WQ0041666_2020 Residuals Annual Report Review_20210517

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ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
Mr. Erik Blankenship, President
EMA Resources, Inc.
755 Yadkinville Road
Mocksville, North Carolina 27028
NORTH CAROLINA
Environmental Quality
May 17, 2021
Subject: Review of the 2020 Annual Report
EMA Resources, Distribution of Class A Residuals Program
Permit No. WQ0041666
Davie County
Dear Mr. Blankenship:
Staff of the North Carolina Division of Water Resources Winston-Salem Regional Office
(Division) has completed a review of the 2020 Annual Report for the subject facility. The initial
review of the annual report found it to be non -compliant with the subject permit. Review of
additional information received on May 17, 2021, reflects compliance with Permit No.
WQ0003351.
The Division request that you notify the Winston-Salem Regional Office prior to your next
land application event to allow for a routine compliance inspection. Please refer to the enclosed
compliance inspection reports for additional observations and comments. If you have any
questions regarding this letter, please contact Patrick Mitchell or me at the letterhead phone
number or address, or by email at [e-mail] or [e-mail].
Sincerely,
EDocuSigned by:
.-0A, 'f . Smiler
14 49 25C EA..
Lon nI er, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc: Compliance Inspection Reports (2)
cc: Mr. Brent Collins — EMA Resources (Electronic Copy)
Davie County Environmental Health (Electronic Copy)
Laserfiche File WQ0041666
WSRO Electronic Files
_1121,..„E\93
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0041666 Effective: 03/25/21 Expiration: 01/31/27 Owner : Ema Resources Inc
SOC: Effective: Expiration: Facility: EMA Resources DCAR
County: Davie 755 Yadkinville Rd
Region: Winston-Salem
Contact Person: Brent M Collins
Directions to Facility:
Mocksville NC 27028
Title: Director of Technical Services Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0087866 Piedmont Triad Regional Water Authority - John F. Kime WTP
NC0002305 Lear Corporation - Lear Corporation WWTP
Inspection Date: 05/17/2021 Entry Time 10:OOAM
Exit Time: 11:OOAM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0041666 Owner - Facility: Ema Resources Inc
Inspection Date: 05/17/2021
Inspection Type : Annual Report Review
Reason for Visit: Follow-up
Inspection Summary:
On May 17, 2021, a written response providing explanation and additional information concerning the 2020 Annual Report
was received via email. WSRO subsequently reviewed the additional info and response on May 17, 2021. No site visit was
made as part of this inspection event. Below are details related to items that were initially found to be noncompliant:
• A residuals source facility (City of Reidsville WTP) that is not approved under the subject permit was reported with
activities occurring on the annual distribution & marketing certification and summary forms.
- RESPONSE: This was a typo due to info from another facility being entered. The response provided revised annual
reporting forms with corrected info.
• The annual distribution & marketing certification and summary forms did not provide information related to residuals source
facility, Lear Corp. (approved by the subject permit); while land application records, residuals analyses results, etc. were
provided in the 2020 report indicating activities occurred.
- RESPONSE: The response provided revised annual reporting forms with corrected info.
The explanation and additional information provided reflect compliance with the subject permit.
Request notification prior to next land application event to allow for routine inspection.
Page 2 of 3

Permit: WQ0041666 Owner - Facility: Ema Resources Inc
Inspection Date: 05/17/2021
Inspection Type : Annual Report Review
Reason for Visit: Follow-up
Type
Land Application
Distribution and Marketing
Yes No NA NE
Page 3 of 3

