WQ0010583_Staff Report_20211215

RESIDUALS SOURCE FACILITY SUMMARY
Applicant's name: Davie County
Status
Code a
Facility Permit Holder
Facility Name
County
Permit Number
Maximum Dry
Tons Per Year
Current b
Proposed
M
Davie County
Cooleemee WWTP
Davie
NC0024872
2817
2817
a Status Code for source facility are: • N (New) • R (Renewed) • M (Modified) • D (Deleted)
b The amount of residuals currently permitted for distribution, land application, or disposal (i.e, not applicable to new facility).
SUMMARY FOR FORM: RSC 06-16
Page 1

DWR
Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
RESIDUALS SOURCE CERTIFICATION
FORM: RSC 06-16
I. RESIDUALS SOURCE -GENERATING FACILITY INFORMATION (See Instruction B.):
1. Facility Name: Cooleemee WWTP
2. Facility permit holder is: in Federal, ❑ State, ® Local Government, or ❑ Private.
Facility permit issued by: ❑ Div. of Water Resources, 11 Div. of Environmental Health,
or ❑ Other (explain: ).
3. Facility contact person and title: Tim Smith - ORC
Complete mailing address: 123 South Main St
City: Mocksville State: NC Zip: 27028-
Telephone number: [phone] E-mail address: tlsmithnu,daviecountync.gov
4. Facility physical address: 175 Hwy 801 S.
City: Cooleemee State: NC Zip: 27028-
Coordinates: Latitude: 35° 48' 15" Longitude: 80° 33' 40"
Datum: NAD83 Level of accuracy: nearest second
Method of measurement: GPS
5. Purpose of the facility:
® treatment of municipal wastewater, ❑ treatment of 100% domestic wastewater,
❑ treatment of potable water, ❑ treatment of 100% industrial wastewater,
61 treatment of industrial wastewater mixed with domestic wastewater,
(approximate percentages: I % industrial and _ % domestic)
▪ other (explain: L ).
6. Does the facility have an approved pretreatment program: Yes ❑ No
7. Facility permitted/design flow: 1_5 MGD and facility average daily flow: 0.5 MGD
8. Average amount of residuals being generated at this facility 315 dry tons per year.
9. Specify the following regarding treatment and storage volumes available at the facility:
Type and volume of residuals treatment: Aerobic Digester — 150,000 gallons
Type and volume of residuals storage (i.e., outside of residuals treatment units): 1.5 MG concrete basin and 3MG concrete
basin
II. RESIDUALS QUALITY INFORMATION (See Instruction C.):
1. Specify if residuals are regulated under:
® 40 CFR Part 503 or ❑ 40 CFR Part 257.
Note: Only residuals that are generated during domestic/municipal wastewater treatment processes are regulated under 40
CFR Part 503, otherwise, the residuals are regulated under 40 CFR Part 257.
2. Specify if residuals are defined under 15A NCAC 02T.1102(6) as:
• Biological ❑ Non -Biological
FORM: RSC 06-16 Page
1 of 5

Note: Biological residuals are residuals that have been generated during the treatment of domestic wastewater, animal
processing wastewater, or the biological treatment of industrial wastewater (biological treatment is a system that utilizes
biological processes including lagoons, activated sludge systems, extended aeration systems, and fixed film systems).
3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non -hazardous under
RCRA: (Note - this item does not have to be completed for facilities that are less than 0.5 MGD in design flow that treat
100% non -municipal, domestic wastewater only)
a. Are the residuals listed in 40 CFR §261.31-§261.33: ❑ yes In no.
If yes, list the number(s):
b. Specify whether or not the residuals exhibit any of the characteristics defined by 40 CFR §261.21-
261.24: ❑ yes ® no.
Fill in the following tables with the results of the latest toxicity characteristic leaching procedure (TCLP) analysis as well
as those for corrosivity, ignitability, and reactivity:
Laboratory: Pace Analytical and Date of analysis: 04/26/2021
Passed corrosivity test: ® yes ❑ no. pH: s.u. (2 < pH < 12.5)
Passed ignitability test: ® yes ❑ no. Flashpoint: >170 °F (> 140°F)
Passed reactivity test: yes lino. HCN: <0.25 mg/kg (<250) & H2S: <25 mg/kg (<500)
TCLP Parameter
Limit
(mg/1)
Result
(mg/1)
TCLP Parameter
Limit
(mg/1)
Result
(mg/1)
Arsenic
5.0
ND
Hexachlorobenzene
0.13
ND
Barium
100.0
0.25
Hexachloro-1,3-Butadiene
0.5
ND
Benzene
0.5
ND
Hexachloroethane
3.0
ND
Cadmium
1.0
ND
Lead
5.0
ND
Carbon Tetrachloride
0.5
ND
Lindane
0.4
ND
Chlordane
0.03
ND
Mercury
0.2
ND
Chlorobenzene
100.0
ND
Methoxychlor
10.0
ND
Chloroform
6.0
ND
Methyl Ethyl Ketone
200.0
ND
Chromium
5.0
ND
Nitrobenzene
2.0
ND
m-Cresol
200.0
ND
Pentachlorophenol
100.0
ND
o-Cresol
200.0
ND
Pyridine
5.0
ND
p-Cresol
200.0
ND
Selenium
1.0
ND
Cresol
200.0
ND
Silver
5.0
ND
2,4-D
10.0
ND
Tetrachloroethylene
0.7
ND
1,4-Dichlorobenzene
7.5
ND
Toxaphene
0.5
ND
1,2-Dichloroethane
0.5
ND
Trichloroethylene
0.5
ND
1,1-Dichloroethylene
0.7
ND
2,4,5-Trichlorophenol
400.0
ND
2,4-Dinitrotoluene
0.13
ND
2,4,6-Trichlorophenol
2.0
ND
Endrin
0.02
ND
2,4,5-TP (Silvex)
1.0
ND
Heptachlor and its Hydroxide
0.008
ND
Vinyl Chloride
0.2
ND

