WQ0035207_NOD-2020-PC-0197_20200415

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 15, 2020
Robert Roth, Technical Services Manager
Synagro Central LLC
284 Boger Rd.
Mocksville, NC
Subject: Notice of Deficiency — (NOD-2020-PC-0197)
Review of the 2019 Annual Report
Distribution of Class A Residual Solids
Permit No. WQ0035207
Davie County
Dear Mr. Roth:
Division of Water Resources (Division) staff person Justin Henderson has completed a review of
the 2019 annual report for the subject permit. Review of the subject report reflects non-
compliance with the Permit No. WQ0035207. The following deficiencies warrant your attention
and action:
1. The total dry tons of residuals reportedly land applied from source facility Hood Creek
WTP (Brunswick County), exceeded the Maximum Dry Tons Per Year limit of 1000 dry
tons as specified in Attachment A. Either ensure all future operations are compliant with
the limits specified in Attachment A or request permit modification to increase the
maximum dry tons for the applicable source facilities.
2. Failure to report Plant Available Nitrogen (PAN) and Sodium Absorption Rate (SAR) on Form
RSSF, specific to source facility City of Dunn WTP, in accordance with the Instructions for
Residuals Application Annual Reporting Forms and Permit Condition IV. (7.) All parameters
required to be monitored in accordance with Permit Condition IV. (3.) shall be reported of Form
RSSF in accordance with the Instructions for Residuals Application Reporting Forms and Permit
Condition Part IV. (7.) in all future annual reports.
Along with the above described deficiencies, the following item of concern also requires your
attention:
A. Failure to conduct residual analysis for nutrient & metals per the frequencies specified in
Attachment A, and in accordance with Permit Condition IV. (3.) specific to source facility John
F. Kime WTP (Piedmont Triad Regional Water Authority). While, the Division acknowledges
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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receipt of an explanation for this matter in the subject report, it is strongly recommended that
future residual analysis be conducted as early as possible, within the specified monitoring period
established in Attachment A, to provide opportunities for resampling to be conducted as may be
warranted should similar scenarios occur in the future. It appears that operations conducted in
the fourth quarter ranged from October 4, 2019 through November 21, 2019, with no
application events documented to have occurred later than November 21, 2019, based upon
FSF(s) forms submitted in the subject report. Based upon this, please provide further
explanation for why resampling was not possible within the required fourth quarter
monitoring period in accordance with Attachment A, as well as what measures will be
implemented to ensure this will not occur in the future.
Our office appreciates your attention to the above listed items. A routine compliance evaluation
inspection is planned to occur within the next 12 months. If you have any questions regarding
this letter, please contact Justin Henderson or me at the letterhead address or phone number, or
by email at [e-mail] or Ion. snidernncdenr.gov.
Sincerely,
Docuft ed by:
T sMa�
on s49�ni er, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: Ryan Copeland — Synagro (Electronic)
Laserfiche Files — (Electronic Copies)

Compliance Inspection Report
Permit: WQ0035207 Effective: 03/27/20 Expiration: 02/28/21 Owner : Synagro Central LLC
SOC: Effective: Expiration: Facility: Synagro Central DCAR
County: Davie
Region: Winston-Salem
Contact Person: Gregory T Flory Title: Executive Director Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NCG590017 City of Greensboro - Lake Townsend WTP
NC0046345 City of Reidsville - Reidsville WTP
NC0075701 City of Albemarle - Tuckertown WTP
NC0087866 Piedmont Triad Regional Water Authority -John F. Kime WTP
NC0057533 Brunswick County - Hood Creek WTP
Inspection Date: 04/14/2020 Entry Time 11:OOAM Exit Time: 04:OOPM
Primary Inspector: Justin L Henderson Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0035207 Owner - Facility: Synagro Central LLC
Inspection Date: 04/14/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
Division of Water Resources (Division) staff person Justin Henderson has completed a review of the 2019 annual report for
the subject permit. Review of the subject report reflects non-compliance with the Permit No. WQ0035207. The following
deficiencies warrant your attention and action:
1. The total dry tons of residuals reportedly land applied from source facility Hood Creek WTP (Brunswick County),
exceeded the Maximum Dry Tons Per Year limit of 1000 dry tons as specified in Attachment A. Either ensure all future
operations are compliant with the limits specified in Attachment A or request permit modification to increase the maximum
dry tons for the applicable source facilities.
2. Failure to report Plant Available Nitrogen (PAN) and Sodium Absorption Rate (SAR) on Form RSSF, specific to source
facility City of Dunn WTP, in accordance with the Instructions for Residuals Application Annual Reporting Forms and Permit
Condition IV. (7.) All parameters required to be monitored in accordance with Permit Condition IV. (3.) shall be reported of
Form RSSF in accordance with the Instructions for Residuals Application Reporting Forms and Permit Condition Part IV. (7.)
in all future annual reports.
Along with the above described deficiencies, the following item of concern also requires your attention:
A. Failure to conduct residual analysis for nutrient & metals per the frequencies specified in Attachment A, and in
accordance with Permit Condition IV. (3.) specific to source facility John F. Kime WTP (Piedmont Triad Regional Water
Authority). While, the Division acknowledges receipt of an explanation for this matter in the subject report, it is strongly
recommended that future residual analysis be conducted as early as possible, within the specified monitoring period
established in Attachment A, to provide opportunities for resampling to be conducted as may be warranted should similar
scenarios occur in the future. It appears that operations conducted in the fourth quarter ranged from October 4, 2019 through
November 21, 2019, with no application events documented to have occurred later than November 21, 2019, based upon
FSF(s) forms submitted in the subject report. Based upon this, please provide further explanation for why resampling was
not possible within the required fourth quarter monitoring period in accordance with Attachment A, as well as what measures
will be implemented to ensure this will not occur in the future.
Our office appreciates your attention to the above listed items. A routine compliance evaluation inspection is planned to
occur within the next 12 months. If you have any questions regarding this letter, please contact Justin Henderson or me at
the letterhead address or phone number, or by email at [e-mail] or [e-mail].
Page 2 of 3

Permit: WQ0035207 Owner - Facility: Synagro Central LLC
Inspection Date: 04/14/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Page 3 of 3