NC0063096_Pretreatment_Annual_Report_20210226

The Town of
HOLLY
SPRINGS
February 24, 2021
ater "esources
Town of Holly Springs (NPDES, NC0063096)
2020 PAR Narrative
GENERAL PROGRAM INFORMATION
• Attached is the Pretreatment Program Info Sheet- (Attachment 1)
• The HWA was submitted to DWR on 10-30-2017 and approved 02/22/18. The allocation
table attached (Attachment 2) is representative of our most current approved HWA/AT.
• The Town of Holly Springs (TOHS) was granted a recension of the land application permit
WQ0019098 in a written letter dated August 29, 2017. The Town did not land apply sludge
in the calendar year 2020.
• The LTMP was submitted to PERCs Unit August 31, 2018 and Approved October 26, 2018.
• There has been welcomed assistance with the industrial sampling from Brendan Reeser
Reclaimed Water/FOG manager.
• On September 4th, a Pretreatment Compliance Inspection was conducted by Mr. Cheng
Zhang, of the Raleigh Regional Office. A copy of that inspection is attached (Attachment
3).
GENERAL PERMIT INFORMATION
TOHS has two Significant Industrial Users (SIUs) one of which is also a Categorical Industrial
User (CIU). Neither SIU has been in SNC during the year 2020.
SIU INFORMATION
South Wake Landfill, (IUP # 001) Known as SWL
• There was a change in operations staff at South Wake Landfill (SWL). Shawn Wilson of Operations
left employment in February 2020. Primary Contacts continue to be Troy Mitchell and Roy Baldwin.
• There was an advanced notification from Smith Gardner Engineering on behalf of Wake County
Disposal for future construction involving a modification to the leachate storage tank located at
SWL. The modification never took place though it still remains in the plans.
• Communication was made with Troy Mitchell on March 25th, 2020 in regards to reviewing the
requirement with his contract laboratory as to what constitutes a composite sample as written in his
permit which requires the documented times for composite beginning and ending. The contracted
lab sampler had not entered the information needed on the Chain of Custody. Information was later
provided.
• April 16, 2020 Stacey Smith with Smith Gardner Engineering sent a letter on behalf of Wake
County Disposal requesting a relief from (2) conditions of the permit as written as well as a
reduction in sampling and monitoring frequency for SWL. Below is a summary of responses to
P.O. Box 8 • 150 Treatment Plant Rd • Holly Springs, NC 27540 • Tel. [phone] • Fax. [phone]
debra.batten(a�hollyspnncsnc.us • www.hollyspringsnc.us

these requests. Attachments of correspondence are included with the Pretreatment Annual Report
(PAR)- (Attachment 4).
1) Request was made for the removal of the certified operator requirement as the modifications to
the pretreatment system referenced above had been postponed "indefinitely" and no advanced
treatment was occurring that the requirement of the certified operator was not necessary until
the upgrades have been put in place and advance treatment occurs. Response: There had
been a misinterpretation of their permit. According to the permit, it was recommended there be
a certified Operator in Responsible Charge. It would only become a requirement "Upon
Classification" by the Water Pollution Control for when the Storage Tank become a Classified
Pretreatment System. No change was necessary.
2) It was presented as an opinion of Mr. Smith that "based on the correspondence with the
manufacturer of the flowmeter being used for discharge monitoring the calibration test was only
recommended every 5 to 10 years. Annual test has been done previously and have remained
consistent without adjustment. These certifications have been provided annually." It is his
opinion the increased flow calibration test is not warranted. Response: Flow meters need to be
calibrated when a defensible accuracy is required. In some cases, meters may be calibrated
every day against a built-in calibration device. Though the most common requirement is annual
calibration the recommendations and requirements can very dramatically depending on the
application, industry or QA requirements monthly, quarterly, or semiannually if you do mostly
critical measurements and do them often, a shorter time span between calibrations means less
chance of questionable results. For this reason, the TOHS now requires all industries to
provide this calibration semiannually. With weekly monitoring requirements TORS does not see
this as excessive for our permitted industries and the requirement remains as written.
3) It was requested the weekly sampling and monitoring be reduced to bi-monthly for the
parameters of pH, Temperature, BOD, TSS, Ammonia, Total Nitrogen and Total Phosphorus.
The justification was based on the previously established trend for managing the parameters for
"many years". Over the past 10 years the site has not experienced any exceedances or
encountered any non-compliance for operations. "This demonstrates 100% reliability of flow
monitoring."
Response:
a. The leachate from SWL is highly toxic to biological wastewater treatment
systems such as the TOHS Utley Creek Water Reclamation Facility.
b. The SWL storage tank has not been classified as a pretreatment system.
Because of this, there is need of consistent thorough evaluation through data
monitoring.
c. SWL has on numerous occasions needed biological "seeding microorganisms"
and technical assistance due to the toxic conditions of the discharge while
utilizing the storage tank as a location for their means of treatment. This
statement is not meant to discourage SWL from seeking assistance from the
TOHS Water Quality department but is to show the long-term pattern of
inconsistent utilization of the storage tank.
d. Finally, in the permitted discharge limits of the UCWRF NPDES permit, the
nutrient limits are concentration based and nearing the limitations of the
technology available. Water Quality department must have a firm understanding
of the loading characteristics of nitrogen and phosphorus from all sources.
For these reasons regarding the weekly monitoring the permit requirements remains as written.
• April 23 an email noting a new policy regarding splitting samples with TOHS was sent to Mr. Roy
Baldwin and Troy Mitchell. (See -Attachment 5)
P.O. Box 8 • 150 Treatment Plant Rd • Holly Springs, NC 27540 • Tel. [phone] • Fax. [phone]
debra.batten(a)hollyspnngsnc.us • www.hollyspringsnc.us

• On May 20th contact was made to Troy Mitchell in regards to an extremely low phosphorus value on the
April 13th monitoring sample. It was determined the contract lab had left a dilution factor off during
calculation of the final result. A correction was made and the monitoring report was resubmitted.
There were no violations as a result of this issue.
• Semi Annual monitoring samples were collected by the TORS on June 16, 2020.
• On June 29'h there was an electrical issue with the flowmeter so notification was given there would be
no discharge until the meter was repaired and put back in operation. The repair was completed on
June 30, 2020. There were no flows between June 26-July 5'h, 2020 due to this issue.
• While working on surcharges for SWL for the months of June/July I noticed the signature on the cover
letter for the DMR submission had been changed from Troy Mitchell to Travis Hitchcock. I contacted
Roy Baldwin, Primary Contact, to inquire and was told he was no longer with the facility. I asked Mr.
Baldwin to follow up with a list of current contacts (on letter head) and reminded going forward this
notification was required as a part of his Industrial User Permit. An email was received from Mr.
Hitchcock listing him as a temporary contact and a letter followed listing the contacts for SWL. Mr.
George Metcalf was the person to replace Troy Mitchell as Primary Contact.
• The annual on -site inspection was conducted on September 2, 2020 and a copy of the inspection has
been included with the PAR.
• During the Pretreatment Compliance Inspection, I discussed with Mr. Zhang the many issues there had
been with SWL since my employment. Recommendations were that I contact staff at the Permitting
Section of NC DWQ and contact information was given. Discussions with Mrs. Dana Foley have been
beneficial. New staff at the SWL facility continue to work on a resolution to ongoing issues.
• There was a meeting September 25'h with TORS, the new staff from SWL and their new engineering
contact Katie Jones of Dewberry Engineering. This meeting was to discuss the ongoing issues that
had been being experienced with the operations of the storage tank no longer performing as it did prior
to mid-2018. The meeting was productive. Mrs. Jones had ideas that she was going to propose to
SWL to help return operations to a normal discharge pattern. Until that time SWL would continue to
operate and discharge based on daily ammonia monitoring to maintain permit compliance.
• Notification was received on October 28'h that the Storage Tank would be taken out of service and
there would be no discharge sent to TOHS. I was to be receiving a plan of action from Dewberry
Engineering on their plans.
• Communication was received from Katie Jones of Dewberry Engineering on October 30, 2020 with an
outlined plan of action. A copy of that email as well as continue updates beginning 11/13/20 through
02/04/21 are attached (Attachment 6). Communications continues as they are now looking at other
options to further improve pretreatment.
• There were no flows and therefore no sampling taken place in the month of November thru the first
week of December 2020.
• On November 6, 2020, TOHS received a request for Authorization to Construct (ATC). There were
plans to expand the existing landfill gas (LFG) collection and control system. This request was denied
due to the inability to treat the discharge at permit limits for example: The total volume discharged, of
the combined waste streams, for September 2020 was 520,424 gallons and only 13.47 % (70,124
gallons) was discharged to TORS. Exceeding this volume of discharge, at current ammonia levels,
would have resulted in Non -Compliance of Permit Limits for ammonia. The other 86.53 % (450, 300
gallons) were pumped and hauled. In addition, provided was a "Historical Review of SWL from 2018-
2020". This review included the many issues that had taken place since my employment with the
TOHS in July, 2018. See attached letter requesting the ATC and the response from TORS
(Attachment 7).
P.O. Box 8 • 150 Treatment Plant Rd • Holly Springs, NC 27540 • Tel. [phone] • Fax. [phone]
debra.battennohoflvspringsnc.us • www.hollyspringsnc.us

Seqirus, (IUP#002)
• Seqirus operated normally in 2020 without violations issued.
• There was a change of contact February 1, 2020. Sean Rasmussen was replaced with Rachel Baker
until a permanent replacement was hired. Allan Wise continued as Primary Contact.
• During a meeting on February 24th, 2020 there was a request made by Allan Wise and Rachael Baker
to make a clarification on the Permit to define Semi Annual Monitoring Periods to January 1- June 30
and July 1- December 31. They requested the for the definition of annual to be included in the
definitions page as meaning once per year within the dates of January 1-December 31 each year.
These requests will be completed the next time the permit is open or at the time of renewal.
• April 23 an email noting a new Policy regarding Splitting Samples with Holly Springs was sent to Mr.
Allan Wise and Rachel Baker. (See Attached- Attachment 8)
• June 12th, 2020 an additional contact of Nilsa Serrano -Ortiz was added for sampling and monitoring.
• Semi Annual monitoring samples were collected by the TORS on June 16, 2020. Theses samples
were collected as split samples and an average of all lab results with acceptable QC were reported.
• June 22, 2020 a letter (dated May 20,2020) was received from Allan Wise updating contacts for
Seqirus: Primary contact: Robert Resek, Secondary: Corma Jarret, and Tertiary Contact: Rachel Baker.
• The second set of Semi -Annual monitoring samples were collected by the TORS on September 2,
2020. Theses samples were collected as split samples and an average of all lab results with
acceptable QC were reported.
• The annual inspection was conducted over a period of two days from 10/01/-10/02/2020. The
inspection was broken up to accommodate the schedules of those needing to escort us through out
various parts of the facility (The inspection in its entirety is attached- Attachment 9).
Dental Amalgam Rule
• TOHS was provided a list on licensed dentist and their addresses, though the majority of them practice
in other locations, the contact was made and documented. In addition to that list we reached out to our
towns business development records and did internet research locating the dentist that actually practice
within the TOHS. A total of 59 dentists that were contacted with a total of 28 practicing in TORS. Of
the 29 practicing in TORS, 16 have at least 1 amalgam separators and in accordance to our Sewer Use
Ordinance will be inspected annually. The response rate being 100% with persistence including
"Certified Letters", a second mailing where needed, email notifications, and phone calls. There were
four NOVs issued and a second NOV in accordance with the ERP. All are currently compliant. Please
see (Attachment 10).
DebtH/C. Batten
E vironmental Compliance Manager
U ey Creek Water Reclamation/Town of Holly Springs
P.O. Box 8 • 150 Treatment Plant Rd • Holly Springs, NC 27540 • Tel, [phone] • Fax. [phone]
debra.batten(a hollvsnringsnc.us • www.hollyspringsnc.us

