WQ0005981_Additional Information Response_20210510

SOIL PLUS
May 10, 2021
NCDEQ-DWR
Non -Discharge Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attention: Lauren Raup-Plummer
Reference: Additional Information Request Dated April 26, 2021
Town of Louisburg RLAP (WQ0005981)
Ms. Raup-Plummer:
Soil Plus, LLC (Soil Plus) received an Additional Information Request dated April 26, 2021
regarding the permit renewal application submitted on behalf of the Town of Louisburg.
Soil Plus is providing responses to the requested information in the order in which it was
received below:
A.1. Within the Item IIL1 Operator In Responsible Charge (ORC) table, Richard Collins
(29306) is listed as the ORC with Jimmy Ellington (23114) listed as the back-up ORC. Our
records indicate that Mr. Collins's association with the Town of Louisburg RLAP ended on
November 22, 2019. Please provide an updated table with the current ORC identified.
• The RLAP has been revised to show Stephen Gilliam (1007907) as the ORC
A.2. Information provided under Item III.2. (a-c) includes the residuals quantity to be
certified, the PAN, the land usage, and the minimum acreage. The Attachment A
certification dated August 13, 2018 increased the residuals limit for the Louisburg WWTP
from 180 to 318 dry tons per year. Additionally, within the submitted documents it appears
that a portion of the land application area has changed ownership (see Comment G.1.
below), and it is unclear if the new owner intends to develop the property. This would
potentially impact Fields 6, 7A, and 7B (9.75 acres). Have additional land application sites
been considered? Please provide additional information.
• The new owner has no plans to develop the property. Should there become a need
for additional land application sites, the Town of Louisburg is also a source on
Granville Farms, Inc. Permit WQ0000838.
E.1. Within the Operation and Maintenance (O&M) Plan, the Spill and Emergency
Response Program indicates that the spills are to be reported to the Town of Louisburg
P.O. Box 1396 officials, and state and local agencies; however, emergency contact information was not
Oxford, NC 27565 provided. Please update the O&M Plan to include contact information in accordance with
15A NCAC 02T .1110.
t [phone]
f [phone]
• The O&M Plan has been revised to include a Spill Response/Clean Up Plan with
emergency contact information.

G.1 For the Land Owner Agreement (LOA) for Fields P-6, P-7A, and P-713 the deed book
lists "528 Collins Mill Rd, LLC"; however, the address provided is for Carmen R.
Parkhurst and no contact information was provided for this business. Is Mr. Greg Schrider
affiliated with the 528 Collins Mill Rd, LLC? We were unable to find this business in the
North Carolina business registration database to confirm that Mr. Schrider has signature
authority for this property.
• Mr. Greg Schrider is the Manager of 528 Collins Mill Rd, LLC. The LLC is based
in Pennsylvania. This property was in the process of being sold during the permit
renewal and that is why the LOA had Mr. Parkhurst's information on it. At the
time I sent the form, Mr. Parkhurst still owned the property. Mr. Schrider uses the
property for his personal enjoyment, particularly hunting, and has no intentions on
developing the property.
H.1. Please provide updated site maps for Fields P-1, P-2, P-313, P-3T, P-7, P-7A, and P-
7B. The provided map is low resolution, and the labels are illegible.
• Please see the enclosed updated maps. Due to more recent/accurate aerials and the
reduction of the Surface Water setback from 100ft to 32.8ft the acreage has been
increased for all but one of the fields. The RLAP and LASCA forms have been
revised to show the updated acreages.
Soil Plus is responsible for completing this permit renewal/additional information request
for the Town of Louisburg. If after reviewing the enclosed information you have any
questions or require further information, please do not hesitate to contact me.
Respectfully,
.U'V L) NV, AtJ2
Drew Matthews, Soil Plus

