6406_CarolinaRecycledAg_RenewalApplication_20190801

Rec'd 8-1-2019 DW
Sherri Stanley
NCDEQDWM
A. R. Rubin, Professor Emeritus, NCSU-BAE and
President, A. R. Rubin and Associates
205 Stanton Gable Lane
Hillsborough, NC, 27278
1646 Mail Service Center
Raleigh, NC, 27699
Dear Ms. Stanley; 29 July 2019
Subject: Carolina Recycled Ag Materials Compost Facility renewal request
Messrs. Steve Crawford and Scott Frederick and I are pleased to submit this renewal
request for the compost operation serving only the Universal Leaf North America
processing facility near Nashville, NC. The initial permit for the compost operation was
approved in 2015 and the renewal request is due by 1 August 2019. This request for
renewal is hereby submitted.
The compost operation remains as described in the initial application and as approved in
the initial permit. There has been one change to the facility plan. That change is a
temporary storage area identified in the initial application has been covered with a concrete
pad to ensure better quality control over the feedstocks entering the compost operation. A
second modification is the physical mailing address change to 4330 Universal Leaf Road.
The facility was initially permitted to accommodate 50,000 tons per year. At no time during
this permit cycle has the volume approached this limit. The compost quality has been
monitored as required and the quality has been excellent. The compost product has been
used on a variety of commercial crops and the USDA has deemed the material a potential
organic amendment.
Please accept the request for the renewal attached. The initial project team has reviewed
this submittal: Mr. Steve Crawford, Mr. Scott Frederick and me. We believe the information
to be accurate.
Thank you for your review of this material.
Respectfully Submitted:
)
PE
A. R. Rubin Steve Crawford, PE
CC: Donna Wilson, NCDEQ DWM
S.J. Frederick, LSS
Section 1 -General Information -Provide a narrative discussion, including the
following:
The name of the facility: Carolina Recycled Agricultural Materials
Street address and mailing address for the facility is:
4330 Universal Leaf Road, PO Box 519, Nashville, North Carolina 27549
Facility type: The Carolina Recycled Ag Materials (CRAM) facility is a large Type II facility.
The facility was permitted previously and this is a request for a permit renewal for
Permit No. 6406-COMPOST-2014.
The facility composts only agribusiness residues from tobacco leaf processing
operations. These residues include dust from initial leaf processing, leaf and stem from
actual leaf and stem manipulation or cutting.
1. Name, address, telephone number, and email address of the applicant/owner
and contact person. Mr. Kyle Bass, Manager of the CRAM facility. The facility is
located on property located at 4330 Universal Leaf Road near Nashville, NC. Mr.
Bass can be contacted at: 252 343 1615 and his e-mail address is:
[e-mail]
2. Name, address, telephone number, and email address of the landowner, if not
the applicant. A landowner authorization form must be signed and notarized if
the facility owner/operator is not the landowner (see attached form). NA
Name, address, telephone number, and email address of the engineer and/or
composting consultant (if applicable). Project personnel are:
Steve Crawford, Crawford Engineering and Consulting, PA, 1119 Purfoy Road Fuquay
Varina, NC 27526, 919 608 0916, [e-mail]
S. J. Frederick, SWE Group, PLLC, 3216 Byers, Raleigh, NC, 27607; 919 368 2029,
[e-mail]
A. R. Rubin, 192 Stanton Gable Ln, Hillsborough, NC, 27278, 919 270 0344,
[e-mail].
The compost operation has been modified since the initial permit to include a second
impermeable feedstock storage area immediately adjacent to that initially permitted.
This new area served as a secondary feedstock storage area and as the operation grew,
the operator deemed the area better suited as storage if developed as a concrete bin,
similar to the bunker silo initially permitted. The new storage area is depicted on the
site plan provided by Mr. Crawford. The additional storage was identified in the initial
application, but the addition of the concrete allows better access to this component of
the operation. The concrete floor allows all season access to gather feedstock and the
concrete wall prevents loss of the feedstock material. The dimensions of the pad
addition are 60Ft. x 150 ft. and the pad is 6 in. thick. Wire mesh adds to the strength of
the pad floor. The pad extension construction includes a 6 in. exterior wall to prevent
product loss. The site plan is included as Attachment 2
1. Name, address, telephone number, and email address of person to receive
permit fee invoices and annual fee invoices, if applicable: Permit Fee recipient is Kyle
Bass, Listed above at CRAM.
Section 2 -Siting Requirements -Provide a narrative discussion that includes the
following items:
1. This is a permit renewal and items in Section 1 remain unchanged from the initial
permit application with the exception of the additional feedstock storage area
identified above.
Section 3 -Design Plan -Provide a narrative discussion, broken into appropriate
sections, that includes the following items: Portions of Section Ill remain unchanged
from the initial permit application. Only those portions of section Ill appropriate to the
renewal are addressed. Others are designated as "NA".
1. List the types of feedstocks, residuals, bulking materials, and amendments to be
accepted (for example, yard waste, land clearing debris, pre-consumer food
waste, post-consumer food waste, grease trap waste, agricultural waste, etc.).
For each material, provide a description, list the sources, and indicate whether it
will be accepted from the general public. Analytical data will be required for
materials that could contain metals or other contaminants, such as commercial
or industrial by-products. For wastewater treatment plant sludge/biosolids,
provide analytical analysis of total metals by SW-846 methods, for arsenic,
cadmium, copper, lead, mercury, molybdenum, nickel, selenium, and zinc, for
each waste source.
The agribusiness residues that serve as the feedstock for this operation are all
generated at the CRAM operation in Nash County. Only leaf, stem, dust and off-
specification leaf that fails to meet the rigorous product quality standards imposed by
the parent company {Universal Leaf North America) for tobacco products distributed to
the customers. The materials are accepted into the compost operation only if
generated at the ULNA facility. Typical analysis of the leaf, dust and stem is provided in
Attachment 3 to this request for the renewal. Regulated metal data as generated by the
North Carolina Department of Agriculture and Consumer Services is provided. Metal
levels reported are below those contained in the NC DWM Compost Rules (.1407, Table
1).
2. Provide an estimate of the total amount of materials to be received at the facility
per day, week, or month, in tons or cubic yards. Provide an approximate amount
for each type of feedstock to be received, per day, week, or month. Describe
any seasonal variation for any of the materials.
The CRAM facility has successfully composted and marketed the agribusiness residues
generated since the initial permit to compost was issued in 2015. Since the permit was
issued, a total of over 25,000 tons of compost has been beneficially recycled onto land
in North Carolina over the life of this operation. The materials are generated in the
tobacco leaf processing season typically extending between September and May in any
year. The volume of compost recycled in the 2018-19 processing season was
approximately 4828 tons.
3. Design capacity of the facility, best estimate. The site capacity is the incoming
volume, or throughput, per year, and is based on the compost method, duration
of the process, and the size of the facility. Show calculations for Large Type 3
and 4 facilities. This is for information purposes only, not to be regulated.
The facility was initially permitted to accommodate 50,000 tons per year and that
volume has never been exceeded.
4. Describe and provide compost recipes.
The compost recipes are proprietary and will depend on the relative volume of each
component at any given time. Typically the recipe includes between 25 and 35% of the
various feedstocks.
a. For Type 2 operations, describe plan for balancing the carbon and nitrogen ratio
("browns" and "greens").
This operation accommodates leaf and stem which are typical of the "Green" feedstock
and dust which are more typical of the "Brown" component. These residues each
reflect C:N ratios of between 20:1 and 30:1 and each will auto-compost. The balance of
C:N is reflected in the make-up of each feedstock.
b. For Type 3 and Type 4 operations, provide carbon to nitrogen ratio (C:N)
testing and calculations. There are compost recipe calculators online that can assist with
this, balancing density, moisture, and C:N ratio. NA
5. Methods used for measuring, shredding, mixing, and proportioning feedstock
materials, to insure the proper ratios are met.
The materials are transported from the ULNA processing facility to the compost site via
a variety of dump vehicles. The feedstocks are stored in one of two designated
feedstock areas and are transported to a mixer/blender as needed. The feedstocks are
measured into the mixer/blender using a front-end loader and the bucket volume serves
as the method for measuring the feedstocks. This was presented in the initial
application for the permit and the method has not changed significantly since initially
proposed.
6. A process flow diagram of the entire facility, including the type, size, and location
of all major equipment, and feedstock flow streams. The flow streams should
indicate the quantity of materials on a wet weight and volumetric basis. Also
include plans and specifications for the facility, including manufacturer's
performance data for all equipment selected.
A process flow diagram was provided in the initial application for the compost permit.
The process flow has not changed since initially proposed in the original application for
this agribusiness residue compost operation.
7. Grading and sloping of site surface to prevent ponding of water.
The original site plan has been modified to include additional storage for feedstock. The
storage bin is located adjacent to the original storage area and the concrete pad was
developed to prevent ponding. Excess water exiting this pad flows to the south
southwest and enters the stormwater system and into the level spreading basin which
will accommodate the additional stormwater without generating any discharge to the
environment.
