 I 0.004
6/1/2021 I 0.004 26 106
6/7/2021 I 0.004 117 69
6/14/2021 I 0.005 38 160
6/21/2021 I 0.005 47 158
6/29/2021 I 0.007 358 312
Average of Column 0.005 37Q, 693
Total Samples 26 0 0 22 0 0 22 0 0 1 0 0
% Violations* 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0
% TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 %
*SNC ? NO SNC ? NO SNC ? NO SNC ? NO

1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells
specific changes, an then reinstate protection again. specific changes, an then reinstate
2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Det(
(Note use second option only when detection level at or below limit) (Note use second option only when
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than". NOTE - Spreadsheet corrected Fek
*Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (:
**pH: TRC (>=33%) SNC definition specifically exempts pH. **pH: TRC (>=33%) SNC definitior
** TRC doesn't a• •I t• •H
pH AMMONIA ARSENIC CADMIUM CHROMIUM
Daily Daily 1 Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L ' Mg/L Mg/L Mg/L
10.00 r
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
8.20 I 358 I ,
8.40 I 376
8.30 268
6.70 187
6.00 484
5.97 544
7.40 533
• 587 0.004 0.21
8.16
7.33 582
7.50 721
-
6.52 754
7.40 928 ,
7.50 1280
8.44 0.010 0.03
7.60 --- 1290 -- -
7.30 1180 0.005 0.33
8.20 1220
7.00 1340 ,
6.90 1220
6.50 1490
10.99 1.00 1350
5.91 914 ,
7.10 • 706
8.30 788
8.30 742
8.30 774
7.45 832 0.006 0 190
23 1 22 0 0 0 0 0 3 0 0 3 0 0
% Violations 4.3 % % Violations 0.0 % % Violations % % Violations 0.0 % % Violations 0.0 %
TRC Violations N/A % % TRC Violations 0.0 % % TRC Violations % % TRC Violations 0.0 % % TRC Violations 0.0 %
SNC ? No SNC ? NO SNC ? SNC ? NO SNC ? NO

only. All other cells protected. Password 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells only. All other cells protected. Pass
protection again. specific changes, an then reinstate protection again.
?ction" choose either to enter detection level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detection" choose either to enter detect
detection level at or below limit) (Note use second option only when detection level at or below limit)
> 09 to properly assess TRC violations using "equal to or greater than". NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violatio
>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "r
i specifically exempts pH. **pH: TRC (>=33%) SNC definition specifically exempts pH.
COPPER CYANIDE LEAD MERCURY MOLYBDENUM
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
0.025 0.025
0.0430
0.100 0.005
0.035 0.0150 0.000 0.000200 0.045
0 053 0.0101 0 000200 0.045
3 0 0 2 0 0 3 0 0 1 0 0 1 0 0
Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 %
% TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 %
SNC ? NO SNC ? NO SNC ? NO SNC ? NO SNC ? NO

— _..
;word 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only
specific changes, an then reinstate protection again.
:ion level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and r
(Note use second option only when detection level at or below limit)
ns using "equal to or greater than". NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
)ollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not requirec
**pH: TRC (>=33%) SNC definition specifically exempts pH.
NICKEL PHENOL SELENIUM SILVER ZINC
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
0.158 0.46
0.200 0.67
0.179 0.56
2 0 0 0 0 0 0 0 0 0 0 0 2 0 0
Violations 0.0 % % Violations % % Violations % % Violations % % Violations 0.0 %
TRC Violations 0.0 % % TRC Violations % % TRC Violations % % TRC Violations % % TRC Violations 0.0 %
SNC ? NO SNC ? SNC ? SNC ? SNC ? NO

Industry Name: South Wake
Land Fill 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
IUP #/Pipe # 001 specific 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: 12/31/2021 (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: TRC (>=33%) SNC definition specifically exempts pH.
1/2 Detection X Not Required to apply
Level (DL) entered Chronic or TRC SNC
FLOW BOD TSS Oil & Grease
Sample Daily Daily Daily
Type- Daily Flow
Sample Date yp MGD Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
P=POTW, I Mg/L Mg/L Mg/L
Inrii ictry
Permit Limit 0.050
TRC Limit 0.060 Optional* L
Reg TRC Reg TRC Reg TRC Reg TRC
8/2/2021 I 0.003 572 43
8/9/2021 I 0.003 300 556
8/16/2021 I 0.004 494 600
8/23/2021 I 0.003 410 487
8/30/2021 I 0.002 569 400
8/31/2021 P 0.005 771 500 <5.0
9/1/2021 A 0.005
9/7/2021 I 0.005 956 357
9/13/2021 I 0.002 628 708
9/20/2021 I 0.002 589 664
9/27/2021 I 0.002 804 239 ,
10/4/2021 I 0.004 490 17 <5.0
10/11/2021 I 0.003 490 530
10/18/2021 I 0.003 789 50 ,
10/25/2021 I 0.004 846 576 ,
12/6/2021 I 0.003 866 180 <5.0
12/13/2021 I 0.002 1520 178 _ ,
12/20/2021 I 0.002 2150 383
12/27/2021 I 0.002 2630 560
r
i
Average of Column 0.003 88Z_ 390
Total Samples 19 0 0 18 0 0 18 0 0 3 0 0
% Violations" 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 %
% TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 %
*SNC ? NO SNC ? NO SNC ? NO SNC ? NO

