WQ0021632_Regional Office Historical File Pre 2016

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
July 27, 2015
Mr. Harold T. Owen, City Manger
City of Burlington
P.O. Box 1358
Burlington,NC 27216
SUBJECT: Compliance Evaluation Inspection
City of Burlington, Compogro Compost Facility - Residuals Distribution Program
Permit No. WQ0021632
Alamance County
Dear Mr. Owen:
On July 24, 2015 staff of the North Carolina Division of Water Resources Winston-Salem Regional
Office (DWR) performed a compliance evaluation inspection of the subject facility. This inspection
was conducted by DWR staff person Patrick Mitchell. All required records and documents were
available at the time of inspection and were in good order. This inspection also consisted of a
separate DWR review of the 2014 Annual Report. The inspection reflects compliance with Permit
No. WQ0021632.
Please refer to the enclosed compliance inspection report form for additional observations and
comments. If you or your staff have any questions, please contact Patrick Mitchell or myself at
336-776-9800.
Sincerely,
Sherri V. Knight, P.E. —Assistant Regional Supervisor
Water Quality Regional Operations
Division of Water Resources, NC DENR
enc.: Compliance Inspection Report
cc: Mr. Shane Fletcher,Residuals Coordinator—City of Burlington, 2471 Boy Wood Rd., Graham,NC 27253
Alamance County Environmental Health
DWR Central Office—Water Quality Permit File WQ0003035, .11111litirossmit
Winston-Salem Regional Office
450 West Hanes Mill Road,Suite 300, Winston-Salem,North Carolina 27105
Phone:[phone] FAX:[phone]\Customer Service 1-877-623-6748
Internet:www.ncdenr.gov
An Equal Opportunity Affirmative Action Employer—Made in part by recycled paper

Permit: W00021632 Owner-Facility:City of Burlington
Inspection Date: 07/24/2015 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On July 24, 2015 a site visit was conducted for the subject facility. The primary purpose for this site visit was for a review
associated with an application for permit modification to add Mackintosh WTP as a residuals source.A compliance
inspection was conducted during the site visit.Accompanying DWR on the inspection was Mr. Shane Fletcher with the City
of Burlington.
This inspection consisted of a review of the Mackintosh WTP facility and a separate DWR in-office review of the 2014
Annual Report(see field inspection form and annual report review forms for more details). The inspection reflects
compliance with the permit.
Page: 2

Compliance Inspection Report
Permit: WO0021632 Effective: 01/14/09 Expiration: 12/31/17 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting Facility an•
County:Alamance 2471 Boy Wood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Stephen Russell Shoaf Title: Phone: [phone]
Directions to Facility:
Take NC Hw.87 South off of 1-85(Exit 147). Proceed on NC Hwy.87 South,and bear left onto Swepsonville Road.At Boywood
Road,bear right.The entrance to the W VTP is 0.25 miles on the right
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 07/24/2015 Entry Time: 01:30PM Exit Time: 03:OOPM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: 1111 Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions In Record Keeping Treatment
II Pathogen and Vector Attraction
(See attachment summary)
Page: 1

North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Section
NON-DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS A RESIDUALS DISTRIBUTION
General Information 1 ,
V
0ti-I., G'�,� �� `'Facility Name: 13 fr , County: AI r.-w
Permit No.: WQ00 21 4 737'7- Permit Issuance Date: l/11(b
Owner: C ,1 0(- RP!"I l ,,, Permit Expiration Date: I z/3 /i 17
Plant ORC Name: 51. ^.- k-L4 L. i Telephone No.: �7C -- 6 7 C- 5-72-7
Other Contact(s): /Vla�k;- J 011 oIZC- 1 Telephone No.:
Facility Location(address, gps or directions): 1 tf d E/ R I1.,7 ?7 S. / L_ Sapi vvIL. (4.1 - J e j i.,o,),1 get
Reason for Inspection ^ �Q�M1
TifROUTINE ❑ FOLLOW-UP ❑ COMPLAINT PERMITTING ❑ Other: r Y Sam
Comments (attach additional pages as necessary)
AJA pk i'�;,,ke^ LA IT �e Qtir 4- .01'1 /- �rei�' ,
* v,,; I ,Ma,1 l-afk
*p.,,,..A zw-/ p_4P " a.l�
Is a follow-up inspection necessary? ❑ Yes No
r
Primary Inspector: 1M a4 1 Secondary Inspector:
Date of Inspection: 7/29/e I I' Entry Time: :30 M Exit Time: 3:"FM

Non-Discharge Compliance Inspection Report
Record Keeping and Reporting Information: N NA NE
Is current permit and prior annual reports available upon request? 1il ❑ ❑ ❑
Has the facility been free of public complaints for the last 12 months? ❑ ❑ ❑
TCLP analysis conducted and results available? Frequency? \Iyr (See permit for frequency) ,n ❑ ❑ ❑
Residuals metals and nutrient analysis conducted?Frequency? 4 (See permit for frequency) 'M ❑ ❑ ❑
Nutrient and metals loading calculations?(to determine most limiting parameter) l ❑ Cl ❑
Do lab sheets support data reported on Residuals Analysis Summary? M ❑ ❑ ❑
Are distribution and/or hauling records available? Cl ❑ ❑
Are Utilization Agreements with recipients established and available for review? 15 ❑ ❑ ❑
Do Utilization Agreements contain the minimum requirements contained in the permit? ! ❑ ❑ ❑
(Restrictions for land application,stockpiling,setback buffers,etc.)
If the Permittee applies bulk residuals,are field loading records available? ❑ ❑ 2 ❑
If the Permittee applies bulk residuals,are field inspections conducted and are records available? ❑ ❑ ❑
Does residuals package label or Utilization agreement contain minimum info required by permit?X. ❑ ❑ ❑
(Name&address of generator,statement of restrictions,nutrient contents)
Is an inspection log available containing record of residuals facility inspections,maintenance, ❑ ❑ YI ❑
and repairs?
Pathogen and Vector Attraction Reduction Records
Patho en Reduction: Requires both pathogen density demonstration and Class A treatment alternative.
Fecal Coliform density or ❑ Salmonella density to demonstrate pathogen requirements. Y N NA NE
s sampling conducted at the permit required frequency?(See permit for frequency) 1 ❑ ❑ ❑
Were multiple samples taken? / CI CI CI
Fecal Coliform,density<1,000 MPN/gram of total solids? K ❑ ❑ ❑
If Salmonella,density<3 MPN/4 grams of total solids? ❑ ❑ X CIelect which treatment Alternative below was used to demonstrate Class A compliance.
❑A tive 1 - Time/Temperature (See White House Manual for specific r rements) Y N NA NE
Wer 'duals maintained for correct time and temperature? ❑ ❑ Cl ❑
Are logs pres howing time and temperature? ❑ ❑ ❑ ❑
Are temperatures wi ' e for complete time ' ? ❑ ❑ ❑ Cl
❑Alternative 2- Alkaline Treatment
Are logs present showing time a empera . ❑ Cl ❑ ❑
Was the pH raised to 12 eater and maintained for 7 or longer? ❑ ❑ Cl ❑
Was the temper 2°C(126°F)for 12 hours or longer while the p s 12 or greater? ❑ ❑ ❑ ❑
Are to sent showing time and pH? ❑ ❑ ❑ ❑
e temperature corrected to 25°C(77°F)by calculation,NOT autocorrect? ❑ ❑ ❑
Alternative 5 - Process to Further Reduce Pathogens(PFRP) [Select the PFRP method below that was utilized]]
Composting, Select which method was used::
❑ Within-Ve 1 Meth or Static Aerated Pile Method
Were res s temperatures maintained at>55°C(131°F)for Y NR NE
>3 conte ti days in the within-vessel or static aerated piles? ❑ ❑ ❑
y indrow C mposting ethod
Were the residuals temperatures maintained at>55°C for at least
15 consecutive days in the windrow,and the windrow was turned a ❑ ❑ ❑
minimum of five times during this time? / \
❑ e mg
Wer esiduals dried by di r indirect contact with hot gases and the ❑ ❑ ❑ ❑
moisture conte es' s reduced to<10%?
Did the temper e of the ' als or the wet bulb temperature of the gas ❑ ❑ ❑ ❑
in cont ith the residuals re ' leave the dryer exceed 80°C(176°F)?
El Other Alternative, Sp (See White House Manual)
Page 2 of 4

Non-Discharge Compliance Inspection Report
,ector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
❑Option 1 -38%Volatile Solids Reduction Y N NA NE
Are lab results and calculations prese c ? ❑ ❑ ❑ ❑
Was the reduction on volatile solids not total solids)? ❑ ❑ ❑ ❑
Were samples collected at correct .cations? ❑ ❑ ❑ ❑
(beginning of digestion process : before land application)
Was there a>38%reduction? ❑ ❑ ❑ ❑
❑ Optio, 2 -40-Day Bench Scale Te• Y N NA NE
ere residuals from anaero. c digestion? ❑ ❑ ❑ ❑
• e lab results and calculat'•ns present? ❑ ❑ ❑ ❑
s the test anaerobically •igested in lab,and test run for 40 days? ❑ ❑ ❑ ❑
W.s the test done betwee, 30°C(86°F)and 37°C(99°F)? ❑ ❑ ❑ ❑
Wa the reduction of on 'olatile solids(not total solids)? ❑ ❑ ❑ ❑
Was the reduction less t an 17%? ❑ ❑ ❑ ❑
❑ Option 3 - '0-Day Bench S•ale Test Y N NA NE
Were -siduals fro .erobic digestion? ❑ ❑ ❑ ❑
Are lab esults an. alculations present? ❑ ❑ ❑ ❑
Were re-"duals 2°, or less total solids? ❑ ❑ ❑ ❑
If not 2% otal s%lids,was the test ran on a sample diluted to 2%
with unchl grin. ed effluent? ❑ ❑ ❑ ❑
Was the tes . for 30 days? ❑ ❑ ❑ ❑
Was the test ,one at 20°C(68°F)? ❑ ❑ ❑ ❑
Was the re..c.'on of on volatile solids(not total solids)? ❑ ❑ ❑ ❑
Was the re cuctiin less than 15%? ❑ ❑ ❑ ❑
❑ Option 4-Specific Ox gen Uptake Rate(SOUR Test) Y N NA NE
Were res duals fo • aerobic digestion? ❑ ❑ ❑ ❑
Were re.iduals<2% otal solids(dry weight basis)(not diluted)? ❑ ❑ ❑ ❑
Was t test done bet een 10°C(50°F)and 30°C(86°F)? ❑ ❑ ❑ ❑
Was e temperature c. ected to 20°C(68°F)? ❑ ❑ ❑ ❑
Was he sampling hold' . time<2 hours? ❑ ❑ ❑ ❑
Wa• the test started within 15 minutes of sampling or aeration maintained? ❑ ❑ ❑ ❑
W.. the SOUR equal to or . s than 1.5 mg of oxygen per hour per gram of
tot;l residual solids(dry weig basis)?)( ❑ CI CI CIOption 5 - 14-Day Aerobic Process Y N NA NE
Were the residuals from aerobic digestion? :/ ❑ ❑ ❑
Was the average residuals temperature higher than 45°C(113°F)? 0 ❑ ❑ ❑
Were the residuals treated for 14 days and temperature maintained higher
than 40°C(104°F)for the 4-day period? ❑ ❑ ❑
❑ Opti.n 6-Alkaline Stabiliz. on Y N NA NE
as the pH of the residuals raised to>12 and maintained for two hours
wit •ut addition of ore alkali? ❑ ❑ ❑ ❑
Did t' - pH of resi. als remain at>11.5 an additional twenty-two hours
without e additi an of more alkali? ❑ ❑ ❑ ❑
Was the p , con cted to 25°C(77°F) (by calculation,NOT auto correct)? ❑ ❑ ❑ ❑
❑ Option 7 -Drying 'Stabilized Residuals Y N NA NE
The residual. .• not contain unstabilized residuals? ❑ ❑ ❑ ❑
Were the r-.idu. mixed with any other materials?If so, what? ❑ ❑ ❑ ❑
Were the -siduals • ied>75%total solids? ❑ ❑ ❑ ❑
❑Option 8 - II, ing of Unsta.' ized Residuals Y N NA NE
Wer- he residuals mixes with any other materials? ❑ ❑ ❑ ❑
We the residuals dried> 1%total solids? ❑ ❑ ❑ ❑
❑Optio •/10—Injection/Incorporat .n of Residuals(Not commonly used-See White House Manual)
Page 3 of 4
76!,-*- P

