WQ0035207_Regional Office Historical File Pre 2016

North Carolina Department of Environmental Quality
Pat McCrory Donald R. van der Vaart
Governor Secretary
November 4, 2015
Mr. Marshall Puryear, Technical Services Director
Synagro Central, LLC
284 Boger Rd.
Mocksville,NC 27028
Subject: Compliance Evaluation Inspection
Synagro Central, LLC —Distribution of Class A Residuals Program
Permit No. WQ0035207
Statewide Operation
Dear Mr. Puryear:
On October 21, 2015 staff of the North Carolina Division of Water Resources Winston-Salem Regional
Office (DWR) performed a compliance evaluation inspection of the subject residuals program. This
inspection was conducted by DWR staff person Patrick Mitchell. The inspection reflects compliance with
permit WQ0035207.
Please refer to the enclosed inspection report for additional observations and comments. If you or your
staff have questions, please contact Patrick Mitchell or me at [phone]:
Sincerely,
Sherri V. Knight, P.E. —Assistant Regional Supervisor
Water Quality Regional Operations
Division of Water Resources,NC DEQ
enc.: Compliance Inspection Report
cc: ARO(electronic)
MRO(electronic)
RRO(electronic)
WiRO(electronic)
DWR WQ Central Office—Permit File WQ0035207
allineartal
Winston-Salem Regional Office
450 W Hanes Mill Rd.,Suite 300,Winston-Salem,NC 27105
Phone:[phone]\Fax:[phone] Customer Service 1-877-623-6748
An Equal Opportunity\Affirmative Action Employer-Made in part by recycled paper

permit: W00035207 Owner-Facility:Synagro
Inspection Date: 10/21/2015 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On October 21, 2015 a routine compliance inspection of the subject facility was conducted by WSRO staff. This inspection
was of application field activities only, and no residuals generating sources were visited as part of this inspection.The
inspection reflects compliance with the permit. Below is a summary of findings.
Land application site'GU-X28-1'(site named assigned by Permittee)was visited.
-Land application was not occurring at the time of the site visit. The application event was completed on October 16, 2015.
-Buffer flags were still present in the fields, and cake residuals were still evident on the land surface. Observed buffers were
compliant.
-Only residuals from Piedmont Triad Regional Water Authority source were reported as being land applied to the site.
-Current residuals sampling results for the above mentioned source were reviewed and reflect compliance.
-PAN: TKN=7720, NH-3= 1220, NO-3=<2; reported application rate within agronomic rates.
All observed activities were found to be compliant.
Page: 2

Compliance Inspection Report
Permit: WQ0035207 Effective: 03/12/15 Expiration: 02/28/16 Owner: Synagro
SOC: Effective: Expiration: Facility: Distribution of Class A Residuals
County: Randolph
Region: Winston-Salem
Randleman NC 27317
Contact Person: Marshall R Puryear Title: Technical Services Director Phone: [phone] Ext.17
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
NC0046345 City of Reidsville-Reidsville WTP
NC0084093 Chatham County-Jordan Lake WTP
NC0081671 City of Greensboro-Lake Townsend WTP
NC0087866 Piedmont Triad Regional Water Authority-John F.Kime WTP
NC0057533 Brunswick County-Hood Creek WTP
Inspection Date: 10/21/2015 Entry Time: 08:45AM Exit Time: 10:45AM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: • Compliant Not Compliant
Question Areas:
Miscellaneous Questions IN Record Keeping Treatment
1111 Sampling Land Application Site 111 Pathogen and Vector Attraction
(See attachment summary)
Page: 1

North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Section
1 NON-DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS A RESIDUALS DISTRIBUTION
General Information
Facility Name: S ,A a,ro D1-4. C Lv, ,k County: tc-
Permit No.: W000 32C '7 Permit Issuance Date:
Owner: . ft.ye 64,,.k4-a-l; LLC Permit Expiration Date:
xl n`t-"sue Name: M L,,..11. __ P,T Telephone No.: �3`7�- 7 3�- ��Z G
C 33G-"if-7/5"G
Other Contact(s): l�l a I� ins SAC ,'Y�, Telephone No.: 33e - /C"3- yfz
Facility Location(ad re , • c ions):
Reason for Inspection �/
AIROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ) PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
if 2.,,,, c/ yr, -- ,,,,,, fiej,,,,,,i- Treg (-J4,-,
— Eve-1- 4 A,L d f p, l6/16/r 15—
Achkrticl et J76,..r As (0,hv, t-6/1`
tj D 5Uru 4,ili-A, vt kt,
Is a follow-up inspection necessary? ❑ Yes No
Primary Inspector: 4, M c 6 a( Secondary Inspector:pp ���
Date of Inspection: (0/21 /2 t�I.� Entry Time: Tom+` a^1 Exit Time: /D :'f fi-,