4. Metals Determination: Complete one of the following tables (i.e., as applicable) to demonstrate that the residuals do not violate
the ceiling concentrations for metals regulated under 15A NCAC 02T .1105.
a. For Distribution/Land Application: Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: Waypoint Analytical and Date of analysis: 6/10/21
Parameter
Ceiling
Concentration Limits
(ClassA & ClassB)
(mg/kg)
Monthly Average
Concentration Limits
(Class A Only)
(mg/kg)
Result
(mg/kg)
Arsenic
75
41
6.12
Cadmium
85
39
2.24
Copper
4,300
1,500
103
Lead
840
300
31.8
Mercury
57
17
.388
Molybdenum
75
n/a
3.44
Nickel
420
420
25.9
Selenium
100
100
<2.11
Zinc
7,500
2,800
390
b. For Surface Disposal Unit (landfill): Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: and Date of analysis:
Distance from Disposal
Unit to Boundary to
Closest Property Line
(meters, check one)
Arsenic
(mg/kg)
Chromium
(mg/kg)
Nickel
(mg/kg)
d > 0 but < 25
30
200
210
> 25 but < 50
34
220
240
39
260
270
— > 50 but < 75
❑ > 75 but < 100
46
300
320
❑ > 100 but < 125
53
360
390
❑ > 125
62
450
420
Result (mg/kg)
5. Nutrient/Micronutrient Determination: Complete the following:
a. Total solids: 19.3 %.
b. Fill in the following table with the results of the latest analyses (i.e., on a dry weight basis) for the following nutrient and
micronutrient parameters:

Laboratory: Waypoint Analytical and Date of analysis: 6/10/21
Parameter
Result
(mg/kg)
Aluminum
48900
Ammonia -Nitrogen
2410
Calcium
4030
Magnesium
3050
Nitrate -Nitrite Nitrogen
127
pH (Standard Unit)
7.1
Phosphorus
4390
Potassium
2140
Sodium
655
Total Kjeldahl Nitrogen
6340
c. Using the results listed in Item II. 5b. above, calculate the sodium adsorption ration (SAR): 0.74
[Note: If residuals contain SAR of 10 or higher, the applicant shall obtain recommendations from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, a
North Carolina Licensed Soil Scientist, or an agronomist, prior to land application of residuals. The recommendations shall
address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a mechanism for maintaining site integrity and
conditions conducive to crop growth].
d. Specify the mineralization rate to be used in calculating the plant available nitrogen (PAN) of the residuals: 30 %. This rate
is a (check one): ® default value, or ❑ actually established.
If the residuals are not generated from the treatment of municipal or domestic wastewater, explain or provide technical
justification as to why the selected default value is appropriate to be applied to these residuals:
e. Calculate the PAN for the residuals (i.e., on a dry weight basis) and fill the results in the following table:
Application Method
First (1st) Year PAN
(mg/kg)
Five -Year
Maximum Adjusted PAN
(mg/kg)
Surface
2511
3216
Injection/Incorporation
3716
4421
6. Other Pollutants Determination: Specify whether or not there are any other pollutants of concern in the residuals and provide
the results of the latest analyses:
7. Pathogen Reduction: Per 15A NCAC 02T.1106, specify how residuals will meet the pathogen reduction requirements:
a. For Distribution/Land Application of Class A or Equivalent:
❑ A fecal coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry solids,
or
❑ A salmonella sp. density that is demonstration to be less than 3 MPN per 4 grams of total dry solids.
AND one of the followings (except for non -biological residuals):
❑ Alternative 1 [15A NCAC 02T.1106(b)(3)(A)] - Time/Temperature Compliance.
▪ Alternative 2 [15A NCAC 02T.1106(b)(3)(B)] - Alkaline Treatment.
▪ Alternative 3 [15A NCAC 02T.1106(b)(3)(C)] - Prior Testing for Enteric Virus/Viable Helminth Ova.
▪ Alternative 4 [15A NCAC 02T.1106(b)(3)(D)] - No Prior Testing for Enteric Virus/Viable Helminth Ova.
❑ Alternative 5 [15A NCAC 02T.1106(b)(3)(E)-(K)] - Process to Further Reduce Pathogens (PFRP).