Non-Discharge Compliance Inspection Report
Residuals Storage:
Describe storage:
Number of days/weeks/months of storage:
x.iResiduals Sampling: Y N NA NE
Is sampling adequate and representative? LI ° CI CI CI
Describe Sampling: I' ,i,,It ���
Transport Vehicle: Y N NE
Is transport occurring at time of inspection? ❑ ❑ ❑
Are necessary records(i.e.permit&spill plan)present in vehicle?ID of observed vehicle(s): ❑ ❑ ❑
Application Site(s)
Were application site(s)inspected? If so,please complete info below. ❑ Yes No
Is ication occurring at the time of inspection? If no,note the date of the last event: es ❑No
Weather Co ' ' s:
❑ Sunny loudy ❑ Cloudy ❑ Overcast tormy
❑ Windy (wind direction: ) eze alm
❑No Precipitation ❑ Drizzle • burst (If applicable,precipitation measurement: )
Weather Notes(i.e. Significant Ch..._-s, Forecasts,etc):
Temp. (°F): ❑ <32 d 32—40 ❑40—60 ❑ 60—80 ❑>80
Permit an. _.1 Plan onsite during application? ❑ Yes ❑No /
• d-g:cation Observations: [Type of application: ❑ Liquid ElCake(>15%total solids) ❑ Other
Site 0 ; (s): Site Owner(s):
Intended Cro.• PAN Requirement: lbs/ac Intended Crop: PAN : •uirement: lbs/ac
Application Rate :allons/acre): Application Rate(gallons/acre):
Nutrient Content: Nutrient Content:
Application occurring at ti ,of visit: ❑Yes❑No Application occurring at ti v of visit: 0 Yes❑No
Application Method:0 Surface \ Incorp/Injection Application Method: .% Surface❑Incorp/Injection
Incorporation/Injection during visit: \` Yes 0 No❑N/A Incorporation/I : ction during visit:❑Yes❑No❑N/A
Vegetative Buffer description: alone IN rass ['Crop ❑Shrub❑ Vegetative :uffer description: ❑None ['Grass DCrop ❑Shrub❑
Tree ❑Other Tree P • er
Current Field Conditions: C -nt Field Conditions:
❑Bare 0 Stubble ❑Planted (crop) \ Pasture a Bare 0 Stubble ❑Planted(crop) ❑Pasture
Soil Condition: Soil Condition:
❑Dry ❑Moist ❑Wet ❑Saturated ❑Dry 0 Moist 0 Wet 0 Saturated
❑Not-Frozen ❑Frost ❑Frozen 0 Snow-Covered 0 Not-Frozen 0 Frost ❑Frozen ❑Snow-Covered
Slope:❑0-3% ❑3-6% ❑6-10% 0 10-18% ❑>18% Slope: 0 0-3% 0 3-6% ❑6-10% 0 10-18% ❑>18%
Odor: ❑None 0 Mild 0 Moderate ❑Strong ,dor: 0 None ❑Mild ❑Moderate 0 Strong
Vectors: ❑None ❑Few ❑Many 0 Exce e Vecto • ❑None ❑Few 0 Many ❑Excessive
Application Details: Y N NA NE Applicatio I etails: V N NA NE
Application areas clearly marked? ❑ 0 ❑ ❑ Application are•: learly marked? 0 ❑ ❑ ❑
Application within authorized area? 0 0 ❑ ❑ Application within .. orized area? 0 ❑ 0 0
Application method appropriate? ❑ ❑ ❑ ❑ Application method app •.riate? ❑ ❑ ❑ ❑
Application is even(no ponding)? 0 0 ❑ ❑ Application is even(no pon. g)? ❑ ❑ ❑ ❑
Sufficient setbacks from wells? ❑ ❑ 0 0 Sufficient setbacks from wells. DODO
Sufficient setbacks from s -'ace waters? ❑ ❑ 0 0 Sufficient setbacks from surface w..-rs? ❑ ❑ ❑ ❑
Slopes>10%avoided irface App.)? ❑ ❑ 0 0 Slopes>10%avoided(Surface App.) . ❑ ❑ ❑ ❑
Slopes>18%avoid-. (Incorp/Inject)? ❑ ❑ ❑ ❑ Slopes>18%avoided(Incorp/Inject)? ❑ ❑ ❑ ❑
Incorp./Injectio .ithin time-frame? 0 0 ❑ ❑ Incorp./Injection within time-frame? ❑ ❑ ❑ ❑
No evidence shallow GW? ❑ ❑ ❑ ❑ No evidence of shallow GW? DODO
Trackin . prevented? ❑ ❑ ❑ ❑ Tracking is prevented? ❑ ❑ ❑ ❑
Biosolids run-off is prevented? ❑ ❑ ❑ ❑ Biosolids run-off is prevented? ❑ ❑ ❑ ❑
Page 4 of 4

Annual Report Review Class A Distribution 7 p; e l3 }"yf �i 3
Reporting Period: ZQ� ? �j '" A f7�o ? 0 ' 2115
Permit Details: rfl,tc 54-A ?,a t
Is 503? Yel �����A.4,eA�'
ClassAorB? A
• Maximum Dry Tons Per Year: 2--� ¢or pr.1+.04-
• Number of acres permitted:-N
• Number of fields in permit:-►J\
• Counties that land is permitted for:4
Monitoring Frequency for TCLP: AnmhAity
• Monitoring Frequency for Residuals Analysis: &u'(k'ly
Monitoring Frequency for Pathogen&Vector Attraction Reduction: Q./4#(1h
1. Class A Annual Distribution and Mark9ting/Surface Disposal Certification Form
• Was a certification form submitted? 105
• Was distribution conducted during the reported period? Vie-,
• How many dry tons were produced and distributed? /(,5 49 pia — 140,
• Were the distributions with the permitted amount? Yes
• Were recipients information listed? e5
Did it indicate compliance? `(es
• Was form complete? e),
Was it signed by the appropriate people? `)ec
2. Monitoring
Were the analyses conducted at the required frequency? 1 of
Was an analyses taken for each source that was distributed? Yes• Were the metals analyses reported on th9 Residual Sampling Summary Form? `kr
Were the results reported in mg/kg? of
• Were the pH's 6.0 or greater for each residual sample?1*
• Were the heavy metals within ceiling con9entration permit limits? ��•
Were the lab analyses attached? "ref
• Were all the required parameters tested? cec
Was TCLP analysis conducted? ( 5
• Were the TLCP contaminants within regulatory limits? e5
Was a corrosivity, ignitability,and reactivity analysis conducted? "(es
3. Pathogen and Vector Attraction Reduction
Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? VCJ
Did the form indicate the period of coverage,the residual clas,and the pathogen reduction
alternative and the vector attraction reduction option used? yei
Was the appropriate documentation to show pathogen and vector attraction reduction included
in the report? ,e)
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503? ye'.
Class A Pathogen Review
To be Class A,residuals shall meet either fecal Coliform density or salmonella density.

Fecal Coliform density `l
• Was the sampling conducted at the required frequency? 't e)
• Were multiple samples taken? Ye)
• Was each sample less than 1000 MPN/gram of total solids? Yes
OR
Salmone nsity
• Was the samp 1 nducted at th • e requency?
• Were multiple '
• W sample less than 3 MP s of total solids?
To be Class A,residuals shall meet one of the following alternatives:
A ternative 1 —Time/Temper. '.re
• - - the residuals maint.• ed for correct time and temperature?
• Were .is submitted s..wing time and temperature?
• Were tem:-ratures - thin range for complete time period?
Alternative 2— • • .line Treatment
• Were logs s .mitte. sowing time and temperature?
• Was the p. raised to 12 o !seater and maintained for 72 hours or longer?
• Was th- emperature 52°C (1 .° ) for 12 hours or longer while the pH was 12 or
greate .
• W- e logs submitted showing time and . .?
• I as the temperature corrected to 25°C (77' ?
46 Alternative 5 —Process To Further Reduce Pathogens
-�PFRP Compostin
e • in-vessel method or static aerated pile methods used?
• Was e resi erature maintained at 55°C (131°F)or higher for three
c ecutive days or longer in within-vessel method or static aerated pile method?
`OR
• Was the windrow composting method used? Vef
• Was the residuals temperature maintained at 55°C or higher for 15 consecutive days or
longer in the w' drow method, and the windrow turned a minimum of five times during
this time? 4Cf
RP Heat ing
• esiduals dried by direct or indirect contact with hot gases and the moisture
conte o • uals reduced to 10%or lower?
• D• the tempera e of the residuals or the of the wet bulb temperature of the gas in
ntact with the residua the residuals leave the dryer exceed 80°C(176°F)?
Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency? ef'
• 1 —38%Volatile Soli uction
• Was the %re 'on?
• Were lab s ca •ons in report?
• Was reduction on volatile so • of total solids)?

• ere the samples take eginning of digestion process and before application
(Inspe •
Were ca io ect?
O o ion 2—40-Day Bench Scale Test
• -re residuals from anaerobically ..gested treatment(Inspection)?
• W.re residuals anaerobically diges -d in lab?
• Wa. the test run for 40 days?
• Wa• the test done between 30°C 86°F)and 37°C (99°F)?
• Was he reduction of on volatil: solids(not total solids)?
• Was i e reduction less than 17"/o?
Were b sheets/calculations • report?
• Were c,lculations correct?
Option 3 — 0-Day Bench :cale Test
• Were resio als from aerobically digested treatment(Inspection)?
• Were resid ..is aerobi illy digested in lab?
• Were residu., s 2%or ess total solids?
• If not 2%tota solid..,was the test ran on a sample diluted to 2%with unchlorinated
effluent?
• Was the test ru far 30 days?
• Was the test don at 20°C (68°F)?
• Was the reduct.on o f on volatile solids(not total solids)?
• Was the reduc ion ;ss than 15%?
• Were lab she ts/calc ations in report?
• Were calcu :tions correct?
Option 4— .pecific Oxygen ptake Rate(SOUR)
• Were re- duals form aerobic:lly digested treatment(Inspection)?
Were r siduals 2%or less tota solids(dry weight basis)(not diluted)?
Was t e test done between 10° (50°F)and 30°C (86°F)?
• Was he temperature corrected to •0°C (68°F)?
• W.. the SOUR equal to or less tha 1.5 mg of oxygen per hour per gram of total
res.,ual solids(dry weight basis)?
• as the sampling holding time two ho s?
• as the test started within 15 minutes o sampling or aeration maintained?
Option 5 — 14-Day Aerobic Process �l
• Were the residuals from aerobically diges ed treatment(Inspection)? Yes
Were the residuals treated for 14 days? yes
• Was the residuals temperature higher than 40°C(104°F)for a 14-day period? Ter
• Was the average residuals temperature higher than 45°C (113°F)? 41er
tion 6—Alkaline Stabiliz • n
• the pH of the res. als raised to 12 or higher by the addition of alkali?
• Did t H of res• als remain at 12 or higher for two hours without the addition of
more alkali.
• Did the p o siduals remain at 11.5 or higher for an additional twenty-two hours
withou e additio f more alkali?
• W the pH correcte 25°C (77°F)?

Op 'on 7—Drying of Stabilized Resid . s
• Do,s the residuals contain any uns . ailized residuals?
• Wer= the residuals mixed with al other materials?
• Were i e residuals dried up to 5%total solids?
Option 8— ► ing of Unst. .ilized Residuals
• Were the res'a uals mix:. with any other materials?
• Were the resi a .als dr'-d to 90%total solids?
Option 9—Inj ecti
• Was there any igni i•.nt amount of residuals on land surface one hour after injection
(Inspection)?
Was inje. ion done on pas re or hay field?
Was i.'ection done at time the crop was growing?
• If C .ss A with respect to patho:-n,were residuals injected with eight hours after
dis, arge from pathogen treatment.
4.General
Was the report in the proper format? e1
Was the annual report complete? ye f
Was the report submitted on time? yes

State of North Carolina
D ` Department of Environment and Natural Resources
Division of Water Resources
Division of Water Resources
Water Quality Programs
Regional Staff Report
July 27,2015
To: Central Office—Water Quality Permitting Section Application No.: W00021632
Attn: Troy Doby,Non-Discharge Permitting Unit Permittee: City of Burlington
From: Patrick Mitchell Winston-Salem Regional Office Alamance County
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or❑No
a. Date of site visit: July 24,2015
b. Site visit conducted by: P. Mitchell
c. Inspection report attached? ❑ Yes or®No
d. Person contacted: Shane Fletcher and their contact information: (336) 675 - 5927 ext.
e. Driving directions: See file.
II. FACILITY AND APPLICATION INFORMATION
1. Are there appropriately certified Operators in Charge(ORCs) for the facility? ® Yes ❑No ❑N/A
ORC: Thomas Murr Certificate#:LA-27409 Backup ORC: Joe Rierson Certificate #:LA-28612
2. Are the design,maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes ❑No ❑N/A-If no, please explain below in Section IV. Review Items
3. Are the site conditions (e.g., soils,topography, depth to water table, etc)maintained appropriately and adequately
assimilating the waste? ® Yes or❑No - If no, please explain below in Section IV. Review Items
4. Has the site changed in any way that may affect the permit(e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or®No -If yes, please explain below in Section IV. Review Items
5. Is the residuals management plan adequate? ® Yes or ❑ No- If no, please explain below in Section IV. Review
Items
6. Are the existing application rates(e.g., hydraulic,nutrient)still acceptable? ® Yes or❑No - If no,please
explain below in Section IV. Review Items
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑No ®N/A
If no, explain and recommend any changes to the groundwater monitoring program below in Section IV. Review
Items
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or®No
If yes, provide comments below attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or❑No - If no, please
explain below in Section IV. Review Items
10. Were monitoring wells properly constructed and located? ❑ Yes ❑No ®N/A If no, please explain below in
Section IV. Review Items.
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑No ® N/A
12. Has a review of all self-monitoring data been conducted(e.g.,NDMR,NDAR, GW)? ® Yes ❑No ❑N/A
Please summarize any findings resulting from this review below in Section IV. Review Items.
FORM: APSRSR 04-10 _ '1 : �' a Page 1 of 2

13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or®No
If yes,please explain below in Section IV. Review Items.
14. Check all that apply:
®No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑Notice(s)of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments(i.e.,NOV,NOD, etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑No ❑N/A
If no, please explain below in Section IV. Review Items.
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No ❑N/A
If yes,please explain below in Section IV. Review Items.
III.REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or®No
If yes,please explain:
2. List any items that you would like APS Central Office to obtain through an additional information request:
•
3. List specific permit conditions recommended to be removed from the permit when issued:
•
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
•
5. Recommendation: ❑ Hold,pending receipt and review of additional information by regional office
❑ Hold,pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
® Issue
❑ Deny(Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor: �: �'
Date: July 27,2015 Fir//'�,ly B�s�•,;r,^
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
•
FORM: APSRSR 04-10 Page 2 of 2

State of North Carolina
PWRDepartment of Environment and Natural Resources
Division of Water Resources
WATER QUALITY REGIONAL OPERATIONS SECTION
Division of Water Resources NON-DISCHARGE APPLICATION REVIEW REQUEST FORM
July 8, 2015 RECEIVED
N.C. Dept of//ENr
. �at r14 JUL 2
015
From: Troy Doby, Water Quality Permitting Section-Non-Discharge Permitting Unit REGIONOANLOFF CE
Permit Number: WQ0021632 Permit Type: Distribution of Residual Solids(503)
Applicant: City of Burlington Project Type: Major Modification
Owner Type: Municipal Owner in BIMS? Yes
Facility Name: CompoGro Composting Facility and Distribution Program Facility in BIMS?Yes
Fee Category: Non-Discharge Minor Fee Amount: $245 -Major Modification
Comments/Other Information:
Attached, you will find all information submitted in support of the above-referenced application for your review,
comment, and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed. ® Return a completed staff report.
❑ Attach an Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer: 14 c 1 ( Date:
/12/ / .14 + ( l
FORM: WQROSNDARR 01-15 Page 1 of 1