(fJ12 ` 1 p1LcL� Oult.t.— esio�
�� ' £
y°`.2(- Non-Discharge Compliance Inspection Report
r Record Keeping and Reporting Information: Y N NA NE
Is current permit and prior annual reports available upon request? ❑ ❑ ❑
\ Has the facility been free of public complaints for the last 12 months? = ❑ ❑ ❑
TCLP analysis conducted and results available? Frequency? (See permit for frequency) 'p ❑ ❑ ❑
Residuals metals and nutrient analysis conducted?Frequency? (See permit for frequency)a ❑ ❑ ❑
Nutrient and metals loading calculations?(to determine most limiting parameter) I 1 ❑ ❑ ❑
Do lab sheets support data reported on Residuals Analysis Summary? 11 r ► ❑ ❑ ❑
Are distribution and/or hauling records available? r�1 . 3 ❑ ❑ ❑
p
p
Are Utilization Agreements with recipients established and available for review? lc- ❑ ❑ ❑
Do Utilization Agreements contain the minimum requirements contained in the permit? ❑ ❑ / ❑
(Restrictions for land application,stockpiling,setback buffers,etc.) \
If the Permittee applies bulk residuals,are field loading records available? N ❑ ❑ ❑
If the Permittee applies bulk residuals,are field inspections conducted and are records available? ._ ❑ ■' ❑
Does residuals package label or Utilization agreement contain minimum info required by permit? ❑ ❑ '4 ❑
(Name&address of generator,statement of restrictions,nutrient contents)
Is an inspection log available containing record of residuals facility inspections, maintenance, ❑ ❑ ❑
and repairs?
Pathogen and Vector Attraction Reduction Records
atho en Reduction:Requires both pathogen density demonstration and Class A treatment alternative.
Fecal Coliform density or ❑ Salmonella density to demonstrate pathogen requirements. Y N NA NE
Was sampling conducted at the permit required frequency?(See permit for frequency) ❑ ❑ ❑
CZ!'
Were multiple samples taken? 1 ❑ ❑
If Fecal Coliform,density<1,000 MPN/gram of total solids? * 6C) "' ❑ ❑
If Salmonella,density<3 MPN/4 grams of total solids? ❑ ❑ ❑
Select which treatment Alternative below was used to demonstrate Class A compliance. /
❑ Alternati'- 1 - Time/Temperature (See White House Manual for specific requirements) Y N NA NE
Were -siduals maintained for correct time and temperature? ❑ ❑ ❑ ❑
Are logs 'resent showing time and temperature? ❑ ❑ ❑ ❑
Are tempe :tures within range for complete time period? ❑ ❑ ❑ ❑
❑ Alternative 2 - Alka ' e Treatment
Are logs present s •wing time and temperature9 1 ❑ ❑ ❑ ❑
Was the pH raised to 2 or greater and mainta' d I. 72 ho .s or longer? ❑ ❑ ❑ ❑
Was the temperature 5 (126°F)for 12 h urs r 1. •:,: hile the pH was 12 or greater? ❑ ❑ ❑ ❑
Are logs present showing t •1 a and pH? ❑ ❑ ❑ ❑
Was the temperature correcte• 0 25°C(77 calculation,NOT autocorrect? ❑ ❑ ❑ ❑
❑Alternative 5 - Process to Further Redu - Pathogens(PFRP) [Select the PFRP method below that was utilized]
❑ Composting, Select which method .'s .sed:
❑ Within-Vessel Method or . att. ' erated Pile Method
Were residuals to s'•eratures • aintained at>55°C(131°F) for Y N NA NE
>3 consecutiv- •ays in the with'.'-vessel or static aerated piles? ❑ ❑ ❑ ❑
❑ Windrow Comp,. ting Method
Were • residuals temperatures main 'fined at>55°C for at least
15 c• secutive days in the windrow,an. . e windrow was turned a ❑ ❑ ❑ ❑
' imum of five times during this time?
❑ Heat Dryin.-
We,- the residuals dried by direct or indirect contact with ho !.ases and the ❑ ❑ ❑ ❑
I'oisture content of residuals reduced to<10%?
Did the temperature of the residuals or the wet bulb temperature oft : :as ❑ ❑ ❑ ❑
in contact with the residuals as the residuals leave the dryer exceed 80° 76°F)?
❑ Other Alternative, Specify: (See ite House Manual)
Page 2 of 4

Non-Discharge Compliance Inspection Report
rector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
❑Option 1 -38%Volatile Solids Reduction Y N NA NE
Are lab results and calculations present? / ❑ ❑ ❑ ❑
Was the reduction on volatile solids(not total solids)? / ❑ ❑ ❑ ❑
Were amples collected at correct locations? / ❑ ❑ ❑ ❑
(begin ing of digestion process&before land application)
Was the e a>38%reduction? ❑ ❑ ❑ ❑
❑ Option 2-40-D: Bench Scale Test Y N NA NE
Were residu:is from anaerobic digestion? j ❑ ❑ ❑ ❑
Are lab resul • and calculations present? ❑ ❑ ❑ ❑
Was the test an.-robically digested in lab,and test run/for 40 days? ❑ ❑ ❑ ❑
Was the test done etween 30°C(86°F)and 37°C(9F)? ❑ ❑ ❑ ❑
Was the reduction o in volatile solids(not total so ds)? ❑ ❑ ❑ ❑
Was the reduction less . an 17%? ❑ ❑ ❑ ❑
❑Option 3 -30-Day Bench Scale -st Y N NA NE
Were residuals from aerobic .•:estion? ❑ ❑ ❑ ❑
Are lab results and calculations resent? ❑ ❑ ❑ ❑
Were residuals 2%or less total so 'ds? ❑ ❑ ❑ ❑
If not 2%total solids,was the test r. on , sam dilut d t °
with unchlorinated effluent? ❑ ❑ ❑ ❑
Was the test run for 30 days? ❑ ❑ ❑ ❑
Was the test done at 20°C(68°F)? ❑ ❑ ❑ ❑
Was the reduction of on volatile so ds(not tot so ' s)? ❑ ❑ ❑ ❑
Was the reduction less than 15%? ❑ ❑ ❑ ❑
❑ Option 4-Specific Oxygen Uptake t ate(SOUR Test) Y N NA NE
Were residuals form aerobic • gestion? ❑ ❑ ❑ ❑
Were residuals<2%total so ds(dry weight basis)(not diluted)? ❑ ❑ ❑ ❑
Was the test done betwee 0°C(50°F)and 30°C(86°F)? ❑ ❑ ❑ ❑
Was the temperature co •cted to 20°C(68°F)? ❑ ❑ ❑ ❑
Was the sampling hold' g time<2 hours? ❑ ❑ ❑ ❑
Was the test started w' hin 15 minutes of sampling or aeration maintained. ❑ ❑ ❑ ❑
Was the SOUR equ. to or less than 1.5 mg of oxygen per hour per gram of
total residual solid (dry weight basis)? ❑ ❑ ❑ ❑
❑Option 5 - 14-Day Ae,e bic Process Y N NA NE
Were the resid .is from aerobic digestion? ❑ ❑ ❑ ❑
Was the aver;ge residuals temperature higher than 45°C(113°F)? ❑ ❑ ❑ ❑
Were the re•duals treated for 14 days and temperature maintained higher
than 40°C 04°F)for the 14-day period? ffi ❑ ❑ ❑
❑Option 6-Al aline Stabilization Y N NA NE
Was th pH of the residuals raised to>12 and maintained for two hours
witho,t addition of more alkali? ❑ ❑ ❑ ❑
Did e pH of residuals remain at>11.5 an additional twenty-two hours
wit out the addition of more alkali? ❑ ►� ❑ ❑
as the pH corrected to 25°C(77°F) (by calculation,NOT auto correct)? ❑ ■ ❑ ❑
❑ Option 7-Drying of Stabilized Residuals Y N NA NE
The residuals do not contain unstabilized residuals? ❑ ❑ ❑ ❑
Were the residuals mixed with any other materials?If so, what? ❑ ❑ ■ ❑
Were the residuals dried>75%total solids? ❑ ❑ \\ ❑
❑ Option 8 -Drying of Unstabilized Residuals Y N NA NE
Were the residuals mixed with any other materials? ❑ ❑ ❑ ❑
Were the residuals dried>90%total solids? ❑ ❑ ❑ ❑
❑Option 9/10—Injection/Incorporation of Residuals (Not commonly used-See White House Manual)
Page 3 of 4