Specify one: ❑ composting, ❑ heat drying, ❑ heat treatment,
❑ thermophilic aerobic digestion, ❑ beta ray irradiation,
❑ gamma ray irradiation, or ❑ pasteurization.
b. For Land Application of Class B:
® Alternative 1 [15A NCAC 02T.1106(c)(1)] - Fecal Coliform Density Demonstration.
❑ Alternative 2 [15A NCAC 02T.1106(c)(2)] - Process to Significantly Reduce Pathogens (PSRP).
Specify one: ❑ aerobic digestion, ❑ air drying, ❑ anaerobic digestion,
❑ composting, or ❑ lime stabilization.
c. For Surface Disposal:
❑ Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item II. 7a. above.
❑ Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item II. 7b. above.
❑ Exempt - If Daily Cover Alternative is chosen in Item II.8. below [15A NCAC 02T.1106(a)(2)].
U Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
8. Vector Attraction Reduction (VAR): Per 15A NCAC 02T.1107, specify how residuals will meet the VAR requirements:
® Alternative 1 [15A NCAC 02T.1107(a)(1)] - 38% Volatile Solids Reduction (Aerobic/Anaerobic Digestion).
❑ Alternative 2 [15A NCAC 02T.1107(a)(2)] - 40-Day Bench Scale Test (Anaerobic Digestion).
® Alternative 3 [15A NCAC 02T.1107(a)(3)] - 30-Day Bench Scale Test (Aerobic Digestion).
11 Alternative 4 [15A NCAC 02T.1107(a)(4)] - Specific Oxygen Uptake Rate Test (Aerobic Digestion).
• Alternative 5 [15A NCAC 02T.1107(a)(5)] - 14-Day Aerobic Processes.
❑ Alternative 6 [15A NCAC 02T.1107(a)(6)] - Alkaline Stabilization.
❑ Alternative 7 [15A NCAC 02T.1107(a)(7)] - Drying of Stabilized Residuals.
❑ Alternative 8 [15A NCAC 02T.1107(a)(8)] - Drying of Unstabilized Residuals.
❑ Alternative 9 [15A NCAC 02T.1107(a)(9)] - Injection.
❑ Alternative 10 [15A NCAC 02T.1107(a)(10)] - Incorporation.
❑ Alternative for Surface Disposal Units Only - Soil/Other Material Cover [15A NCAC 02T.1107(b)(2)].
❑ Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
Note: For animal processing residuals, only alternatives 9 or 10 may be chosen due to the nuisance conditions that typically occur
when these residuals are applied and left on the land surface.

Standard Operating Procedure and Operation and
Maintenance Plan for the Davie County — Land
Application Program
1. Purpose
a. Ensure the requirements of the Davie County Non -Discharge Permit#
WQ0010583 are met.
2. Personnel
a . The following is a list of personnel in o rder they are to be contacted when
information needs to be shared.
i. EMA Resources inc.
1. David Ackley - Project Manager 419-212-3699
2. Roy Whitaker- Director of Bus.Development./Ops. 336-909-1718
3. Brent Collins - Director of Technical Services 336-399-3646
ii. Davie County
1. David Bone - County Manager 336-753-6001
2. Johnny Lambert- Utilities Director 336-749-6313
3. Tim Smith-ORC Cooleemee WWTP 336-477-5096
3. Operational Functions
a. The operational function of this project it going to involve mixing the
lagoon with a tractor powered Houle pump to achieve a well -mixed and consistent
material that is suitable for land application. It is going to be spread at agronomic
rates that are determined using the Realistic Yield Expectations (RYE) as outlined in
the permit, the amount of other nutrient sources the landowner and operator has
applied, and the residuals nutrient and metal sample that is current for that
monitoring period. It is going to be spread with a liquid applicator that will use
pressure to spread the material in such a way as to achieve a consistent spread pattern.
The material is going to be land applied on fields that have a crop growing on them
that are going to either be grazed or cut for animal feed. Application rates will be
reduced by25% on fields that are primarily used for grazing in accordance with
USDA NRCS 590. Grazed fields will be determined by the farmers and EMA project
managers.
4. Maintenance Schedule
a. EMA Resources Inc. will follow the maintenance schedule as recommended by the
EMA Resources Operations Manager (Mike Collins) for the equipment necessary to
complete the job.
5. Safety Measures