AIWA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
July 8, 2015
SHANE FLETCHER—RESIDUALS MANAGEMENT COORDINATOR
CITY OF BURLINGTON
POST OFFICE BOX 1258
BURLINGTON,NORTH CAROLINA 27215
Subject: Acknowledgement of
Application No. WQ0021632
City of Burlington DRS
Residuals Management System
Alamance County
Dear Mr. Fletcher:
•
The Water Quality Permitting Section acknowledges receipt of your permit application and
supporting documentation received on July 8. 2015. Your application package has been assigned the
number listed above, and the primary reviewer is Troy Doby.
Central and 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 Division of Water Resources 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
Troy Doby at(919) 807-6336 or [e-mail].
Sincerely.
Nathaniel D. Thornburg, Superviot-
Division of Water Resources
cc: gb d �yX E t
Permit File WQ0021632
Non-Discharge Permitting Unit
1617 Mail Service Center,Raleigh,North Carolina 27699-1617
Phone:[phone] Internet:httcalportal.ncdenr.orglweblwa
-n Envy, En:e;c:=r--'Gade in part pith rea'cld pa;,er

Compliance Inspection Report
Permit: WQ0021632 Effective: 09/01/15 Expiration: 12/31/17 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington Class A Residuals Management Pi
County:Alamance 2471 Boywood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Frank H Watkins Title: Town Manager Phone: [phone]
Directions to Facility:
Take NC Hw.87 South off of 1-85(Exit 147).Proceed on NC Hwy.87 South,and bear left onto Swepsonville Road.At Boywood
Road,bear right.The entrance to the WWTP is 0.25 miles on the right
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
NC0023876 City of Burlington-Southside WWTP
NC0083828 City of Burlington-J.D.Mackintosh,Jr.WTP
Inspection Date: 04/18/2016 Entry Time: 01:OOPM Exit Time: 01:45PM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Reconnaissance
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
•
111 Miscellaneous Questions
(See attachment summary)
Page: 1

Permit: WQ0021632 Owner-Facility:City of Burlington
Inspection Date: 04/18/2016 Inspection Type:Reconnaissance Reason for Visit: Routine
Inspection Summary:
On April 18, 2016 WSRO conducted an unannounced reconnaissance inspection of the subject Class A residuals
distribution program. Only the composting facility and related activities was visited(WTP was not visited). The primary
purpose in the site visit was for a compliance evaluation inspection of the associated Class B land application program
(Permit no.WQ0000520). The reconnaissance inspection reflects compliance with the permit. Below are summary notes
from the inspection:
-Temp. logs were found to be present and reflect compliance.
-Aerated compost batches were reviewed.The observed temperature measures in the labeled batches were found to be
>131 degrees C.
-Permit, annual reports and other required records were present.
WSRO will conduct a full compliance evaluation inspection at a later date.
Page: 2

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
June 27, 2014
Mr. Harold T. Owen, City Manger
City of Burlington
P.O. Box 1358
Burlington, NC 27216
SUBJECT: 2013 Annual Report Review
City of Burlington, Compogro Compost Facility
Residuals Distribution Program
Permit No. WQ0021632
Alamance County
Dear Mr. Owen:
The Division of Water Resources (DWR) acknowledges receipt of your 2013 annual report
for the subject permit and additional information received on March 21 and June 17, 2014.
A review of this report was conducted by DWR staff and reflects compliance with Permit
No. WQ0021632.
If you or your staff have any questions, please contact Stephen Berry at 336-771-5288.
Sincerely,
Sherri V. Knight, PE
Assistant Supervisor
Water Quality Regional Operations
Division of Water Resources, NCDENR
Cc: Alamance County Health Department
Non-Discharge Permitting Unit — Permit File WQ0021632
01 O s.
585 Waughtown Street,Winston-Salem,North Carolina 27107
Phone:[phone] Internet:www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer—Made in part by recycled paper

AT7A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, Ill
Governor Director Secretary
September 13, 2013
Mr. Harold T. Owen, City Manger
City of Burlington
P.O. Box 1358
Burlington,NC 27216
SUBJECT: Compliance Evaluation Inspection
City of Burlington, Compogro Compost Facility
Residuals Distribution Program
Permit No. WQ0021632
Alamance County
Dear Mr. Owen:
On September 10, 2013 staff of the North Carolina Division of Water Resources Winston-Salem
Regional Office (DWR) performed a compliance evaluation inspection of the City of
Burlington's Composting Facility. This inspection was conducted by DWR staff person Patrick
Mitchell. All required records and documents were available at the time of inspection and were
in good order. The facility was found to be compliant with Permit No. WQ0021632. The
Division appreciates your diligence in ensuring compliance with the permit.
Please refer to the enclosed compliance inspection report form for additional observations and
comments. If you or your staff have any questions, please contact Patrick Mitchell or myself at
336-771-5000.
Sincerely,
121AAY1A-
Sherri V. Knight, P.E.
• Assistant Regional Supervisor
cc: Mr. Shane Fletcher,Residuals Coordinator—City of Burlington, 2471 Boy Wood Rd, Graham,NC 27253
Alamance County Environmental Health
APS Central Office-Permit File WQ0021632
11111111.111
WATER QUALITY SECTION
585 Waughtown Street,Winston-Salem,North Carolina 27107
Phone:[phone] FAX:[phone]\Customer Service 1-877-623-6748
Internet:www.ncwaterquality.orq
An Equal Opportunity\Affirmative Action Employer

North Carolina Department of Environment and Natural Resources
Division of Water Resources
NON-DISCHARGE COMPLIANCE INSPECTION REPORT
General Information
Owner: City of Burlington County: Alamance
Permit No.: WQ0021632 Issuance Date:January 14,2009
Facility Name:Composting&Distribution Program Expiration Date:December 31, 2017
Facility ORC: Shane Fletcher Telephone No.:O: [phone] C: 675-5927
Land App. ORC: Telephone No.:
Backup/Other Contact: Telephone No.:
Location(address,gps or directions):I-40 E,R Hwy 87 S,L Swepsonville Rd,R Boywood Rd,on Right.
Reason for Inspection
® ROUTINE ❑ COMPLAINT ❑ FOLLOW-UP ❑ Other:
Inspection Status
® Compliant ❑Not Compliant ❑ Other:
Ins•ection Summa : additional comments ma be included on attached I a!es
Inspection of the subject facility was conducted on September 10, 2013. Accompanying DWR on the
inspection was Mr. Shane Fletcher, Residuals Coordinator with the City of Burlington. All required records
and documents were available at the time of inspection and were in good order. The facility was found to be
compliant with Penuit No. WQ0021632.
Is a follow-up inspection necessary ❑ Yes ® No
Primary Inspector: Patrick Mitchell Secondary Inspector:
Telephone: (336)771 —5000 Fax: [phone]
Date of Inspection: September 10,2013 Entry Time: 11:00 am Exit Time: 12:30 pm

Non-Discharge Compliance Inspection Report
Type
❑ Land Application(Class B) ® Distribution and Marketing (Class A)
❑ Other
Transport Y N NA NE
Is transport occurring at time of inspection?If so, answer the following. ❑ ❑ ® ❑
Is a copy of permit in transport vehicle? ❑ ❑ ® ❑
Is a spill control plan in transport vehicle? ❑ ❑ Z ❑
Is spill plan satisfactory? ❑ ❑ ® ❑
Does transport vehicle appear to be maintained? ❑ ❑ ® ❑
Comments:NA
Land Application Site(s) (end use—land application) Y N NA NE
Were site(s) inspected?If so, answer the following. ❑
Is application occurring at the time of inspection? ❑ ❑ ® ❑
Is the permit and spill plan on site during application? ❑ ❑ ® ❑
Is there a rain gauge on site during application? ❑ ❑ ® ❑
Is access restricted and/or are signs present? ❑ ❑ ® ❑
Are buffers adequate &maintained? ❑ ❑ ® ❑
Is cover crop same as specified in permit? ❑ ❑ ® ❑
Are site conditions adequate? ❑ ❑ ® ❑
Are there signs of runoff/ponding? ❑ ❑ ® ❑
Are limiting slopes buffered? (>10%for surface app.AND>18%for subsurface app) ❑ ❑ Z ❑
Is application site free of ordors and/or vectors? ❑ ❑ ® ❑
Is land application equipment in good operating condition, If present? ❑ ❑ ® ❑
Are surrounding wells properly buffered? ❑ ❑ ® ❑
Comments:NA
Groundwater Monitoring Wells Y N NA NE
Does the permit require monitoring wells?If so, answer the following. ❑
Are the monitoring wells properly installed according to the permit? ❑ ❑ ® ❑
Are the monitoring wells located properly w/respect to RB & CB? ❑ ❑ ® ❑
Are the wells properly identified& free of damage? ❑ ❑ ® ❑
Comments:NA
Page 2 of 4

Non-Discharge Compliance Inspection Report
Treatment (check treatment type(s) used) Y N NA NE
❑ Aerobic digestion ❑ Anaerobic digestion
❑ Alkaline Pasteurization(Class A) ❑ Alkaline Stabilization(Class B)
❑ Compost ❑ Drying Beds ❑ Other:
Are treatment facilities consistent with those outlined in permit? ® ❑ ❑ ❑
Do all treatment units appear to be operational? If no, note below. ® ❑ ❑ ❑
Comments:
Residuals Storage
Describe storage: Primary: Concrete pad with covered roof.
Number of days/weeks/months of storage: -24 months(at current production rate).
Residuals Sampling Y N NA NE
Describe Sampling: Composite-Grab sample from"finish piles" storage.
Is sampling adequate and representative? ® ❑ ❑ ❑
Recordkeeping Y N NA NE
Is current permit available upon request? ® ❑ ❑ ❑
Has the facility been free of public complaints for the last 12 months? ® ❑ ❑ ❑
TCLP analysis conducted and results available? ® ❑ ❑ ❑
Residuals metals and nutrient analysis conducted? (see permit for frequency) ® ❑ ❑ ❑
Nutrient and metals loading calculations? (to determine most limiting parameter) ❑ ❑ ® ❑
Do lab sheets support data reported on Residuals Analysis Summary? ® ❑ ❑ ❑
Are PAN balance records available and within permit limits? ❑ ❑ ® ❑
Are there nutrient(crop) removal practices in place? ❑ ❑ ® ❑
Are hauling records available? (gal and/or tons hauled during calendar year to date) ® ❑ ❑ ❑
Are field loading records available? ❑ ❑ ® ❑
Are field inspections conducted and are records available? ❑ ❑ ® ❑
Pathogen & Vector Attraction Reduction Records: (Check which method(s) apply)
❑ Fecal coliform: ❑ SM 9221 E(Class A or B) ❑ SM 9222 D (Class B only)
❑ pH records for alkaline stabilization: [' Class A? ❑ Class B?
❑ Salmonella(Class A, all test must be <3MPN/4 gram day)
n Time/Temp records on: ❑ Digester (MCRT) ® Compost
n Volatile solids calculations
❑ Bench-top Aerobic/Anaerobic digestion results
Pathogen and vector attraction reduction records available and complete? ® ❑ ❑ ❑
Page 3 of 4

Non-Discharge Compliance Inspection Report
Recordkeeping continued Y N NA NE
Soil Analysis.
Were annual soil analysis conducted and results available? ❑ ❑ ® ❑
Was lime called for on the Agronomist report? ❑ ❑ ® ❑
If required,was lime applied(purchase receipts available)? ❑ ❑ ® ❑
Copper and Zinc indices: Li<2,000 ❑ 2,000—3,000 ❑>3,000
Was Sodium less than 0.5 meq/100 cm3 ? CIO ® ❑
Was Exchangeable Sodium Percentage (ESP) less than 15% ? ❑ ❑ ® ❑
Groundwater Monitoring:
Were GW-59's submitted? ❑ ❑ ® ❑
Has GW-59A certification been completed for facility? ❑ ❑ ® ❑
Are all samples analyzed for the required parameters? ❑ ❑ ® ❑
Are there any 2L GW quality violations? ❑ ❑ ® ❑
Comments:Records reviewedfor 2013 (Jan.-TCLP,April-Resd, Feb.-Aug.-Path/VAR)were up to date and complete.
Page 4 of 4

North Carolina Department of Environment and Natural Resources
Division of Water Resources
NON-DISCHARGE COMPLIANCE INSPECTION REPORT
General Information
Owner: City of Burlington County: Alamance
Permit No.: W00021632 Issuance Date: January 14,2009
Facility Name:Composting&Distribution Program Expiration Date:December 31,2017
Facility ORC: Shane Fletcher Telephone NcP:[phone] c: 334 -LIs's927
Land App. ORC: Telephone No.:
Backup/Other Contact: Telephone No.:
Location(address,gps or directions):I-40 E,R Hwy 87 S,L Swepsonville Rd,R Boywood Rd,on Right.
Reason for Inspection
® ROUTINE ❑ COMPLAINT ❑ FOLLOW-UP ❑ Other:
Inspection Status
❑ Compliant ❑Not Compliant ❑ Other:
la-)Ins I ection Summa additional comments ma be included on attached ,a,es + ^�,
FilIAA
T-e--(A)-(-4 ii.,_ <1
--> Mil\
ila
T ,v,,,e,, ,.,,,
, ,,,,..c., 0
.(,,, ,,_, tta ,,,,f, v-- ,
i 1 risly,K \ eix A, I);Per
914,
'0 °D or/ Qt.* 0 wivtlei i
\ �
:---bt, 1 Z f (j a
Is a follow-up inspection necessary ❑ Yes ❑ No \ m-
Primary Inspector: Patrick Mitchell Secondary Inspector:
Telephone: (336)771 —5000 Fax: [phone] �Z 3eO•ti
Date of Inspection: September 10, 2013 Entry Time: 11 QUO Exit Time: /

Non-Discharge Compliance Inspection Report
Type
❑ Land Application(Class B) ® Distribution and Marketing(Class A)
❑ Other
Transport Y N NA NE
Is transport occurring at time of inspection?If so, answer the following. ❑ ❑ ® El
Is a copy of permit in transport vehicle? ❑ ❑ ® ❑
Is a spill control plan in transport vehicle? ❑ El ® El
Is spill plan satisfactory? ❑ ❑ ® ❑
Does transport vehicle appear to be maintained? ❑ ❑ ® ❑
Comments:NA
Land Application Site(s) (end use—land application) Y N NA NE
Were site(s) inspected?If so, answer the following. ❑
Is application occurring at the time of inspection? ❑ El ® ❑
Is the permit and spill plan on site during application? El ❑ ® ❑
Is there a rain gauge on site during application? El El ® El
Is access restricted and/or are signs present? El El ® El
Are buffers adequate &maintained? ❑ ❑ ® ❑
Is cover crop same as specified in permit? El ❑ ® ❑
Are site conditions adequate? ❑ El ® El
Are there signs of runoff/ponding? ❑ ❑ ® El
Are limiting slopes buffered? (>10%for surface app. AND>18%for subsurface app) ❑ El ® ❑
Is application site free of ordors and/or vectors? El El ® ❑
Is land application equipment in good operating condition, If present? El El ® ❑
Are surrounding wells properly buffered? ❑ ❑ ® ❑
Comments:NA
Groundwater Monitoring Wells Y N NA NE
Does the permit require monitoring wells?If so, answer the following. El IZ
Are the monitoring wells properly installed according to the permit? ❑ ❑ ® El
Are the monitoring wells located properly w/respect to RB & CB? ❑ El ® El
Are the wells properly identified & free of damage? ❑ ❑ ® El
Comments:NA
Page 2 of 4