Compliance Inspection Report
Permit: WQ0041666 Effective: 03/25/21 Expiration: 01/31/27 Owner : Ema Resources Inc
SOC: Effective: Expiration: Facility: EMA Resources DCAR
County: Davie 755 Yadkinville Rd
Region: Winston-Salem
Contact Person: Brent M Collins
Directions to Facility:
Mocksville NC 27028
Title: Director of Technical Services Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0087866 Piedmont Triad Regional Water Authority - John F. Kime WTP
NC0002305 Lear Corporation - Lear Corporation WWTP
Inspection Date: 05/14/2021 Entry Time 10:30AM
Exit Time: 12:30PM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0041666 Owner - Facility: Ema Resources Inc
Inspection Date: 05/14/2021
Inspection Type : Annual Report Review
Reason for Visit: Routine
Inspection Summary:
On May 14, 2021, WSRO staff conducted a review of the subject facility's 2020 Annual Report. No site visit was made as
part of this inspection event. The report was found to be noncompliant with the subject permit. The following items were
found to be noncompliant:
• A residuals source facility (City of Reidsville WTP) that is not approved under the subject permit was reported with
activities occurring on the annual distribution & marketing certification and summary forms.
• The annual distribution & marketing certification and summary forms did not provide any required information related to
residuals source facility, Lear Corp. (approved by the subject permit); while land application records, residuals analyses
results, etc. were provided in the 2020 report indicating activities occurred for this source.
Request an explanation for the above listed items.
Page 2 of 3

Permit: WQ0041666 Owner - Facility: Ema Resources Inc
Inspection Date: 05/14/2021
Inspection Type : Annual Report Review
Reason for Visit: Routine
Type
Land Application
Distribution and Marketing
Yes No NA NE
Page 3 of 3

Mitchell, Patrick
From: Brent Collins <[e-mail]>
Sent: Monday, May 17, 2021 8:25 AM
To: Mitchell, Patrick
Subject: [External] RE: Additional Info Request on the 2020 Annual Report for EMA Resources'
DCAR (Permit No. WQ0041666)
Attachments: 2T Annual Report Forms.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
I tried to call you Friday to go over this on the phone. I will try to explain it here but it might be easier over the phone.
This was the first year we had to submit an annual report for EMA's Class A permit so I guess in the process of me
copying and pasting sheets, I accidentally used the Reidsville WTP as my template and didn't change all of the data. The
farmer's name was incorrect and the source was incorrect but the months and the actual dry ton data was correct. I
have corrected the sheets and included those. We only land applied residuals from the Lear Corp/Guilford Mills plant
under our permit.
I believe you had a question about why the numbers on our permit's (WQ0041666) annual report did not match the
annual report for Lear Corp's (WQ0018107) report? We land applied multiple events for Lear Corp during the year. One
event in January and one event in April. Those were land applied under their class B permit (WQ0018107.) EMA's permit
was issued on July 16, 2020 and Lear Corp was listed as a Class A source. The events from that day forth, were under
EMA's class A permit.
I hope that clarifies things. If you have any other questions please give me a call.
Brent Collins
Director of Technical Services
EMA Resources Inc.
From: Mitchell, Patrick <[e-mail]>
Sent: Friday, May 14, 2021 12:17 PM
To: Brent Collins ([e-mail]) <[e-mail]>
Cc: Snider, Lon <[e-mail]>; Graznak, Jenny <[e-mail]>
Subject: Additional Info Request on the 2020 Annual Report for EMA Resources' DCAR (Permit No. WQ0041666)
Brent,
I am in the process of reviewing the 2020 annual report for the subject EMA DCAR permit. There have been several
compliance issues noted during review thus far. The Class A Annual Distribution & Marketing Certification and Summary
forms indicated that the City of Reidsville WTP was the only source land applied under this permit in 2020. The residuals
volumes "in" and "out" reflect dry tons differently from other data provided in the 2020 report related to Lear Corp. In
year 2020 the only permitted residuals source facility covered under the subject permit was Lear Corp; the City of
Reidsville is not a residuals source facility covered by this permit.
Within 10 days, please provide an explanation as to why a source facility that is not covered under the subject permit
was reported as being active under this permit and why the data provided in the remainder of the annual report was not
included in the signed Annual Distribution & Marketing Certification and Summary forms.
i

Patrick L. Mitchell, REHS, LSS
Environmental Program Consultant — Soil Scientist
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environmental Quality
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Nothing Compares._
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
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