SLAS3604_NOV_20190730

North Carolina Department of Environmental Quality | Division of Waste Management
217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200

July 30, 2019

CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Mr. Shane Roberts
Stanley Environmental Solutions, Inc.
P.O. Box 184
Stanley, NC 28164

SUBJECT: Notice of Violation
Stanley Environmental Solutions, Inc.
SLAS 36-04
Gaston County

Dear Mr. Roberts:

On July 17, 2019, Connie S. Wylie, representing the State of North Carolina, Division of Waste
Management Solid Waste Section, reviewed the submitted land application site logs for
compliance with North Carolina solid waste statutes and rules. The following violations were
noted:

A. 15A NCAC 13B .0842(b)(1) Domestic septage land application shall be in accordance
with 40 CFR Part 503.12(c). Permit Condition 7. “a maximum annual volume of
8,375,400 gallons may be applied to this entire site with Field 1 receiving 3,702,600
gallons, Field 2 receiving 3,425,400 gallons and Field 3 receiving 1,247,400 gallons per
year.”

Upon review of the site logs that were submitted for the permit modification it was
noted that (per the permit dated February 23, 2016) the maximum annual application
rate of 1,247,400 gallons was exceeded on Field 3 by 44,600 gallons in 2016 and by
335,600 gallons in 2017. This resulted in a total of 380,200 gallons being over applied
to Field 3 during the 2016-2017 timeframe.

North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200
Stanley Environmental Solutions
Notice of Violation
Page 2 of 3
July 30, 2019

B. 15A NCAC 13B .0842 (a)(17) Approved nutrient management plans shall be followed.
Permit Condition 2. This site shall be operated and maintained in accordance with the
nutrient management plan submitted by Jim Lanier and approved by the Division of
Waste Management. Permit Condition 7. “… Application rates to the disposal fields
shall not exceed the maximum annual application rate or the monthly application
rates as listed in the approved nutrient management plan for the site.”

Upon review of the site logs that were submitted for the permit modification it was
noted that (per the permit dated February 23, 2016 and the approved nutrient
management plan) the monthly application rates were exceeded in August 2016 (by
93,900 gallons), in June 2017 (by 36,900 gallons) and in July 2017 (by 69,900 gallons).

Based upon the foregoing, Stanley Environmental Solutions shall come into compliance
immediately with all requirements of the regulations in 15A NCAC 13B .0842(b)(1) & .0842(a)(17)
by completing the following:

1. There was an over application of 380,200 gallons to Field 3 during the 2016-2017
timeframe. However, in 2018 only 1,082,000 gallons were applied for a deficit of
165,400 gallons in regards to the 1,247,400 maximum annual application rate allowed.
Subtracting the 165,400 gallons from the over application amount of 380,200 gallons
results in 214,800 gallons of over application to still be addressed. Therefore, this
amount of 214,800 gallons shall be deducted from the application rate for Field 3 for
the calendar year of 2019. The maximum annual application rate for Field 3 in 2019
shall not exceed 1,032,600 gallons (which is 1,247,400 gallons minus 214,800 gallons).
Monitor the total annual application rate for Field 3 thru the calendar year of 2019
to not exceed this temporary limit of 1,032,600 gallons.

2. The monthly application rate (as per the approved nutrient management plan) shall
not be exceeded. The appropriate monthly application rate (low, medium, high) shall
be used in accordance with correct field acreage as per the current permit. Monitor
the discharge amounts to ensure that the monthly application rates are not
exceeded.

North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200
Stanley Environmental Solutions
Notice of Violation
Page 3 of 3
July 30, 2019

3. Stanley Environmental Solutions shall provide a written certification with supporting
documentation on company letterhead confirming the noted compliance schedule
has been completed. Include in the certification any actions taken to prevent these
violations from occurring in the future. Mail this certification to Connie S. Wylie,
DWM, Fayetteville Regional Office, 225 Green Street, Suite 714, Fayetteville, NC
28301 within 15 days of receipt of this letter.

The violations listed above were observed by Section staff and require action on behalf of the
facility in order to come into or maintain compliance with the Statutes, Rules, and/or other
regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22,
an administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid
Waste Laws, Regulations, Conditions of a Permit, or Order under Article 9 of Chapter 130A of the
N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to
enforcement actions including penalties, injunction from operation of a solid waste management
facility or a solid waste collection service and any such further relief as may be necessary to
achieve compliance with the North Carolina Solid Waste Management Act and Rules.

Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct
a follow-up inspection to verify that the facility has completed the requirements of this Notice of
Violation. If you have any questions please contact me at [phone] or email
[e-mail].

Sincerely,

Connie S. Wylie
Environmental Program Consultant
Division of Waste Management - Solid Waste Section