SC)A C-11-A Non-Discharge Compliance Inspection Report
Residuals Storage:
Describe storage:
Number of days/weeks/months of storage:
Residuals Sampling: Y N NA NE
Is sampling adequate and representative? R-J,.,,,4-- I rovl. r ❑ ❑ ❑ ❑
Describe Sampling:
Transport Vehicle: Y N , NA NE
Is transport occurring at time of inspection? ❑ ❑
,*Are necessary records(i.e.permit&spill plan)present in vehicle?ID of observed vehicle(s): " ❑ ❑ ❑
Application Site(s)
Were application site(s)inspected? If so,please complete info below. �d Yes ❑No
Is application occurring at the time of inspection? If no,note the date of the list ent: I p/l 0491,5❑ Yes `�: No
We ther Conditions: /
i9 Sunny ❑ Partly Cloudy ❑ Cloudy ❑ Overcast ❑ Stormy
✓❑ Windy (wind direction: ) ❑ Breeze *Calm
XNo Precipitation ❑ Drizzle ❑ Rain ❑ Cloudburst (If applicable,precipitation measurement: )
Weather Notes(i.e. Significant Changes, Forecasts, etc):
Temp. (°F): ❑ <32 ❑ 32—40 ❑ 40—60 X60—80 ❑>80
Permit and Spill Plan onsite during application? °---8 Yes/ L-N,-
Application Observations: [Type of application: ❑ Liquid Cake(>15%total solids) ❑ Other
Site Owner(s): GU-X 2-Y— 1 W P-,); S•
ite Owner(s):
Intended Crop: .stye, p+r1-n.._ PAN Requirement: lbs/ac Intended Crop: PAN Requirement: lbs/ac
Application Rate(gallons/acre):, ` 6A ke- — k 772t Application Rate(gallons/acre):
Nutrient Content: L J Lame.4- 1325 I2zo 1'141 Nutrient Content:
Application occurring
xattime of visit: IDYes!JZ{J No
3 Z Application occurring at time of visit: ❑Yes ID No
Application Method: Surface❑Incorp/Injection Application Method:❑Surface❑Incorp/Injection
Incorporation/Injection during visit:❑Yes No, N/A Incorporation/Injection during visit:❑Yes❑No❑N/A
Vegetative Buffer description:❑None Grass ❑Crop 'Shrub ❑ ['Grass Buffer description: None Grass Crop ❑Shrub❑
Tree 0 Other lll��� Tree 0 Other
Current Field Conditions: Current Field Conditions:
❑Bare ❑Stubble ❑Planted (crop) Pasture 0 Bare 0 Stubble ❑Planted. crt p.) ❑Pasture
Soi Condition: Soil Condition:
,A Dry ❑Moist ❑Wet ❑Saturated ❑Dry 0 Moist ❑Wet ❑Saturated
N it-Frozen Frost ❑Frozen ❑Snow-Covered ElEl ❑Not-Frozen Frost Frozen ❑Snow-Covered
Slope: 0-3% •3-6% 0 6-10% ❑ 10-18% ❑>18% Slope: ❑0-3% ❑3-6% ❑6-10% 0 10-18% ❑>18%
Odor: None ❑Mild ❑Moderate ❑Strong Odor: ❑None ❑Mild ❑Moderate 0 Strong
Vectors: None ❑Few ❑Many ❑Excessive Vectors: 0 None ❑Few 0 Many ❑Excessive
Application Details: Y N NA NE Application Details: Y N NA NE
Application areas clearly marked? M ❑ ❑ ❑ Application areas clearly marked? ❑ ❑ ❑ ❑
Application within authorized area? ^ ❑ 0 0 Application within authorized area? ❑ ❑ ❑ ❑
Application method appropriate? z ❑ 0 ❑ Application method appropriate? ❑ ❑ ❑ ❑
Application is even(no ponding)? u ❑ ❑ 0 Application is even(no ponding)? ❑ ❑ ❑ ❑
Sufficient setbacks from wells? N 0 0 ❑ Sufficient setbacks from wells? 0 ❑ ❑ 0
Sufficient setbacks from surface waters? ! ❑ ❑ ❑ Sufficient setbacks from surface waters? ❑ El ❑ 0
Slopes>10%avoided(Surface App.)? ! ❑ ❑ ❑ Slopes>10%avoided(Surface App.)? ❑ ❑ ❑ ❑
Slopes>18%avoided(Incorp/Inject)? • ❑ ❑ Slopes>18%avoided(Incorp/Inject)? 0 0 El 0
Incorp./Injection within time-frame? ,❑ El Incorp./Injection within time-frame? ❑ ❑ ❑ ❑
No evidence of shallow GW? ❑ ❑ No evidence of shallow GW? 0 ❑ El El
Tracking is prevented? 0 ❑ ❑ Tracking is prevented? ❑ ❑ ❑ ❑
Biosolids run-off is prevented? 0 0 0 Biosolids run-off is prevented? ❑ 0 El ❑
Page 4 of 4

State of North Carolina
D1k/R Department of Environment and Natural Resources
Division of Water Resources
Division of Water Resources
Water Quality Programs
Regional Staff Report
October 30, 2015
To: Central Office—Water Quality Permitting Section Application No.: WQ0035207
Attn: Troy Doby,Non-Discharge Permitting Unit Permittee: Synagro Central, LLC
From: Patrick Mitchell Winston-Salem Regional Office STATEWIDE County
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or❑No
a. Date of site visit: October 21,2015
b. Site visit conducted by: P. Mitchell
c. Inspection report attached? ❑Yes or®No
d. Person contacted: Marshall Puryear and their contact information: (434) 738 - 8002 ext.
e. Driving directions: See file.
II. FACILITY AND APPLICATION INFORMATION
1. Are there appropriately certified Operators in Charge(ORCs)for the facility? ❑ Yes ❑No /1 N/A
ORC: Certificate#: Backup ORC: Certificate#:
2. Are the design,maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes ❑No ❑N/A-If no,please explain below in Section IV. Review Items
3. Are the site conditions (e.g., soils, topography, depth to water table, etc)maintained appropriately and adequately
assimilating the waste? ® Yes ❑No ❑N/A -If no,please explain below in Section IV. Review Items
4. Has the site changed in any way that may affect the permit(e.g.,drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or®No-If yes,please explain below in Section IV. Review Items
5. Is the residuals management plan adequate? ® Yes or❑No-If no,please explain below in Section IV. Review
Items
6. Are the existing application rates (e.g., hydraulic, nutrient)still acceptable? ® Yes ❑No ❑N/A -If no,please
explain below in Section IV. Review Items
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑No ®N/A
If no, explain and recommend any changes to the groundwater monitoring program below in Section IV. Review
Items
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or®No
If yes,provide comments below attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or❑No-If no,please
explain below in Section IV. Review Items
10. Were monitoring wells properly constructed and located? ❑ Yes❑No ®N/A If no, please explain below in
Section IV. Review Items.
11. Are the monitoring well coordinates correct in BIMS? ❑Yes ❑No®N/A
12. Has a review of all self-monitoring data been conducted(e.g.,NDMR,NDAR, GW)? ® Yes ❑No ❑N/A
Please summarize any findings resulting from this review below in Section IV. Review Items.
FORM: APSRSR 04-10 Page 1 of 2