1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells
specific changes, an then reinstate protection again. specific changes, an then reinstate
2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detf
(Note use second option only when detection level at or below limit) (Note use second option only when
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than". NOTE - Spreadsheet corrected Fet
*Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (:
**PH: TRC (>=33%) SNC definition specifically exempts pH. **oH: TRC (>=33%) SNC definitior
** TRC doesn't a• •1 t• •H
PH AMMONIA ARSENIC CADMIUM CHROMIUM
Daily Daily I Daily Daily Daily
Concentration Violation Type Concentration Violation Type i Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
10.00
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
8.30 1010
8.30 1130
8.40 1360 0.086 0.010 0.39
8.31 1160
8.20 1020
8.07 1095 0.058 0.004 0.33
8.00 1370 0.083 0.001 0.34
8.00 1180
8.00 1270
7.95 985
7.80 1150 0.064 0.001 0.37
7.98 1130
8.00 1470
8.10 1150
8.40 1700 0.100 0.005 0.47
8.60 1560
8.20 1850
7.80 1480
8.13 1 282 0.078, 0 004 0.381
18 0 18 0 0 5 0 0 5 0 0 5 0 0
Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 %
% TRC Violations % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0
SNC ? SNC ? NO SNC ? NO SNC ? NO SNC ? NO

only. All other cells protected. Password 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells only. All other cells protected. Pass
protection again. specific changes, an then reinstate protection again.
action" choose either to enter detection level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detection" choose either to enter detect
detection level at or below limit) (Note use second option only when detection level at or below limit)
> 09 to properly assess TRC violations using "equal to or greater than". NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violatio
>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "K
I specifically exempts pH. **DH: TRC (>=33%) SNC definition specifically exempts pH.
COPPER CYANIDE LEAD MERCURY MOLYBDENUM
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
0.028 0.0380 0.050
0.040 0.0090 0.012 0.000200 0.063
0.018 0.019
0.005 <0.0080 11.600 0.002000 0.049
0.025 <0.0080 0.025
0.023 2.341 0.001100 0 056
5 0 0 4 0 0 5 0 0 2 0 0 2 0 0
Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 %
% TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 %
SNC ? NO SNC ? NO SNC ? NO SNC ? NO SNC ? NO

;word 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only
specific changes, an then reinstate protection again.
:ion level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and r
(Note use second option only when detection level at or below limit)
ns using "equal to or greater than". NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
)ollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not requires
*pH: TRC (>=33%) SNC definition specifically exempts DH.
NICKEL PHENOL SELENIUM SILVER ZINC
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
0.240 0.008 0.87
0.201 0.008 0.60
0.200 -_ - 0.52
0.220 0.38
0.280 0.62
0.228 0.Q08 0.60
5 0 0 0 0 0 0 0 0 2 0 0 5 0 0
% Violations 0.0 % % Violations % % Violations % % Violations 0.0 % % Violations 0.0 %
% TRC Violations 0.0 % % TRC Violations % % TRC Violations % % TRC Violations 0.0 % % TRC Violations 0.0 %
SNC ? NO SNC ? SNC ? SNC ? NO SNC ? NO

