WQ0037135_NOD-2020-PC-0193_20200413

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Mr. Dennis Key, President
Southern Soil Builders, Inc.
958 Hoots Road
Roaring River, NC 28669-9148
NORTH CAROLINA
Environmental Quality
April 13, 2020
Subject: Notice of Deficiency — (NOD-2020-PC-0193)
2019 Annual Report Review
Southern Soil Builders
Land Application of Class B Residuals (Non -Dedicated)
Permit No. WQ0037135
Wilkes County
Dear Mr. Key:
The Division of Water Resources (DWR) acknowledges receipt of your 2019 Annual Report for
the subject permit. A review of this report was conducted by DWR staff person Justin Henderson.
Review of the subject report reflects non-compliance with Permit No. WQ0037135. The following
deficiencies require your attention:
1) The total dry tons of residuals reportedly land applied from source facility Yadkin Valley
Sewer Authority WWTP, exceeded the Maximum Dry Tons Per Year limit of 100 dry tons
as specified in Attachment A. Either ensure all future operations are compliant with the
limits specified in Attachment A or request permit modification to increase the maximum
dry tons for the applicable source facilities.
2) The subject annual report was not submitted in the order specified by the Instructions for
Residuals Application Annual Reporting Forms, in accordance with Permit Condition IV.
(8.), which states: The annual report shall meet the requirements described in the
Instructions for Residuals Application ReportingForms.
orms.
3) The subject annual report did not clearly demonstrate compliance with the Vector
Attraction Reduction requirements associated with the indicated method, for the following
source facilities: Baxter Healthcare Corporation, YVSA WWTP, Thurman Street WWTP,
Rutherfordton WWTP. While the reported method results suggested compliance, the
following information was omitted: calculations, Total Solids & Volatile Solids volumes
and percentages, and documentation that the analysis was conducted for 30-days. Submit
the supporting documentation described above for the listed source facilities.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
nahr�cA�o�.�Ha �
De _War r,o^ma^�ru�•r` r 336.776.9800

4) TCLP results submitted for source facility Yadkin Valley Sewer Authority WWTP were
incomplete. The following parameter results were omitted from this report: Arsenic,
Barium, Cadmium, Chlordane, Chromium, Cresol, Endrin, Heptachlor (and its epoxide),
Hexachlorobenzene, Hexachlorobutadiene, Hexachloroethane, Lead, Lindane, Mercury,
Methoxychlor, Nitrobenzene, Pentachlorophenol, Pyridine, Selenium, Silver, Toxaphene,
2,4,5-Trichlorophenol, and 2,4,6-Trichlorophenol. Permit Condition IV. (2.) states that
residuals for each source generating facility shall be analyzed to demonstrate they are non-
hazardous under the Resource Conservation and Recovery Act (RCRA). Annual TCLP
analysis for the subject facility is required in accordance with Attachment A. Submission
of TCLP sampling results in the subject report is required per the Instructions for Residuals
Application Reporting Forms. Submit the complete TCLP analysis results for source
facility Yadkin Valley Sewer Authority WWTP.
Along with the above described deficiencies, the following items of concern also require your
attention:
A) Standard Soil Fertility Analysis (SSFA) results for application site NC-WK-BP-02
indicated that copper accumulation has reached levels of greater than 2000. Copper
accumulation in soils approaching levels greater than 2000 could be detrimental to crop
production. Provided proper sample collection was conducted and that copper
accumulation results are accurate, consideration should be given to removing this site from
operations to prevent crop toxicity impacts.
B) Lime recommendations were present in the SSFA results associated with the following
fields: NC-WK-SK-03, NC-WK-SK-04, NC-RU-FLB-04, NC-RU-FLC-01. While there
were no reported residuals application events conducted at these sites during 2019, it is
unclear as to if lime application occurred at these sites to achieve proper pH maintenance
per the specified recommendations. Please indicate if and at what rate lime application has
occurred at the above listed sites.
Please submit the information requested herein to this office within 60-days of receipt of this
Notice. An announced routine compliance inspection is planned to be scheduled within the next
12 months. If you have any questions, please contact Mr. Justin Henderson or me at (336) 776-
9800.
Sincerely,
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u SiTgnedl�by:
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LonSnider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
cc: Laserfiche Files — (electronic copies)

