WQ0041666_Staff Report_20210308

DocuSign Envelope ID: 80DA321 C-8E3D-4536-A518-A25B565FF2A2
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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
March 8, 2021
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: Erick Saunders
Application No.: WQ0041666
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 nondischarae and NPDES permit applications and/or renewals. Pease complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
a. Person contacted: Brent Collins (EMA)
b. Driving directions: See file.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? n Yes n No Z N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or n No
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? n Yes n No ® N/A
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 n No ® N/A
5. Is the residuals management plan adequate? ® Yes or n No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? n Yes n No ® N/A
7. Is the existing groundwater monitoring program adequate? n Yes n No ® N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? n Yes or Z No
9. Is the description of the facilities as written in the existing permit correct? ® Yes or n No
10. Were monitoring wells properly constructed and located? n Yes n No ® N/A
11. Are the monitoring well coordinates correct in BIMS? n Yes n No Z N/A
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or n No
13. Are there any permit changes needed in order to address ongoing BIMS violations? n Yes or ® No
14. Check all that apply:
® No compliance issues n Current enforcement action(s) n Currently under JOC
❑ Notice(s) of violation n Currently under SOC n Currently under moratorium
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes n No n N/A
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
n Yes ®No n N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? n Yes or Z No
FORM: WQROSSR 04-14
Page 1 of 2

DocuSign Envelope ID: 80DA321 C-8E3D-4536-A518-A25B565FF2A2
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
Updated O&M Plan and
Sampling Plan
Was not included in the application package.
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
Z Hold, pending review of draft permit by regional office
n Issue upon receipt of needed additional information
n Issue
n Den
(Please state reasons:
Do uSigned by:
6. Signature of report preparer: —PAM& d'Ltf(, ii,
Signature of regional supervis
Date: March 8, 2021
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(—DocuSigned by:
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IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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A review of the application for modification of the subject permit has been completed. The residuals appear to meet
regulatory limits for metals and TCLP. The proposed source facility is a non -biological WTP and should be exempt
from PFRP and VAR requirements. There was no Fecal Coliform test results provided in the application package.
Also, there was no update Operation & Maintenance Plan or Residuals Sampling Plan provided in the application
package.
Sampling of Fecal Coliform could be conducted prior to the first application or distribution event. Also, a schedule
condition could be included for submittal of an updated O&M Plan including Sampling Plan within 30 days of permit
issuance. Or these items could be requested via an add info request.
FORM: WQROSSR 04-14 Page 2 of 2