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name Town Of Holly Springs
2. "Primary" NPDES Number NCOO 63096
or Non Discharge Permit # if applicable => WQ0032289
PAR Begin Date, please enter 01/01/yyyy 3. => 1/1/2020
4. PAR End Date, please enter 12/3 1/yyyy 4. => 12/31/2020
5. Total number of SIUs, includes C1Us 5. => 2
6. Number of CIUs 6. _> 1
7. Number of SIUs with no IUP, or with an expired IUP 7. _> 0
8. Number of SIUs not inspected by POTV 8. => 0
9. Number of SIUs not sampled by POTW 9. => 0
10. Number of SIUs in SNC due to IUP Limit violations 10. => 0
11. Number of SIUs in SNC due to Reporting violations 11. _> 0
12. Number of SIUs in SNC due to violation of a Compliance Schedule, CO, AO or similar 12. _> 0
13. Number of ClUs in SNC 13. => 0
14. Number of SIUs included in Public Notice 14. _> 0
15 Total number of SIUs on a compliance schedule, CO, AO or similar 15. _> 0
16. Number ofNOVs, NNNCs or similar assesed to SIUs 16. _> 0
17. Number of Civil Penalties assessed to SIUs 17. _> 0
18. Number of Criminal Penalties assessed to SIUs 18. _> 0
19. Total Amount of Civil Penalties Collects 19. _> $ 0.00
20. Number of IUs from which penalties collected 20. _> 0
Foot Notes:
AO Administrative Order IUP Industrial User Pretreatment Permit POTW Publicly Owned Treatment Works
CIU Categorical Industrial User NNC Notice of Non -Compliance SIU Significant Industrial User
CO Consent Order NOV Notice of Violation SNC Significant Non -Compliance
IU Industrial User PAR Pretreatment Annual Report
revised 1/2018: PAR PPS 2018

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Attachment 1
Pretreatment Program Info Database
for Program Name
WWTP Name
Program Approval Date
Pretreatment Status
Region
County
NPDES Number
NPDES Effective Date
NPDES Expire Date
POTW is Primary WWTP
Design Flow mgd
WWTP SIU's
WWTP CIU's 1
date Inactive
Formal Name
Holly Springs
Utley Creek
09/05/2006
Full
RRO
Wake
NC0063096
11/01/2017
07/31/2021
TRUE
6.0000
% Des'
Program Sills
Program CIUs 1
Date Next Due
Date Received by DWR
Date Approved
Adopt Date Required
Date Adopted
om Pt Contacts
PT_Pro
a:Prime Phonel
printed on: 12/22/2020
Stream Information
7010 Flow cfs / mgd
1 Q10 Flow cfs / mgd
Stream Classification
IWC % at 7Q10 98.83
.11 / 0.07
0.09 / 0.06
C
Basin Number CPF07
Receiving Stream Name Utley Creek
Last PAR Rec 03/02/2020
Current Fiscal 09/04/2020
Year PCI Done
Last Audit on 09/07/2017
gn mgd is SIU permitted
05/01/2022
5.00
12/31/2016 1. 08/31/2018
02/22/2018 I 10/26/2018
ext
Fax
PAR Due Date 03/01/2021
Audit Year Next21/22
Permitted SIU flow (mgd) [Pt_SIU)
SUO
09/30/2021
09/29/2016
10/19/2016
r'. Date Date
Attended Attended
HWA Wksp ;IUP Wksp
11/08/2012
12/07/2012
11/06/2012
Date
Attended
PAR Wksp
mercury
1631
required
yes
ERP';
06/22/2010
08/04/2010
Mc Seann Byrd
i1919-577-1090
1919-577-2280
II '
1 -
I '.
[e-mail]
Public Utilities Director
P
O. Box 8
27540
Ms. Katelyn Tresino
I
(919-577-2273
Lab Technician
P
O. Box 8 1
7540
Debra Batten
(Prim
11(919)557-2907
I
I
11 4/11/2019
5/24/2016
(s.
[e-mail]
Labom
Manager/Pretreatment
P
0. Box 8
7540
ory
Pretreatment RelatedNOVs from.DWQ.
DWR Central Office Contact
DWR Regional Contact
Zhong
Cheng Zhang

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ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
September 25, 2020
Attachment 3
Mr. Seann Byrd
Water Quality Director
Town of Holly Springs
P.O. Box 8
Holly Springs, NC 27540
Subject: Pretreatment Compliance Inspection
Town of Holly Springs
Utley Creek WWTP - NPDES Permit No. NC0063096
Wake County
Dear Mr. Byrd:
On September 4, 2020, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Compliance Inspection of Town of Holly Springs' pretreatment program. The
assistance given by Ms. Debra Batten, the lab manager and pretreatment coordinator, was
greatly appreciated. The inspection report is attached. Findings during the inspection were as
follows:
1. Town of Holly Springs has two Significant Industrial Users (SIUs), one of which is also
Categorical Industrial Users (CIUs). It was noted that neither SIU was in SNC during the
two most recent semi-annual periods.
2. The pretreatment inspection file review included Seqirus, Inc. (Permit No. 002) and
South Wake Landfill (Permit No. 001). The files needed for review were available for
inspection, contained all the required elements and were in excellent condition.
3. The POTW and both SIUs completed monitoring as required by the IUPs during the first
send -annual period of 2020, both SIUs were in compliance. Although South Wake
Landfill was in compliance in the past two semi-annual periods, it has been having
difficulty to remove ammonia in its pretreatment process, as a result, the facility s flow to
the POTW has been limited, and has to pump and haul its wastewater to another
wastewater treatment plant out of the region (Lumberton WWTP). Ms. Batten has been
discussing solutions to solve South Wake Landfill's pretreatment issues with
pretreatment staff in DWR Central Office
4. A review of the files containing the pretreatment program elements was conducted All
pretreatment program elements are up to date.
o/primnaaO"n, anmunun
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

5. The review of Long Term Monitoring Plan (LTMP) data indicated that all locations were
sampled with required frequencies and detection limits since last inspection. It was noted
that LTMP data which were not available for review during the previous inspection were
successfully retrieved.
Thank you for your continued support of the Pretreatment Program. If you have any questions
or comments, please call Cheng Zhang at [phone] (or email cheng.zhang(c1�,ncdenr.gov).
Sincerely,
1—Docuslgned by:
Vig/lLSSel. t. kg/ &d
`-82918E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Holly Springs PCI Inspection Form
CC: Central Files w/attachment (Laserfiche)
Cheng Zhang, RRO
Debra Batten, Town of Holly Springs (Electronic copy only)

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL REALITY
BACKGROUND INFORMATION [Complete Prior To PCI: Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Town of Holly Springs
2. Control Authority Representative(s): Debra Batten
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: September 26, 2018 Inspection Type (Check One): ® PCI n Audit
5.
6. Is POTW under an Order That Includes Pretreatment Conditions? YES // NO
Order Type, Number, Parameters:
ICIS CODING
Main P ogram Permit Number
J NIC I O 10 1613101916[
Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
Are Milestone Dates Being Met? ❑ YES • NO
MM/DD/YY
J 09104120J
7. Current Number Of Significant Industrial Users (SIUs)?
2
8 Number of SIUs With No IUP, or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year9
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year9
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13, Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
1
15. Current Number Of Categorical Industrial Users (CIUs)?
16. Number of CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
Not Put
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
®
YES
■
NO
To
al phosphorous
11/2018
❑ YES
►/
NO
Limits: None
Reporting: None
lished: None
None
❑
YES
I
NO
LTMP/STMP FILE REVIEW:
22 Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and F •equenc es? ® YES NO
23. Are Correct Detection Levels being used for all LIMP/STMP Monitoring? A/ YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? YES ❑ NO Is Table Adequate? Z YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ►1 YES • NO Division Inspector, please verify yourselfl
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ►1 NO
If yes, which ones? Eliminated: Added:_
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
•files complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworlcs Analysis (HWA)
10/30/2017
® Yes
•
No
2/23/2018
® Yes ❑ No
5/1/2022
Lndustrial Waste Survey (IWS)
9/26/2016
® Yes n No
10/19/2016
/1
Yes ❑ No
9/30/2021
Sewer Use Ordinance (SUO)
11/8/2012
2/
Yes
•
No
12/7/2013
S.
Yes ❑ No
6/22/2010
//
Yes ❑ No
8/4/2010
/1
Yes ❑ No
Enforcement Response Plan (ERP)
Long Term Monitoring Plan (LTMP)
8/31/2018
N
Yes
❑
No
10/26/2018
aI
Yes ❑ No
INDUSl'RIAL USER PERMIT
(IUP)
PILE REVIEW (3 lUY tIL1: ICRVIL W $ UR 1 t'ILL' i vrnw IUNJ 11u 1NvornL11v1N)
29. User Name
1 I. South
Wake Landfill
2. Segirus, Inc.
3.
001
002
30. IUP Number
31. Does File Contain Current Permit?
®
Yes
•
No
//
Yes
❑ No
32. Permit Expiration Date
12/31/2023
10/31/2022
N/A
439.17
&
47
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
34. Does File Contain Permit Application Completed Within One Year Prior
M
Yes
Li
No
iI
Yes
❑
No
to Permit Issue Date?
_
35. Does File Contain an Inspection Completed Within Last Calendar Year?
N
Yes
❑
No
—.
/A
Yes
❑
No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a.
®Yes
❑No
a.
b.
X4
•Yes
Yes
•No
■No
b.
❑Yes
❑No
■Yes❑NoNN/A
❑YesONobN/A
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a.
b.OYesONoDN/A
ccYes
•No
a,
b.DYesDNoDN/A
NYes
•No
/1
Yes ❑ No
® Yes
•
No
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
_.
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
�/
Yes
•
No
—'
®
Yes
No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
NYes❑No
•N/A
NYesUNo❑N/A
NYes❑No❑N/A
NYes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
42a. For categorical Ms with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
1Yes/No:rN/A
OYes•NoNN/A
42b. For categorical Ns with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
43a, During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
❑Yes❑NoNN/A
❑Yes❑No.N/A
43b. During
All
the
Reporting
Most Recent Semi -Annual Period, Did the POTW Identify
Non -Compliance from SIU Sampling?
■Yes❑NonN/A
❑Yes•NoecN/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
a.OYesDNo®N/A
b.OYes0NotaN/A
c.OvesONo®N/A
a.DYesDNo®N/A
b.OYesONo®N/A
apYesONo N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
•
Yes
►/
No
❑
Yes
®
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑N0r_rN/A
❑Yes❑No n N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
■Yes❑NoNN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No :cN/A
❑Yes❑NoNN/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.UYesONo®N/A
b.DYesONoa N/A
a.DYesDNaa N/A
b.OYesONo®N/A
b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
n Yes
►1 No
n Yes
4
No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
Although South Wake Landfill was in compliance in the past two semi-annual periods, it has been having difficulty to remove ammonia
in its pretreatment process, as a result, the facility's flow to the POTW has been limited, and has to pump and haul its wastewater to
another wastewater treatment plant out of the region (Lumberton WWTP).
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
ill 1 1 1 1 1 1 I 1 1 1 l
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:_
4. Industry Contact: Title: Phone: Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? • YES ❑ NO
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview • YES • NO
B. Plant Tour ❑ YES ■ NO
C. Pretreatment Tour ❑ YES • NO
D. Sampling Review ■ YES ❑ NO
E. Exit Interview ■ YES ■ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: The program is well managed
Requirements: None
Recommendations: Discuss with DWR Central Office staff about operation (nitrification) at South Wake Landfill.
NOD: E1 YES NO
NOV: ❑ YES NO
QNCR: ■ YES /1 NO
POTW Rating:
Satisfactory • Marginal • UnSatisfactory 1
PCI COMPLETED BY: Cheng Zl ang, Raleigh Regional Office DATE: September 04, 2020
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

