WQ0035777_Regional Office Historical File Pre 2018

North
Beverly Eaves Perdue
Governor
GA`
NCDENR
Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P. E.
Mr. Mitch Vestal, Senior Vice President
Nature Works Organics
1151 Strathmore Circle
Winston-Salem, NC 27104
Dee Freeman
Director
__..May
,-,,-.—,—.Secretary,
8, 2012
i_.
A,;uifer Proba,3 ioti
SUBJECT: Temporary Approval for Land Application of Residuals by Incorporation
Nature Works Organics
Permit No. WQ0035777
Wilkes County
Dear Mr. Vestal:
The Winston-Salem Regional Office hereby grants permission for Nature Works Organics to temporarily
resume land application activities with incorporation at the following properties: 1) Claude Shew Property
and 2) Wilkes County Property as discussed in our May 3 meeting and subsequent telephone
conversations provided that permit conditions and requirements in NCAC 15A 2T are followed. Both
properties are planted by Mr. Shew; some fields are included under his waste management plan. This
temporary approval only applies to the above mentioned properties; approval must be received from
DWQ prior to land application at any other locations.
The following requirements should be demonstrated or met for compliance with Permit WQ0035777 and
NCAC 15A 2T:
1. Pathogen Reduction: Fecal or Salmonella Density
A Fecal Coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry
solids, or a salmonella sp. density that is demonstrated to be less than 3 MPN per 4 grams of total
dry solids.
It is my understanding that this has been demonstrated with data that has been provided to this
office. Please note that monitoring frequencies are based on the actual dry tons applied per year
using the table found on page 1 of the Attachment A of permit WQ0035777.
2. Pathogen Reduction: Alternative 5 — Process to Further Reduce Pathogens (PFRP)
It is our understanding that it is your intention is to demonstrate this requirement by PFRP using
Pasteurization. This method requires that the temperature of the biological residuals be
maintained at 70°C (158°F) or higher continuously for 30 minutes or longer (EPA/625/R-92/013,
page 33 and 55). Demonstration of this alternative involves keeping a time and temperature log
which should include date, time, temperature, and initials of personnel collecting this data.
Winston-Salem Regional Office
585 Waughtown Street Winston-Salem, NC 27107
Phone: [phone] FAX: [phone]
NCDENR Customer Service: 1-877-623-6748
Internet: www.ncwateroualitv.om
Nne
orthCarohna
Aaturally
An Equal Opportunity 1 Affirmative Action Employer

Nature Works Organics
Land Application of Residuals by Incorporation
. ff
May 8, 2012 i
WQ0035777
Based on our May 8, 2012 phone conversation, it is our understanding that there are at least three
(3) points in the process in which temperature can be recorded. These points include the heat
exchanger, entry point into the centrifuge, and at storage tank(s). A data log interval of no less
than 30 minutes would be required. The treatment works should have adequate temperature
measuring equipment such as temperature gauges. Once the pasteurization process has resumed,
please notify this office so that our staff can observe that the pasteurization meets all
requirements and that data collection is adequate.
3. Vector Attraction Reduction (VAR):
It is my understanding that Alternative (1) (38% Volatile Solids Reduction) is being used,
however please note that for animal processing residuals, only alternatives 9 or 10 may be chosen
due to the nuisance conditions that typically occur when these residuals are applied and left on the
land surface (FORM: RSC 08-11, page 5). Alternative 9 is for Injection and Alternative 10 is for
Incorporation of residuals.
"Incorporation" shall mean the mixing of residuals with top soil to a minimum depth of four
inches by methods such as discing, plowing, and rototilling. (15A NCAC 02T .1102 (19), p. 53)
15A NCAC 02T .1107(a)(10) applies to both Class A and Class B:
(10) Incorporation.
(A) If Class B with respect to pathogens, the biological residuals shall be incorporated into the
soil within six hours after application to the land.
(B) If Class A with respect to pathogens, the biological residuals shall be applied to the land
within eight hours after being discharged from the pathogen treatment process.
4. Setbacks
Land Application Setbacks for any material currently being stored at the Nature Works facility
should be land applied with setbacks that are required for Class B residuals.
Please note the following regulations applicable to injection of residuals found in 15A NCAC
02T .1108:
(b) For land onto which bulk residuals are applied or stockpiled, the following minimum setbacks
(i.e., in feet) shall be adhered to: (2) If the bulk residuals do not meet the requirements of Rules
.1105(c), .1106(b), and .1107 of this Section: Injection /Incorporation
Habitable residences or places of public assembly under separate ownership
200
or not to be maintained as part of the project site
Habitable residences or places of public assembly owned by the
0
permittee, the owner of the land, or the lessee/operator of the land
to be maintained as part of the project site
Property lines
50
Public rights of way
50
Private or public water supply sources
100
Surface waters (streams - intermittent and perennial, perennial waterbodies,
50
and wetlands)
Surface water diversions (ephemeral streams, waterways, ditches)
25
Groundwater lowering ditches (where the bottom of the ditch intersects the SHWT)
25
Subsurface groundwater lowering drainage systems
0
Wells with exception to monitoring wells
100
Page 2 of 4

Nature Works Organics
May 8, 2012
Land Application of Residuals by Incorporation
WQ0035777
Bedrock outcrops
25
Top of slope of embankments or cuts of two ft or more in vertical height
15
Building foundations or basements
0
Water lines
0
Swimming pools
100
Nitrification fields
5. Operation And Management Practices
High Water Table
Please verify that the seasonal high water table is greater than one foot below the proposed depth
of incorporation before applying to any land application site. Bulk residuals shall not be land
applied if the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot.
Harvesting/Grazing
For land onto which bulk residuals that do not meet the requirements of Rule .1106(b) of this
Section are applied, the following harvesting and grazing restrictions shall be adhered to: (E) food
crops with harvested parts below the surface of the land shall not be harvested for 3 8 months after
any residuals land application event when the residuals remain on the land surface for less than
four months prior to incorporation into the soil (15A NCAC 02T .1109, page 65)
In addition to the above mentioned requirements please provide a Product Information Sheet to and
collect a signed Utilization Agreement from the receiving parties.
Due to the nuisance conditions that have been documented with the land application of the residuals and
the recommendation that only Alternative 9 (Injection) or Alternative 10 (Incorporation) be used for
animal processing residuals, we believe that the permit should be modified. We also have concerns with
the ability of Natureworks to meet the restrictions included in 2T .1107(9) or (10) on a day-to-day basis.
Our records indicate that the ability to discharge to the Town of Wilkesboro's sewer system was
terminated in January of 2012, which closes this option of disposal. A permit modification request will
be needed to start this process. Permit Condition VI. 6. states that this permit is subject to revocation or
unilateral modification upon 60 days notice from the Division Director, in whole or part for the
requirements listed in 15A NCAC 02T .0110. The applicable requirements include (1) violation of any
terms or conditions of the permit and (2) obtaining a permit by misrepresentation or failure to disclose
fully all relevant facts.
If you have questions concerning this letter, please contact Mr. Derek Denard or me at [phone].
Sincerely,
Cvu Y 1��� f ��.
Sherri V. Knight (J
Regional Supervisor
cc: Mr. Chris Redcay, Nature Works Organics — 3412 Garden Rd., Burlington, NC27215
Mr. Danny Cockerham, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Bob Binkley, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Dennis Key, Southern Soil Builders — 958 Hoots Rd., Roaring River, NC 28669
Page 3 of 4

Nature Works Organics
Land Application of Residuals by Incorporation
May 8, 2012
WQ0035777
Mr. Doug Baxter, Tyson Foods, Inc. —13264 Mountain Rd., Glen Allen, VA 23059
Mr. James Brown, Tyson Foods, Inc. —1600 River St., Wilkesboro, NC 28697
Wilkes County Health Department
Mr. Jon Risgaard, APS Central Office
Mr. Ed Hardee, APS Central Office
Ms. Chonticha McDaniel, APS Central Office
r Ms=Ellen.Hu_ffman DWQ—APS MRO
Permit File WQ6035777
APS WSRO file
Page 4 of 4

A�
WDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
April 26, 2012
CERTIFIED MAIL #7010 0290 00014856 3884
RETURN RECEIPT REQUESTED
Mr. Doug Baxter
Tyson Foods, Inc.
13264 Mountain Rd.
Glen Allen, VA 23059
SUBJECT: Additional Information Request
Nature Works Organics
Permit No. WQ0035777
Wilkes County
Dear Mr. Baxter:
Dee Freeman
Secretary
e•--^..�.+....
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Non -discharge Permit No. WQ0035777 was issued to Nature Works Organics on February 22, 2012 for the
distribution of Class A residuals with a maximum dry tonnage of 1,750 Dry Tons per year. Tyson Food, .Inc.
Chicken Processing — DAF Unit (Skimmer) in Wilkes County, NC is listed as the residuals source -generating
facility for this permit.
Our office has received numerous complaints about the operation of the subject residuals management program
and have documented violations of permit WQ0035777 including the creation of nuisance conditions and
discharges to the surface waters at both land application sites and at the Nature Works Organics facility in North
Wilkesboro, NC. As a result -of this non-compliance this office has requested that Nature Works Organics at
least temporarily cease all distribution and land application of these residuals.
The Division of Water Quality may pursue enforcement action for this and any additional violations of State
law. Failure to abide by the conditions and limitations contained in Permit No. WQ0035777 may subject the
Permittee to an enforcement actionby the Division in accordance with North Carolina General Statute 143-
215.6A through 143-215.6C. Prior to making such a recommendation, we need to be certain that we have all
relevant information.
Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, North Carolina 27107 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 NorthCarohna
Internet: http:llportal.ncdenr.orglweblwq //
An Equal Opportunity\ Affirmative Action Employer Na!a �'rraliI

Mr. Baxter
April 25, 2012
Page 2 of 2
Our office is in the process of documenting all findings of fact in this case and is requesting that Tyson Food,
Inc. provide documentation of any contractual agreement with Nature Works Organics for the disposal of
residuals from the Chicken Processing — DAF Unit (Skimmer) in Wilkes County, NC. Please send such
information to me in writing with fifteen (15) days following receipt of this letter. Should you have any
questions on this matter, contact Derek Denard or me at 336-771-5000.
Sincerely,
.f
Sherri V. Knight, P.E.
Regional Supervisor, Aquifer Protection Section
cc: Mr. James Brown, Tyson Foods, Inc. —1600 River St., Wilkesboro, NC 28697
Mr. Mitch Vestal, Nature Works Organics —1151 Strathmore Circle, Winston-Salem, NC 27104
Mr. Chris Redcay, Nature Works Organics — 3412 Garden Rd., Burlington, NC 27215
Mr. Danny Cockerham, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Bob Binkley, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
�M ._perm is_Key, Southern Soil Builders — 958 Hoots Rd., Roaring River, NC 28669
r. Jon Risgaard, AZ'S C—en ral Office
Mr. Ed Hardee, APS Central Office
Ms. Chonticha McDaniel APS Central Office
s. n Huff—M` n
Permit File WQ0035777
APS WSRO file
Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, North Carolina 27107 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 NorthCarolina
Internet: http:l/portal.ncdenr.orglweblwq ���t"//�J/,/_ l
An Equal Opportunity 1 Affirmative Action Employer Aa`

ALIV_11�wj
NCDEhIR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
April 26, 2012
CERTIFIED MAIL # 7010 0290 0001 4856 3877
RETURN RECEIPT REQUESTED
Mr. Mitch Vestal, Senior Vice President
Nature Works Organics
1151 Strathmore Circle
Winston-Salem, NC 27104
Natural Resources
SUBJECT: Cease Distribution/Land Application of Residuals
& Additional Information Request
Nature Works Organics
Permit No. WQ0035777
Wilkes County
Dear Mr. Vestal:
Dee Freeman
Secretary
it
lj 2012
pp �
After receiving numerous complaints, investigating multiple incidents occurring at the facility,
and documenting numerous violations of conditions found in Permit No. WQ0035777 issued
February 22, 2012, from the operation of the subject residuals management program, this office
hereby requests that Nature Works Organics temporarily cease all distribution/ land application
of residuals, effective April 24, 2012. Mr. Danny Cockerham, Nature Works Organics, and Mr.
Dennis Key, Southern Soil Builders, were each 'contacted via telephone and verbally notified of
this request on Tuesday April 24, 2012.
While the Division recognizes and supports the value of Nature Works' commitment,to develop
environmental friendly products and recycle waste materials to promote environmental
protection, at the same time, it is very important that an effective residual land application
program is maintained to be protective of both environment and public health.
The facility has failed to effectively maintain and operate the subject residuals management
program, in order to prevent discharge to surface waters. In addition, improper operation and
maintenance has led to the creation of nuisance conditions due to odor, flies, etc. The land
applied material appears to be unstable according to these observations. Condition II. 1 of
permit WQ0035777 requires that upon the event that the facilities fail to perform satisfactorily,
including the creation of nuisance conditions, the Permittee shall immediately cease distribution
of residuals. Other actions required within this permit condition, to be taken by the Permittee in
the event that the facilities fail to perform satisfactorily, include contacting the Winston-Salem
Winston-Salem Regional Office
585 Waughtown Street Winston-Salem, NC 27107
Phone: [phone] FAX: [phone]
NCDENR Customer Service: 1-877-623-6748
Internet: www.ncwaterguality.org
NorthCarohna
Naturally
An Equal Opportunity 1 Affirmative Action Employer

l_
Nature Works Organics April 26, 2012
Compliance Evaluation Inspection/Complaint Investigation WQ0035777
regional office's Aquifer Protection Section supervisor and to take any immediate corrective
actions.
Other applicable permit conditions include Condition III. 1. which requires the residuals program
be properly maintained and operated at all times. The program shall be effectively maintained
and operated as a non -discharge system to prevent any contravention of surface water or
groundwater standards. In addition, Condition III 8. b. requires that bulk residuals not be land
applied if the application causes prolonged nuisance conditions.
Recent land application of residuals by NatureWorks Organics have resulted the Division issuing
notices of violation to NatureWorks Organics for failure to meet conditions established in the
permit. This letter is intended to clarify the permit language and to better assure that
NatureWorks Organics and the Division have mutual understanding of what the permit allows
and does not allow. According to the residuals source information and treatment process flow
diagram submitted to the Division, skimmer wastes from a chicken -processing Dissolved Air
Floatation (DAF) unit are sent to NatureWorks Organics facility for further treatment through a
1/4-inch bar screen, heat exchanger, and a centrifuge. Upon completion of treatment, the DAF
waste stream has been separated in to three separate waste streams 1) fats; 2) solids (comprised
of approximately 60% water); and 3) water (a wastewater fraction from the centrifuge). The
solids and a portion of wastewater are to be stored inside a sealed dump trailer and taken to a
local farm for land application. If an alternate storage site is used, prior approval must be
obtained from the Division in accordance with the permit Condition III.11. The mixture of solids
and wastewater have been permitted for land application under the DWQ issued permit which
requires proper management of the residuals program so that it will not result in a threat to
human health or a public nuisance including control of odors which are, in this case, the cause of
nuisance condition. The distribution of the pelletized worm casting products is currently not
covered under the issued permit which allows the distribution/ land application of the solids and
water streams from the heat exchanger/centrifuge process. A permit modification or a separate
permit is. needed in order to cover both residuals/products.
After contacting the City of North Wilkesboro WWTP, it has come to our attention that Nature
Works Organics has been denied use of discharge of any wastewater other than domestic waste
to the collection system. It should be noted that a portion of the wastewater stream was shown to
be discharged to the WWTP in the application. The WWTP has reported to this office that
effluent from Nature Works Organics has resulted in treatment plant upsets. With few other
options for disposal of the waste stream from this facility, it is imperative that we reach an
agreement on an alternative to the present permit before distribution/ land application may again
proceed.
Facility site inspections conducted by the Division during visits of land application sites noted
that the residuals consisted mostly of a highly odorous liquid waste. The application indicated
that the residuals were a "cake" material that "will be given away to local land owners and
farmers as a soil amendment or "in a wetter form to be sprayed when available".
Our office recommends that this permit be modified as soon as possible for clarification. Permit
Condition VI. 6. states that this permit is subject to revocation or unilateral modification upon 60
Page 2 of 4

fi
Nature Works Organics
Compliance Evaluation Inspection/Complaint Investigation
April 26, 2012
WQ0035777
days notice from the Division Director, in whole or part for the requirements listed in 15A
NCAC 02T .0110. The applicable requirements include (1) violation of any terms or conditions
of the permit and (2) obtaining a permit by misrepresentation or failure to disclose fully all
relevant facts.
We request the following additional information for clarification:
1. A clarification of all permitted waste streams including facilities at Nature Works
Organics and Tyson Food, Inc. Chicken Processing — DAF Unit (Skimmer), which
should include a mass balance (mass in/ mass out) quantification of the waste stream: The
flow chart included with the application indicates that a solids stream and water stream
are combined prior to land application. How are these streams combined and/or what has
been the applied product to date (water only or combined)? It appears that the solids
stream goes to the worm beds. The middle stream of water indicates that it goes to
fertilizer production. Is this going to the worm beds also? Please clarify the information
provided in this flow chart diagram.
2. A residuals sampling plan, which should include all sampling as described in Permit
Condition IV.1-8. and Attachment A of permit WQ0035777. Included should be a
detailed description of all sampling locations for 38% Volatile Solids Reduction. Please
see Permit Condition III. 2. f. for requirements for a sampling and monitoring plan.
3. Please submit all sampling in the form of an up-to-date annual report as describes in
Permit Condition IV.7. Although distribution programs typically do not need to
complete the Annual Land Application Field Summary Form (DENR FORM FSF),
please prepare this form for each field on each site that residuals were applied to from the
beginning of application at Bill Arnold's farm. The report should meet the requirements
described in the Instructions for Residuals Application Annual Reporting Forms.
Instructions for reporting and annual report forms are available at
http://portal.ncdenr.org_/web/wq/aps/lau/reporting. Please note that additional sampling
maybe required to meet monitoring requirements. It would be recommended that
additional samples be analyzed to prepare this report. All calculations of 38% Volatile
Solids Reduction should be included.
4. Any proposed alternatives to the way in which the residuals program is operated which
may include injection of the residuals, incorporation of the residuals, or suggestions for
odor reduction. Others alternatives may include having the material designated as Class
B. Please note that page 5 of the permit application (Form RSC 08-01) indicated that
only alternative 9 or 10 should be used for animal processing residuals.
Page 3 of 4

