WQ0006101_NOV-2007-PC-0125_20070529

4, AV
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
May 29, 2007
Mr. Ronald Autry, City Manager
City of Dunn
Post Office Box 1065
Dunn, North Carolina 28335
Subject: NOTICE OF VIOLATION: NOV-2007-PC-012'S - Resolved
Permit # WQ0006101,: City of Dunn Residuals Land Application/Pope Farms
Harnett County
Dear Mr. Autry:
After reviewing the information supplied in a,letter dated 5 March 2007 from Synagro, the City.of
Dunn's (Dunn) residuals contractor, the Notice of Violation (NOV) dated 26 February 2007 has been
resolved and this compliance issue is closed. The Division of Water Quality (DWQ) appreciates your
prompt response concerning this matter and providing a remedy to the violation to avoid future
compliance issues. DWQ personnel conducted a site visit on 20 February 2007 to review -nine (9)
farm fields to be added to the Dunn program.
DWQ would like to take this time to_ remind Dunn that the fields used for land application that the
notice of violation related to, i.e. Andy Pope land (Pope), were approved for emergency approval in
December 2006. The emergency approval was valid for 90 days (until 14 March 2007),-as stated on
page two of the letter dated 14 December 2006. If residuals' have been applied to any, of the Pope
farmland after 14 March 2007, additional compliance action will be necessary by DWQ.
DWQ personnel conducted a site visit on 20 February 2007 to review nine (9) farm fields to be
added to the Dunn program. To date, DWQ has not received an application: to modifytheDunn
residuals land application program permit to allow additional residuals application to the Pope
farmland.
If you have any questions concerning this matter, please do not hesitate to contact either Jinn
Barber at (910-433-3340) or myself at (910- 433-3336). .
hen B dt, L. .
Regional quifer Protection Supervisor
cc: Joel Shields
APS Central Office File/Ed Hardee
ASPS FRO e:: Cit of Dunri#49 6,1�01 one
N rthCarolinE
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N.C. Division of Water Quality/Aquifer Protection Section 225 Green St./ Suite 714 Fayetteville, NC 28301 - Phone [phone]
FAX [phone]
Internet: h2o.enr.state.nc.us Customer Service 1-877-623-6748
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SYNAGIV
A Residuals Management Company
March 5, 2007
NCDENR-DWQ
Aquifer Protection Section
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301
ATTENTION: Mr. Stephen Barnhardt
REFERENCE: NOTICE OF VIOLATION
City of Dunn (WQ0006101)
RECEIVED
MAR 0 6 Y007
DENR - FAYE71BgLLE REGIONAL OFFICE
Dear Mr. Barnhardt:.
In response to the Notice of Violation (NOV) issued by the Fayetteville Regional Office on February 26, 2007,
Synagro is presenting you with the causes of noncompliance and actions taken to prevent recurrence of similar
situations.
On December 16, 2006, Synagro initiated land application activities on field NC-SA-23-3 (22.7 acres, owned
and operated by Any Pope). Beginning on December 18, 2006, the activities were initiated on field NC-SA-23-2
(48.3 ac, owned and operated by Andy Pope). Due to the inability of the Dunn WWTP to meet VAR
requirements, it was decided by Synagro that the material would be incorporated within 6 hours of application
(Option 10). This was discussed with the farmer on December 8, 2006, upon which he agreed to perform the
incorporation with use of his tractor and disc, and plant wheat soon thereafter (within 30 days). It was apparent
to all parties during the site review on February 20, 2007 by Synagro and Fayetteville Regional Office staff that
this did not occur as originally planned.
Based on conversations with the Synagro Technical Service Manager (TSM) and Operations Manager (OM), it
appears that at the time of this incident, Synagro did not have protocols in place in order to verify incorporation
when done by a 3rd party. Once the Syi agro Sr. Operations Manager (Sr. OM) and I Were made aware of this,
procedures were put in place and were discussed at length with all appropriate personnel. These procedures
include, but are not limited to: daily verification of incorporation by the OM and/or TSM and reporting activities
to the Sr. OM and/or Technical Services Director (TSD). The same procedures (albeit not daily, but within 30
days) will also be used to verify that a suitable cover crop is established on sites with no actively growing crop.
Please feel free to contact me (336-998-7150 ext 17) if you have any further questions or comments regarding
this situation. I welcome your comments and suggestions in my quest for the achievement of 100% compliance
with all State and Federal regulations..
Sincerely,
Todd E. Shearin, Technical Services Director
Cc: Mr. Ronald Autry, City Manager (City of Dunn)
Mr. Billy Addison, Assistant Public Works Director (City of Dunn)
284 Boger Road • Mocksville, NC 27028-7619 • Ph: [phone] • Fax: [phone] • Toll Free: [phone]