13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or®No
If yes,please explain below in Section IV. Review Items.
14. Check all that apply:
®No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑Notice(s)of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments(i.e.,NOV,NOD, etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑No ❑N/A
If no,please explain below in Section IV.Review Items.
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑Yes®No ❑N/A
If yes,please explain below in Section IV. Review Items.
M.REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or®No
If yes,please explain:
2. List any items that you would like APS Central Office to obtain through an additional information request:
•
3. List specific permit conditions recommended to be removed from the permit when issued:
•
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
•
5. Recommendation: ❑ Hold,pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
® Issue
❑ Deny(Please state reasons: )
6. Signature of report preparer: �7,/ ' � I�' -
Signature of regional supervisor: �� ,u, 1,-;g.tit-
mot'
Date: October 30,2015
IV.ADDITIONAL REGIONAL STAFF REVIEW ITEMS
•
FORM: APSRSR 04-10 Page 2 of 2

State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
of Water Resources
Water Quality Programs
Regional Staff Report
February 27,2015
To: Central Office—Water Quality Permitting Section Application No.: W00035207
Attn: Troy Doby,Non-Discharge Permitting Unit Permittee: Synagro Central,LLC
From: Patrick Mitchell Winston-Salem Regional Office STATEWIDE County
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted?❑Yes or®No
a. Date of site visit:
b. Site visit conducted by:
c. Inspection report attached? ❑ Yes or®No
d. Person contacted: Marshall Puryear and their contact information: ( ) - ext.
e. Driving directions:
II. FACILITY AND APPLICATION INFORMATION
1. Are there appropriately certified Operators in Charge(ORCs)for the facility?❑Yes ❑No®N/A
ORC: Certificate#: Backup ORC: Certificate#:
2. Are the design,maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes ❑No ❑N/A-If no,please explain below in Section IV.Review Items
3. Are the site conditions (e.g., soils,topography,depth to water table,etc)maintained appropriately and adequately
assimilating the waste? ❑Yes El No ®N/A -If no,please explain below in Section IV.Review Items
4. Has the site changed in any way that may affect the permit(e.g.,drainage added,new wells inside the compliance
boundary,new development,etc.)? ❑Yes or®No-If yes,please explain below in Section IV.Review Items
5. Is the residuals management plan adequate? ®Yes or❑No-If no,please explain below in Section IV.Review
Items
6. Are the existing application rates(e.g.,hydraulic,nutrient)still acceptable?®Yes ❑No ®N/A -lino,please
explain below in Section IV. Review Items
7. Is the existing groundwater monitoring program adequate? ❑Yes❑No ®N/A
If no,explain and recommend any changes to the groundwater monitoring program below in Section IV. Review
Items
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑Yes or®No
If yes, provide comments below attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ®Yes or❑No-If no,please
explain below in Section IV. Review Items
10. Were monitoring wells properly constructed and located? ❑Yes❑No®N/A If no,please explain below in
Section IV.Review Items.
11. Are the monitoring well coordinates correct in BIMS? ❑Yes❑No®N/A
12. Has a review of all self-monitoring data been conducted(e.g.,NDMR,NDAR, GW)? ❑Yes ❑No ®N/A
Please summarize any findings resulting from this review below in Section IV. Review Items.
FORM:APSRSR 04-10 Page 1 of 2

13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑Yes or®No
If yes,please explain below in Section IV.Review Items.
14. Check all that apply:
®No compliance issues ❑ Current enforcement action(s) ❑Currently under JOC
Notice(s)of violation ❑ Currently
under SOC El Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments(i.e.,NOV,NOD,etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ® Yes❑No ❑N/A
If no,please explain below in Section IV.Review Items.
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑Yes®No ❑N/A
If yes,please explain below in Section IV.Review Items.
M.REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑Yes or®No
If yes,please explain:
2. List any items that you would like APS Central Office to obtain through an additional information request:
•
3. List specific permit conditions recommended to be removed from the permit when issued:
•
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
•
5. Recommendation: ❑Hold,pending receipt and review of additional information by regional office
❑Hold,pending review of draft permit by regional office
❑Issue upon receipt of needed additional information
® Issue
❑Deny(Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor:
Date: February 27,2015
IV.ADDITIONAL REGIONAL STAFF REVIEW ITEMS
•
FORM:APSRSR 04-10 Page 2 of 2

, Patrick
m: Mitchell, Patrick
ent: Friday, February 27, 2015 11:31 AM
To: Doby, Troy
Subject: FW: Synagro Class A Dist. Permit Mod (WQ0035207)
Troy,
Marshall Puryear called me a few minutes ago to explain the Fecal Coliform results...
He indicated that the August samples were taken for Class B land application purposes and that is why the test were ran
the way they were,with results being reported as<1,770 etc. He said once they decided to add this WTP to their Class A
permit they took a separate sample,to be ran at the lab specifically to demonstrate that they can meet the Class A limit
of 1,000 MPN/g.This was the December sample sent to Prism Labs which came back as not detected.
I am ok with this explanation and it makes since. I will finish my review early next week and get the staff report to you
soon thereafter.
Patrick
Patrick L. Mitchell, REHS, LSS
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environment& Natural Resources
Winston-Salem Regional Office
NEW Address:
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
NEW Phone: [phone]
Mobile: [phone]
NEW Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Mitchell, Patrick
Sent: Friday, February 27, 2015 10:56 AM
To: Doby, Troy
Subject: Synagro Class A Dist. Permit Mod (WQ0035207)
Troy,
I started looking through the application for the subject permit modification application this morning. So far all looks
good, but I do have a comment about the lab results contained in the application.
There is an August 2014 lab result from Statesville Analytical that indicates the geometric mean for Fecal Coliform test
results as 1,280 MPN/g.This is above the limit of 1,000 to meet Class A. However,there is also a lab result in the
1

application from Prism Labs dated December 2014 which indicates Fecal Coliform results as not detected. I&
this should hold up the permit, but I just think this is odd. I will email the applicant and mention this to them.
I will continue my review between other projects and get you a staff report soon on this one.
Thanks and have a good weekend,
Patrick
Patrick L. Mitchell,REHS, LSS
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environment& Natural Resources
Winston-Salem Regional Office
NEW Address:
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
NEW Phone: [phone]
Mobile: [phone]
NEW Fax: [phone]
E-mail correspondence to and from this address may be subject to the.North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
2

