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Home My WebLink AboutWQ0035207_NOV-2023-PC-0177_20230501ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality May 1, 2023 CERTIFIED MAIL No. 7019 1120 0001 5505 1763 RETURN RECEIPT REQUESTED Robert N. Roth, Technical Services Manager Synagro Central, LLC 284 Boger Road Mocksville, NC 27028 SUBJECT: Notice of Violation (NOV-2023-PC-0177) Synagro Central DCAR Permit No. WQ0035207 Davie County Dear Mr. Roth: On April 26, 2023, Division of Water Resources staff Caitlin Caudle completed a review of the 2022 Annual Report. This review reflected noncompliance with the subject permit. The following violation was noted: A. The dry tons reported for Siler City WTP was 233.68 tons. The most recent Attachment A issued March 10, 2021, lists Siler City WTP with a permitted dry tons per year of 125 tons. This is an exceedance of the permitted dry tonnage for Siler City WTP. If the dry tonnage is expected to exceed 125 tons on a regular basis, a permit modification application should be submitted. The following items of concern were noted: • For Hood Creek WTP, staff calculated plant available nitrogen (PAN) for 4/20/2022 to be 5,672mg/kg, for 7/20/2022 to be 3,157 mg/kg, and 10/17/2022 to be 7,003.9 mg/kg. The application method during this time frame was incorporation. Staff used a volatilization rate (VR) of 1.0 and a mineralization rate (MR) of 0.4. For Mebane WTP, staff calculated PAN for 1/18/2022 to be 11,130 mg/kg. The application method used during this time frame was surface application. Staff used a VR of 0.5 and MR of 0.4. For Siler City WTP, staff calculated PAN for 3/2/2022 to be 7,288 mg/kg. The application method used during this time frame was surface application. Staff used a VR of 0.5 and MR of 0.4. Moving forward, please ensure PAN calculations are correct. Please provide an explanation for these reported values to Ms. Caudle. • Annual sampling for Siler City WTP was completed on 3/2/2022. The lab report showed that the majority of parameters were beyond hold time. Please provide an explanation for this qualifier on the lab report. North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 NoanicaaouNn oep.m.m or em�nmen� Qualm 336.776.9800 Please refer to the enclosed inspection report for additional comments and observations. If you have any questions, please contact Ms. Caudle at the letterhead address and phone number, or by email at Caitlin.caudle(a)ncdenr.gov. Sincerely, DocuSigned by: OD2D3CE3F167456... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO Enc: Inspection Report Cc: Davie County Environmental Health (electronic copy) D North Carolina Department of Environmental Quality I Division of Water Resources ✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly Compliance Inspection Report Permit: WQ0035207 Effective: 03/10/21 Expiration: 01/01/27 Owner : Synagro Central LLC SOC: Effective: Expiration: Facility: Synagro Central DCAR County: Davie Region: Winston-Salem Contact Person: Gregory T Flory Title: Executive Director Phone: 336-498-5510 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NCG590017 City of Greensboro - Lake Townsend WTP NC0046345 City of Reidsville - Reidsville WTP NC0075701 City of Albemarle - Tuckertown WTP NC0087866 Piedmont Triad Regional Water Authority -John F. Kime WTP NC0057533 Brunswick County - Hood Creek WTP Inspection Date: 04/24/2023 Entry Time 09:OOAM Exit Time: 03:30PM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Distribution of Residual Solids (503) Facility Status: ❑ Compliant Not Compliant Question Areas: Miscellaneous Questions Record Keeping Sampling (See attachment summary) Inspection Type: Annual Report Review Treatment Page 1 of 4 Permit: WQ0035207 Owner - Facility: Synagro Central LLC Inspection Date: 04/24/2023 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: On April 26, 2023, Division of Water Resources staff Caitlin Caudle completed a review of the 2022 Annual Report. This review reflected noncompliance with the subject permit. The following violation was noted: A. The dry tons reported for Siler City WTP was 233.68 tons. The most recent Attachment A issued March 10, 2021, lists Siler City WTP with a permitted dry tons per year of 125 tons. This is an exceedance of the permitted dry tonnage for Siler City WTP. If the dry tonnage is expected to exceed 125 tons on a regular basis, a permit modification application should be submitted. The following items of concern were noted: • For Hood Creek WTP, staff calculated plant available nitrogen (PAN) for 4/20/2022 to be 5,672mg/kg, for 7/20/2022 to be 3,157 mg/kg, and 10/17/2022 to be 