ATTACHMENT 1
REVISED RI.AP

State of North Carolina
DWR
Department of Environment and Natural Resources
Division of Water Resources
Division of Water Resources 15A NCAC 02T .1100 — RESIDUALS LAND APPLICATION PROGRAM
FORM: RLAP 03-15
L APPLICANT INFORMATION:
1. Applicant's name: Town of Louisburg
Applicant type: ❑ Individual ❑ Corporation ❑ General Partnership ❑ Privately -Owned Public Utility
❑ Federal ❑ State ® Municipal ❑ County
Signature authority's name per 15A NCAC 02T .0106: Karl Pernell Title: MUor
Applicant's mailing address: 110 West Nash Street
City: Louisburg State: NC Zip: 27549-
Telephone number: 9( 19) 496-4145 Email Address:
2. Consultant's name: Drew Matthews License Number (for P.E.): _
Affiliation: ❑ On Staff ® Retained (Firm: Soil Plus, LLC)
Consultant's mailing address: PO Box 1396
City: Oxford State: NC Zip: 27565-
Telephone number: [phone] Email Address: dmatthewsksoilplus.net
3. Agronomist's name: License Number:
Affiliation: ❑ N/A ❑ On Staff ❑ Retained (Firm: )
Agronomist's mailing address:
City: State: Zip: -
Telephone number: (_) _- Email Address:
4. Soil Scientist's name: License Number:
Affiliation: ❑ N/A ❑ On Staff ❑ Retained (Firm: )
Soil Scientist's mailing address:
City: State: Zip: -
Telephone number: (_) _- Email Address:
5. Fee submitted: $0.00 (See Instruction B)
IL PERMIT INFORMATION:
1. Application is for (check all that apply): ❑ new, ❑ modified, ® renewed permit
2. If this application is being submitted to renew or modify an existing permit, provide the following:
Permit number: W00005981
Date of most -recently issued permit: August 31, 2016
Date of most -recently certified Attachment A (if different than the permit): August 13, 2018
Date of most -recently certified Attachment B (if different than the permit):
FORM: RLAP 03-15 Page 1 of 5

III. RESIDUALS LAND APPLICATION PROGRAM INFORMATION:
1. Residuals Processing Facility's physical address: Wastewater Road
City: Louisburg State: NC Zip: 27549-
Coordinates: Latitude: 36' 5' 25.9" Longitude: 78. 17' 20.1"
Datum: NAD 83 Level of accuracy: Sub -Meter
Method of measurement: GIS
County where residuals land application program is headquartered: Franklin
1. List the Operator In Responsible Charge (ORC) and all Back -Up ORCs for the residuals land application program, their
certification numbers, and their affiliations in the following table:
Designation
Name
Affiliation
Certification Number
ORC
Stephen Gilliam
Town of Louisburg
1007907
Back -Up ORC
Jimmy Ellington
Town of Louisburg
23114
Additional Back -Up
ORCs
(if applicable)
If an ORC and at least one Back -Up ORC are not currently designated for this residuals land application program, provide
the candidates' names, affiliations, and an estimated time schedule for each candidate's completion of the required training
school and certification test:
2. Complete the following tables regarding management of the residuals land application program:
a. Plant Available Nitrogen Summary: Determine the maximum plant available nitrogen (PAN) generated by all residuals
source -generating facilities as currently certified and proposed for certification with this application and list the results in
the following table:
Maximum amount of residuals to be certified: 318 dry tons per year.
PAN
Pounds of PAN per Dry Ton
(Weighted Average)
Pounds of PAN per Year
Surface
Incorporation
or Injection
Surface
Incorporation
or Injection
First -Year
33.13
49.63
10,537
15,784
Five -Year Maximum Adjusted
46.69
58.94
14,848
18,744
b. Land Application Site Use Summary: Summarize information regarding the land application sites as currently certified
and proposed for certification with this application:
Category
Use
Acres
Comments
Crops
Forest or Plantation
Row Crops
Hay
100.73
Pasture
100.73
Total:
100.73
Methods
Surface
100.73
Incorporation or Injection
Total:
100.73
FORM: RLAP 03-15 Page 2 of 4