State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
WATER QUALITY REGIONAL OPERATIONS SECTION
Islon of Wader Resources NON-DISCHARGE APPLICATION REVIEW REQUEST FORM
February 5, 2015
p CEIVED�
ot.of ENR
To: WSRO-WQROS: Corey Basinger/ Sherri Knight I'tli 0 9 2015
From: Troy Doby, Water Quality Permitting Section-Non-Discharge Permitting Unit ,nston-Salem
Regional Office
Permit Number: WQ0035207 Permit Type: Distribution of Residual Solids(503)
Applicant: Synagro Project Type: Major Modification
Owner Type: Organization Owner in BIMS?Yes
Facility Name: Distribution of Class A Residuals Facility in BIMS?Yes
Fee Category: Non-Discharge Major Fee Amount: $395 -Major Modification
Comments/Other Information:
Attached, you will find all information submitted in support of the above-referenced application for your review,
comment, and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed. ® Return a completed staff report.
❑ Attach an Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer: f q4y;Gk IV);4-cLe1( Date:
FORM: WQROSNIIARR 01-15 Page 1 of 1

Central Files: APS _ SWP
2/5/2015
r
00035207 Permit Tracking Slip
Status Project Type
In review Major modification
Permit Type Version Permit Classification
Distribution of Residual Solids(503) F Individual
Primary Reviewer Permit Contact Affiliation
troy.doby Marshall R.Puryear
Coastal SWRule 284 Boger Rd
Mocksville NC 270287615
Permitted Flow
Facility
Facility Name Major/Minor Region
Distribution of Class A Residuals Major Winston-Salem
Location Address County
Randolph
Facility Contact Affiliation
Randleman NC 27317 Greg Flory
director executive
PO Box 1325
Owner Randleman NC 27317
Owner Name Owner Type
Synagro Unknown
Owner Affiliation
Marshall R.Puryear
284 Boger Rd
Dates/Events Mocksville NC 27028761
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
3/17/2011 2/5/2015
Regulated Activities Requested/Received Events
Wastewater treatment and disposal RO staff report received
Water conditioning RO staff report requested
Water treatment,surface water
Outfall
Waterbody Name Streamindex Number Current Class Subbasin

VA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
February 5, 2015
Marshall Puryear
284 Boger Road
Mocksville,NC 27028
Subject: Acknowledgement of
Application No. WQ0035207
Distribution of Class A
Residuals
Residual Solids System
Randolph County
Dear Mr. Puryear:
The Water Quality Permitting Section acknowledges receipt of your permit application and
supporting documentation received on February 5,2015. Your application package has been assigned the
number listed above,and the primary reviewer is Troy Doby.
Central and Winston-Salem Regional Office staff will perform a detailed review of the provided
application, and may contact you with a request for additional information. •To ensure maximum
efficiency in processing permit applications,the Division of Water Resources requests your assistance in
providing a timely and complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt of a complete application. If you have any questions, please contact
Troy Doby at(919)807-6336 or [e-mail].
Sincerely,
ciJon Risgaard, Supervisor
Division of Water Resources
cc: Winston-Salem Regional Office,Water Quality Regional Operations Section
Permit File WQ0035207
Non-Discharge Permitting Unit
1617 Mail Service Center,Raleigh,North Carolina 27699-1617
Phone,919-807-6464 Internet:http://portal.ncdenr.orq/web/wq
An Equal Opportunity\Affirmative Action Employer-Made in part with recycled paper

RState of North Carolina
�, Department of Environment and Natural Resources
Division of Water Resources
Division of Water Resources
Water Quality Programs
Regional Staff Report
October 2, 2014
To: Central Office—Water Quality Permitting Section Application No.: W00035207
Attn: Troy Doby,Non-Discharge Permitting Unit Permittee: Synagro Central,LLC
From: Patrick Mitchell Winston-Salem Regional Office STATEWIDE C4
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or® No
a. Date of site visit:
b. Site visit conducted by:
c. Inspection report attached? ❑ Yes or®No
d. Person contacted: Marshall Puryear and their contact information: (434)738- 8002 ext.
e. Driving directions:
H. FACILITY AND APPLICATION INFORMATION
1. Are there appropriately certified Operators in Charge(ORCs)for the facility? ❑ Yes ❑No ® N/A
ORC: Certificate#: Backup ORC: Certificate#:
2. Are the design,maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes ❑No ❑N/A- If no,please explain below in Section IV. Review Items
3. Are the site conditions(e.g., soils,topography, depth to water table, etc)maintained appropriately and adequately
assimilating the waste? ❑ Yes ❑No ®N/A -If no,please explain below in Section IV. Review Items
4. Has the site changed in any way that may affect the permit(e.g.,drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or®No -If yes,please explain below in Section IV.Review Items
5. Is the residuals management plan adequate? ®Yes or❑No- If no,please explain below in Section IV. Review
Items
6. Are the existing application rates(e.g.,hydraulic,nutrient)still acceptable? ® Yes ❑No ®N/A - If no,please
explain below in Section IV. Review Items
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑No ®N/A
If no, explain and recommend any changes to the groundwater monitoring program below in Section IV. Review
Items
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑Yes or®No
If yes,provide comments below attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ®Yes or❑No-If no,please
explain below in Section IV. Review Items
10. Were monitoring wells properly constructed and located? ❑ Yes ❑No ®N/A If no,please explain below in
Section IV. Review Items.
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑No®N/A
12. Has a review of all self-monitoring data been conducted(e.g.,NDMR,NDAR, GW)? ❑ Yes ❑No ®N/A
Please summarize any findings resulting from this review below in Section IV. Review Items.
FORM: APSRSR 04-10 Page 1 of 2

13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑Yes or®No
If yes,please explain below in Section IV.Review Items.
14. Check all that apply:
®No compliance issues ❑ Current enforcement action(s) ❑Currently under JOC
❑Notice(s)of violation ❑ Currently under SOC ❑Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments(i.e.,NOV,NOD,etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ®No ❑N/A
If no,please explain below in Section IV.Review Items.
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes®No ❑N/A
If yes,please explain below in Section IV. Review Items.
M.REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or®No
If yes,please explain:
2. List any items that you would like APS Central Office to obtain through an additional information request:
•
3. List specific permit conditions recommended to be removed from the permit when issued:
•
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
•
5. Recommendation: ❑ Hold,pending receipt and review of additional information by regional office
® Hold,pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny(Please state reasons: )
6. Signature of report preparer: �i ,p- //
Signature of regional supervisor: �� r /4u?
Date: October 2,2014
IV.ADDITIONAL REGIONAL STAFF REVIEW ITEMS
• The Permittee is requesting to continue to be allowed to stockpile WTP residuals uncovered for 60 days,as
already approved in current Permit Condition III. 10. b. ii.
WSRO recommends allowing them to continue to do this.However,a note should be added in the permit
condition that this applies to WTP residuals only, and other Class A residuals approved in this permit shall
not be stockpiled for more than 30 days.
FORM:APSRSR 04-10 Page 2 of 2

