WQ0035207_Inspection Letter_20240416

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
April 16, 2024
Delivered electronically via email to: rroth synagro.com
Robert N. Roth — Technical Services Manager
Synagro Central, LLC
284 Boger Road
Mocksville, NC 27028
SUBJECT: 2023 Residuals Annual Report Review
Synagro Central DCAR
Permit No. WQ0035207
Davie County
Dear Mr. Roth:
On April 11, 2024, Division of Water Resources staff Caitlin Williams completed a review
of the 2023 residuals annual report. This review reflected compliance with the subject
permit.
The following items of concern were noted:
A. Per Permit Condition 11.3 only residuals generated by facilities listed in
Attachment A are approved for distribution, and Attachment A lists the maximum
permitted dry tons for each facility. A reported 642.9 dry tons were distributed for
the Town of Siler City WTP. The most recent Attachment A issued on March 10,
2021, lists the maximum dry tons for Siler City WTP as 125 tons. The dry tons were
exceeded by April 2023, with 153.86 tons applied during the month.
A permit modification application was submitted on October 25, 2023, and rejected
per the Permittee's request. The associated check was returned on December 12,
2023, as another permit modification application was not submitted. Another permit
modification application was submitted on December 19, 2023, that included a
request to increase the permitted dry tons for Siler City to 1,000 tons. A staff report
was completed by the Winston Salem Regional Office on December 21, 2023. An
additional information request was sent by Central Office on March 4, 2024.
Permit modification is currently pending review of additional information received
on April 3, 2024.
The above constitutes a violation of the subject permit but corrective actions were
taken during the 2023 calendar year.
D 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
Moan caaouNn 336.776.9800
oep.m.m or em�nmen� Qualm

B. Per Permit Condition IV.3 residuals from each source generating facility shall be
analyzed for specified nutrients and metals at the frequency specified in
Attachment A. As stated above, 642.9 dry tons were distributed for Siler City WTP.
The required sampling for >_ 290 dry tons to < 1,500 dry tons is once per quarter or
four times per year. Nutrient and metals samples were collected on March 13,
2023, September 28, 2023, and October 12, 2023, Quarter 1, Quarter 3, and
Quarter 4 respectively. Distribution of residuals was reported for Quarter 2, Quarter
3, and Quarter 4. Please provide an explanation for why quarterly sampling
was not completed.
Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact Mrs. Williams at the letterhead address and
phone number, or by email at caitlin.williams(a)_deq.nc.gov.
Sincerely,
Docu Signed by,
'�-.-'!�^/
OD2D3CE3F1 B7456...
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enc: Inspection Report
Cc: Adam Brigman, Synagro (electronic copy)
Davie County Environmental Health (electronic copy)
NORTH CAROLINAD � ��
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North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

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: [phone]
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: 04/16/2024 Entry Time 10:OOAM Exit Time: 03:45PM
Primary Inspector: Caitlin L(±v,dteeuSi9^ed by: Phone: [phone]
Secondary Inspector(s): Rwms
968199D49D_
Reason for Inspection: Routine
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
(See attachment summary)
Inspection Type: Annual Report Review
Sampling
Page 1 of 4