c. Residuals Land Application Summary: Determine the minimum acreage required to land apply the residuals as currently
certified and proposed for certification assuming the scenarios listed in the following table:
Assumed
Application Rate
(lbs PAN/ac yr)
Acres Required Using
First -Year PAN Concentrations
Acres Required Using
Five -Year Maximum Adjusted PAN
Concentrations
Surface
Incorporation or
Injection
Surface
Incorporation or
Injection
50
210.73
315.67
296.96
374.88
100
105.37
157.84
148.48
187.44
150
70.24
105.22
98.99
124.96
200
52.68
78.92
74.24
93.72
6. If applicable, provide a plan and a schedule to resolve any known issues that would prevent land application of the proposed
residuals due to the violation of North Carolina Administrative Code (e.g. not enough storage, not enough land, vector
reduction practices not in place, etc.): The Town of Louisburg is also listed as a generating source under Granville Farms
Class B Land Application Permit (W00000838). This Land Application Permit will be used in conjunction with the
Granville Farms permit.
7. Specify type of residuals program (See Instruction F): ® Non -dedicated ❑ Dedicated
If Dedicated, specify the following (check all that apply):
❑ Residuals program contains any land application site(s) that receives residuals at rates or frequencies greater than
agronomic rates, explain;_
❑ Residuals program contains any land application site(s) that is used primarily for residuals disposal, and agricultural crop
production is of secondary importance, explain;
❑ Residuals program contains any land application site(s) that receives residuals through fixed irrigation facilities or
irrigation facilities fed through a fixed supply system, explain;
IV. RESIDUALS SOURCE INFORMATION: (Required for all new, renewed, or modified residuals source)
Complete and submit the following Residuals Source Certification and all associated documentation.
Residuals Source
Certification
V. LAND APPLICATION SITE INFORMATION: (Required for all new, renewed, or modified land application site)
Complete and submit the following Land Applications Site Certification and all associated documentation.
tl
Land Application Site
Certification. doc
FORM: RLAP 03-15 Page 3 of 4

Applicant's Certification (signing authority must he in compliance with 1.5A NCAC 02T .0106):
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 H No, Explain;
I, Karl Pernell Mayor
(Signature Authority's Name — PLEASE PRINT) (Title)
attest that this application for Town of Louisburg
(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.
Signature: �� •�L� Date:
.)L--2-2/
FORM: RLAP 03-15 Page 4 of 4

ATTACHMENT 2
REVISED O&M PLAN

TOWN OF LOUISBURG
OPERATION AND MAINTENANCE PLAN
LAND APPLICATION OF CLASS B RESIDUAL BIOSIOLIDS
WQ#0005981
Revised January 2021

1.0 ANALYTICAL REQUIREMENTS
Prior to the hauling and land application event being schedule the generator must provide analytical results
documenting that all parameters listed in Condition IV. 2 — 4 and at the frequency listed in most recent copy of this
permit. The Town of Louisburg will collect the sample prior to land application and will be done in the following
manner:
Four factors that may ultimately affect the integrity of reported data include: 1) obtaining a representative sample, 2)
preventing contamination of the sample, 3) providing legal documentation of the sampling event, and 4) protecting
the sample from chemical, physical or biological change prior to analysis.
A sample will be collected according to the schedule provided in the most recent copy of the Attachment A of this
permit and prior to land application one composite sample should be pulled from a designated location from the
generating source. The Town of Louisburg has identified Meritech, Inc. out of Reidsville, NC to be used as the
Certified Laboratory. The composite sample should be analyzed for:
• % Solids,
• Nitrogen Series (TKN, Ammonia, Nitrate, Nitrite, and Organic Nitrogen),
• Phosphorus,
• Potassium,
• Sulfur,
• Calcium,
• Magnesium,
• Sodium,
• Iron,
• Aluminum,
• Manganese,
• Copper,
• Zinc,
• and Remaining 503 Metals (i.e. Arsenic, Cadmium, Chromium, Mercury, Molybdenum, Lead, Nickel,
Selenium)
Approximately 2 quarts of residual should be collected. The sample containers should be clean and sterile. They
should also be labeled so that they are easily identifiable in the lab. The samples should be pulled using the method
listed below:
❖ Collect one sample from each digester(s) from which the material will be land applied using a "swing sampler"
o The swing sampler must be used with a sterile, plastic 960 ml container
❖ Combine each sample in a stainless steel bucket
❖ Mix thoroughly using a fiberglass rod
❖ Collect each sample from the top of the access point at each digester. This access point is obtained by climbing
the installed ladder on the side of the digester.
Once the sample is pulled, it should be placed in medium size cooler packed with ice. The sample should be collected
with an enough time so that it can be delivered to the laboratory.
Revised 01 /21 OTown of Louisburg Operation and Maintenance Plan