8. Anticipated process duration for each stage of the process, including receiving,
preparation, composting, curing, and distribution:
This is an aerated bin operation, the time required to achieve the PFRP and VAR
requirements are achieved in 14 days. The VAR operation begins as soon as the
composting mass achieves a 110 degree F temperature and continues for 14 days with a
maximum temperature often exceeding 170degrees F. The PFRP portion of the
operation begins soon after the mass achieves this 110 degree level and continues for
the required 4 days with temperatures often exceeding 170 degrees F. The receiving
portion of the process typically requires between just a few days to as much as 15 days,
depending on the product quality required. The curing phase of the operation requires
up to 6 months depending on the anticipated end use of the compost. Following the
curing activity product may be transported to a staging area for several days to assure
sufficient product is available to supply specific customer needs.
9. Describe the compost method (windrow, static aerated pile, in-vessel, etc.), and
method for time and temperature monitoring.
The compost production occurs in an aerated bin. Time and temperature monitoring is
accomplished using a set of temperature monitors installed in each mass of material as
the process starts. The time and temperature monitoring is accomplished automatically
and an example of the data collected in this phase of the operation is provided as
Attachment 4 to this request for permit renewal.
.
10. For outdoor facilities, surface water control features, including run-on and run-
off. Describe plan for operation of the facility in wet weather. Surface water
must be diverted from the operational, compost curing, and storage areas. For
sites that will have run-off from the facility operation, a stormwater/wastewater
permit will most likely be required (see page 3 for contact information).
These remain as proposed in the initial application.
11. Process water or contact water (water and liquid that has come in contact with
compost or feedstocks) may either be collected and disposed of separately, or
for some facilities, it is possible that it may be combined with clean surface
water run-off for discharge from the site with a stormwater/wastewater permit.
Describe the collection, storage, and disposal of process water. Disposal may
involve connection with a sanitary sewer line, or collection in a holding tank,
with the liquid periodically pumped and removed from the site for proper
disposal. Process water may also be added back to the compost; however, time
and temperature requirements to reduce pathogens must begin again, and the
text should describe this.
This remains unchanged since the initial application.
12. Describe any amendments (lime, wood ash, gypsum, etc.) to be added to the
finished compost, if applicable, including the amount. For wood ash, provide
analytical data for total metals by methods in SW-846. Describe storage of the
amendments, maximum pile size, and methods to prevent surface water run-on
and run-off, if applicable. If wood ash is added, it should be stated that samples
for required finished compost metals analysis will be taken from the compost
after the ash is added.
Only material generated at ULNA is accepted for processing at this facility.
13. For Large Type 2, Large Type 3, and Type 4 facilities:
1. Description and sizing of the storage areas or containers for feedstocks,
amendment, recyclables, finished compost, and waste:
The addition of a second feedstock storage area was incorporated into the site design.
This area is depicted on the site map. The area covers 150 feet by 60 feet and is located
immediately adjacent to the bunker silo located on the original plan. Th is new storage
area/bin provides all season access to feedstock and prevents incorporation of soil and
stone from the secondary storage area initially identified on the plan.
2. A description of controls to address dust, odors, gas, and other air
emissions. Examples include a spray mist for dust, and a biofilter or the
application of three to six inches of finished compost cover over piles to
control odors. For indoor facilities, describe how particulates are
minimized.
The compost operation occurs in an aerated bin in a building. A layer of finish compost
is placed atop each of the bins as the process starts as a method of odor control.
3. A description of any recycling or other material handling processes used
at the facility.
Only materials generated at ULNA are composted at this site. Materials that do not
meet the rigorous compost standards imposed by CRAM are land applied through an
approval letter issued to ULNA. A copy of the approval letter is provided as Attachment
5 to this request.
Section 4 -Operation Plan -Provide a narrative discussion, broken into appropriate
sections, that includes the following items:
1. A list and description of the equipment, scales, structures, tipping floor, water
source for cleaning, hopper, and any other feedstock or compost management
devices. Also describe equipment maintenance.
Equipment available on the site include: Front End Loaders, Roto-Mixer, Screen, bin
aerators and temperature monitoring probes all as listed in the original application.
2. Site security and access control. Gates, chains, berms, fences, or other measures
to prevent unauthorized entry must secure the site.
Access to the site is controlled by a guard and the property is fenced to prevent
unauthorized access.
3. Confirm that an operator will be on duty at the site at all times while the facility
is open for public use to ensure compliance with operational requirements.
The operator and an assistant are on-site during compost mixing and blending activities,
during product removal from the bin, during placement into curing areas and removal
from curing areas and during all loading of finish compost for transport to customers.
4. Confirm that access roads will be of all-weather construction and maintained in
good condition. All access roads are well maintained and in excellent condition.
5. Access roads are all weather and are well maintained.
6. Days and hours of operation, preparations before opening, and procedures to be
followed after closing for the day.
The operations plan provides procedures for opening, operating and closing for the day.
7. Signs to be posted at the entrance. Signs must provide a description of the types
of feedstocks and residuals received, the types of waste prohibited, operating
hours, permit number, and emergency contact phone numbers. The sign should
state that no hazardous waste, asbestos containing waste, or medical waste can
be received at the site. State whether the site will receive feedstocks or residuals
from the general public.
A sign is located at the access road to the facility. The facility accepts only material from
ULNA.
8. Permanent boundary markers may be required, depending on the layout of the
site, to maintain the operation's required setbacks to the property line or to
other nearby residences, wells, floodplains, etc. If natural or existing
benchmarks don't exist, include a description of the boundary markers, installed
at intervals to allow for line of sight from one marker to the next.
No boundary markers are located within the ULNA host facility property. The CRAM
operation is located well within the ULNA property and receiving, composting and
curing areas are clearly identified on the site.
9. List of personnel required and the responsibilities of each position. For Large
Type 2, Large Type 3, and Type 4 facilities, describe personnel training (including
site specific operating conditions, safety, procedures in the event of equipment
failure) and record keeping of training records.
The personnel involved in the operation include a manager and compost production
technician. The automated operation necessitates few people involved in the activity.
Mr. Kyle Bass is the manager of the facility and Jonathan Joyner serves as a compost
'production facility technician.
10. A narrative description of the compost process, from beginning to end, to
include arrival of materials, unloading, processing, mixing, storage, composting,
curing, testing, final product storage, and removal from site. Describe the
location that each of the activities takes place, and the estimated time for
composting and curing.
The operation remains as described in the initial plan. Material is transported from the
ULNA facility to CRAM and placed into one of the two storage areas. The leaf, stem and
dust is removed by front-end loader as required and placed into the Rotary Mixer.
Materials are mixed and placed automatically onto a belt that discharge into a pile. The
pile is removed by loader and placed into a bin for composting. The bin is filled with
material and the access door closed throughout the process. The composting process
proceeds through the VAR and PFRP process within the bin and the time temperature is
monitored. Once material has achieved the required VAR and PFRP level, it is moved to
one of several designated curing areas to undergo the lengthy curing process. Product
may remain in the curing area for as long as 6 months depending on customer need. As
a customer requires compost product, it is removed, screened and the desired end
product is placed in a finish product storage area or staging area until sufficient volume
is available to satisfy customer need. The overs generated in the screening are recycled
back into the compost operation or may be applied to farmland at the ULNA site.
11. Method for screening loads for unacceptable waste. Describe plan for handling
incoming loads that contain unacceptable waste. Describe storage of the
unacceptable waste, the frequency of removal of the waste (at least weekly),
and final disposition.
Finish product is screened through a rotating screen and the customer generally
specifies the screen size desired for the finish compost.
NA
12. Any special feedstock or residual handling (e.g., odorous residuals, liquids, etc.).
13. Any amendment to be added to the compost, how it will be stored, and when it
will be added. If wood ash is used, also provide total metals lab testing of the
ash, and confirm that metals testing of the finished compost will be after ash is
added.
NA, No amendments are currently added to the compost.
14. Processing activities to prepare materials for composting, such as grinding.
No grinding is required. Th e only pre-processing is the mixing in the rota-mixer located
on site.
15. Pile sizes for feedstock, composting, curing, and final product storage (width and
height). Length is unlimited within the permitted boundary of each area.
Describe distance between rows, etc.
The aerated bins measure 12 feet x 16 feet x 8 feet. The curing bins typically measure
40 feet at the base x 100 feet in length x 5 to 6 feet in height. Curing piles are typically
covered to prevent re-wetting during the curing process.
Curing piles are typically separated by 15 to 20 feet to ensure adequate space for
vehicle operation. No storage of curing pile exceeds 20 feet in height during operations
at the CRAM facility.
15. Describe compliance with the time, temperature, and turning requirements in
Rule .1406 (11) or (12), as appropriate for the feedstock and compost method.