Compliance Inspection Report
Permit: WQ0037135 Effective: 02/14/20 Expiration: 09/30/24 Owner : Southern Soil Builders Inc
SOC: Effective: Expiration: Facility: Southern Soil Builders RLAP
County: Wilkes 397 Riverside Dr
Region: Winston-Salem
Forest City NC 28043
Contact Person: Dennis Key Title: President Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Zach D Key Certification: 27660 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0020761 Town of North Wilkesboro - Thurman Street WWTP
NC0006564 Baxter Healthcare Corporation - Baxter Healthcare Corporation
NC0025909 Town of Rutherfordton - Rutherfordton WWTP
NC0021181 City of Belmont - Belmont WWTP
NC0020664 Town of Spindale - Spindale WWTP
NC0020567 Yadkin Valley Sewer Authority - Yadkin Valley Sewer Authority WWTP
NC0025984 Town of Forest City - Forest City WWTP
Inspection Date: 03/27/2020 Entry Time 08:OOAM Exit Time: 02:OOPM
Primary Inspector: Justin L Henderson Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0037135 Owner - Facility: Southern Soil Builders Inc
Inspection Date: 03/27/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) acknowledges receipt of your 2019 Annual Report for the subject permit. A review of
this report was conducted by DWR staff person Justin Henderson. Review of the subject report reflects non-compliance with
Permit No. WQOThe Division of Water Resources (DWR) acknowledges receipt of your 2019 Annual Report for the subject
permit. A review of this report was conducted by DWR staff person Justin Henderson. Review of the subject report reflects
non-compliance with Permit No. WQ0037135. The following deficiencies require your attention:
1) The total dry tons of residuals reportedly land applied from source facility Yadkin Valley Sewer Authority WWTP,
exceeded the Maximum Dry Tons Per Year limit of 100 dry tons as specified in Attachment A. Either ensure all future
operations are compliant with the limits specified in Attachment A or request permit modification to increase the maximum
dry tons for the applicable source facilities.
2) The subject annual report was not submitted in the order specified by the Instructions for Residuals Application Annual
Reporting Forms, in accordance with Permit Condition IV. (8.), which states: The annual report shall meet the requirements
described in the Instructions for Residuals Application Reporting Forms.
3) The subject annual report did not clearly demonstrate compliance with the Vector Attraction Reduction requirements
associated with the indicated method, for the following source facilities: Baxter Healthcare Corporation, YVSA WWTP,
Thurman Street WWTP, Rutherfordton WWTP. While the reported method results suggested compliance, the following
information was omitted: calculations, Total Solids & Volatile Solids volumes and percentages, and documentation that the
analysis was conducted for 30-days. Submit the supporting documentation described above for the listed source facilities.
4) TCLP results submitted for source facility Yadkin Valley Sewer Authority WWTP were incomplete. The following
parameter results were omitted from this report: Arsenic, Barium, Cadmium, Chlordane, Chromium, Cresol, Endrin,
Heptachlor (and its epoxide), Hexachlorobenzene, Hexachlorobutadiene, Hexachloroethane, Lead, Lindane, Mercury,
Methoxychlor, Nitrobenzene, Pentachlorophenol, Pyridine, Selenium, Silver, Toxaphene, 2,4,5-Trichlorophenol, and
2,4,6-Trichlorophenol. Permit Condition IV. (2.) states that residuals for each source generating facility shall be analyzed to
demonstrate they are non -hazardous under the Resource Conservation and Recovery Act (RCRA). Annual TCLP analysis for
the subject facility is required in accordance with Attachment A. Submission of TCLP sampling results in the subject report
is required per the Instructions for Residuals Application Reporting Forms. Submit the complete TCLP analysis results for
source facility Yadkin Valley Sewer Authority WWTP.
Along with the above described deficiencies, the following items of concern also require your attention:
A) Standard Soil Fertility Analysis (SSFA) results for application site NC-WK-BP-02 indicated that copper accumulation
has reached levels of greater than 2000. Copper accumulation in soils approaching levels greater than 2000 could be
detrimental to crop production. Provided proper sample collection was conducted and that copper accumulation results are
accurate, consideration should be given to removing this site from operations to prevent crop toxicity impacts.
B) Lime recommendations were present in the SSFA results associated with the following fields: NC-WK-SK-03,
NC-WK-SK-04, NC-RU-FLB-04, NC-RU-FLC-01. While there were no reported residuals application events conducted at
these sites during 2019, it is unclear as to if lime application occurred at these sites to achieve proper pH maintenance per
the specified recommendations. Please indicate if and at what rate lime application has occurred at the above listed sites.
Please submit the information requested herein to this office within 10-days of receipt of this Notice. An announced routine
compliance inspection is planned to be scheduled within the next 12 months. If you have any questions, please contact Mr.
Justin Henderson or me at [phone].
037135. The following deficiencies require your attention:
Page 2 of 3

Permit: WQ0037135 Owner - Facility: Southern Soil Builders Inc
Inspection Date: 03/27/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Page 3 of 3