a. Davie County and EMA Resources Inc. believe in operating in a safety conscious
manner and all employees participate in safety training that is designed to help
employees recognize safety issues and take steps to
prevent accidents from occurring. In addition, EMA Resources employees have the
authority to stop operations if they think any aspect of the operation is going to cause
environmental or personal harm.
6. Spill Response Plan
a. In the unlikely event of a spill, the following action shall be taken immediately.
i. Management of Spill Clean-up Activities: The EMA Resources Project
Manager shall take immediate charge and initiate clean-up activities.EMA
Resources labor and equipment is to be utilized. In the event additional labor
and equipment is required, assistance may be requested from Davie County,
The NC Department of Transportation, and other private contractors, as
necessary.
ii. Halt the Source of the Spill: Such as a ruptured container or damaged transport
unit.
iii. Contain the Spill: Form a barrier. Sufficient quantities of straw shall be used
for such purposes. Earthen barriers may be constructed to augment the straw bale
containment area. of the spill. The Operations Manager or the person in charge
on the spill site will be advise the clean-up personnel where to get the straw,
lime, and other items necessary to complete the clean-up operation. le. local
farmers, farm supply centers, nurseries.
iv. Initial Clean -Up: Employ front-end loaders, vacuum equipment, sludge
application vehicles, and/or local septic tank service to remove as much of
the spilled material as possible. Straw and/or sand should be scattered in the
spill area to soak up the remaining material. The straw and sand -soaked
material will be collected and removed to a disposal area approved by
representatives of the state regulatory agency.
v. Final Clean -Up: Employ rotary brush sweeper if needed and apply lime to
the spill area upon the approval of the clean-up efforts by the state regulatory
representative. If the event occurs on private property, the clean-up will be
completed to the- satisfactory of the property owner and state regulatory
representatives. The ultimate goal will be restoring the spill area to its original
condition if possible.
vi. Notification: As soon as possible after the spill occurs, the EMA Resources
Project Manager or designee will notify the Davie County and the EMA
Resources main office. EMA Resources office staff are then responsible for
notifying other key EMA Resources personnel.
vii. Reporting: EMA Resources staff will notify the Winston Salem regional office
of the NCDENR by telephone [phone] as soon as possible, but not

more than 24 hours after, or on the next working day following the occurrence.
The EMA Project Manager shall provide awritten report with 48 hours of the
spill to the EMA Resources Director of Technical Services and Davie County
staff. The report shall list all relative information and actions taken. With the
assistance of EMA Resources personnel, and the Davie County personnel,
a written report will be filed with the Winston Salem regional office within
5 days of the occurrence. For after-hours reporting, the Division's emergency
number shall be called to report all incidences (800) 662- 7956.
7. Inspection Plan
a. Inspection for the land application of residuals will conducted on a minimum
of a weekly basis at the land application site during land application activities. The
inspection frequency is based on the time frame that it is going to take to complete the
project and the number of dry tons to be land applied from this facility. The
inspections will consist of inspecting a current field that is being applied as well as
inspecting random fields that have been completed. Inspections will be conducted by
David Ackley - Project Manager. These inspections will consist of the following:
i. Verifying the application rates for each field that plan on receiving
material.
ii. Checking the calculated loads to ensure the correct amount of residuals
are being land app lied.
iii. Ensure that all manned equipment has a copy of the permit and the
operation and maintenance plan.
iv. Ensure that the field has been flagged properly and that all buffers are being
adhered to.
v. Verify that the proper number of samples of the residuals have beentaken and
that it meets the criteria for land application.
vi. The records will be kept in the EMA Resources project files in the mainoffice.
Copies of all analyses and records will be forwarded to DavieCounty and
kept on file.
vii. EMA Resources and Davie County staff will immediately inform the other
part if any of the following conditions are noted.
1. Any occurrence with the distribution program resulting in the land
application of significant amounts of material that is abnormal in
quantity or characteristics.
2. Any failure of the distribution system that results in the release to
surface waters.
3. Any time that self -monitoring indicates that the facility has gone out
of compliance with the permit.
4. Any process failure that results in the system not adequately treating the
residuals.