1,
Nature Works Organics
Compliance Evaluation Inspection/Complaint Investigation
April 26, 2012
WQ0035777
Your immediate attention is greatly appreciated. Please respond in writing and submit all of the
requested additional information within thirty (30) days following receipt of this letter. If you
have questions concerning this letter, please contact Mr. Derek Denard or myself at (336) 771-
5000.
Sincerely,
" 1
Sherri V. Knight
Regional Supervisor
cc: Mr. Chris Redcay, Nature Works Organics — 3412 Garden Rd., Burlington, NC 27215
Mr. Danny Cockerham, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Bob Binkley, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. -Dennis Key Sow uthern S.oil Builders�_QS_8 f oots�Rd.,-Roar_ing_River,aVC_ 88669
Mr. Doug Baxter, Tyson Foods, Inc. —13264 Mountain Rd., Glen Allen, VA 23059
Mr. James Brown, Tyson Foods, Inc. —1600 River St., Wilkesboro, NC 28697
Iredell County Health Department
Wilkes County Health Department
Yadkin County Health Department
Mr. Jon Risgaard, APS Central Office
Mr. Ed Hardee, APS Central Office
Ms. Chonticha McDaniel, APS Central Office
�n Lci�'man +1i�J:� AP
Permit File WQ0035777
APS WSRO file
Page 4 of 4

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
February 22, 2012
Mitch Vestal — Senior Vice President
NatureWorks Organics
1151 Strathmore Circle -
Winston Salem, NC 27104
Subject Permit No. WQ0035777
NatureWorks Organics
Distribution of Class A Residuals
Wilkes County
Dear Mr. Vestal:
In accordance with your permit application request received fFebruary`I3; 20-12 and subsequent
additional information received February 15, 2012, we are forwarding herewith Permit No. WQ0035777,
dated February 22, 2012, to NatureWorks Organics for the operation of the subject residuals management
program.
This permit shall be effective from the date of issuance until January 31, 2017, and shall be
subject to the conditions and limitations as specified therein. Please pay particular attention to the
monitoring requirements listed in Attachments A. Failure to establish an adequate system for collecting
and maintaining the required operational information shall result in future compliance problems.
Please note that "bulk residuals" shall mean residuals that are transported and not sold or given
away in a bag or any receptacle with a load capacity of one metric ton or less.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the
North. Carolina, General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and
biri#.ing.
ITyou need additional. information concerning this matter, please contact Chonticha WDaniel at
r(9;19):807.-63.3:[e-mail].
AQUIFEk: ORQTECTION,-SECTJON'
1636 huI I Service Center; Relegh,. North Cai ilina 27699-1636
Location: 512 N.- Salisbury St, Raleigh, North -Carolina 27604
Phone: [phone] FAX: [phone]
Internet- httr):' ial.hcd nr.ora/wbbhwalaos
An Equal Opportunity 1 Affirmative Action Employer
Sincerely,
Z, Cha Wakild, P. E.
NorthCarolina
Natmra!!y.

Mr. Vestal = ---_ -
February 22, 2012
Page 2 of 2
cc: Wilkes County Health Department
Winston-Salem Regional Office, Aquifer Protection Section
Zach Key — Southern Soil Builders, Inc.-(958 Hoots Rd., Roaring River, NC 28669-9148)
Technical Assistance and Certification" Unit --
Permit File WQ0035777
Notebook File WQ003577 , -

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COAU IISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF CLASS A RESIDUAL SOLIDS PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
NatureWorks Organics
Wilkes County
FOR THE
operation of a residuals management program for NatureWorks Organics - and consisting of the
distribution of Class A residuals generated by the approved facilities listed in Attachment A with no
discharge of wastes to surface waters, pursuant to the application received February 13, 2012, and
subsequent additional information received by the Division of Water Quality, and in conformity with
other supporting data subsequently filed and approved by the Department of Environment and Natural
Resources and considered a part of this permit. The use and disposal of residuals are regulated under Title
40 Code of Federal Regulations Part 257. This permit does not exempt the Permittee from complying
with the federal regulations.
This permit shall be effective from the date of issuance until January 31, 2017, and shall be subject to the
following specified conditions and limitations:
I. SCHEDULES
1. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division .will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
H. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all times
so there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In --the event the facilities fail to perform satisfactorily, including the creation of nuisance
conditions due to improper operation and maintenance, the Permittee shall immediately cease
distribution of residuals, contact the Winston-Salem regional office's Aquifer Protection Section
supervisor, and take any immediate corrective actions.
2. This permit shall. not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this residuals management program.
WQ0035777 Version 1.0 Shell Version 111027 Page 1 of 10

3. Only residuals generated by the facilities listed in Attachment A are approved for distribution in
accordance with this permit.
4. Pollutant concentrations in residuals distributed or applied to any land application site shall not
exceed the following Ceiling Concentrations or Monthly Average Concentrations (i.e., dry weight
basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
n/a
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
5. Residuals that are distributed shall meet Class A pathogen reduction requirements in 15A NCAC 02T
.1106 (a) an(b): Exceptions to this requirement shall be specified in Attachment A.
17
6. Biological resi s (i.e: residuals generated during the treatment of domestic or animal processing
wastewater, or the biological treatment of industrial wastewater, and as identified in Attachment A)
that are distributed shall meet one of the vector attraction reduction alternatives in 15A NCAC 02T
.1107(a). Exceptions to this requirement shall be specified in Attachment A.
7. Setbacks for land applied bulk residuals shall be as follows:
Setback Description
Setback by residual type
(feet)
Liquid
Cake*
Private or public water supply
100
100
Surface waters (streams — intermittent and perennial,
perennial waterbodies, and wetlands
100
25
Surface water diversions (ephemeral streams,
waterways, ditches
25
0
Groundwater lowering ditches (where the bottom of
the ditch intersects the S
25
0
Wells with exception to monitoring wells
--
Bedrock outcrops
25
0
* Unless otherwise noted in Attachment A, "cake" residuals are those that have greater than 15%
solids by weight and can be stacked without fhyeving, as well as can be handled, transported and
spread as a solid (e.g., using a backhoe, front end loader; Slinger spreader, broadcast spreader or
other equipment designed for handling solid materials) without leaving any significant liquid
fraction behind.
WQ0035777 Version 1.0 Shell Version 111027 Page 2 of 10

8. Bulk residuals and other sources of Plant Available Nitrogen (PAN) shall not be applied in
exceedance of agronomic rates. Appropriate agronomic rates shall be calculated using expected
nitrogen requirements based on the determined Realistic Yield Expectations (RYE) using any of the
following methods:
a. Division's pre -approved site specific historical data for specific crop or soil types by calculating
the mean of the best three yields of the last five consecutive crop harvests for each field.
b. North Carolina Historical Data for specific crop and soil types as provided by North Carolina
State University Department of Soil Science (http://www.soil.ncsu.edu/programLnmQ/yieldsn. A
copy shall be kept on file and reprinted every five years in accordance with Condition IV.6.
c. If the RYE cannot be determined using methods (a) or (b) above, the Permittee may use the RYE
and appropriate nutrient application rates reported in any of the following documents:
i. Crop management plan as outlined by the local Cooperative Extension Office, the North
Carolina Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, or other agronomist.
H. Waste Utilization Plan as outlined by the Senate Bill 1217 Interagency Group - Guidance
Document: Chapter.Ia=://www.enr.state.nc.usIDSWC/pages/eWdance docs.html).
iii. Certified Nutrient Management Plan as outlined by the Natural Resources Conservation
Services (NRCS). These plans must meet the USDA NRCS 590 Nutrient Management
Standards (ftp:bft-fe.sc.egov.usda. ov/NH /practice-standards/standards/590.12dn.
d. If the RYE and appropriate nutrient application rates cannot be determined, the Permittee shall
contact the Division to determine necessary action.
9. The Permittee shall not distribute Class A residuals that have a sodium adsorption ratio (SAR) of 10
or higher without prior written Division approval. The Permittee may seek approval by
demonstrating that the entity accepting the residuals is: aware of the effects of a high SAR content;
has agreed on proper residual application rates; and has agreed to operational considerations to ensure
that the high SAR content will not adversely impact the receiving sites. Recommendations regarding
sodium application rate, soil amendments (e.g., gypsum, etc.) or a mechanism for maintaining site
integrity and conditions conducive to crop growth, can be obtained from the local Cooperative
Extension Office, the Department of- Agriculture and Consumer Services, the Natural Resource
Conservation Service, a North Carolina Licensed Soil Scientist, or an agronomist.
11J. OPERATION AND MAINTENANCE REQUIREMENTS
1. The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards.
2. The Permittee shall maintain ,an approved Operation and Maintenance Plan (O&M Plan) pursuant to
15A NCAC 02T .1110. Modifications to the O&M Plan shall be approved by the Division prior to
utilization of the new plan. The O&M Plan, at the minimum, shall include:
a)
Operational functions;
b)
Maintenance schedules;
c)
Safety measures;
d)
Spill response plan;
WQ0035777 Version 1.0 Shell Version 111027 Page 3 of 10

e) Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including .record keeping and actions -to be
taken by the inspector in the event that noncompliance is observed pursuant to the
noncompliance notification requirements under the monitoring and reporting section of the
permit;
f) Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring,
ii. Detailed description of monitoring procedures including parameters to be monitored;
iii.. Sampling frequency and procedures 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 particular sampling -event. The sampling plan 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 (e.g. 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).
3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in
responsible charge (ORC) and one or more certified operators as back-up ORCs in accordance with
15A NCAC 08G .0201. The ORC or their back-up shall visit the facilities in accordance with 15A
NCAC 08G. 0204, or as specified in the most recently approved O&M plan (i.e., see Condition III.
2.� and shall comply with all other conditions of 15A NCAC 08G. 0204. For more information
regarding classification and designation requirements, please contact the Division of Water Quality's
Technical Assistance & Certification Unit at [phone].
4. When the Permittee land applies bulk residuals, a copy of this permit and a copy of O&M Plan shall
be maintained at the land application sites during land application activities.
5. When the Permittee transports or land applies bulk residuals, the spill control provisions shall be
maintained in all residuals transport and application vehicles.
6. When the Permittee land applies bulk residuals, adequate measures shall be taken to prevent wind
erosion and surface runoff from conveying residuals from the land application sites onto adjacent
properties or into surface waters.
7. When the Permittee land applies bulk residuals, a suitable vegetative cover shall be maintained on
land application sites onto which residuals are applied in accordance with the crop management plan
outlined by the local Cooperative Extension Office, the Department of Agriculture and Consumer
Services, the Natural Resource Conservation Service, or an' agronomist and as approved by the -
+:Division..
8.: Bulk residuals shall not be land applied under the following conditions:
a. If the residuals are likely to adversely affect a threatened or endangered species listed under
section 4 of the Endangered Species Act or its designated critical habitat;
b. If the application causes prolonged nuisance conditions;
c. If the land fails to assimilate the bulk residuals or the application causes the contravention of
surface water or groundwater st-odards;
WQ0035777 Version 1.0 Shell Version 111027 Page 4 of 10

d. If the land is flooded, frozen or snow-covered, or is otherwise in a condition such that runoff of
the residuals would occur,
e. Within the 100-year flood elevation, unless the bulk residuals are injected or incorporated within
a 24-hour period following a residuals land application event;
f. During a measurable precipitation event (i.e., greater than 0.01 inch per hour), or within 24 hours
following a rainfall event of 0.5 inches or greater in a 24-hour period;
g. If the slope is greater than 10% for surface applied liquid residuals, or if the slope is greater than
18% for injected or incorporated bulk liquid residuals;
h. If the soil pH is not maintained at 6.0 or greater, unless sufficient amounts of lime are applied to
achieve a final soil pH of at least 6.0, or if an agronomist provides information indicating that the
pH of the soil, residuals and lime mixture is suitable for the specified crop. Any approved
variations to the acceptable soil pH (6.0) will be noted in this permit;
i. If the land does not have an established vegetative cover unless the residuals are incorporated or
injected within a 24-hour period following a residuals land application event. Any field that is in
a USDA no -till program shall be exempted from meeting this vegetative cover requirement;
j. If the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
k. If the vertical separation of bedrock and the depth of residuals application is less than one foot;
1. Application exceeds agronomic rates.
9. A Utilization Agreement between the Penmittee and the entity agreeing to accept and distribute Class
A bulk residuals shall be in place prior to distribution of the bulk residuals. The agreement shall
specify' the agreeing entity's responsibilities. The Permittee or his designee and the person
responsible for application of the residuals shall sign the Utilization Agreement, which shall be
considered expired concurrent with the permit expiration date, and shall be renewed during the permit
renewal process.
10. At a minimum, the Utilization Agreement shall stipulate the following:
a. By agreeing to accept the bulk Class A residuals, it is recognized that the application of these
residuals is allowed under the conditions of this agreement. Land application of Class A residuals
is considered the beneficial reuse of a waste under 15A NCAC 02T .1100, and has been deemed
permitted under 15A NCAC 02T .1103(4) provided the conditions of this agreement are met. Any
action resulting in damages to surface water or groundwater, caused by failure to follow the
conditions of this agreement, is subject to Division enforcement action;
b. The person or entity accepting the bulk Class A residuals shall to the best of their knowledge
meet the following application requirements:
i. List all prohibitions under Condition III.8 with a statement that bulk residuals shall not be
land applied under these conditions.
ii. Residuals stockpiled for more than 14 days shall be covered;
iii. Application of.bulk residuals shall not occur within 100 feet of a public or private water
supply source;
iv. Application of bulk residuals shall not occur within 100 feet of any well, with the exception
of Division approved monitoring wells;
v. Application of bulk residuals shall not occur within 25 feet of surface waters.
WQ0035777 Version 1.0 Shell Version 111027 Page 5 of 10

c. The generator of the Class A bulk residuals shall provide information on the proper use of the
residuals, including information on the nutrient quantities within the residuals and recommended
application rates. A copy of the label or information sheet attached to bags or other containers, as
specified in the labeling requirements under Condition 111.12, is sufficient;
d. The applicator or party accepting bulk residuals from the Permittee shall supply all third parties
receiving bulk residuals with documentation specifying that application shall occur consistent
with the utilization agreement;
e. Instructions, including contact information for key personnel, shall be provided to the applicator
or party receiving bulk residuals in the event that any requirements specified in the utilization
agreement are not met.
f. A copy of the Utilization Agreement shall be maintained at the land application sites when bulk.
residuals are being applied.
11. All residuals shall be adequately stored to prevent untreated leachate runoff. The finished product
may be placed on a concrete pad, placed under shelter or physically covered until it is distributed to
the buyer. If an alternate storage site is used, approval must be obtained from the Division.
12. A label shall be affixed to the bag or other container in which residuals are sold or given away for
land application, or an information sheet shall be provided to the person who receives Class A
residuals. At a minimum, the label or information sheet shall contain the following.
a. The name and address of the person who prepared the residuals;
b. A statement that residual land application is prohibited except in accordance with the instructions
on the label or information sheet;
c. A statement identifying that this material shall be prevented from entering any public or private
water supply source (including wells) and any surface water (e.g., stream, lake, river, wetland,
etc.);
d. A statement that the residuals shall be applied at agronomic rates and recommended rates for its
intended use.
13. The Permittee shall not distribute bulk residuals to any person or entity known to be applying
residuals contrary to the condition of the signed Utilization Agreement.
IV. MONITORING AND REPORTING REOUTMEM ENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed.
- 2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation -
and Recovery Act (RCRA). The analyses [corrosivity, ignitability, reactivity, and toxicity
characteristic leaching procedure (TCLP)] shall be performed at the frequency specified in
Attachment A, and the Permittee shall maintain these results for a minimum of five years. Any
exceptions from the requirements in this condition shall be specified in Attachment A.
r
WQ0035777 Version.1.0 Shell Version 111027 Page 6 of 10

The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2 Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
0.008
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
-. - Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
L ndane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A,
the Permittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
3. An analysis shall be conducted on the Class A residuals at the frequency specified in Attachment A,
and the Penmittee shall maintain the results for a minimum of five years. The analysis shall include
the following parameters:
Aluminum
Mercury
Potassium
Ammonia -Nitrogen
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite Nitrogen
Sodium Adsorption Ratio
(SAR)
Calcium
Percent Total Solids
TKN
Copper
pH
Zinc
Lead =
Phosphorus
Magnesium
Plant Available Nitrogen
(by calculation)
4. Residuals shall be monitored for compliance with pathogen and vector attraction reduction
requirements at the frequency specified in Attachment A, and at the time indicated in the sampling
---------------
and monitoring sections of t e approved_ Q&M plan The required data shall be specific to the
stabilzatiT o- n`p o ss utilized, and sufficient to demonstrate compliance with the Class A pathogen
reduction requirements in 15A NCAC 02T .1106 (a) and(b) and oeieVectQr attraction reduction
,��,--'-:.,,, ..<,.... J.:� "�� ��--r -;._.� �_.--} a _-�_•' _ - c �-- `�-- -- --- - -"- -- �Lc_
WQ0035777 Version 1.0 Shell Version 111027 Page 7 of 10

S. Laboratory parameter analyses shall be performed on the residuals as they are distributed, and shall
be in accordance with the monitoring requirements in 15A NCAC 02B .0505.
6. The Permittee shall maintain records tracking all bulk residual distribution or land application events
performed by the Permittee. At a minimum, these records shall include the following:
a. Source of residuals;
b. Date of distribution/land application;
c. Name and address of recipient of residuals;
d. Volume of residuals distributed to each recipient;
e. Intended use of residuals;
f. If land application events performed by the Permittee - Nitrogen Application Rate based on
RYEs (if using data obtained from the North Carolina State University Department of Soil
Science Website, the printout page shall be kept on file and reprinted every five years).
7.. Three copies of an annual report shall be submitted on or before March 1'`. The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Reporting
Forms. Instructions for reporting and . annual report forms are available at
hM://portal.ncdenr.org/web/wg/ays/lau/reporting, or can be obtained by contacting the Land
Application Unit directly. The annual report shall be submitted to the following address:
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
8. Noncompliance Notification
The Permittee shall report by telephone to the Winston-Salem 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. Any occurrence with the distribution program resulting in the land application of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the distribution 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 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.
WQ0035777 Version 1.0 . Shell Version 111027 Page 8 of 10