Describe location of monitoring points, probe depth (at least 24 to 36 inches),
monitoring frequency, and recordkeeping. Monitoring frequency during the
time and temperature requirement period should be every other day, or
Monday-Wednesday-Friday if the site is not open on weekends. The
thermometer should be a probe thermometer, and it should be stated that it will
be calibrated at least once per year. If the site is designed to meet Rule (12)(A),
then Rule (11) is automatically met.
Time/temperature compliance for VAR and PFRP is accomplished in the aerated bins.
Temperature probes are placed along the top of the composting material in each of the
aerated bins. The probes are 36 inches in length. Temperature is monitored
continuously and reported electronically to a bin record. An example is provided as
stated previously.
The temperature probes are calibrated against a NIST calibrated temperature probe
annually. The procedure and NIST certificate are provided as Attachment 6.
16. Describe other monitoring, such as moisture content, oxygen level, porosity,
carbon to nitrogen ratio testing, etc., including method and frequency.
Samples of the finish compost and the feedstocks are collected and tested periodically
during a processing year. The quality of the finish compost is reported to customers on
a product quality information sheet that reports recent product quality test results.
General nutrient testing is accomplished by NCDA & CS and a private certified laboratory
(PRISM Laboratory) accomplishes metal and biological indicator testing. Those results
are provided as attachment 7.
17. The method of aeration provided, frequency, and the capacity of aeration
equipment, for both composting and curing piles.
Individual air blowers in each of the aerated bins provide aeration. The aerators are
0.75 HP GAST Model 1023 capable of delivering over 8.5 CFP at 10 PSI as listed in the
initial product literature from Advanced Compost Systems, Inc.
18. Provide an odor management plan, which describes odor control measures and
steps to be taken in the event of unexpected offsite odors. If odorous feedstocks
are managed, that may cause odors to be detected offsite, a layer of clean
compost or other material should be placed over outdoor windrows, as
necessary, to control odors.
Odor is controlled through the covered aeration process in each of the bins. A layer of
finish compost is typically placed atop a bin to control odor if necessary.
19. Describe compost testing and the method for collecting samples, in accordance
with Rule .1408(a).
1. The sample that is collected for pathogens testing should not be collected
and held over a six-month period. The pathogens sample should be
collected as a composite sample from finished compost onsite on the
same day it is to be taken to the lab for analysis. The sample should be
processed within the hold time required by the lab testing procedure,
and this is usually six hours.
2. The sample that is collected for metals analysis is to be collected and
composited over a six-month period (or every 20,000 tons produced)
from each batch of compost. See Rule .1408(a)(2).
3. Foreign matter/man-made inerts testing may be conducted by
employees onsite (Rule .1408(a)(S)), or a sample can be sent to a lab for
testing. Describe how it will be tested.
Samples are collected as composite samples during active curing or finish product
storage. Samples are assessed by NCDA & CS since that laboratory is most trusted by
growers in NC. Samples for metal and microbiological sampling are collected randomly
from the finish product area, stored in a cooler and sent to a private laboratory for
testing as required by the permit.
The finish product is assessed to determine the foreign matter content through visual
assessment of a composite sample. The foreign matter level is assessed using a 10 and
50 power scope to ensure no small inert particles are detected.
20. Describe distribution and ultimate use of the finished compost, in compliance
with the classification requirements in Rule .1407. Describe method for removal
from the site, and a contingency plan for disposal or alternative usage of
residues or finished compost that cannot be used in the expected manner due to
poor quality or change in market conditions. Describe the distribution label or
other use instructions, in compliance with Rule .1407(g).
Finished compost is distributed in bulk to customers on a will call basis. An information
sheet is provided to all customers as they receive the product. A copy of the information
sheet is provided as Attachment 8.
21. Describe recordkeeping and annual reporting in accordance with Rule .1408 (b),
(c), and (d). Record keeping should also include personnel training, inspection
reports, and odor complaints and actions taken. Plan should indicate that a copy
of the permit, operations plan, and site drawings will be kept on site at all times.
Provide a copy of the temperature log forms and other record keeping forms.
Temperature records are maintained automatically for all bins and all probes. The
information is generated and maintained in electronic files. These files are submitted to
NCDWM annually as required.
22. Describe operational activities for surface wat_er and process water control
features (for example, drain covers, pipes, ponds, tanks). For onsite tanks,
frequency of pumping and removal.
Surface water generated from storm events is routed through level spreaders and onto
large grassed areas for assimilation into the soil. This system was approved in the initial
permit. Mr. Frederick (LSS) initially assessed these areas and there has been no change
to the soil in these areas; at present the grass crop is thriving and there has been no
runoff from the facility to any waters of the state.
Process water generated is collected in an underground tank and used as a moisture
source for the operation. This process water is blended with pond water to provide
sufficient moisture for the operation. Plan for fire prevention and actions to be taken in
the event of an accidental fire. Describe equipment provided to control accidental fires
and arrangements made with the local fire protection agency to provide services when
needed.
Water from the pond system serves as fire control if needed. In the event of a fire at the
CRAM facility, CRAM or ULNA personnel will call the local volunteer fire department
(VFD) for assistance in controlling the fire.
23. Plan for maintaining facility property in a sanitary condition and actions to be
taken to minimize noise, vectors, litter, dust, and other airborne particulates. It
should be stated that at the end of each operating day, the unloading area will
be clean and all feedstocks will be processed/mixed or properly stored. Describe
procedures to prevent blowing litter and dust from leaving the compost area and
from leaving the property.
Facility property is maintained clean and sanitary by efforts of the compost system
operators. litter, spillage from the mixer or screen, and other solids are collected and
placed into bins as needed.
24. Contingency plans for wind, heavy rain, snow, freezing weather and other
extreme weather events, air pollution, equipment breakdown, spills, unusual
traffic patterns, long-term power outages, cracks in concrete pads, etc.
Extreme weather events do not adversely impact the operation since it is accomplished
under cover. In the event of heavy winds, tornados, or hurricanes operations cease
until conditions are safe.
25. Site safety procedures concerning onsite equipment (especially grinders), safety
during unloading and loading of materials, and safety to address other possible
site hazards to workers or the public.
Only site personnel properly trained to operate equipment can manage the equipment
on site.
26. Describe closure procedures for the site, if the operation should close or become
inactive for at least 60 days (other than seasonal reasons). Plan should indicate
that all feedstocks, waste, and compost will be removed from the site within 60
days.
The site plans are to operate as long as the ULNA operation is in existence. Should
ULNA close, compost operations will cease and the product in place will be sold to the
current customers.
Section 5 -Signature Pages
Place signature page(s) at the end of the application text, before the appendices.
1. Applicant signature page (see attached). Attachment 1
2. If the landowner of the property is not the applicant, the attached certification
form by the land owner is required.
The property is owned by the parent company, Universal Leaf North America.
Section 6 -Stormwater Discharge and Sedimentation and Erosion Control Plan
For new facilities or existing facilities with proposed construction modifications, provide:
1. A copy of the sedimentation and erosion control plan and permit as required by
loca l governments and/or the NC Division of Land Resources. Include summary,
maps, and informational pages, but do not include calculation pages.
2. A copy of the DEM LR stormwater/process discharge application and permit.
Include summary, maps, and informational pages, but do not include calculation
pages.
Stormwater control measures were addressed in the initial permit and there has been
no change in the stormwater discharge pattern. Stormwater from the feedstock storage
area continues to enter the level spreader basin initially permitted and the liquid from
the spreader basin discharges onto a large, grassed pad for assimilation into site soils.
This was described in the original plan.
Attachments:
1. Signature page
2: Site Plan
3: Waste analysis of feedstock
4. Temperature example for compliance
5. ULNA land application permit
6: Sample Instrument Calibration Card
7: Test Results (PRiSM laboratories and NCDA&CS)
8: Compost Information Sheet
Signature page of applicant -/2
Name of facility t/;t/@L../ri/tl. ~CyC..LG/) A (;, J1174 7€,(( 14 ~s
I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision and that the information provided in this application
is true, accurate, and complete to the best of my knowledge.
I understand that North Carolina General Statute 130A-22 provides for administrative
penalties of up to fifteen thousand dollars ($15,000.00) per day per each violation of the
Solid Waste Management Rules. I further understand that the Solid Waste Management
Rules may be revised or amended in the future and that the facility siting and operations
of this solid waste management facility will be required to comply with all such revisions
or amendments.
Signature
0 /< £21_:_ Title -------'--------
_ 4 ,<7, ~ t/ I,/ --i ,./ A-.s:<oe-. Business or organization name
4. R. KJt, ,J l tJ ,,Jj>rint Name Date ,
-Attachment A-
Universal Leaf North America U.S., Inc.
Sites for Land Application
12/1/2018
GRAPHIC SCALE
• ; .. ; , .. ;
< IN rEET >
J
Note,,: 1. Component areas and dimensions indicated show both the previous areas and the new
concrete floor raw feedstock material storage area.