Once per calendar year a sample should be collected and submitted to Meritech, Inc. of Reidsville, North Carolina.
This sample should be analyzed for:
• Full TCLP
• Ignitability, Corrositivity, and Reactivity
• Requires 5 Liters (In Opac Glass Bottles)
A third should be submitted to Meritech, Inc. for a 30-Day Scale Bench test and Fecal Colifom Density Test. The
30-Day Scale Bench Test also requires 1 quart of "clear" water from the Clarifier for Dilution if necessary. This
sample would be analyzed for:
• 30-Day Scale Bench Test (4 Quarts of Residuals and 1 Quart of Clarifier water)
• Fecal Coliform Density Test (seven pint samples)
The contact information for the labs is:
Mailing Address
Meritech, Inc.
642 Tamco Road
Reidsville, NC 27320
[phone] (phone)
[phone] (fax)
Sampling frequency will be conducted in accordance with the Table listed in the most recent Attachment A of this
permit. The sample will be collected by a representative of Soil Plus, LLC. For further information please contact:
Drew Matthews
PO Box 1396
Oxford, NC 27565
252-883-9301
Revised 01 /21 OTown of Louisburg Operation and Maintenance Plan

2.0 BIOSOLIDS REMOVAL, TRANSPORT, AND APPLICATION
Biosolids will be transported from the generators to suitable, permitted land application sites. Transport equipment
will be inspected, licensed and appropriately marked, as required, for the purpose of transporting biosolids. Biosolids
will be delivered to the application sites between sunrise to sunset.
Both liquid and dewatered biosolids distribution on the land application sites will be uniform throughout the
application area. To ensure adequate control of the application rate for each site, the equipment used for spreading
the sludge will be calibrated by measuring the amount handled on a known square footage. While the rate of discharge
from the application vehicle is fixed, the speed of the equipment can be adjusted to maintain the flow rate needed to
achieve specific application rates. Spreading operations will be discontinued during periods of inclement weather and
will not be resumed until sufficient drying of the fields has occurred. This allows equipment access without causing
excessive soil compaction or rutting. To prevent adherence of the biosolids, transport vehicles will be equipped with
rear mud flaps, thereby preventing biosolids from being tracked onto roadways. Biosolids adhering to the mud flap
will be scraped off in the field before the truck returns to the roadway. Examples of our application tracking and
summary form/reports can be provided upon request.
3.0 SITE OPERATION
Biosolids will be surface applied at the properly -calculated agronomic rate and in strict accordance with any state and
federal regulations for the land application of the biosolids. Buffer zone distances will be observed in accordance with
applicable state and federal regulations. Buffer zones will be flagged and no biosolids will be applied within those
areas. The most restrictive buffer will apply in combined situations. Operational provisions will be taken to prevent
soil loss through erosion. Provisions will include contour application and avoidance of areas where surface drainage
patterns result in concentrated flow of runoff from rainfall. In accordance with sound, industry standard agronomic
practice, areas which are unseasonably wet (and would produce rutting or damage to the field) will not be utilized for
biosolids application operations during those periods. Operations will be discontinued when soils are saturated and
will not be resumed until the field has sufficient dried. The amount of biosolids applied will not exceed the hydraulic
capacity of the soil at the time of each application. If a subsequent pass across a field is necessary to achieve the
desired application rate, sufficient drying time will be allowed between passes.
4.0 PROJECT CONTROL
To ensure biosolids are continuously applied at the correct application rate and in a manner consistent with the
Operations Plan, a Field Manager (provided by the contracted land application company) will be in direct charge of
the field operations, controlling the amount of biosolids delivered to each field, and conducting daily field inspections.
Field inspections will include ensuring that flags are in place, biosolids are applied uniformly at the designated
application rate, setbacks are observed, trucks are unloading at best location, trucks are not driving over biosolids,
trucks are cleaned before leaving the field and the land application equipment is maintained in working condition.
5.0 TRANSPORTATION SYSTEM ROUTING
Per the specifications, transportation vehicles will be equipped with GPS devices that will guide drivers to the land
application sites. Transportation routes will follow primary highways and avoid residential areas where possible.
Designated routes are followed unless a detour is specified. In the event of a detour route, it shall be taken as specified
by the detour authority. There shall be no unscheduled stops when loaded. Transportation vehicles will be inspected,
licensed and appropriately marked as required with identification numbers for the purpose of this contract. All units
will be equipped with spill guards and full mud flaps. This will prevent the biosolids from adhering to the tires and
undercarriage of the transport vehicle, thereby preventing biosolids from being tracked onto roadways. Biosolids
adhering to the mud flap will be scraped off in the field before the truck returns to the roadway. All federal OSHA
Revised 01 /21 OTown of Louisburg Operation and Maintenance Plan