V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan.
2. Prior to each bulk residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport and application facilities to prevent malfunctions, facility deterioration
and operator errors resulting in discharges, which may cause the release of wastes to the
environment, a threat to human health or a public nuisance. 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. The Permittee shall maintain this inspection log .
for a period of - five years from the date of inspection, and this log shall be made available to the
Division upon request.
3. Any duly authorized Division representative may, upon presentation.of credentials, enter and inspect
any property, premises or place on or related to the land application sites or facilities permitted herein
at any reasonable time for the purpose of determining compliance with this permit; may inspect or
copy any records required to be maintained under the terms and conditions of this permit; and may
collect groundwater, surface water or leachate samples.
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
2. This permit shall become voidable - if the residuals land application events are not carried out in
accordance with the conditions of this permit.
3. This permit is effective only with respect to the nature and volume of residuals described in the
permit application and other supporting documentation.
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules
in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4
and under the Division's General Permit NCG010000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
5. In the event the residuals program changes ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner.
6. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110.
7. Unless the Division Director grants a variance, expansion of the permitted residuals program
contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC
02T .0120(b).
WQ0035T17 Version 1.0 Shell Version 111027 Page 9 of 10

8. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A
NCAC 02T .0105(ex3).
Permit issued this the 22nd day of February 2012
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
akild, P. E., Director .
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0035777
WQ0035777 Version 1.0 Shell Version 111027 Page 10 of 10

ATTACHMENT A - Approved Residual Sources
NatureWorks Organics
Residuals Source -Generating Facility
Certification Date: February 22, 2012
Permit Number: WQ0035777 Version: 1.0
Owner
Facility
County
Permit Number
Biological Residuals
Maximum Dry Tons per
ea
Year
Tyson Food, Inc.
Chicken Processing — DAF Unit (Skimmer)
Wilkes
Yes
Total
Class A Residuals Product Generated for Distribution
Owner
Facility Name
County
Permit
Biological
Mgximum
Dry Tons
Monitoring
Frequency for
Monitoring
Frequency for
Monitoring
Frequency for
Pathogen &
Approved
Mineralization
Number
Residuals
Per Year 1
Non -hazardous
Characteristics 2
Metals and
Nutrients 3, S
Vector Attraction
Rate
Reductions','
NatureWorks Organics
NatureWorks Organics, NW
Wilkes
Yes
1,750
Annually
See Table Below
See Table Below
0.4
Total
1,750
t. maximum oryruns per Year is the amount of residuals• approved for distribution from each permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition IV.2.
3. Testing of metals and nutrients as stipulated under permit Condition IV.3.
4. Analyses of pathogen and vector attraction reductions as stipulated under permit Condition IVA, Permit application indicated that Fecal Coliform DensityDemontration will be performed to
meet pathogen reduction requirements, and 38%vY%olatile Solids educti� on�will be erfonnedrt�o meet vector attraction xeduct ans However, other methods listed under 15A NCAC 02T .1106(b)
and .1107(a) can also be used to demonstrate compliance with this permit requirement.
5. Monitoring frequencies are based on the actual dry tons applied per year using the table below, unless specified above.
Dry Tons Generated
short tons per ear
Monitoring Frequency
Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
1/Year
=>319 - <1 650
1/ Quarter 4 times per ear
=>1,650 - <16,500
1/60 Days 6 times per year).
=>16 500
1/month 12 times per ear
If no distribution/land application events occur during a required sampling period (e.g. no land application occur during an entire year when annual monitoring is
required), then no sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data.
Page 1 of 1

Nature Work Organics
1410 2nd Street
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A�QUI}FER PROTECTION SECTION N-cRr Prry f ENR
-.-. APPLICATION REVIEW REQUEST FORM
EB 2012,
Date: February 15 2012 wJ,>stn" Salem
Reglonal offtc*
To: ❑ Landon Davidson, ARO APS ❑ David May, WaRO-APS
❑ Art Barnhardt, FRO-APS ❑ Charlie Stehman, WiRO-APS
❑ Andrew Pitner, MRO-APS ® Sherri Knight, WSRO-APS
❑ Jay Zimmerman, RRO-APS
From: Chonticha McDaniel ❑AFO❑GW Protection❑GW Planning ®LAU
1 -Mail: chonticha.medaniel(a7mcdenr_ aov
Telephone: [phone] Fax:[phone]
A. Permit Number: WQ0035777 B. Owner: NatureWorks Organics
C. Facility/Operation: NatureWorks Organics
® Proposed ❑ Existing ❑ Facility ® Operation
D. Application:
L Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reclaimed . ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
❑ UIC - (SA7) open loop geothermal ❑ Single Family Residence
® Residuals.
Z Project Type: ® New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewalw/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
The applicant had several discussions with Jon Risgaard regarding the Distribution of Class A (protein.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, pleasetake the following actions:
❑ Return a Completed APSARR Form..
❑ BM indicates monitoring wells -locations are not complete. Please update monitoring well
locations not currently in BIMS.
❑ BIMS indicates ongoing ❑ NDMR ❑NDAR ❑ GW monitoring violations. Please investigate
reoccurring compliance issues and summarize results in staff report.
❑ Attach Well Construction Data Sheet.
❑ Process Attachment B for Certification by the Land Application Unit (LAU).
❑ Issue an Attachment B Certification from the RO_*
*coordinating site visits and reviews, as well as additional information requests with other RO-APS
representatives in order to prepare a complete Attachment B for certification. Refer to the RPP .SOP for
the appropriate Central Office -Aquifer Pro Lectimi Section cQontact person listed ahave.
-�.-
RO-APS Reviewer: pa) !" { Date: Z 1 t? l Z—
FORM: APSARR 03/10 Page 1 of 1

Mitchell, Patrick
From: Mcdaniel, Chonticha
Sent: Monday, February 20, 2012 1:29 PM
To: Mitchell, Patrick
Subject: RE: Application W00035777 (Nature Works Organics - Distribution of Class A)
Patrick,
Thank you for the comments. I talked to Mitch Vestal (Owner) last week and his response to my question (similar to
vours #1 question) is that the only source of waste is the skimmer from the DAF unit that treats wastewater from
Chonticha McDaniel,
Environmental Engineer
North Carolina Department of Environment and Natural Resources
Division of Water Quality/Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
Phone: [phone] Fax: [phone] http://Portal.ncdenr.org/web/­wa
DISCLAIMER: Email correspondence to and from this address is subject to the North Carolina Public Records Low and may
be disclosed to third parries unless the content Is exempt by statute or other regulation.
From: Mitchell, Patrick
Sent: Monday, February 20, 2012 12:12 PM
To: Mcdaniel, Chonticha
Cc: Knight, Sherri
Subject: Application WQ0035777 (Nature Works Organics - Distributlon of Class A)
Chonticha,
I have reviewed the application for Nature Works Organics (WQ0035777). I do not foresee any reason to hold up the
application from our point. However, I did have the following general questions:
1. The website for Nature Works Organics states that the source of the protein is from_hog wastes. Do you
know if there will be any hog wastes used at this facility?
I spoke with Zach Key of Southern Soil Builders briefly this morning and he indicated the following: The
waste generated at the Wilkesboro Tyson plant will be the source of protein [approximately 20 tanker
loads/week (6,500 gallons/tanker load)l. The waste is separated into (1) oil to be sold or possibly used in
the heat exchanger; (2) water to be sent to the Wilkesboro WWTP; and finally (3) solids to be "cooked"
and fed to worms in "3' x 200' bays w/ soil in them, The worm waste is then used to generate fertilizer.
�,_Apyy "wormfood" produced that is i- excess of what-tfle-worms can eat gets land'ap;plied ��
I

2. It sounds like they will have no storage available other than sealed dump trucks. Is this okay?
Please let me know if you need anything further.
Thanks,
Patrick
Patrick L. Mitchell, LSS
NC DENR - DWQ
Aquifer Protection Section
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Phone:[phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law.and may be
disclosed to third parties.
2

2. It sounds like they will have no storage available other than sealed dump trucks. Is this okay?
Please let me know if you need anything further.
Thanks,
Patrick
Patrick L. Mitchell, LSS
NC DENR - DWQ
Aquifer Protection Section
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
PJ

Governor
NGIP
r "\ EWR
North Carolina Department of Environment and Natural Resources
Director
February 15, 2012-
Mitch Vestal — Sr. Vice President
Nature Works Organics
1151 Strath moor Circle
Winston-Salem, NC 27104
Dear Mr. Vestal:
Subject: Acknowledgement of
Application No. WQ0035777
Nature Works Organics
Distribution of Residual Solids
(503) System:
Wilkes County
The Aquifer Protection Section acknowledges receipt of your permit application and supporting
documentation received .on February 13, 2012. Your application package has been assigned the number
listed above, and the primary reviewer is Chonticha McDaniel.
Central and Winston-Salem Regional Office staff will perform a detailed review of the provided
application, and may . contact you with a request for additional information. To ensure maximum
efficiency in processing permit applications, the Aquifer Protection Section requests your assistance in
providing a timely and complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as.60 to 90 days
after receipt of a complete application. If .you have any questions, please contact
Chonticha McDaniel at [phone] or [e-mail].
Sincerely,
•j
for Jon Risgaard
Land Application Unit Supervisor
cc: Winston-Salem Regional Office, Aquifer Protection Section
Zach Key -- Southern Soil Builders, Inc.
Permit File WQ0035777
1636 Mail Service Center, tttrleigh, North Carolina 2./699.1636
Locatlon: 512 N. Sallsbury-St., Raleigh, North Carolina 27604 brie ......... .
Phone: [phone] FAX: [phone] -
. �To : Ca�'oliria
Internet wo'namterauali .ora ; t
An Equal Opportunity 1 Affirmative Action Employer��"

February 12, 2012
North Carolina Department of Environmental and Natural Resources
Division of Water Quality
Aquifer Protection Section
512 N. Salisbury Street
Raleigh NC 27604
Subject: Permit Application for the Distribution of Class A Residuals
Nature Works Organics
North Wilkesboro, NC
Good Morning,
Please accept the application enclosed. It is submitted In a collaborative effort with Southern
Soil Builders of Roaring River, NC, You will find that testing supports the application of this
material:
1. As a cake product as described in the Southern Soils Builder's note
I 2. Orin a wetter form to be sprayed when available
The processing is identical as you will find in the flowchart included in application packet.
Either form (liquid or solid) will be applied In an agronomic manner as not to overload the soil
and cause contravention of the surface or groundwater standards, limit crop growth, or
adversely impact soil quality.
We will certainly appreciate a quick consideration of this request and are prepared to respond
to any question in a timely fashion.
Warm Regards,
Mitch Vestal
Senior Vice President, Business Development
Nature Works Organics
Nature Works Organics ° 4.140 Clemmons Road • Clemmons NC o 27104•

I �
I ,
S Southern
Soil
B Builders, Inc.
Friday, February 10, 2012
958 Hoots Road Roaring River, NC 28669
[phone] 9 Fax [phone]
North Carolina Department of Environmental and Natural Resources
Division of Water Quality
Aquifer Protection Section
512 N, Salisbury Street
Raleigh, NC 27604
Sqbject: Permit Application for the Distribution of Class A Residuals
Nature Works Organics
North Wilkesboro, NC
Enclosed you will find the permit application for the distribution of class A residuals from the Nature
Works Organics facility at 1014 2"d Street North Wilkesboro, NC 28659.
This distribution of class A residuals will occur using dump trucks/trailers and cake spreaders. The
material will be given away to local land owners and farmers as a soil amendment. The residuals will be
land applied in an agronomic matter as not to: overload the soil and cause contravention of surface
water or groundwater standards, limit crop growth, or adversely impact soil quality.
Your prompt attention to the permit application will be greatly appreciated. If you have any questions or
concerns, please contact me at [phone] or at [e-mail]
Sincerely,
?chKey
Southern Soil Builders, Inc.

WA rp
O.a..•X w,z9� State ofNo.rtli Carolina
Department of Environment and Natural Resources
a; r Division of Water Qualify
L `='1>r'-• _^.•.>. DISTRIBUTION OF CLASS A RESIDUALS
INSTRUCTIONS FOR FORM: DCAR 01-.12
Please use the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these
instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of additional
information requested. Failure to submit all of the required items will lead to additional processing and review time for the
permit application. Unless otherwise noted, the Applicant shall submit one original and two copies of the application and
supporting documentation
For nnore, inforrnation or.f , an electronic version q/7his form, visit the Land Applicati m Unit (LAU) web site at:
Llm ri�lurtcr(..si'linr
General — This application is for treatment, storage, transport, distribution, land application, and/or marketing of Class A (or
Equivalent) residuals under 1 iA NCAC
Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed
below.
A. Distribution of Class A Residuals (FORM: DCAR 08•-11):
❑ Submit the compieted and appropriately executed Distribution of Class A Residuals (FORK DCAR 08-1 1) form. Please do
not make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachment's to
the application may be made, as long as the attachments are numbered to correspond to the section and item to which they
refer.
❑ The project name should be consistent on the plans, specifications, etc.
❑ The Applicant's Certification oil Page 3 of this form shall be signed in accordance with.15.1__�;QC;,_•03�i.,0.1•(:!(l(b). An
alternate person may be designated as the signing official if a delegation letter is provided from a person who meets the
criteria in 1 5 A._NC-�C Q2T .0l
❑ ll'this project is for a modification of an existing permit, submit one copy of the existing perinit.
❑ Please submit this application form at least 180 days prior to the expiration date on the existing permit, or 90 days prior to
operation of proposed facility(ies) for application packages involving new or changes to treatment and storage units.
B. Application Fee (New and Major Modification Application Packages)
❑ Submit a check, money order or electronic funds transfer made payable to: North Carolina Department of Environment and
Natural Resources (NCDEN.R).
❑ STANDARD REVIEW -- Submit the appropriate fee for all new and major modification applications as listed in the table
below.
❑ EXPRCSS REVIEW —Visit the Express Review webpage for the C:�ress ee Schcciulr.:
STANDARD APPLICATION REVIEW FEES:
Facility Classification New Permit Major Modification'
Major (residuals permitted far distribution ? 3,000 dry tons/year) $1,310 $395
Minor (residuals permitted for distribution < 3,000 dry tons/year) $810 $245
r - A major modification shall be defined as any permit modification that: increases the generating facility's residuals dry tonnage;
adds additional residuals sources; or includes the addition of new treatment or storage units/processes not previously permitted.
There is no fee for minor pennit modifications.
C. Cover Letter (All Application Packages)
❑ List all items included in the application package, as well as a brief description of the requested permitting action.
INSTRUCTIONS FOR FORM; DCAR 01-1.2 Page I of

D. Program Information (All Application Packages)
❑ I rovide a narrative explaining the following:
❑ How the materials will be handled and transported from where the residuals were produced to where it will be treated.
❑ Flow the residuals will be processed/treated (attach. process flow diagram).
❑ How leachate collection wild be handled.
❑ Where the residuals willl be stored until processed_
❑ How the 'final product will be distributed (packaging, bulk, etc.)
❑ What nutrients or other constituents (i.e. nitrogen, phosphorous, altnniuum, calcium, etc.) are used or recommended as the
limiting parameter for determination of residuals loading rate to ensure that it does not overload the soil and cause
contravention of surface water or groundwater standards, limit crop growth; or adversely impact soil quality.
❑ Attach a marketability statement detailing destinations and approximate amounts ofthc final product to be distributed.
❑ Provide either a label that shall be affixed to the bagged processed residual or an information sheet that shall be provided to
the person who receives the processed residual. The label or information sheet shall contain, at a minimum, the following
in formation:
❑ Name and address of the person who prepared the residual that is sold or given away.
❑ A statement that application of the residuals to the land shall be in accordance with the instructions on the label or
information sheet.
❑ A statement that the residuals shall not be applied to any site that is flooded, frozen or snow-covered.
❑ A statement that adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored
residuals into any surface waters.
❑ Information on all applicable setbacks in accordance with .1 SA..NC rlC' U? 1.:_
❑ A statement that the residuals shall be applied at agronomic or recommended rates for intended Uses.
E. Detailed Plans and Specifications (Application Involving New or Changes to Treatment or Storage Units)
❑ Submit detailed plans and specifications that have been signed, sealed, and dated by a NC Professional Engineer per
INC_AC 02T .1.1 Specifications for standard equipment may oily be otnitted for municipalities with approved standard
specifications, but use of the standard specifications must be noted on each sheet of the plans.
❑ Plans must include the following minimum items: a general location map, a topographic snap, plan and profile view of the
residuals treatment and storage units as well as tide proximity of the residuals treatment and storage units to other utilities and
natural features within 500 feet of all treatment and storage facilities, and detail drawings of -'all items pertinent to the residuals
treatment and storage units. Depict minimum separations required in 1.5A NCAC_02'f on the plans_
❑ Specifications must include, at a minimum, the following for all items pertinent to residuals treatment and storaoc units:
description of materials to be used, methods of construction, quality of construction testing procedures to ensure the integrity
of the final product in, accordance with 15 ';NCAC 0;"1'_ 1.1._l.(13), including leakage and pressure testing as appropriate.
❑ Plans and specifications must notbe labeled with preliminary phrases (e.g., FOR itE:VIEW ONLY, NOT FOlZ
CONSTRUCTION, etc.) that indicate that they are anything other than final plans and specifications. However, the plans and
specifications may labeled with the phrase. FINAL DESIGN — NOT .RELEASED FOR CONSTRUCTION—
F. Engineering Calculations (Application involving New or Changes to Treatment or Storage Units)
❑ Submit all design calculations that have been signed, sealed, and elated by a NC Professional Engineer per 1 tir...Nc;__lc:' f),,.- 1
C. Environmental Assessments (Maybe Required— See 15A NC;.AC. 1C_ t1;DU)
❑ Submit a copy of the Findings of No Significant Impact (FUNS[) or Environmental Impact Statement (EIS). Also, include
information on any mitigatbig factor(s) from the Environmental Assessment (EA) that impact the construction of: the residuals
treatment and storage facilities. An. EA may also be required for private systems if any public funds andlor lands are used for
the construction of the subject facilities.
H. Operation and Maintenance Plan (New and Renewal Application Packages)
❑ For Modification Application, if -there are any changes to the existing plan, submit an updated O&M plan.
❑ Submit the O&M Plan in accordance with i_5 A .N("AQ, Un:f,�_, 1._1_10 and include at a minimum:
❑ Operational functions; describe the operation of the program to show what operations are necessary for the program to
function and by whom the functions are to be conducted.
INSTRUCTIONS FOR FORM: DCAR 01-12 Page 2 of 3