2. Drainage from the new raw material area is still to the South-southwest and is intercepted
by the existing control structure.
• E
Carolina Recycled Ag Materials, LLC Compost Facility
Facility Components
Clllfn laptrmt Id lmllilf, '6
l1l9PurfoyRoad
Fuquay Varina, NC 27S26
Telephone: [phone]
W91W.crawfordenginming.com
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_,, 1"= 100'
D,1,r£: 7114/19
ULNA_S4a.dwg
NCDA&CS Agronomic Division Phone: [phone] Website: www.ncagr.gov/agronoml/ Report No. FY19-W002826
Diagnostic
Waste Report
Links to Helpful Information
Farm: Not Provided
Sampled: Not Provided
Received: 10/30/2018
Completed: 11/01/2018
Client: A. Robert Rubin
192 Fearrington Post
Pittsboro, NC 27312
Chatham County
PALS #: 404965
Advisor:
PALS#:
Sample Information
ID: UL1
Nutrient Measurements are given in units of parts per million (ppm), unless utherwise specifed. Other Results
Nitrogen (N) P K Ca Mg S Fe Mn Zn Cu B Mo Al Na
Code: NCR
Description:
Total N: 13800 4210 74700 15600 5840 3560 89.1 80.7 44.6 8.16 29.3
C
346000 113 73.5
Non-Composted Plant
Material
Grower Comments:
Not Provided
Inorganic: 599
NH4-N 67.3
NO3-N 531 ss .5 (10 Siem)
2560
EC
(mS/cm)
25.60
pH
(Unitless)
5.53
BO
(lb/yd3)
CCE
(%)
1.75
ALE
(tons)
72.2
C:N
(Unitless)
25.1 : 1
OM
(%)
71 .3
Estimate of Nutrients Available for First Year (lb/ton) Other Results (lb/ton)
Application Method:
Broadcast
Soil Incorporated
N
19.7
19.7
P2Os K2O Ca Mg S Fe Mn
13.8 128 22.2 8.33 5.07 0.13 0.11
13.8 128 22.2 8.33 5.07 0.13 0.11
Zn
0.06
0.06
Cu
0.01
0.01
B
0.04
0.04
Mo Al
0.16
0.16
Na
0.10
T
Heavy Metals are given in units of parts per million (ppm). Heavy Metals Estimate of Availability (lb/ton)
As Cd Cr Ni Pb Se Application Method: As Cd Cr Ni Pb
1.19 0.59 0.84 Broadcast T T T
Soil Incorporated T T T
Agronomist's Comments: Insufficient information is available regarding the first year availability of nutrients in this material. The nutrient availability reported here is
therefore the TOTAL nutrients in the material. Samples submitted prior to 2016 reported an estimated value rather than total nutrient levels. Please contact me if you have
an uestions. Hunter G. Landis 11/1/2018 1 :57 PM
Cl
Se
Cl
Reprogramming of the laboratory-information-management system that makes this report possible is being funded
through a grant from the North Carolina Tobacco Trust Fund Commission.
Thank you/or using agronomic services to manage nutrients and safeguard environmental quality.
-Steve Troxler, Commissioner of Agriculture.
NCDA&CS Agronomic Division Phone: [phone] Website: www.ncagr.gov/agronomi/ Report No. FY19-W002826
A. Robert Rubin Sampled: Not Provided I Received: 10/30/2018 I Completed: 11/01/2018 Page 2 of 2
Sam~le Information Nutrient Measurements are given in units of parts per million (ppm), unless utherwise specifed. Other Results
ID: UL2 Nitrogen (N} p K Ca Mg s Fe Mn Zn Cu B Mo C Al Na Cl
Code: NCR Total N: 15300 4290 82300 15900 5950 3680 68.4 80.4 41.1 7.59 31.4 -371000 70.0 72.0 -
Description: Inorganic:
Non-Composted Plant NH4-N
Material NO3-N ss EC pH BD CCE ALE C:N DM
-5
Grower Comments: (10 Siem) (mS/cm) (Unitless) (lb/yd3) (%) (tons) (Unitless) (%)
Not Provided 2590 25.90 5.61 ---24.3: 1 71.3
Estimate of Nutrients Available for First Year (lb/ton) Other Results (lb/ton)
Application Method: N P2Os K2O Ca Mg s Fe Mn Zn Cu B Mo Al Na Cl
Broadcast 21.8 14.0 141 22.7 8.49 5.25 0.10 0.11 0.06 0.01 0.04 -0.10 0.10 -
Soil Incorporated 21 .8 14.0 141 22.7 8.49 5.25 0.10 0.11 0.06 0.01 0.04 -0.10 --
Agronomist's Comments: Insufficient information is available regarding the first year availability of nutrients in this material. The nutrient availability reported here is
therefore the TOTAL nutrients in the material. Samples submitted prior to 2016 reported an estimated value rather than total nutrient levels. Please contact me if you have
anv auestions.
Understanding the Waste Report
Nutrient concentrations and other data on this report are provided so that waste materials can be applied at agronomic rates, thereby supplementing or reducing fertilizer
application and preventing environmental contamination. In reading the Laboratory Results section, remember that materials with < 15% dry matter (generally liquids) are
analyzed as received; all other wastes are dried first. Values in the Estimate of Nutrients Available for First Crop section are based on the type of waste and method of
application you specify and reflects the fact that only 40-60% of the nitrogen becomes available within one year of application. The remainder may or may not ever become
available.
ALE is Agricultural Lime Equivalence. The ALE OM% is percent Dry Matter [for semi-solid and Al = Aluminum Cu = Copper NH4-N = Ammonium -N
indicates the amount of the waste material that solid waste, this value facilitates conversion of As = Arsenic Fe = Iron Ni = Nickel
provides a limiting effect equivalent to one ton of dry-basis concentrations (ppm) back to B = Boron K = Potassium NO3-N = Nitrate -N
agricultural grade limestone. wet-basis of original sample]. Ca = Calcium Mg = Magnesium p = Phosphorus
BO is Bulk Density in lb/yd3• EC (Electrical Conductivity) measures Cd = Cadmium Mn = Manganese Pb = Lead
CCE is Calcium Carbonate Equivalence and is salinity, or soluble salts (SS). Cl = Chloride Mo = Molybdenum s = Sulfur
used to determine ALE. pH measures basicity/acidity. Cr = Chromium N = Nitrogen Se = Selenium
C:N ratio is the Narbon:Nitrogen ratio. Na = Sodium
meq/L = milliequivalent per liter; ms = millisiemens; ppm = parts per million or mg/L; S = siemens; T = trace (<0.005 lb/unit)
Additional information: www.ncagr.gov/agronomi/i;idffiles/uwaste.i;idf & www.ncagr.gov/agronomi/i;idffiles/wasteguide.i;idf
/Jr c.1-/ 1
ULNA INSTRUMENTATION CALIBRATION CARD
I COMMENTS
lNITlAL FINAL PREY. CALIBRATOR/S NAME SIGNATlJRE ERROR ERROR CAL. SIN PIN: A36PF OF OF
DATE AUTHOR AUTHOR
Temperature X Temperature X Cal Date 9/15/16
Moisture D Moisture [J Due Date 9/15/17
SIN
Cal Date
Due Date
SIN
Cal Date
Due Date
100 0,'c C).~
::r.~0-jl'Rf 1-1 140 \.3 \o 3 NA. 180 L?.:. J '2,.
10 0 ~.1+ o.~ C 1/rZ./1 1 4~4 I '-tO o .. -, 041 r:=if 2-1/ /6 v 9li1.,,f ,s .s~M( 180 6L.15 n."5
\oo o.~ o.s C 9/11/li Ho \.C) i" 9/ J'2-/n 0,Tc-1r-o.( 4.{'-4 \'60 C),5 05 ·D 9 In I 111
I
I
GAUGE IDENTIFICATION: Compost RTD
GAUGE DESCRIPTION: Krohne Temperature Sensor
GAUGE SERIAL #: IA
GAUGE LOCATION: Carolina Recycled Ag Materials
REQUIRED CALIBRATION FREQUENCY: Annual
TEMP CALIBRATION LIMITS OF ERROR: (l00°F +/. 2.2°F). (1 40°F +/-2.2°F), (180°F +/-2.2°F) (check box)
MOISTURE CALIBRATION LIMITS OF ERROR: (ZERO:+/-) (SPAN:+/-) (HYSTERESIS:+/-)
F-ULN-7.6-002
Rev. I
Pagel of I Approved by: Dan Fuller
Effective: 10/13/08
DATE
cy2-1/1c,
9/ r2./ 11
9/J<t/ 11)
ROY COOPER NORTH CAROLINA
Environmental Quality Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Direcror
Mr. John A Sabatini
Assistant Vice President, Engineering
Universal Leaf North America US, Inc.