ATTACHMENT 17
Pretreatment Annual Report (PAR) Control Authority,
Industrial Data Summary Form (IDSF) Town Name => Town of Holly Springs Industry Name South Wake Landfill
Use separate forms for each industry/pipe WWTP Name => Utley Creek WRF IUP # 001
Enter BDL values as < (value) NPDES # => NC0063096 Pipe # 001
1st 6 months, dates => 1/1/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
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
* Total # of samples => 144 143 27 27 27 27 27 27
* Maximum (mg/1) _> 0.0080 0.0070 996 2,630 5,550 708 1,490 1,850
* or Maximum (ib/d) => 62.3 50.4 231.6 20.8 45.1 52.2
* Average (mg/I) => 0.0045 0.0029 319.37 796.37 593.10 350.41 838.37 1,280.22
* or Average Loading (lb/d) => 12.68 18.82 23.61 8.57 27.92 32.00
% violations,(chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) _>
Arsenic (ug/L) Cadmium (ug/L) Chromium (ug/L) 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
* Total # of samples => 0 6 3 7 3 7
* Maximum (ug/l) => 100.0 <10.0 10.00 330.0 470
* or Maximum (lb/d) =>
* or Average (mg/1) => N/A
* or Average Loading (lb/d) _>
% violations, (chronic SNC is >= 66%) _> MONITOR ONLY
% TRC violations, (SNC is >= 33 %) _>
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
* Total # of samples => 3 7 2 6 3 7 1 2
* Maximum (ug/l) => <100.00 50.00 0.0430 0.0380 <25.00 11,600.00 <200.00 <2,000.00
* or Maximum (lb/d) =>
* or Average (mg/1) _>
* or Average Loading (ib/d) _>
% violations, (chronic SNC is >= 66%) _> MONITOR ONLY
% TRC violations, (SNC is >= 33 %) =>
BDL=> Below Detection Limit 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 WWTP=> wastewater treatment plant

Pretreatment Annual Report (PAR) Control Authority,
Industrial Data Summary Form (IDSF) Town Name => Town of Holly Springs Industry Name South Wake Landfill
Use separate forms for each industry/pipe WWTP Name => Utley Creek WRF IUP # 001
Enter BDL values as < (value) NPDES # => NC0063096 Pipe # 001
1st 6 months, dates => 1/1/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
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
* Total # of samples => 2 7 0 2 2 7
* Maximum (mg/1) => 200 280 <8.00 670 870
* or Maximum (lb/d) _>
* Average (mg/I) _> N/A
* or Average Loading (lb/d) =>
% violations,(chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) _>
Molybdenum (ug/L) Total Phosphorus (mg/L) Total Nitrogen (mg/L) Oil and Grease (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
* Total # of samples => 1 2 27.0 27.0 27 27 1 3
* Maximum (ug/l) => 45.0 63.4 61.0 12.7 1,760.2 2,220.2 <5.0 <5.0
* or Maximum (1b/d) _> 88.3 77.9
* or Average (mg/1) _> 13.07 9.74 1,104.7 1,493.0
* or Average Loading (lb/d) => 42.1 37.4
% violations, (chronic SNC is >= 66%) _>
TRC violations, (SNC is >= 33 %) _> 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
* Total # of samples => 28 27
* Maximum (ug/l) => 10.99 8.60
* or Minimum (lb/d) => 5.91 7.80
* or Average (mg/I) =>
* or Average Loading (lb/d) =>
% violations, (chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
BDL=> Below Detection Limit 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 WWTP=> wastewater treatment plant

ATTACHMENT 18
Town of Holly Springs
Utilities and Infrastructure
�... Water Resources
Industrial
Pretreatment Program
Industrial Self-Monitoring Permit Violation(s) Notification
From:
Industry Name: Seqirus, Inc. Date: 07-Jun-2021_
Industry Representative: Nilsa M. Serrano Time: 14:04
Representative's Phone #: [phone] Permit #: IUP-002
a.) As Part II 2. b.) 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 Units Date Results Received Date Results Reviewed
Limit
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 at [phone] to verify this email has been received If 1 am not able to take your call, please leave a message on my voice mail. You will be
contacted as quickly as possible to discuss the reported violation, and to determine the appropriate course of action.
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
HOLLY Utilities and Infrastructure
'` Water Resources
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
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 2450 lbs./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 26th. 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 7th, 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 8th, but samples were also on June 9th and 10th . 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 10th thru
May 11 th 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 th 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 Seqirus creates means, to make sure all sampling requirements of the permit are
scheduled on a routine 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 a t t 114\--)
Environmental 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
Qs,3)
ISKr ^�t.11 r-wswn?r d.cf
*Please check with the appropriate staff before visiting 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 <[e-mail]>
Sent: Friday, June 18, 2021 2:13 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: (919) 557-2907 I Cell: (919) 524-2509
Town Website: www.hollyspringsnc.us
„e:
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
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- h . p•. .s unless you recognize the sender and know the content is safes
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
5

CAUTION: • v va s t, of the organi ation. Do not click links or open
at c -me is unless you recognize the sender and know the content is safe.
6

