WQ0039552_Staff Report_20220419

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
April 19, 2022
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: Cord Anthony
Application No.: WQ0039552
Facility name: Mocksville DCAR
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: 4/14/2022
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
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or n 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.)? ['Yes or ® No
5. Is the residuals management plan adequate? ® Yes or n No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
7. Is the existing groundwater monitoring program adequate? ['Yes ❑ No ® N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? n Yes or ® 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? ['Yes ❑ No ® N/A
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
12. Has a review of all self -monitoring data been conducted (e.g., NDMR, NDAR, GW, ARR)? ® Yes or n No
Please summarize any findings resulting from this review: The annual report reflected compliance with the
subject permit.
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 Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation n Currently under SOC ❑ Currently under moratorium
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes n No n N/A
FORM: WQROSSR 04-14 Page 1 of 2

15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
nYes ®NonN/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. Recommendation:
❑ Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
Issue
n Deny (Please state reasons:
3. Signature of report preparer:
Signature of regional supervisor:
4/19/2022
Date:
,-DocuSianed bv:
) DocuSigned by: 1V,
Caitti
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IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Attached:
• Inspection Report
• Updated O&M Plan (Town of Hillsborough listed in 7.a.vii)
• Signed Permit Renewal Form
FORM: WQROSSR 04-14 Page 2 of 2

Compliance Inspection Report
Permit: WQ0039552 Effective: 11/17/17 Expiration: 10/31/22 Owner : Town of Mocksville
SOC: Effective: Expiration: Facility: Town of Mocksville DCAR
County: Davie 771 Sanford Ave
Region: Winston-Salem
Contact Person: Roy L Whitaker
Directions to Facility:
Mocksville NC 27028
Title: Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/14/2022
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Entry Time 10:OOAM Exit Time: 12:45PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Storage
(See attachment summary)
Page 1 of 3

Permit: WQ0039552 Owner - Facility:Town of Mocksville
Inspection Date: 04/14/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On April 14, 2022, Division of Water Resources staff Caitlin Caudle conducted a routine compliance inspection. Brent Collins
and Roy Whitaker of EMA Resources, Inc. were present during the entire inspection. A review of available records and
storage facilities were reviewed. This review reflected compliance with the subject permit.
The following item of concern was noted:
A. Per Permit Condition V.2 "prior to each bulk residuals land application event, the Permittee or his designee shall inspect
the residuals storage, transport, and application facilities to identify malfunctions, facility deterioration and operator errors ...
The permittee shall maintain an inspection log that includes, at a minimum, the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken...." Mr. Collins stated that a record of field inspections is
not available, but all fields are inspected and flagged with courtesy and required buffers prior to application activities. Moving
forward, please keep a log of all field inspections prior to the commencement of land application activities.
188 dry tons/year is permitted with no intention of increasing or decreasing this amount. Residuals are produced from the
sediment basin and filters. Liquid residuals are land applied at agronomic rates. Based on the residuals analysis results
provided for 1/24/2022, the residuals contain 4.78 Ibs PAN/ton. Two concrete storage basins (275,000 gallons each) are
used for storage, with at least 365 days of storage. Residuals were last hauled at the end of the previous calendar year.
Residuals are likely to be hauled again during the next budget year. Ms. Caudle requested that the field summary form be
provided for this last application event as application fields are included in the Davie County Class B permit.
Mr. Collins stated that all bulk residuals are land applied on fields included in permits managed by EMA because of existing
landowner agreements to accept residuals. If bulk residuals are applied to fields not included in a permit a utilization
agreement will be signed.
Ms. Caudle requested that she be notified during the next application event to review application activities.
Page 2 of 3

Permit: WQ0039552 Owner - Facility:Town of Mocksville
Inspection Date: 04/14/2022 Inspection Type : Compliance Evaluation
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:
Yes No NA NE
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Yes No NA NE
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Page 3 of 3