3174 Boddie Mill Pond Road
PO Box 519
Nashville, North Carolina 27549
Dear Mr. Sabatini:
January 8, 2019
The Division of Waste Management, Solid Waste Section, has reviewed your proposal,
submitted through Dr. AR. Rubin, to continue the land application of tobacco dust on the
property owned by Universal Leaf North America US, Inc. in Nash County, NC. The tobacco
dust will originate from the Universal Leaf processing facility in Nash County, NC. The proposal
is considered approved with the following conditions.
1. No approvals will be made after August 1, 2020 for any land application site having a soil pH
greater than the optimal range suggested by the NCDA&CS for the proposed crop.
2. Tobacco dust shall be land applied in accordance with the proposal submitted by Dr. AR.
Rubin.
3. At no time shall tobacco dust be land applied when the soil is saturated to within 12 inches
of the soil surface or when land application activities will result in depressions in the soil
surface in excess of 3 inches.
4. Moisture content of the dust shall be adequate to prevent drift off land application areas.
5. Tobacco dust shall not be land applied on bare ground unless the area land applied on will
be vegetated within 30 days of land application.
6. No more than 1.5 inches of tobacco dust not to exceed 9 tons/acre may be applied to a site
in a 12-month period.
7. No more than 3 tons/acre, approximately½ inch, of tobacco dust may be applied on a cover
crop, unless within 30 days of planting a primary crop. A cover crop must cover at least
80% of the soil surface over the entire area to be used for tobacco dust.
8. Reseeding of the forage stand and timely weed control measures shall be implemented to
ensure that a healthy receiver crop with at least 80% coverage remains established on the
application sites. Forested areas shall maintain the appropriate number of trees per acre to
be utilized for dust applications.
9. The following minimum setbacks shall be maintained:
.Residences or businesses 400 feet
Surface Waters 25 feet when vegetated in accordance with Dr.
Rubin's proposal
State road right of way 25 feet
North CaroUna Department of Environmental Quality I Division of Waste Management
217 West Jones Street I 1646 Mail Service Center I Raleigh. North Carolina 27699-1646
919.707.8200
Ditches or drainage ways 20 feet
Property Lines 25 feet
Wells 100 feet
10. Documentation must be maintained that tobacco dust from tobacco sources outside the
United States do not contain chemical residues or metal levels in excess of dust from
domestic tobacco.
11. Tobacco dust may not be stored in the fields for more than one week and may not be stored
on slopes greater than 6%. Sites where longer storage in the field is necessary due to
weather conditions shall be stabilized down slope with hay bales and vegetation to control
and filter runoff. In no case shall tobacco dust be stored outside for more than 90 days.
12. Division of Waste Management staff may visit the site any working day during regular hours
to observe land application activities or review records and may visit the site at any time to
respond to complaints.
13. An annual report, containing the information outlined in the proposals, must be submitted by
August 1 of each year for the previous July 1 through June 31. The report shall include the
amount of dust land applied on each field or test plot, the amount of nutrients added the
commercial cost of those nutrients and the results of testing. In addition, soil testing of each
field shall include a Heavy Metals Soil Report.
14. This approval shall expire August 1, 2020. This approval may be withdrawn at any time that
the conditions of the approval are not followed or a threat to public health or the environment
is created. If an extension is desired a properly completed application shall be submitted at
least 90 days prior fo that date.
Mr. Davey Conners, Environmental Specialist II will be primarily responsible for site
inspections. Mr. Conners can be reached at 919 707-8290.
If you have any questions regarding this approval, please contact me at 919-707-8210.
cc: Davey Conners, Environmental Specialist II
Dr. A.R. Rubin
Sincerely,
d I. h Digitally signed by Adam A am u IS ney ulishney
Date: 2019.01.08 13:27:10 -05'00'
Adam Ulishney
Environmental Compliance Branch Head, DWM
Solid Waste Section
Mr. Kyle Bass, Universal Leaf North America, US Inc.
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street I 1646 Mail Service Center I Raleigh. North Carolina 27699-1646
919.707.8200
Carolina
Recycled Ag
Materials LLC
Purpose
Compost RTD Probe Verification
To describe the method to verify the accuracy of RTD Probes used to measure
compost bin temperatures.
Method of Verification
This method shall be used to verify that Compost RTD Probes are reading within
the manufactures limits of error.
a) Items needed are an induction hotplate, large pot and water.
b) Place the pot on the induction hotplate and fill the pot with approximately
four gallons of water.
c) Using a stand that will accommodate the three bin probes and the calibrated
temperature reading device. Place the probes in the water, assuring the tips
are about two inches from the bottom of the pot.
d) Turn the induction hotplate on to raise the temperature of the water.
e) As the water is heating, monitor the calibrated temperature reading device.
Once a temperature of 100° Fis obtained record the RTD Probe initial error
on the calibration card. Repeat this process at 140° F and 180° F.
CRAM RTD Probe Cal.
Rev. 0
Example
Pagel of 1 Approved By: Kyle Bass
Effective Date: 09/1 6/1 6
TJMNSQT ® CERTlFlCATE OF CALIBRAT.ION
Trust in every measure
Customer: UNIVERSAL LEAF N.A. (NASH FAC)
3174 BODDIE MILL POND ROAD
NASHVILLE, NC 27856
PO Number: 79462
" ANAB
ACCREDITED
ANSI/NCSl ZS~0-1
ANAB AC-2489
Certificate/SO Number: 1-B7I4V-60-1 Revision 0
Manufacturer: Hart Scientific/Fluke
Model Number: 9103
Description: Calibrator, Dry Block, -25° to 140°C, ±0.25°C
Serial Number: A17234
ID: 2 00-210-10451
As-Found: O ut Of Tolerance
As-Left: In Tolerance
Calibration Date: May 08, 2018
Due Date: May 08, 2019
Calibrated To: Manufacturer Specification
Calibration Procedure: 1-AC08874-0
Transcat Calibration Laboratories have been audited and found in compliance with ISO/IEC 17025:2005. Accredited calibrations performed within the Lab's Scope of
Accreditation are indicated by the presence of the Accrediting Body's Logo and Certificate Number. Any measurements on an accredited calibration not covered by that
Lab's Scope of Accreditation are listed in the notes section of the certificate. sec, NRC. CLAS or ANAB do naj_ guarantee the ~ccunicy of an indiviqu=al~ca=lib~r=at=io~n=b_.y _____ _
accredited laboratories.
Transcat calibrations, i.s applicable, are performed in compliance with the requirements of the Tran scat Quality Manual QAC-P01-000 Revision 1 :0, the customer's
Purchase Order and/or Quality Agreement requirements, ISO 9001 :2008, ANSVNCSL 2540.1-1994 (R2002). Complete records of work performed are maintained by
Transcat and are available for inspection. Laboratory standards used in the performance of this calibration are listed below.
Transcat documents the traceability of measurements to the SI units through the National Institute of Standards and Technology (NISD, or the National Research Council
of Canada (NRC), or other national measurement institutes (NMI) that are signatories to the CIPM Mutual Recognition Arrangement. or accepted fundamental and/or ---
natural physical constants, or by the use of specified methods, consensus standards or ratio type measurements. Documentation supporting traceability information is
available for review upon written request at a Transcat facility. The measured quantity and the measurement uncertainty are required for Further dissemination of
traceability.
Uncertainties are reported with a coverage factor k=2, providing a level of confidence of approximately 95%. All calibrations have been performed using processes
having a TUR of 4:1 or better (3:1 for mass calibrations), unless otherwise noted. The Test Uncertainty Ratio(TUR) is calculated in accordance with NCSL International
RP-18. For mass calibrations: Conventional mass referenced to 8.0 g/cm'.
The results in this report relate only to the item calibrated or tested. Recorded calibration data is valid at the time of calibration within the stated uncertainties at the
environmental conditions noted. The determination or compliance to the specification is specific to the model/serial no./1D no. referenced above based on the tolerances
shown; these tolerances are either the original equipment manufacturers (OEM's) warranted specifications or the client's requested specifications. This certificate may
not be reproduced except in full, without the written approval of Transcal Additional information, if applicable may be included on separate report(s).
Notes:
The OOT readings were verified. Received out of tolerance, Calibrated, Returned in tolerance.
