WQ0031712_Additional Information Request_20210310

ROY COOPER
Governor
DIONNE DELLFGATTI
Secretary
S. DANIEL SMITH
Director
RON SINK — GENERAL MANAGER
DAVIDSON WATER, INC.
POST OFFICE BOX 969
WELCOME, NORTH CAROLINA 27374-0969
Dear Mr. Sink:
NORTH CAROLINA
Environmental Quality
March 10, 2021
Subject: Application No. WQ0031712
Additional Information Request
Davidson Water WTP
Distribution of Class A Residuals
Davidson County
Division of Water Resources' Central and Regional staff has reviewed the application package
received December 22, 2020. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on April 9,
2021.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through H, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with an
electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3660 or [e-mail]. Thank you for your cooperation.
Sincerely y:
ZuS,,g,led
n
6Piummer, P.E., Engineer III
Division of Water Resources
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Brent Collins — EMA Resources, Inc. (Electronic Copy)
Permit Application File WQ0031712
E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROHNA -
oePemmencaieml—mentaiWsul /� 919.707.9000

Mr. Ron Sink
March 10, 2021
Page 2 of 3
A. Application:
1. The renewal package appears to have been prepared by Mr. Brent Collins of EMA Resources, Inc.;
however, Item I.1 does not provide information for the consultant (Mr. Collins). Please complete
Item 1. 1.
The responses to Item IV.3 and Item IVA are different quantities by more than 100 dry tons. Is the
applicant requesting to increase their approved maximum dry tonnage from 566 (the current
permitted maximum dry tons per year) to 673? The quantitative justification for residuals
production rate did not indicate an increase request; however, the residuals source certification
indicates that 673 dry tons of residuals are being generated annually. Is there another disposal
method that has not been indicated? Please provide additional information.
3. Reviewing the submitted Residuals Source Certification (RSC) form and the lab report, there
appear to be differences between the results provided. For example, the RSC lists a lead value of
0.402 mg/L while the lab report indicates it was not detected. Was lead detected in a previous
sample? Please provide clarification of the discrepancy.
B. Application Fee:
1. Not applicable.
C. Cover Letter:
1. No comment.
D. Pro2ram Information
1. Program information was not provided as required in the application checklist. Please provide the
program narrative, a marketability statement, and a label or information sheet to be provided to the
person who receives the processed residuals. These documents shall include the following:
a. Program narrative
i. How the materials will be handled and transported from where the residuals were produced
to where it will be treated.
ii. How the residuals will be processed/treated (attach process flow diagram).
iii. How leachate collection will be handled.
iv. Where the residuals will be stored until processed.
v. How the final product will be distributed (packaging, bulk, etc.)
vi. What nutrients or other constituents (i.e. nitrogen, phosphorous, aluminum, calcium, etc.) are
used or recommended as the limiting parameter for determination of residuals loading rate
to ensure that it does not overload the soil and cause contravention of surface water or
groundwater standards, limit crop growth, or adversely impact soil quality.
b. Marketability statement
i. Detail destinations and approximate amounts of the final product to be distributed.
c. Product label/information sheet
i. Name and address of the person who prepared the residual that is sold or given away.

Mr. Ron Sink
March 10, 2021
Page 3 of 3
ii. A statement that application of the residuals to the land shall be in accordance with the
instructions on the label or information sheet.
iii. A statement that the residuals shall not be applied to any site that is flooded, frozen or snow-
covered.
iv. A statement that adequate procedures shall be provided to prevent surface runoff from
carrying any disposed or stored residuals into any surface waters.
v. Information on all applicable setbacks in accordance with 15A NCAC 02T .1108(b).
vi. A statement that the residuals shall be applied at agronomic or recommended rates for
intended uses.
E. Detailed Plans and Specifications:
1. Not applicable.
F. Engineering Calculations:
1. PAN and SAR calculations were not provided. Please provide the 1-year and 5-year PAN
calculations and the SAR calculations.
G. Environmental Assessments
1. Not applicable.
H. Operation & Maintenance Plan:
1. No comment.

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