Permit: WQ0035207 Owner - Facility: Synagro Central LLC
Inspection Date: 04/16/2024 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
On April 11, 2024, Division of Water Resources staff Caitlin Williams completed a review of the 2023 residuals annual report.
This review reflected compliance with the subject permit.
The following items of concern were noted:
A. Per Permit Condition 11.3 only residuals generated by facilities listed in Attachment A are approved for distribution, and
Attachment A lists the maximum permitted dry tons for each facility. A reported 642.9 dry tons were distributed for the Town
of Siler City WTP. The most recent Attachment A issued on March 10, 2021, lists the maximum dry tons for Siler City WTP
as 125 tons. The dry tons were exceeded by April 2023, with 153.86 tons applied during the month.
A permit modification application was submitted on October 25, 2023, and rejected per the Permittees request. The
associated check was returned on December 12, 2023, as another permit modification application was not submitted.
Another permit modification application was submitted on December 19, 2023, that included a request to increase the
permitted dry tons for Siler City to 1,000 tons. A staff report was completed by the Winston Salem Regional Office on
December 21, 2023. An additional information request was sent by Central Office on March 4, 2024. Permit modification is
currently pending review of additional information received on April 3, 2024.
The above constitutes a violation of the subject permit but corrective actions were taken during the 2023 calendar year.
B. Per Permit Condition IV.3 residuals from each source generating facility shall be analyzed for specified nutrients and
metals at the frequency specified in Attachment A. As stated above, 642.9 dry tons were distributed for Siler City WTP. The
required sampling for ❑ 290 dry tons to < 1,500 dry tons is once per quarter or four times per year. Nutrient and metals
samples were collected on March 13, 2023, September 28, 2023, and October 12, 2023, Quarter 1, Quarter 3, and Quarter 4
respectively. Distribution of residuals was reported for Quarter 2, Quarter 3, and Quarter 4. Please provide an explanation for
why quarterly sampling was not completed.
The certification forms for each facility were not signed. Mrs. Williams requested signed copies of the forms on 4/12/2024.
These forms were provided on 4/15/2024.
Other observations:
• Hood WTP
0 557.74 tons were reported. Staff calculated 560 tons based on provided Field Summary Forms.
o Nutrient and metals samples were collected on 1/16/23, 2/14/23, 4/12/23, 7/18/23, and 10/18/23. TCLP was sampled
1/16/23.
o A mineralization rate (MR) of 0.4 was used to calculate PAN.
o PAN for 7/18/23 was reported as 2,594 mg/kg. Staff calculated 2,392.2 mg/kg.
o PAN for 10/18/23 was reported as 4,224 mg/kg. Staff calculated 3,968.2 mg/kg.
o Recipient information was included on the Field Summary Forms provided.
• Dukes WTP
o The certification form reported distribution took place in May 2023. All other forms and data provided show that
distribution took place in July 2023.
0 54.38 tons were distributed.
o Nutrients and metals samples were collected on 1/10/23, 4/11/23, 7/3/23, and 10/2/23. TCLP was sampled on 1/10/23.
o pH for 4/11/23 was 4.80.
• Tuckertown WTP
0 40.04 tons were distributed.
o Nutrients and metals samples were collected on 1/5/23. TCLP was sampled on 1/9/23.
o A note on the TCLP analysis report stated: TCLP extract was not stored below 6 degrees C between TCLP tumble and
analysis. Sample results may be biased low.
• Graham Mebane WTP
o 19.98 tons were distributed.
Page 2 of 4

Permit: WQ0035207 Owner - Facility: Synagro Central LLC
Inspection Date: 04/16/2024 Inspection Type: Annual Report Review Reason for Visit: Routine
o Nutrients and metals samples were collected 1/26/23. TCLP was sampled 3/13/23.
• Pittsboro WTP
o 105.88 tons were distributed.
o Nutrients and metals samples were collected on 1/26/23. TCLP was sampled on 1/26/23.
o pH was 5.10.
o A MR of 0.2 was used to calculate PAN.
• Reidsville WTP
o 52.98 tons were distributed.
o Nutrient and metals samples were collected on 7/21/23 and 10/23/23. TCLP was sampled on 7/21/23.
o For 7/21/23 PAN was calculated with a MR of 0.4 and reported as <20,000 mg/kg. Staff calculated 10,217 mg/kg.
o For 10/23/23 PAN was calculated with a MR of 0.4 and reported as <5,500 mg/kg. Staff calculated 17,740 mg/kg. Staff
have no concern for over application.
• Siler City WTP
o 642.9 tons were distributed.
o Nutrients and metals samples were collected 3/13/23, 9/28/23, and 10/12/23. TCLP was sampled on 1/26/23.
o Distribution occurred in Qt 2, Qt3, and Qt4. Sampling occurred in Qt1, Qt3, and Qt4.
o PAN for 9/28/23 was calculated with a MR of 0.4 and reported as 5,076 mg/kg. Staff calculated 5,076 mg/kg. PAN for
10/12/23 was calculated with a MR of 0.4 and reported as 2,202 mg/kg. Staff calculated 1,688 mg/kg.
o pH for 10/12/23 was reported as 8.4.
• South Fork Industries
o 120.32 tons were distributed.
o Nutrients and metals samples were collected on 10/3/23. TCLP was sampled on 10/3/23.
o PAN was calculated with a MR of 0.3 and reported as 23,355 mg/kg. Staff calculated 23,349 mg/kg.
Page 3 of 4

Permit: WQ0035207 Owner - Facility: Synagro Central LLC
Inspection Date: 04/16/2024 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?
❑
❑ 0 ❑
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?
❑
❑ 0 ❑
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?
0
❑ ❑ ❑
Are hauling records maintained and up-to-date?
0
❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
0
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
0
❑ ❑ ❑
Comment:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment: See summary.
Page 4 of 4

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