D E Qs)
Please check with the appropriate staff before visiting 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 <[e-mail]>
Sent: Tuesday, June 22, 2021 10:40
To: Yitbarek, Diana <[e-mail]>
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 2750 mg/L 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 2509 lbs./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 % RPD of the sample spiked with a 0% 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*
3

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.
If 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 I Holly Springs, NC 27540
Office: (919) 557-2907 I Cell: (919) 524-2509
Town Website: 3.vww.hollyspringsnc.u:3
4.r
4 � 1
From: Yitbarek, Diana <[e-mail]>
Sent: Tuesday, June 22, 2021 6:23 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 lbs/day and a Daily Maximum of 3800 lbs/day for
chlorides. What was exceedance?
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
4

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.
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 § 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.
1

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 § 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.
Please let us know if you have any questions,
Best,
-Diana
Diana Yitbarek (she/her)
Engineer
T: 919-707-9130
[e-mail]
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
2

ATTACHMENT 19
Debra Batten
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 9th to the 12th. the 9th 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 8IHolly Springs, NC 27540
Office: [phone] I Cell: (919) 524-2509
Town Website: hollyspingsnc.gov
1

� k
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.
•
CAUTION: "his email originated from outside of the organization. Do not c i :k links or open
-. .you recognize the sender and know the content is safe.
2

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 8IHolly Springs, NC 27540
Office: [phone] I Cell: (919) 524-2509
Town Website: hollyspingsnc.gov
r I
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, 2021 3:25 PM
To: Serrano-Ortiz, Nilsa US/HSP <[e-mail]>
Cc: Rezek, Robert US/HSP <[e-mail]>; Lorusso, Ellen US/KOP <[e-mail]>
Subject: [EXT] RE: --[EXTERNAL]--RE: Sampling
EXTERNAL: This email originated from outside of the organization. Do not dick any links or open any attachments
unless you trust the sender and know the content is safe.
1

Mr. Resek will be the primary contact?
From: [e-mail] <[e-mail]>
Sent: Monday, August 2, 2021 3:24 PM
To: Debra Batten <[e-mail]>
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 9th to the 12th. the 9th 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 8IHolly Springs, NC 27540
Office: [phone] I Cell: [phone]
Town Website: hollyspingsnc.gov
2

4
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.
CAUTION: is email originated from outside of the organization. Do not click links or open
_.. .. . unless you recognize the sender and know the content is safa. ...
Warning: This email is subject to disclosure under the North Carolina Public Records Law (NCGS 132-1).
CAUTION: ;his email originated from outside of the organization. Do not click links or open
, .. , ,.. unless you recognize the sender and know the content is safe.
3

ATTAC HIM E NT 20
-_" a, Town of Holly Springs
�'da �; :per° esourc s
\\`�...
l Pf gc`< I Oriuiipil llidG e}
SIU Inspection Form
Name of Industry: IUP # 002
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 12/30/2021 10:27
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.
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020 Page 1

t
Town of Holly Springs
.s 1 Water Resources
/7ii ukzemllI ii is ll C oopp��lli )/id
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 adjustment 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

4 (. 1 Town of ��-iioHHy Sprit = as
Water Resources
Elv ron eng a 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? Boiler 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

HollySprings
, �, , Town of
d
Water Resources
l��i�) "Uli'<< lit7Girt7�?Gi)ts' 11 C oliiiivolli nc
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 TORS 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.
5. 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

r
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:
Inspector(s) Debra Batten (signature) .�'>�: Date: % e�4 f
Easton Rains (Signature) ,4 ���1111111111111° Date: /2/36 Zt
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020 Page 5