Non-Discharge Compliance Inspection Report
Treatment (check treatment type(s) used) Y N NA NE
❑ Aerobic digestion ❑ Anaerobic digestion
❑ Alkaline Pasteurization(Class A) ❑ Alkaline Stabilization (Class B)
® Compost [' Drying Beds ❑ Other:
Are treatment facilities consistent with those outlined in permit? ►:4 ❑ ❑ ❑
Do all treatment units appear to be operational? If no, note below. ' ❑ ❑ ❑
Comments:
Residuals Storage r rr` It'Describe storage: Primary: Concrete pad with covered roof. P rd
Number of days/weeks/months of storage: "' 2 it Man lhl
N4 A - S,�Residuals Sampling -7 1� Y N NA NE
Describe Sampling: Composite-Grab sample from storage.
Is sampling adequate and representative? X ❑ ❑ ❑
Recordkeeping Y N NA NE
Is current permit available upon request? .Mi ❑ ❑ ❑
Has the facility been free of public complaints for the last 12 months? ❑ ❑ ❑
kr,f7TCLP analysis conducted and results available?--- -1, ZfA°15 ,Ail ❑ ❑ ❑
lot3
Residuals metals and nutrient analysis conducted? (see permit for frequency) X ❑ ❑ ❑
Nutrient and metals loading calculations? (to determine most limiting parameter) ❑ ❑ X ❑
Do lab sheets support data reported on Residuals Analysis Summary? • ❑ ❑ ❑
Are PAN balance records available and within permit limits? ❑ ❑ ,. ❑
Are there nutrient (crop) removal practices in place? ❑ ❑ ❑
Are hauling records available?(gal and/or tons hauled during calendar year to date) X ❑ ❑ LI
Are field loading records available? ❑ ❑ E ❑
Are field inspections conducted and are records available? ❑ ❑ 2 ❑
Pathogen & Vector Attraction Reduction Records: (Check which method(s) apply)
❑ Fecal coliform: n SM 9221 E (Class A or B) n SM 9222 D (Class B only)
n pH records for alkaline stabilization: ❑ Class A? ❑ Class B? „(,i
GarbI 0 t3
n Salmonella(Class A, all test must be <3MPN/4 gram day) f,t
7 rb
/13
❑ Time/Temp records on: n Digester (MCRT) /= Compost
n Volatile solids calculations
❑ Bench-top Aerobic/Anaerobic digestion results
Pathogen and vector attraction reduction records available and complete? ❑ ❑ ❑
Page 3 of 4

141 Non-Discharge Compliance Inspection Report
Recordkeeping continued Y N NA NE
Soil Analysis:
Were annual soil analysis conducted and results available? ❑ ❑ i1 ❑
Was lime called for on the Agronomist report? ❑ ❑ I.: ❑
1
If required, was lime applied(purchase receipts available)? ❑ ❑ e:1 ❑
Copper and Zinc indices: ❑ <2,000 ❑ 2,000—3,000 ❑ >3,000
Was Sodium less than 0.5 meq/100 cm3 ? ❑ ❑ ►1 ❑
Was Exchangeable Sodium Percentage (ESP) less than 15% ? ❑ ❑ ❑
Groundwater Monitoring:
Were GW-59's submitted? ❑ ❑ l CI
Has GW-59A certification been completed for facility? CI CI ® ❑
Are all samples analyzed for the required parameters? ❑ ❑ ❑
Are there any 2L GW quality violations? ❑ ❑ ❑
Comments:
Te'eeL PL _ezi
����p r // a
CI 0\e_el /ie\_,))kf‘-t-
CoJv 4J p1 aJ�i L -�o �I d li it"�`7,/* l(f✓ 62L/ offI 4
— Il dddddcccc 7-
7 n!a _IfPe) v- J ' /
(,.ie, l ls 1 tMd n 4'
I i�5 o Iyi/ /
I�b/ � Ste- /
�,Ay 3 y cL � A)
/Jc f
sad -) 4'-': -
gc( w4-t--1i^,/ MQ O r
v6) 1 c. ,i
�4 lam`" nn /kA ,/?'
C3,A,._,(1-0,‘ L (v n4 e ,a-,
f a(t// Iv w/ fI
0--C-1-1--0) 4_, rf-G,_4,-) 7-5 cl
_ y .1-tier......-4..1.-e
ostrri6440', 40( fvv<Z4As) H-11W"('/kre CIO r,
e kvl(-2- r „Lt-4) 8°
D 01( ' 4 r
" ( v." C`� d Mu c GPage 4 of 4 Z M'
kr t., +I&e cii r/ 0-1- p o0 ,

Permit: WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 09/10/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection of the subject facility was conducted on September 10, 2013.Accompanying DWR on the inspection was Mr.
Shane Fletcher, Residuals Coordinator with the City of Burlington.All required records and documents were available at
the time of inspection and were in good order. The facility was found to be compliant with Permit No. WQ0021632.
NOTES:
-Facility has 10 blowers total, but only use 6 to 8 blowers.
- Facility uses a flag label system for tracking batch piles.
- Facility uses 4 thermometers(one on each side of batch piles)to demonstrate temp. compliance.
Page: 2

Compliance Inspection Report
Permit: WQ0021632 Effective: 01/14/09 Expiration: 12/31/17 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
F4i1 iB oayn dW DooisdiRdtion Program
County: Alamance
Region: Winston-Salem
Graham NC 27253
Contact Person: Stephen Russell Shoaf Title: Phone: [phone]
Directions to Facility:
Take NC Hw.87 South off of 1-85(Exit 147). Proceed on NC Hwy. 87 South,and bear left onto Swepsonville Road.At Boywood Road,
tear right.The entrance to the WWTP is 0.25 miles on the right
yste Classi ications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09/10/2013 Entry Time: 11:00 AM Exit Time: 12:30 PM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: • Compliant 0 Not Compliant
Question Areas:
Miscellaneous Questions •Record Keeping IITreatment •Sampling
■Pathogen and Vector ■Storage
Attraction
(See attachment summary)
Page: 1

i
1
Cr 'Y OF BURLINGTON
SOUTH BURLINGTON WASTEWATER TREATMENT PLANT
2471 BOYWOOD ROAD, GRAHAM,NC 27253
PO BOX 1358, BURLINGTON;NC 27216-1358
[phone]
"COMPOGRO" COMPOST INFORMATION SHEET
Our"COMPOGRO" compost is manufactured from a controlled blend of biosolids,woody residues,leaves and other
compatible organic wastes. These materials are co posted under carefully controlled conditions to assure the highest quality
product suitable for topsoil production,flowerbeds lawn care,shrubbery,golf courses,parks,cemeteries,greenhouses,and
nurseries. The compost is analyzed routinely and ,as the following nutrient contents:
Available Nutrients per Ton(1 yard of Compogro weighs 528 lbs.)
Application Method: N P205 K20 Ca Mg S Fe Mn Zn Cu B Mo Cl Na
Broadcast 9.78 7.65 6.36 10.05 2.24 1.59 2.75 .43 .14 .06 .02 - - 1.08 pH 6.4-6.5
Soil Incorporation 13.10 9.58 7.16 12.60 2.81 1.99 3.43 .54 .17 .07 .03 - 1.08 %dry 57.04
1 Range of values based on the most recent analyses by NCDA&CS for FP#45
The production of COMPOGRO met all of the temperature requirements for pathogen destruction as required by EPA and the
North Carolina Department of Environment and Natural Resources(NCDENR). The composting process has achieved
temperatures of not less than 131 degrees Fahrenheit for three consecutive days,and has been tested for pathogen indicator
organisms prior to public distribution. This produ4t has been composted for at least 21 days and cured for more than 21 days to
provide additional product quality. The heavy m 1 content of COMPOGRO is less than or equal to the metals limitations
established by EPA and recognized by NCDENR r classification as exceptional quality biosolids. During the composting and
curing process,this product met the EPA and NC ENR requirements for vector attraction reduction by achieving an average of
113 degrees Fahrenheit for at least 14 consecutive ys. COMPOGRO is suitable for distribution to the public for a variety of
agricultural,landscaping,and horticultural uses wi the following restrictions:
1. COMPOGRO shall not be applied t land except in accordance with the instructions contained herein.
2. Do not ingest or allow others to ing t COMPOGRO. Wash hands after handling.
3. Third parties must be provided with COMPOGRO information sheet.
4. COMPOGRO shall not be applied any site that is flooded,frozen,or snow covered.
5. COMPOGRO shall not be applied 'thin 25 feet of any waterway,stream,river,or lake.
6. COMPOGRO shall not be applied ithin 100 feet of any wells or private or public water supply sources.
7. COMPOGRO stored for longer th 14 days must be covered.
8. Adequate precaution must be taken prevent runoff of COMPOGRO during rainfall events
9. COMPOGRO should not be appli if it threatens any species listed under section 4 of the Endangered Species Act.
10. COMPOGRO shall not be applied any area in the 100 Year Flood Elevation unless it is tilled in to the soil.
11. COMPOGRO shall not be applied an area if there is less than 1-foot separation from the vertical water table.
12. COMPOGRO shall not be applied 'thin 24 hrs of a rainfall event of 0.5 inches or greater.
13. COMPOGRO should be applied at nomic rates or as recommended for intended use
The end user of this product is expected to use thi product as described above. All state and federal regulations are intended for
the protection of the public health and the enviro ent. ,
Limited Warranty and Disclaimer: The City o Burlington warrants that the product,COMPOGRO,meets the specifications
stated above. Except as stated in the preceding tence,there are no warranties,express or implied,that extends beyond the
representations herein made. Specifically,there a no warranties of merchantability or fitness or suitability thereof for any
purpose. If for any reason COMPOGRO fails to eet the specifications,the Buyer's sole remedy shall be limited to the recovery
of the purchase price. Under no circumstances sh ll the City of Burlington be liable for any other damages,including direct,
indirect,consequential or special damages.
1
_ j

co •
COMPOST USE ESTIMATOR
Cubic Yards of Compost Raquired le Cover 1,000 Square Peet
►/4-inch layer -0 approximately 0.73 cubic yards
1/2-inch layer -• apprehensibly 1.3 cubic yards
►-inch layer -• appraiwslsiy► 3.0'pubic yards
l'ti-taeh layer -• apprereeesityr 4.3 cubic yards
2-�neh'layer -• appresswslaly+ 6.0 cubic yards
2 ti4-inch ley er -+ apprerdfiutsly 7.5 cubic yards
3-inch layer -4, appiexiritataiy 9.0 cubic yards
Cubic Yards of Compost qua d to Cover Oa. Acre
l/4-inch layer -+ approximataly 34 cubic yards
1 r2-inch layer -4, approximately 67 cubic yards
1-inch layer -• approximately 134 cubic yards
1''4-inch layer + approximately 201 cubic yards
2-inch layer -• approximately 269 cubic yrds
2%-inch layer -• apprexiwstely► 333 cubic yards
3-inch layer -• approximately 402 cubic yards
Approximate Number of Pew Piled by One
Cubic Yard of Compost Amended Media
Pot Sine a Pilled
4 inch 1,210
1 gallon (6 inches) 225
2 gallon (8 inches) 120
3 gallon (10 inches) $0
7 gallon (14 inches) 3$
15 gallon (17 inches) 14
Cubic Yards of Compost amulets/ to Cover a Specific Area Formula:
Specific area to cover (esterstwd as square ) compost fest x amount of apply to aPP Y (expressed 1
depth in inches) x 0 0031 • equals cubic yards of compost to cover a specific area
x inches of compost x 0 0031 in
y63)
Ezaasple:
We are u+tarestad in determining the amount of compost nocassary to cover 5,000 fi with a one
half inch layer of compost.
(5,000R2x05 inches of depth x00031 775y&3)

t
(":- � '1' 1,, CITY OF BURLING ! ON
�le?1� COMPOGRO COMPOST FACILITY
1
4i:z,� DELIVERY INVOICE - PICKUP RECEIPT
BUYER/ DELIVER TO:
NAME: DA E: PILE#
ADDRESS: SHI VIA: CITY TRUCK
CITY/STATE: SHI3 VIA: P.O.V.
ZIP CODE: CHECK#
PHONE#: CAH SALE: $
DATE CU. YDS. CU. YDS. LOADED COST PER TOTAL COST DELIVERY TOTAL
SHIPPED ORDERED SHIPPED BY CU. YD. COMPOST CHARGE COST
TOTALS 2><C><CK
MILEAGE STOP: TIME END:
MILEAGE START: TIME BEGIN:
TOTAL MILAGE: TOTAL TIME:
DATE: REC. BY
( SEE REVERSE SIDE )
COMPOST SALES SHEET.xis

it
CITY OF BURLINGTON
SOUTH BURLINGTON WASTEWATER TREA I MEN"I PLAN I
2471 BOYWOOD ROAD, GRAHAM, NC 27253
PO BOX 1358, BURLINGTON, NC 27216-1358
"COMPOGRO" COMPOST INFORMATION SHEET
Acknowledgement: The undersigned Buyer acknowledges that he or she has been provided with a
COMPOGRO information sheet and a estimated use calculator worksheet. The undersigned agrees to abide
by the restrictions concerning use of this product.
Buyer Signature Date
Name: Quantity:
Address: Intended use:
Telephone: Purchase price$