Attachment 4
Debra Batten
From: Stacey Smith <[e-mail]>
Sent: Thursday, April 16, 2020 7:55 PM
To: Debra Batten
Cc: John Fearrington; John Roberson; Roy Baldwin; Travis Hitchcock; Bryan Wuester; Troy
Mitchell
Subject: --[EXTERNAL]--TONS Relief Request Letter 4-16-20.pdf
Attachments: TOHS Relief Request Letter4-16-20.pdf
Debra,
Following our conversation last week, please find our request for relief from some of the conditions of the newest
IUP. Please feel free to contact me with any questions or concerns.
Thank you.
sas
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
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Stacey A. Smith, P.E.
President, Senior Engineer
SMITH GARDNER, INC.
14 N. Boylan Avenue
Raleigh, North Carolina. 27603
Ph. [phone]
Cell. [phone]
www.smithgardnerinc.com

DocuSig Envelo e ID: DABDB138-2C76-4F1C-B860-3FCC5F7B1A40
SMITH:GARDNER
ADDRESS TEL
WEB
14 N. Boylan Avenue, Raleigh NC 27603 919.828.0577 wwwsmithgaNnerinc.com
April 16, 2020
Ms. Debra C. Batten
Pretreatment Coordinator
Utley Creek Water Reclamation
Town of Holly Springs
PO Box 8
Holly Springs, NC 27540
Re: South Wake Landfill
IOPnooi
Holly Springs, North Carolina
Dear Ms. Batten:
On behalf of Wake County Disposal, LLC (WCD) and Wake County, Smith Gardner, Inc. (SAG) is
requesting relief from two (21 conditions for the above referenced permit. As you are aware, IUP Part
3, Section E requires a certified wastewater pretreatment plant operator, Part 3, Section C requires
flowmeter calibrations twice annually and Part 1, Section F requires weekly sampling for the following
parameters:
• pH
• Temperature
• BOD
• TSS
• Ammonia
• Nitrogen, T
• Phosphorous, T
WCD is requesting 1) removal of the certified operator requirement, 2) annual calibration of the
flowmeter and 3) decreasing the frequency of sampling for the parameters listed above to bi-monthly
(every two (2) weeks). Further discussion on the basis of this request is provided below on each of
these requests.
Certified Plant Operator
The site teachate management operations forecasted additional pretreatment upgrades in 2020.
However, these upgrades were postponed indefinitely. The current operation includes physical
methods of mixing and aeration for nitrification of ammonia. No further advanced treatment is
occurring at the site. Therefore, it is our opinion the certified plant operator is not necessary until
such time upgrades have been made and advanced treatment occurs.
Flawmeter Calibration
The existing flowmeter that is used for discharge monitoring is a Seametrics EX-82. Based on
correspondence with the manufacturer, a flow calibration (test) is recommended every five (51 to ten
(10) years. Since operations have begun, annual calibrations (tests) have been performed and have
remained consistent without adjustment. These certifications have been provided annually to the
Town. Therefore, it is our opinion the increased frequency of flow calibration tests is not warranted.

DocuSign Envelope ID. DABDB138-2C76-4F1 C-B860-3FCC5F7B1A40
Ms. Debra Batten
April 16, 2020
Page 2 of 2
Sampling Frequency
WCD has established a consistent trend for management of these parameters for many years. Over
the past ten (10) years, the site has not experienced any exceedances and has not encountered any
non-compliance for operations. This demonstrates 100% reliability on flow monitoring by WCD.
Based on the information provided above we feel that the site is justified in support of this request. If
this request requires permit modification, please advise. We appreciate your assistance and hope that
our request addresses any Town concerns. If you have any questions or require additional
information, please feet free to contact us at (9191 828-0577 or by email below.
ttttttttttttt
Sincerely, ���CAR
SMITH GARDNER INC. `►`..Essf.................
;
•
=q gEAL col 4 n 6/2020
Docusiened3: f 023002+ mcusi ae
rP gne7 y:
Qr Noise •1I. `.-4.4-t u:nytdn.
Senior Engineer,Stacey P ?41 ' a ��Aii•
. ... Project6Engineer, extP1•E2"5
stacevfdsmithgardnerinc.com johnffasmithgardnerinc.com
sas/jrf
CC: Mr. Troy Mitchell, Wake County Disposal, LLC
Mr. Travis Hitchcock, GFL Environmental
Mr. Bryan Wuester, GFL Environmental
Mr. John Roberson, P.E., Wake County
Mr. Roy Baldwin, Wake County
File
\\ratnas\Office_share\Projects\South Wake\06 Leachate Disposal \Town of Holly Springs\Relief Request Letter 4-16-20.docx

The Town of
HOLLY
SPRINGS Department of Water Quality
May 8, 2020
Mr. Stacey Smith P.E.
Smith +Garner Engineering
14N Boylan Ave.
Raleigh, NC 27603
Re: TORS Relief Request
South Wake Landfill
IUP # 001
Mr. Smith,
In response to the request for relief from the conditions of IUP #001 issued to South Wake Landfill
consideration and review of each request has been given and responses for each are stated below;
1. Regarding to the relief of the requirement of the certified operator: The requirement is as cited in the
permit is based on rules NC Pretreatment rules stating "a)Upon classification of pretreatment facilities
permitted under this Section and upon development of specific certification and training programs for
o perators of classified facilities, the industrial user shall designate an operator in responsible charge
and a back-up operator as required by the Water Pollution Control System Operators Certification
Commission as established in Subchapter 08G of these Rules. b) In order to insure the proper operation
and maintenance of facilities permitted under this Section and classified under the rules of the Water
Pollution Control System Operators Certification Commission (Subchapter 08G of these Rules), the
o perator in responsible charge, or a back-up operator when appropriate, shall operate and visit the
facility as required by the Water Pollution Control System Operators Certification Commission as
established in Subchapter 08G of these Rules. As referenced in 15A NCAC 02H .0920 PRETREATMENT
FACILITY OPERATION AND MAINTENANCE a) Pursuant to conditions of Title 15A, Chapter 8G.0200
North Carolina General Statutes, upon classification of the facility by the Certification Commission, the
permittee shall employ a certified wastewater pretreatment plant operator in responsible charge
(ORC) of the wastewater treatment facilities. Since the storage tank at SWLF has not yet been
classified as a Pretreatment Facility, I will agree to the temporary relief of the requirement. At the time
that the "Pretreatment Facility" (Storage Tank) has been "classified" by the Certification Commission,
the requirement will be reinstated.
2. Regarding the relief of the requirement of twice annually calibration of the flow meter: Flow meters
n eed to be calibrated when a defensible accuracy is required. In some cases, meters may be calibrated
every day against a built-in calibration device. Though the most common requirement is annual

calibration, the recommendations and requirements can vary dramatically depending on the
application, industry regulation, or QA requirements to monthly, quarterly, or semiannually if you do
mostly critical measurements and do them often, a shorter time span between calibrations means less
chance of questionable test results. For this reason, The Town of Holly Springs require all industries to
provide this calibration a semiannual requirement. With weekly monitoring requirements TOHS does
not see this as excessive for our permitted industries. Requirement remains as written in the IUP.
3. Regarding the relief of weekly monitoring: The monitoring requirements of the IUP were instituted for
multiple reasons.
a. The leachate from South Wake Landfill is highly toxic to biological wastewater treatment
systems such as the Town of Holly Springs Utley Creek Water Reclamation Facility.
b. The South Wake Landfill storage tank has not been classified as a pretreatment system.
Because of this, there is need of consistent thorough evaluation through data monitoring.
c. South Wake Landfill has on numerous occasions needed biological "seeding microorganisms"
and technical assistance due to the toxic conditions of the discharge while utilizing the storage
tank as a location for their means of treatment. This statement is not meant to discourage
SWLF from seeking assistance from the TORS Water Quality department but is to show the
long-term pattern of inconsistent utilization of the storage tank.
d. Finally, in the permitted discharge limits of the UCWRF NPDES permit, the nutrient limits are
concentration based and nearing the limitations of the technology available. Water Quality
department must have a firm understanding of the loading characteristics of nitrogen and
phosphorus from all sources.
For these reasons regarding the weekly monitoring, Requirement remains as written in the IUP.
If you have any other questions or concerns, please do not hesitate to contact me.
Resp
eira'C. Batten
En ironmental Compliance Laboratory Manager/Pretreatment Coordinator
Utl y Creek Water Reclamation/Town of Holly Springs
Cc:
Mr. Seann Byrd
Mr. Troy Mitchell WCD, LLC
Mr. Travis Hitchcock, GFL Environmental
Mr. Bryan Wuester, GFL Environmental
Mr. John Roberson, Wake County
Mr. Roy Baldwin, Wake County
File

Attachment 5
Debra Batten
From: Debra Batten
Sent: Thursday, April 23, 2020 2:44 PM
To: [e-mail]; Troy Mitchell; Wise, Allan US/HSP; Baker, Rachel US/HSP
Subject: TOHS Policy for Splitting Samples
Attachments: TOHS Split Samples Policy 05012020.doc
Importance: High
Good afternoon all,
I hope this email still finds all doing well.
As I am quickly approaching the time frame for performing Semi Annual Monitoring for The TORS permit requirements I
wanted to send you the new policy for the Town of Holly Springs on splitting samples. As in previous discussions, I have
shared correspondence from NC DWQ Pretreatment Section and there recommendations on the topic. The response
was "POTWs are not required to split samples with the Ills." They go on to say "It is not recommended that POTWs
use split samples with the industry to satisfy its annual or semi-annual sampling requirements. The POTW should pull
its own samples so that it has data which are truly independent of the IU's results." For this reason it was the practice
of the Pretreatment program that I came from not to allow the splitting of sampling being performed for the monitoring
requirement of the PTOW. As this practice was allowed prior to my position with Town of Holly Springs I will continue to
allow the split sampling as long as the TOHS Policy attached is followed.
Respectfully,
Debra C. Batten
Environmental Compliance Laboratory Manager/Pretreatment Coordinator
Utley Creek Water Reclamation/Town of Holly Springs
PO Box 8 I Holly Springs, NC 27540
Office: [phone] ) Ce11: [phone] I Email: debra.batten(a hollyspringsnc.us
Town Website: www.hollyspfinksfic.us
Sent from Mail for Windows 10
1

Industrial User Requirements for Sphtting a
Sample
Though NC Department of Water Resources does not recommend the practice, splitting
samples is permitted under the following conditions•
• Results of multiple samples meeting requirements are acceptable and an average
with the POTW results of the same sample to evaluate the industrial User's
wastewater:
Contributor must follow and document 40CFR136 and North Carolina procedures for
collecting, handling and analyzing the split sample. The burden of proof is on the
Industrial User.
Industrial User must provide acceptable bottles with the required preservation at time of
sampling
A POTW representative and a Industrial User representative must be present at the split.
The sample must be mixed well, as always, before pouring any amount into any of the
sample bottles. After the POTW has gotten the sample it needs for its purposes, the
Industrial User may use the remaining sample for a split.
The Town of Holly Springs will also send a split sample to a third lab for analysis. The
Industrial User will be responsible for the expenses of these extra analyses.
The Industrial User may not use the split to fulfill its self -monitoring requirements. See
explanation below:
This is to clarify the use of split samples that are given by the Town
of Holly Springs during wastewater sampling events. Title 40 Code of
Federal Regulations 403.8(f)(1)(v) states that the City shall carry out
all inspections, surveillance and monitoring procedures necessary to
determine, independent of information supplied by Industrial Users,
compliance or noncompliance with applicable Pretreatment Standards and
Requirements by Industrial Users.
Therefore, industries who obtain split samples from the Town may not
use those results to fulfill the self -monitoring requirements as set
forth in the industrial user permits. Those results will, however, be
reported to the Town and the Town will record all results individually
and as an average. The average of all data meeting the requirements of
each analysis will be used for compliance judgement.