❑ Maintenance schedules; may include equipments calibration, maintenance of signs, etc,
❑ Safety measures; may include safety training program, manuals, signs, etc.
❑ Spill response plan; including control, containment, remediation, emergency contact information, etc.
❑ .Inspection plan including the following information;
❑ Names and titles of personnel responsible for conducting the. inspections.
❑ Frequency and location of inspections, including those to be conducted by the ORC, and procedures to assure that the selected
location(s) and inspection fi•equency are representative of tite residuals management program.
❑ Detailed description of inspection procedures including record keeping and actions to be taken by the inspector in the event
that noncompliance is observed.
❑ Sampling and monitoring plan including the following information;
❑ Names and titles of personnel responsible for conducting the sampling and monitoring.
❑ Detailed description of monitoring procedures including parameters to be monitored.
❑ Sampling frequency and procedures to assure that representative samples am being collected. Fluctuation in temperature,
flow, and other operating conditions can affect the quality of the residuals gathered during a particular sampling event. The
sampling plan sball account for any foreseen fluctuations in residuals quality and indicate the most limiting times for residuals
to meet pathogen and vector attraction reduction requirements (e.g. 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.
ONE ORIGINAL AND TWO COPIES OF THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION AND MATERIALS, SHALL BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
LAND APPLICATION UNIT
By U.S. Postal Service:
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636
TELEPHONE NUMBER: [phone]
OY Courier/Special Delivery:
512 N. SALISBURY STREET
RALEIGH, NORTH CAROLINA 27604
FAX NUMBER: [phone]
INSTRUCTIONS FOR FORM; DCAR 01-I2 Page 3 of 3

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
DISTRIBUTION OF CLASS A RESIDUALS
FORM: DCAR 01-12
4 1. APPLICANT INFORMATION:
a
1. Applicant's name: Nature Works Organics
Applicant type: 0 Individual Z Corporation ❑ General Partnership F] Privately -Owned Public Utility
OFederal E3 State ❑ Municipal n Count
Signature authority's name per.1 5A NC'_ C 02 1',0 106: Mitch Vestal Title: Senior Vice President
Applicant's mailing address: 4140 Clemmons Road Suit 296
City: Clernmons State: NC Zip: 27012
Telephoneriumber: [phone] Email Address: nigvestal(@,ilaatmwoi,ksorgariies.com
2. Consultant's name: Zach ley License Number (for P.E.):
-in: Southern Soil builders', Inc.)
AfF ation: El On Staff Retained (Fit
Consultant's mailing address: 958 Hoots Road
City: Roaring River State, NC Zip: 28669-9148
Telephone number: [phone] Ernail Addi,ess:,zachkey((Dsouthei-asoilbiLilders,com
3. Fee submitted: 810.00 (See Instruction B)
11. PERMIT INFORMATION:
1. Application is for (check all that apply): Z new, El modified, El renewed pert -nil
2- If this application is being Submitted to renew or modify an existing permit, provide the following;
Permit ]lumber:
Date of most -recently issued permit:
Date of most -recently certified Attachment- A (if diffierent than the permit):
Ill. FACILITY INFORMATION:
I Name of residuals processing -facility: Nature Works Organic
City: North Wilkesboro State: NC Zip: 28652
Coordinates: Latitude; 36.170498 Longitude: -81.140004
Datum; NAD 83 Level Of accuracy: 0.001
Method of measurement: GPS
County where facility is located: Wilkes
2. Facility contact (person familiar with residuals preparation):
FEE3 t
Name: Mitch Vestal Title: Senior Vice President
Mailing address: 4140 Clernmons Road Spit 296
City: Clommons Road State: NC Zip: 27012
Telephone number: [phone] E-mail address: ineyesta.l((4i.iatureworksot-ganics.coiii
FORM: DCAR 0 1- 12 Page I of 3

3. is tite residual process facility also the generator? ❑ Yes; ® No
If No, please specify delivery frequency and quantity ofresidual to be processed: 20,000 gallons daily
4. Length of residuals storage at facility: 30 days (Note: the Division requires minimum 30 days storage in units that are separate
from treatment system, i.e. not. in clarifiers, aeration basins, etc.)
IV. RESIDUALS QUALITY INFORMATION:
l . Specify how these residuals wi I be distributed:
❑ sold or given away in bags or other containers; ❑ lawn (bulk); ❑ horne garden (bull:);
® other (explain); Given awav through land application
Note: Bulk residuals shall mean residuals that are transported and not sold or giving away in a bag or other receptacles with a
load capacity of one metric ton or less,
2. Complete the following if residuals are to be mixed with other materials:
Type of Materials AMOn11tS to be added
per 1.0 dry ton of residuals (dry ton)
3. Approximate amounts of the residuals received and processed at the facility: 1,750 dry tons per year.
4. Approximate amounts of the final product (processed residuals) to be distributed: 1,750 dry torts per year.
i
5. Provide a description of the onsite storage management plan for the treated residuals (including estimated average and
i
maximum storage times prior to distribution): All residuals produced will either be used as worm food or will he loaded onto
a sealed damp trailer. The dump trailer will be then taken to a local farm for land application it weather does not permit land
application all the residuals will be used as worm food or taken to Wilkes County land Fill.&
G. Does the facility have a stormwater management plan? ❑ Yes: E No
l-
.xplain whether the treatment and storage areas are under roof or how storul water runoff will be handled: All residuals
produced will be stored inside a sealed durnp trailer
V. RESIDUALS SOURCE INFORMATION: (Not required if no new, renewed, or modia'ied residuals source)
Complete and submit the attached Residuals Source Cap iff7c ition and all associated documentation.
Residuals Source
Certification

I
I Professional Engineer's Certification-.(AppIication. Involving New or Changes to Treatment or Storage Units)
[, attest that this app.] icati.on for
has been reviewed by me and is accurate and complete to the best of my knowledge. 1 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 l 5A_NC_AC:. 02T.U._10 .
Fy Yes ❑ No, Explain;
C L Ile
(Signature Authority's Name-- PLEASE PRINT) (Title)
attest that this application for
(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 Quality
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. T will make no claim against the
Division of Water Quality 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 attacbrrients 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 §1.43-21.5.613, 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: -�/ V_, > Date: ;/z / fT
i;.. t 1 i.;:a�Jai r °.;LlV;l
FEB iilaj
FORM: DCAR 01-12 Page 3 of 3

Operation and Maintenance Plan
Nature Works Organics
I In accordance to the requirements set forth by the North Carolina
Department of Environmental and Natural Resources using NCGS 143-
215.1 and 143-215.3(a) based oft 15A NCAC 02T .110, Nature Works
Organics and Southern Soil Builders, Inc. is implementing this Operation
and Maintenance Plan.
The project manager of. the distribution event will make sure a daily check
off is performed at the start of each work day. This inspection is to prevent
any spills, leaks, or run-offs...
The daily 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 teak 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.
7. All equipment will be calibrated per outline in the owner's
manual of each piece of equipment.
The ORC or back up ORC will inspect fhe field after each distribution
evelit to make sure all regulation's as required.by the -permit are followed. .
Also the project manager at the end of each working day during a land
. pplicatiori event will make sure that all gates if present are closed.

= The following procedures will take place in the unlikely event of a spill:
SPILL CONTROL PLAN- Southern Soil Builders Inc.
Nature Works Organics
In the event of a spill, the following should be taken IMMEDITALY.
1. Halt the source of the spill- overturned truck, leaking valve, ruptured
tank.
2. Contain the spill. Use straw bales or earthen barrier to forma dike to
contain the spill.
3. 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.
4. Flush the roadways with water if needed. If the spill occurred on a
tillable area, till the same into 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.
5. Notification. (This should be done as soon as safely possible.)
A. Southern Soil Builders, Inc. Main Office [phone]
B: Mature Works �?rga�nics- Mitch Vestal�33.6-499=7353��
C. NCDENR, Winston Regional Office [phone]
D. County Emergency Services (Sheriff, Fire Dept.) 911
6. Reporting. The project manager shall detail how the spill occurred
and all action that was taken. A written report shall be given to the
Asheville regional office as soon as possible, and within 24 hours of
the spill, or next working day.
7. 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.

All samples shall be taken as early as possible before the first application
event of the calendar year to make sure the facility is compliance.
The samples will be taken in a matter that is representative of the residuals
and all grab samples will be mixed prior to be placed in to the containers
that will go to the laboratory. These samples must be collected and
transported as outlined in the Sampling Plan attached to this O&M Plan.
All records of these laboratory results as well as the annual report and
loading rates will be kept on file for a minimum of five (5) years.
All recipients of the alum residuals will receive a copy of the product
information label attached with this O&M Plan

C. Inspect ail seals and replace if necessary,

Nature Works Organics
SAMPLING PLAN
Quarterly, if a distribution event occurs, grab samples are collected before the heat exchanger,
after the heat exchanger and off the centrifuge. These Samples will be sent to a laboratory for analysis.
If a distribution event is to occur in the early part of a calendar year (i.e. January or early February) these
samples may have to be taken in December so results can be obtained before the land application
event, as some results take 30+ days to receive.
These individual grab samples are collected and tested for fecal coliform analysis, nutrient
analysis, Vector Attraction, and a TCLP test. These tests will be taken by Zach Key of Southern Soil
Builders, Inc, All samples with the exception of the composite residual sample will be taken to
Statesville Analytical, the composite residual sample will be sent to A&L Eastern Laboratory: All samples
taken will be taken in the same condition as the residuals are to be land applied.
Fecal Coliform is gather in seven (7) individual samples and tested to meet the requirements of
[503.32(b)(2)]. This requirement is for the geometric mean fecal coliform density of the samples be less
than one thousand (1,000) MPN per gram. These samples will be placed in 250ml containers and placed
on ice, in a cooler for transport to the laboratory before 1600 hours (4pm) the same day the samples are
obtained.
The Vector Attraction samples will be placed into 250ml containers and placed on ice, in a cooler
for transport to the laboratory before 1600 hours (4pm) the same day the samples are obtained.
Quarterly, 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 digester.

Annually, a composite TCLP sample will be collected to include:
Flresenic
l-lexachlorobenzene
Barium
l-lexachloro-1, 3-Butadiene
Benzene
Hexachloroethane
Cadi urn
Lead
Carbon Tetrachloride
Lindane
Chlordane
Mercury
Chlorobenzerie
Methoxychlor
Chloroform
Methyl Ethyl Ketonc
Chromium
Nitrobenzene
M-Cresol
l'entachlorophenol
O-Cresol
Pyridine
11-Cresol
Selenium
C: reso I
Silver
4-D
Tetrachloroethylene
! #, 4-Dichlorobenzene
Toxaphene
PH forCorrosivity
Flash point for ignitability
Sulfides and Cyanides for reactivity
l ,2-Dichloroethane
I <1-Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor and its Hydroxide
`i'richloroethylene
2, 4, 5-Trichlorophenol
2, 4, 6-Trichlorophenol
2, 4, 5-1'P (Silvex)
Vinyl Chloride
I -his sample must Gonlain at team Two t2) g?Mons ()v proper analysis to take place.

Product Information:
Residuals produced from:
Nature Works organics
Mailing Address:
4140 Clemmons Road, Suite 296
Clemmons, NC 27012
Facility Address;
1014 2"d Street
North Wilkesboro, NC 28659
• This product contains plant nutrients such as nitrogen and aluminum and can be used as a soil
amendment. phis material has beenn proeessed in acc_ord_an_ce with EPA guidelines:aChemical
composition of this product is such that it does not exceed pollutant ceiling concentrations
• This material shall not be applied to any site that Is frozen, snow-covered or flooded, It shall not
be applied within 10 feet of any public or private water supply source (including wells) and any
stream, lake, river, or natural drainage way.
• For current analysis and appropriate loading rates for farmland application, contact;
Southern Soil Builders, Inc,
958 Roots Road
Roaring River, NC 28669
Phone [phone]
zl<[e-mail]
• Application of this material to the land is prohibited except in the accordance with the
instructions on this label. Use of this material should conform to the recommendations of the
current analysis and loading rates.

r \ AT��R
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
RESIDUALS SOURCE CERTIFICATION
INSTRUCTIONS FOR FORM: RSC 08-11
Please use the following instructions as a cliecklist in order to ensure all required Items are submitted. Adherence to these
instructions and checking tite provided boxes will help produce a quicker review time and reduce file amount of additional
information requested. Failure to submit all of the required items will lead to additional processing and review time for the
permit application. Unless otherwise noted, the Applicant shall submit one original and two copies of the application and
supporting documentation
For more irrrortnation orfor an electronic version o 'this• jbi-In, visit the Lai7d application Unit (LAU) ,veb site nt:
I71f%�. '7(il't(tI.11C'((G'14r.01„'f�l,refl/_4tki!�t�+.tiilcrtr
General — This certification provides detailed information of residuals source generating facility and its residuals quality 1'or land
application, distribution, or disposal in accordance with ,15A NCAC:, 02T11 I Q0. Do not submit this certification for review without
a corresponding application form (FORM: RLAP 08-11, FORM: IDCAR08-.11, or FORM: SDR 08-1.1).
Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed
below.
A. Residuals Source Certification (FORM: RSC 08-I1):
❑ Submit the completed and appropriately executed Residuals Source Certification (FORM: RSC 08-1 1) form. Please do not
make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachments to the
application may be made, as long as the attachments are numbered to correspond to the section and item to which they refer.
❑ For new or renewed permits, submit a separate certification for each source facility.
❑ For modified permits, submit a separate certification for only those facilities that are affected by tile proposed modification.
❑ 'Complete the residuals source facility summary page. List all new, renewed, or modified facilities.
B. Residuals Source -Generating Facility information:
❑ For each source facility, attach the following:
❑ Vicinity map - A vicinity map that shows the location of the facility and meets all of the criteria in the " 411) (.1_uici_�},r
han tern,;{>.'
❑ Process flow diagram and/or narrative - A detailed narrative and/or process flow diagram that describes how the residuals
are to be generated, treated, processed, and stored at the facility.
❑ Quantitative justification for residuals production rate - A quantitative justification for the value provided in Item 1. 8.
Ensure that the amount of residuals listed is the maximum amount expected to be generated by the facility for the life of
the permit. In addition; ensure that this amount is equivalent to that which is actually to be land applied, distributed,
and/or disposed, including any chemicals, amendments, or other additives that are added to the residuals during
processing.
❑ Sampling plan - A detailed sampling plan for the residuals source -generating facility. Ensure that the plan identifies
sampling points, sampling frequency, sample type, as well as the Division -certified laboratory to be used. In addition,
ensure that the plan details how the facility and/or the residuals are monitored for any applicable pathogen reduction and
vector attraction reduction requirements. Note that all sampling and monitoring must be completed on the residuals as
they are to be land applied, distributed, and/or disposed.
C. Residuals Quality Information:
❑ For each source facility, attach the following:
❑ Laboratory analytical reports and operational data - reports for all laboratory analyses used to complete this certification.
❑ Documentation that the facility complies and/or the residuals comply with any applicable pathogen reduction and vector
attraction reduction requirements.
❑ For new facility that may have not yet been constructed and analytical results of residuals cannot be obtained, please
attach analytical results of residuals generated from a. similar facility along with the description of similarities of the two
facilities.
INSTRUCTIONS FOR FORM: RSC 08-11 _ -y4t (j);j?i Page I of 1
C t-

