WQ0035207_NOD-2020-PC-0197_20200428

SYNAGRO
April 28, 2020
N.C. Department of Environmental Quality
Division of Water Resources
Water Quality Regional Operations Section, Division of Water Resources
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
ATTENTION: Mr. Lon T. Snider
REFERENCE: NOTICE OF DEFICIENCY — (NOD-2020-PC-0197)
REVIEW OF 2019 ANNUAL REPORT
DISTRIBUTION OF CLASS A RESIDUAL SOLIDS
WQ0035207, DAVIE COUNTY
Dear Mr. Snider:
Synagro is submitting this letter in response to the 2019 annual report review letter
received via email on April 15th, 2020. Each item listed in the review letter is addressed
below:
As result of the Hood Creek WTP exceeding the maximum dry tons per year limit, a
modification to the NCDEQ Water Resources Division will be submitted within the
2020 calendar year to increase the maximum dry tonnage limit. Growing plant
volumes have ultimately led to in increase in residuals production.
2. As a follow up to recent phone conversation between you and myself, I would like to
request email confirmation allowing Synagro to submit Synagro developed forms
when completing annual reports. The above referenced review letter noted that only
division provided forms are allowed however, Synagro forms have been used for quite
some time across all regional offices in North Carolina with no issues of non-
compliance from other regional office reviews. Plant Available Nitrogen (PAN) and
Sodium Absorption Rate (SAR) are provided in all Synagro reports but they are not
typically listed on form RSSF. Traditionally, SAR results and calculations are
provided directly behind each nutrients and metals results while PAN is noted on each
FSF form. The Dunn WTP portion of the 2019 annual report depicts how Synagro
would like to submit annual report information to the Winston Salem Regional Office
going forward.
3. The annual report was marked as "non -compliant" due to the lack of appropriate
sample timing. As directed by the Synagro Central, LLC DCAR permit, quarterly
(4x/yr) sampling is required however the 4th nutrients and metals sample provided in
the report was not sampled in the appropriate timeframe. This inconsistency wasn't
discovered until after the new year began.
As a correction action, once an issue with sampling frequency was determined,
Synagro immediately began retraining of all staff responsible for biosolids sampling
across North Carolina. Special emphasis was placed on the relationship of dry tons
284 Boger Road, Mocksville, NC 27028 • Phone: [phone] • Fax: [phone]

SYNAGRO
land applied and the required sampling frequency as set forth in all North Carolina
RLAP permits.
Lastly, in an effort to avoid future sampling frequency issues, a sampling
checklist has been developed. The checklist documents when samples need to be taken
and when sample results are received and reviewed. This checklist not only tracks
when samples need to be taken but also will be updated to show when results are
received and reviewed for compliance. This checklist should alleviate any future
issues with sample retrieval dates, sample shipping and receiving interruptions, and
possible lab -based issues. The current 2020 sampling checklist for the above
referenced facility is provided as an attachment.
I appreciate your consideration, however if you require additional information or have
further questions, please contact me at [phone] or rroth@syna rgro.com.
Sincerely,
Robert "Nate" Roth
/1�1 X_Iz_�7�
Cc: Justin Henderson-NCDEQ Winston Salem Regional Office -via email
284 Boger Road, Mocksville, NC 27028 • Phone: [phone] • Fax: [phone]

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