Date Received: April 27, 2018
Service Level : R6 Certificate -Page 1 of 3 Customer Number: 1-528209-000
0PS-F20-013R1 01/23/2017 FP001R1 10/12/2017
TRANSQT ® CERTIFlCA TE OF CALlBRATION
Trust in every measure
Customer: UNIVERSAL LEAF N.A. (NASH FAC)
3174 BODDIE MILL POND ROAD
NASHVILLE, NC 27856
PO Number: 79462
AC C R ED I TED
ANSI/NCSL 2540•1
ANAB AC-2489
Certificate/SO Number: 1-B7I4V-60-1 Revision 0
Description
Temperature Source
Temperature •c
Temperature °F
Description
Temperature Source
Temperature °C
Temperature °F
As Found Data
Setpoints Accuracy Low Limit
-20.00°c ±( 0.25 °c) -20.25
0.0°c ±( 0.25 °c) -0.25
25.0°c ±( 0.25 ·c) 24.75
5o.o·c ±( 0.25 °c) 49.75
100.o·c ±( 0.25 °c) 99.75
40...00~_--±{...o.25.;c) 39 ZS
32.0°F ±( 0.4 °F) 31.60
212.oo·F ±( 0.4 °F) · 211 .60
As Left Data
Setpoints Accuracy Low Limit
-20.oo·c ±( 0.25 °C) -20.25
o.o·c ±( 0.25 °c) -0.25
25.o•c ±( 0.25 °c) 24.75
5o.o·c ±( 0.25 °c) 49.75
100.o·c ±( 0.25 °c) 99.75
140.oo·c ±( 0.25 °c) 139.75
32.0°F ±( 0.4 °F) 31.60
212.'00°F ±( 0.4 °F) 211.60
Traceable Standards
High Limit As Found
-19.75 -20.34 ·c
0.25 -0.24 ·c
25.25 24.86 ·c
50.25 49.93 ·c
100.25 100.02 °c
14025 39.99 °G
32.40 31.57 °F
212.40 212:04 °F
High Limit As Left
-19.75 -20.04 ·c
0.25 0.01 °c
25.25 24.99 ·c
50.25 50.01 °c
100.25 100.01 ·c
140.25 140.03 °c
32.40 32.02 °F
212.40 212.02 °F
0
0
T
0
0
T
Asset Manufacturer Model Number Description Cal Date Due Date Traceability Number
101156 AccuMac AM1760-12-B Secondary SPRT 31-Oct-17 31-Oct-18 15-& 101156-3-1
Corporation
3053 Hart Scientific/Fluke 2560 Black Stack, PRT 26°Oct-17 31-Oct-18 5-&3053-17-1
The use of the standard is defined as: AF -used for as-found readings, AL-used for as-left readings.
TUR
TUR
Use
AF/AL
AF/AL
Date Received: April 27, 2018
Service Level : R6 Certificate -Page 2 of 3 Customer Number: 1-528209-000
OPS-F20-013R1 01/23/2017 FP001R110/12/2017
TRANSQT ® CERTlFlCATE OF CA'LlBRA TION
Trust in every measure
Customer: UNIVERSAL LEAF N.A. (NASH FAC)
3174 BODDIE MILL POND ROAD
NASHVILLE, NC 27856
PO Number: 79462
Certificate/SO Number: 1-87I4V-60-1 Revision 0
As Found:
As Left:
Calibrated At·
35 Vantage Point Dr
Rochester, NY 14624
Temperature
71.55°F /21.97°C
72.1 fF / 22.28°C
Facility ResponsibJe:
35 Vantage Point Dr
Rochester, NY 14624
800-828-14 70
Unit Barcode: 1111~11111111m 1rnrn111111110011111111
900A3325338
Date Received: April 27, 2018
Service Level : R6
Environmental Data
Relative Humidity
37.20%
40.10%
Calibrated By: ~fa Electronically Signed By:
. "Jeremy Cwiklinski
Revjewed By:
Temp/ RH Asset
2958B
29588
~--Electronically Signed By: . !W Frederick Tank
Jeremy Cwiklinski
Calibration Technician
May 08, 2018 Frederick Tank May 08, 2018
13:21 :45 -04:00 11 :29:45 -04:00 Lab Manager
Certificate -Page 3 of 3 Customer Number: 1-528209-000
OPS-F20-013R1 01/23/2017 FP001R1 1011 2/2017
"TR4NS01T ® SUPPLEMENTAL REPORT
Trust in every measure CALIBRATION LAB OUT OF TOLERANCE DATA AS FOUND
Customer: UNIVERSAL LEAF N.A. (NASH FAG)
PO Number: 79462
Certificate/SO Number: 1-B7I4V-60-1 Revision 0
Manufacturer: Hart Scientific/Fluke
I
Model Number: 9103
Description: Calibrator, Dry Block, -25° to 140°C, ±0.25°C
Serial Number: A17234
ID: 200-210-10451
Description
Temperature Source
Temperature •c
Temperature °F
Setpoints
-20.oo•c
32.0°F
Accuracy
±( 0.25 °cJ
±( 0.4 °F)
As Found Data recorded from May 07, 2018 to May 08, 2018
Service Type: R6
Calibration Date: May 08, 2018
Due Date: May 08, 2019
Calibration Procedure: 1-AC08874-0
Low Limit High Limit As Found
-20.25 -19.75 -20.34 ·c
31.60 32.40 31.57 °F
8 T TUR
* r_;s~_-·i . I ~' r,
~ . . .. ;
_T..:;.;em-"-pec.cr"'"at=u.;,..;re:'-7'-1:...:..6=-0.c...F..:../-=2-=-2.;..::;0....:°C"----~Relative HumidityJ~Z~%~---..:..Te,._,m"""p'RH ASSJl::.i.·~2:;,:;9;;::5::::8B~--------------------
Asset Manufacturer Model Description Cal Date Due Date Traceability Numbers
101156
3053
AccuMac Corporation AM 1760-12-B Secondary SPRT
Black Stack, PRT
Oct 31, 2017 Oct 31, 2018 15-&101156-3-1
Hart.Scientific/Fluke 2560 Oct 26,. 2017 Oct 31, 2018 5-&3053-1 7-1
Remarks:
The OOT readings were verified. Received out of tolerance, Calibrated, Returned in tolerance.
Calibration Lab Out of Tolerance Data Report (As Found Data) -Page 1 of 1
., Field not applicable. (P = Pass, F = FaiQ Certificate/SO Number: 1-B714V-60-1 Revision O
OPS-F20-011 R1 04/01/2017
,,
ULNA INSTRUMENTATION CALIBRATION CARD (7) (~7 :;J,J l'},Z u J
1 V;✓1CrtL
INITIAL FINAL PREY. CALIBRA TOR/S NAME SIGNATURE
COMMENTS ERROR ERROR CAL. CALIBRATOR OF OF DATE
Temperature ~ V ✓ DATE AUTHOR AUTHOR
C\-\at.tJ c~·1 \\--l. Temperature ~ SIN Al7234
~ \\...ov->'':) \-c..""Q '. Moisture Q Moisture 2 HART 9103-A See See Attached
Thermo-well Attached Cal. sheet
1oc/, 1'io", 1s-o• Cal Date5/26/l 6 Cal. sheet
Due Date5/26/l 7
\OV 0 0. r Jr,.. As /~c,v-e. <f)1 T),_} ?;-J. 9/1511~ I'-{(; C 0
i B°D -\. l) -\· 6 3'
tc,U -\ ,() -l.o .4&-A ,,~ <CJ)_<?)_ 14.c, -Lo -1 -6 '1/l~}lb D. $h-,,..:.,\ °1/ l'Z/1' 7
(%0 -l. () -1.0
160 (\ 0
Cff 1.o_( ti Ao~~
I~
140 -\.D -\.<', c).~'40 C\/\11[ 11 1io -f'J.~ -o.~ \~ -. ...,_._
GAUGE IDENTIFICATION: Compost Temperature Probe
GAUGE DESCRIPTION: Dial Analog Thermometer
GAUGE SERIAL #
GAUGE LOCATION: Compost
REQUIRED CALIBRATION FREQUENCY: Annually
TEMP CALIBRATION LIMITS OF ERROR: (50°F +/-l .5°F ). ( I 00°f7 +/-l .5°F). (200°F +/-I .5°F) or ( l 50°F +/-I 5°F) (check box)
MOISTURE CALIBRATION LIMITS OF ERROR: (ZERO:+/-) (SPAN:+/-) (HYSTERESIS: T/--/Ji' -1-e.,"'-p, O..u..o,n:,{;"5 ¼. •
\.,-ls <\.\'.. "\v--..cJ1v'\S '. {Du ;. /lfo,
Approved by: Dan Fuller , I~IJ~
Effective: 10/13/08 t,~
F-ULN-7.6-002 Pagel of I
Rev. 1
Full-Service Analytical &
Environmental Solutions
NC Certification No. 402
NC Drinking Water Cert No. 3TT35
SC Certification No. 99012
Case Narrative
7/9/19 15:34
Carolina Recycled Ag Materials LLC
Kyle Bass
PO Box 519
Nashville, NC 27856
Project: Compost
Project No.: CRAM Compost
Lab Submittal Date: 06/26/2019
Prism Work Order: 9060370
This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample
Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed
according to the referenced methods.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case
narrative.
Please call if you have any questions relating to this analytical report.
Respectfully,
PRISM LABORATORIES, INC.
Robbi A.Jones
President/Project Manager
Data Qualifiers Key Reference:
BRL Below Reporting Limit
MDL Method Detection Limit
RPO Relative Percent Difference
Reviewed By Robbi A. Jones
President/Project Manager
* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and
reporting limit indicated with a J.
