WQ0016966_More Information Received_20200210

S Southern
S Soil
B Builders, Inc.
Tuesday, January 28, 2020
Poonam A. Giri, Hydrogeologist
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
958 Hoots Road Roaring River, NC 28669
Zach Key 336-957-7871 • fax [phone]
Email: [e-mail]
Subject: Land Application Permit No. WQ0016966
Additional Information Request Town of Denton RLAP
Dear Ms. Giri:
In a letter dated January 9, 2020 additional information was requested in the review of the Land
Application permit for the Town of Denton WQ0016966. The following documents have been included
with this letter to provide the requested information:
An updated Operation and Maintenance Plan with additional information was requested. This
plan has been updated to meet all the requirements of 15 NAC 02T .1110.; including an updated
sampling plan for the Wastewater and Water Treatment Plants.
The update sampling plans have been changed to reflect that the frequency and procedures of
the samples taken will assure representatives samples are being collected.
Updated field maps with the buffer changes as requested; some of these fields will have a small
change in acreage due to the improved GIs mapping. Some of the previous maps where old hand drawn
maps where acreage calculations were more of an estimate than the measurements that GIs mapping
now provides. We feel this is not a permit modification. No new fields, nor field expansions are being
added; this is just a more accurate measurement of the acreage. Map changes are one of the reason
permit renewals are required as buffers are constantly changing, for example, houses being built, wells
being added or abandoned, and regulation changes, as just happened with surface water (100 feet vs
now 10 meters).

Form LASC has also been updated and included with this letter to reflect the change in acreage
due to the update and more modern maps. There is a less than %0.42 change in the acreage between
the last permit issuance and the new permit renewal request; 128.8 acres in the last permit vs 129.34 in
the newest permit renewal.
Two paper copies of this letter and documents have been included with this package, as well as one
electronic copy has been submitted.
If you have any questions or concerns, please do not hesitate to contact me at my direct line at 336-957-
7871 or at [e-mail]
Sincerely,
Zach Key
Southern Soil Builders, Inc .

Operation and Maintenance Plan
Town of Denton
Permit No. WO0016966
In accordance to the requirements set forth by the North Carolina
Department of Environmental Quality using NCGS 143-215.1 and 143-
215.3(a) based on 15A NCAC 02T .1 10, and land application Permit
WQ0016966 the Town of Denton is implementing this Operation and
Maintenance Plan.
A paper and/or an electronic copy of this Operation and Maintenance
Plan will be available when land applying residuals.
Troy Branch, with the Town of Denton will be responsible for the day to
day operations, maintenance and inspections of the Wastewater
Treatment Plant.
Heather Marie, with the Town of Denton will be responsible for the day to
day operations, maintenance and inspections of the Water Treatment
Plant.
Zach Key with Southern Soil Builders, Inc. will be responsible to make
ensure that land application inspections are completed, and
maintenance of the land application is sufficient.
Safety is the top property; all operations will be following all OSHA and the
NCDOL regulations. All signs and safety warnings will be followed. (i.e
confined space, electrical hazrds)
The project manager of the land application event will make sure a daily
check off is performed at the start of each workday that land application
occurs. This inspection is to prevent any spills, leaks, or run-offs. The daily
check -off will be done by the ORC or the back-up ORC. This check off is
located on the back of all load sheets; this load sheets will be turned in at
the end of each day. This check off will consist of inspection the following
items:
1. Access to the facility will be controlled with a locked gate and
signs to prevent any unauthorized entry into the complex.
2. All pumps and hose will be checked at the start of each day for
leaks or loose fittings.