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Michael F. _Easley,`Govemor,.
William G. Ross Jr ;:Secret
North Carolina Department of Environment and Natural Resources
- Alan W'. Klimek P.B:=Director :.'.
Division of Water Quality
February.26 2007
CERTIN D. MAIL.
RETURN RECEIPT REQUESTED
Mr. Ronald Autry, City Manager
City of Dunn
Post Office Box 1065
Dunn, North Carolina 28335
ITICE OF YIOLATI(
Pemut No. WQ0006'I01
City of Dunn Residuals Land Application Program
Harnett & Sampson County
$c_—C(Z.,...
Dear Mr. Autry:
On 20 February 2007 personnel with -the Division:of Water Quality (DWQ) met with the
City of Dunn's (Dunn) land application contractor, Synagro, to evaluate proposed -farm-
land to be added to the City of Dunn's land application program Also on this day DWQ
and Synagro evaluated current farmland utilized underthe emergency approval granted to'
Dunn' on 14 December 2006. During this, evaluation it was observed that wastewater
treatment plantresidualsland applied to fields identified as SA-23 02- and. SA-23-03 had.
not been incorporated nor was a -suitable vegetative cover.growing or present. After a
brief discussion with Synagro at the site, it's the understanding of DWQ that the residuals
were land applied during the month of December 2006 once the emergency' approval was
granted; therefore the City of Dunn land application program is in violation of its permit,
WQ0006101, and the following specific conditions:
Violation #1: Section I — PERFORMANCE STANDARDS
Condition (7) in Permit No WQ0006101 states the following (edited):
"When residuals are land applied under the conditions of this permit, the Class A pathogen
requirements and site restrictions in 40 CFR Part 503.32(a) or the Class B pathogen
requirements and site restrictions in 40 CFR 503.32(b) and'one of the vector attraction reduction'
requirements in 40 CFR 503.33 shall be meet"
This condition; refers to incorporation, of wastewater residuals. that are land applied, as a vector
attraction reduction method. As reported on. the ANNUAL PATHOGEN AND VECTOR
ATTRACTION REDUCTION FORM in. the 2005 Dunn annual report; the City of Dunn utilizes
Option 10, incorporation of residuals as its vector attraction reduction method. As of 20 February '
2007 the wastewater residuals land applied in December 2006 on fields SA-23-02 and SA-23-03
have not been incorporated (disced or plowed). .
North Carolina
atura!!y
North Carolina Division of Water Quality/Aquifer Protection Section 225 Green St./•Suite 714 Fayetteville, NC 28301 Phone [phone]
FAX [phone] Internet: h2o.enr.state.ne.us Customer Service 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Mr. Ronald Autry, City Manager
City of Dunn
February 26, 2007
Page 2
Violation #2: Section II — OPERATION AND MAINTENANCE. REQUIREMENTS
Condition (12) in Permit No.WQ0006101 states the following (edited)
"A suitable vegetative,as listed in Condition II (13) shall be maintained On' land application sites
onto which residuals are land applied in accordance with- the crop management plan outlined by.
the local'CooperativeExtension office"
This condition refers. to planting of a crop and maintaining: a, suitable crop for the utilization of the
nutrients applied:in the form of wastewater residuals.. As of 20February2007 ,a suitable cover
crop has not been:, established on?>fields`SA 23-02.'and SA 23 03 for the applicationevent of
December 2006.
Violation #3: Section II — OPERATION .AND MAINTENANCE REQUIREMENTS
Condition.(22) in Permit No.WQ0006101 states the following:
"Surface -applied residuals shall be plowed or disced.:within 24 hours after land application on
land application sites with no cover crop established"
As of 20 February 2007 fields SA-23-02 and SA-23-03 have not been disced or plowed; for the
application event. of December 2006:-,This-.observation was made and photos taken of the fields in
which:remnants of the pervious, years crop of soybeans was evident andthe tracks from
equipmentused in the application.ofthe wastewater residuals were evident.
Remedial actions should be taken to correct this problem immediately. The Division of
Water•Quality may pursue enforcement action for this and anyadditional violations of
State law if violations of permit conditioni or rules persist.
To prevent further action, carefully review this violation and respond in writing to this
. office within 10 working days of receipt of this letter. You should address the causes'of
noncompliance and all actions taken to prevent the recurrence of similar situations. If
you should have any questions, please do not hesitate to contact me at [phone] or
Jim Barber at (910).433-3340.
Sinc -
S phen '• . Barnhardt
Re'ona Supervisor
Aquifer Protection Section
Fayetteville Region
Division of Water Quality
Cc: DWQ Central Files: WQ0006101
Mr. Ed Hardee; DWQ Central Office — AP Section/Non-Discharge
Compliance/Enforcement Unit.
I -FRO -Region la Files WQ9Qlf61.0`I