and DOT laws and regulations are complied with for the protection of our clients, the community and our drivers.
Examples of vehicle and driver transportation logs and inspection forms can be provided upon request.
6.0 DEWATERED BIOSOLIDS
Dewatered biosolids will be transported in standard end dump trailers. The trailers will be loaded per the generator's
specifications and standard protocols. The dump trailers used for transportation of dewatered cake biosolids will be
equipped with sealed tailgates and will be completely sealed to prevent leakage. All trucks will be fully covered and
will be fitted with positive lock tailgates.
7.0 LIQUID BIOSOLIDS
Liquid biosolids will be transported using 7,000 gallon capacity liquid tankers, pulled by standard road tractors, for
liquid biosolids transportation. The tankers will be loaded per the generator's specifications and standard protocols.
The tractor/tanker unit will transport its load to a designated staging area inside the buffered area of a permitted
land application site.
8.0 APPLICATION (SPREADING) — DEWATERED BIOSOLIDS
At the staging area each load will be unloaded in a designated area within the land application site. Biosolids will be
loaded into our Side Slinger cake box by a front-end loader. This unit is capable of delivering an accurate, calibrated
application of dewatered biosolids over the application site. The uniform spread pattern ensures that biosolids are
applied at proper agronomic (nutrient) and hydraulic loading rates. The application rates for each site, and its
corresponding crop, will be determined based on the Plant Available Nitrogen (PAN) content of the biosolids, or
other limiting factors. Typical applications will deliver between 75 and 100 percent of a crop's annual PAN
requirement.
9.0 APPLICATION (SPREADING) — LIQUID BIOSOLIDS
At the staging area each load will be transferred into a 4,000 gallon capacity pull behind subsequent land application.
This unit is capable of delivering an accurate, calibrated application of liquid biosolids over the application site. The
uniform spread pattern ensures that biosolids are applied at proper agronomic (nutrient) and hydraulic loading rates.
The application rates for each site, and its corresponding crop, will be determined based on the Plant Available
Nitrogen (PAN) content of the biosolids, or other limiting factors. Typical applications will deliver between 75 and
100 percent of a crop's annual PAN requirement.
10.0 SPILL AND EMERGENCY RESPONSE PROGRAM
In the unlikely event of a spill, the Town of Louisburg will take the following actions immediately.
• Halt Source of Spill. Use of any leaking or damaged unit which is causing the spill will cease immediately. The
unit will be repaired before resuming its use.
• Contain Spill. In the event large quantities of biosolids have been spilled, straw bales will be used where
available and as necessary to either form a barrier or absorb biosolids.
• Clean -Up. Depending on the type and amount of biosolids spilled, a variety of equipment may be used to
remove the biosolids: front-end loader, shovels and brooms and vacuum equipment of a liquid biosolids
applicator. Any biosolids removed from the spill site will be spread on an approved application site, returned
to the WWTP, or disposed of in an approved landfill.
Revised 01 /21 OTown of Louisburg Operation and Maintenance Plan