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ATTACHMENT 22
Industry Name: Seqrius I 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
IUP #/Pipe # 002 specific changes, an then reinstate protection again.
Reporting 1/1/2021 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: 6/30/2021 (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: TRC >=33%) SNC definition specifically exempts pH.
I'll-it. I\i.yu1 IL.0 w uNN'Y
1/2 Detection X Chronic or TRC SNC
Level (DL) entered
FLOW BOD TSS CHLORIDES
Sample Type- Daily Daily Daily
Sample Date P=POTW, I Daily FlowMGD Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Industry Mg/L Mg/L Mg/L
Permit Limit 0.250 2,033 J 3,800
TRC Limit 0.300 Optional* 2,440 1 4,560
Reg TRC Reg TRC Reg TRC Reg TRC
1/12/2021 I 0.096000 192.0 10 1 37 I 1/13/2021 I 0.071000 104.0
2/10/2021 I 0.091000 159.0 11 119 I ,
2/11/2021 I 0.094000 209.0 ,
2/12/2021 I 0.115000 496.0
3/9/2021 I 0.121000 193.0 15 738
3/10/2021 I 0.124000 319.0
3/11/2021 I 0.101000 266.0
4/13/2021 I 0.102000 418.0 16 I 286
4/14/2021 I 0.134000 1010.0
4/15/2021 I 0.126000 43.2
5/11/2021 I 0.106000 346.0 36 2550 * 1 .00
5/12/2021 I 0.117000 796.0
5/13/2021 I 0.135000 513.0
6/8/2021 P 0.111000 332.4 31 821
6/9/2021 I 0.122000 1870
6/10/2021 I 0.115000 41
6/15/2021 I 0.124000 872.0 14 172
6/16/2021 I 0.125000 680.0
6/17/2021 I 0.112000 1270.0
Average of Column 0.112100 456.6 18.91 737
Total Samples 20 0 0 18 0 0 7 0 0 9 0 0
% Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 11 .0 %
TRC Violation: 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 %
*SNC ? NO SNC ? NO SNC ? NO t SNC ? NO r a
s (2alic.;.:1 i-z) . 4.3.E .. ,;? I1 s./.4aA

* Chloride limit is 2450 Ibs/da

11) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells
specific changes, an then reinstate protection again. specific changes, an then reinstate
2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Det(
(Note use second option only when detection level at or below limit) (Note use second option only when
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than". NOTE - Spreadsheet corrected Fet
*Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (:
**pH: TRC (>=33%) SNC definition specifically exempts pH. **pH: TRC (>=33%) SNC definitior.
** TRC doesn't a.•I t• •H
pH AMMONIA ARSENIC CADMIUM CHROMIUM
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
10.000
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
7.60 0.310
7.90
7.60 0.800 0.010 0.0010 0.008
7.10
7.90
8.10 1 .700
7.90
8.20 I
8.20 5.100 I _
7.60
7.40
8.30 6.800
7.80
7.80
7.81 4.260 0.001 0.0002 0.005
8.30
7.50
7.60 3.500
7.90
7.40
I
7.80 _ 3.210 0.01 0.0006 0.006
20 0 7 0 0 2 0 0 2 0 0 2 0 0
% Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 %
TRC Violations % % TRC Violations 0.0 % % TRC Violations 0.0 % % 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 lbs/day

only. All other cells protected. Password 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells only. All other cells protected. Pass
protection again. specific changes, an then reinstate protection again.
action" choose either to enter detection level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detection" choose either to enter detect
detection level at or below limit) (Note use second option only when detection level at or below limit)
i 09 to properly assess TRC violations using "equal to or greater than". NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violatio
>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow. `Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term
t specifically exempts pH. **pH: TRC (>=33%) SNC definition specifically exempts pH.
COPPER CYANIDE LEAD MERCURY MOLYBDENUM
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
0.000001
0.006 0.005 0.000004
I
0.000001
0.000020
0.000028
0.011 0.005 0.000200
0.000016
1
0.008 0.0050 0.000039
2 0 0 0 0 0 2 0 0 7 0 0 0 0 0
% Violations 0.0 % % Violations % % Violations 0.0 % % Violations 0.0 % Violations
%
°
% TRC Violations 0.0 % % TRC Violations % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations
SNC ? NO SNC ? SNC ? NO SNC ? NO SNC

;word 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only
specific changes, an then reinstate protection again.
:ion level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and r
(Note use second option only when detection level at or below limit)
ns using "equal to or greater than". NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
)ollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not requirec
**pH: TRC (>=33%) SNC definition specifically exempts pH.
NICKEL PHENOL SELENIUM SILVER ZINC
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
0.005 0.010 0.005 0.010
I
0.005 0.002 0.000 0.011
I
0.0050 0.01 0.00 0.01
2 0 0 0 0 0 2 0 0 2 0 0 2 0 0
% Violations 0.0 % % Violations % % Violations 0.0 % % Violations 0.0 % % Violations 0.0 %
% TRC Violations 0.0 % % TRC Violations % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 %
SNC ? NO SNC ? SNC ? NO SNC ? NO SNC ? NO

