WQ0041666_Staff Report_20240528

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
May 28, 2024
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00041666
Attn: Elton Luona Facility name: EMA DCAR
From: Caitlin Williams
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 m they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
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. 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
4. Is the residuals management plan adequate? ® Yes or ❑ No
5. Are there any setback conflicts for existing treatment, storage, and disposal sites? ❑ Yes or ® No
6. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
7. Has a review of all self -monitoring data been conducted (e.g., AR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: NOV issued for 2023 AR due to exceeding permitted
dry tons for Brown WTP.
8. Has a review of compliance history been completed (CEI's)? ® Yes or ❑ No
9. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
10. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
® Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) See
NOV-2024-PC-0303 in LF.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
11. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
FORM: WQROSSR 04-14 Page 1 of 2

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
❑ Deny s6tibIge„reasons: )
3. Signature of report preparer:
Signature of regional supervisor:
Date: 5/28/2024
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See attached O&M Plan and email requesting corrected mineralization rates for all WTPs on Attachment A.
Staff requested the O&M Plan be updated to include non-compliance notification to the Winston Salem Regional
Office as the permit is located in WSRO. Should the 5-day report also be sent to WSRO or just to RRO?
FORM: WQROSSR 04-14 Page 2 of 2

Williams, Caitlin
From:
brent.collins emaresourcesinc.com <[e-mail]>
Sent:
Sunday, May 26, 2024 8:32 AM
To:
Williams, Caitlin
Subject:
[External] RE: WQ0041666 Mod
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Caitlin,
Per our conversation concerning the mineralization rate for the Brown WTP modification, we would like to request
that the mineralization rate be changed to 0.1 to be in line with the other Water Treatment Plant residuals for all of
the other Class A WTP permits that we manage.
Thankyou
Brent Collins
Director of Technical Services
EMA Resources Inc.
From: Williams, Caitlin <[e-mail]>
Sent: Friday, May 24, 2024 10:07 AM
To: brent.collins emaresourcesinc.com <[e-mail]>
Subject: WQ0041666 Mod
Hey Brent,
I noted a few things when going through the permit mod application.
The permitted mineralization rate in the most recent Att. A is 0.4 for Brown WTP, the others also a have a permitted
MR. Should this be corrected during this permit mod? You used 0.10 in the application.
Can you add WSRO to the O&M plan on page 21 in section vii? RRO is listed, but I would like to see WSRO as well.
The emergency response number has also been changed to 800-858-0368.
If you have any questions, give me a call.
Thanks,
Caitlin Williams, LSS (she/her)
Environmental Program Consultant, Division of Water Resources
North Carolina Department of Environmental Quality
Office: (336) 776-96991 Cell: [phone]
[e-mail]

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Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Standard Operating Procedure and Operation
and Maintenance Plan for Brown WTP Residuals -
EMA Resources Inc. Permit
Land Application Program - WQ0041666
1. Purpose
a. Ensure the requirements of EMA Resources Inc. Permit# WQ0041666 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. David Ackley —Project Manager — 419-212-3699
2. Brent Collins — Director of Technical Services — 336-399-3646
3. Roy Whitaker —Director or Marketing — 336-909-1718
4. Mike Collins — Director of Operations — 336-399-6670
ii. City of Durham
1. Tom Lucas — WTP ORC — 919-560-4362 x35267
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. City of Durham -Brown WTP 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 City of Durham, 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 the City of Durham
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 Raleigh 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. EMA Resources will also notify the Winston
Salem Regional office of NCDENR by telephone [phone]. The
EMA Project Manager shall provide a written report within 48 hours
of the spill to the EMA Resources Director of Technical Services and
City of Durham staff. The report shall list all relative information and
actions taken. With the assistance of EMA Resources personnel, and
City of Durham 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 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 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.
vii. EMA Resources and City of Durham 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. David Ackley, Brent Collins, Roy Whitaker 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.
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.