WQ0000543_NOV-2020-PC-0192 Response_20200429

City of Sanford
Water Reclamation Facility
P.O. Box 3729
Sanford, NC 27331
April 29, 2020
NC Department of Environmental Quality
Division of Water Resources
Water Quality Regional Operations Section
Division of Water Resources
3800 Barret Drive
Raleigh, NC 27609
Subject: Notice of Violation
Tracking Number: NOV-2020-PC-0192
Permit No.: WQ0000543
City of Sanford RLAP
Lee County
Dear Mr. Vinson:
NC Dept of Environmental Quality
MAY -1 2020
Raleigh Regional Office
As per your letter dated April 3", 2020, citing a NOV issued for missed sampling, the additional information is
being included in this letter. The City of Sanford has contracted with Synagro to manage a majority of the Land
Application program to include required sampling. I have reached out to Synagro upon receipt of the Notice of
Violation requesting the response to your letter. I have included their response. I have also reviewed it and will
implement the changes Synagro has noted in their letter. I will also maintain better communications with my
contacts at Synagro to avoid further infractions. If you have any questions or comments please contact me.
Sincerely,
C�_�"" 4. 'ij�
Scott A. Siletzky
City of Sanford
Water Reclamation Facility Administator
Phone: [phone]
Email: [e-mail]
Enc: Syangro Letter
Sampling Schedule Checklist

SYNAGRO
NC Dept of Environmental Quality
April 24, 2020
MAY -1 2020
N.C. Department of Environmental Quality
Division of Water Resources Raleigh Regional Office
Water Quality Regional Operations Section, Division of Water Resources
3800 Barrett Dr.
Raleigh, NC 27609
ATTENTION: Mr. Scott Vinson
REFERENCE: NOTICE OF VIOLATION
NOV-2020-PC-0192
PERMIT NO. WQ0000543
CITY OF SANFORD RESIDUALS LAND APPLICATION
LEE COUNTY
Dear Mr. Vinson:
On behalf of the City of Sanford, Synagro is submitting this in response to the Notice
of Violation letter received April 14`h, 2020. As requested, the below items are in reference to
the additional training conducted and plans on how to avoid such occurrences in the future.
As a corrective 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 land applied and
the required sampling frequency as set forth in all North Carolina RLAP permits.
Additionally, further training was implemented outlining how the required sampling
frequency applies to not only pathogen and VAR testing but nutrients and metals testing as
well. This training was conducted as a result of having all the required pathogen and VAR
data but lacking the appropriate number and nutrients and metals results in the 2019 annual
report of the above referenced permit.
Additionally, 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
sampling schedule for the above referenced permit is provided as an attachment.
If you require additional information or have further questions, please contact me at
[phone] or rrothasyna ram.
Sincerely,
71 xo�
Robert "Nate" Roth
284 Boger Road, Mocksville, NC 27028 + Phone: [phone] Fax: [phone]

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ROY COOPER
Gaynor
MICHAEL S. REGAN
5rrmary
S. DANIEL SMITH
Plrectar
NORTH CAROLINA
Environmental Quality
Certified Mail # 7017 0190 0000 9562 6520
Return Receipt BMuested
April 03, 2020
T Chet Mann
City of Sanford
PO Box 3729
Sanford, NC 27331
SUBJECT: NOTICE OF VIOILATION
Tracking Number: NOV-2020-PC-0192
Permit No. WQ0000543
City of Sanford RLAP
Lee County
Dear Permittee:
I V
Ph 14 2026
The North Carolina Division of Water Resources conducted an inspection of the City of Sanford RLAP on April 1,
2020. This inspection was conducted to verify that the facility is operating in compliance with the conditions and
limitations specified in Non -discharge Permit No. WQ0000543. A summary of the findings and comments noted
during the inspection are provided in the enclosed copy of the inspection report.
The Annual Report Review inspection was conducted by Division of Water Resources staff from the Raleigh
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Sampling Condition IV.3 requires analysis be conducted on residuals from each source generating
facility at the frequency specified in Attachment A. During 2019, there were only two
samples of residuals when there were required to be four samples based on dry tons applied.
This was noted in the land application certification form submitted in the 2019 annual report.
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Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
An explanation of non-compliance was submitted with the annual report but further information is required. To
prevent further action, please respond in writing to this office within 30 dam upon your receipt of this Notice
of Violation regarding your plans for additional training and checks and balances to ensure samples are taken,
delivered and reported in the correct timeframe.
If you should have any questions, please do not hesitate to contact Gary Kreiser with the Water Quality
Regional Operations Section in the Raleigh Regional Office at 919-791-4200.
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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Cc: WQS Raleigh Regional Office - Enforcement File
NON -DISCHARGE Compliance/Enforcement Unit - Enforcement File
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