RESIDUALS SOURCE FACILITY SUMMARY
Applicant's name: Nature Works Or as-iies
Status Maximum Dry Tons Per Year
Code' Facility Permit Holder Facility Name I County Permit Number
Current b Proposed
N Nature Works Organics i Nature Work Organics, NW Wilkes I 1,750
a Status Code for source facility are: + N (New) + R (Renewed) + M (Modified) ♦ D (Deleted)
"The amount of residuals currently permitted for distribution, land application, or disposal (i.e. not applicable to new facility).
SUMMARY FOR FORM: RSC 08-11
Paue i

f forte I yse"v1 �c� ����
Wastewater arrives
!s to tank._
Chopped to pass
through 1/4 inch
screen
Centrifuge
generates
three streams
I fats 2.Solids
3.water
Centrifuge
Sent to heat
exchanger and Centrifuge separates
heated 200 - 212 fats, solids and water
^� -*To land Application_
No vA-9.1
Pelletized
fertilizer
produced r nV�7
To land application --
added to solids stream
wavins

of y A f
'' State of North Carolina
De
Y art►nent of Environment and Natural Resources
4
$
> i 1 r Division of Water Quality
J
RESIDUALS SOURCE CERTIFICATION
FORM: RSC 08-1 l
1. RESIDUALS SOURCE -GENERATING FACILITY INFORMATION (See Instruction B.):
1. Facility Name: Nature Worl(s Oreanics
2. Facility permit holder is: ❑ Federal, ❑ State, ❑ Local Government, or ® Private.
Facility permit issued by: ❑ Div. of Water Quality, ❑ Div, of Environmental .Health,
or ❑ Other (explain:
3. Facility contact person and title: Mitch Vestal
Complete mailing address: 4140 Clemmons Road Suit 296
City: Clemmons State: NC Zip; 28359
Telephone number: QU6 998-3170 E-mail address: nt vestal@natureworksorcanies coin
4. Facility physical address: 10.14 2" � Street
City: North Wilkesboro State: NC Zip: 28659
Coordinates: Latitude: 36.170488 Longitude:-81.140004
Datum: NAD 83 Level of accuracy: 0.001
Method of measurement: GPS
5. Purpose of the facility:
❑ treatment of municipal wastewater, ❑ treatment of 100% domestic wastewater,
❑ treatment of potable water, ® treatment of 100% industrial wastewater,
❑ treatment of industrial wastewater mixed with domestic wastewater,
(approximate percentages: % industrial and % domestic)
❑ other (explain: ).
6. Does the facility have an approved pretreatment program: ❑ Yes ® No
7. Facility permitted/design flow: MGD and facility average daily flow: 0.019 MGD
8. Average amount of residuals being generated at this facility 1750 dry tons per year.
9. Specify the following regarding treatment and storage volumes available at the .facility:
Type and volume of residuals treatment: Heat exchanaer and centrifuge
Type and volume of -residuals storage (i.e., outside ofresiduals treatment units): All residuals made will be stored in sealed
dump trailers or used for worm food.
11. RESIDUALS QUALITY INFORMATION (See Instruction C.):
1. Specify if residuals are regulated under:
❑ 40 CFR Part 503 or ® 40 CFR Part 257.
Note; Only residuals that are generated during domestic/municipal wastewater treatment processes are regulated tinder 40
CFR Part 503, otherwise, the residuals are regulated under 40 CFR Part 257,
2. Specify if residuals are defined under 15A NCA(,; O?_i, l 102(6) as:
® Biological ❑ Non -Biological
FORM: RSC 08-1 1 Page 1 of 5

Note: Biological residuals are residuals that have been generated during the treatment of domestic wastewater, animal
processing wastewater, or the biological treatment of industrial wastewater (biological treatment is a system that utilizes
d biological processes including lagoons, activated sludge systems, extended aeration systems, and fixed film systems).
3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non -hazardous under
RCRA: (Note - this item does not have to be completed For facilities that are less than 0.5 MGD in design flow that treat
100% non -municipal, domestic wastewater only)
a. Are the residuals listed in 40 CFR §261.31-§261.33: ❑ yes ® no.
If yes, list the number(s):
b. Specify whether or not. the residuals exhibit any of the characteristics defined by 40 CFR §261.21-
261.24: ❑ yes ® no.
Fill in the following tables with the results of the latest toxicity characteristic leaching procedure (TCLP) analysis as
tvel I as those for corrosivity, ignitability, and reactivity:
Laboratory; Summit and Date of analysis: 1-17-2012
Passed conosivity test: ® yes . ❑ no. pl•1: sm. (2 < pH < 12.5)
Passed ignitability test: Z yes ❑ no. Flashpoint: >200 °F (> 140T)
Passed reactivity test: ®yes ❑no. FICN: ND nig/kg (<250) & Iq,;S:.ND tng/kg, (•,500)
TCLP Parameter
Limit
(rng/1)
Result
NO)
TCLP Parameter
Limit
(mg/1)
Result
0119/0
Arsenic
5.0
ND
Hexachlorobenzene
0.13
0.1
Barium
100.0
ND
Hexachloro-1,3-Butadiene
0.5
0.1
Benzene
0.5
0.1
[4exachloroetliane
3.0
0,1
Cadmium
1.0
ND
Lead
5.0
ND
Carbon Tetrachloride
0.5
0.1
Lindane
0.4
0,002
Chlordane
0.03
0.01
Mercury
0.2
ND
Chlorobenzene
100.0
0.1
Methoxychlor
10.0
.002
Chloroform
6.0
0.1
Methyl Ethyl Ketone
200.0
2
Chromium
5.0
ND
Nitrobenzene
2,0
0.1
m-Cresol
200.0
5
Perttach.lorophenol
100.0
0.25
o-Cresol
200.0
5
Pyridine
5.0
0.25
p-Cresol
200.0
5
Selenium
1.0
ND
Cresol
200.0
5
Silver
5.0
ND
2,4-D
10.0
5
Tetrachloroethylene
0.7
0.1
1,4-Dielilorobenzetie
7.5
0.1
Toxaphene
0.5
0.1
1,2-131chloroethane
0.5
0.1
Trichloroethylene
0,5
0.1
l,l-Dichloroetliylene
0.7
0.1
2,4,5-Trichlorophenol
400.0
0.25
2,4•Dinitrotoluene,
0.13
0.1
2,4,6-Trichlorophenol
2.0
0.25
Endrin
0.02
0.002
2,4,5-TP (Silvex)
1.0
0.5
Heptachlor and its Hydroxide
O.fl08
<0.002
Vinyl Chloride
0.2
<0.2
FORM: RSC 08-11 Page 2 of 5

r
4, Metals Determination: Complete one of the following tables (i.e., as applicable) to demonstrate that the residuals do not
violate the cei ling concentrations for metals regulated under 15A NQAC' 0_]', 1 105.
a. For Distribution/Land Application: Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
.Laboratory: A&L Labs and Date of analysis: 1-11-2012
Parameter
Ceiling
Concentration Units
(ClassA & ClassB)
(mg/kg)
Monthly Average
Concentration Units
(Class A Only)
(Mg/leg)
Result
(rrxgJkg)
Arsenic
75
41
2.0
Cadmium
85
39
1
Copper
4,300
1,500
34
Lead
840
300
5
Mercury
57
17
0.4
Molybdenum
75
nla
5
Nickel
420
420
7
Selenium
100
100
2
Zinc
F 7,500
2,800
69
b. !'i,! Surface Disposal Unit (landfill): Fill in the following table with the results of the latest analyses (i.e„ on a dry weight
basis) for the following .metal parameters:
Laboratory: and Date of analysis:
Distance from Disposal
Unit to Boundary to
Closest Property Line
(meters, check one)
Arsenic
(rng/kg)
Chromium
(mg/kg)
Nickel
(mg/kg)
❑ > 0 but < 25
30
200
210
❑ > 25 but < 50
34
220
240
❑ > 50 but < 75
39
260
270
❑ :> 75 but < 100
46
300
320
-- ❑ '^ > 100 but < 125
53
360
390
❑ > 1.25
62
450
420
Result (rng/kg)
FORM: RSC 08-1 1 Page 3 of 5

5. Nutrient/Micronutrient Determination: Complete the following:
a. Total solids: 5.75 %.
b. Fill in the ibIlowing table with the results of the latest analyses (i.e., on a. dry weight basis) for the following nutrient and
rnicronutrient. parameters:
Laboratoiy: A&L Labs and Date of analysis: 1=11-2012
Parameter
Result
(rng/kg}
Aluminum
500
Ammonia -Nitrogen
661.0
Calcium
848
Magnesium
178
Nitrate -Nitrite Nitrogen
29.6
pH (Standard: Unit)
4.37
Phosphorus
5060
Potassium
857
Sodium
1240
Total KJeidahl Nitrogen
70400
c. Using the results listed in Item 11. 5b. above, calculate the sodium adsorption ration (SAR): 224
[Note: If residuals contain SAR of 10 or higher, the applicant shall. obtain recommendations from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation. Service, a
North Carolina .Licensed Soil Scientist, or an agronomist, prior to land application of residuals. The recommendations shall
address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a mechanism for maintaining site integrity
and conditions conducive to crop growth].
d. Specify the mineralization rate to be used in calculating the plant available nitrogen (PAN) of the residuals: 40 %. This
rate is a (check one): ® default value, or EJ actually established.
If the residuals are not generated from the treatment of municipal or domestic wastewater, explain or provide technical
justification as to why the selected default value is appropriate to be applied to these residuals: Default for unstabilzed
secondary residuals
e. Calculate the PAIN for the residuals (i.e., oai a dry weight basis) and fill the results in the following table:
Application Method
First (0) Year PAN
rive -Year
Maximum Adjusted PAN
(mg/kb')
(Mglkg
Surface
28850.6
45006.9
Injection/incorporation
32155.6
50162.7
6. Other Pollutants Determination: Specify whether or not there are any other pollutants of concern in the residuals and provide
the results of the latest. analyses:
FORM: RSC 08-1 1 Page 4 of 5

7. Patlio%rcn Reduction: Per 15A NCAQ 02TA 106, specify how residuals will meet the pathogen reduction requirements:
a. For DistribudonlLand Application. of Class A or F.qulyalent.
A fecal coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry solids,
or
❑ A salmonella sp. density that is demonstration to be less than 3 MPN per 4 grams of total dry solids.
AND one of the followings (except .for non -biological residuals):
❑ AIternative 1 [I 5A NCAC 02T.1106(b)(3)(A)] -Time/Temperature Compliance.
❑ Alternative 2 [15A NCAC 02T.1106(b)(3)(B)] -Alkaline Treatment_
❑ Alternative 3 [15A NCAC 02T.1106(b)(3)(C)] - Prior Testing for Lateric Virus/Viable Relminth Ova.
❑ Alternative 4 [ 15A NCAC 02T.I 106(b)(3)(D)] - No Prior Testing for Enteric Virus/Viable Helrninth Ova.
❑ Alternative 5 [15A NCAC 02T.I 106(b)(3)(E)-(K)] - Process to Further Reduce Pathogens (PFRP).
Specify one: ❑ composting, ❑ heat drying, ❑ heat treatment,
❑ thermophilic aerobic digestion, ❑ beta ray irradiation,
❑ gamma ray irradiation, or ❑ pasteurization.
b. for Land Application of Class B:
❑ Alternative.[ [I5A NCAC 02T.1106(c)(1)] - Fecal Coliform Density Demonstration.
❑ Alternative 2 [15A NCAC 02T.1106(c)(2)] -Process to Significantly Reduce Pathogens (PSRP).
Specify one: ❑ aerobic digestion, ❑ air drying, ❑ anaerobic digestion,
❑ composting, or ❑ line stabilization.
c. f'or Surface Disposal:
❑ Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item 11. 7a. above.
❑ Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item 11. 7b. above.
❑ .Exempt - If Daily Cover Alternative is chosen in Item 1.1.8. below [ 15A NCAC 02T. 1106(a)(2)].
[I Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
8. Vector Attraction leduction (VAR): Per.] 5A NCAC 02; f _l_I 07, specify how residuals will meet the VAR requirements:
® Alternative I [15A NCAC 02T.I 107(a)(1)] - 39% Volatile Solids (b11> robtc/AriaetablclLlt�+cstionuj.
❑ Alternative 2 [15A NCAC 02T.I 107(a)(2)] - 40-Day Bench Scale Pest (Anaerobic Digestion).
❑ Alternative 3 [15A NCAC 02T.1 107(a)(3)] - 30-Day Bench Scale Test (Aerobic Digestion).
❑ Alternative 4 115A NCAC 02T. 1. 107(a)(4)] - Specific Oxygen Uptake Rate 'Pest: (Aerobic Digestion).
❑ Alternative 5 [15A NCAC 021'. 1 107(a)(5)] - 14-Day Aerobic Processes.
❑ Alternative 6 [ 15A NCAC 02T.I 107(a)(6)] - Alkaline Stabilization.
❑ Alternative 7 [15A NCAC 02T.1107(a)(7)] - Drying of Stabilized Residuals.
❑ Alternative 8 [15A NCAC 0271'. 1 107(a)(8)] - Drying of Unstabilized Residuals.
❑ Alternative 9 [15A NCAC 02T.I 107(a)(9)] - Injection.
❑ Alternative 10 [15A NCAC 02T.1 107(a)(10)) - incorporation.
❑ Alternative for Surface Disposal Units Only - Soil/Other Material Cover [I5A NCAC 02T.1 107(b)(2)].
❑ Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
FORM: RSC 08-1 1 Page 5 of

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Nature Work Organics
1410 2nd Street
North Wilkesboro, NC
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1 of 1 2/11/2012 1.06 AM

Quantitative Justification for residuals rate:
Nature Works Organics expects to receive 130,000 gallons weekly or approximately
19,000 gallons daily of waste to be treated. This translated into 4.55 dry tons per day or
1,662.8 dry tons per year; if all the material brought is land applied.

Ar
TOLP Mercury
J antiary 2) 7. 20 12
Received: 1/17i 20 I
Pro ft Project 4. , N wure Work,.*,
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!201.099-01
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12f)j ()99-0.1
f I -Jan- 1.2 2-Butanone (MEK)
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200
19 -jilt: 2
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11 Jan 12 chlorob(IMA1.0c.
100
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11 -Jan. 12 Te.tractitcyciethene
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11 -Ja; 1 2 1; i -DichiororAl iene
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0.25
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1201099-01
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0.3
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0,002
<0.002
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131 It
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Nature Works
1201099-01
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0,002
<0.002
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1311
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11-Jan-12 Endrin
0.002
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1
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25.-Ian- 12 313NI
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1201099-01
11-Jan-12 Gamma-BHC
0.002
eO.002
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1311
1
0.4
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17_G1()99-01
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0.002
<0,002
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1311
1
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25-Jan-12 IN
11-ilturc Vrolks
1201099-01
11-Jan-12 Chlordane
0.01
<0.01
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1311
1
0.03
25-Jan. 12 JBN
7201099.01
11 Jari- 12 7oxaphei it.,
0.1
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4
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Analytical results
Entered 1/23/2012
j Reported: ti3012012
ForNw
Sample ID Parameter Cust ID Result Units Method oateAnalyzed Analyst
120123-9.1
'/,, Solids
In I
6.07
%
SM25408
i/23/12
CL
120123-9 1
Fecal Cottlorm MIT
I,t I
7
MPN/g
SW192210E
1/23/12
CL
120123-9,2
% Solids
Out 2
35,5
%
SM2540B
1123112
CL
120123-9,2
Fecal Coli%rm MTF
Out 2
11
MPN/9
SM92210E
1/23/12
CL
120123-9.3
Total Solids
VS in
58,020
mg/L
EPA 1684
1124/12
CL
120123-9,3
Volatile Solids
VS In
56,920
mglL
EPA 1684
1/25112
CL
'120123-9.4
Total Solids
VS Out
308,353
mg/L
EPA 1684
1/24/12
CL
120123-9.4
Volatile Solids
VS Out
281.323
mg/L
EPA 1684
1/25112
CL
120`123-9.5
% Sowis
Out 3
33.0
%
SM2540B
1/23/12
CL
120123-9-5
Fecal Coliiorm MTF
<)ui 1
24
MPN/g
SM92210E
1123112
CL
Respectfully submitted,
Dena Myers
NC Cert #440,
NCDW Cert #37755,
EPA NCO0909
P.U. lio, '228 " SI-M-w lle, North Corolina Nw " 70.Iq"71,.I4i47

VS in 0.981
VS out 0.91
VSFR= 0.804168

Page; /ofz
Report Number: 12-0 i7-02O2
Account Number: 46622
Submitted By:
� �/ Eastem Laboratories,
^ Inc.
���L�_o�������u0y������ //
no`Whi*�m�Richmond. Virginia 23r-7 (804)743---dm Fay. (8C-4)m��
pnojort,m*TVKEVV0KKS
mCCBRT#257
R��zO���rC�F�4NW�LYSIS
Date Sampled: 1/11�O1111oo0o
Lab Numbo ' �57OO
Number,Date
Received. O1/1712U12O8:8O
Sample hd�NATUREVYORKS
Date Reported: O1/z0oo12
Moisture °
84.25
100.0
Jm
01/17/201213:59 SK8-2540G
Total KJe|dohlNitrogen
7.04
70400
10.0
JK8
01/18/201207:14 SM-4500'NH3C-T{w
Total Phosphorus
051
oosO
100
KM
01/10201211:51 8VVGO1OC
Total Potassium
0.09
857
100
0w
01/18/201211:51 SVV6010C
Total Sulfur
0.58
5770
100
KM
01/18/201211:51 8vv8n1oo
Total Calcium
O.00
840
100
0N
01/10201211:51 SVV6010C
Total Magnesium
0.02
178
100
KM
01/18/201211:51 SVV6V10C
Total Sodium
0.12
1240
100
KM
O1/18/201211:51 SVV6O1GC:
Total Iron
1580
1
KM
01/181201211:51 SVV6010C
Tnt2|Aluminum
500
10
0N
01/181201211:51 SW' 801UC
Total Manganese
22
1
0W
01/18/201211:51 SVV8Oi0C
Total Copper
34
1
Km
01/10201211:51 3YV001 OC
Total Zinc
68
1
0M
01/18/201211:51 8VvOn1oC
Ammonia Nitrogen
0.68
8610
10.0
Jm
01/18/201207:14 GM-4500-NH3C
Organic
6.38
63790
10.0
01/181201207:14 CALCULATION
Nit,ate+Nithto'N
29.5
1.00
JKV
01/18/201207:15 8M4500w03F
Total Cadmium
<11.0
1.0
KM
01,1181201211:51 svvU010c
All values are onadry weight basis except osnoted byasterisk
Detection limit onall mseries /onnawet basis.
Debbie Holt

B
as decimal
ITotal dry
tonslyeaf
lAcres
Applied on
Rate
0.4
TKN
70400
NFI3
6610
NO3
29.6
NO2
0
%Q Solids
0.0575
0
1 0
PAN Surface
2M'•G.0 1 nIgIk-Q
5:7.e Ch2 ih. ldq CM
0 fl s twjtmi : lAN
3^�,i r,
PAN Injection
:3? a ,r:5.t? i it Ikg
64.E a 12 lasldr y' ta3 i
fr ibs total TAN
:DID+`/tat jibs PAMIac.^e
Dry Tons/1 OOO gal.
1st year PAN
lbs./acre
Surface lbs.
Surface
#Di` iu!
1st year PAN
Ibs.lacre
Injected I.bs.
Infects!
C
MR(TKN-NH3)+ + .5(NH3)+NO3+NO2 =mg/kg
mg/kg x .002 =Ibs/dry ton
MR(TKN-NH3) + 1(NH3)+NO3+NO2 =mg/kg
mg/kg x .002 =1bs/dry ton
1000 X 8..34 X %solids X sp. gravity
2000
"=dry tons/1000gal."