WATER QUALITY REGIONAL OPERATIONS SECTION
APPLICATION REVIEW REQUEST FORM
Date: September 17, 2014 N RECEIVED
.C.Dent.of ENR
To: WiRO-WQROS: Jim Gregson/Morella Sanchez-King SEP 19 2014
Wsnsfon-Salem
From: Troy Doby,Water Quality Permitting Section-Non-Discharge Permittin' Unit Re•ional office
Telephone: [phone] Fax: [phone] E-Mail: [e-mail]
A. Permit Number: WQ0035207
B. Applicant: Synagro
C. Facility Name: Synagro Residuals Management System
D. Application:
Permit Type: Surface Disposal of Residual Solids (503 Exempt)
Project Type:Major Modification
E. Comments/Other Information:
❑ I would like to accompany you on a site visit.
Attached, you will find all information submitted in support of the above-referenced application for your
review, comment, and/or action. Within 45 calendar days,please take the following actions:
® Return a completed WQROSARR Form. ® Return a completed WQROSSR Staff Report
❑ Attach a classification rating sheet. ❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office Water Quality Permitting Section contact
person listed above.
RO-WOROS Reviewer: 6 k r Date:
•
FORM:WQROSARR 02-14 Page 1 of 1

Central Files: APS _ SWP
•
9/16/2014
Permit Number WQ0035207 Permit Tracking Slip
Program Category Status Project Type
Non-discharge In review Major modification
Permit Type Version Permit Classification
Distribution of Residual Solids(503) E Individual
Primary Reviewer Permit Contact Affiliation
troy.doby Marshall R.Puryear
Coastal SWRule
284 Boger Rd
Mocksville NC 27028761 f
Permitted Flow
Facility
Facility Name Major/Minor Region
Distribution of Class A Residuals Major Winston-Salem
Location Address County
Randolph
Facility Contact Affiliation
Randleman NC 27317 Greg Flory
director executive
PO Box 1325
Owner Randleman NC 27317
Owner Name Owner Type
Synagro Unknown
Owner Affiliation
Marshall R.Puryear
284 Boger Rd
Dates/Events Mocksville NC 27028761
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
3/17/2011 9/5/2014
Regulated Activities Requested/Received Events
Wastewater treatment and disposal RO staff report requested
Water conditioning RO staff report received
Water treatment,surface water
Outfall
Waterbody Name Streamindex Number Current Class Subbasin

RECEIVED
N.�Dert o'i.NR
SEP 19 2'014
AVA
� Winston-Salem
NCDENR Regional Office
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
September 16,2014
Marshall Puryear—Technical Services Manager
Synagro
284 Boger Road
Mocksville,NC 27028
Subject: Acknowledgement of
Application No.WQ00035207
Synagro
Residuals Management System
Randolph County
Dear Mr.Puryear:
The Water Quality Permitting Section acknowledges receipt of your permit application and
supporting documentation received on September 5, 2014. Your application package has been assigned
the number listed above,and the primary reviewer is Troy Doby.
Central and Regional Office staff will perform a detailed review of the provided application, and
may contact you with a request for additional information. To ensure maximum efficiency in processing
permit applications, the Division of Water Resources requests your assistance in providing a timely and
complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt of a complete application. If you have any questions, please contact
Troy Doby at(919) 807-6336 or [e-mail].
Sincerely,
657)d.
csi Jon Risgaard, Supervisor
Division of Water Resources
cc: 41001111111111...11111111
Permit File WQ0035207
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
Phone:[phone] Internet:http://portal.ncdenr.orq/web/wq
An Equal Opportunity 1 Affirmative Action Employer-Made in part with recycled paper

•
Mitchell, Patrick
From: Mitchell, Patrick
Sent: Monday, December 09, 2013 12:09 PM
To: Mcdaniel, Chonticha
Subject: WQ0035207 Permit Modification
Chonticha,
As requested my comments on the application for modification of Permit No. WQ0035207 are listed below.
NOTES:
1. Change the facility name to"Distribution of Class-A Residuals" since they are proposing to include wastewater
treatment plant residuals from the City of Philadelphia. The current permit list the facility name as"Distribution
of Water Treatment Plant Residuals".
2. I'm not sure if it is necessary, but Philadelphia Renewable Biofuels was not listed under"Facility Information" on
the Distribution of Class-A Residuals form DCAR. Only Piedmont Regional Triad WTP was listed. Most of the info
for Philadelphia Renewable Biofuels is listed on the Residuals Source Certification form RSC,with the exception
of the length of residuals storage at the facility.This may not be an issue since the facility is located in
Pennsylvania. If necessary, please request this missing info trough an additional information request.
3. There is no explanation of procedures for the Philadelphia Renewable Biofuels listed in the "Operational
Functions" section of the "Operations and Maintenance Plan", in the application package. Recommend
obtaining a description of the proposed procedures through an additional information request.
4. Would the lab performing the analyses of the residuals distributed from Philadelphia Renewable Biofuels have
to be NC certified. If so,a reminder to Synagro in the cover letter would be good.
5. Request changing the Regional assignment in BIMS for Permit No.WQ0035207 from ARO to the WSRO.The
reason I suggest WSRO as the primary region in BIMS is due to there being more activity for this permit in WSRO
then any other region (i.e.three facilities located in WSRO under this permit with a total of 3,500 dry tons per
year).The annual report can also be compared to three facilities within WSRO during the facility inspections.
Please let me know if you need anything further.
Thanks,
Patrick
Patrick L. Mitchell, REHS, LSS
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environment& Natural Resources
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
FAX: [phone]
1