Town of Holly Springs Procedure for Splitting Samples
Because all acceptable results from the split must be used to get an average result, it is
important that the POTW and the Contributor are following all of the required procedures
in collecting, handling and analyzing a split sample. The Industrial User's
responsibilities are in "Industrial User Requirements for Splitting a Sample."
1. Make sure that the Industrial User is meeting the requirements in "Industrial User
Requirements for Splitting a Sample" before allowing the split and/or accepting results of
a split from the Industrial User.
2. Enough sample should be collected for a three-way split: POTW-regular lab, POTW-
third party lab, Industrial User.
3. A POTW Representative and an Industrial User representative must be present at the
split. The sample must be mixed well, as always, before pouring any amount into any of
the sample bottles. After the POTW has gotten the sample it needs for its purposes
(including the third party lab), the Industrial User may have the remaining sample for a
split.
4. On the chain of custody, it must be noted that a split was done and signatures received
from both individuals receiving the split samples these individuals should also have
chains of custody and/or copies thereof.
5. REMEMBER: Industrial User may not use a split sample result for self -monitoring
requirements! The Industrial User must sample separately.

Attachment 6
Debra Batten
From: Jones, Katie L. <[e-mail]>
Sent: Friday, October 30, 2020 11:10 AM
To: Debra Batten
Cc: George Metcalf; 'Roy Baldwin'; 'John Roberson'; Whitmyer, Holly; Bryan Wuester;
[e-mail]
Subject: --[EXTERNAL]--South Wake Landfill - Status Update
Hi Debbie,
It was good to tall< to you yesterday. As a follow up, I wanted to give you in writing a status update, as we look to reseed
the leachate storage tank:
1. The leachate storage tank is currently being emptied and cleaned out. Once empty, the plan is to inspect the
diffuser to ensure it's not compromised (scaling, sediment blocking, etc).
2. Once the tank is empty/cleaned and inspected, we intend to do the following (beginning next week, 11/02):
a. Discharge "3'.of leachate into the tank.
b. Add high -strength industrial sludge with robust nitrifier population from AJinomoto at the rate of
"25,000 gallons per day.
c. Once the first day of sludge is added, we will be able to turn on the blower as the diffuser will be
submerged. We will operate the tank in continual aeration mode until nitrification is established and
treatment requirements are met.
d. Sludge will continue to be added for 3-4 additional days. Depending on the system performance,
additional sludge may be added after the initial loads.
e. Daily, we will monitor the tank for the following to observe biological performance:
i. NH3
ii. NO3
iii. NO2
iv. DO
v. pH
f. We will also periodically monitor for COD and MLSS on a less frequent basis.
g. Daily, our team will review the data and agree upon a leachate feeding strategy for the next day (e.g.
how much leachate, if any, will be fed to the tank).
h. Leachate and condensate flow to the leachate storage tank will be determined based on tank
performance. The excess leachate/condensate will be collected prior to discharge to the leachate
storage tank and pump and hauled to Lumberton.
i. Once treatment requirements are met in the leachate storage tank, we will then begin operating the
tank as a sequencing batch reactor again, with an aerate cycle, a settle cycle, and discharge cycle. We
would like to coordinate with you all in advance on your preference for the duration of the discharge
cycle. At that point, we will then begin discharging to Holly Springs again. We will keep you informed
next week on the progress of reseeding, and will provide notification prior to initiating discharge to Holly
Springs again.
Dewberry will provide a staff engineer onsite to assist with sample collection and analysis, and general oversight of the
reseeding process. We would welcome you to visit the site in the near term if you would like to observe any of these
activities.
We appreciate your support with this. Please don't hesitate to reach out to me on my mobile if you have any questions.

Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for someone
else, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
This email originated from outside of the organization. Do not click links or open
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2

Debra Batten
From:
Sent:
To:
Cc:
Subject:
Hi Debbie,
Jones, Katie L. <[e-mail]>
Thursday, November 5, 2020 12:41 PM
Debra Batten
George Metcalf; 'Roy Baldwin'; 'John Roberson'; Whitmyer, Holly; Bryan Wuester;
[e-mail]
RE: --[EXTERNAL]--South Wake Landfill - Status Update
Yes sounds good. I will make sure to document our updates and also find it helpful to talk through as well.
Reseeding of the leachate storage with biology has been delayed until Monday (11/09). At that point, we hope to have
the liquid level at a point where we can operate the blower. At that point we will begin hauling Return Activated Sludge
(RAS) from Alinomoto.
I'll look forward to your call.
Take care,
Katie
•
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberrv.com
From: Debra Batten[mailto:[e-mail]]
Sent: Thursday, November 5, 2020 12:14 PM
To: Jones, Katie L. <[e-mail]>
Cc: George Metcalf<[e-mail]>;'Roy Baldwin' <[e-mail]>; 'John Roberson'
<[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<[e-mail]>; [e-mail]
Subject: RE: --[EXTERNAL]--South Wake Landfill -Status Update
[CAUTION] External Email. Do NOT click links or open attachments unless expected. Please use the
all suspicious emails.
Phish Alert" button
o report
Katie,

I am sorry I missed you call. I will try to give you a call later this afternoon. As I would prefer written notes to refer back
to, you can also email updates and I will be able to review before and after our call so I can make sure I understand
everything and don't forget anything that I should share. that is taking place. I will give you a call this afternoon.
Kindest Regards,
Debra C. Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 8 I Holly Springs, NC 27540
Office: [phone] ) Ce11: [phone] I Email: debra.battenAhollyspringsnc.us
Town Website: www.hollysps ringsnc.us
From: Jones, Katie L. <[e-mail]>
Sent: Friday, October 30, 2020 11:10 AM
To: Debra Batten <[e-mail]>
Cc: George Metcalf <[e-mail]> 'Roy Baldwin' <[e-mail]>;'John Roberson'
<[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<[e-mail]>; [e-mail]
Subject [EXTERNALJ--South Wake Landfill -Status Update
Hi Debbie,
It was good to talk to you yesterday. As a follow up, I wanted to give you in writing a status update, as we look to reseed
the leachate storage tank:
1. The leachate storage tank is currently being emptied and cleaned out. Once empty, the plan is to inspect the
diffuser to ensure it's not compromised (scaling, sediment blocking, etc).
2. Once the tank is empty/cleaned and inspected, we intend to do the following (beginning next week, 11/02):
a. Discharge ^'3' of leachate into the tank.
b. Add high -strength industrial sludge with robust nitrifier population from Ajinomoto at the rate of
"25,000 gallons per day.
c. Once the first day of sludge is added, we will be able to turn on the blower as the diffuser will be
submerged. We will operate the tank in continual aeration mode until nitrification is established and
treatment requirements are met.
d. Sludge will continue to be added for 3-4 additional days. Depending on the system performance,
additional sludge may be added after the initial loads.
e. Daily, we will monitor the tank for the following to observe biological performance:
i. NH3
ii. NO3
iii. NO2
iv. DO
v. pH
f. We will also periodically monitor for COD and MLSS on a less frequent basis.
g. Daily, our team will review the data and agree upon a leachate feeding strategy for the next day (e.g.
how much leachate, if any, will be fed to the tank).
h. Leachate and condensate flow to the leachate storage tank will be determined based on tank
performance. The excess leachate/condensate will be collected prior to discharge to the leachate
storage tank and pump and hauled to Lumberton.
2

i
i. Once treatment requirements are met in the leachate storage tank, we will then begin operating the
tank as a sequencing batch reactor again, with an aerate cycle, a settle cycle, and discharge cycle. We
would like to coordinate with you all in advance on your preference for the duration of the discharge
cycle. At that point, we will then begin discharging to Holly Springs again. We will keep you informed
next week on the progress of reseeding, and will provide notification prior to initiating discharge to Holly
Springs again.
Dewberry will provide a staff engineer onsite to assist with sample collection and analysis, and general oversight of the
reseeding process. We would welcome you to visit the site in the near term if you would like to observe any of these
activities.
We appreciate your support with this. Please don't hesitate to reach out to me on my mobile if you have any questions.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for
someone else, then please delete the email, don't share its contents with others, and don't read its attachments.
Thank you.
This email originated from outside of the organization. Do not click li
attachments unless you recognize the sende r and know the content.is safe: ;
nks or open'
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3

Debra Batten
From:
Sent:
To:
Cc:
Subject:
Attachments:
Hi Debbie,
Jones, Katie L. <[e-mail]>
Friday, November 13, 2020 9:22 AM
Debra Batten
George Metcalf; 'Roy Baldwin'; 'John Roberson'; Whitmyer, Holly; Bryan Wuester;
[e-mail]; Greune, Amber
--[EXTERNAL]--11/13/20 South Wake Landfill - Status Update
2020 11 13 South Wake Landfill Wastewater Data.pdf
Thanks for checking in. The startup began this week —two loads of sludge were placed in the tank Monday and four
loads on Tuesday (from Ajinomoto). The leachate tank is being operated in batch continuous aeration mode (e.g. there
is no influent feed or effluent discharge). The attached data shows a decrease in ammonia and COD, which is indicative
of biomass activity, and our MLSS is within our target range at 2,700 mg/I. The nitrate concentrations in the tank remain
low, but we suspect we're getting simultaneous nitrification/denitrification as we have low DO conditions in the
tank. The blower is on at max capacity, so currently we do not have a mechanism to increase the DO.
We continue to pump and haul all leachate and condensate to Lumberton and will be doing so until we reach our target
treatment objectives in the tank. The condensate remains segregated from the leachate and will do not plan to
introduce condensate into the leachate tank in the near term.
Currently we are focused on a couple of key criteria:
1. pH in the leachate tank. The leachate is highly buffered (alkaline) and has a high pH. Currently the pH is ^'8.7
s.u., which is above the typical target range for nitrification (7.5 — 8.0). Historically, the leachate tank
successfully nitrified at pH between 8-8.5. We are currently running bench tests to evaluate acid addition for pH
adjustment, and the impacts of pH on nitrification performance. if those tests indicate enhanced performance
at a lower pH, we will likely move forward with acid addition full-scale. We have a chemical vendor lined up
who can provide a turnkey addition system. Furthermore, if we are able to continue nitrifying, that may also
serve to decrease the pH, as nitrification consumes alkalinity. So we may see the pH drop due to the biological
activity as well.
2. Ammonia concentration in the leachate tank. The current ammonia concentration ("1,000 mg/I) is likely
inhibitory to nitrification rates as well. We are planning to run some dilution tests to evaluate the ammonia
toxicity which may also help inform our path forward.
Please let me know if you have additional questions.
Thank you for your support.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry

2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
From: Debra Batten[mailto:[e-mail]]
Sent: Thursday, November 12, 2020 4:10 PM
To: Jones, Katie L. <[e-mail]>
Cc: George Metcalf<[e-mail]>;'Roy Baldwin' <[e-mail]>; 'John Roberson'
<[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<[e-mail]>; [e-mail]
Subject: RE: --[EXTERNAL]--South Wake Landfill - Status Update
[CAUTION] External Email. Do NOT click links or open attachments unless expected. Please use the "Phish Alert" button to report
all suspicious emails.
If there are plans to introduce the "Gas Condensate" back into the system ( Based on the original plan sent to me on
October 30th, 2020 that was the original plan) when do you think that will happen?
Debra C. Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 8 I Holly Springs, NC 27540
Office: [phone] [ Cell: [phone] [ Email: debra.batten(2,,hollyspringsnc.us
Town Website: www.hollvsprangsnc.us
From: Debra Batten
Sent: Thursday, November 12, 2020 4:05 PM
To: Jones, Katie L. <[e-mail]>
Cc: George Metcalf <[e-mail]> 'Roy Baldwin' <[e-mail]>; 'John Roberson'
[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<[e-mail]>; travis.hrtchcock@gflenv com
Subject: RE: —[EXTERNAL]--South Wake Landfill - Status Update
Hi Katie,
I Just wanted to touch base with you as I said I would. How are things progressing with the outlined plan you had
submitted? I know when I left from vacation it had been dry which had cause a short delay Also are there any plans to
introduce the "Gas Condensate" back into the system?
2

Debra C. Batten
Enviromnental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 8 I Holly Springs, NC 27540
Office: [phone] [ Ce11: [phone] I Email: debra.battenn,hollyspringsnc.us
Town Website: www.ho1iysJran snc.us
From: Jones Katie L. <[e-mail]>
Sent: Thursday, November 05, 2020 2:35 PM
To: Debra Batten <[e-mail]>
Cc: George Metcalf <[e-mail]>; 'Roy Baldwin' <[e-mail]>; 'John Roberson'
<[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<[e-mail]>; [e-mail]
Subject: RE: --[EXTERNAL]--South Wake Landfill - Status Update
Debbie,
That's correct. We understand that we'll need to note on the DMR cover letter instances where we had no discharge to
Holly Springs and thus no analytical data.
I will provide an update early next week as we reseed.
Have a great weekend!
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberrv.com
From: Debra Batten[mailto:[e-mail]]
Sent: Thursday, November 5, 2020 1:33 PM
To: Jones Katie L. <[e-mail]>
Cc: George Metcalf <[e-mail]> 'Roy Baldwin' <[e-mail]>; 'John Roberson'
<[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<bryan [e-mail]>; [e-mail]
Subject: RE: --[EXTERNAL]—South Wake Landfill -Status Update
[CAUTION] External Email. Do NOT click links or open attachments unless expected. Please use the "Phish Alert" button to report
all suspicious emails.
3

So with that being said there is still no flow at all corning from SWL7
From: Jones, Katie L. <[e-mail]>
Sent: Thursday, November 05, 2020 12:41 PM
To: Debra Batten <[e-mail]>
Cc: George Metcalf <[e-mail]>; 'Roy Baldwin' <[e-mail]>; 'John Roberson'
<[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<[e-mail]>; [e-mail]
Subject: RE: —[EXTERNAL]--South Wake Landfill - Status Update
Hi Debbie,
Yes sounds good. I will make sure to document our updates and also find it helpful to talk through as well.
Reseeding of the leachate storage with biology has been delayed until Monday (11/09). At that point, we hope to have
the liquid level at a point where we can operate the blower. At that point we will begin hauling Return Activated Sludge
(RAS) from Ajinomoto.
I'll look forward to your call.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
From: Debra Batten[mailto:[e-mail]]
Sent: Thursday, November 5, 202012:14 PM
To: Jones Katie L. <[e-mail]>
Cc: George Metcalf <[e-mail]>; 'Roy Baldwin' <[e-mail]>; 'John Roberson'
<[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<[e-mail]>; traws.hitchcock@gflenv com
Subject: RE: --[EXTERNAL]--South Wake Landfill -Status Update
[CAUTION] External Email. Do NOT click links or open attachments unless expected. Please use
all suspicious emails. '
Phish Alert" button to rpp.
•
Katie,
4

I am sorry I missed you call. I will try to give you a call later this afternoon. As I would prefer written notes to refer
back to, you can also email updates and I will be able to review before and after our call so I can make sure I understand
everything and don't forget anything that I should share. that is taking place. I will give you a call this afternoon.
Kindest Regards,
Debra C. Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs
PO Box 8 I Holly Springs, NC 27540
Office: [phone] [ Ce11: [phone] I Email: debra.battena,hollyspringsnc.us
Town Website: www.hollyspringsnc.us
From: Jones, Katie L. <kllones@Dewberry com>
Sent: Friday, October 30, 2020 11:10 AM
To: Debra Batten <[e-mail]>
Cc: George Metcalf <[e-mail]>; 'Roy Baldwin' <[e-mail]>; 'John Roberson'
<[e-mail]>; Whitmyer, Holly <[e-mail]>; Bryan Wuester
<[e-mail]>; [e-mail]
Subject: --[EXTERNAL]--South Wake Landfill - Status Update
Hi Debbie,
It was good to talk to you yesterday. As a follow up, I wanted to give you in writing a status update, as we look to reseed
the leachate storage tank:
1. The leachate storage tank is currently being emptied and cleaned out. Once empty, the plan is to inspect the
diffuser to ensure it's not compromised (scaling, sediment blocking, etc).
2. Once the tank is empty/cleaned and inspected, we intend to do the following (beginning next week, 11/02):
a. Discharge "3' of leachate into the tank.
b. Add high -strength industrial sludge with robust nitrifier population from AJinomoto at the rate of
"25,000 gallons per day.
c. Once the first day of sludge is added, we will be able to turn on the blower as the diffuser will be
submerged. We will operate the tank in continual aeration mode until nitrification is established and
treatment requirements are met.
d. Sludge will continue to be added for 3-4 additional days. Depending on the system performance,
additional sludge may be added after the initial loads.
e. Daily, we will monitor the tank for the following to observe biological performance:
i. NH3
ii. NO3
iii. NO2
iv. DO
v. pH
f. We will also periodically monitor for COD and MLSS on a less frequent basis.
g. Daily, our team will review the data and agree upon a leachate feeding strategy for the next day (e.g.
how much leachate, if any, will be fed to the tank).
h. Leachate and condensate flow to the leachate storage tank will be determined based on tank
performance. The excess leachate/condensate will be collected prior to discharge to the leachate
storage tank and pump and hauled to Lumberton.
s

i. Once treatment requirements are met in the leachate storage tank, we will then begin operating the
tank as a sequencing batch reactor again, with an aerate cycle, a settle cycle, and discharge cycle. We
would like to coordinate with you all in advance on your preference for the duration of the discharge
cycle. At that point, we will then begin discharging to Holly Springs again. We will keep you informed
next week on the progress of reseeding, and will provide notification prior to initiating discharge to Holly
Springs again.
Dewberry will provide a staff engineer onsite to assist with sample collection and analysis, and general oversight of the
reseeding process. We would welcome you to visit the site in the near term if you would like to observe any of these
activities.
We appreciate your support with this. Please don't hesitate to reach out to me on my mobile if you have any questions.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2510 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for
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Thank you.
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i
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6

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7

South Wake Lan
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Debra Batten
From: Jones, Katie L. <[e-mail]>
Sent: Monday, November 30, 2020 5:17 PM
To: Debra Batten
Cc: Travis Hitchcock; George Metcalf; Whitmyer, Holly; Greune, Amber; 'John Roberson';
'Roy Baldwin'
Subject: --[EXTERNAL]--South Wake Leachate Treatment System Update (11/30/2020)
Attachments: 11.30.2020 South Wake Landfill Reseeding Results.pdf
Hi Debbie,
It was good to speak with you this morning. As we discussed, we are now seeing positive signs of treatment within the
leachate storage tank. Per the attached data summary, over the last several days, ammonia has trended down
significantly and nitrate has trended up. Both of these are very positive signs that nitrification is occurring. We suspect
that we have decreased the ammonia below the concentration where it is causing significant inhibition to the
biomass. Given the positive indicators, the tank was fed 10,000 gallons today as a mechanism to increase the liquid level
and subsequently oxygen transfer rates. We will keep a close eye on the tank concentrations as we begin to feed, and
will halt or slow down the feeding if we deem necessary based on the data.
Our path forward is as follows:
1. Continue to monitor the tank closely
2. Feed the tank daily to increase liquid level to allow for more oxygen transfer into solution (which will help our
nitrification rates)
3. Continue sending condensate directly to Lumberton
We understand that you require notification once we are ready to begin discharging leachate to Holly Springs again, and
that the notification will need to include the following daily estimates:
1. Amount of leachate to be discharged
2. Duration of time over which the leachate will be discharged
We appreciate your support of our activities. Please let me know if you have any questions.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
1

Visit Dewberry's website at www.dewberry com If you've received this email even though it's intended for someone
else, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
I
This email originated from outside of the organization. Do not click links or open
attachments unless you recognize the sender and know the content issafe
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November 30, 2020
d
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Debra Batten
From:
Sent:
To:
Cc:
Subject:
Attachments:
Hi Debbie,
Jones, Katie L. <[e-mail]>
Tuesday, December 8, 2020 3:35 PM
Debra Batten
George Metcalf; Travis Hitchcock; Greune, Amber; Whitmyer, Holly
--[EXTERNAL]--South Wake Landfill Update and Request to Discharge
12.07.2020 South Wake Reseeding Results.pdf
Thank you for your time this afternoon. I've attached the updated reseeding results. We have begun feeding the
leachate storage tank to increase the liquid level, and have seen the ammonia remain relatively low and stable — a really
positive sign. We would like to begin discharging from the leachate storage tank to Holly Springs this week, and are
seeking guidance from you on the following:
1. Maximum amount of leachate to be discharged in one day through next Monday December 15, 2020
2. Duration of daily discharge (hours)
As I indicated, GFL has rented a 21,000 gallon temporary frac tank that can be used onsite as either a clarification tank (it
has multiple discharge ports at variable liquid levels), or as a holding tank to assist with bleeding the leachate into the
sewer.
As we discussed, we continue to capture the condensate separate from the leachate and ahead of the leachate tank, so
there is no condensate in the leachate storage tank. The condensate is all being hauled to Lumberton for
treatment. Wake County will respond to Holly Springs' ATC letter under a separate email.
Please let us know your thoughts.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for someone
else, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
1

This email originated from outside of the organization: Do not click links or open
attachments unless, you recognize the sender and know the content is safe;
2