Ob
SAR
Sodium Absorption Ratio
Na ldiqLQ
Ga(M iL) [A MgIL)
Ne : Sodium (MgIL) Equivalent weight 23
71.3
48.76 1 10.2
Ca: Calcium (MgIL.) Equivalent weight: 20
Mg : Magnesium (Mg/L) Equivalent weight: 12
3.1
2.438
0.8.E
Milli Equivalent = Mg/L / Equivalent weight
The amour
amount of c
SAR= Na Milli Equivalent/[0.5 X (Ca Milli Equivalent
+ Mg Milli equivalent)]0,5 power
Permitting +,
1 UAR- 2, 177v.7,(From ME entered below)
Na ME
Ga Mi-
2.438
I�ic}�Mf^i
0.85
3.1

• r
WDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
June 1, 2012 D
Mr. Mitch Vestal, Senior Vice President - JUN 1 2 2012 i.
Nature Works Organics
1151 Strathmore Circle
Winston-Salem NC 27104 L - Aquiferff� rote
DV;�C1- Aquifer Protectiort_�,
SUBJECT: May 9, 2012 Reconnaissance Inspection
Nature Works Organics
Permit No: WQ0035777
Wilkes County
Dear Mr. Vestal:
A letter requesting that Nature Works Organics permit WQ0035777 cease all distribution/ land application of residuals,
effective April 24, 2012 was drafted on April 26, 2012. Nature Works Organics responded to this letter with the
alternative of incorporation of the residuals on the Claude Shew, Jr. farm. On May 8, 2012, the Winston-Salem Regional
Office gave Nature Works Organics temporary approval for land application of the residuals by incorporation at the
Claude Shew farm with a requirement to use Class B buffers. The activities could resume under the condition that they
meet Pathogen/Vector Attraction by use of Pasteurization and the use of setbacks for a Class B material in the event that
Class A could not be properly demonstrated.
A Reconnaissance Inspection was conducted by Derek Denard and Patrick Mitchell of the Winston-Salem Regional
Office to observe the land application and incorporation of the residuals. Present for the reconnaissance inspection was
Dennis Key, Southern Soil Builders, and Bob Binkley, Nature Works Organics.
An inspection of the Claude Shew land application site (see attached map) on May 9, 2012 noted the following:
A hobby park for remote controlled model airplane was adjacent to the proposed land application areas. For a
Class B material the setbacks for Habitable residences or places of public assembly under separate ownership or
not to be maintained as part of the project site is 200 feet for injection/incorporation (15A NCAC 02T
.1108(b)(2), page 64). In addition, public access to public contact sites shall be restricted for one calendar year
after any residuals land application event (15A NCAC 02T .1109(b)(2)(A), page 65).
Measurements of 45 to 60 feet were taken from the edge of the application area to a tree line along the Yadkin
River and a tributary. The distance from the tree line to the river could be estimated to be approximately 50 feet
from aerial photographs. The setbacks for Class B liquid residuals for Surface waters (streams - intermittent and
perennial, perennial waterbodies, and wetlands) is 100 feet (15A NCAC 02T .1108(b)(1), pages 63-64).: .
Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, North Carolina 27107 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 NorthCarohna
Internet: http:llportal.ncdenr.orglweblwq '�'}���N����
An Equal Opportunity 1 Affirmative Action Employer � �/

'\
Mr. Vestal
June 1, 2012
Page 2 of 2
• A railroad was located on the northern side of the land application site. Residuals had not been applied up this
public right of way at the time of the inspection. The setback for Class B residuals for a public right of way is 50
feet. (15A NCAC 02T .1108(b)(2), page 64).
o Wilkes county tax records indicated a property line that traversed a proposed land application site for two adjacent
lots. One lot is listed as being owned by Wilkes County, part of which is being used as a hobby park for remote
controlled plans, and the other property is owned by Claude Shew. A Utilization Agreement should be prepared
and signed by Wilkes County and Claude Shew for these properties. A setback of 50 feet is required on both
property lines.(15A NCAC 02T .1108(b)(2), page 64). This requirement includes property lines for adjacent lots
onto, which residuals are applied to both properties regardless of ownership.
• Humic`acidVva being used to control odor during the site visit. There was no significant odor from the residuals
applied to the surface. However, odor was very significant around the loading area due to pumping, etc.
• During the site inspection it started raining at—12:00pm and land application was ceased. Only a —50 foot strip of
land had been applied to. The farmer arrived with a tractor and the residuals were immediately incorporated. A
rain gage was present near the field and indicated 0.75 inches of rainfall.
• The vertical separation between the seasonal high water table and the depth of residuals application was
evaluated.
• Residuals from Louisiana Pacific's Distribution Program permit WQ0000461 were present on the surface of the
land application site. Review of their 2011 annual report indicated that residuals were applied to the Claude
Shew, Jr, farm in May and June 2011 (see attached documents). All residuals applied to Claude Shew's land
should be accounted for in loading calculations for plant available nitrogen (PAN).
Please refer to the enclosed inspection report for additional observations and continents. If you or your. staff have any
questions, please call Derek Denard at 336-771-5286.
Sincerely,
Sherri V. Knight, P.E.
Regional Aquifer Protection Supervisor
cc: Mr. Chris Redcay, Nature Works Organics — 3412 Garden Rd., Burlington, NC 27215
Mr. Danny Cockerham, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Bob Binkley, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Dennis Key, Southern Soil Builders — 958 Hoots Rd., Roaring River, NC 28669
Mr. Doug Baxter, Tyson Foods, Inc. —13264 Mountain Rd., Glen Allen, VA 23059
Mr. James Brown, Tyson Foods, Inc. —1600 River St., Wilkesboro, NC 28697
Iredell County Health Department
Wilkes County Health Department
Yadkin County Health Department
Mr. Jon Risgaard, APS Central Office
Mr. Ed Hardee, APS Central Office
Ms. Chonticha McDaniel, APS Central Office
M-SIUKot''o`gym f M �. „ �
Permit File WQ0035777
APS WSRO file
Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, North Carolina 27107 One
Phone: [phone] \ FAX: [phone] Customer Service: 1-877-623-6748 NorthCarolina
Internet: http:/lporlal.ncdenr.orglweb/wq �
An Equal Opportunity\ Affirmative Action Employer A!l �y.�' Ll/r`[�//

Compliance Inspection Report
Permit: WQ0035777 Effective: 02/22/12 Expiration: 01/31/17 Owner: Nature Works Organics
SOC: Effective: Expiration: Facility: Nature Works Organics
County: Wilkes N Wilkesboro
Region: Winston-Salem
North Wilkesboro NC 28659
Contact Person: Zach D Key Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/09/2012 Entry Time: 11:40 AM
Primary Inspector: Derek Denard
Secondary Inspector(s):
Patrick Mitchell
Reason for Inspection: Follow-up
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
0 Miscellaneous Questions
(See attachment summary)
Certification: Phone:
Exit Time: 12:35 PM
Phone: [phone]
Phone:
Inspection Type: Reconnaissance
Page: 1

Permit: WQ0035777 Owner - Facility: Nature Works Organics
Inspection Date: 05/09/2012 Inspection Type: Reconnaissance Reason for Visit: Follow-up
Inspection Summary:
A letter requesting that Nature Works Organics permit W00035777 cease all distribution/ land application of residuals,
effective April 24, 2012 was drafted on April 26, 2012. Nature Works Organics responded to this letter with the alternative
of incorporation of the residuals on the Claude Shew, Jr. farm. On May 8, 2012, the Winston-Salem Regional Office
agreed to allow Nature Works Organics to resume distribution/ land application of the residuals. The activities could
resume under the condition that they meet PathogenNector Attraction by use of Pasteurization and the use of setbacks
for a Class B material in the event that Class A could not be properly demonstrated.
The Reconnaissance Inspection was conducted by Derek Denard and Patrick Mitchell of the Winston-Salem Regional
Office. Present for the reconnaissance inspection was Dennis Key, Southern Soil Builders, and Bob Binkley, Nature
Works Organics.
An inspection of the Claude Shew land application site (see attached map) on May 9, 2012 noted the following:
A hobby park for remote controlled model airplane was adjacent to the proposed land application areas. For a Class B
material the setbacks for Habitable residences or places of public assembly under separate ownership or not to be
maintained as part of the project site is 200 feet for injection/incorporation (15A NCAC 02T .1108(b)(2), page 64). In
addition, public access to public contact sites shall be restricted for one calendar year after any residuals land application
event (15A NCAC 02T .1109(b)(2)(A), page 65). Residuals can be applied up to the hobby park area that was mowed as
a landing strip. However, if a remote controlled aircraft ventures or lands on the application area and has be to be
recovered by a hobbyist a violation would occur.
• Measurements of 45 to 60 feet were taken from the edge of the application area to a tree line along the Yadkin River
and a tributary. The distance from the tree line to the river could be estimated to be approximately 50 from aerial
photographs. The setbacks for Class B liquid residuals for Surface waters (streams - intermittent and perennial,
perennial waterbodies, and wetlands) is 100 feet (15A NCAC 02T .1108(b)(1), pages 63-64).
• A railroad was located on the northern side of the land application site. Residuals had not been applied up this public
right of way at the time of the inspection. The setback for Class B residuals for a public right of way is 50 feet. (15A
NCAC 02T .1108(b)(2), page 64).
• Wilkes county tax records indicated a property line that traversed a proposed land application site for two adjacent
lots. One lot is listed as being owned by Wilkes County, which is being used as a hobby park for remote controlled plans,
and the other property is owned by Claude Shew. A Utilization Agreement should be prepared and signed by Wilkes
County and Claude Shew for these properties. A setback of 50 feet is required on both property lines.(15A NCAC 02T
.1108(b)(2), page 64). This requirement includes property lines for adjacent lots onto which residuals are applied to both
properties regardless of ownership.
• Humic acid was being used to control odor during the site visit. There was no significant odor from the residuals
applied to the surface. However, odor was very significant around the loading area due to pumping, etc.
• During the site inspection it started raining at—12:00pm and land application was ceased. Only a —50 foot strip of land
had been applied to. The farmer arrived with a tractor and the residuals were immediately incorporated. A rain gage was
present on near the field and indicated 0.75 inches of rainfall.
Page: 2

Permit: WQ0035777 Owner - Facility: Nature Works Organics
Inspection Date: 0510912012 Inspection Type: Reconnaissance Reason for Visit: Follow-up
The vertical separation between the seasonal high water table and the depth of residuals application was evaluated.
Residuals from the application form the application Louisiana Pacific's Distribution Program permit WQ0000461 were
present on the surface of the land application site. Review of their 2011 annual report indicated that residuals were
applied to the Claude Shew, Jr. in May and June 2011 (see attached documents). All residuals applied to Claude Shew's
land should be accounted for in loading calculations for plant available nitrogen (PAN).
Page: 3

Permit: Nature Works WQ0035777
Site: Claude Shew Farm
r
a� h'
jclA
f
1r Y
AJ
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ty, y
VT
r' yc
.�' < -fie ..�•�. 75. t 1 •; �� � ._p.�.+',yY��`1°'�,�, 4 dr Y`- � `.
440
YADKIN RVIER , } E
.ZIL
#, # i
V
A.
This map was produced for illustrative purposes. Information data
used for this map were collected from federal, state, county, and
private organizations. While every effort is made to keep this map ,' ., ''
accurate and up-to-date, it is not intended to replace an official
source. Under no circumstances shall the State of North Carolina�`�
be liable for any actions taken or omissions made from reliance on X 44.
any information contained herein from whatever source nor shall the
State be liable for any other consequences from any such reliance ,, ` ---• ;ti? '�. h' - . _. �qt+
Feet
0 285 570 1,140
p Map Datium: NAD83
wE Map Projection: NC State Plan
e Map Scale: 1:7,920 Legend
Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Intemet: http://portal.ncdenr.orgAvebtwq
An Equal Opportunity 1 Affirmative Action Employer
1 inch = 660 feet
Nne
orthCarolina
Vatura!!tf

Form SLID-1 LP Corp Solids Application Field [Record
Form SLD-2 For Recording Solids A► lication'Events on Different Fields
(Modified) Farm Owner Claude Shew Jr. 4930 Facility Number WQ0000461
Address 955 Dellaplane Rd. Roaring River NC 28669 Location River Bottom Rd./Elkin Hwy 268 Ronda
Phone Number 336 957 7160 Application I Broadcast surface applied
Spreader Operator LP Corp
Tract Number 77 From Animal Waste Management Plan
Field Number 4763 Waste Analysis PAN (lbsfton) (A)
Field Size (acres) (c) 87.90 Waste Analysis Phosphorus (Ibs/ton) (s)
Crop Corn/Silage Recommended PAN Loading (Ibs/acre)
Sludge
Ash
4.45
0.09
1.05
0.76
200
Date
Loads
Spread
Dry Tons
Spread
Tons
per Acre
(1) (C)
PAN Applied
(Ibs/acre)
(2) X (A)
Cumlative PAN
(Ibs/acre)
Phosphate Applied
(lbs/acre)
(2) X (B)
Cumlative Phosphate
(Ibs/acre)
Prior Loading
0.00
0,00
0.00
0.00
0.00
0.00
515/2011
4
10.07
0.11
0.51
0.51
0.12
0.12
5/6/2011
10
25.13
0.29
1.27
1.78
0.30
0.42
5/7/2011
3
7.97
0.09
0.40
2.19
0.10
0.52
T,

Form SLD-1
Form SLD-2
(Modified) Farm Owner
Address
Phone Number
Spreader Operator
Tract Number
Field Number
Field Size (acres) (c)
Crop
LP Corp Solids Application Field Record
For Recording Solids Application Events on Different Fields
Claude Shew JR 4910 Facility Number r021
000461
955 Dellaplane Rd. Roaring River NC 28669 Location Elkin H 268
3369577160 Applicationoadcast (surface applied)
LP Corp
52 From Animal Waste Management Plan
2658 Waste Analysis PAN (Ibs/ton) (A)
15.00 Waste Analysis Phosphorus (lbs/ton) (s)
Corn/Silage Recommended PAN Loading (Ibs/acre)
(1) (2)
Sludge
Ash
4.45
0.09
1.05
0.76
200
Date
Loads
Spread
Dry Tons
Spread
Tons
per Acre
(1) / (C)
PAN Applied
(Ibs/acre)
(2) X (A)
Cumlative PAN
(Ibs/acre)
Phosphate Applied
(Ibs/acre)
(2) X (6)
Cumlative Phosphate
(Ibs/acre)
Prior Loading
0.00
0.00
0.00
0.00
0.00
0.00
5/13/2011
7
18.35
1.22
5.44
5.44
1.28
1.28
6/1/2011
5
12.04
0.80
3.57
9.02
0.84
2.13
6/2/2011
4
13.19
0,88
3.91
12.93
0.92
3.05
r-- _------- _ _
METAL ANALYSIS
4 _

7�
4
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
May 30, 2012
CERTIFIED MAIL # 7010 0290 0001 4856 3938
RETURN RECEIPT REQUESTED
Mr. Mitch Vestal, Senior Vice President
Nature Works Organics
1151 Strathmore Circle
Winston-Salem, NC 27104
SUBJECT: Notice of Violation/Notice of Intent to Enforce (NOWNOI)
Discharge of Wastewater to the Surface Waters
Permit Condition Violations — NOV-2012-PC-0201
Permit No. WQ0035777
Wilkes County
Dear Mr. Vestal:
Dee Freeman
Secretary
4 ► J U N 1 2 2012}�
NR Ivlri0
Ifel- Protection
Please find the enclosed compliance inspection report from the April 23, 2012 compliance evaluation
inspection/complaint investigation. This inspection was conducted in response to reports from the Town
of North Wilkesboro to the Division of Water Quality Surface Water Protection Section of discharge to
the surface waters from the Nature Works Organics facility.
On March 21, 2012, Mr. Patrick Mitchell and Mr. Derek Denard conducted a follow-up inspection for
complaints received about land application of Nature Works residuals on the Arnold Farm. During this
visit to the Nature Works Organics facility in North Wilkesboro, NC, stormwater concerns were noted
around the loading area at the backside of the facility. Photos were taken of recent run-off (wet channels)
leading to a silt screen placed at the edge of a slope to a stream. Although it appeared that the run-off had
not reached surface waters, the discharge to a wetted channel is considered to be a violation of permit
Condition IV 8. e. (see below), which requires reporting any spill or discharge from a vehicle or piping
system during residuals transportation.
On Monday April 23, 2012 Mr. Patrick Mitchell of the Winston-Salem Regional Office received a call
from Mr. Dennis Key of Southern Soil Builders inquiring if we (DWQ) had received any complaint calls
concerning Nature Works Organics over the weekend (April 21 or 22, 2012). Mr. Key then stated that the
Town of North Wilkesboro "shut Nature Works down Saturday over odor conditions at the facility". Mr.
Key stated that the odor came from the cleanout of the storage tanks removed from the Arnold farm.
The same morning Mr. Mitchell spoke with Mr. George Smith with the Surface Water Protection Section
of DWQ in the WSRO. Mr. Smith had received a call from Mr. Jimmy Martin (ORC) with the Town of
North Wilkesboro WWTP. Mr. Martin's call concerned a spill that occurred at the Nature Works
Organics facility on Saturday April 21, 2012 and that Mr. Martin had photos taken of the incident (see
Winston-Salem Regional Office
585 Waughtown Street Winston-Salem, NC 27107
Phone: [phone] FAX: [phone]
NCDENR Customer Service: 1-877-623-6748
Internet: www.ncwaterguality.orq
One
NorthCarolina
Naturalltf
An Equal Opportunity 1 Affirmative Action Employer

