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Home My WebLink AboutWQ0041666_2021 Residuals Annual Report Review_20220404ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Erik Blankenship, President EMA Resources, Inc. 755 Yadkinville Road Mocksville, NC 27028 NORTH CAROLINA Environmental Quality April 4, 2022 SUBJECT: Notice of Deficiency (NOD-2022-PC-0037) 2021 Annual Report Review EMA Resources Distribution of Class A Residuals Program Permit No. WQ0041666 Davie County Dear Mr. Blankenship: Division of Water Resources staff person Caitlin Caudle completed a review of the 2021 Residuals Annual Report. This review reflected noncompliance with the subject permit. The following deficiency were noted: 1. Per Permit Condition IV.3 "the residuals from each source generating facility shall be analyzed at the frequency specified in Attachment A." The dry tons produced for Piedmont Triad Regional Water Authority in the 2021 calendar year was 830.97 tons, requiring quarterly sampling according to the most recent Attachment A issued on March 25, 2021. The dry tons applied in the first quarter of the year (January, February, and March) was already at a volume which required quarterly sampling. Samples were not collected in the second (April, May, and June) and third quarter (July, August, and September) of the year. Land application activity did occur in June and September. Failure to sample quarterly is a violation of the subject permit. 2. Per the most recent Attachment A issued on March 10, 2022 Pathogen and Vector Attraction Reduction must be demonstrated annually for Lear Corporation WWTP. According to the Pathogen and Vector Attraction Reduction Form provided in the annual report only Pathogen Reduction was demonstrated, Vector Attraction Reduction was not demonstrated. Footnote 6 was not included from the Attachment A issued on July 16, 2020, which exempted the facility from Vector Attraction Reduction requirements if the Permittee can demonstrate that the residuals are pathogen free. If this footnote was mistakenly excluded from the most recent Attachment A please submit a correction request to the Non -Discharge Permitting Unit within thirty (30) days of receipt of this notice. GDE NORTH C OLI JA ' D. mmm�� .ore�nt o�.i North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Please refer to the enclosed inspection report for additional comments and observations. If you have any questions about this letter please contact Caitlin Caudle at the letterhead address and phone number, or by email at caitlin.caudle(a�ncdenr.gov. Sincerely, ig< DocuSigned by: t- . l . cin.af - "- 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Brent Collins, EMA Resources (electronic copy) Davie County Environmental Health (electronic copy) Laserfiche File WQ0041666 WSRO Electronic Files D_E NORTH CAROLINA gaparMeM of Environment,/quay North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQ0041666 Effective: 03/10/22 Expiration: 01/31/27 Owner : Ema Resources Inc SOC: Effective: Expiration: Facility: EMA Resources Class A Residuals Program 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: 336-751-1441 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: 03/31/2022 Entry Time 11:OOAM Exit Time: 02:30PM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 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 Record Keeping Sampling ▪ Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 Permit: WQ0041666 Owner - Facility: Ema Resources Inc Inspection Date: 03/31/2022 Inspection Type : Annual Report Review Reason for Visit: Routine Inspection Summary: Division of Water Resources staff person Caitlin Caudle completed a review of the 2021 Residuals Annual Report. This reviev reflected noncompliance with the subject permit. The following deficiency was noted: 1. Per Permit Condition IV.3 "the residuals from each source generating facility shall be analyzed at the frequency specified in Attachment A." The dry tons produced for Piedmont Triad Regional Water Authority in the 2021 calendar year was 830.97 tons, requiring quarterly sampling according to the most recent Attachment A issued on March 25, 2021. The dry tons applied in the first quarter of the year (January, February, and March) was already at a volume which required quarterly sampling. Samples were not collected in the second (April, May, and June) and third quarter (July, August, and September) of the year. Land application activity did occur in June and September. Failure to sample quarterly is a violation of the subject permit. 2. Per the most recent Attachment A issued on March 10, 2022 Pathogen and Vector Attraction Reduction must be demonstrated annually for Lear Corporation WWTP. Per the Pathogen and Vector Attraction Reduction Form provided in the annual report only Pathogen Reduction was demonstrated, Vector Attraction Reduction was not demonstrated. Footnote 6 was not included from the previous Attachment A, which exempted the facility from Vector Attraction Reduction requirements if the Permittee can demonstrate that the residuals are pathogen free. If this footnote was mistakenly excluded from the most recent Attachment A please submit a correction request to the Non -Discharge Permitting Unit. Other observations: • The pH for Piedmont Water was less than 6. • Lear WWTP uses aerobic digestion to treat the residuals. • Residuals are being applied to some fields that are included in other permits. Steve Fields is included in WQ0001648 Asheboro Class B. Roger Spillman is included in WQ0010583 Davie RLAP. Page 2 of 4 Permit: WQ0041666 Owner - Facility: Ema Resources Inc Inspection Date: 03/31/2022 Inspection Type : Annual Report Review Reason for Visit: Routine Type Land Application Distribution and Marketing 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 • ❑ ❑ ❑ • O 000 O 000 O 000 O 000 Page 3 of 4 Permit: WQ0041666 Owner - Facility: Ema Resources Inc Inspection Date: 03/31/2022 Inspection Type : Annual Report Review 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: Sampling Describe sampling: Is sampling adequate? Is sampling representative? Comment: Sampling was not completed in the second and third quarter. Yes No NA NE ❑ • ❑ ❑ ❑ • ❑ ❑ Page 4 of 4