5. Any spill or discharge from a vehicle or piping system during
residuals transportation.
6. Any release that requires immediate reporting outside normal business
hours shall be called in by EMA Resources staff to DENR at (800) 66
2-7956. This number is to be called in the event of a release to surface
waters or imminent failure of a storage system when the event occurs
outside of normalbusiness hours.
8. Sampling and Monitoring Plan
a. Sampling for this project consists of sampling the residuals prior to land application
occurring to ensure that the residuals are suitable for land application.
b. The samples will be collected from the storage lagoon that holds the residuals.
c. David Ackley, Brent Collins, or other designee will be responsible for sample collection
for nutrient and metal, TCLP, and fecal coliform.
d. Nutrient, metal and TCLP sample aliquots will be collected randomly and consist
of at least 7 individual aliquots mixed together in order to get the composite sample
for these parameters.
e. The residuals will be sampled annually for TCLP including the RClls.
f. Metal and nutrient parameters will be collected and analyzed based on the requested
dry ton numbers in the permit application.
g. Residuals will be sampled for fecal coliform to demonstrate pathogen requirements have
been met. Seven separate samples will be collected and analyzed.
9. Environmental Impacts
a. The environmental impacts for residuals may be affected by this procedure.
b. This procedure helps assure that land application is conducted in a safe and efficient
manner while ensuring compliance with the laws and regulations and to minimize
exposure, negative environmental impacts, and public relation concerns.

LAND APPLICATION SITE CERTIFICATION
Applicant's name: Davie County
Land application sites currently certified: 363.14 net acres and Total to be certified: 244.10 net acres.
I. LAND APPLICATION SITE INFORMATION (See Instruction B):
Status
Codes
Site/Field ID
Landowner(s)Lessee(s)or
Operator(s)
Net Acres
CountyCrop(s)
p�
Predominant Soil
Series Name b
Mapping Unit
or Rep. Slope'
M
NC-DV-008-04
Roger Spillman
19.49
Davie
Fescue
Cecil
CeB2
M
NC-DV-008-05
Roger Spillman
17.66
Davie
Fescue/Small Grain
Mecklenburg
MrC2
M
NC-DV-008-06
Roger Spillman
19.08
Davie
Fescue/Small Grain
Mecklenburg
MrB2
M
NC-DV-008-07
Roger Spillman
42.9
Davie
Fescue
Mecklenburg
MrB2
M
NC-DV-008-08
Roger Spillman
17.09
Davie
Fescue
Mecklenburg
MrB2
R
NC-DV-008-09
Roger Spillman
23.67
Davie
Fescue
Mecklenburg
MrB2
R
NC-DV-009-01
Thomas Whitaker
6.48
Davie
Fescue
Tomlin
ToB2
R
NC-DV-009-02
Thomas Whitaker
15.75
Davie
Fescue
Tomlin
ToB2
M
NC-DV-012-01
Herbert Dooley
15.43
Davie
Fescue
Clifford
CfB2
M
NC-DV-012-02
Herbert Dooley
9.48
Davie
Fescue
Fairview
FeC2
M
NC-DV-012-03
Herbert Dooley
8.46
Davie
Fescue
Fairview
FeC2
M
NC-DV-012-04
Herbert Dooley
13.44
Davie
Fescue
Fairview
FeC2
M
NC-DV-012-05
Herbert Dooley
16.19
Davie
Fescue
Cordorus
CoA
D
NC-DV-125-05
Edward Leagans
4.80
Davie
Fescue
Mecklenburg
MrB2
D
NC-DV-125-06
Edward Leagans
16.40
Davie
Fescue
Mecklenburg
MrB2
D
NC-DV-125-07
Edward Leagans
6.80
Davie
Fescue
Mecklenburg
MrB2
D
NC-DV-125-08
Edward Leagans
9.50
Davie
Fescue
Mecklenburg
MrB2
D
NC-DV-125-23
Edward Leagans
4.75
Davie
Fescue
Mecklenburg
MrB2
D
NC-DV-125-40
Edward Leagans
4.60
Davie
Fescue
Mecklenburg
MrB2
D
NC-DV-125-41
Edward Leagans
21.70
Davie
Fescue
Mecklenburg
MrB2
D
NC-DV-192-01
Cletus Miller
12.00
Davie
Fescue
Cecil
CeB2
FORM: LASC 06-16
Page 1

LAND APPLICATION SITE CERTIFICATION
D
NC-DV-192-03
Cletus Miller
41.50
Davie
Fescue
Cecil
CeB2
R
NC-RO-001-01
James Taylor
18.99
Rowan
Fescue
Appling
ApB
FORM: LASC 06-16 Page 2

Field Total Acres Applicable Acres
5 19.77 17.66
6 21.94 19.08
7 57.83 42.9
8 27.2 17.09
9 30.68 23.67
SCALE
1 "=660'
PROJECT NO
WQ0010583
DATE:
12-01-21
DRAWN BY:
BC
EMA
-Resources, Inc.
Legend
• Well
A Structure
On Site Dwelling
▪ Off Site Dwelling
— Drain
— Stream
Pond
Buffer
nWet Area
O Field Boundary
Property Boundary
• Rock Outcrop
Davie County
Land Application Program
NC-DV-008
Roger Spillman
FIGURE NO.
2
J
C:\Users\letsg\Documents\ArcGIS\GIS Data\Davie County \ Maps \DV008-(5-9)(2).mxd