4
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John E, Skvarla, Ill
Governor Director Secretary
May 1, 2013
Mr. Harold T. Owen, City Manger
City of Burlington
P.O. Box 1358
Burlington,NC 27216
SUBJECT: Annual Report Review
City of Burlington, Compogro Compost Facility
Residuals Distribution Program
Permit No. WQ0021632
Alamance County
Dear Mr. Owen:
The Division of Water Quality (DWQ) acknowledges receipt of your 2012 annual report for the subject
permit. A review of this report was conducted by DWQ staff person Mr. Patrick Mitchell. Review of the
subject annual report reflects compliance with Permit No. WQ0021632. An announced routine facility
compliance inspection is planned to be scheduled within the next 12 months.
•
If you or your staff have any questions, please contact Mr. Patrick Mitchell or me at 336-771-5000.
Sincerely,
� ,Kt-C L
Sherri V. Knight, P. .
Regional Supervisor, Aquifer Protection Section
cc: Mr. Shane Fletcher,Residuals Management Coordinator—City of Burlington,2471 Boy Wood Rd., Graham,NC 27253
Mr.James Blackwell,ORC—Synagro, 284 Boger Rd.,Mocksville,NC 27028
Alamance County Health Department
APS Central Office-Permit File WQ0021632
585 Waughtown Street,Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:[phone] NorthCarolina
Internet: ppotucwatArqualtiv Action
;Vatu r'//,I
An Equal Opportunity I Affirmative Action Employer KL "

Compliance Inspection Report
Permit: WQ0021632 Effective: 01/14/09 Expiration: 12/31/17 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
F7 itB oayn WDistribution Program
County: Alamance
Region: Winston-Salem
Graham NC 27253
Contact Person: Stephen Russell Shoaf Title: Phone: [phone]
Directions to Facility:
Take NC Hw.87 South off of 1-85(Exit 147). Proceed on NC Hwy.87 South,and bear left onto Swepsonville Road.At Boywood Road,
bear rigght.The ntrance to the WWTP is 0.25 miles on the right
yste lassi ications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 04/15/2013 Entry Time: 01:00 PM Exit Time: 02:30 PM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: ■ Compliant Q Not Compliant
Question Areas:
III Miscellaneous Questions •Record Keeping
(See attachment summary)
Page: 1

ate of North Carolina O�OF \NAr i(?
Department of Environment and Natural Resources
Division of Water Quality
u' r
Beverly Eaves Purdue, Governor 0 •.-
Dee Freeman, Secretary
Coleen H. Sullins, Director
Annual Report Review Distribution/Surface Disposal of Residuals
2-V 1 z
Facility Name: Burlington Compoqro Compost Reporting Period: 2
Permit No.: WO0021632 Counties that land is permitted for: NA
Maximum Dry Tons Per Year: 450 source/2250 product Dry tons distributed: 360.45 Distributed/158 IN/648 OUT
Acres permitted: NA Acres applied on: NA
Dry tons per acre applied: NA
Number of fields in permit: NA Number of fields applied on: NA
Monitoring Frequency: <319(1/Year)❑ 319—<1,650(1/Quarter)® z1,650—<16,500(1/60Days)❑ z16,500(1/,Month)❑
Monitoring Frequency for TCLP: Annually ® Permit Cycle ❑
Groundwater monitoring: ❑Yes No
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
Was a certification form submitted? lY- - ❑No DNA ONE
Was distribution conducted during the reported period? _= ❑No DNA LINE
- "Mere the distributions with the permitted amount? ? �'es ❑No DNA ENE
Were recipients information listed? .. :- ❑No DNA ENE
Did it indicate compliance? '`4`j es ❑No DNA ENE
Was form complete? r► es ❑No DNA ONE
Was it signed by the appropriate people? 'ri es ❑No DNA LINE
Comments:
2. Monitoring
Were the analyses conducted at the required frequency? ► , -s ❑No DNA ONE
Was an analyses taken for each source that was distributed? PLk -s [No DNA ENE
Were the metals analyses reported on the Residual Sampling Summary Form? 1:s ❑No DNA ONE
Were the results reported in mg/kg? ►_ -s ❑No DNA ENE
Were the pH's 6.0 or greater for each residual sample? .�n - ❑No ®NA ENE
Were the heavy metals within ceiling concentration permit limits? ~` - ❑No DNA ONE
Were the lab analyses attached? _► .-s ❑No DNA LINE
Were all the required parameters tested? ► 1 s ❑No DNA ONE
Was TCLP analysis conducted? ►lY-s ❑No DNA ONE
Were the TCLP contaminants within regulatory limits? �:. s ❑No DNA LINE
Was a corrosivity, ignitability, and reactivity analysis conducted? :;IYes [No DNA LINE
Comments: Aluminum, Calcium, Magnesium, Potassium, pH, Sodium were not repo ed on form RSSF-B. Please
use form RSSF-B to summarize additional data not reported on form RSSF.
3. Pathogen and Vector Attraction Reduction
Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? , s ❑No DNA ENE
Did the form provide all the required information? -s ❑No DNA ENE
Was pathogen and vector attraction reduction documented? 1-_i es ❑No DNA ENE
Was pathogen/vector demonstrated according to 40 CFR Part 503? ►Y es ❑No DNA LINE
Class A Pathogen Review
To be Class A, residuals shall meet either fecal Coliform density or salmonella density.
Fecal Coliform density .
Was the sampling conducted at the required frequency? -s ❑No DNA LINE
Were multiple samples taken? ;_! es ❑No DNA ONE
Was each sample less than 1000 MPN/gram of total solids? %! es ❑No DNA ENE
OR
Salmonella density
Was the sampling conducted at the required frequency? Dyes ❑No NA ONE
Were multiple samples taken? Oyes ❑No NA LINE

City of Burlington—Compogro Compost Permit No WQ002163L.
Annual Report Review December 0, 2012
Was each sample less than 3 MPN/4 grams of total solids? ❑Yes ❑No NA ONE
To be Class A, residuals shall meet one of the following alternatives:
Alternative 1— Time/Temperature
Were the residuals maintained for correct time and temperature? es ❑No ❑NA ONE
Were logs submitted showing time and temperature? T.1 es ❑No ❑NA ONE
Were temperatures within range for complete time period? ►'� es ❑No ❑NA ONE
Alternative 2—Alkaline Treatment
Were logs submitted showing time and temperature? ❑Yes ❑No ►`iNA ONE
Was the pH raised to 12 or greater and maintained for 72 hours or longer? Oyes ❑No ►'= A ONE
Was the temperature 52°C (126°F)for 12 hours or longer while the pH was z12? Oyes ❑No 5 NA ONE
Were logs submitted showing time and pH? Oyes ❑No e A ONE
Was the temperature corrected to 25°C (77°F)? Oyes ❑No 12 NA ONE
Alternative 5—Process To Further Reduce Pathogens
PFRP Composting
Were the within-vessel method or static aerated pile methods used? ► ► es ❑No DNA ONE
Was temp. z55°C(131°F)for z3 days in within-vessel or static aerated pile method? ► es ❑No DNA ONE
OR
Was the windrow composting method used? Oyes ❑No % A ONE
Was the temp. at>_55°C for a15 days in windrows and turned a minimum of 5 times? Oyes ❑No O NA ONE
PFRP Heat Drying
Was drying by direct or indirect contact w/hot gases& moisture reduced to s10%? Oyes ❑No NA ONE
Was temp. of residuals or temp. of the gas in contact w/residuals at exit>80°C(176°F)? Oyes ❑No NA ONE
Vector Attraction Reduction Review
Was the sampling conducted at the required frequency? Oyes ❑No ENA ONE
Option 1 —38% Volatile Solids Reduction
Was there 38% reduction? Oyes ❑No @ NA LINE
Were lab sheets/calculations in report? Oyes ❑No ►;I NA ONE
Was the reduction on volatile solids(not total solids)? Oyes ❑No 0 NA ONE
Were samples taken at beginning of digestion process & before application (Inspection)? Oyes ❑No 12 NA ONE
Were calculations correct? Oyes ❑No 0 NA ONE
Option 2—40-Day Bench Scale Test
Were residuals from anaerobically digested treatment (Inspection)? Oyes ❑No ►;DNA ONE
Were residuals anaerobically digested in lab? Oyes ❑No ►:INA ONE
Was the test run for 40 days? Oyes ❑No 1'1 NA ONE
Was the test done between 30°C (86°F) and 37°C (99°F)? Oyes ❑No ►`1 NA ONE
Was the reduction of on volatile solids (not total solids)? Oyes ❑No ►TINA ENE
Was the reduction less than 17%? Oyes ❑No ►MINA ❑NE
Were lab sheets/calculations in report? Oyes ❑No ►;DNA LINE
Were calculations correct? Oyes ❑No ►;DNA ONE
Option 3—30-Day Bench Scale Test
Were residuals from aerobically digested treatment(Inspection)? Oyes ❑No ►,7NA ONE
Were residuals aerobically digested in lab? Oyes ❑No 0 NA ONE
Were residuals 2% or less total solids? Oyes ❑No PZ/NA LINE
If not 2%total solids, was the test ron a sample diluted to 2%w/unchlorinated effluent? Oyes ❑No ►J NA ONE
Was the test run for 30 days? Oyes ❑No ►ZA NA ONE
Was the test done at 20°C (68°F)? Oyes ❑No ri A ONE
Was the reduction of on volatile solids (not total solids)? Oyes ❑No ►Z@ NA ONE
Was the reduction less than 15%? ❑Yes ❑No ►:INA ONE
Were lab sheets/calculations in report? Oyes ❑No @ NA LINE
. _ , Page 2 of 3

dity of Burlington—Compogro Compost Permit No WQ0021632
Annual Report Review December 0, 2012
Were calculations correct? ❑Yes ❑No NA LINE
Option 4—Specific Oxygen Uptake Rate (SOUR)
Were residuals form aerobically digested treatment(Inspection)? ['Yes ❑No NA ONE
Were residuals 2% or less total solids (dry weight basis) (not diluted)? ❑Yes ENo NA ❑NE
Was the test done between 10°C (50°F) and 30°C (86°F)? ❑Yes ❑No NA ❑NE
Was the temperature corrected to 20°C (68°F)? ❑Yes ❑No NA ONE
Was SOUR <_1.5 mg of oxygen per hour/gram of total residual solids (dry weight basis)? ❑Yes ❑No NA ONE
Was the sampling holding time two hours? Oyes ❑No NA LINE
Was the test started within 15 minutes of sampling or aeration maintained? ['Yes [No NA ❑NE
Option 5— 14-Day Aerobic Process
Were the residuals from aerobically digested treatment(Inspection)? 2. -s [No DNA ENE
Were the residuals treated for 14 days? ►,,j es ❑No DNA ONE
Was the residuals temperature higher than 40°C (104°F)for a 14-day period? ► Y-s ❑No DNA LINE
Was the average residuals temperature higher than 45°C (113°F)? V es ❑No DNA ONE
Option 6—Alkaline Stabilization
Was the pH of the residuals raised to 12 or higher by the addition of alkali? Dyes ❑No NA ENE
Did the pH of residuals remain at z12 for two hours without the addition of more alkali? ❑Yes ❑No NA ENE
Did the pH remain at>_11.5 for an additional 22 hours w/out the addition of more alkali? Dyes ❑No NA ONE
Was the pH corrected to 25°C (77°F)? ❑Yes ❑No NA ONE
Option 7—Drying of Stabilized Residuals
Does the residuals contain any unstabilized residuals? ❑Yes ❑No NA LINE
Were the residuals mixed with any other materials? Dyes ❑No NA ENE
Were the residuals dried up to 75%total solids? Oyes ❑No NA ONE
Option 8—Drying of Unstabilized Residuals
Were the residuals mixed with any other materials? Dyes ENO ONA LINE
Were the residuals dried to 90%total solids? Dyes ❑No NA LINE
Option 9—Injection
Was any significant amount of residuals on surface one hour after injection (Inspection)? Dyes [No NA ENE
Was injection done on pasture or hay field? ['Yes ❑No NA ❑NE
Was injection done at time that crop was growing? ❑Yes ❑No NA ONE
If Class A, were residuals injected with 8 hours after discharge from pathogen treatment? Dyes ❑No NA LINE
Comments:
4. General
Was the report in the proper format? 7.1 es ❑No DNA LINE
Was the annual report complete? n' es ❑No DNA ONE
Was the report submitted on time? ►.`;Yes ❑No DNA ONE
Comments:
.4 ' Page 3 of 3 ' 'k.

A74:17,,A
NCDER.R
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
December 27,2012
Mr. Harold T. Owen, City Manger
City of Burlington
P.O. Box 1358
Burlington,NC 27216
SUBJECT: November 28,2012 Compliance Evaluation Inspection
City of Burlington
City of Burlington CompoGro Composting Facility and Distribution Program
Permit No: WQ0021632
Alamance County
Dear Mr. Owen:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on November
28,2012. The Compliance Evaluation Inspection was conducted by Derek Denard of the Winston-Salem Regional
Office. Present for the inspection was Shane Fletcher,Residuals Coordinator. The facility was found to be in compliance
with permit WQ0021632.
In addition,enclosed please find a copy of the Annual Report Review conducted on December 20, 2012. The review was
conducted by Derek Denard of the Winston-Salem Regional Office. The Annual Report was reviewed for the year 2011,
which was received on February 15,2012. The Annual Report was found to be in compliance with permit WQ0021632.
Shane Fletcher,with City of Burlington, should be commended for his high level of compliance during the past year.
Overall,the inspection found the facility to be above average.
The next routine compliance evaluation will be scheduled for the week of February 27, 2014.
The Division greatly appreciates your efforts to maintain compliance and solicits any input you may have regarding this
report. Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have
any questions,please call Derek Denard at 336-771-5286.
Sincerely,
•
rt:
Sherri V.Knight,P.E.
Regional Aquifer Protection Supervisor
cc: Shane Fletcher,2471 Boy Wood Rd.,Graham,NC 27253
James Blackwell,SYNAGRO,284 Boger Rd.,Mocksville NC,27028
Alamance County Health Department
APS Central Office-Permit File WQ0000520, o""
Winston-Salem Regional Office
585 Waughtown Street,Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:[phone]\Customer Service:1-877-623-6748 NO hCarolina
Internet http:/Iportal.ncdenr.orgMreblwq
An Equal Opportunity 1 Affirmative Action Employer (Naturally