Nature Works Organics
Compliance Evaluation Inspection/Complaint Investigation
May 30, 2012
WQ0035777
attached photos). Mr. Mitchell also spoke with Mr. Martin concerning the incident. Mr. Martin stated that
there was a discharge of material down the hillside behind the Nature Works facility and indicated that
there was a very strong odor present as well.
The same morning at 11:15 am DWQ staff members Mr. George Smith, Mr. Derek Denard and Mr.
Patrick Mitchell conducted an incident investigation at the Nature Works Organics facility located in
North Wilkesboro. The following persons were also present for this investigation, but did not necessarily
accompany DWQ during all portions of the investigation: Mr. Dennis Key (ORC from Southern Soil
Builders); the following Nature Works representatives- Mr. Bob Binkley, Mr. Mark Helms, Mr. Cory
(unknown last name), and Mr. Thomas (unknown last name). Mr. Smith took several photos indicating a
discharge to an unnamed tributary to the Yadkin River Class C waters (see attached map).
It has also come'to our attention upon conversations with Mr. Jimmy Martin and Mr. George Smith that
an additional discharge occurred from the facility on March 15, 2012 to an unnamed tributary to the
Yadkin River. Mr. Martin took several photos (see attached). There was no report of this incident to the
Division of Water Aquifer Protection Section in the Winston-Salem Regional Office.
Discharge of wastewater to surface waters from this facility is in direct violation of Non -Discharge permit
WQ0035777. Not reporting such incidents to the Winston-Salem regional office's Aquifer Protection
Section is also a violation of your permit. In summary, two (2) violations of discharging wastewater to
surface waters have been documented on March 15, 2012 and April 21, 2012. Not reporting these spills
on March 15, 2012 and April 21, 2012 is also a violation of your permit. Please note the following permit
Conditions:
Permit Condition II. 1.: The subject residuals management program shall be effectively maintained and
operated at all times so there is no discharge to surface waters, nor any contravention of groundwater or
surface water standards. In the event the facilities fail to perform satisfactorily, including the creation of
nuisance conditions due to improper operation and maintenance, the Permittee shall immediately cease
distribution of residuals, contact the Winston-Salem regional office's Aquifer Protection Section
supervisor, and take any immediate corrective actions.
Permit Condition II.2.: This permit shall not relieve the Permittee of their responsibility for damages to
groundwater or surface water resulting from the operation of this residuals management program.
Permit Condition II1. l .: The residuals management program shall be properly maintained and operated at
all times. The program shall be effectively and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards.
Permit Condition III. 2.: The Permittee shall maintain an approved Operation and Maintenance Plan
(O&M Plan) pursuant to 15A NCAC 02T .1110. (See permit page 3 and 4 for details.) This O&M plan
should include a spill response plan.
Permit Condition IV. 8.: The permit shall report by telephone to the Winston-Salem 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. Any occurrence with the distribution program resulting in the land application of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to surface waters.
Page 2 of 3

Nature Works Organics
Compliance Evaluation Inspection/Complaint Investigation
May 30, 2012
WQ0035777
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 residuals 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 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 phone 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.
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue
enforcement action for this and any additional violations of State law. Failure to abide by the conditions
and limitations contained in Permit No. WQ0035777 may subject the Permittee to an enforcement action
by the Division in accordance with North Carolina General Statute 143-215.6A through 143-215.6C.
Our office is considering a recommendation in favor of the pursuit of punitive sanctions for these
violations. Prior to making such a recommendation, we need to be certain that we have all relevant
information. If you wish to present an explanation for the violations cited, or if you believe there are
other factors, which should be considered, please send such information to me in writing with thirty (30)
days following receipt of this letter. Any additional information will be reviewed, and, if an enforcement
action is still deemed appropriate, that information will be forwarded to the Director with the enforcement
package for his consideration. Should you have any questions on this matter, contact Derek Denard or me
at 336-771-5000.
Sincerely,
Sherri V. Knight
Regional Supervisor
Aquifer Protection Section
enc.: Compliance Inspection Report
cc: Mr, Chris Redcay, Nature Works Organics — 3412 Garden Rd., Burlington, NC 27215
Mr. Danny Cockerham, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Bob Binkley, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Dennis Key, Southern Soil Builders — 958 Hoots Rd., Roaring River, NC 28669
Mr. Doug Baxter, Tyson Foods, Inc. —13264 Mountain Rd., Glen Allen, VA 23059
Mr. James Brown, Tyson Foods, Inc. —1600 River St., Wilkesboro, NC 28697
Iredell County Health Department
Wilkes County Health Department
Yadkin County Health Department
Mr. George Smith, DWQ-SWPS WSRO
Mr. Jon Risgaard, APS Central Office
Mr. Ed Hardee, APS Central Office
Ms. Chonticha McDaniel, APS Central Office
elVI-sICI en a :m7n,17 : ` Rr*
APS WSRO file
Page 3 of 3

Permit: WQ0035777
SOC:
County: Wilkes
Region: Winston-Salem
Compliance Inspection Report
Effective: 02/22/12 Expiration: 01/31/17 Owner: Nature Works Organics
Effective: Expiration: Facility: Nature Works Organics
N Wilkesboro
Contact Person: Zach D Key Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/23/2012 EntryTime: 11:15 AM
Primary Inspector: Derek Denard
Secondary Inspector(s):
George S Smith
Patrick Mitchell
Reason for Inspection: Complaint
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
North Wilkesboro NC 28659
Phone: [phone]
Certification
Exit Time: 12:40 PM
Inspection Type: Complaint
Miscellaneous Questions 0 Record Keeping 0 Treatment
(See attachment summary)
Phone:
Phone: [phone]
Phone:
Phone:
Pathogen and Vector
Attraction
..V
Page: 1

Permit: WQ0035777 Owner - Facility: Nature Works Organics
Inspection Date: 04/23/2012 Inspection Type: Complaint Reason for Visit: Complaint
Inspection Summary:
4/23/2012 Dennis Key Phone Conversation:
On Monday April 23, 2012 1 received a call from Mr. Dennis Key of Southern Soil Builders at approximately 9:38 am. Mr.
Key was calling to inquire if we (DWQ) had received any complaint calls concerning Nature Works Organics over the
weekend (April 21 or 22, 2012). 1 responded by saying no I have not received any calls or messages and that I would
check with other staff to see if they received any calls. Mr. Key then stated that the town of North Wilkesboro "shut Nature
Works down Saturday over odor conditions at the facility". Mr. Key stated that the odor came from the cleanout of the
storage tanks removed from the Arnold farm. Mr. Key followed this by asking "can North Wilkesboro do this". I told Mr.
Key that I would call him back after asking around the office to see if other staff was aware or involved with this incident.
4/23/2012 George Smith Conversation:
The same morning I spoke with George Smith with the Surface Water Section of DWQ in the WSRO. George
had received a call from Mr. Jimmy Martin ORC with the town of North Wilkesboro WWTP. He said that Mr.
Martin's call concerned discharge from a spill that occurred at the facility on Saturday April 21, 2012 and that Mr. Martin
had photos taken of the incident.
4/23/2012 Jimmy Martin Conversation:
The same morning I spoke with Mr. Jimmy Martin ORC with North Wilkesboro concerning the incident that
occurred on Saturday (4/21/2012). Mr. Martin stated that there was a discharge of material down the hillside behind the
Nature Works facility on the subject date. Mr. Martin also indicated that there was a very strong odor present as well.
4/23/2012 Incident Investigation at the Nature Works Organics Facility:
DWQ staff members G. Smith, D. Denard and myself conducted an incident investigation at the Nature Works
facility located in North Wilkesboro. The following persons were also present for this investigation, but did not necessarily
accompany DWQ during all portions of the investigation: Mr. Dennis Key (ORC from Southern Soil Builders); the following
Nature Works representatives- Mr. Bob Binkley, Mr. Mark Helms, Mr. Cory (unknown last name), and Mr. Thomas
(unknown last name).
NOTES:
• DWQ entry at 11:15 am.
• Mr. Key provided March 27-29, 2012 records for the waste analysis, fecal coliform results, and volatile solids
calculations.
• Mr. Key provide the March 30, 2012 Utilization Agreement that Mr. Bill Arnold signed.
• Mr. Binkley indicated that the Tyson waste is heated to 200° F during the treatment process at Nature
Works.
• Mr. Key stated that the Saturday April 21, 2012 incident originated as a result of an emergency call that was made to
911 concerning a spill in the area of the Nature Works facility.
• When asked why Tyson was now sending 100% of the waste material to Nature Works. Mr. Helms
answered stating that Tyson stopped using TRS to haul the material to SC because it was cheaper to use
Nature Works for disposal.
• Mr. Cory (unknown last name) and Mr. Thomas (unknown last name) were reported as Nature Works employees by Mr.
Bob Binkley. It should be noted that both of these men were present and assisting Mr.
Bill Arnold on March 15, 2012 when DWQ conducted a complaint investigation.
• DWQ exit at 12:40 pm.
Page: 2

'il
Permit: WQ0035777 Owner - Facility: Nature Works Organics
Inspection Date: 04/23/2012 Inspection Type: Complaint Reason for Visit: Complaint
Type Yes No NA NE
Land Application ❑
Distribution and Marketing
■
Record Keeping
Yes No
NA NE
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?
❑ ❑
■ 0-
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?
❑ Cl
■ ❑
Are there pH records for the land application site?
❑ ❑
■ ❑
Are nutrient/crop removal practices in place?
Cl ❑
❑ ■
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑
■ ❑
Are hauling records available?
❑ ❑
■ ❑
Are hauling records maintained and up-to-date?
❑ ❑
Cl ■
# Has permittee been free of public complaints in last 12 months?
❑ ■
❑ ❑
Has application occurred during Seasonal Restriction window?
❑ ❑
■ ❑
Comment: See summary
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B) ■ ❑ ❑ ❑
Class A, all test must be <1000 MPN/dry gram ■
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram ■
Fecal coliform SM 9222 D (Class B only) ❑ ❑ ■ ❑
Page: 3

Permit: WQ0035777 Owner - Facility: Nature Works Organics
Inspection Date: 04/23/2012 Inspection Type: Complaint
Reason for Visit: Complaint
Geometric mean of 7 samples per monitoring period for class B<2.0`10E6 CFU/dry gram
❑
b. pH records for alkaline stabilization (Class A)
❑ ❑
■ ❑
c. pH records for alkaline stabilization (Class B)
❑ ❑
■ ❑
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑ ❑
■ ❑
e. Time/Temp on:
❑ ❑
■ ❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: See summary
■ ❑ ❑ ❑
OO■❑
■
Page: 4

Permit: Nature Works WQ0035777
Site: North Wilkesboro 2nd Street Facility
Area of Spill
This map was produced for illustrative purposes. Information data
used for this map were collected from federal, state, county, and
private organizations. While every effort is made to keep this map
accurate and up-to-date, it is not intended to replace an official
source. Under no circumstances shall the State of North Carolina
be liable for any actions taken or omissions made from reliance on
any information contained herein from whatever source nor shall the
State be liable for any other consequences from any such reliance.
Feet
0 170 340 680
v' Map Datium: NAD83 Legend
Map Projection: NC State Plan
Map Scale: 1:4,800 p Waypoints
Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, North Carolina 27107
Phone: [phone] FAX [phone] Customer Service:1-877-623-6748
Internet: ht1pJ1portal.ncdenr.or&eb1wq
An Equal Opportunity 1 Affirmative Action Employer
1 inch = 400 feet
NorthCarohna

Runoff on hillside. Arrow indicates
direction of flow
Solids in stream.
Solids, Oil and Grease in stream.
3/15/2012
PHOTOS
Runoff on hillside.
Solids, Oil and Grease in stream.
6 of 41
M -V jxv M 4N,
Solids, Oil and Grease in stream.
Page I of 7

Solids, Oil and Grease in stream.
Solids, Oil and Grease in stream.
Solids, Oil and Grease in stream.
3/15/2012
PHOTOS
Page 2 of 7 .
Solids on stream bank. Red arrow indicates
close-up of area in photo 7.
Solids, Oil and Grease in stream.
Red arrow indicates close-up of area in
photo 11.

3/21/2012
PHOTOS
Spillage and channel beside frac tanks
Spillage and channel beside frac tanks.
Silt screen at crest of hill above stream
behind frac tanks.
Page 3 of 7
x 3
_
T
t �S
Spillage and channel beside frac tanks.
With channel entering drain pipe. Silt
screen at crest of hill in background.
16 of 41
�. -:j - -f
i
_1 j
Background: Spillage and channel beside
frac tanks with water exiting drain pipe.
Foreground: Silt screen at crest of hill
above stream which is located behind frac
tanks.

4/22/2012
PHOTOS
18 of 41
Spillage around storm drain and roof down
spout.
20 of 41
nTV
"�
1. d
Close-up of roof down spout drain into
which spill was conveyed.
22 of 41
x
x - r
Close-up of spillage channel entering drain
pipe. Same as in 3/21/2012 photos 13, 14,
15 and 16.
Page 4 of 7
19 of 41
t r a
c' .
� e
- z
r
�.+�yyyy� T b
Spillage around storm drain and
roof down spout.
21 of 41
Spillage and channel beside frac tanks.
With channel entering drain pipe. Same as
in 3/21/2012 photos 13, 14, 15 and 16.
23 of 41 IMI
;,u✓ pis
Ali
Y �
Silt screen at crest of hill above stream
which is located behind frac tanks.

4/22/2012
PHOTOS
24 of 41
Spillage around frac tank transfer hoses and
valves.
Wetted area from spill around frac tanks.
25 of 41
Page 5 of 7
Wetted area from spill around frac tanks.
27of4l
47
Wetted area from spill around frac tanks.
Wetted area from spill around frac tanks.

Silt screen at crest of hill above stream
which is located behind frac tanks.
Silt screen at crest of hill above stream
which is located behind frac tanks.
Spillage channel down hill to stream below.
4/22/2012
PHOTOS
Page 6 of 7
Silt screen at crest of hill above stream
which is located behind frac tanks.
Silt screen at crest of hill above stream
which is located behind frac tanks. Spillage
that passed through or under silt screen.
Spillage channel down hill to stream below.

4/23/2012
PHOTOS
Spillage channel down hill to stream below
with lime applied. Same are as 4/22/2012
photos 34 and 35.
Storm drainage pipe discharge on side of
hill. Red arrow indicates close-up of
Spillage channel down hill to stream below
with lime applied.
Page 7 of 7
Spillage channel down hill to stream below
with lime applied. Same are as 4/22/2012
photos 34 and 35.
Spillage channel down hill to stream below
with lime applied. Same are as 4/22/2012
photos 34 and 35.
Spillage channel down hill to stream below
with lime applied.

Untitled - Google Maps
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Created on Apr 20 • By princess28115 Updated < 1 minute ago
WQ003577
field location
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April 13, 2012
Ms. Sherri V. Knight
Regional Supervisor
Aquifer Protection Section
North Carolina Department of Environment and Natural Resources
Division of Water Quality
585 Waughtown Street
Winston-Salem, North Carolina 27107
Re: Permit N�o.�WQ0035777
Dear Ms. Knight,
NatureWorks Organics, LLC has.received your
review and investigate the alleged permit con(
respond to each of the four items (numbered I
it is inappropriate and unnecessary for youra
for the alleged violations you have raised..
as you requested, and we would we co
of NCDENR to answer any questions�y(a 'a�.
further action is necessary on your pertt
your agency in order to confirm t.aTatue
permit.
RECENED
N.C. Dept. of ENR
APR 1 T 2012
Winston-Salem
Regional Office
:p, . 2012 and has had an opportunity to
olaions outlined therein. This letter will
ulave raised and explain to you why we believe
ybpursue any enforcement action or sanctions
; pponding within ten days of receipt of your letter
Kmity to meet with you or other representatives
or further explain why we do not believe any
i also welcome continued interaction with you and
is in full compliance with all requirements of the
NatureWorks is a com an Qr` initi d't `'e'nvironmental awareness and protection. The entire basis
P 'S 1?
of the company is to prorxro."Phtal protection by the recycling of otherwise useless waste
material and develop(ng eriip�t��►itlly friendly organic fertilizers. In addition, we are producing
a primary component ofdels;tf{yf successful, we will significantly contribute to the use of
biofuels in the futuek,it�nh{tttly`flucing the use of fossil fuels. We are committed to this plan and
welcome your s*%,, a l'' h arcJgMentaIly friendly corporate citizen.
Before addressor fltd 1*pfiff outlined in your letter, you should be aware that prior to the transfer
of any resic�isot* ;A�raic� NatureWorks did have an analysis of the residuals conducted by
Research Fll'al�ii �; IiQttories in Kernersville, North Carolina. We would be happy to provide
you with{th" ftlesdDIU!`����Nanalyses for your review. Mr. Arnold, prior to taking ownership of the
residuai<S�`Ifor IattareW�pr s, took the analyses to the Yadkinville, North Carolina office of the U.S.
Sol] gnd`WdritiJllfiIe was informed by that office that the materials were considered fertilizer
andpd15e�pJl'd 'Hst about anywhere." No need for any permit was indicated to Mr. Arnold and
he ferenership of the material and apply it to his land as he deemed appropriate. In
spite pf�apan btti i ese assurances that Mr. Arnold's land application was not an environmental
orrguol'yissi:TatureWorks continued to evaluate this and other options. Mr. Mitch Vestal of
1Vtu%rirk sole with Mr. Jon Risgaard of your office and discussed the potential land application
of t'e tijalt�ral5z ;its a result of those discussions, and in spite of the assurances received by Mr.
AizJa dr f414t ,,w rks determined that it would be appropriate to obtain a residuals land application
4zti;�1#terf'taining Mr. Dennis Key of Southern Soil Builders to assist in this area, Mr. Vestal and
Myj of�ejialf of NatureWorks, submitted the application that resulted in the issuance of Permit
illrQ00,5/ Ton February 22, 2012. The application included the results of additional testing that
hl be`e;'ri'dtYiducted on the materials.
296 1 Clemmons, NC 27012 1 p: 336.998.3170 1 [e-mail]