PStanding atthe back of field S.A-23-03"lo o king tw.-vard 42-1. Dark streaks
—crossing
Vehicle tracks and land |icetiunpattonn.Thisoamaaoehahowmo0aundat
�fleld SA-23-702 located -on Rabbit Street,north application field.

City of Dunn: WQ00061 01.Field SA 20 03, 2/20/07
astewater residuals land;applied ir1 December 2006, under emergency approval granted bit
after<dated 1 ^/14103, that ha e not been p.?perly manage Sotrbean residue from previous
ears crop evident No vegetation e_stablishsd (Nlnter rye U4heat, oats, e" '

u SYNAGBO
TOPOGRAPHIC MAP
A Re idualsAlanagement Company
OWNER 1Pe SCALE: 1" = (660 FIELDS 1 3
� °
PHOTOQ UAD/YEAR e Sk'n (NC] / 1 ci9Sb
CONTOUR INTERVAL @

Facility Name
WWTP Nsune
ANNUAL PATHOGEN AND VECTOR ATTRACTION REDUCTION FORM
City of Dunn Permit Number W00006101
Dunn WWTP NPDES # NC0043176
Monitoring Period: From 01 / 01 / 05 To 12 / 31 / 05 (April 2005 Event)
Pathogen Reduction (40 CFR 50332) - Please indicate level achieved and alternative performed
Class A
Alternative 1 Alternative 2 Alternative 3
Alternative 4 Alternative 5 Alternative 6
Class.B X
Alternative 1 _X_ Alternative 2 Alternative 3
If applicable tonitemative performed (Class B only) indicate "Process to Significantly Reduce Pathogens":
- Apraik DigeitiOn. Anaerobic Digestion Composting Lime Stabilization
apphcaole to -alternative porotindd(Ciass A or Class B) complete* following monitonng data.
Paflrnetr
Allowable Level in
Sludge.
athugeu Des-
• Mild***
9e0. melt*
lhalts
Nsinber.of
Exceedentes
. . . ,
Frequency of
Analysis -
, Sample
Type
Analytical
Technique
Fead Coliform
2,000,000 MPN per
gram pftotid solids
96,500
,188,057
• -
• .
309,000
• MPN/
„ .
Pet Event
-thab •
St418922T
or 2,000,000 CFU. per
1000 MPN er gram ol
total solids (dry
weight)
Salmonella Maeda
( in lien of fecal
colifonn)
3MPN per 4 grams
• total solids (thy
weight)
=••
Vector Attraction Reduction (40 CFR 503.33) - Please indicate option performed
Option 1 01366112 Option 3 Option4 Option 5
Option 6 Option 7 •Option 8 Option 9 •Option 10 X
No vector attraction reduction options were performed
CERTIFICATION STATEMENT (please check the appropriate statement)
X • "I certify, under penalty of law; that the pathogen requirements in 40 CFR 503.32nrid the vector attraction
reduction requirement in 40 CFR 503.33 have been met."
"I certify, under penalty of law, that the pathogen requirements in 40 CFR 503.32 and the vector attraction
reduction requirement in 40 CFR 503.33 have not been' met." (Please note if yen check this statement attach an
explanation why you have not met one or both ofthe requirements.)
"This determination has been made under my direction and supervision in accordance with the system designed to ensure
that qualified personnel properly gather and evaluate the information used to determine that the pathogen and vector