• Final Clean -Up. Flush roadways with water or sweep as necessary to clean. Allow to dry and incorporate if
spill occurs on non -paved and tillable area. In the event a spill occurs on private property, final clean-up
should be completed immediately to the satisfaction of the owner.
• Management of Clean -Up Efforts. The Operations Manager will take immediate charge and initiate clean-up
activities. The Contract Land Applier along with the Town of Louisburg labor will be used, with additional
labor secured as needed. The Operations Manager will also communicate with the public on the scene,
answering questions and advising of clean-up activities.
• Reporting. All spills will be reported immediately to the Town of Louisburg officials. State and local agencies
will be notified in accordance with their notification requirements. Within 24 hours of the spill, the Operations
Manager will send the Town of Louisburg a written report detailing how the spill occurred and remedial action
taken. This report will be provided using the enclosed Spill Report form.
• Spill Prevention. The Operations Manager will implement the following spill prevention measures:
o Ensure truck drivers watch trailer while loading and do not overload;
o Ensure trailer hatches are closed and latched while transporting;
o Ensure trailer seals are inspected on a daily basis and replaced as necessary; and
o Ensure unloading operations in the field are conducted to minimize any potential runoff or tracking.
The Town of Louisburg require that the Contract Land Applier shall ensure that all employees receive safety and spill
response training as part to their new hire training and thereafter participate in our monthly safety and spill response
training program. In addition to their internal training and protocols, they must also contract with a regional
emergency response firm - HEPACO - available to respond to an incident in the Central and Eastern North Carolina
area within two hours. A copy of our agreement with HEPACO can be provided upon request.
Names and Titles of Inspection Personnel
Andy Smith, Area Supervisor
Jason Smith, Area Supervisor
JT Bryant, Regional Supervisor
Jay Bryant, Project Supervisor
Matt Foster Project Supervisor
BJ Bryant, Field operators
Jeff Bumpass, Field operators
Tammy Walston, Field operators
11.0 PREVENTION
The goal of a compliance assurance system is to prevent compliance issues from occurring. Prevention involves:
• Ensuring personnel understand their role in assuring compliance;
• Identifying compliance requirements at the federal, state and local levels;
• Implementing a system where compliance tasks are scheduled, assigned and tracked to completion;
• Developing standard operating procedures where appropriate; and
• Reviewing the compliance task list and standard operating procedures on an ongoing basis and modifying
them as appropriate to account for changes in regulations/requirements and operating methods, and to
address compliance deficiencies.
Revised 01 /21 OTown of Louisburg Operation and Maintenance Plan

12.0 Standard Operating Procedures (SOP's)
The Town of Louisburg will direct the Contract Land Applier to develop and implements SOPS to ensure compliance
tasks are completed consistently across the company. The SOP provides standard forms to use, approved biosolids
analytical methods, frequency of monitoring information, etc. Another key SOP relative to preventing compliance
issues from occurring is the use of a "Pre -Operating and Buffer Checklist".
The Pre -Operating and Buffer Checklist ensures federal, state and local regulations and permit requirements are met
prior to initiating biosolids applications at field sites. Compliance items on the Checklist include:
• The field is permitted and suitable for the biosolids/residuals type being applied;
• Pre -application requirements are met;
• Farmer and landowner agreements are current and the crop to be grown has been verified;
• The field is flagged to prevent applications in buffer zones and restricted areas;
• The appropriate application rate and field capacity is calculated; and
• Any special permit or local requirements are met.
• A listing of the buffer zones and restricted areas where biosolids/residuals cannot be applied
• A listing of operating requirements including notification requirements,
• application method requirements, and inclement weather operating requirements
13.0 ASSESMENT
To help ensure compliance requirements are being met and the compliance assurance system is implemented and
working, periodic, consistent, objective and documented assessments of the project/facility's compliance status are
conducted.
14.0 CORRECTIVE ACTION
Once compliance issues have been identified during the course of day to day business and through internal audits and
inspections a system must be in place which ensures that appropriate and timely corrective action is taken, the cause
of the compliance issue is identified and actions are taken to prevent recurrence of the issue.
The Town of Louisburg's goal is to have no instances of non-compliance. However, issues and incidents may occur
and when this happens employees work to correct the incident in a timely and thorough manner. When compliance
issues are identified, the situation is examined to determine the root cause of the problem and the corrective and
preventive action that must be taken. The preventive action must address the root cause with the goal of preventing
a recurrence.
Depending on the nature of the compliance issue, it is assigned to one or more responsible parties to ensure that the
corrective and preventive actions are implemented. A deadline for completion of the task is assigned and the issue is
tracked to completion by regional and corporate compliance personnel.
Revised 01 /21 OTown of Louisburg Operation and Maintenance Plan

15.0 TRAINING
An effective compliance training program involves:
• Identifying training needs and requirements;
• Assigning personnel to provide training and providing them the resources they need to conduct training;
• Documenting and tracking that mandatory t raining has occurred; and
• An employee's training needs and requirements, as well as their training responsibilities, are based on
his/her position within the company.
Revised 01 /21 OTown of Louisburg Operation and Maintenance Plan