I. March 15, 2012 Complaint Investigation
I. Based on the facts outlined in the previous paragraph NatureWorks, in good faith,
did not believe the materials transferred to Mr. Arnold were considered "waste."
Without debating the statutory definition of this term, there was never a knowing
violation of the referenced statute prior to submission of the application for the
permit to your office.
2. Mr. Arnold has received and signed a Utilization Agreement in accordance with
Condition III.9. and 10. of the permit He signed theAgreement'on March 30, 2012:
3. NatureWorks has contracted with Southern Soil Builders for. -the application of all
residuals. All applications meet required buffers as outling.l in the permit. In
�.
addition, all residuals are being applied within agronornx`,rates.
4. Dennis Keys of Southern Soil Builders is the ORC of e'permit and he inspects
application areas on each application. event Also,ijoperation and maintenance
AM ,:
plan has been implemented which mandates wlN. inspections shall take place
and by whom. « };
5. While the tanks at Mr. Arnold's farm refere6'... ley you have been used for short
term storage, much less than the fourteen>da aIlowed by the permit (and therefore
not a violation of the permit in any evetlt�;tanks are in the process of being
relocated to the Natureworks facilittfi}%forth Wilkesboro.
II. March 16, 2012 Complaint
On March 15, 2012 Mr. Key of
Mitchell in which he was giver
areas upon which they had nai'
site on March 16, but based. C
krijowing] providing resit,
small amount of the rqq)' s'
X;
Mr. Arnold had ivrevaQarsly aoi
III. March 21,
}t Builders had a telephone conversation with Mr.
f.. roval for Mr. Arnold to land apply residuals to any
ly been applied. Mr. Cockerham was present at the
val from Mr. Patrick Mitchell, NatureWorks was not
nold in violation of the permit. It does appear that a
been applied on that day to a small area upon which
of the residuals.
Investigation
Mr. Arnoldft.en if he indicated on March 21 that he had not yet received any
guidance fhtvreWor,Yts ro Mr. Key had verbally given Mr. Arnold guidance on the
applicatLa0 a O Och 16. In addition, Mr. Key has been retained as the ORC for
NatureWoksn,xs aohg as such on an ongoing basis. With respect to the concerns
,4a roc e�
exnreC se:Yeiarili'ntlie site visit:
i erY eft storage capacity of 42,000 gallons is deemed by NatureWorks to be
f 1ti0na163,000 gallons of capacity is being added as outlined above.
i. certain the cracks and holes in the floor result in any leaching, all holes
k the cement have been sealed and all of the cement under the worm beds
sjaected and sealed as needed.
;catch basin has been installed at the cleanout area in the back of the facility
tnp pump has been added to return any spillage to the storage tanks.
of treatment, samples and utilization of material in worm beds is being
ied. All material goes through a heat exchanger and oil is removed to meet all
i-vector requirements of the permit
29, 2012 Complaint Investigation
respect to the three bullet points in this section, Mr. Keys, as the ORC has ensured that
plications by Mr. Arnold are in accordance with the permit. All well setbacks and slope
ctions are being followed to the best of his and NatureWorks knowledge. Again, Mr.
i nfo@ natureworkso rga n i cs, co m

z
Q0
r+
0*
ME
Ir
0
n�
Arnold's statement that he had not received any guidance from NatureWorks as of March 29
is simply mistaken, and in fact is belied by the next sentence which indicates that Mr. Key
had met him at the field and shown him well setbacks and slope restrictions. In addition, the
irrigation system is no longer used.
In summary, NatureWorks has in the past and will continue to strive to comply with all applicable
environmental statutes and regulations. We are committed to working with you and your agency to
ensure that you are completely assured that NatureWorks is in compliance with all permit
requirements. We also encourage you to work with Mr. Key on NatureWorks' bonalf. Finally,
NatureWorks strongly believes that any sanctions or enforcement action are brth unnecessary and
unwarranted under the circumstances. A110
Please feel free to contact any management personnel at Naturel
information or have further questions. I can be reached at (336)
We Iook forward to hearing from you and working with you
Sincerely,
'Charles A. Blixt
Chairman
Cc: Mr. Mitch Vestal
Mr. Bob Binkley
Mr. Danny Cockerham
Mr. Doug Baxter
Mr. James Brown
Mr. Dennis Key
Mr. Joseph Bumgarner
Mr. William Arnold
Mr. Justin Henders.qffi=
me if you need further
296 1 Clemmons, NC 27012 1 p: 336.998.3170 1 [e-mail]

G' !
APIWA
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
April 3, 2012
CERTIFIED MAIL # 7010 0290 0001 4856 3822
RETURN RECEIPT REQUESTED
Mr. Mitch Vestal, Senior Vice President
Nature Works Organics
1151 Strathmore Circle
Winston-Salem, NC 27104
SUBJECT: Notice of Violation/Notice of Intent to Enforce
Permit Condition Violations — NOV-2012-OP-0005
North Carolina General Statute Violations
Permit No. WQ0035777
Wilkes County
Dear Mr. Vestal:
Dee Freeman
Secretary
On March 12, 2012 the North Carolina Division of Water Quality's Winston-Salem Regional
Office (DWQ) received a complaint from the Yadkin County Health Department concerning the
land application of a waste too close to surface waters at Mr. William Arnold's farm located on
the corner of Bethel Church Road and Mize Road in Yadkin County. DWQ staff determined that
the subject waste being land applied by Mr. William Arnold was liquid residuals waste from
your facility located in Wilkes County.
This complaint is one of a total of four complaints that DWQ has received thus far concerning
waste application at Mr. Arnold's farm since January 27, 2012. The following is a listing of the
subsequent investigations that have occurred and the observed violations.
I. March 15, 2012 Complaint Investigation
On March 15, 2012 Mr. Patrick Mitchell of this office made a site visit to the subject property to
investigate the above mentioned complaint received from the Yadkin County Health Department
on March 12, 2012. The investigation revealed the following violations:
1. Land application of residuals from Nature Works Organics has been occurring at
Mr. Arnold's farm since at least December 16, 2011. Records submitted to DWQ indicate
that greater than 80 tanker loads or 520,000 gallons. or more of liquid residuals from
Nature Works Organics have been delivered and land applied at Mr. Arnold's farm prior
Winston-Salem Regional Office
585 Waughtown Street Winston-Salem, NC 27107
Phone: [phone] FAX: [phone]
NCDENR Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.om
Nne
orthCarohna
Naturally
An Equal Opportunity 1 Affirmative Action Employer

Nature Works Organics April 3, 2012
NOV/NOI (NOV-2012-OP-0005) WQ0035777
to February 22, 2012, when Nature Works Organics received a residuals land application
permit (Permit No. WQ0035777) from DWQ.
This is a violation of North Carolina General Statute 143-215.1(a)(2), which prohibits
the land application of waste without a valid permit.
2. Nature Works Organics did not establish a Utilization Agreement with Mr. William
Arnold prior to distributing residuals to him. This is a violation of Permit Condition
III. 9. & 10. Permit Condition III. 10. informs the receiving party of proper residuals
handling, guidance and requirements. Residuals were improperly land applied by
Mr. Arnold likely as a result of Nature Works Organics failing to provide this required
information.
3. The following Permit Condition violations occurred at Mr. Amolds farm due to improper
land application:
• Permit Condition II. 1. — the residuals management program shall be properly
operated at all times so there is no discharge to surface waters. The improper land
application of residuals resulted in multiple points of discharge to surface waters.
The impacted unnamed tributaries flow into Fisher Creek which is classified as a
Water Supply (WS-III) water of the state. This designation identifies waters used
as sources of water supply for drinking, culinary, or food processing purposes.
The discharge of this waste into the waters of the State is also a violation of
North Carolina General Statute 143-215.1.(6).
• Condition II. 7. — land application of residuals shall be greater than or equal to
100 feet from surface waters. Our investigation determined that residuals were
applied as close as 10 feet from a freshwater pond and into an intermittent stream.
• Condition II.7. — land application of residuals shall be greater than or equal to 25
feet from a ditch or waterway. Residuals were applied into ditches and waterways.
• Condition II. 8. — land applied residuals shall not be applied at rates in
exceedance of agronomic rates. The estimated amount of Plant Available
Nitrogen (PAN) that was applied by Mr. Arnold likely is well over the approved
PAN rate for the crop and soil type located at his farm.
Records submitted to DWQ show that greater than 144 tanker loads or 936,000
gallons or more of liquid residuals from Nature Works Organics had been land
applied at Mr. Arnold's farm from December 16, 2012 through March 22, 2012.
This PAN estimation does not include other sources of PAN (i.e., poultry litter
applications, commercial fertilizers, or others) or that some fields are utilized as
pasture and do not receive the 100% PAN credit.
4. Nature Works Organics failed to institute an inspection plan for the application fields
prior to each residuals land application event. This is a violation of Permit Condition V.
2., which requires the Permittee or designee (ex. an ORC) to inspect the residuals
application facilities (i.e., application fields) prior to each land application event.
Page 2 of 5

Nature Works Organics
NOV/NOI (NOV-2012-OP-0005)
April 3, 2012
WQ0035777
5. Nature Works Organics has approximately 63,000 gallons of residuals storage capacity
located on Mr. Arnold's farm in the form of three 21,000 gallon tanks. This is a violation
of Permit Condition III. 11. which prohibits the use of an alternate storage site being
used without prior approval from the Division.
On March 15, 2012 DWQ attempted to contact Mr. Mitch Vestal of Nature Works Organics and
left a message with a Nature Works representative. Mr. Danny Cockerham of Nature Works
Organics then contacted DWQ. Mr. Cockerham was informed of the violations that had occurred
at Mr. Arnold's farm. DWQ's understanding from the conversation with Mr. Cockerham was
that the land application activities involving Mr. Arnold would be stopped until completion of
the investigation.
II. March 16, 2012 Complaint Investigation
On March 16, 2012 DWQ received an anonymous complaint alleging over application of waste
and waste being applied too close to surface waters at Mr. William Arnold's farm located, again,
on the corner of Bethel Church Road and Mize Road in Yadkin County. On March 16, 2012
Mr. Derek Denard of this office made a site visit to the subject property to investigate this
complaint.
It was confirmed by Mr. Denard that the waste material was residuals from Nature Works
Organics and that additional, new violations of the above mentioned had occurred. Mr. William
Arnold was again applying the residuals. This is a violation of Permit Condition III. 13.,
which states the Permittee shall not distribute residuals to any person or entity known to be
applying residuals contrary to the conditions required in the Utilization Agreement. Mr. Danny
Cockerham of Nature Works Organics was present at the site at the time of Mr. Denard's
investigation and was aware of March 16, 2012 complaint.
III. March 21, 2012 Follow-up Inspection & Investigation
On March 21, 2012 DWQ staff members Mr. Patrick Mitchell and Mr. Derek Denard conducted
a follow-up inspection as part of the continued investigation of Nature Works Organics. A site
meeting was scheduled with Mr. William Arnold at his farm. A separate site meeting was also
scheduled with Mr. Danny Cockerham to meet at the Nature Works Organics facility. Additional
information was requested from each meeting and later received by DWQ.
It should be noted that Mr. Arnold stated that he was still applying residuals on a regular basis
and that he had not yet received any guidance from Nature Works Organics as required in the
permit. This is a continued violation of Permit Conditions III. 13. and III.9. & 10.
During the Nature Works Organics site meeting, DWQ reiterated the violations that had occurred
to date, discussed the permit requirements with Mr. Cockerham, and once again strongly
recommended to Mr. Cockerham that Nature Works Organics work with an ORC for land
application activities. The following concerns should also be noted from the facility site visit:
A. There were two 21,000 gallon storage tanks, for a total storage capacity of 42,000 gallons
at the facility used for Class A residuals storage. Is this sufficient?
Page 3 of 5

Nature Works Organics
NOV/NOI (NOV-2012-OP-0005)
April 3, 2012
WQ0035777
B. Cracks and holes in floor of the facility potentially leaching waste offsite and/or to
ground water.
C. Spillage and the cleanout area in back of the facility leading to a ditch and bermed area.
D. There is the potential for residuals not to be treated properly to meet pathogen -vector
attraction reduction requirements at the Nature Works facility due to storage capacity at
the facility, volume of waste being transported to the facility, and the possibility of waste
being hauled to the receiving farms bypassing the treatment works. We strongly advise
you to keep detailed records of treatment, sample location, and utilization of material
used in worm beds versus land application.
IV. March 29, 2012 Complaint Investigation
On March 29, 2012 DWQ received another anonymous complaint concerning over application of
waste and the presence of a nuisance odor condition on a field adjacent to Mr. Arnold's farm
located on Bethel Church Road. On March 29, 2012 DWQ conducted a complaint investigation
at the subject field. Mr. Arnold accompanied DWQ during a brief portion of this investigation.
It was confirmed that the material being land applied by Mr. Arnold was again indeed residuals
from Nature Works Organics. No land application was occurring at the time of the site
investigation. Mr. Arnold again indicated that he has not received any guidance or requirements
from Nature Works Organics. Mr. Arnold indicated that Mr. Dennis Key of Southern Soil
Builders had met him at the subject field and shown him where to apply based upon well
setbacks and slope restrictions. Mr. Arnold alone preformed the irrigation of the residuals. The
following Permit Condition violations were noted:
• Condition II. 7. states that land application of residuals shall be greater than or equal to
100 feet from a well. A minor amount of residuals were observed to be applied and/or
tracked within 75 feet of the onsite well.
• Condition III. 8. g. states that residuals shall not be surface land applied to land with
slopes greater than 10%. There were two minor areas of the field where residuals were
observed to have been applied onto slopes >10%.
• Condition III. 13. which states the Permittee shall not distribute residuals to any person
or entity known to be applying residuals contrary to the conditions required in the
Utilization Agreement. This was the third confirmed complaint that DWQ had received
concerning land application activities of Mr. Arnold applying Nature Works Organics
residuals.
It should be noted that our current records indicate that we have received a total of four separate
complaints concerning waste applications at Mr. William Arnold's farm since January 27, 2012.
The initial January 27, 2012 complaint was investigated by a staff member with another section
within DWQ. This anonymous complaint concerned nuisance odor conditions at Mr. Arnold's
farm resulting from the land application of waste. Given the hauling and delivery dates on the
records submitted to DWQ, this waste was likely from Nature Works Organics. Permit Condition
VI. 2. states that this permit shall become voidable if the residuals land application events are not
carried out in accordance with the conditions of this permit.
Page 4 of 5

Nature Works Organics
NOV/NOI (NOV-2012-OP-0005)
April 3, 2012
WQ0035777
Our office is considering the pursuit of punitive sanctions for these violations against Nature
Works Organics. If you wish to present an explanation for the violations cited, or if you believe
there are other factors which should be considered, please send such information to me in writing
within ten (10) days following receipt of this letter. Any additional information will be
reviewed, and if an enforcement action is still deemed appropriate, that information will be
forwarded to the Director with the enforcement package for their consideration.
Your written response should be sent to my attention at the address shown on the letterhead. Be
advised that NC General Statutes provide for penalties of up to $25,000 per day per violation as
well as criminal penalties for violations of state environmental laws and regulations.
Your immediate attention is greatly appreciated. If you have questions concerning this Notice,
please contact Mr. Patrick Mitchell or myself at [phone].
Sincerely,
Sherri V. Knight
Regional Supervisor
Aquifer Protection Section
enc.: Photos
cc: Mr. Bob Binkley, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Danny Cockerham, Nature Works Organics — 4140 Clemmons Road, Suite 296, Clemmons, NC 27012
Mr. Doug Baxter, Tyson Foods, Inc. —13264 Mountain Rd., Glen Allen, VA 23059
Mr. James Brown, Tyson Foods, Inc. —1600 River St., Wilkesboro, NC 28697
Mr. Dennis Key, Southern Soil Builders — 958 Hoots Rd., Roaring River, NC 28669
Mr. Joesph Bumgamer, Bumgarner Services — 3204 Statesville Rd., North Wilkesboro, NC 28659
Mr. William Arnold — 2617 Bethel Church Rd., Yadkinville, NC 27055
Mr. Justin Henderson, Yadkin County Health Department
Mr. Ed Hardee, APS Central Office
APS WSRO Files
Page 5 of 5

Analytical Results
Southern Soil Builders
958 Hoots Road
Roaring River NC 28669
Entered 3/27/2012
Reported: 4/11 /2012
For: N WO
Sample ID Parameter Cust ID Result Units Method Date Analyzed Analyst
120327-18.1
% Solids 1
11.7
%
SM2540B
3/27/12
CL
120327-18.1
Fecal Coliform MTF 1
20
MPN/g
SM9221 CE
3/27112
CL
120327-18.1
Geometric Mean 1
33
MPN/g
dry wt. basis
3/28/12
CL
120327-18.2
% Solids 2
11.0
%
SM2640B
3/27/12
CL
y 120327-18.2
Fecal Coliform MTF 2
45
MPN/g
SM9221 CE
3/27/12
CL
120327-18.3
% Solids 3
10.9
%
SM2540B
3/27/12
CL
120327-18.3
Fecal Coliform MTF 3
64
MPN/g
SM9221 CE
3/27/12
CL
F 120327-18.4
% Solids 4
11.2
%
SM2540B
3/27/12
CL
120327-18A
Fecal Coliform MTF 4
54
MPN/g
SM9221 CE
3/27/12
CL
" 120327-18.5
% Solids 5
10.6
%
SM2540B
3/27112
CL
120327-18.5
Fecal Coliform MTF 5
22
MPN/g
SM9221 CE
3/27/12
CL
120327-18.6
% Solids 6
10.4
%
SM2540B
3/27/12
CL
120327-18.6
Fecal Coliform MTF 6
22
MPN/g
SM92210E
3/27/12
CL
120327-18.7
% Solids 7
11.0
%
SM2540B
3/27/12
CL
120327-18.7
Fecal Coliform MTF 7
27
MPN/g
SM9221 CE
3127/12
CL
120327-18.8
% Volatile Solids In
24.1
%
SM2540G
4/3/12
CL
'1 120327-18.9
% Volatile Solids Out
11.3
%
SM254OG
4/3/12
CL
Ii Respectfully submitted,
Dena Myers /
4
NC Cert #440,
NCDW Cert #37755,
EPA NCO0909
P.O. Box 228 a Statesville, North Carolina 28687 • 704/872/4697

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