Compliance Inspection Report
Permit: WO0021632 Effective: 01/14/09 Expiration: 12/31/17 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
Facility and Distribution Program
County: Alamance 2471 Boy Wood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Stephen Russell Shoaf Title: Phone: [phone]
Directions to Facility:
Take NC Hw.87 South off of 1-85(Exit 147).Proceed on NC Hwy.87 South,and bear left onto Swepsonville Road.At Boywood Road,
bear night.The Antr nce to the WWTP is 0.25 miles on the right
yste Classi cattions:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 11/28/2012 Entry Time: 11:00 AM Exit Time: 03:00 PM
Primary Inspector: Derek Denard Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
III Miscellaneous Questions •Record Keeping •Treatment 1111 Sampling
■Pathogen and Vector .Storage •Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 11/28/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Aluminum, Calcium, Magnesium, Potassium, pH, Sodium were not reported on form RSSF-B. Please use form RSSF-B
to summarize additional data not reported on form RSSF.
Storage is 25,000 ft^2 (1 acre)under roof.
Page: 2

Permit: WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 11/28/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application 0
Distribution and Marketing ■
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? 0 0 ■ 0
Are GW samples from all MWs sampled for all required parameters? 0 0 • 0
Are there any GW quality violations? 0 0 ■ 0
Is GW-59A certification form completed for facility? 0 0 • 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? 0 0 ■ 0
a. TCLP analysis? ■ ❑ ❑ ❑
b. SSFA(Standard Soil Fertility Analysis)? 0 0 • 0
Are PAN balances being maintained? 0 0 ■ 0
Are PAN balances within permit limits? 0 0 • 0
Has land application equipment been calibrated? 0 0 ■ 0
Are there pH records for alkaline stabilization? 0 0 ■ 0
Are there pH records for the land application site? 0 0 • 0
Are nutrient/crop removal practices in place? 0 0 ■ 0
Do lab sheets support data reported on Residual Analysis Summary? ■ ❑ ❑ ❑
Are hauling records available? ■ ❑ ❑ ❑
Are hauling records maintained and up-to-date? ■ ❑ ❑ ❑
#Has permittee been free of public complaints in last 12 months? ■ ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? ■ ❑ ❑ ❑
Comment:
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 0
Fecal coliform SM 9222 D(Class B only) 0 0 ■ 0
Page: 3

Permit: WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 11/28/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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) 0 0 • 0
c. pH records for alkaline stabilization(Class B) ❑ ❑ ■ ❑
Temperature corrected 0
d. Salmonella(Class A,all test must be<3MPN/4 gram day) 0 0 • 0
e. Time/Temp on: ■ ❑ ❑ ❑
Digester(MCRT) ❑
Compost ■
Class A lime stabilization 0
f. Volatile Solids Calculations 0 0 • 0
g. Bench-top Aerobic/Anaerobic digestion results 0 0 ■ 0
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion ■
Anaerobic Digestion ❑
Alkaline Pasteurization(Class A) ❑
Alkaline Stabilization(Class B) 0
Compost ■
Drying Beds 0
Other ❑
Comment:
Sampling Yes No NA NE
Describe sampling:
Grab sample from each pile with three cores combined in a bucket.
Is sampling adequate? ■ ❑ ❑ ❑
Is sampling representative? ■ ❑ ❑ ❑
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? 0 0 0 ■
Is a copy of the spill control plan in the vehicle? 00011
Page: 4

Permit: WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 11/28/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is the spill control plan satisfactory? 0 0 0 •
Does transport vehicle appear to be maintained? 0 0 0 •
Comment:
Page: 5

to of North Carolina O� W A T9
epartment of Environment and Natural Resources p
ivision of Water Quality �� y
�? r
Beverly Eaves Purdue, Governor p - - ♦<
Dee Freeman, Secretary
Coleen H. Sullins, Director
Annual Report Review Distribution/Surface Disposal of Residuals
Facility Name: Burlington Compogro Compost Reporting Period: 2011
Permit No.: WQ0021632 Counties that land is permitted for: NA
Maximum Dry Tons Per Year: 450 source/2250 product Dry tons distributed: 360.45 Distributed/158 IN/648 OUT
Acres permitted: NA Acres applied on: NA
Dry tons per acre applied: NA
Number of fields in permit: NA Number of fields applied on: NA
Monitoring Frequency: <319(1/Year)❑ z319—<1,650(1/Quarter)® >_1,650—<I6,500(1/60Days)0 Z16,500(1/,Month)1=1
Monitoring Frequency for TCLP: Annually ® Permit Cycle ❑
Groundwater monitoring: Oyes ZNo
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
Was a certification form submitted? ®Yes ❑No DNA ENE
Was distribution conducted during the reported period? EYes ❑No DNA ENE
Were the distributions with the permitted amount? ®Yes ❑No DNA DNE
Were recipients information listed? ®Yes ❑No DNA DNE
Did it indicate compliance? ®Yes ❑No DNA ENE
Was form complete? ®Yes ❑No DNA ENE
Was it signed by the appropriate people? ®Yes ❑No DNA LINE
Comments:
2. Monitoring
Were the analyses conducted at the required frequency? ®Yes ❑No DNA ONE
Was an analyses taken for each source that was distributed? ®Yes ❑No DNA DNE
Were the metals analyses reported on the Residual Sampling Summary Form? ZYes ❑No DNA ONE
Were the results reported in mg/kg? ®Yes ❑No DNA ONE
Were the pH's 6.0 or greater for each residual sample? Dyes ❑No ®NA ONE
Were the heavy metals within ceiling concentration permit limits? ZYes ❑No DNA ONE
Were the lab analyses attached? ®Yes ❑No DNA ONE
Were all the required parameters tested? ®Yes ❑No DNA ONE
Was TCLP analysis conducted? ®Yes ❑No DNA ONE
Were the TCLP contaminants within regulatory limits? ®Yes DNo DNA ENE
Was a corrosivity, ignitability, and reactivity analysis conducted? ZYes ❑No DNA ONE
Comments: Aluminum, Calcium, Magnesium, Potassium, pH, Sodium were not reported on form RSSF-B. Please
use form RSSF-B to summarize additional data not reported on form RSSF.
3. Pathogen and Vector Attraction Reduction
Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? ZYes ❑No DNA ONE
Did the form provide all the required information? ®Yes ❑No DNA ENE
Was pathogen and vector attraction reduction documented? ZYes ['No DNA LINE
Was pathogen/vector demonstrated according to 40 CFR Part 503? ®Yes ❑No DNA ONE
Class A Pathogen Review
To be Class A, residuals shall meet either fecal Coliform density or salmonella density.
Fecal Coliform density
Was the sampling conducted at the required frequency? ®Yes ❑No DNA DNE
Were multiple samples taken? ®Yes ❑No DNA DNE
Was each sample less than 1000 MPN/gram of total solids? ®Yes ❑No DNA ONE
OR
Salmonella density
Was the sampling conducted at the required frequency? Oyes ❑No DNA ONE
Were multiple samples taken? Oyes ❑No DNA ONE

City of Burlington—Compogro Compost Permit No WO0021632
Annual Report Review December 20, 2012
Was each sample less than 3 MPN/4 grams of total solids? DYes DNo DNA ONE
To be Class A, residuals shall meet one of the following alternatives:
Alternative 1— Time/Temperature
Were the residuals maintained for correct time and temperature? ®Yes DNo DNA ONE
Were logs submitted showing time and temperature? ZYes DNo DNA ONE
Were temperatures within range for complete time period? ®Yes DNo DNA ONE
Alternative 2—Alkaline Treatment
Were logs submitted showing time and temperature? Oyes DNo ®NA ONE
Was the pH raised to 12 or greater and maintained for 72 hours or longer? Oyes DNo ZNA ONE
Was the temperature 52°C (126°F)for 12 hours or longer while the pH was Z12? Dyes DNo ®NA ONE
Were logs submitted showing time and pH? DYes DNo ®NA ONE
Was the temperature corrected to 25°C (77°F)? Dyes DNo ®NA ONE
Alternative 5—Process To Further Reduce Pathogens
PFRP Composting
Were the within-vessel method or static aerated pile methods used? ®Yes DNo DNA ONE
Was temp. Z55°C(131°F)for z3 days in within-vessel or static aerated pile method? ®Yes DNo DNA ONE
OR
Was the windrow composting method used? Dyes DNo ®NA ONE
Was the temp. at z55°C for Z15 days in windrows and turned a minimum of 5 times? DYes DNo ®NA ONE
PFRP Heat Drying
Was drying by direct or indirect contact w/hot gases& moisture reduced to 510%? DYes DNo ®NA DNE
Was temp. of residuals or temp. of the gas in contact w/residuals at exit>80°C(176°F)? Oyes DNo ZNA ONE
Vector Attraction Reduction Review
Was the sampling conducted at the required frequency? DYes DNo ®NA ONE
Option 1 —38% Volatile Solids Reduction
Was there 38% reduction? Oyes DNo ®NA ONE
Were lab sheets/calculations in report? Oyes DNo ZNA ONE
Was the reduction on volatile solids (not total solids)? Oyes DNo ®NA ONE
Were samples taken at beginning of digestion process & before application (Inspection)? Dyes DNo ®NA ONE
Were calculations correct? Oyes DNo ®NA ONE
Option 2—40-Day Bench Scale Test
Were residuals from anaerobically digested treatment(Inspection)? Dyes DNo ®NA ONE
Were residuals anaerobically digested in lab? Dyes DNo ZNA ONE
Was the test run for 40 days? Oyes DNo ®NA ONE
Was the test done between 30°C (86°F) and 37°C (99°F)? Oyes ❑No ®NA ONE
Was the reduction of on volatile solids (not total solids)? Oyes DNo ZNA ONE
Was the reduction less than 17%? DYes DNo ZNA ONE
Were lab sheets/calculations in report? Dyes DNo ZNA ONE
Were calculations correct? Oyes DNo ZNA ONE
Option 3—30-Day Bench Scale Test
Were residuals from aerobically digested treatment(Inspection)? Oyes DNo ®NA ONE
Were residuals aerobically digested in lab? Dyes DNo ®NA ONE
Were residuals 2% or less total solids? Oyes DNo ZNA ONE
If not 2% total solids, was the test ron a sample diluted to 2%w/ unchlorinated effluent? DYes DNo ZNA ONE
Was the test run for 30 days? Oyes DNo ZNA ONE
Was the test done at 20°C (68°F)? Dyes DNo ZNA ONE
Was the reduction of on volatile solids (not total solids)? Oyes DNo ZNA ONE
Was the reduction less than 15%? Dyes DNo ZNA ONE
Were lab sheets/calculations in report? Oyes DNo ZNA ONE
Page 2 of 3

,ty of Burlington—Compogro Compost Permit No WQ0021632
,nnual Report Review December 20, 2012
Were calculations correct? ❑Yes ❑No ®NA ONE
Option 4—Specific Oxygen Uptake Rate (SOUR)
Were residuals form aerobically digested treatment(Inspection)? EYes ❑No ®NA ONE
Were residuals 2% or less total solids (dry weight basis) (not diluted)? EYes ❑No ®NA ONE
Was the test done between 10°C (50°F) and 30°C (86°F)? EYes ❑No ®NA ONE
Was the temperature corrected to 20°C (68°F)? EYes ❑No ®NA ONE
Was SOUR_5.1.5 mg of oxygen per hour/gram of total residual solids(dry weight basis)? EYes ❑No ®NA ONE
Was the sampling holding time two hours? EYes ❑No ZNA ONE
Was the test started within 15 minutes of sampling or aeration maintained? EYes ❑No ®NA ONE
Option 5— 14-Day Aerobic Process
Were the residuals from aerobically digested treatment(Inspection)? ®Yes ❑No ❑NA ONE
Were the residuals treated for 14 days? ®Yes ❑No ❑NA ONE
Was the residuals temperature higher than 40°C (104°F)for a 14-day period? EYes ❑No ❑NA ONE
Was the average residuals temperature higher than 45°C (113°F)? ®Yes ❑No DNA ONE
Option 6—Alkaline Stabilization
Was the pH of the residuals raised to 12 or higher by the addition of alkali? Oyes ❑No ®NA ONE
Did the pH of residuals remain at z12 for two hours without the addition of more alkali? Oyes ❑No ®NA ONE
Did the pH remain at>_11.5 for an additional 22 hours w/out the addition of more alkali? Oyes ❑No ZNA ONE
Was the pH corrected to 25°C (77°F)? Oyes ❑No ®NA ONE
Option 7—Drying of Stabilized Residuals
Does the residuals contain any unstabilized residuals? Oyes ❑No ZNA ONE
Were the residuals mixed with any other materials? Oyes ❑No ®NA ONE
Were the residuals dried up to 75%total solids? Oyes ❑No ZNA ONE
Option 8—Drying of Unstabilized Residuals
Were the residuals mixed with any other materials? Oyes ❑No ®NA ONE
Were the residuals dried to 90%total solids? Oyes ❑No ®NA ONE
Option 9—Injection
Was any significant amount of residuals on surface one hour after injection (Inspection)? Oyes ❑No ®NA ONE
Was injection done on pasture or hay field? EYes ❑No ®NA ONE
Was injection done at time that crop was growing? Oyes ❑No ®NA ONE
If Class A, were residuals injected with 8 hours after discharge from pathogen treatment? Oyes ❑No ®NA ONE
Comments:
4. General
Was the report in the proper format? EYes ❑No DNA ONE
Was the annual report complete? ®Yes ❑No ❑NA ONE
Was the report submitted on time? ®Yes ❑No DNA ONE
Comments:
Page 3 of 3

APS Event Data Sheet
Event# 1603
Section 'APS
Date 15/3/2012
Status Closed
Staff Derek Denard
Time Spent(Minutes) 15
First Name Shane
Last Name [Fletcher
Phone Number ,[phone]
Fax Number
Street
City Burlington
County Alamance
Event Category Residuals
Event Category Other
Event Affiliation ORC
Event Affiliation Other
Phone Call
Email/Fax ❑
Mail Ltr ❑
Referral ❑
Walk-In ❑
Meeting ❑
Comments Discussed 503 and 2T and rules on Class A compost being used in
vegetable gardens for roots crops.
Thursday,May 03,2012 Page 1 of 1

APS Event Data Sheet
Event# 1582
Section ,APS
Date 4/23/2012
Status Closed
Staff Derek Denard
Time Spent(Minutes) ,15
First Name Shane
Last Name Fletcher
Phone Number [phone]
Fax Number
Street
City
County Alamance
Event Category 1Residuals
Event Category Other
Event Affiliation (Local Government
Event Affiliation Other
Phone Call
Email/Fax ❑
Mail Ltr ❑
Referral ❑
Walk-In ❑
Meeting ❑
Comments Discussion of 503 regulations for composting permit WQ0021632.
Wednesday,April 25,2012 Page 1 of 1

