The URL can be used to link to this page

Home My WebLink AboutWQ0035207_Staff Report_20231221State of North Carolina Division of Water Resources Water Quality Regional Operations Section Staff Report December 21, 2023 To: DWR Central Office — WQ, Non -Discharged Application No.: W00035207 Attn: Erick Saunders Facility name: Svnagro DCAR From: Caitlin Caudle Winston-Salem Regional Office Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections m they are applicable. I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? ❑ Yes or ® No II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A 2. Are the design, maintenance, and operation of the treatment facilities adequate for the type of waste and disposal system? ® Yes or ❑ No 3. Is the residuals management plan adequate? ® Yes or ❑ No 4. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No 5. Are there any setback conflicts for existing treatment, storage, and disposal sites? ❑ Yes or ® No 6. Has a review of all self -monitoring data been conducted (e.g., AR, NDMR, NDAR, GW)? ® Yes or ❑ No Please summarize any findings resulting from this review: NOV issues last year for exceeding permitted da tons for Siler City WTP, NOV-2023-PC-0177. 7. Has a review of compliance history been completed (CEI's)? ® Yes or ❑ No 8. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ❑ No 9. Check all that apply: ❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC ® Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) See attached NOV_ 10. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑ Yes ®No❑N/A If yes, please explain: Increased dry tonnage for Siler City WTP will resolve the most recent NOV. FORM: WQROSSR 04-14 Page 1 of 2 III. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No 2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an additional information request: Item Reason The phone number for the Mooresville Regional Office is not included in the Update Spill Plan Spill Plan reporting section on pg. 14. Kerr Lake WTP also needs to be added to the reporting list. A table may be a more effective way to display the information. Complete RSC for Siler pages 1 and 2 are missing. City WTP The reported SAR is 1.41, I calculated SAR to be 0.94. The reported PAN surface application and injection/incorporation is 22,006 mg/kg and 25,766 PAN and SAR calculations mg/kg. I calculated 11,003 mg/kg and 12,883 mg/kg respectively. Am I calculating something wrong? I normally have discrepancies in calculated values when reviewing S na ro facilities. Siler City WTP Label for Land Application Should the label be updated to reflect all items listed in Permit Condition III.8? Clarification of Kerr Lake WTP storage Do the decant basins total 500,000 gallons, or are they both 500,000 gallons? Complete RSC for Kerr pages 3 — 5 are missing. Lake WTP Update Residual Sampling The Residuals Sampling Plan on pg. 78 is titled Siler City WTP. TCLP Plan for Kerr Lake WTP frequency is also listed as once per permit. Will this need to be updated to reflect annual TCLP sampling? Kerr Lake WTP Label for Land Application Should the label be updated to reflect all items listed in Permit Condition 111.8? Kerr Lake WTP The last sentence lists Siler City WTP. Marketability Statement 3. Recommendation: ® Hold, pending receipt and review of additional information by regional office ❑ Hold, pending review of draft permit by regional office ❑ Issue upon receipt of needed additional information ❑ Issue ❑ Deny (Please state reasons: ) /—DocuSigned by: 4. Signature of report preparer: Signature of regional supervisor: Date: 12/21/2023 IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS 4. _!� 0D2D3CF3F1 B7456.._ The most recent Att. A was issued 3/10/2021. Siler City WTP is currently permitted for 125 dry tons/yr not 250 dry tons/ . FORM: WQROSSR 04-14 Page 2 of 2 ROY 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