3. All tanker valves are closed prior to loading and lids are closed
prior to transport.
4. All dump trailers or dump trucks gates are tightly fastened and
do not leak prior to transport.
5. All on road equipment is check as per DOT regulations for any
safety or mechanical hazards or issues.
6. All equipment is secured at the end of each working day to
prevent any tampering or unauthorized use.
The ORC or back up ORC of the land application program will inspect the
field after each land application event to make sure all regulations as
required by the permit are followed. Also, the project manager at the end
of each working day, during a land application event will make sure that
all gates, if present are closed at the WWTP and at the land application
sites.
If any noncompliance is observed, the Winston-Salem Regional Office
Phone: [phone] will be contacted as soon as possible.
All samples shall be taken as described in the attached sampling plan.
All records of these laboratory results as well as the annual report
loading rates, and inspection sheets will be kept on file for a minimum of
five (5) years.
Also, in the unlikely event of a spill or unintended release of residuals,
actions should be immediately taken as outlined in a copy of the spill
control plan attached.
Residuals shall be stored or staged in a manner to prevent runoff of
leachate and other wastewaters generated from residuals storage or
staging.
Class A residuals may be staged at the application site for up to 30 days
for biological residuals and 60 days for non -biological residuals. Storage or
staging that exceeds these limits shall require written approval from the
Division.
Class B residuals shall not be stored or staged at any land application site
without prior written approval from the Division.

The permittee shall perform inspections and maintenance on storage,
distribution, and application facilities.
Class B land application areas shall be clearly marked on each site prior
to and during any land application of residuals.

TOWN OF DENTON, NC
WTP SAMPLING PLAN
WQ0016966
Annually, if a land application event occurs, grab samples are collected from the back -wash
pond. Samples from the pond will be combined to form individual grab samples to be sent to a
laboratory for analysis.
Sampling frequency and procedures need to assure that representative samples are being
collected. Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a sampling event. Sampling shall account for any foreseen fluctuations in
residuals quality and indicate the most limiting times for residuals to meet pathogen and vector
attraction reduction requirements; facilities that land apply multiple times per year but have an annual
sampling frequency, may need to sample during winter months when pathogen reduction is most likely
to be negatively affected by cold temperatures.
Annually, if land application occurs, a composite residual sample will be analyzed, prior to a
land application event for:
Cadmium, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium, Zinc, Aluminum, Ammonia
Nitrogen, Calcium, Nitrate Nitrogen, Magnesium, %total Solids, pH, Phosphorus, Potassium, TKN,
Sodium. From this information, the Plant Available Nitrogen (PAN) and a Sodium Absorption Ratio (SAR)
will be calculated. This sample will collected in a non -breakable container, at least one quart in size. This
sample will be taken from the aeration tank. This sample will be taken by Zach Key of Southern Soil
Builders, Inc.
A Toxicity Characteristics Leaching procedure (TCLP) analysis as well as an ignitability,
corrosivity, and reactivity test shall be done as required by land application Permit WQ0016966. This
sample will require 2 gallons of residuals. This sample will be taken by Zach Key of the Southern Soil
Builders, Inc.

TOWN OF DENTON, NC
WWTP SAMPLING PLAN
WQ0016966
Annually, if a land application event occurs, grab samples are collected from the aerobic
digester. Samples from the digester will be combined to form individual grab samples to be sent to a
laboratory for analysis.
Sampling frequency and procedures need to assure that representative samples are being
collected. Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a sampling event. Sampling shall account for any foreseen fluctuations in
residuals quality and indicate the most limiting times for residuals to meet pathogen and vector
attraction reduction requirements; facilities that land apply multiple times per year but have an annual
sampling frequency, may need to sample during winter months when pathogen reduction is most likely
to be negatively affected by cold temperatures.
A grab sample will be collected and tested for pH monitoring to meet the requirements of
Alternative 6, Alkaline Stabilization; this will be done by Troy Branch of the Town of Denton. This test
will be done prior to every land application event.
Annually, if land application occurs, a composite residual sample will be analyzed, prior to a
land application event for:
Cadmium, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium, Zinc, Aluminum, Ammonia
Nitrogen, Calcium, Nitrate Nitrogen, Magnesium, % total Solids, pH, Phosphorus, Potassium, TKN,
Sodium. From this information, the Plant Available Nitrogen (PAN) and a Sodium Absorption Ratio ($AR)
will be calculated. This sample will collected in a non -breakable container, at least one quart in size. This
sample will be taken from the aeration tank. This sample will be taken by Troy Bran of the Town of
Denton.
A Toxicity Characteristics Leaching procedure (TCLP) analysis as well as an ignitability,
corrosivity, and reactivity test shall be done as required by land application Permit WQ0016966. This
sample will require 2 gallons of residuals. This sample will be taken by Troy Branch of the Town of
Denton.