Industry Name: Segrius 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make
IUP #/Pipe # 002 specific 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: 12/31/2021 (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: TRC (>=33%) SNC definition specifically exempts pH.
IvvL . UU�.0 tv aNN'Y
1/2 Detection X Chronic or TRC SNC
Level (DL) entered
FLOW BOD TSS CHLORIDES
Sample Type- Daily Daily Daily
Sample Date P=POTW, I- Da ViolationViolation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Industry Mg/L Mg/L Mg/L
Permit Limit 0.250 2,033 3,800
TRC Limit r 0.301 Optional* 2,440 4,560
Reg TRC Reg TRC Reg TRC Reg TRC
7/7/2021 I 0.103000 728.0 12 451
7/8/2021 I 0.105000 898.0
7/9/2021 I 0.111000 80.5
7/14/2021 I 0.111000
8/10/2021 I 0.135000 224.0 9 91
8/11/2021 I 0.113000 837.0
8/12/2021 I 0.130000 873.0
8/25/2021 P 0.108000 727.0 17 95
9/8/2021 I 0.111000 410.0 6 464
9/9/2021 I 0.099000 335.0
9/10/2021 I 0.088000 208.0
10/5/2021 I 0.074000 258.0 15 189
10/6/2021 I 0.120000 335.0
10/7/2021 I 0.105000 1720.0
11/9/2021 I 0.043000 612.0 7 80
11/10/2021 I 0.054000 12.0
12/7/2021 I 0.052000 0.0 6 54
12/8/2021 i 0.062000 11 .0
Average of Column 0.095778 486.4 10.04 203
Total Samples 18 0 0 17 0 0 7 0 0 7 0 0
% Violations 0.0 % % Violations 0.0 % % Violations 0.0 % % Violations 0.0
TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations 0.0 %
*SNC ? NO SNC ? NO SNC ? NO SNC ? NO

1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells
specific changes, an then reinstate protection again. specific changes, an then reinstate
2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Deb
(Note use second option only when detection level at or below limit) (Note use second option only when
NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than". NOTE - Spreadsheet corrected Fek
'Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC
**pH: TRC (>=33%) SNC definition specifically exempts pH. **pH: TRC (>=33%) SNC definitior.
** TRC doesn't a• •I to •H
pH AMMONIA ARSENIC CADMIUM CHROMIUM
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
10.000
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
7.60 3.900
7.30
6.90
7.20
8.30 2.200
7.40
7.80
7.97 2.490 0.0002 0.009
7.60 1 .800
8.50
7.20
7.00 2.400
7.20
8.60
7.03 0.340
6.95
6.40 0.100
6.80
7.43 1 .890 0.0002 0.009
18 0 7 0 0 0 0 0 1 0 0 1 0 0
Violations 0.0 % % Violations 0.0 % % Violations % % Violations 0.0 % % Violations 0.0 %
TRC Violations % % TRC Violations 0.0 % % TRC Violations % % 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 1) Data entry in blue bordered cells only. All other cells protected. Pass
protection again. specific changes, an then reinstate protection again.
action" choose either to enter detection level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detection" choose either to enter detect
detection level at or below limit) (Note use second option only when detection level at or below limit)
> 09 to properly assess TRC violations using "equal to or greater than". NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violatio
>=33%) SNC definitions use term "pollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "
i specifically exempts pH. **pH: TRC (>=33%) SNC definition specifically exempts pH.
COPPER CYANIDE LEAD MERCURY MOLYBDENUM
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
0.000036
0.000005
0.009 0.005
0.000003 I
0.000004
0.000001
0.000003
..
0.009 _ 0.0050 0.000009
1 0 0 0 0 0 1 0 0 6 0 0 0 0 0
Violations 0.0 % % Violations % % Violations 0.0 % % Violations 0.0 % % Violations %
% TRC Violations 0.0 % % TRC Violations % % TRC Violations 0.0 % % TRC Violations 0.0 % % TRC Violations
SNC ? NO SNC ? SNC ? NO SNC ? NO SNC ?

;word 3. Strongly Recommend only unprotect to make 1) Data entry in blue bordered cells only. All other cells protected. Password 3. Strongly Recommend only
specific changes, an then reinstate protection again.
:ion level or 1/2 detection level and mark choice in cell B5. 2) For data reported as "Below Detection" choose either to enter detection level or 1/2 detection level and r
(Note use second option only when detection level at or below limit)
ns using "equal to or greater than". NOTE - Spreadsheet corrected Feb 09 to properly assess TRC violations using "equal to or greater than".
)ollutant," so technically not required to apply to flow. *Flow: Chronic (>=66%) and TRC (>=33%) SNC definitions use term "pollutant," so technically not requirec
**pH: TRC (>=33%) SNC definition specifically exempts pH.
NICKEL PHENOL SELENIUM SILVER ZINC
Daily Daily Daily Daily Daily
Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type Concentration Violation Type
Mg/L Mg/L Mg/L Mg/L Mg/L
Reg TRC Reg TRC Reg TRC Reg TRC Reg TRC
./1 1
0.007 0.014
-- - ,
,
0.0067 _ 0.01
1 0 0 0 0 0 0 0 0 0 0 0 1 0 0
% Violations 0.0 % % Violations % % Violations % % Violations % % Violations 0.0 %
% TRC Violations 0.0 % % TRC Violations % % TRC Violations % % TRC Violations % % TRC Violations 0.0 %
SNC ? NO SNC ? SNC ? SNC ? SNC ? NO