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 23, 2020
Mr. Johnny Lambert, Public Utilities Director
Utilities Director
261 Chaffin Street
Mocksville, NC 27028
SUBJECT: Notice of Deficiency — (NOD-2020-PC-0204)
2019 Annual Report Review
Davie County RLAP
Land Application of Class B Residuals
Permit No. WQ0010583
Davie County
Dear Mr. Lambert:
The Division of Water Resources (DWR) acknowledges receipt of the 2019 Annual Report for
the subject permit. A review of this report was conducted by DWR staff person Justin
Henderson. Review of the subject report reflects non-compliance with Permit No. WQ0010583.
The following deficiencies warrant your attention and action:
1) The total dry tons of residuals reportedly land applied exceeded the Maximum Dry Tons
Per Year limit of 315 dry tons as specified in Attachment A. Either ensure all future
operations are compliant with the limits specified in Attachment A or request permit
modification to increase the maximum dry tons for the applicable source facilities.
2) The reported TCLP results for Lead of 6.85 mg/L constitute an exceedance of the
regulatory level of 5 mg/L. Permit Condition IV. (2) states: Residuals that tests or is
classified as a hazardous or toxic waste under 40 CFR Part 261 shall not be used or
disposed under this permit.
3) Failure to report the above described non -compliant analytical results and operations.
Permit Condition IV. (9) states: The Permittee shall report by telephone to the Winston
Salem Office, telephone number [phone], as soon as possible, of the occurrence
or first knowledge of the occurrence of land application of residuals, abnormal in quantity
or characteristic. Furthermore, compliance was indicated on the Annual Land
Certification Form (ACF) submitted in the subject annual report. Please provide a written
response explaining why the above described non-compliance was not reported via
telephone to the Winston Salem office nor acknowledged on Form ACF, as well as what
corrective actions will be implemented to ensure proper non-compliance notifications are
achieved.
D_E
rvahrI-1 CAROLINA
Department el Environmental ouar�
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Along with the above described deficiencies, the following item of concern warrants your
attention:
a) The Pathogen and Vector Attraction Reduction Forms (PVRF), submitted in the subject
report, indicated an annual monitoring period. However, based upon the total amount of
dry tons of residuals that were land applied and per monitoring requirements established
in Attachment A, the PVRF forms should have indicated a quarterly monitoring period.
While analyses conducted to demonstrate pathogen and vector attraction reduction met
the required frequencies, reporting forms should be properly completed to be
representative of the specified monitoring periods in accordance with the monitoring
frequencies established in Attachment A.
b) On Form ACF, submitted in the subject report, you indicated that the facility was not in
operation during the past calendar year. This response conflicts with the included Cover
Letter, and all other Land Application Reporting Forms submitted with the subject annual
report. Please ensure all forms relay consistent and accurate reporting of facility
operations for the specified report period.
Please submit your written response, requested in Item #3 above, within 60-days of receipt of
this Notice. An announced routine compliance inspection is planned to be conducted within the
next 12 months. If you have any questions, please contact Justin Henderson or me at (336) 776-
9800.
Sincerely,
EDocuSigned by:
.—o, T SMJcr
145B49E225C94EA...
Lon Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
encl: Compliance inspection report
cc: Brent Collins, EMA Resources — Electronic Copy
Laserfiche Files — (electronic copy)

Compliance Inspection Report
Permit: WQ0010583 Effective: 07/02/21 Expiration: 04/30/22 Owner : Davie County
SOC: Effective: Expiration: Facility: Davie County RLAP
County: Davie Hwy 801 S
Region: Winston-Salem
Contact Person: Brent M Collins
Directions to Facility:
System Classifications: LA,
Primary ORC: Brent M Collins
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Cooleemee NC 27014
Title: Phone: [phone]
Certification: 27651 Phone: [phone]
NC0024872 Davie County - Cooleemee WWTP
Inspection Date: 12/01/2021
Entry Time 10:25AM Exit Time: 01:30PM
Primary Inspector: Caitlin Caudle Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
▪ Miscellaneous Questions
II Sampling
▪ Storage
(See attachment summary)
▪ Record Keeping
▪ Land Application Site
▪ Transport
▪ Treatment
▪ Pathogen and Vector Attraction
Page 1 of 6