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December 7, 2020

Debra Batten
From:
Sent:
To:
Cc:
Subject:
Attachments:
Hi Debbie,
Jones, Katie L. <[e-mail]>
Thursday, December 17, 2020 7:12 AM
Debra Batten
George Metcalf; Travis Hitchcock; Whitmyer, Holly; John Roberson
--[EXTERNAL]--South Wake Leachate Update and Request to Increase Discharge Rate
12.16.2020 South Wake Reseeding Results pdf
I hope this note finds you well. Please find attached the weekly summary of the leachate tank data. We continue to
achieve nitrification in the tank, as yesterday's ammonia reading was 317 mg/I. We brought in several loads of
AJinomoto sludge on Friday, and we expect to being seeing positive results of that sometime in the next 1-2 weeks. We
anticipate that will help us decrease the ammonia concentration even further. We are also exploring supplemental
oxygen addition options, and have a vendor onsite today to tall< to the team about super DO saturation of an influent
side stream.
We would like to 'request that our discharge rate to the TORS be increased to 7,500 gallons per day for the next 7 days.
Please let me know if you have any questions.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
91023.7946 mobile
dewberry.com
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for someone
else, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
This email originated from outside of the organization: Do not click links or open
attachments unless you recognize the sender and lcnowthe content'is safe:..:,'

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Debra Batten
From:
Sent:
To:
Cc:
Subject:
Attachments:
Hi Debbie,
Jones, Katie L. <[e-mail]>
Sunday, December 27, 2020 10:30 AM
Debra Batten
Whitmyer, Holly; Travis Hitchcock; George Metcalf
--[EXTERNAL]--South Wake Update
12.24.2020 South Wake Reseeding Results.pdf
I hope you are having a nice Holiday season! Please find our latest data attached. The site has been closed since
Christmas so we don't have data for the last couple of days. During days of operation, we have continued to feed
10,000 gpd to the tank, and discharge 7,500 gpd to TORS.
Our ammonia concentrations have hovered around 400 mg/I for the last week or so, which would not allow us to
discharge 10,000 gpd to the TORS. However, it would allow us to discharge more than the current allowable flow of
7,500 gpd. Therefore we would like to request an increase in discharge allowance to a max of 10,000 gpd. We will
continue to monitor ammonia on the days of discharge, and will use that data to calculate the actual amount of flow we
can send and still remain in compliance with our limit, allowing for some safety factor. We remain hopeful we can
decrease the ammonia concentrations, allowing us to discharge more flow.
To that end, we received a quote for a supplemental oxygen addition system last week, and have a call with the vendor
scheduled for Monday to review in detail. This is the technology we are looking at -
https://www.blueinereen.com/oxygenation.
As always, please feel free to reach out to me with questions.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for someone
else, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
1

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Debra Batten
From:
Sent:
To:
Cc:
Subject:
Attachments:
Hi Debbie,
Jones, Katie L. <[e-mail]>
Tuesday, January 12, 2021 9:41 AM
Debra Batten
Travis Hitchcock; George Metcalf; Whitmyer, Holly
--[EXTERNAL]--South Wake Landfill Update
01.11.2021 South Wake Reseeding Results.pdf
I hope this note finds you doing well in the New Year. Please find attached our data update. We are still averaging
mostly between 300 and 400 mg/I ammonia. Our mixed liquor concentration had gradually decreased; to address, we
brought in several loads of Ajinomoto sludge last week and are adding several more loads this week. We are also
evaluating the TSS in our discharge to the TOHS, to see if we need to adjust our settling time to minimize solids
carryover to the Town.
We continue to evaluate feasibility of supplemental oxygen addition.
Please let me know if you have questions.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader
Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for someone
else, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
Tills email originated from outside of the organization Do not click links
attachments unless you recognize the sender and know tile content is safe,,,,

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Debra Batten
From: Jones, Katie L. <[e-mail]>
Sent: Thursday, February 4, 2021 3:59 PM
To: Debra Batten
Cc' Whitmyer, Holly; Travis Hitchcock; George Metcalf
Subject: --[EXTERNAL]--South Wake Update
Attachments: 02.04.2021 South Wake Reseeding Results.pdf
Hi Debbie,
Thank you for your time earlier this week. The following provides a summary of our conversation.
Leachate Treatment System Testing/Restart Update
We have concluded the first phase of system testing (see attached data summary). In this phase, we accomplished the
following key objectives:
1. Identify a robust nitrifying industrial seed sludge to be used for system startup and/or to supplement when
additional biomass is needed.
Results: Utilized sludge from a high -strength nitrifying industrial WWTP, Ajinomoto, which was successful in both
initially seeding the leachate tank as well as when additional biomass was needed to supplement.
2. Achieve sustained nitrification.
Results: System consistently nitrified for approximately 9-10 weeks, achieving >75% ammonia removal in spite of
an average dissolved oxygen concentration lower than 0.5 mg/I
3. Establish treatment capacity of existing system.
Results: Over the last three months, the performance results indicate that that the existing infrastructure is
capable of treating 7,500—10,000 gallons per day (gpd). The primary existing system limitation is the aeration
system.
We are currently generating 20,000 — 25,000 gpd of leachate/condensate, which is in excess of treatment capacity of the
existing system. In addition, operationally it is difficult to manage the excess leachate/condensate that has not been
discharged into the leachate tank during the last 3 months when we've limited flow into the tank to protect/manage the
biological system. As such, we are in the process of evaluating treatment system improvements and have decided to
temporarily shut down the biological reactor to be able to use as storage again. Once the system upgrades are
designed, equipment is received, and construction is imminent, we will drain the tank again, install the upgrades, and re-
seed the tank. We will work with the Town to ensure we satisfy all permitting requirements (ATC) to support this
activity.
We intend to continue discharging to the Town a volumetric amount that is based on our ammonia concentrations and
our ammonia mass limit.
As always, please let me know if you have any questions. We appreciate the Town's support.
Take care,
Katie
Katie L. Jones, PE
Associate Vice President
Industrial Practice Leader

Dewberry
2610 Wycliff Road, Suite 410
Raleigh, NC 27607-3073
919.424.3723
919.723.7946 mobile
dewberry.com
i
Visit Dewberry's website at www.dewberrycom If you've received this email even though it's intended for someone
else, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
Visit Dewberry's website at www.dewberry.com If you've received this email even though it's intended for someone
eke, then please delete the email, don't share its contents with others, and don't read its attachments. Thank you.
This .ernall originatedfrom outsideof the organization. 'Do not click links or open
attachments unllessyou recognize the sender and know the content is safe.

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Attachment 7
SCS E- NGINEE.RS
November 6, 2020
File No, 02199312.03-15A
Environmental Consulting & Contracting
Sean Byrd
Water Quality Department Director - Public Utilities Department
Town of Holly Springs
150 Treatment Plant Road
Holly Springs, NC 27540
Subject: South Wake Landfill Industrial User Permit 001(IUP 001)
Dear Mr. Byrd:
SCS Engineers, PC, on behalf of Wake County, is submitting this letter, with the attached drawing, as
required by Part II, Specific Conditions; Section 25 - Reports of Changed Conditions, for your
consideration and approval.
Wake County plans to expand the existing active landfill gas (LFG) collection and control system at
their South Wake Landfill (SWLF), to achieve multiple objectives. This expansion project will extend
the 8" header piping into the interior of Phase 2A of the Landfill, and add lateral piping for new gas
wells. As part of this project, approximately twenty-five (25) new vertical LFG extraction wells and five
horizontal collectors will be installed and be connected to the gas collection system. Additional
condensate that is generated, which is anticipated to be approximately 270 gallons per day
(maximum value during winter months when ambient temperatures are low), from this expansion
project will drain into the existing condensate system that was installed during the initial LFG system
expansion project. Attached is a draft plan sheet that reflects the proposed project described above.
Wake County anticipates beginning construction in November 2020. The actual construction project
will be executed in two phases, likely over a timespan of 2-3 months.
Sincerely,
Robert E. Dick, PE
Project Director
SCS Engineers
RED/QFA
cc: Lee Squires, Wake County
Tom Covington, Wake County
George Metcalf, GFL
Enclosures
Quinn Albertson, EIT
Staff Professional
SCS Engineers
15521 Midlothian Turnpike, Suite 305, Midlothian, VA 23113 1804-378-7440
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The Town of
HOLLY
SPRINGS Department of Water Quality
November 17, 2020
Mr. John Roberson, PE
Project Manager
Facilities Design & Construction
P.O. Box 550
Raleigh, NC 27602
RE• Authorization to Construct
Dear Mr. Roberson,
The Town of Holly Springs received a letter from Robert E. Dick PE, Project Director, SCS Engineers,
and Quinn Albertson, EIT with the requested "Report of Changed Conditions" for consideration and
approval. The plans are to expand the existing active landfill gas (LFG) collection and control system.
It is my understanding that objectives to be achieved are as follows:
• Extend the 8" header piping into the interior of Phase 2A of the Landfill
• To add lateral piping for the new gas wells.
• Install (25) new vertical LFG gas extraction wells
• Five horizontal collectors will be installed and connected to system
• Four(4) existing leachate cleanouts wells will be connected to the system as well
• There is an anticipated additional 270 gallons/day, maximum (during winter months when
ambient temperatures are low) which will drain into the existing LFG installed during the initial
LFG system expansion project.
• ` Authorization to Construct" with the Report of Changed Conditions as provided are Dented at
this time. Evidence shows SWL has difficulty treating discharge at permit limits. Example:
The total volume discharged, of the combined waste streams, for September 2020 was
520,424 gallons. Only 13.47 % (70,124 gallons) was discharged to TOIIS Exceeding this
volume of discharge, at current ammonia levels, would have resulted in Non Compliance
of Permit Limits for ammonia. The other 86.53% (450,300 gallons) were pumped and
hauled. (Continuing to do so could result in a permit modification reducing the volume of
permitted flow)
P.O. Box 8 • 150 Treatment Plant Rd 0 Holly Springs, NC 27540 • Tel. [phone] Fax. [phone]
debra.batten(a hollyspringsnc.us • www.hollyspringsnc.us

In addition, please see the attached review, and continued occurrences of "Non Compliance" in regards
to "Permit Conditions" and "Sampling/Monitoring Violations" prior to, and after the last approved
expansion of July 2018.
I am currently waiting for another status update from Katie Jones of Dewberry Engineering, to include
plans for improvements to the Leachate Collection System as discussed with Town of Holly Springs in
October. TOHS has requested a hard copy of plans of implementing an adequate treatment method which
will assure SWL's ability to meet the conditions and limits of the permit These plans are to include
milestone dates for completion of each step of the process including an estimated final date of
completion. The plans are to be submitted to my office by a scheduled date of January 15, 2020.
After the Leachate Collection System project has been completed, and evidence confirms the of the
ability to operate and maintain conditions of the penult as well the ability to meet limits with the
combined waste streams of both the Leachate and Gas Condensate, for 3 consecutive months, the
"request for the expansion" can be resubmitted. For any further information or clarification please
contact me at 919-557-2907.
Res c, fully,
2 e✓
br _ . Batten
Environmental Compliance Manager
Enclosure Historical review for the years 2018, 2019, 2020
Cc: Roy Baldwin, Wake County
George Metcalf, GFL Environmental General Manager
Seth Gundersen, GFL Environmental Operations Supervisor I
Lee Squires, Wake County
Tom Covington, Wake County
Seann Byrd, Interim Water Resources Director
P.O. Box 8 • 150 Treatment Plant Rd • Holly Springs, NC 27540 • Tel. [phone] • Fax. [phone]
debra.battenCa?hollyspringsnc.us • www.hollyspringsnc.us