SPILL CONTROL PLAN- Southern Soil Builders Inc.
Town of Denton - Permit WQ0016966
In the event of a spill, the following should be taken IMMEDITALY.
1. Make sure all personal and bystanders are safe- if not contact emergency
services
2. Halt the source of the spill- overturned truck, leaking valve, ruptured tank.
3. Contain the spill. Use straw bales or earthen barrier to forma dike to
contain the spill.
4. Cleanup. Employ vacuum trucks, dump trucks, and loaders to remove as
much of the spilled material as possible. Use straw to soak -up the
remaining material. Dispose of the some in a landfill.
5. Flush the roadways with water if needed. If the spill occurred on a tillable
area, till the same info the soil and spread lime if necessary. If a spill occurs
on private property, final clean-up should be to the satisfaction of the
owner.
6. Notification. (This should be done as soon as safely possible.)
A. Southern Soil Builders, Inc. [phone]
B. Town of Denton WWTP [phone]

C. NCDEQ-Winston Regional Office [phone]
D. County Emergency Services (Sheriff, Fire Dept.) 911
7. Reporting:
The Permittee shall report by telephone to the Winston Regional Office,
telephone number [phone], as soon as possible, but in no case
more than 24 hours or on the next working day following the occurrence
or first knowledge of the occurrence of any of the following:
A. Surface disposal of residuals abnormal in quantity or characteristic.
B. Any failure of the surface disposal program resulting in a release of
material to surface waters.
C. Any time self -monitoring indicates the facility has gone out of
compliance with its permit limitations.
D. Any process unit failure, due to known or unknown reasons,
rendering the facility incapable of adequate residual treatment
E. Any spill or discharge from a vehicle or piping system during
residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to
surface waters, imminent failure of a storage structure, etc.) outside of
normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone],
or [phone]. Persons reporting such occurrences by telephone shall
also file a written report in letter form within five days following first
knowledge of the occurrence. This report shall outline the actions taken or
proposed to be taken to ensure that the problem does not recur.
8. Spill Prevention. The easiest way to clean a spill is to prevent one.
A. Ensure loading personal watch the vehicle being loaded.
B. Ensure all valves and lids are closed
C. Inspect all seals and replace if necessary.

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02-03
8.75 Acres
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10.07 Acres
02-05 Legend
8.77 Acres Property Line A Residence
Stream Well
— Field Boundary Pond
FieldDrain ® UnusedArea
Buffers
Property Line (50')
Stream (100')
Field Drain (50')
Residence - Wavier (100')
(� Residence - No Waiver (400')
0 Well (100')
Pond (100')
Southern Soil Builders, Sexton Tract - 02-01/02-02/02-03/02-04/02-05
William H., Billy H. & Joel Sexton
1129 Gallimore Rd. Denton, NC
W+E
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Parcel Numbers: 0704200000020, 0 250 500 750 1000 ft
0704200000020E,07042000000203 I I I I I
Davidson, NC
35.6264,-80.0876 North Carolina State Plane, NAD83
Produced: October, 2019
Created by: Joseph Jarvis

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Pond (100')
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Southern Soil Builders, Sexton Tract - JSi/JS2/JS3/JS4A/JS4B N
Billy H. & Joel L. Sexton
1589 NC HWY 47. Denton, NC W E
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Parcel Number: 0704100000008
Davidson, NC
35.6232,-80.0743
0 250 500 750 ft
North Carolina State Plane, NAD83
Produced: October, 2019
Created by: Joseph Jarvis

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