ATTACHMENT 23
Pretreatment Annual Report (PAR) Control Authority,
Industrial Data Summary Form (IDSF) Town Name => Town of Holly Springs Industry Name Seqirus
Use separate forms for each industry/pipe WWTP Name => Utley Creek WRF 1UP # 002
Enter BDL values as < (value) NPDES # _> NC0063096 Pipe # .�62-- co
1st 6 months, dates => 1/1/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
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
* Total # of samples => I 181 183 18 17 7 7 7 7
* Maximum (mg/1) _> 0.157000 0.139000 1,270 1,720 36.2 17.3 6.8 3.9
* or Maximum (lb/d) _> 1,300.9 1,834.7 _
* Average (mg/1) _> 0.103746 0.075295 456.6 486.4 18.9 10.0 3.210 1.890
* or Average Loading (Ib/d) => 450.5 439.2
% violations,(chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) => MONITOR ONLY
Arsenic (ug/L) Cadmium (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
* Total # of samples => 2 0 2 1 2 1 9 7
* Maximum (ug/l) _> <10.0 <1.000 <0.200 7.6 9.4 2550 464
* or Maximum (lb/d) _> 2,721.7 426.4
* or Average (mg/1) => 737 203
* or Average Loading (lb/d) => 722.9 162.8
% violations, (chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) => 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
* Total # of samples => 2 1 2 2 2 1 7 6
* Maximum (ug/1) _> 11.0 9.1 <0.0100 <0.0080 <5.0 <5.0 200.0 36.0
* or Maximum (lb/d) => _
* or Average (mg/1) => 38.5 8.6
* or Average Loading (lb/d) _>
% violations, (chronic SNC is >= 66%) _>
MONITOR ONLY
% TRC violations, (SNC is >= 33 %) =>
BDL=> Below Detection Limit 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 WWTP=> wastewater treatment plant

Pretreatment Annual Report (PAR) Control Authority,
Industrial Data Summary Form (IDSF) Town Name => Town of Holly Springs Industry Name Seqirus
Use separate forms for each industry/pipe WWTP Name => Utley Creek WRF IUP # 002
Enter BDL values as < (value) NPDES # _> NC0063096 Pipe # , kEe- DO/
1st 6 months, dates => 1/1/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
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
* Total # of samples => 2 1 2 0 2 0 2 1
* Maximum (mg/1) _> <5.0 6.7 <10.0 <5.0 10.7 13.8
* or Maximum (lb/d) =>
* Average (mg/1) =>
* or Average Loading (lb/d) =>
% violations,(chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) => MONITOR ONLY
Total Nitrogen (mg/L) Total Phosphorus (mg/L) pH (s.u)
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months J 2nd 6 months 1st 6 months 2nd 6 months
* Total # of samples => 7 7 7 7 20 18
* Maximum (ug/l) => 38 35 8.30 8.60
* or Maximum (lb/d) _> 24.4 28.2 7.10 6.40
* or Average (mg/1) _> 22.66 16.03
* or Average Loading (lb/d) => 12.7 14.9
% violations, (chronic SNC is >= 66%) _>
MONITOR ONLY
% TRC violations, (SNC is >= 33 %) =>
Benzene (ug/L) Chlorobenzene (ug/L) Chloroform (ug/L) 1,2 Dichloroethane (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
* Total # of samples => 2 1 2 1 2 1 2 1
* Maximum (ug/1) => <5.0 <40.0 <10.0 <80.0 <10.0 <20.0 <5.0 <80.0
* or Maximum (lb/d) =>
* or Average (mg/1) => <5.7 <20.0
* or Average Loading (lb/d) =>
% violations, (chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) _>
BDL=> Below Detection Limit 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 WWTP=> wastewater treatment plant