Spill Response/Clean Up
THE FOLLOWING ACTIONS MUST BE TAKEN IN THE EVENT OF A SPILL
Halt the source of the spill: Ruptured line or valve, or damaged tank unit.
Contain spill: Use straw bales to form a barrier. Straw or hay bales can be obtained
from several sources for this purpose. Soil near the site can also be used to form a
barrier for containment.
Clean up: Use application equipment to recover as much of the material as possible.
After the application equipment has recovered as much material as possible, it will
be land applied as per the management plan. A temporary sump pit may be dug in
the containment area and spilled material washed into it to enhance recovery.
Final Clean up: Any unrecoverable material will be washed from road surfaces and
incorporated into an adjacent tillable area.
Notification: As soon as possible after a spill occurs notify:
Town of Louisburg
[phone]
Bryan (Andy) Smith, GFI - President
[phone]
Department of Environmental Quality
Division of Water Resources
Raleigh Regional Office
[phone]
Fire Department if assistance is required for wash down "911"
Highway Patrol if accident is on a public road "911"
Management of cleanup efforts: The field superintendent will take immediate
charge of the cleanup activities. Additional labor will be requested from the
groundwater recovery site and other departments as needed.
Reporting: Within 24 hours of a spill, the field superintendent will present a written
report detailing the cause of the spill and all actions taken in response to the spill.
The report will be sent to the NCDEQ Regional office having jurisdiction at the
location in which the release occurred.

TOWN OF LOUISBURG
O&M PLAN
PROCESS FLOW DIAGRAM

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— — — — — — — —
I I
I TAR RIVER
— — — — — — — — — J

TOWN OF LOUISBURG
O&M PLAN
MAXIMUM PRODUCTION
QUANTIFICATION & JUSTIFICATION

AVERAGE
# of
Gallons I Dry Tons I WWTP IYears Counted
2,423,800 264.75 Louisburg WWTP

TOWN OF LOUISBURG
O&M PLAN
SOURCE VICINITY MAPS

SOURCE FIGURE
Louisburg WWTP

N
W E
S
--,.,C._` Creek
sue;
_N
a �
� �SR n
_ N
6-
S�1
SR�12�2 J
SR-1256
SR-1231
burg
sR 16v z
sR-126a
�Ns
Sl/
1606 Sg_1656 NG56581
burg
1491
<rl
Legend
Source Location
— Road
Stream
L_
'JCount Y Boundary
[I Municipal Boundary
Surface Water ��� 0.5 0.25 0 0.5
SR-1604 Miles
Scale: 1 inch = 0.5 miles LOCATION MAP
SOIL PLUS
T Figure
Drawn by: DM S V s Town of Louisburg RLAP (WQ0005981)
Reviewed by: Louisburg, North Carolina 1
Date: January 2020 Soil Plus Project # 200705.G10

ATTACHMENT 3
REVISED I ASCA

LAND APPLICATION SITE CERTIFICATION
Applicant's name: Town of Louisbursl
Land application sites currently certified: 84.44 net acres and Total to be certified: 100. net acres.
L LAND APPLICATION SITE INFORMATION (See Instruction B):
Status
Code'
Site/Field
ID
Landowners
(�
Lessees or Operator(s)
O
Net Acres
County
Crop(s) s
PO
Predominant Soil
Series Name'
Mapping Unit
or Rep. Slope'
R
P-1
Carmen R. Parkhurst
Karl Holshouser
9.13
Frank
Fescue
Georgeville
GeB
R
P-2
Carmen R. Parkhurst
Karl Holshouser
40.33
Franklin
Fescue
Georgeville
GeB
R
P-3B
Carmen R. Parkhurst
Karl Holshouser
17.70
Franklin
Fescue
Varina
VnB
R
P-3T
Carmen R. Parkhurst
Karl Holshouser
9.54
Franklin
Fescue
Varina
VnB
R
P-4
Carmen R. Parkhurst
Karl Holshouser
11.24
Franklin
Fescue
Varina
VnB
R
P-5
Carmen R. Parkhurst
Karl Holshouser
1.89
Franklin
Fescue
Georgeville
GeB
R
P-6
528 Collins Mill Rd, LLC
Earl Holshouser
6.96
Franklin
Fescue
Varina
VnB
R
e-7A&B
528 Collins Mill Rd, LLC
1[arl Holshouser
3.94
Franklin
Fescue
Georgeville
GeB
a Status Code for land application sites are: ♦ N (New) ♦ R (Renewed) ♦ M (Modified) ♦ T (Transferred) ♦ D (Deleted)
b Soil Series Name (i.e. Appling, Cecil, etc.)
Mapping Unit must be consistent with those used in the County Soil Survey (i.e. for a 2-8% slope Cecil in Anson County the mapping unit is CeB2)
IL WATERBODY AND CLASSIFICATIONS INFORMATION (See Instruction C):
Site/Field ID
Latitude
Longitude
Location
Datum
Location Method Code
Location Accuracy
Waterbody Subbasin and
Stream Index No.
Current and Proposed
Class
P-1
60 08' 37.5"
780 05' 11.5"
NAD 83
MAP
Nearest Second
Deer Branch 28-78-1-15
C
C
P-2
60 08' 28.3"
780 04' 51.7"
NAD 83
MAP
Nearest Second
Deer Branch 28-78-1-15
C
C
P-3B
60 08' 43.2"
780 04' 51.3"
NAD 83
MAP
Nearest Second
Deer Branch 28-78-1-15
C
C
P-3T
�6° 08' 419"
780 04' 43.5"
NAD 83
MAP
Nearest Second
Deer Branch 28-78-1-15
C
C
P-4
60 08' 29.6"
780 04' 19.8"
NAD 83
MAP
Nearest Second
Deer Branch 28-78-1-15
C
C
P-5
�6° 08' 20.8"
780 04' 11.5"
NAD 83
MAP
Nearest Second
Deer Branch 28-78-1-15
C
C
P-6
60 08' 44.4"
780 05' 10.3"
NAD 83
MAP
Nearest Second
Deer Branch 28-78-1-15
C
C
&7A&i
� 60 08' 46.1"
1 780 05' 03.51,1
NAD 83
MAP
Nearest Second
Deer Branch 28-78-1-15
C
C
Note: Please keep the site information (I.) and waterbody information (II.) of the same field on the same page.
FORM: LASC 11-13 Page 1