2018
2019
South Wake Landfill
Historical review 2018 2020
• In 2018, there were no resulting violations but there were a couple times where high ammonia
values were experienced. The Town of Holly Springs provided microorganisms from Utley
Creek Water Reclamation Facility to re -seed their Leachate Collection System which resulted in
the return of nitrification
• The request of Authorization to construct was submitted to the existing landfill gas collection
and control system. on July 5'h, 2018 and was granted for the expansion on July 20, 2018 This
project was projected to last for 75 days from beginning to end. Holly Springs was not told of the
completion as not told of its completion. The final inspection by the contractors was September
30, 2018. Shortly afterward there was a problem with the gas collection and control system and
it was down for repairs. Discharge did not resume until December 20, 2018.
• In September, prior to Hurricane Florence, needing to make room for the suspected heavy
rainfall, SWLF, without notification to the POTW, emptied the Leachate Collection System.
While the average monthly flow is typically <7,000 gal/day, the average flow from September
9th- September 12'h, 2018 was 43,044 gal/day Though they did not exceed their flow limit of
50,000 gal /day, this is a significant increase in flow. The nitrifying bacteria at SWLF were of
good population at the time and there was minimal detriment to the POTW. It was also during
this time that I was notified that there had been a change in `Waste Industries" staff. (Waste
Industries is now known as Green for life ,GFL)
• A significant increase in discharged flow in September 2018 resulted in the wasting of all of the
nitrifying bacteria, resulting in the increase ammonia concentrations of>1400 mg/L However,
SWL staff monitored ammonia levels with field equipment to make sure the volume of discharge
released each day, would assure permit limits would not be exceeded nor cause problem for the
Town of Holly Springs POTW. Their Leachate Collection System was pumped and hauled until
empty. More seeded biosolids was requested from UCWRF after which the nitrification again
returned.
• 1'he annual onsite inspection was conducted on November 1, 2018. Though the nitrification
process was beginning to return, the volume discharged was limited to assure no permit
violations would occur.
• Upon receipt of the renewed permit issued December 28, 2018 South Wake Landfill requested a
meeting to discuss question the permit as written Changes were also requested some of permit
limits. This meeting was January 15, 2019 and the request were made as follows:
➢ A requested increase the total nitrogen average mass limit from 227 lb. /day to 325
lb. /day There was also request reduced monitoring which was denied. Total
Nitrogen and Ammonia sampling and monitoring was increased to weekly until
consistent removal is achieved.
• SWLF began the pump and haul in January 2019. The Town of Holly Springs provided SWL
microorganisms from Utley Creek Water Reclamation Facility to re -seed their Leachate Collection
System, which resulted in nitrification returning as a treatment method but they were not successful in
maintaining the nitrification process needed for removal of Ammonia Nitrogen.
P.O. Box 8 e 150 Treatment Plant Rd • Holly Springs, NC 27540 • Tel. [phone] • Fax. [phone]
debra.batten a hollvspringsnc.us • www.hollyspringsnc.us

• SWL reduced their discharged flow, significantly, to prevent violating the permitted Ammonia limit.
Private contractor started removing wastewater from their Leachate Collection System (Pump and Haul
records were requested and provided. during the annual inspection. This process continues. No limits
violations issued for the year 2019.
o As a requirement of the ERP there was a Notice of Non Compliance issued to SWL on June 5,
2019 for failure to monitor Total Phosphorus and Ammonia.
• The annual inspection confirmed that the pretreatment system still was not functioning properly and
the limited discharge continued to be limited as they were trying to assure no permit violations would
occur. There has also been another change in GFL staff.
2020
• Conditions of the permit were not met as there was a change of contact for Operations with GFL There
was also a failure to submit the "Signatory Requirement" for signatures when submitting the Monthly
DMR. Town of Holly Springs made the request during the annual Inspection on September 2, 2020 and
the letter was received returning them to compliance.
• The sampling of the weekly composites often fell short of the 1 hour required discharge as written in the
peituit This is a violation of the conditions of the permit. It was noted however, the reason for the
reduced discharge time was to prevent SWL from exceeding the limits for ammonia by increasing
volume of discharged flow.
• Also the permit requires the use of a continuous flow meter. Though SWL has a continuous flow meter
the flow meter used to determine volume discharged for each event was recorded from the flow meter
after resetting to "0" at the beginning of sampling event and does not meet the permit requirement.
• It was determined that SWL is currently discharging only 13 % of their permitted flow. Continuing to
do so could result in a permit modification reducing the volume of permitted flow allowing other
industrial growth in the Town of Holly Springs.
P.O. Box 8 • 150 Treatment Plant Rd • Holly Springs, NC 27540 • Tel. [phone] Fax. [phone]
debra.batten a(�hollvspringsnc.us • www.hollyspringsnc.us

Attachment 8
Debra Batten
From:
Sent:
To:
Subject:
Attachments:
Importance:
Good afternoon all,
Debra Batten
Thursday, April 23, 2020 2:44 PM
[e-mail]; Troy Mitchell; Wise, Allan US/HSP; Baker, Rachel US/HSP
TONS Policy for Splitting Samples
TOHS Split Samples Policy 05012020.doc
High
I hope this email still finds all doing well.
As I am quickly approaching the time frame for performing Semi Annual Monitoring for The TOHS permit requirements I
wanted to send you the new policy for the Town of Holly Springs on splitting samples. As in previous discussions, I have
shared correspondence from NC DWQ Pretreatment Section and there recommendations on the topic. The response
was "POTWs are not required to split samples with the lUs." They go on to say "It is not recommended that POTWs
use split samples with the industry to satisfy its annual or semi-annual sampling requirements. the POTW should pull
its own samples so that it has data which are truly independent of the IU's results." For this reason it was the practice
of the Pretreatment program that I came from not to allow the splitting of sampling being performed for the monitoring
requirement of the PTOW. As this practice was allowed prior to my position with Town of Holly Springs I will continue to
allow the split sampling as long as the TONS Policy attached is followed.
Respectfully,
Debra C. Batten
Environmental Compliance Laboratory Manager/Pretreatment Coordinator
Utley Creek Water Reclamation/Town of holly Springs
PO Box 81 Holly Springs, NC 27540
Office: [phone] ) Cell: [phone] ( Email: debra.batten anhollysprinpsnc.us
Town Website: www.hollyspringsnc.us
Sent from Mail for Windows 10

Industrial User Requirements for Splitting a
Sample
Though NC Department of Water Resources does not recommend the practice, splitting
samples is permitted under the following conditions:
• Results of multiple samples meeting requirements are acceptable and an average
with the POTW results of the same sample to evaluate the industrial User's
wastewater:
Contributor must follow and document 40CFR136 and North Carolina procedures for
collecting, handling and analyzing the split sample. The burden of proof is on the
Industrial User.
Industrial User must provide acceptable bottles with the required preservation at time of
sampling
A POTW representative and a Industrial User representative must be present at the split.
The sample must be mixed well, as always, before pouring any amount into any of the
sample bottles. After the POTW has gotten the sample it needs for its purposes, the
Industrial User may use the remaining sample for a split.
The Town of Holly Springs will also send a split sample to a third lab for analysis. The
Industrial User will be responsible for the expenses of these extra analyses.
The Industrial User may not use the split to fulfill its self -monitoring requirements. See
explanation below:
This is to clarify the use of split samples that are given by the Town
of Holly Springs during wastewater sampling events Title 40 Code of
Federal Regulations 403.8(f)(1)(v) states that the City shall carry out
all inspections, surveillance and monitoring procedures necessary to
determine, independent of information supplied by Industrial Users,
compliance or noncompliance with applicable Pretreatment Standards and
Requirements by Industrial Users.
Therefore, industries who obtain split samples from the Town may not
use those results to fulfill the self -monitoring requirements as set
forth in the industrial user permits. Those results will, however, be
reported to the Town and the Town will record all results individually
and as an average. The average of all data meeting the requirements of
each analysis will be used for compliance judgement.

Town of Holly Springs Procedure for Splitting Samples
Because all acceptable results from the split must be used to get an average result, it is
important that the POTW and the Contributor are following all of the required procedures
in collecting, handling and analyzing a split sample. The Industrial User's
responsibilities are in "Industrial User Requirements for Splitting a Sample."
1. Make sure that the Industrial User is meeting the requirements in "Industrial User
Requirements for Splitting a Sample" before allowing the split and/or accepting results of
a split from the Industrial User.
2 Enough sample should be collected for a three-way split: POTW-regular lab, POTW-
third party lab, Industrial User.
3. A POTW Representative and an Industrial User representative must be present at the
split. The sample must be mixed well, as always, before pouring any amount into any of
the sample bottles After the POTW has gotten the sample it needs for its purposes
(including the third party lab), the Industrial User may have the remaining sample for a
split.
4. On the chain of custody, it must be noted that a split was done and signatures received
from both individuals receiving the split samples these individuals should also have
chains of custody and/or copies thereof.
5. REMEMBER: Industrial User may not use a split sample result for self -monitoring
requirements! The Industrial User must sample separately.

Town of Holly Springs
Water Resources
Environmental Compliance
SIU Inspection Form
Name of Industry: Seqirus
Attachment 9
IUP # 002
Address of Industry: 475 Green Oaks Parkway
IUP Expiration date: 12/31/2022
Industry Representatives:
Robert Rezek
POTW Representatives: Debra Batten
Brendan Reeser
Nilsa Serrano -Ortiz, Title: EHS Specialist
Title: EHS Director
Title: Environment Compliance
Title: Reclaim & Fog Manager
Date Of Inspection: 10/01/2020 Time Of Inspection:10:00 am/pm
Purpose of Inspection: Annual X Other (Describe)
POTW to which IU discharges Town of Holly Springs NPDES # 0063096
Is SIU currently in SNC? No If yes for what?
* Inspection ended at 12:20 pm on 10/02/2020.
s PART I - INITIAL INTERVIEW
Has anything changed since the last inspection or IUP application in the following:
COMMENTS
Product: YES / NO Flu vaccine (Cell Bases)
Raw materials used YES / NO Phosphate buffer/ Saline, Nitrogen based growth
media, Citric Acid NaOH, Proteins
Manufacturing processes Categorical, if applicable: YES / NO
Production Rate/ Flow Increase: Yes / No There was an increase in production and
also a projected increase for the upcoming year. However, after a cost recovery
study was performed there was an actual decrease of flow.
Number of employees: YES / NO There are currently 729 employees. (Also additional
contractors but less than 10% increase.
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020
Page 1

Town of Holly Springs
Water Resources
Environmental Compliance
Number of Shits: There has been no change in shifts. Currently there are 2-(12 hour) shifts
for production and laboratory staff and a 3 rd. line on standby. Pilot Plant and administrative
is first shift only.
PART II - PLANT TOUR -
Plant Tour Section A - PRODUCTION AND STORAGE AREAS
1. Are there floor drains in the production area? YES / NO Where do they go? All production
waste (Infectious) go through Thermal Deactivation. (Non- Infectious and Formulated Fill/Finish
waste streams) pass through the Equalization tank and the pH adjustment tank prior to effluent
discharge.
2. Are production areas diked, contained, or otherwise constructed in such a way as to prevent harm
to the WWTP, especially from spills or slugs? YES / NO Comments: All drains in the production area
are closed and or protected from spills with either containment or berms. In the event of a spill,__
employees know to call security whom activates the spill plan.
3. Are there floor drains in the storage area? YES / NO Where do they go? All area with wet
chemicals are contained with dikes, and berms. Chemical storage area also had 'wash pits" available
for rinsing spills and containment until waste the waste recovery (Triumvirate Environmental) has
been contacted.
4. Are storage tanks and areas diked, contained, or otherwise constructed in such a way as to prevent
harm to the WWTP, especially from spills or slugs? YES / NO Comments:
5. Are process and storage tanks and pipes labeled? YES / NO
6. How are off -spec raw materials, and products disposed of? Disposed of by Triumvirate
Environmental. (Minimum of every 2 week scheduled pick up) Manifest were available for review.
7. When is the production area cleaned? Daily by staff and floors cleaned by contractors weekly. A
request was made for a copy of the schedule of "Contractor s" cleaning schedule and was received for
placement in the Industrial file along with Floor cleaning Procedures and SDS for cleaning solutions
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020
Page 2