Pretreatment Annual Report (PAR) Control Authority,
Industrial Data Summary Form (IDSF) Town Name => Town of Holly Springs Industry Name Seqirus
Use separate forms for each industry/pipe WWTP Name => Utley Creek WRF IUP # 002
Enter BDL values as < (value) NPDES # _> NC0063096 Pipe # ,,G0-2-00/
1st 6 months, dates => 1/1/2021 6/30/2021
2nd 6 months, dates => 7/1/2021 12/31/2021
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
* Total # of samples => 2 1 2 1 2 1 2 1
* Maximum (mg/1) => <10.0 <80.0 <5.0 <40.0 _ 3,480.0 6,710.0 <100.0 , <120.0
* or Maximum (lb/d) _>
* Average (mg/1) _>
* or Average Loading (Ib/d) =>
% violations,(chronic SNC is >= 66%) =>
% TRC violations, (SNC is >= 33 %) =>
I
4-Methyl-2-pentanone (ug/L) Isobutyralhyde (ug/L) n-Amyl acetate (ug/L) n-Butyl acetate (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
* Total # of samples => 1 0 1 0 1 0 1 0
* Maximum (ug/1) _> <50.0 <50.0 <50.0 <25.0
* or Maximum (lb/d) =>
* or Average (mg/I) =>
* or Average Loading (lb/d) =>
% violations, (chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) => 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
* Total # of samples => 2 1 1 0 1 0 1 0
* Maximum (ug/I) _> <500.0 <4,000.0 <50.0 <500.0 <25.0
* or Maximum (lb/d) _>
* or Average (mg/1) =>
* or Average Loading (lb/d) =>
i
% violations, (chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) _> MONITOR ONLY
BDL=> Below Detection Limit mg/I => 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 WWTP=> wastewater treatment plant

Pretreatment Annual Report (PAR) Control Authority,
Industrial Data Summary Form (IDSF) Town Name => Town of Holly Springs Industry Name Seqirus
Use separate forms for each industry/pipe WWTP Name => Utley Creek WRF IUP # 002
Enter BDL values as < (value) NPDES # _> NC0063096 Pipe # ..ger oar
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) o-Dichlorobenzene (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
* Total # of samples => 2 1 1 0 1 0 1 0
* Maximum (mg/I) => <250.0 <2,000.0 <50.0 <50.0 <5.0
* or Maximum (lb/d) =>
* Average (mg/1) =>
* or Average Loading (lb/d) =>
% violations,(chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) _> MONITOR ONLY
Diethyl 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
* Total # of samples => 1 0 1 0
* Maximum (ug/l) _> <50,000.0 <50,000
* or Maximum (lb/d) _>
* or Average (mg/I) =>
* or Average Loading (Ib/d) =>
% violations, (chronic SNC is >= 66%) _> MONITOR ONLY
% TRC violations, (SNC is >= 33 %) _>
1st 6 months 2nd 6 months 1st 6 months _ 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
* Total # of samples =>
* Maximum (ug/1) _>
* or Maximum (lb/d) =>
* or Average (mg/I) =>
* or Average Loading (Ib/d) =>
% violations, (chronic SNC is >= 66%) _>
% TRC violations, (SNC is >= 33 %) _>
BDL=> Below Detection Limit mg/I => 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 => Technical Review Criteria WWTP=> wastewater treatment plant

ATTACHMENT 24
..= 1-1
rfl MY Fd of11-1[1cAlly Swings
Water Resources
Environmental <�-?offirgolliin accy
SIU Inspection Form
Name of Industry: Triangle Truck Wash IUP # N/A
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
cleaner.
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
File name: COMP.INSP
Revision date: October 2, 2020 Page 1

• t(
Town of Holly Springs
1 Water Resources
/lid Lifffir 1 /t7Gu c)lllh}1 7II GoiiiidraI<:-'1/ir7C','>
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 N/A
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 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

`f ' { eR7in Tii' G-1o1111y Springs
yl
``, M'r/ad: rc R050airces
1/4-1i1171 <>GIJI/iid lid& giapliance
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 TORS 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
S ri n s
as
Water Resources
En vfrc nmen tal Complii fli G o
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 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).
6. Is SIU implementing slug/spill plan? YES / NO
Comments:
INSPECTION RESULTS
Slug/Spill Control Plan Needed? YES / NO
Comments, Required or Recommended Actions:
Inspector(s) Debra Batten (signature) yl' Date: a"
(Signature) Date.
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020 Page 4

ATTAC H M ENT 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
Practice
Inspection Compliance Reason for Non-Compliance Course of Action Inspection Compliance
Date Date
Avent 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 11/18/2021 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 TORS staff shortages due to illnesses occurring during the
Covid19 pandemic.
Required Information for Compliance According to CFR 441 .50:
(1 ) Documentation of the date, person(s) conducting the inspection, and results of each inspection of the amalgam separator(s) 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, person(s) 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."