Professional Engineer's Certification: (Application Involving New or Changes to Treatment or Storage Units)
I, , attest that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I further attest that to the best of my knowledge
the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package
may have been developed by other professionals, inclusion of these materials under my signature and seal signifies that I have reviewed
this material and have judged it to be consistent with the proposed design.
North Carolina Professional Engineer's Seal, Signature, and Date:
Applicant's Certification:
The applicant or any affiliate has not been convicted of an environmental crime, has not abandoned a wastewater facility without proper
closure, does not have an outstanding civil penalty where all appeals have been exhausted or abandoned, are compliant with any active
compliance schedule, and do not have any overdue annual fees under Rule 15A NCAC 02T .0105.
Yes ❑ No, Explain; _
I, Ken Gamble Town Manager
(Signature Authority's Name — PLEASE PRINT) (Title)
attest that this application for Town of Mocksville - WTP
(Facility Name)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that the Division of Water Resources
may not conduct a technical review of this program and approval does not constitute a variance to any rules or statutes unless specifically
granted in the permit. Further, any discharge of residuals to surface waters or the land will result in an immediate enforcement action,
which may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the Division of Water
Resources should a condition of this permit be violated. I also understand that if all required parts of this application are not completed
and that if all required supporting information and attachments are not included, this application package will be returned to me as
incomplete.
Note: In accordance with North Carolina General Statutes § 143-215.6A and § 143-215.6B, any person who knowingly makes any false
statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up to $25,000 per violation.
�e��reih GverIe Gamrbhe
Signature: Kenneth Wesley Gamble (Mar 2022 07:15 EDT)
Mar 25, 2022
Date:
FORM: DCAR 06-16 Page 3 of 3

Town of Mocksville WTP - Permit Renewal -
WQ0039552
Final Audit Report
2022-03-25
Created: 2022-03-24
By: Brent Collins ([e-mail])
Status: Signed
Transaction ID: CBJCHBCAABAA8VRvyozpRxXYDaq_C-6BgKAuyLV3a99U
"Town of Mocksville WTP - Permit Renewal - WQ0039552" Histo
rY
Document created by Brent Collins ([e-mail])
2022-03-24 - 9:27:59 PM GMT- IP address: 206.85.202.26
Document emailed to Kenneth Wesley Gamble ([e-mail]) for signature
2022-03-24 - 9:31:37 PM GMT
Email viewed by Kenneth Wesley Gamble ([e-mail])
2022-03-25 - 11:15:00 AM GMT- IP address: 67.213.52.2
Document e-signed by Kenneth Wesley Gamble ([e-mail])
Signature Date: 2022-03-25 - 11:15:57 AM GMT - Time Source: server- IP address: 67.213.52.2
Agreement completed.
2022-03-25 - 11:15:57 AM GMT
Ea Adobe Sign

Standard Operating Procedure and Operation
and Maintenance Plan for the Town of Mocksville
WTP- Land Application Program
1. Purpose
a. Ensure the requirements of the Town of Mocksville, NC Non -Discharge
Permit#WQ0039552 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. Jeff Thompson — Project Manager 336-477-4078
2. Roy Whitaker — Director of Bus.Dvlpmt./Ops. 336-909-1718
3. Brent Collins — Director of Technical Services 336-399-3646
ii. Town of Mocksville, NC
1. Ken Gamble — Town Manager 336-753-6701
2. Justin Turbyfill — WTP-ORC 336-751-2635 (EnviroLink)
3. Operational Functions
a. The operational function of this project it going to involves transporting the
thickened liquid residuals via tanker trailers to a staging area in the receiver
sites. The liquid residuals will be off-loaded into tractor/pull tank spreader
or pumper truck and land applied in a uniform 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. 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 or row crops for feed
or fiber. 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 EHS&T Director for the equipment necessary to
complete the job.
5. Safety Measures
a. The Town of Mocksville 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 the Town of Mocksville, 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. 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 the Town of
Mocksville and the EMA Resources main office. EMA Resources
office staff is 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 a written report with 48 hours of the spill to the EMA
Resources Director of Technical Services and the Town of Mocksville
staff. The report shall list all relative information and actions taken.
With the assistance of EMA Resources personnel, and the Town of
Mocksville 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 [phone].
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 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 Jeff

Thompson — 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. Ensure proper signage has been posted
vi. Verify that the proper number of samples of the residuals have been
taken and that it meets the criteria for land application.
vii. 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
the Town of Mocksville and kept on file.
viii. EMA Resources and the Town of Mocksville 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 two storage tanks that holds the
thickened residuals
c. Roy Whitaker, Brent Collins, or other designee will be responsible for sample
collection for nutrient and metal and TCLP.
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 RCIIs.
f. Metal and nutrient parameters will be collected and analyzed based on the
requested dry ton numbers in the permit application.
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.