WQ0041666_More Information (Received)_20210324

Program Information
1. Provide a narrative explaining the following:
a. How will the materials be handled and transported from where the residuals were
produced to where it will be treated?
The residuals are treated at the Piedmont Water Plant. See process flow. Once the
residuals have been dewatered, they will be stored at the on -site pad. When the residuals
are ready to be land applied, they will be taken to agricultural sites by their contractor
and land applied at agronomic rates.
b. How will the residuals be processed/treated?
The residuals are not actually processed or treated. See Process flow diagram and
narrative.
c. How will leachate collection be handled?
There is a drain in each section of the storage area that flows to a lift station which then
pumps it back to the thickener.
d. Where will the residuals be stored until processing?
The residuals will be stored at their 9600 square foot uncovered sludge storage
e. How will the final product be distributed?
The residuals will be delivered to local farmers via end dump trailers. Each loadwill be off-
loaded to a high flotation applicator for application on a receiver site (grassland or row
crop).
2. Attach a marketability statement detailing destinations and approximate amounts of the
final products to be distributed.
The residuals have limited major (N, P, K) nutrient value, but they have additional
micronutrients that can be utilized by crops for optimum plant growth. The program will
recruit local farmers to participate in the bulk land application program. They will be advised
as to the limited nutrient value of the residuals, but they will be offered up to one ton of
agriculturallime for soil pH adjustment where soil analysis indicated a need.
Additionally, the timing of the application can be marketed as a water source during drought
conditions. Typical application rates will be from 10-13,000 gallons per acres. The
application rate will be the equivalent to a one third to one half inch rainfall event.
3. Provide either a label that shall be affixed to the bagged processed or an information sheet
that shall be provided to the person who receives the processed residuals. The label or
information sheet shall contain, at a minimum, the following information.
Note: Residuals will be distributed through bulk land application of liquid, managed by
contracted land application firm.

Standard Operating Procedure and Operation and
Maintenance Plan for Piedmont Water Residuals -
EMA Resources Inc. Permit
Land Application Program - WQ0041666
1. Purpose
a. Ensure the requirements of EMA Resources Inc. Permit# W00041666 are met.
2. Personnel
a. The following is a list of personnel in order they are to be contacted when
information needs to be shared.
i. EMA Resources Inc.
1. Landon Whitaker - Project Manager - 336-409-6082
2. Brent Collins -Director of Technical Services - 336-399-3646
3. Mike Collins -Director of Operations - 336-399-6670
ii. Guilford Mills
1. Greg Flory- Executive Director- 336-498-5510
3. Operational Functions
a. The operational function of this project will involve trucking cake residuals to
agronomic sites. 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 cake applicator that will use an auger and paddles
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 by 25% 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 Director of Operations (Mike Collins) for the equipment
necessary to complete the job.
5. Safety Measures
a. Piedmont Water 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 betaken 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 Piedmont Water, 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 advise the clean-up personnel
where to get the straw, lime, and other items necessary to complete the
clean-up operation. ie. 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 restore 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 Piedmont Water 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 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 a written report
within 48 hours of the spill to the EMA Resources Director of Technical
Services and Piedmont Water staff. The report shall list all relative
information and actions taken. With the assistance of EMA Resources
personnel, and Piedmont Water personnel, a written report will be filed
with the Raleigh Regional office within 5 days of the occurrence. For
after-hours reporting, the Division's emergency number shall be called to
report all incidences [phone].
7. Inspection Plan
a. Inspection for the land application of residuals will be 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 amount 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 Landon Whitaker - 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 applied.
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 been
taken and that it meets the criteria for land application.

vi. The records will be kept in the EMA Resources project files in the main
office. Copies of all analyses and records will be forwarded to Piedmont
Water and kept on file.
vii. EMA Resources and Piedmont Water staff will immediately inform the
other party 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 [phone]. 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 normal business hours.
8. Sampling and Monitoring Plan
a. Sampling for this project consists of sampling the residuals prior to land
application occurring in order to ensure that the residuals are suitable for land
application.
b. The samples will be collected from the storage pad that holds the residuals
c. Landon Whitaker, Brent Collins, Mike Collins or other designee will be
responsible for sample collection for nutrient and metal, TCLP, and soil samples.
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. Soil samples will be taken by sampling multiple cores in a random pattern
throughout the field. These cores will be mixed together to get a representative
sample. The samples will be submitted to NCDA for analysis.
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.