attraction reduction requirements have been met. I am aware that there are significant penalties for false certification
including fine and imprisonment"
Bobby E. Burnette, WWTP ORC
Preparer Name and Title (type or print)
dif
Signattre
ors(4,1-2-A -024
William C. Toman, Jr., President ABS, Inc.
Land Applier Name and JtIe (if applicable)(type or print)
izaelc
Signature of Appl (if applicable) • Date

Michael•F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W:.Klithek P.E. Director
Division of Water Quality
February 26, 2007
• RETURN
RECEIPT
CERTIFIED:MAILREQUESTED
Mr. Ronald Autry, City Manager
City Ofpunn
Post Office 11,cnt 1065
Dunn, North Carolina 28335
Subject': NOTICE OF VIOLATION0 V 2 oP —
PermitNo. W00006101
City of Dunn Residuals Land Application Program
Harnett & Sampson County
Dear Mr. Autry:
On 20 February 2007 personnel with the Division ofWater Quality (DWQ) met With the
City of Dunti's (Dunn) land application contractor, Synagro, to evaluate proposed farm-
land to be added.to.the City of Dunn' s land application program. Also on this day DWQ
and Synagro evaluated current farmland ittilixedviidertheemergency-approvif granted to
Dunn on 14 December.2006.During.this evaluation it was observed that wastewater
treatment plant residuals land applied to fields identified as SA-23=02 and SA-23;03 had
not been incorporated nor was a suitable vegetative cover growing or present. After a
brief discussion with Synagro at the site, it's the understanding of.DWQ that the residuals
were land applied during the month of December 2006 once the emergency approvalwas
granted; therefore the City of Dunn land application program is in violation of its permit,
WQ0006101, and the following specific conditions:
Violation #1: Section 1— PERFORMANCE STANDARDS
Condition (7) in Permit No.WQ0006101 'states the'folloiving (edited):
"When residuals are land applied under the conditions of thts permit, the Class A pathogen
requirements and site restrictions in 40 CFR Part 503.32(a) or the Class B pathogen
requirements and site restrictions in 40 CFR 503.32(b) and one of the vector attraction reduction
requirements in 40 CFR 503.33 shall be meet"
•
This condition refers to incorporation, of wastewater residuals that are land applied, as a vector
attraction reduction method. As reported on the ANNUAL PATHOGEN AND 'VECTOR
ATTRACTION REDUCTION FORM in the 2005 Dunn annual report; the City of Dunn utilizes
Option 10, incorporation of residuals as its vector attraction reduction method. As of 20 February
2007 the wastewater residuals land applied in December 2006 on fields SA-23-02 and SA-23-03
have not been incorporated (disced or plowed).
•
North Carolina Division of Water Quality/Aquifer Protection Section 225 Green St./ Suite 714 Fayetteville, Ne .2601 Phone [phone]
• FAX [phone] • Internet: h2o:enr.state.bc.us . • Customer Service 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
None Carolina
7t7atura11ij