ATTACHMENT 4
UPDATED BUFFER MAPS

�s
_k"
`®
NO
P-2
Ditch
10- Stream
The Compliance Boundary is established either 250
Application Area feet from the residuals application area or 50 feet
Buffer within the property boundary, whichever is closest to
❑ Field Boundary the application area. The Review Boundary is
established midway between the Compliance
Pond Boundaryand the perimeter of the residuals
P 400 200 0 400
u Property Boundary application area.
Feet
Scale: 1 inch = 400 feet T PLUS
P-1, P-6, P-7A&B BUFFER MAP Figure
Drawn by: DM SOIL PL lJ s Town of Louisburg RI -.AP (WQ0005981)
Reviewed by: Centerville, North Carolina
Date: May 2021 Soil Plus Project # 200705.A18

N
FIELD
NET AC.
W E P-2
40.33
P-313
17.70
s
P-3T
9.54
P-6
PY
t
P-2
P-3T
Legend
■ House
,
A Structure
40 Well
Ditch
10- Stream
The Compliance Boundary is established either 250
Application Area
feet from the residuals application area or 50 feet
® Buffer
within the property boundary, whichever is closest to
❑ Field Boundary
the application area. The Review Boundary is
established midway between the Compliance
Pond
Boundaryd the perimeter of the residuals
ane P 400 200 0 400
"Property Boundary
application area.
Feet
Scale: 1 inch = 400 feet
T PLUS
SOIL PLUS
P-2, P-3B, P-3T BUFFER MAP
Figure
Drawn by: DM
Town of Louisburg R1-.AP (WQ0005981)
Reviewed by:
I Centerville, North Carolina
Date: May 2021
Soil Plus Project # 200705.A18

IN N
w E
S
FIELD NET AC.
P-4 11.24
P-5 1.89
$. .
i
a
41
Legend
■ House
A Structure
40 Well
Ditch
10- Stream
Application Area
® Buffer
❑ Field Boundary
Pond
"Property Boundary
Scale: 1 inch = 400 feet
Drawn by: DM
Reviewed by:
Date: May 2021
A
x
K
r q
Jk
The Compliance Boundary is established either 250
feet from the residuals application area or 50 feet
within the property boundary, whichever is closest to
the application area. The Review Boundary is
established midway between the Compliance
Boundary and the perimeter of the residuals 400 200 0
application area.
400
i Feet
�,� r r P-4 & P-5 BUFFER MAP Figure
SOl- Pt U s Town of Louisburg RLAP (WQ0005981)
4940OPOOOP� Centerville, North Carolina
Soil Plus Project # 200705.A18