7,003.9 mg/kg. The application method during this time frame was incorporation. Staff used a volatilization rate (VR) of 1.0 and a mineralization rate (MR) of 0.4. For Mebane WTP, staff calculated PAN for 1/18/2022 to be 11,130 mg/kg. The application method used during this time frame was surface application. Staff used a VR of 0.5 and MR of 0.4. For Siler City WTP, staff calculated PAN for 3/2/2022 to be 7,288 mg/kg. The application method used during this time frame was surface application. Staff used a VR of 0.5 and MR of 0.4. Moving forward, please ensure PAN calculations are correct. Please provide an explanation for these reported values to Ms. Caudle. • Annual sampling for Siler City WTP was completed on 3/2/2022. The lab report showed that the majority of parameters were beyond hold time. Please provide an explanation for this qualifier on the lab report. Other observations: • Six residual sources were utilized in the 2022 calendar year. • Hood Creek WTP — 823.41 tons o Quarterly sampling was completed on 1/10/2022, 4/20/2022, 7/20/2022, and reportedly 10/25/2022. Lab reports show that the October sampling was completed on 10/17/2022. TCLP was completed on 1/10/2022. pH on 4/20/2022 was below 6. o Application activities occurred January through December on 36 fields in Brunswick and Columbus Counties. Incorporation and surface application was used. • Mebane WTP — 76.01 tons o Annual sampling was completed on 1/18/2022. TCLP was completed on 1/19/2022. o Application activities occurred in May and June on one field in Alamance County. Surface application was used. • Tuckertown WTP — 14 tons o Annual sampling was completed on 1/27/2022. TCLP was completed on 1/27/2022. o Application activities occurred in June on three fields in Randolph County. Surface application was used. • Pittsboro WTP — 131.05 tons o Annual sampling was completed on 1/5/2022. TCLP was completed on 1/5/2022. pH was below 6. o Application activities occurred in February, June, and July on two fields in Chatham County. Surface application was used. A MR of 0.2 was used in the PAN calculation. • Siler City WTP — 233.68 tons o Annual sampling was completed on 3/2/2022 . TCLP was completed on 1/19/2022. The lab report sample qualifiers show that most parameters were outside of hold time and the sample was not cooled appropriately when received. Based on the laboratory's website, the parameters marked as "beyond holding time" were within the hold time. o Application activities occurred in April, June through September, and December on seven fields in Chatham County. Surface application was used. • Franklin WTP — 108.14 tons o Annual sampling was completed on 7/21/2022. TCLP was completed on 7/21/2022. o Application activities occurred in October on three fields in Macon County. Surface application was used. Page 2 of 4 Permit: WQ0035207 Owner - Facility: Synagro Central LLC Inspection Date: 04/24/2023 Inspection Type: Annual Report Review Reason for Visit: Routine Type Yes No NA NE Land Application ❑ Distribution and Marketing Record Keeping Yes No NA NE Is GW monitoring being conducted, if required? ❑ ❑ 0 ❑ Are GW samples from all MWs sampled for all required parameters? ❑ ❑ 0 ❑ Are there any GW quality violations? ❑ ❑ 0 ❑ Is GW-59A certification form completed for facility? ❑ ❑ 0 ❑ Is a copy of current permit on -site? ❑ ❑ ❑ Are current metals and nutrient analysis available? 0 ❑ ❑ ❑ Are nutrient and metal loading calculating most limiting parameters? 0 ❑ ❑ ❑ a. TCLP analysis? 0 ❑ ❑ ❑ b. SSFA (Standard Soil Fertility Analysis)? 0 ❑ ❑ ❑ Are PAN balances being maintained? 0 ❑ ❑ ❑ Are PAN balances within permit limits? 0 ❑ ❑ ❑ Has land application equipment been calibrated? ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ ❑ 0 ❑ Are there pH records for the land application site? ❑ ❑ 0 ❑ Are nutrient/crop removal practices in place? 0 ❑ ❑ ❑ Do lab sheets support data reported on Residual Analysis Summary? 0 ❑ ❑ ❑ Are hauling records available? ❑ ❑ ❑ Are hauling records maintained and up-to-date? ❑ ❑ ❑ # Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ ❑ Has application occurred during Seasonal Restriction window? 0 ❑ ❑ ❑ Comment: Treatment Yes No NA NE Check all that apply Aerobic Digestion ❑ Anaerobic Digestion ❑ Alkaline Pasteurization (Class A) ❑ Alkaline Stabilization (Class B) ❑ Compost ❑ Drying Beds ❑ Other ❑ Comment: Page 3 of 4 Permit: WQ0035207 Inspection Date: 04/24/2023 Sampling Describe sampling: Is sampling adequate? Is sampling representative? Comment: Owner - Facility: Synagro Central LLC Inspection Type: Annual Report Review Reason for Visit: Routine Yes No NA NE ■❑❑❑ ■❑❑❑ Page 4 of 4