This report should not be reproduced, except in its entirety, without the written consent of PTism Laboratories, Inc.
449 Springbrook Road -P.O. Box 2'40543 -Charlotte, NC 28224-0543
Phone: [phone] • Toll Free Number: 1-800/52~64 -Fax: [phone] Page 1 of 6
Client Sample ID
CRAM Compost
Full-Service Analytical &
Environmental Solutions
Lab Sample ID Matrix
9060370-01 Solid
Sample Receipt Summary
07/09/2019
Prism Work Order: 9060370
Date/Time Sampled Date/Time Received
06/25/19 12:30 06/26/19 10:10
Samples were received at 22.9 degrees C. See case narrative for further information.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road· P.O. Box 240543 · Charlotte, NC 28224-0543
Phone: [phone] -Toll Free Number: 1-800/529-6364 • Fax: [phone] Page 2 of 6
Full-Service Analytical & Laboratory Report
Environmental Solutions
LAl!IQRATOfflu.l,NC.
Carolina Recycled Ag Materials LLC Project Compost Client Sample ID: CRAM Compost
Attn: Kyle Bass Prism Sample ID: 9060370-01
PO Box 519 Project No.: CRAM Compost Prism Work Order: 9060370
Nashville, NC 27856 Sample Matrix: Solid Time Collected: 06/25/19 12:30
Time Submitted: 06/26/19 10:10
Parameter Result Units Report MDL Dilution Method Analysis Analyst
Limit Factor Date/TTme
General Chemistry Parameters
% Solids 62.3 %by 0.100 G.100 1 •sM2540G 7/9M9 9:20 KBS
Weight
Microbiological Parameters
Fecal Colifonns BRL MPN/g dry 0.3 •sM9221 E 6/26/19 11 :00 BMS
Total Metals
Mercury BRL mg/kg dry 0.080 0.028 "7471B 7/3/19 12:06 MMR
Arsenic BRL mg/kg dry 1.6 0.21 •50100 6/28/19 13:15 JAB
Cadmium 1.6 mg/kg dry 0.80 0.054 ·6010D 6/28/19 13:15 JAB
Copper 16 mg/kg dry 4.0 0.55 1 ·60100 6/28/19 13:15 JAB
Lead 3.2 mg/kg dry 1.6 0.27 1 •so100 6/28/19 13:15 JAB
Nickel 4.1 mg/kg dry 1.6 0.48 •6010D 6/28/19 13:15 JAB
Selenium 1.7 mg/kg dry 1.6 0.44 ·60100 6/28/19 13:16 JAB
Zinc 78 mg/kg dry 16 2.3 •60100 6/28/19 13:15 JAB
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road -P.O. Box 240543 -Charlotte, NC 28224--0543
07/09/2019
Batch
ID
P9G0125
P9F0424
P9G0069
P9F0439
P9F0439
P9F0439
P9F0439
P9F0439
P9F0439
P9F0439
Phone: [phone]-Toll Free Number: 1-300/529-6364 -Fax: [phone] Page 3 of 6
Full~Service Analytical &
Environmental Solutions
Level II QC Report
7/9/19
Carolina Recycled Ag Materials LLC
Attn: Kyle Bass
Project Compost Prism Work Order: 9060370
Time Submitted: 6/26/2019 10:10:00AM
PO Box 519 Project No: CRAM Compost
Nashville, NC 27856
Total Metals -Quality Control
Analyte
Batch P9F0439 -3050B
Blank (P9F0439-BLK1)
Arsenic
Cadmium
Copper
Lead
Nickel
Selenium
Zinc
LCS (P9F0439-8S1)
Arsenic
Cadmium
Copper
Lead
Nickel
Selenium
Zinc
Batch P9G0069 • 7471B
Blank (P9G0069-BLK1)
Mercury
LCS (P9G0069-BS1)
Mercury
Reporting
Result Limit Units
BRL 1.0 mg/kg wet
BRL 0.50 mg/kg wet
BRL 2.5 mg/kg wet
BRL 1.0 mg/kg wet
BRL 1.0 mg/kg wet
BRL 1.0 mg/kg wet
BRL 10 mg/kg wet
12.9 1.0 mg/kg wet
12.8 0.50 mg/kg wet
13.4 2.5 mg/kg wet
12.8 1.0 mg/kg wet
13.0 1.0 mg/kg wet
12.5 1.0 mg/kg wet
12.3 10 mg/kg wet
BRL 0.050 mg/kg wet
0.424 0.050 mg/kg wet
Spike
Level
Source %REC
Result %REC limits
Prepared & Analyzed: 06/28/19
Prepared & Analyzed: 06/28/19
12.50 103 80-120
12.50 102 80-120
12.50 107 80-120
12.50 103 80-120
12.50 104 80-120
12.50 100 80-120
12.50 99 80-120
Prepared & Analyzed: 07/03/19
Prepared & Analyzed: 07/03/19
0.4167 102 80-120
RPO
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road -P.O. Box 240543 -Charfotte, NC 28224--0543
Phone: 704/529~364 • Toll Free Number: 1-800/529~364 -Fax: 704/525.o409
RPO
limit Notes
Page 4 of 6
Full-Service Analytical &
Environmental Solutions
Level II QC Report
7/9/19
Carolina Recycled Ag Materials LLC
Attn: Kyle Bass
Project: Compost Prism Work Order: 9060370
Time Submitted: 6/26/2019 10:10:00AM
PO Box 519
Nashville, NC 27856
Microbiological Parameters -Quality Control
Analyte
Batch P9F0424 -NO PREP
Blank (P9F0424-BLK1)
Fecal Coliforms
Prep Method: Solids, Dry Weight
Lab Number Batch
9060370-01 P9G0125
Prep Method: 30508
lab Number Batch
9060370-01 P9F0439
Prep Method: 74718
Lab Number Batch
9060370-01 P9G0069
Project No: CRAM Compost
Reporting
Result limit Units
BRL 0.2 MPN/g wet
Spike
Level
Source %REC
Result %REC limits
Prepared & Analyzed: 06/26/19
Sample Extraction Data
Initial Final Date/Time
30 g 30 g 07/08/19 16:52
Initial Final Datemme
2 g 50 ml 06/28/19 7:40
Initial Final Datemme
0.6 g 50 ml 07/03/19 8:25
RPD
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road -P.O. Box 240543 -Charlotte, NC 28224-0543
Phone: 704/S29-6364 -Toll Free Number: 1-800/529-6364 -Fax: 704/S25-0409
RPD
limit Notes
Page 5 of 6
Full Service Anelytlcal & Environmental Soluttons
449 Springbrook Road • P.O. Box 240543 • Charlotte, NC 28224-0543 Phone: [phone] • Fax: [phone]
Client Company Name: Carolina Recycled Ag Materials LLC
Report To/Contact Name: _K..;.Y_1•_6•_•_• ________ _
Reporting Address: _P_o_a_ox_s_10 __________ ~
Nashville, NC 27856
CHAIN OF CUSTODY RECORD
PAQW _1 _ OF'_1_ QUOTE• TO INSURE PRon11 ■ILLINO, -------1
Project Name: _c_RA_M _______________ _
Short Hold Analysis: (Yes) (No) UST Project: (Yes) (No)
•Please ATTACH any project specific reporting (QC LEVEL I .II Ill IV)
provisions and/or QC Requirements
Invoice To:_K_Yl_• _9•_••-------------------
Addreas: PO Box 519
Nashville, NC, 27858 Phone: [phone] Fax (Yes) (No): _____ _
Email (V s) (No) Email Address [e-mail] Purchase Order No./Bililng Reference _________ _ TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
EDD Type:_ PDF_ Excel_Othar Requested Due Date 1 Day 2 Days 3 Days
"Wortdng Days" 6-9 Days Standard 10 days
4Days 5Days Certification: NELAC __ USACE __ FL NC __
Site Location Name: corollna Recycled Ali MAterlal• LLC SC_ OTHER ___ NIA __
Site Location Physical Address: _4_3_30_u_n1_va_rs_a1_L_••-' o_r1_v• __ _
.Samples received after 15:00 wlll be processed next business day.
Turnaround time Is based on busl~ess days, excluding weekends and holidays.