DWR-WATER QUALITY PROGRAMS RECEIVED
APPLICATION REVIEW REQUEST FORM =nt.of ENR
't�, t22013
Date: November 25,2013 ,.,n,ion-Salem
Regional Office
To: ❑ Landon Davidson, ARO-WQROS ❑ David May,WaRO-WQROS
❑ Art Barnhardt, FRO-WQROS ❑ Morella King, WiRO-WQROS
❑ Andrew Pitner, MRO-WQROS ® Sherri Knight, WSRO-WQROS
❑ Rick Bolich,RRO-WQROS ‘PA.> "►Gk /1/;7LC i
From: Chonticha McDaniel,CO-NDPU /
E-Mail: [e-mail]
Telephone: [phone] Fax:[phone]
A. Permit Number: WQ0035207 B. Owner: Synagro
C. Facility/Operation: Synagro Class A Distribution Program
❑ Proposed ® Existing ❑ Facility ® Operation
D. Application:
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reclaimed ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation(ND)
❑ UIC -(5A7) open loop geothermal ❑ Single Family Residence
® Residuals
2. Project Type: ❑ New ® Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
n a.hill-staff.report 4us comments'- emai tl „ .g_.
Attached, you will find all information submitted in support of the above-referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
❑ Return a Completed APSARR Form.
❑ BIMS indicates monitoring wells locations are not complete. Please update monitoring well
locations not currently in RIMS.
❑ BIMS indicates ongoing ❑ NDMR ❑NDAR ❑ GW monitoring violations. Please investigate
reoccurring compliance issues and summarize results in staff report.
❑ Attach Well Construction Data Sheet.
❑ Process Attachment B for Certification by the Land Application Unit(LAU).
❑ Issue an Attachment B Certification from the RO.*
*coordinating site visits and reviews, as well as additional information requests with other RO-APS
representatives in order to prepare a complete Attachment B for certification. Refer to the RPP SOP for
additional detail.
Please indicate the name and date assigned in the spaces below, make a copy of this sheet, and return it to
the appropriate Central Office-Aquifer Protection Section contact person listed above.
RO-APS Reviewer: Date:
FORM: APSARR 11/13 Page 1 of 1

A745274b,A
NCDE�IR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
November 22,2013
Marshall Puryear—Technical Services Manager
Synagro Corporation
284 Boger
Mocksville,NC 27028
Subject: Acknowledgement of
Application No.WQ0035207
Piedmont Regional Triad WTP
Distribution of Residuals Solid
System
Randolph County
Dear Mr.Puryear:
The Water Quality Permitting Section acknowledges receipt of your permit application and
supporting documentation received on November 22, 2013. Your application package has been assigned
the number listed above,and the primary reviewer is Chonticha McDaniel.
Central and Winston-Salem Regional Office staff will perform a detailed review of the provided
application, and may contact you with a request for additional information. To ensure maximum
efficiency in processing permit applications, the Division of Water Resources requests your assistance in
providing a timely and complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt of a complete application. If you have any questions, please contact
Chonticha McDaniel at(919)807-6337 or [e-mail].
Sincerel
for Jon • d
-Discharge Permitting Unit Supervisor
cc: INTINWPIIINIINIMPIIIIiledisimmmaiw
Permit File WQ0035207
WATER QUALITY PERMITTING SECTION
1636 Mail Service Center,Raleigh,North Carolina 27699-1636
Location:512 N.Salisbury St.,Raleigh,North Carolina 27604
Phone:[phone] FAX:[phone]
Internet htto://portal.ncdenr.oralrebluq
An Equal Opportunity 1 Affirmative Action Employer

e
• t
Mitchell, Patrick
From: Mcdaniel, Chonticha
Sent: Tuesday, December 10, 2013 9:39 AM
To: Mitchell, Patrick
Subject: FW: WQ0035207 Permit Modification
Attachments: Operational Functions doc Piedmont .doc
Importance: High
FYI
Chonticha McDaniel,
Environmental Engineer
North Carolina Department of Environment and Natural Resources
Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Phone: [phone] Fax: [phone]
http://portal.ncdenr.org/web/wq
DISCLAIMER: Email correspondence to and from this address is subject to the North Carolina Public Records Law and may
be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Puryear, Marshall [mailto:[e-mail]]
Sent: Monday, December 09, 2013 8:24 PM
To: Mcdaniel, Chonticha
Subject: RE: WQ0035207 Permit Modification
Importance: High
Chonticha, Please see the attached updated Operation functions document for Synagro permit WQ0035207, Let me
know if you need any more information to complete this permit. Also if you could send me a draft to review.
Thanks
Marshall Puryear
Area Technical Services Manager
0 434-738-8002 cell
Ct 336-998-8450 fax
t 19 336-998-7150 ext 17 office
[e-mail] email
People + Planet-> Synchronization
www.synagro.com
tn 284 Boger Road , Mocksville, NC 27028
From: Mcdaniel, Chonticha [mailto:[e-mail]]
Sent: Monday, December 09, 2013 12:24 PM
1

To: Puryear, Marshall
Subject: WQ0035207 Permit Modification
Hi Marshall,
I received comments on the subject application from Patrick in WSRO today. He pointed out that there is no explanation
of procedures for the Philadelphia Renewable Biofuels listed in the "Operational Functions" section of the "Operations
and Maintenance Plan". Please amend the plan to include a description of the proposed procedures.Thank you!
Chonticha McDaniel,
Environmental Engineer
North Carolina Department of Environment and Natural Resources
Division of Water Resources
1636 Mail Service Center
Raleigh, NC 27699-1636
Phone: [phone] Fax: [phone]
http://portal.ncdenr.org/web/wq
DISCLAIMER: Email correspondence to and from this address is subject to the North Carolina Public Records Law and may
be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Mitchell, Patrick
Sent: Monday, December 09, 2013 12:09 PM
To: Mcdaniel, Chonticha
Subject: WQ0035207 Permit Modification
Chonticha,
As requested my comments on the application for modification of Permit No.WQ0035207 are listed below.
NOTES:
1. Change the facility name to "Distribution of Class-A Residuals" since they are proposing to include wastewater
treatment plant residuals from the City of Philadelphia. The current permit list the facility name as"Distribution
of Water Treatment Plant Residuals".
2. I'm not sure if it is necessary, but Philadelphia Renewable Biofuels was not listed under"Facility Information" on
the Distribution of Class-A Residuals form DCAR. Only Piedmont Regional Triad WTP was listed. Most of the info
for Philadelphia Renewable Biofuels is listed on the Residuals Source Certification form RSC,with the exception
of the length of residuals storage at the facility.This may not be an issue since the facility is located in
Pennsylvania. If necessary, please request this missing info trough an additional information request.
3. .
4. Would the lab performing the analyses of the residuals distributed from Philadelphia Renewable Biofuels have
to be NC certified. If so,a reminder to Synagro in the cover letter would be good.
5. Request changing the Regional assignment in BIMS for Permit No.WQ0035207 from ARO to the WSRO.The
reason I suggest WSRO as the primary region in BIMS is due to there being more activity for this permit in WSRO
then any other region (i.e.three facilities located in WSRO under this permit with a total of 3,500 dry tons per
year).The annual report can also be compared to three facilities within WSRO during the facility inspections.
Please let me know if you need anything further.
2