Permit: WQ0010583 Owner - Facility: Davie County
Inspection Date: 12/01/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On December 1, 2021, Division of Water Resources staff Caitlin Caudle conducted a schedule compliance and permitting
inspection. Brent Collins of EMA Resources was present during the majority of the inspection. A review of records, permit
application, and application fields was completed. A separate review of residuals analysis was completed in office the
following the inspection. This review reflects compliance with the subject permit.
The address provided for this facility is for a Citgo, but the driveway for the facility is directly across from the Citgo. A more
accurate location for the facility is 35.8038044, -80.5598631.
The WWTP discharges to the South Yadkin River. Roughly, the flow path is pump station ❑ EQ basin I aeration basin I
clarifiers ❑ digestor ❑ sludge basin.
The following observations were made:
• According to the permit application, a desired dry tonnage of 2,871 dry tons was requested due to cleaning out the
sludge storage basins for repairs. A permit modification was completed in July 2021 to increase the dry tonnage. Ms. Caudle
clarified that the increased dry tonnage is still needed. As of the date of inspection, both sludge storage basins had been
partially emptied to allow for assessment of repairs.
o The current storage capacity of the facility is the 150,000 gallon digestor and part of the 1.5 MG sludge basin. The
smaller sludge basin was also damaged.
o The normal operations dry tonnage is 315 dry tons/year.
• The permit application states that fecal and 38% volatile solids reduction are used for pathogen and vector reduction.
But the facility used 30-day bench scale test this calendar year. Mr. Collins is going to provide an updated Residuals Source
Certification Form to include 30-day bench scale as an option for vector reduction.
• The WSRO phone number listed in the O&M Plan is outdated, Mr. Collins is going to update the phone number and
provide an updated copy of the O&M Plan.
• TCLP is analyzed annually.
• Nutrients and metals samples are collected from the sludge basin. Multiple samples are collected, and a composite
sample is analyzed.
• Multiple fecal samples are collected on one day. This calendar year samples were collected on 4/26/2021, 6/10/2021,
7/6/2021, and 8/10/2021.
• The metals and nutrient analysis provided with the application was not the same as what was provided in the permit
application. Mr. Collins provided the correct analysis, and the results were consistent with what was provided in the
application.
• TCLP samples were collected on 4/26/2021. All parameters were below permit limits.
• Mr. Collins created updated site maps with updated acreage and buffers.
o DV-008, most of these fields appear to be grazed. A 25% reduction must be applied to grazed fields.
❑ 04 listed Bermuda grass on the LASC form, but the FSF listed fescue. Mr. Collins stated that fescue was correct.
Land clearing changed the acreage of this field. The pond is 100ft from the application area. Deborah Spillman is no longer
listed on the parcel that contains this field.
❑ 05 listed row crop as the crop grown, but a rotation of fescue and small grain is a more accurate description of the
crop. The FSF provided lists the PAN for rye grass as 167 lb/ac. According to NC State RYE database, 167 is the PAN rate
for pearl millet hay for this soil series, another type of small grain that can be cut for hay. A previous inspector stated that
using the PAN rate of a similar cools season grass was acceptable as there is not a PAN rate for rye grass in the NC State
RYE database. There is no concern for overapplication. A rock outcropping was located during the inspection. The
approximate location of the rock outcropping is shown on the attached map. Mr. Collins buffered out the outcropping while
Ms. Caudle was on site. Mr. Collins is going to provide an updated site map with the rock outcropping shown.
❑ 06 listed row crop as the crop grown, but a rotation of fescue and small grain is a more accurate description of the
crop. The FSF provided lists the PAN for rye grass as 198 lb/ac. According to NC State RYE database, 198 is the PAN rate
for pearl millet hay for this soil series. There is no concern for over application.
❑ 07 lists PAN on the FSF as 198 lb/ac. The correct PAN rate for fescue hay for the listed soil series is 188 lb/ac.
❑ 09 listed fescue as the crop grown, but a rotation of fescue and small grain is more accurate. The crop listed on the
FSF is teff, which Mr. Collins stated is a small grain similar to millet.
o DV-012
Page 2 of 6

Permit: WQ0010583 Owner - Facility: Davie County
Inspection Date: 12/01/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
• The land owner agreement form is missing for these fields.
• Metals field loading and summary forms were only provided for fields 01 and 02. Mr. Collins stated that they have
only applied on these two fields since they were permitted in 2019. The other four fields have not been applied on yet.
▪ Updated maps have provided more accurate measurements of acreage.
• A drive by of these fields show that no houses or other buildings have been constructed near the property that would
impact the application area. Greenhouses were on the property, which may impact the application area. Greenhouses are
marked on the attached field map.
o RO-001
• All necessary information was provided for this field. All information appears to be correct.
▪ This field was not reviewed as Patrick Mitchell reviewed this field in July 2021.
• A single 6,500 gallon pump truck, truck 606, was running at the time of inspection. Hauling had just started during my
inspection of the application field, hauling records were not reviewed. The truck did have the permit and the spill plan. The
project manager for this facility was not present, the technical specialist was there.
• Soil reports were provided via email on 12/1/2021. Only soil reports for DV-008 were provided as that was the only field
applied on last year.
• DV-008-05 and 06 were reviewed during the site visit. The ground cover in 05 was sparse and may need to be reseeded
There was some evidence that areas of 05 had been drilled. All buffers in 05 and 06 were appropriate, with additional areas
that are not on the application buffered out due to seasonal changes. A wetter area and a cow wallow were buffered out in
06. A sign was located at the access gate for the application area. A rain gauge was put on site while Ms. Caudle was
present.
Page 3 of 6

