WQ0041666_Staff Report_20200602

DocuSign Envelope ID: EB6B7DD1-C6EE-4CE7-84BF-965BCC4151BE
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June 2, 2020
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00041666
Attn: Erick Saunders Facility name: EMA Resources DCAR
From: Patrick Mitchell
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 as they are applicable.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Are the treatment facilities adequate for the type of waste and disposal system? ® Yes or ❑ No
2. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ® N/A
3. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ® N/A
4. Is the proposed residuals management plan adequate? ® Yes ❑ No ❑ N/A
5. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ® N/A
6. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ® No
7. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
8. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ® N/A
III. REGIONAL OFFICE RECOMMENDATIONS
Do you foresee any problems with issuance/renewal of this permit? ® Yes or ® No
If yes, please explain: The application indicates that 1% of the daily flow is domestic waste produced from
restrooms, etc. inside the waste generatin fly. This is a small fraction of the total daily flow. However, that is
9,000 to 15,000 GPD of domestic waste (i.e. 1% of 0.9 - 1.5 MGPD) that is generated and subsequently treated to
produce residuals.
If sludge (intended to produce Class A Residuals) contains any portion of domestic waste, in addition to Fecal
Coliform testing compliance with one of the approved Processes to Further Reduce Pathogens and one of the Vector
Attraction Reduction methods should be demonstrated per 2T regs. The application erroneously indicates that they
are only regulated under 40 CFR Part 257 and that they do not have to meet one of the processes to further reduce
Dathogens. It also indicates that vector attraction reduction is not aDDlicable (i.e. No Domestic Wastewater
Contributions).
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 residuals produced contain domestic wastes and therefore require
Revised application for
compliance with 40 CFR Part 503. One of the Class A processes to further
Pathogen & VAR.
reduce pathogens and one of the Class A vector attraction reduction methods
are required.
FORM: WQROSSR 04-14 Page 1 of 2

DocuSign Envelope ID: EB6B7DD1-C6EE-4CE7-84BF-965BCC4151BE
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
5. 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: )
,'—Docuftned by:
6. Signature of report preparer:
Signature of regional supervisor:
Date: June 2, 2020
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FORM: WQROSSR 04-14 Page 2 of 2