WQ0035207_More Information (Requested)_20240304

March 4, 2024
ADAM J. BRIGMAN – TECHNICAL SERVICES MANAGER
SYNAGRO CENTRAL, LLC
284 BOGER ROAD
MOCKSVILLE, NORTH CAROLINA 27028
Subject: Application No. WQ0035207
Additional Information Request #1
Synagro Central Class A Residuals
Program
Distribution of
Class A Residuals
Davie County
Dear Mr. Brigman,
Division of Water Resources’ Central and Regional staff have reviewed the application package
received on December 19, 2023. However, the Division requires additional information before completing
our review. Please address the items on the attached pages no later than the close of business on April 3,
2024.
Please be aware that the Applicant is responsible for meeting all requirements set forth in North
Carolina rules and regulations. The Applicant is also responsible for any oversights that occur during the
review of the subject application package. The Division may return the application as incomplete pursuant
to 15A NCAC 02T .0107(e)(2) if any omissions are made when responding to the outstanding items in
Sections A through M or the Applicant fails to provide the additional information on or before the above-
requested date.
Please reference the subject application number when providing the requested information. The
Applicant shall sign, seal, and date (where applicable) all revised and/or additional documentation and
submit an electronic response to my attention via the Non-Discharge online portal.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Erick Saunders
Division of Water Resources
cc: Fayetteville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Adam J. Brigman
March 3, 2024
Page 2 of 3
A. Overall:
1. No comments.
B. Cover Letter:
1. The cover letter requests the modification to increase the Siler City WTP dry tonnage from 250 to
1,000 dry tons per year (DT/yr). However, the current permitted dry tonnage is 125 DT/yr. Please
clarify the discrepancy.
C. Application Fee:
1. No comments.
D. Application (Form: DCAR 06-16):
1. No comments.
E. Program Information:
1. The marketability statement included in the section for the Kerr Lake WTP includes references to
the Siler City WTP. Please revise this section to refer to the correct facility.
F. Operation & Maintenance Plan:
1. In section 7 of the Spill Response Plan, each of the DWR Regional Offices has their phone listed
except for the Mooresville Regional Office (MRO). In accordance with the reporting requirements
of 15A NCAC 02T .1110(a)(4)(B), the contact information for the MRO shall also be included.
Please note that for clarity, a table would be a more effective way to display each regional office’s
contact information.
G. Application (Form: RSC 06-16):
1. Pages 1 and 2 of the RSC form for the Siler City WTP are missing, while pages 3 through 5 of the
RSC for the Kerr Lake WTP are missing. These forms shall be submitted in full in the response.
2. The sodium adsorption ratio (SAR) and plant available nitrogen (PAN) calculations provided in
Section II.5. of the RSC for the Siler City WTP are different than the calculations the Division
performed. Based on the lab results provided, the SAR should have been 0.937, while the first year
PAN should be 11,033 mg/kg for surface application and 12,883 mg/kg for subsurface application.
Please provide calculations for review.
3. The toxicity characteristic leaching proceure (TCLP) results provided in Item II.3. of the RSC form
are from December 21, 2020, which is almost three years prior to the application date. The results
from the latest TCLP analysis shall be provided. If these are the latest results, an explanation shall
be provided as to why there hasn’t been an analysis in the previous year.
Mr. Adam J. Brigman
March 3, 2024
Page 3 of 3
H. Vicinity Maps:
1. No commets.
I. Process Flow Diagram & Narrative:
1. No comments.
J. Quantitative Justification:
1. No comments.
K. Sampling Plan:
1. The sampling plan included in the section for the Kerr Lake WTP includes the Siler City Water
Treatment plant in the title. Additionally, it says that TCLP sampling frequency is only once per
permit, when it is typically annually. Please revise this sampling plan to refer to the Kerr Lake
WTP, and provide justification for the reduced TCLP monitoring if that is requested.
L. Laboratory Analytical Reports:
1. See Item H.3.
M. Pathogen Reduction (PR) & Vector Attraction Reduction (VAR) Compliance Documentation:
1. N/A.