Permit: WQ0010583 Owner - Facility: Davie County
Inspection Date: 12/01/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Pathogen and Vector Attraction
a. Fecal coliform SM 9221 E (Class A or B)
Class A, all test must be <1000 MPN/dry gram
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
Fecal coliform SM 9222 D (Class B only)
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
b. pH records for alkaline stabilization (Class A)
c. pH records for alkaline stabilization (Class B)
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
Yes No NA NE
El
•
Yes No NA NE
❑ ❑ • ❑
❑ ❑ • ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ▪ ❑ ❑ ❑
❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ •
• ❑ ❑ ❑
▪ ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
•
• ❑ ❑ ❑
•
❑ ❑•❑
❑ ❑ • ❑
❑ ❑ • ❑
Page 4 of 6

Permit: WQ0010583 Owner - Facility: Davie County
Inspection Date: 12/01/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment: Uses both 30-day bench and volatile solids reduction.
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Sampling
Describe sampling:
Is sampling adequate?
Is sampling representative?
Comment:
❑ ❑ • ❑
II ❑ ❑ ❑
Yes No NA NE
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Transport
Yes No NA NE
Is a copy of the permit in the transport vehicle? • ❑ ❑ ❑
Is a copy of the spill control plan in the vehicle? • ❑ ❑ ❑
Is the spill control plan satisfactory? • El El El
Does transport vehicle appear to be maintained? • ❑ ❑ ❑
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 5 of 6

Permit: WQ0010583 Owner - Facility: Davie County
Inspection Date: 12/01/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment:
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ ❑ •
❑ ❑ • ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 6 of 6

XigIEC:V?
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
Date December 15, 2021
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: Lauren Plummer
Application No.: WQ0010583
Facility name: Davie County RLAP
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 as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 12/1/2021
b. Site visit conducted by: Caitlin Caudle
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Brent Collins and their contact information: (336) 399 - 3646
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ❑ N/A
ORC: Roy Whitaker Certificate #: 13283 Backup ORC: Brent Collins Certificate #:27651
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.) Both storage basins are still damaged, with the 3 MG basin unusable. Mr. Collins indicated that the
facility is still working with FEMA to determine the best plan of action to repair or replace the basins.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? n Yes or ® No
5. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or No
7. Is the existing groundwater monitoring program adequate? n Yes ❑ No ® N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
10. Were monitoring wells properly constructed and located? n Yes ❑ No ® N/A
11. Are the monitoring well coordinates correct in BIMS? n Yes n No ® N/A
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: The facility received an NOD for the 2019 annual
report. The violation letter is attached. All deficiencies were addressed by the next annual report.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
FORM: WQROSSR 04-14 Page 1 of 2

14. Check all that apply:
® No compliance issues
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
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
LOA for field DV-012.
This LOA was not included in the permit application and it has not been
received to date.
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
Remove I.2
This permit condition has been satisfied.
Remove 1.3
This permit condition has been satisfied.
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
n Issue upon receipt of needed additional information
n Issue
❑ Deny (Please state reasons: ,} /r DocuSigned by:
6. Signature of report preparer: DocuSigned by: 6461A' (16tbD
�� ?• �SB834968199D49D...
I.)dts
Signature of regional supervisor:
Date:
12 / 15 /2 0 21 `145B49E225C94EA...
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Please see the attached inspection report. Additional items requested from Mr. Collins are also attached.
FORM: WQROSSR 04-14 Page 2 of 2

DWR
Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
WATER QUALITY REGIONAL OPERATIONS SECTION
NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
November 2, 2021
To: WSRO-WQROS: Lon Snider / Jenny Graznak
From: Lauren Plummer, Water Quality Permitting Section - Non -Discharge Branch
Permit Number: WQ0010583 Permit Type: Land Application of Residual Solids (503)
Applicant: Davie County Project Type: Renewal
Owner Type: County Owner in BIMS? Yes
Facility Name: Davie County Class B Residuals Program Facility in BIMS? Yes
Signature Authority: Johnny Lambert Title: Utilities Director
Address: 123 S. Main St., Mocksville, NC 27028 County: Davie
Fee Category: Non -Discharge Major Fee Amount: $0 - Renewal
Comments/Other Information: [e-mail]; [e-mail]
Attached, you will find all information submitted in support of the above -referenced application for your review, comment,
and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed.
❑ Attach an Attachment B for Certification.
❑ Return a completed staff report.
Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer:
DocuSigned by:
8B834968199D49D...
Date: 12/15/2021
FORM: WQROSNDARR 09-15 Page 1 of 1