(SEE REVERSE FOR TERMS & CONDITlONS REGARDING SERVICES
RENDERED BY PRISM LASORATORIEB, INC. TO CLIENT)
Water Chlorinated: YES NO
Nashvlle, NC 27856 Sample Iced Upon Collection: YES NO
CLIENT
SAMPLE DESCRIPTION
CRAM Compost
Sampler's Signature
Rellnqulsh8<1 By: (Signature)
DATE
COLLECTED
TIME
COLLECTED
MILITARY
HOURS
06/25/2019 12:30
MATRIX
(SOIL,
WATER OR
SLUDGE)
SAMPLE CONTAINER J ANALYSES REQUESTI!D
PRESERVA• ~
'TYPE TIVES ~ SEE BELOW NO, SIZE ;:E
Soil G 2 1 PT
M. Kyle Bass Sampled By (Print Name)
Received By: (Signature)
Reoolvod For Pr'!Sm Labomtorles By:
✓ ✓
Affiliation
Oota
\0(0
70
ST: l GROUNDWATER: I DRINKING WATER: I SOLID WASTE: I RCRA: l CERCLA I LANDFILL I OTHER: NC -SC -NC -SC -NC -SC _ NC _ SC _ NC _ SC _ NC _ SC _ NC _ SC _ NC _ SC ---~--------------------·coNTAINER TYPE CODE91 A= Amber C = Clear G = Glass P = Plastic; Tl= Terton-Uned Cap VOA= Volatile Organics Analysis (Zero Head Space)
REMARKS
Coliform (By MPN)
Hg, As, Cd, Cu, Pb,
Ni, Se, Zn
PRISM
LAB
IDNO.
PRESS DOWN FIRMLY · 3 COPIES
...
SEE REVERSE FOR
TERMS & CONDITIONS
OR\GINAL
<O -0
<O
(1)
i a.
NCDA&CS Agronomic Division Phone: [phone] Website: www.ncagr.gov/agronomi/ Report No. FY19-W008250
Kyle Bass Sampled: 06/25/2019 I Received: 06/26/2019 I Completed: 07/08/2019 Page 3 of4
Saml!le Information Nutrient Measurements are given in units of parts per million (ppm), unless utherwise specifed. I Other Results
ID: era 19 Nitrogen (N) I p K Ca Mg s Fe Mn Zn Cu B Mo I C Al Na Cl
Code: FCW Total N: 23900 I 3130 27600 27100 5690 3190 3800 257 80.0 14.0 33.8 -I 302000 3430 93.0 -
Description: Inorganic: ~-----------------------L _________ Compost, Plant NH4-N
Material NO3-N I ss EC pH BD CCE ALE C:N DM -5
Grower Comments: I (10 Siem) (mS/cm) (Unitless) (lb/yd3) (%) (tons) (Unitless) (%)
Not Provided 1750 17.45 6.10 -6.50 21.7 12.7 : 1 63.8 I
Estimate of Nutrients Available for First Year (lb/ton) I Other Results (lb/ton)
Application Method: I N P2Os K2O Ca Mg s Fe Mn Zn Cu B Mo I Al Na Cl
Broadcast I 30.5 9.15 42.2 34.5 7.27 4.07 4.85 0.33 0.10 0.02 0.04 -I 4.38 0.12 -
Soil Incorporated I 30.5 9.15 42.2 34.5 7.27 4.07 4.85 0.33 0.10 0.02 0.04 -' 4.38 0.12 -
Agronomist's Comments: The electrical conductivity is high in this sample. If using this material in a container substrate mix, take this property into consideration.
High EC can indicate good fertilizer value. High EC can also lead to root damage especially when the material is allowed to dry out. • Insufficient information is available
regarding the first year availability of nutrients in this material. The nutrient availability reported here is therefore the TOTAL nutrients in the material. Samples submitted prior
to 2016 renorted an estimated value rather than total nutrient levels. Please contact me if vou have anv auestions.
SCHEDULE B
COMPOST INFORMATION
Carolina Recycled Ag Materials, LLC
Compost Information Sheet
Grade: Grade A Compost-Based upon the standards established for vector attraction reduction, pathogen reduction and regulated
metal content by the North Carolina Division of Waste Management
Recommended Use: Commercial and Agricultural at rates determined by NCDA Soil Test
Recommended Application Rate: 5 to IO tons per acre to satisfy crop Nitrogen and Phosphorus requirements of crop. Specific
application rates should be based upon recipient's soil test data for nitrogen and phosphorus.
Restrictions on Use: Restricted Use -As disclosed in the Agreement, the Compost is derived from tobacco by-product. Any tobacco
by-product may contain plant viruses and weed seed, related to tobacco agricultural production. To protect water quality do not
apply compost into waterways or regulated buffers adjacent to waterways
Nutrient Levels Range: The results presented below represent the range of values generated from evaluation of samples collected
from the finished compost storage area. Testing show plant available nutrient level ranges. To calculate compost required, soil test
results and these values can be used to optimize loading as demonstrated in the calculations below.
Test results Pounds per ton
Nitrogen 1.5% to 3% (assume 50% PAN or 0.5% ofN is plant 20 to 40
available)
Phosphorus 0.2%to0.4% 5 to 10
Potassium 2%to4% 40 to 80
Crop need based on NCDA Soil test: 150 lb N, 60 lb P and 120 lb K required by crop. Compost need is:
N 150 lb-N/ac/20 lb-N/ton = 7.5 tons/ac
P 60 lb P/ac/7.5 lb Piton= 8 tons/ac
K 120 lb -K/ac/40 lb -K/ton = 3 tons/ac*
* application of potassium (K) in excess of agronomic need is not associated with contravention of environmental quality. N and Pare
the critical nutrients where environmental sensitivity is present.
No Representations and Warranties.NOTWITHSTANDING ANY PROVISION TO THE CONTRARY CONTAINED HEREIN
OR IN ANY REPORT OR OTHER STATEMENT OR INSTRUMENT, SELLER MAKES NO WARRANTY OR GUARANTEE,
EXPRESS OR IMPLIED, WITH RESPECT TO 1HE COMPOST, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTY OF
MERCHANTABILITY OR FITNESS FOR AP ARTICULAR PURPOSE.
Disclaimer: This compost product has been sampled and tested as required by North Carolina Division of Waste Management Rules.
Test results are available upon request by calling Carolina Recycled AG Materials LLC at 252-462-4456. Seller makes no warranties
or performance claims regarding this product or its contents, quality, or suitability for any particular application.
Revised 1/17/2017
A.R. Rubin, Professor Emeritus, NCSU-BAE and
President A. R. Rubin and Associates
205 Stanton Gable Lane
Hillsborough, NC, 27278

Sustainable Environmental Solutions

Memo from: A. R. Rubin

Subject: Odor Control at CRAM Compost Facility

To: Donna Wilson, NCDEQ DWM 17 January 2022

Odor Control Plans are now required at compost operations in North Carolina. These
requirements are imposed on both new and existing operations permitted through 15 A NCAC
13B .0800 rules. With few exceptions, odor is not a regulated air quality issue at compost
operations but is a frequent cause of complaints expressed by the general public whenever
waste management permits are proposed.

The Carolina Recycled Ag Materials compost operation is unique for several reasons including:

1. The compost operation is set in the middle of a very large agricultural field associated
with the Universal Leaf processing facility
2. The compost operations take place in open-top, aerated bins located within a covered
building
3. The compost operation involves automated aeration supplied to each of the production
bins and aeration is tailored to meet the temperature controls and aeration
requirements within each unique bin
4. There are no residential facilities located within 0.5 miles of the compost operation

Should odor emanate from the compost operation it is most likely associated with either the
initial storage of the incoming feedstock or storage of the composted material in the open
curing areas specified on the operations permit. Odor control activities will vary depending on
the source of the odor as described below.

Incoming Feedstock: Should odor originate from the incoming feedstock the operator of the
facility can simply cover the material with a tarp or mix and blend the feedstock generating the
odor with bulking material and introduce it to an open bin for subsequent composting. Both the
agricultural fields and the forested area on the Universal Leaf property have been permitted to
accommodate class B compost and dry tobacco processing by-product. The application of the
dry agribusiness product in accordance with the land application permit would be an additional
option to reduce odor associated with the incoming feedstock.

Product Curing: Should odor emanate from product that has been composted to meet the PFRP
and VAR requirements contained in the Rule, the product could be remixed and returned to a
compost bin for further processing through the compost process. If no bin is open, the material
could be covered with a tarp or applied to one of the agricultural or silvicultural fields at
Universal Leaf. These fields have been permitted to receive compost and as an odor control
activity, compost can be applied using a spreader that applies a low rate of compost. As the
compost is applied, it is aerated, and the odor potential is reduced and controlled.

Special Testing: The permitted land application activity mentioned as options in each of the
scenarios would require compliance with the land application permit issued to Universal Leaf,
North America. This permit required testing of the product to determine the nutrient levels (N,
P, and K) the calcium carbonate equivalency (CCE) and calculation of the appropriate
application rate for product based on the nutrient levels and the CCE value. The CCE is a
measure of the liming potential of material and soil pH is an important factor in optimizing crop
production in North Carolina. The nutrient management plan developed to support the odor
control effort would utilize a most limiting criteria to determine the appropriate loading rate for
the odiferous material. Should the land application operation be used, the North Carolina
Department of Agriculture, Agronomic Services Laboratory will test material to determine the
nutrient and CCE levels. This laboratory can provide reliable test results within 3 days.

Respectfully Submitted

A. R. Rubin