•
OPERATIONS AND MAINTENANCE PLAN
SYNAGRO RESIDUALS LAND APPLICATION FOR WQ0035207(Synagro Central) cRF�F�
Operational Functions k
4), ept "11R
1 nstont v4I
Peg/cow Sale
07
The operation function of this project is going to involve mixing the lagoon up with a tractor powered Houle pump co
achieve a well mixed and consistent material that is suitable for land application for Chatham County North Water
System, Franklin WTP and City of Reidsville WTP . Brunswick NW WTP material will be mixed and pumped to a belt press
to press material to a cake material. Lake Townsend WTP material is going to be dredged pumped to a frat tank for
mixing then dewatered through 2 centrifuges to produce a cake material.This material will be loaded on to tractor
trailers and hauled to land application sites. Piedmont Triad WTP is going to consist of two products that are going to be
a dewatered cake product and a thickened liquid product. It is going to be spread at agronomic rates that are
determined by the nutrient and metal sample that is current for that monitoring period. Chatham County North Water
System, Franklin WTP,City of Reidsville WTP and Piedmont Triad Regional WTP thickened liquid material is going to be
spread with a liquid applicator that will use pressure to spread the material in such a way to achieve a consistent spread
pattern. Brunswick NW WTP, Lake Townsend WTP and Piedmont Triad Regional dewatered cake material is going to be
dumped in the field and loaded into a cake spreader with a front end loader. The spreader will able to spread the
material in an even and consistent manner. The material is going to be land applied on fields that have grass growing on
them that are going to either be grazed or cut for hay for animal feed some fields may be in row crop production and
rates will be determined by RYE for the crop that is going to be grown for animal consumption.
Philadelphia Renewable Biofuels material will be from a Class A pelletizer located in Philadelphia Pa. This material will
be made through the heat drying of biosolids. The material will be stored in one of the silos at the facility until such time
it is ready to be delivered to a farm. When it arrives at a farm in NC it will come with a label that list the nutrient
analysis of the pellets.The label will also have a list of the buffers as they pertain to the NC regulations.The farmer will
also be provided a phone number of a local Synagro person that can answer any buffer questions or application
questions that the farmer might have during the application of the pellets. This material will be spread with a fertilizer
spreader that will be calibrated based on the bulk density of the material.The material is going to be land applied on
fields that have grass growing on them that are going to either be grazed or cut for hay for animal feed some fields may
be in row crop production and rates will be determined by RYE for the crop that is to be grown.
SAFETY MEASURES
Synagro believes in operating in a safety conscious manner and is has all employees participate in quarterly online safety
course that are designed to help its employees recognize safety issues and take steps to prevent accidents from
occurring. In addition all Synagro employees have the authority to stop operations if they think any aspect of the
operation is going to cause environmental or personal harm.
Maintenance Schedule
Synagro will follow the maintenance schedule as recommended by the Synagro fleet manager for the equipment
necessary to complete the job.

/(4) 0-63 -C .P- ° 17
Synagro
Distribution of Residuals
Permit No. WQ0035207
2012 Annual Report
RECEIVED pj
MAY 2
Aquifer Protection Sew

ANNUAL LAND APPLICATION CERTIFICATION FORM
WQ Permit#: W00035207 County Macon Year 2012
Facility Name(as shown on permit)Town of Franklin WTP NPDES No.PWS 01-57-010
Land Application Operator Svnagro Phone# [phone]
Land application of residuals as allowed by the above permit occurred during the past calendar year?
_YES X NO. If NO,skip Part A,and Part B and proceed to Part C. Also,if residuals were generated but not land applied,
please attach an explanation on how the residuals were handled.
Part A—Residuals Application Summary:
Total number of application fields in the permit:
Total number of fields utilized for land application during the year:
Total amount of dry tons applied during the year for all application sites:
Total number of acres utilized for land application during the year:
Part B—Annual Compliance Statement:
Facility was com liant during calend ar 21 with all c nbUCátionOg2
f the landit permit(includi ut not limited to items
1- elow iss by ' ter r F %
ro a w ec' 2
it
. Only residuals approved for this permit were applied to the permitted sites.
2. Soil pH was adjusted as specified in the permit and lime was applied(if needed)to achieve a soil pH of at least 6.0 or the
limit specified in the permit.
3. Annual soils analysis was performed on each site receiving residuals during the past calendar year and three(3)copies of
laboratory results are attached.
4. Annual TCLP analysis(if required)was performed and three(3)copies of certified laboratory results are attached.
5. All other monitoring was performed in accordance with the permit and reported during the year as required and three(3)
copies of certified laboratory results are attached.
6. The facility did not exceed any of the Pollutant Concentration Limits in 15A NCAC 02T.1105(a)or the Pollutant Loading
Rates in 15A NCAC 02T.I 105(b)(Applicable to 40 CFR Part 503 regulated facilities).
7. All general requirements as specified in the Land Application Permit were complied with(applicable to 40 CFR Part 503
regulated facilities).
8. All monitoring and reporting requirements in 15A NCAC 02T.1111 were complied with(applicable to 40 CFR Part 503
regulated facilities).
9. All operations and maintenance requirements in the permit were complied with or,in the case of a deviation,prior
authorization was received from the Division of Water Quality.
10. No contravention of Ground Water Quality Standards occurred at a monitoring well or explanations of violations are
attached to include appropriate actions and remediations.
11. Vegetative cover was maintained and proper crop management was performed on each site receiving residuals,as specified
in the permit.
12. No runoff of residuals from the application sites onto adjacent property or nearby surface waters has occurred.
13. All buffer requirements as specified on the permit were maintained during each application of residuals.
Part C—Certification:
"I certify,under penalty of law,that the above information is,to the best of my knowledge and belief;true,accurate,and complete. I
am aware that there are significant penalties for submitting false information,including the possibility of fines and imprisonment for
knowing violations."
Marshall Purvear.Technical Service Director Q/�/` O 57 ob
Permittee Name and Title(type or print) Signatu e of ermitteE?— Date 3
Signature of Preparer* Date Signature of Land Applier Date
(if different from Permittee) (if different from Permittee and Preparer)
*Preparer is defined in 40 CFR Part 503.9(r)and l5A NCAC 02T.1102(26) DENR FORM ACF(12/2006)

Residuals Handling in Calendar Year 2012
Town of Franklin, NC
Permit No. WQ0035207
No residuals from the Town of Franklin's water treatment plant (PWS 01-57-010) in
Franklin, NC were land applied in 2012. The facility has been retaining the biosolids
within available onsite storage vessels at the treatment facility location.

2012 ANNUAL REPORT
PROJECT: Town Of Franklin WTP
Franklin NC
FACILITY: Town of Franklin WTP
437 Industrial Park Road
Franklin, NC 28744
(828)-369-8998
WTP NPDES: PWS 01-57-010
RESPONSIBLE OFFICIAL: Marshall Puryear TSD
284 Boger Road
Mocksville, NC 27028
[phone]
FACILITY OPERATOR: Robert Hartzel, WTP Superintendent
Town Of Franklin WTP
437 Industrial Park Road
Franklin, NC 28744
(828)-369-8998