6406_CarolinaRecycledAg_Request for Name Change_1286874_20160105

Jan. 05, 2016
Mr. Anthony (Tony) Gallagher
North Carolina Department of Environmental Quality
Division of Waste Management
Mail Service Center 1646
Raleigh, NC, 27699-1646
Dear Mr. Gallagher;
Subject: Name change for ULNA Compost Operation
Universal Leaf North America (ULNA) received a permit from NCDEQ DWM to
manufacture compost from the agribusiness residues generated at the leaf
processing operation near Nashville, NC. The initial operation has been successful
and to improve marketing opportunities for this high quality compost ULNA wishes
to develop a soil blend and modify the name on the permit. The purpose of this
letter is to describe the soil blend and to request the name change.
Soil Blend: The compost generated in the aerated bin process is a very high quality
material. NCDA testing has assured us that the product is very high quality and is
well suited for a variety of end uses. One end use that offers tremendous potential to
open the market for the product is to blend the finished compost with soil material
to generate high quality topsoil. Preliminary testing of the compost in agricultural
settings indicates improvements to soil quality. The blending of the compost with
soil will help market this value added product considered a manufactured soil.
The blending will be targeted to specific use. A typical blend will involve two (2) or
three (3) parts (by volume) of compost to one part (by volume) of soil. Testing
indicates these mix or blend ratios provide soil that can be used effectively in any
application. Turf, garden, landscape, agricultural and horticultural operations can
benefit through use of this manufactured soil.
Once the manufacture is approved, samples of the blend will be submitted to NCDA
for testing. To date, none of the compost manufactured contains any regulated metal
level that raises a concern and there is no reason to assume that blending with soil
will add appreciable levels of metal to the blend. Nonetheless we will test the blends
to assure no element detected raises concern for use when the materials are used in
accord with good practice. In addition to the testing, we will develop simple
guidelines for users of the manufactured soil.

The testing will be accomplished based on the volume of the manufactured soil
produced. Testing will involve assessment of the quality of the compost through an
NCDA waste analysis and assessment of the manufactured soil through an NCDA soil
test. The soil test will include assessment of regulated metal levels as determined by
NCDA. The testing scenario is volume based in accordance with the table below.
Volume
Test Frequency
Less than 1000 cubic yards soiljyear _
1000 to 5000 cubic ards soil ear
1 soil test per year
1 test eve 6 months
5000 to 15000 cubic yards soil year
._..w,.. _- ., � __.
1 test every 3 months
15000 to 50000 cubic yards soil% ear
1 test eveg 2 months
Over 50000 cubic yards year
1 test eve month
These volumes of manufactured soil are equivalent to compost volumes of between
250 and 350 cubic yards per year for the 1000 cubic yard volume and 12,500 and
17,000 cubic yards for the 50,000 cubic yard volume. The testing frequency
proposed may be reduced if the testing conducted in the first year of operation
indicates the product is of consistent quality.
Naine Change: To better promote the use of the compost, ULNA management made
the decision to promote the use of recycled agricultural materials. The management
team here at ULNA decided to establish the recycled market as a central theme in
the company vision. Consequently, the ULNA group decided to name this new
venture "Carolina Recycled Ag Materials, LLC". This is a wholly owned subsidiary of
Universal Leaf North America. The documents attached indicate that this new
company is an integral part of the ULNA operation and is supported by our
Company President, Mr. Clayton Frasier. i will be the local manager and Mr. Kyle
Bass will be the facility manager.
The officers and managers of the new company, Carolina Recycled Ag Materials, LLC
are located in Nashville, NC. The new company remains dedicated to beneficially
utilizing agricultural residues generated at the ULNA facility in Nash County, NC and
potentially incorporating other agricultural by-products generated at sister ULNA
facilities located here in North Carolina.
The operation will occupy the permitted facility located on the ULNA property here
in Nash County. Overall responsibility for the operation remains with ULNA and the
operation simply provides a name change to promote the use of the recycled
agricultural products.
Thank you for your attention to this request. If I may be of help to you in this matter
please feel free to contact me, John Sabatini or Kyle Bass here at Universal or our

coworker Dr. A. R. Rubin who has assisted us throughout development of our
compost and beneficial use operations.
Sincerely;
M. T. Haymore, TITLE
1 Attachment: Organization Chart

Attachment 1
Carolina Recycled Ag Materials, LLC
Organizational Chart
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Kyle Bags
k F.Icillry Ma.o. ge. 1.