Town of Holly Springs
Water Resources
Environmental Compliance
9. What non -process wastewaters are discharged to POTW? Boiler Blowdown, Lab sinks, Water
treatment Chemicals, Cooling Tower blowdown Cafeteria (after passing through grease interceptor).
The "Pilot Plant" waste after passing through pH adjustment tank, also is discharged to the POTW.
Mrs. Serrano offered to send to me 40 CFR 439 in regards to discharge from Research and
Development discharge"(for Pilot Plant discharge. To determine if and which monitoring
requirements there are of for discharge from Pilot Plans as research and development I have this
available and will be reviewing permit requirements.
PART II - Plant Tour Section B - PRETREATMENT SYSTEM
Ask the operator to describe pretreatment system.
1. Does operator seem knowledgeable about the system? YES / NO
Comments: A full explanation of system was given.
2. Are all units operational? YES / NO
3. How often does operator/maintenance person check system? Visual Inspections are completed
daily. Equipment Maintenance and Calibration Records were made available for review.
4. Is there an operator for each shift? YES / NO
5. How and when is sludge disposed of? Not Applicable
6. Is there a schedule for preventative. maintenance? YES / NO
Comments: Equipment Maintenance and Calibration Records were made available for review.
PART II - Plant Tour Section C - SAMPLING POINT(S) AND FLOW MEASUREMENT
1. Does an outside lab complete sampling? YES / NO If yes, name of Lab: Pace Analytical, contract
lab has completed sampling in the presence of TOHS sampling staff 2 times in the past 12 months.
Sampling Procedures are satisfactory.
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020
Page 3

Town of Holly Springs
Water Resources
Environmental Compliance
2. If industry completes sampling, ask the industry representative to describe sampling procedures.
Comments: Not applicable
3. Is flow measurement equipment operational? YES / NO Comments:
4. Is there a calibration log for the flow meter? YES / NO Comments: Last Calibration was
December 2019. Calibrations are performed in house on an annual basis. Calibration Records were
available for review Totalizer is reset to "zero" annually. Current reading was 225663378 which
correlates with last reading provided on sampling earlier this month.
PART III - EXIT INTERVIEW
Review monitoring records and other SIU records required by IUP.
1. Are files well organized? YES / NO Comments:
2. Are sample collection / chain -of -custody forms filled out properly? YES / NO
3. Do results in files agree with reports sent to POTW? YES / NO Comments:
4. Who has authority to shut down production should a spill or slug discharge occur? Operator in area
at the time and location of spill, is to close off discharge flow and contact Security. Security follows
"Spill Plan" Procedure.
5. How does SIU inform employees of whom to call at POTW in case of spill/slug? Signage is posted
throughout the plant. Training is completed as part of the "New Hire training" and again annually
during annual waste training..
(If slug/spill plan is already required by POTW review procedures). There is a current Slug Spill plan
but it is currently be update. Draft was available for review.
6. Is SIU implementing slug/spill plan? YES / NO
Comments: In process of updating current plan. Draft was available for review.
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020
Page 4

Town of Holly Springs
Water Resources
Environmental Compliance
INSPECTION RESULTS
Slug/Spill Control Plan Needed? YES / NO
Comments, Required or Recommended Actions:
Exiting Summary: The facility was in production, and also in the midst of conducting a flu vaccine
clinic for their staff and family. The inspection was a thorough. All drains were either closed or
protected from harm with dikes and berms. In the "wet Chemical storage areas, in addition to the
berms, there are also holding pits for waste from spills to be rinsed into and held until removal by
contractors. All records available and were made available and in order. Other information
requested and to be received for review are the List of Chemicals and SDS used in the floor
disinfection, the Volumes of Steri-Peroxide Spray(contains 70% IPA) used Also a copy of Appendix
"A" in the cleaning contractor's agreement that reference the cleaning schedule. And finally the EPA
CFR 40 Part 439 will be reviewed for permitting and monitoring requirements for Research and
Development discharge under the Pharmaceutical Guidelines.
Equipment Maintenance and Calibration Records were made available for review.
Inspector(s) Debra Batten (signature)
Brendan Reeser (signature)
Industrial Contact Nilsa Serrano (Signature)
Date:g ij
Date:
Date: i3-CC1 2020
Title: SIU Inspection Form
File name: COMP.INSP
Revision date: October 2, 2020
Page 5

The Town of
HOLLY
SPRINGS
November 4, 2020
CERTIFIED MAIL 7019 2280 0002 1897 0312
RETURN RECEIPT REQUESTED
Dr. Diana Caroline Molta-Moore
Spring Village Dentistry
349 Ernie Ln.
Holly Springs, NC 27540
Attachment 10
Water Resources
Subject: Notice of Violation
Dental Amalgam Rule EPA
40 CFR Part 441- Dental Category Compliance
Dear: Dr. Molta-Moore
This letter serves as a Notice of Violation for failure to complete the EPA required one time
report. The report (Attached) was due October 12'1', 2020. There were multiple attempts by
TOHS via email and Certified Letters and no response was received.
It is the customer's responsibility to follow the Sewer Use Ordinance. As the "Regulatory
Authority" it is the duty of the Town of Holly Springs Pretreatment Coordinator to make the
requirements known to the customers and to follow the Sewer Use Ordnance and Enforcement
Response Plan as approved by NC DENR/DWR.
Upon receipt of this violation, please complete the attached one time report and submit to my
office no later than November 20, 2020. IF the report is not received by this date a Second
Notice if Violation will be issued and more stringent enforcement action can be taken.
If you have any questions please contact me at [phone].
Sincerely,
Debra C. Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs

The Tosvn of
HOLLY
SPRINGS
November 4, 2020
CERTIFIED MAIL 7019 2280 0002 1897 0305
RETURN RECEIPT REQUESTED
Dr. Joyce P. Guanga
Guanga Family Dentistry
640 Holly Springs Rd
Holly Springs, NC 27540
Water Resources
Subject: Notice of Violation
Dental Amalgam Rule EPA
40 CFR Part 441- Dental Category Compliance
Dear: Dr. Guanga,
This letter serves as a Notice of Violation for failure to complete the EPA required one time
report. The report (Attached) was due October 12'1', 2020. There were multiple attempts by
TORS via email and Certified Letters and no response was received.
It is the customer's responsibility to follow the Sewer Use Ordinance. As the "Regulatory
Authority" it is the duty of the Town of Holly Springs Pretreatment Coordinator to make the
requirements known to the customers and to follow the Sewer Use Ordnance and Enforcement
Response Plan as approved by NC DENR/DWR.
Upon receipt of this violation, please complete the attached one time report and submit to my
office no later than November 20, 2020. IF the report is not received by this date a Second
Notice if Violation will be issued and more stringent enforcement action can be taken.
If you have any questions please contact me at [phone].
Sincerely,
Debra C. Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs

The Town of
HOLLY
SPRINGS
November 4, 2020
CERTIFIED MAIL — 7019 2280 0002 1897 0329
RETURN RECEIPT REQUESTED
Dr. Gabriel Duncan
Spring Smile Dentistry
242 S Main St Suite 208
Holly Springs, NC 27540
Water Resources
Subject: Notice of Violation
Dental Amalgam Rule EPA
40 CFR Part 441- Dental Category Compliance
Dear: Dr. Duncan
This letter serves as a Notice of Violation for failure to complete the EPA required one time
report. The report (Attached) was due October 12'1', 2020. There were multiple attempts by
TOHS via email and Certified Letters and no response was received.
It is the customer's responsibility to follow the Sewer Use Ordinance. As the "Regulatory
Authority" it is the duty of the Town of Holly Springs Pretreatment Coordinator to make the
requirements known to the customers and to follow the Sewer Use Ordnance and Enforcement
Response Plan as approved by NC DENR/DWR.
Upon receipt of this violation, please complete the attached one time report and submit to my
office no later than November 20, 2020. IF the report is not received by this date a Second
Notice if Violation will be issued and more stringent enforcement action can be taken.
If you have any questions please contact me at [phone].
Sincerely,
Debra C. Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs

The Town of
HOLLY
SPRINGS
November 4, 2020
CERTIFIED MAIL 7019 2280 0002 1897 0336
RETURN RECEIPT REQUESTED
Dr. Brent R. Niendenthal
Sunset Ridge Family Dentistry
1100 Holly Springs Rd #115
Holly Springs, NC 27540
Water Resources
Subject: Notice of Violation
Dental Amalgam Rule EPA
40 CFR Part 441- Dental Category Compliance
Dear: Dr. Niendenthal
This letter serves as a Notice of Violation for failure to complete the EPA required one time
report. The report (Attached) was due October 12th, 2020. There were multiple attempts by
TOHS via email and Certified Letters and no response was received.
It is the customer's responsibility to follow the Sewer Use Ordinance. As the "Regulatory
Authority" it is the duty of the Town of Holly Springs Pretreatment Coordinator to make the
requirements known to the customers and to follow the Sewer Use Ordnance and Enforcement
Response Plan as approved by NC DENR/DWR.
Upon receipt of this violation, please complete the attached one time report and submit to my
office no later than November 20, 2020. IF the report is not received by this date a Second
Notice if Violation will be issued and more stringent enforcement action can be taken.
If you have any questions please contact me at [phone].
Sincerely,
Debra C. Batten
Environmental Compliance Manager
Water Resources/ Town of Holly Springs

The Toirn of
HOLLY
SPRINGS
Water Resources
November 30, 2020
CERTIFIED MAIL 7019 2280 0002 1897 0343
RETURN RECEIPT REQUESTED
Dr. Brent R. Niendenthal
Sunset Ridge Family Dentistry
1100 Holly Springs Rd #115
Holly Springs, NC 27540
Subject: Notice of Violation/Notice of Non Compliance
Dental Amalgam Rule EPA
40 CFR Part 441- Dental Category Compliance
Dear: Dr, Niendenthal
This letter serves as a Notice of Violation for failure to complete the EPA required one time report. The
report was due October 12lb, 2020. There have been multiple attempts by TOHS via email and Certified
Letters the last of which was sent on November 4, 2020,
It is the customer's responsibility to follow the Sewer Use Ordinance for the Town of Holly Springs. As
the "Regulatory Authority" it is the duty of the Town of Holly Springs Pretreatment Coordinator to make
the requirements known to the customers and to follow the Sewer Use Ordnance and Enforcement
Response Plan as approved by NC DENR/DWR.
Upon receipt of the first notice of violation, you were to complete the required one time report and submit
to my office no later than November 20, 2020. This was extended beyond the EPA Compliance due date
of October 12"', 2020, As stated in the first Notice of Violation, a Second Notice of Violation/Notice of
Non Compliance is now being issued for failure to submit the report by November 20, 2020. if the report
is not in my office by December 156, 2020. The next course of action to be taken based on the
"Enforcement Response Plan" (see attached) could include a fine of a minimum of' $500.00. With each
failure to be compliant according to the approved ERP the enforcement action will be more stringent.
Please submit the report to me as soon as possible to return to compliance according to 40 CFR Part 441
for the Dental Category of dischargers. Any assistance or any questions can be directed to me at
[phone] or debra.batten@a hollysp ingsnc.us.
llly
Ii't C. Batten
pyironmental Compliance Manager
Water Resources/ Town of Holly Springs

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