AT&
EIR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director Secretary
December 22,2011
Shane Fletcher
City of Burlington
PO Box 1358
Burlington NC 272161358
SUBJECT: November 22,2011 Compliance Evaluation Inspection
City of Burlington
City of Burlington CompoGro Composting Facility and Distribution Program
Permit No: WQ0021632
Alamance County
Dear Mr. Fletcher:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on
November 22, 2011. The Compliance Evaluation Inspection was conducted by Derek Denard of the Winston-Salem
Regional Office. The 2010 Annual Report received on February 18, 2011 was reviewed as part of this inspection. Present
for the inspection was Shane Fletcher with the City of Burlington. The facility was found to be in compliance with permit
WQ0021632.
Please refer to the enclosed inspection report for additional observations and comments. 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: Alamance County Health Department
APS Central Office-Permit File WQ0021632
1111.111111111111
Winston-Salem Regional Office
585 Waughtown Street Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:[phone] I Customer Service:1-877-623-6748 NorthCarolina
Internet:http:/lportal.ncdenr.org/web/wq Naturally Equal Opportunity 1 Affirmative Action Employer

Compliance Inspection Report
Permit: WO0021632 Effective: 01/14/09 Expiration: 12/31/17 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
Facility and Distribution Program
County: Alamance 2471 Boy Wood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Stephen Russell Shoaf Title: Phone: [phone]
Directions to Facility:
Take NC Hw.87 South off of 1-85(Exit 147).Proceed on NC Hwy.87 South,and bear left onto Swepsonville Road.At Boywood Road,
ear ri ht.The ntrance to the WWTP is 0.25 miles on the right
ystem Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 11/22/2011 Entry Time: 10:15 AM Exit Time: 03:00 PM
Primary inspector: Derek Denard Phone: [phone]
Secondary inspector(s):
Reason for inspection: Routine inspection Type: Compliance Evaluation
Permit inspection Type: Distribution of Residual Solids(503)
Facility Status: ■Compliant 0 Not Compliant
Question Areas:
II Miscellaneous Questions Record Keeping II Treatment II Sampling
1'Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit: WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 11/22/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Annual Report Review Distribution/Surface Disposal of Residuals
Summary:
(1)A type-o was noted in the permit Attachment A. The approved residuals sources for Composting gives 450 Maximum
Dry Tons Per Year as the amount of residual biosolids approved for composting from each residuals source-generated
facilities. The former permit issued July 15, 2008 approves 2,250 Dry Tons from source-generating facilities. Our
database(BIMS)confirms that this value should be 2,250 as stated in the former permit. The permit can be amended to
correct this discrepancy.
(2)The Annual Residual sampling summary form noted that Molybdenum was 808 mg/kg for the September 13,2010
sample. The lab report indicated that Molybdenum was reported at<5 mg/kg and Chloride was 808 mg/kg.
(3)SAR data was not reported. During the inspection it was noted that the operator has five years of SAR data available
in a spreadsheet on the computer.
(4)Fecal Coliform densities of 890 MPN/gram where reported on both 6/10/10 and 9/23/10,which is close to the
threshold limit of 1,000 MPN/gram. Please monitor Coliform densities carefully.
Page: 2

m G) d II
n I * > D o D D D d D D > D u) v, > > a) m 0 1.G
m 5 O to 2 m m a m W C co m cu m 0) G) m m G) n 1 'G
3 n m �' 0) v c m m ni D D 'c c GCS 0 a O —
N N tD W 73 CJ1 < 3 C
-4; n' y CD 7 o t0 t0 a 7 •a -o 0) •Q 0 j .,+ O D cu 0) CD O X -0 O
g 3 D o =' •• ( m 2 m o _ = v m d n v 3 3 c m v
m O tD tD ^ 7 ca n 0 7 m C 5 '0 ,, -/�� o p 0
cn CD CD p a 1 o 0 - C fD > V = 0 n ` y yo 0 m St g
(D o H n a) co !A 1O CD a a j * Q U) z .O. d .0 a Q co
N V M O �, 03) < o co co, m _ �. ar) a m aci �'
co0
IQ co c D d N 0) �. 0) �' O CD Cl)' N c N t0CI
N 0
8 7 O
p vIV c o - m °) d CD 3 m a J �. o o 0 -
n tC .0:
pct, - p) _ 0 O
CO En
CA m 0 F.) 3 v • a m w °) to Cr 3 a m c n=i 11) a 3if 0 3 a
O. v v CD _ _
o O y - fA 8 C O Q' 7 y •J v N '`) .0 �; 5 E
3. - > m v X d o v J c) 0) 5' a m 0
�. z d a m o o o c 2
n co N 7 Ol y •J 7 0 0) y 3 m ; T
to `Z y a C to •J N `G CAS v ogle:
w a W
O *5. N - t0 a O
o a 3 (!i -ow
v 0
o)) f ? c 3 °' CD co
'J 3 to m 8 �'
n 3 6Cs) m CO
N N in' < O
co:. ; 'J C 7
0)
co
m
a)
0
m
c
a
sZ
CO
@
3
XI
to
d
a
0
❑ ■ ■ II ❑ ■ ■ III ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ III ■ ❑ ❑ ❑ ❑ @I ■ ❑ a <
❑ ❑ a ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ o 0 CA
FF
■ ❑ a ■ ❑ ❑ ❑ ❑ ■ ■ ■ ■ ■ ■ ■ ❑ ❑ ❑ ❑ ■ ■ ■ ■ a a xi
o
w 0 ❑ Z ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ z z ='
(OD m m m 0
co.)

Permit: WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 11/22/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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) 0 0 • 0
c. pH records for alkaline stabilization(Class B) 0 0 • 0
Temperature corrected ❑
d. Salmonella(Class A,all test must be<3MPN/4 gram day) 0 0 • 0
e. Time/Temp on: ■ ❑ ❑ ❑
Digester(MCRT) ❑
Compost
Class A lime stabilization 0
f. Volatile Solids Calculations 0 0 ■ 0
g. Bench-top Aerobic/Anaerobic digestion results 0 0 ■ 0
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion ■
Anaerobic Digestion ❑
Alkaline Pasteurization(Class A) ❑
Alkaline Stabilization(Class B) 0
Compost ■
Drying Beds 0
Other 0
Comment:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate? 0 0 0 ■
Is sampling representative? 0 0 0 ■
Comment:
Page: 4

State of North Carolina �OF WA TF,QQ
Department of Environment and Natural Resources
Division of Water Quality ,O G
� r
Beverly Eaves Purdue, Governor ? —►
Dee Freeman, Secretary
Coleen H. Sullins, Director
Annual Report Review Distribution/Surface Disposal of Residuals
Facility Name: City of Burlington Compogro Compost Reporting Period: 2010
Permit No.:W00021632 Counties that land is permitted for: N/A
Maximum Dry Tons Per Year: 2,250 In/2,250 Out Dry tons distributed: 990.89 In/594.53 Out
Acres permitted: N/A Acres applied on: N/A
Dry tons per acre applied: N/A
Number of fields in permit: N/A Number of fields applied on: N/A
Monitoring Frequency: <319(1/Year)0 Z319—<1,650(1/Quarter)❑ z1,650—<16,500(1/60Days)® a16,500(1/,Month)❑
Monitoring Frequency for TCLP: Annually ® Permit Cycle ❑
Groundwater monitoring: ❑Yes No
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
Was a certification form submitted? ®Yes ❑No DNA LINE
Was distribution conducted during the reported period? ®Yes ONo DNA ONE
Were the distributions with the permitted amount? ®Yes DNo DNA ONE
Were recipients information listed? ZYes ONo DNA ONE
Did it indicate compliance? ZYes ONo DNA ONE
Was form complete? ®Yes ONo DNA ONE
Was it signed by the appropriate people? ZYes ❑No DNA ONE
Comments: (1)A type-o was noted in the permit Attachment A. The approved residuals sources for Composting
gives 450 Maximum Dry Tons Per Year as the amount of residual biosolids approved for composting from each
residuals source-generated facilities. The former permit issued July 15,2008 approves 2,250 Dry Tons from
source-generating facilities. Our database(BIMS)confirms that this value should be 2,250 as stated in the former
permit. The permit can be amended to correct this discrepancy.
2. Monitoring
Were the analyses conducted at the required frequency? ®Yes ONo DNA ONE
Was an analyses taken for each source that was distributed? ZYes ONo DNA ONE
Were the metals analyses reported on the Residual Sampling Summary Form? ®Yes :No DNA ONE
Were the results reported in mg/kg? ZYes ONo DNA ONE
Were the pH's 6.0 or greater for each residual sample? ZYes ❑No DNA ONE
Were the heavy metals within ceiling concentration permit limits? ®Yes ONo DNA ONE
Were the lab analyses attached? ®Yes ONo DNA ONE
Were all the required parameters tested? ®Yes ONo DNA ONE
Was TCLP analysis conducted? ZYes ONo DNA ONE
Were the TCLP contaminants within regulatory limits? ZYes ONo DNA ONE
Was a corrosivity, ignitability, and reactivity analysis conducted? ZYes ONo DNA ONE
Comments: (2)The Annual Residual sampling summary form noted that Molybdenum was 808 mg/kg for the
September 13, 2010 sample. The lab report indicated that Molybdenum was reported at<5 mg/kg and Chloride
was 808 mg/kg. (3)SAR data was not reported. During the inspection it was noted that the operator has five
years of SAR data available in a spreadsheet on the computer.
3. Pathogen and Vector Attraction Reduction
Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? ®Yes ONo DNA ONE
Did the form provide all the required information? ®Yes ['No DNA ONE
Was pathogen and vector attraction reduction documented? ®Yes ONo DNA ONE
Was pathogen/vector demonstrated according to 40 CFR Part 503? ®Yes ONo DNA ONE

.ty of Burlington Compogro Compost Permit No WQ0021632
Annual Report Review November 21, 2011
Class A Pathogen Review
To be Class A, residuals shall meet either fecal Coliform density or salmonella density.
Fecal Coliform density
Was the sampling conducted at the required frequency? ®Yes ❑No DNA ®NE
Were multiple samples taken? ®Yes [No DNA ONE
Was each sample less than 1000 MPN/gram of total solids? ®Yes ❑No DNA ONE
OR
Salmonella density
Was the sampling conducted at the required frequency? Dyes ONo ®NA ONE
Were multiple samples taken? Dyes ONo ®NA ONE
Was each sample less than 3 MPN/4 grams of total solids? ❑Yes ONo ZNA ONE
To be Class A, residuals shall meet one of the following alternatives:
Alternative 1— Time/Temperature
Were the residuals maintained for correct time and temperature? Oyes ONo ®NA ONE
Were logs submitted showing time and temperature? Dyes ONo ®NA ONE
Were temperatures within range for complete time period? Dyes ONo ZNA ONE
Alternative 2—Alkaline Treatment
Were logs submitted showing time and temperature? Oyes ONo ®NA ONE
Was the pH raised to 12 or greater and maintained for 72 hours or longer? Oyes ONo ZNA ONE
Was the temperature 52°C (126°F)for 12 hours or longer while the pH was z12? Oyes ONo ZNA ONE
Were logs submitted showing time and pH? Oyes ONo ®NA ONE
Was the temperature corrected to 25°C (77°F)? Oyes ❑No ®NA ONE
Alternative 5—Process To Further Reduce Pathogens
PFRP Composting
Were the within-vessel method or static aerated pile methods used? ®Yes ONo DNA ONE
Was temp. a55°C(131°F)for a3 days in within-vessel or static aerated pile method? ®Yes ONo DNA ONE
OR
Was the windrow composting method used? Oyes No DNA ONE
Was the temp. at>_55°C for a15 days in windrows and turned a minimum of 5 times? Oyes ONo ZNA ONE
PFRP Heat Drying
Was drying by direct or indirect contact w/ hot gases & moisture reduced to s10%? Oyes ONo ZNA ONE
Was temp. of residuals or temp. of the gas in contact w/residuals at exit>80°C(176°F)? Oyes ONo ZNA ONE
Vector Attraction Reduction Review
Was the sampling conducted at the required frequency? ®Yes ONo DNA ONE
Option 1 —38% Volatile Solids Reduction
Was there 38% reduction? Oyes ONo ZNA ONE
Were lab sheets/calculations in report? Oyes ONo ®NA ONE
Was the reduction on volatile solids (not total solids)? Oyes ONo ZNA ONE
Were samples taken at beginning of digestion process &before application (Inspection)? Oyes ONo ZNA ONE
Were calculations correct? Oyes ❑No ®NA ONE
Option 2—40-Day Bench Scale Test
Were residuals from anaerobically digested treatment(Inspection)? Oyes ONo ®NA ONE
Were residuals anaerobically digested in lab? Oyes ONo ZNA ONE
Was the test run for 40 days? Oyes ❑No ZNA ONE
Was the test done between 30°C (86°F)and 37°C (99°F)? ❑Yes ONo ZNA ONE
Was the reduction of on volatile solids(not total solids)? Oyes ONo ZNA ONE
Was the reduction less than 17%? Oyes ONo ZNA ONE
Were lab sheets/calculations in report? Oyes ❑No ®NA ONE
Were calculations correct? Oyes ❑No ZNA ONE
Page 2 of 3

City of Burlington Compogro Compost Permit No WQ0021632
Annual Report Review November 21, 2011
Option 3—30-Day Bench Scale Test
Were residuals from aerobically digested treatment(Inspection)? DYes :No ®NA ONE
Were residuals aerobically digested in lab? :Yes ONo ®NA ONE
Were residuals 2%or less total solids? DYes ONo ®NA ONE
If not 2%total solids, was the test ron a sample diluted to 2%w/unchlorinated effluent? :Yes ONo ®NA ONE
Was the test run for 30 days? DYes ❑No ZNA ONE
Was the test done at 20°C (68°F)? ❑Yes ONo ®NA ONE
Was the reduction of on volatile solids(not total solids)? DYes ONo ZNA ONE
Was the reduction less than 15%? DYes ONo ®NA ONE
Were lab sheets/calculations in report? DYes ONo ZNA ONE
Were calculations correct? DYes ONo ®NA ONE
Option 4—Specific Oxygen Uptake Rate(SOUR)
Were residuals form aerobically digested treatment(Inspection)? DYes ONo ZNA ONE
Were residuals 2% or less total solids (dry weight basis)(not diluted)? Oyes ONo ZNA ONE
Was the test done between 10°C (50°F)and 30°C (86°F)? DYes ONo ®NA ONE
Was the temperature corrected to 20°C (68°F)? ['Yes ONo ZNA ONE
Was SOUR s1.5 mg of oxygen per hour/gram of total residual solids (dry weight basis)? DYes ONo ZNA ONE
Was the sampling holding time two hours? DYes ONo ®NA ONE
Was the test started within 15 minutes of sampling or aeration maintained? DYes ONo ®NA ONE
Option 5— 14-Day Aerobic Process
Were the residuals from aerobically digested treatment(Inspection)? ®Yes ONO DNA ONE
Were the residuals treated for 14 days? ®Yes ONo DNA ONE
Was the residuals temperature higher than 40°C (104°F)for a 14-day period? ®Yes ONo DNA ONE
Was the average residuals temperature higher than 45°C (113°F)? ZYes ONo DNA ONE
Option 6—Alkaline Stabilization
Was the pH of the residuals raised to 12 or higher by the addition of alkali? DYes :No ZNA ONE
Did the pH of residuals remain at z12 for two hours without the addition of more alkali? DYes ONo ZNA ONE
Did the pH remain at z11.5 for an additional 22 hours w/out the addition of more alkali? DYes ONo ZNA ONE
Was the pH corrected to 25°C (77°F)? DYes ONo ZNA ONE
Option 7—Drying of Stabilized Residuals
Does the residuals contain any unstabilized residuals? DYes :No ZNA ONE
Were the residuals mixed with any other materials? DYes ONo ZNA ONE
Were the residuals dried up to 75%total solids? DYes ONo ®NA ONE
Option 8—Drying of Unstabilized Residuals
Were the residuals mixed with any other materials? DYes ONo ®NA ONE
Were the residuals dried to 90%total solids? DYes ONo ZNA ONE
Option 9—Injection
Was any significant amount of residuals on surface one hour after injection (Inspection)? DYes ONo ®NA ONE
Was injection done on pasture or hay field? ['Yes ONo ZNA ONE
Was injection done at time that crop was growing? DYes ONo ZNA ONE
If Class A,were residuals injected with 8 hours after discharge from pathogen treatment? DYes ONo ®NA ONE
Comments: (4) Fecal Coliform densities of 890 MPN/gram where reported on both 6/10/10 and 9/23/10,which is
close to the threshold limit of 1,000 MPNlgram. Please monitor Coliform densities carefully.
4. General
Was the report in the proper format? ZYes ONo ONA ONE
Was the annual report complete? ®Yes ONo DNA ONE
Was the report submitted on time? ZYes ONo DNA ONE
Comments: Received on February 18,2011.
Page 3 of 3

CITY OF BURLINGTON
SOUTH BURLINGTON WASTEWATER TREATMENT PLANT
2471 BOYWOOD ROAD, GRAHAM, NC 27253
PO BOX 1358, BURLINGTON, NC 27216-1358
[phone]
"COMPOGRO" COMPOST INFORMATION SHEET
Our"COMPOGRO" compost is manufactured from a controlled blend of biosolids,woody residues, leaves and other
compatible organic wastes. These materials are composted under carefully controlled conditions to assure the highest quality
product suitable for topsoil production,flowerbeds, lawn care, shrubbery, golf courses, parks,cemeteries, greenhouses, and
nurseries. The compost is analyzed routinely and has the following nutrient contents:
Available Nutrients per Ton ( 1 yard of Compogro weighs 660 lbs )
Application Method : N P205 K20 Ca Mg S Fe Mn Zn Cu B Mo CI Na
Broadcast 11.4 14.0 6.1 14.1 2.8 1.9 4.6 .47 .16 .09 .04 - - 97 p11 5.29
Soil Incorporation 15.2 17.4 6.9 17.7 3.5 2.4 5.7 .58 .20 .12 .05 - .97 dry 60.19
Range of values based on the most recent analyses FP#35
The production of COMPOGRO met all of the temperature requirements for pathogen destruction as required by EPA and the
North Carolina Department of Environment and Natural Resources(NCDENR). The composting process has achieved
temperatures of not less than 131 degrees Fahrenheit for three consecutive days,and has been tested for pathogen indicator
organisms prior to public distribution. This product has been composted for at least 21 days and cured for more than 21 days to
provide additional product quality. The heavy metal content of COMPOGRO is less than or equal to the metals limitations
established by EPA and recognized by NCDENR for classification as exceptional quality biosolids. During the composting and
curing process,this product met the EPA and NCDENR requirements for vector attraction reduction by achieving an average of
113 degrees Fahrenheit for at least 14 consecutive days. COMPOGRO is suitable for distribution to the public for a variety of
agricultural, landscaping, and horticultural uses with the following restrictions:
1. COMPOGRO shall not be applied to land except in accordance with the instructions contained herein.
2. Do not ingest or allow others to ingest COMPOGRO. Wash hands after handling.
3. Root or leaf crops for direct human consumption should not be grown within one(I)year of the last application
of COMPOGRO to the site.
4. COMPOGRO shall not be applied to any site that is flooded, frozen,or snow covered.
5. COMPOGRO shall not be applied within 25 feet of any waterway, stream, river, or lake.
6. COMPOGRO shall not be applied within 100 feet of any wells or private or public water supply sources.
7. COMPOGRO stored for longer than 14 days must be covered.
8. Adequate precaution must be taken to prevent runoff of COMPOGRO during rainfall events
9. COMPOGRO should not be applied if it threatens any species listed under section 4 of the Endangered Species Act.
10. COMPOGRO shall not be applied to any area in the 100 Year Flood Elevation unless it is tilled in to the soil.
1 I. COMPOGRO shall not be applied to an area if there is less than 1-foot separation from the vertical water table.
12. COMPOGRO shall not be applied within 24 hrs of a rainfall event of 0.5 inches or greater.
13. COMPOGRO should be applied at agronomic rates or as recommended for intended use.
14. Third parties must be provided with COMPOGRO information sheet.
The end user of this product is expected to use this product as described above. All state and federal regulations are intended for
the protection of the public health and the environment.
Limited Warranty and Disclaimer: The City of Burlington warrants that the product,COMPOGRO, meets the specifications
stated above. Except as stated in the preceding sentence,there are no warranties,express or implied,that extends beyond the
representations herein made. Specifically,there are no warranties of merchantability or fitness or suitability thereof for any
purpose. If for any reason COMPOGRO fails to meet the specifications,the Buyer's sole remedy shall be limited to the recovery
of the purchase price. Under no circumstances shall the City of Burlington be liable for any other damages, including direct,
indirect,consequential or special damages.

6.0 COMPOST USE ESTIMATOR
Cubic Yards of Compost Requited to Cover 1,000 Square Feet
1/4-inch layer -. approximately 0.75 cubic yards
1/2-inch layer -• approximately 1.5 cubic yards
1-inch layer -• approximately 3.0 cubic yards
l►i-inch layer -. approximately 4.5 cubic yards
2-inch layer -. approximately 6.0 cubic yards
2%-inch layer -• approximately 7.5 cubic yards
3-inch layer -• approximately 9.0 cubic yards
Cubic Yards of Compost Required to Cover One Acre
1i4-inch layer approximately 34 cubic yards
1/2-inch layer approximately 67 cubic yards
1-inch layer -• approximately 134 cubic yards
1'h-inch layer -0 approximately 201 cubic yards
2-inch layer -0 approximately 269 cubic yards
2%inch layer -• approximately 335 cubic yards
3-inch layer -• approximately 402 cubic yards
Approximate Number of Pots Pilled by One
Cubic Yard of Compost Amended Media
Pot Size 0 Filled
4 inch 1,210
1 gallon (6 inches) 225
2 gallon (8 inches) 120
3 gallon (10 inches) 80
7 gallon (14 inches) 38
15 gallon (17 inches) 14
Cubic Yards of Compost Required to Cover a Spedlie Area Formula:
Specific area to cover (expressed as square feet) x amount of compost to apply (expressed as
depth in inches)x 0 0031 - equals cubic yards of compost to cover a specific area
( ft2 x inches of compost x 0.0031 - y 3)
Example:
We are interested in determining the amount of compost necessary to cover 5,000 ft2 with a one-
half inch layer of compost.
(5,000 ft2 x 0.5 inches of depth x 0 0031 - 7.75 yd3)

AVIA
NCDETIR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
January 3, 2011
Shane Fletcher
City of Burlington
PO Box 1358
Burlington NC 27216-1358
SUBJECT: November 10,2010 Compliance Evaluation Inspection
City of Burlington
City of Burlington CompoGro Composting Facility and Distribution Program
Permit No: WQ0021632
Alamance County
Dear Mr. Fletcher:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on
November 10, 2010. The Compliance Evaluation Inspection was conducted by Derek Denard and Patrick Mitchell of the
Winston-Salem Regional Office. Present for the inspection was Shane Fletcher,residuals coordinator. The facility was
found to be in compliance with permit WQ0021632.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any
questions, please call Derek Denard at 336-771-5286.
Sincerely,
f
Sherri V. Knight,P.E.
Regional Aquifer Protection Supervisor
cc: Alamance County Health Department
APS Central Office-Permit File WQ0021632
laffailailikaNOMPOt
Winston-Salem Regional Office
585 Waughtown Street,Winston-Salem,North Carolina 27107
Phone:[phone] FAX:[phone] Customer Service:1-877-623-6748 NonrthCarolina
Internet http://portal.ncdenr.orglweblwq NaturallyAn Equal Opportunity 1 Affirmative Action Employer

State of North Carolina
Department of Environment •
and Natural Resources AN"
Division of Water Quality
Beverly H. Purdue, Governor
CD E R
Dee Freeman, Secretary
Coleen H. Sullins, Director
NON-DISCHARGE COMPLIANCE INSPECTION REPORT
GENERAL INFORMATION
Owner: City of Burlington County: Alamance
Permit No.: W00021632 Issuance Date: January 14, 2009
Facility Name: Residuals Land Application Expiration Date: December 31,2017
Permittee Contact: Shane Fletcher Telephone No.: [phone]
ORC Name: Shane Fletcher Cert#: N/A Telephone No.: ( )
Backup ORC: N/A Cert#: N/A Telephone No.: ( )
Email Address: [e-mail]
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER:
Type of inspection
X Residuals (503) Residuals(non-503) Other:
Inspection Summary: (additional comments may be included on attached pages)
RECORD KEEPING/SELF-MONITORING:No comments.
PATOGEN AND VECTOR ATTRACTION:
Alternative: 5—Process To Further Reduce Pathogens
Option: 5— 14-Day Aerobic Process
TREATMENT: Aerobic digestion and Compost
STORAGE: Total of 826,635-sq ft storage capacity.
SAMPLING:Not evaluated.
TRANSPORT: Receipts were available for compost. Recipients are required to cover their loads before
leaving the composting facility.
LAND APPLICATION SITE:NA
OTHER:NA

City of Burlington—CompoGro Permit No WQ0021632
Compliance Inspection Report 11/10/2010
Is a follow-up inspection necessary: _Yes X No
Inspector(s)Name(s): Derek C Denard and Patrick Mitchell
Telephone: [phone] Fax: (336)771 —4631
Date of Inspection: 11/10/2010 Entry Time: 10:00 am Exit Time: 04:00 pm
Type of Residual
Land Application(class B) X Distribution and Marketing(class A)
Record Keeping [Y,N,NA, or NE]
Y Copy of current permit available at residual generating site
Y Current metals and nutrient analysis(see permit for frequency)
Y TCLP analysis,NA SSFA(Standard Soil Fertility Analysis)
NA Nutrient and metals loading calculations(to determine most limiting parameter)YTD
NA Are PAN balances being maintained? NA Are PAN balances within permitted limits?
NA Are there pH records for alkaline stabilization?
NA Are there pH records for the land application site?
NA Nutrient/Crop removal practices in place?
Y Do lab sheets support data reported on Residual Analysis Summary?
Y Hauling records available(#gal and/or tons hauled during calendar year to date)
NA Field loading records,NA Field site maps and information
NA Records of lime purchased
Y Pathogen&Vector Attraction Reduction
NA Field inspection records
Y Free of complaint in past 12 months?
Comments:
Pathogen &Vector Attraction Reduction Records
(Check which method(s) apply)
X Fecal coliform: X SM 9221 E(Class A or B)
SM 9222 D(Class B only)
pH records for alkaline stabilization: _Class A? _Class B?
Salmonella(Class A, all test must be<3MPN/4 gram day)
X Time/Temp records on: _Digester (MCRT)
X Compost
Class A lime stabilization
_ Volatile solids calculations
Bench-top Aerobic/Anaerobic digestion results
Comments:
Page 2 of 3

City of Burlington—CompoGro Permit No WQ0021632
Compliance Inspection Report 11/10/2010
Treatment(check treatment type(s) used)
X Aerobic digestion
Anaerobic digestion
Alkaline Pasteurization(Class A)
Alkaline Stabilization(Class B)
X Compost
Drying Beds
Other: (explain)
Transport
NA Copy of permit in transport vehicle?
NA Spill control plan in transport vehicle?
NA Is spill plan satisfactory?
NA Does transport vehicle appear to be maintained?
Y Are receipts available for distribution?
Comments:
Receipts were available for compost. Recipients are required to cover their loads before leaving the
composting facility.
Storage
Describe storage: 25,500-sq ft open area for amendment material
1,875-sq ft open area for amendment material
1,710-sq ft covered area for blending
35, 700-sq ft covered area for composting
(maximum of 22 piles that are 7-ft high X 12-ft wide X 80-ft long)
2,225-sq ft bunker for storing composted residuals/amendment cake and
recovering bulking material
625-sq ft bunker for storing recovered bulking material
15,000-sq ft open area for fmal curing and maturation of compost
Total of 826,635-sq ft storage capacity.
Number of days/weeks/months of storage: >>one year
NE Is there a Spill Control Plan?
Sampling
DescribeSampling: NE
Is sampling adequate? NE Is sampling representative? NE
Page 3 of 3

- 3 -
Introduction
In 1999, the Burlington City council agreed to allocate funds to construct a small-scale compost
facility at the South Burlington WWTP capable of processing 5.5 dry tons of biosolids per day.
Although the compost facility would not be large enough to compost 100% of the daily sludge
production of the wastewater plant, it would be large enough to answer some important questions such
as:
1. Could the City produce a quality and compliant compost at a reasonable cost?
2. Is the local demand for compost enough to warrant an expansion of the compost
operations?
3. How will the cost of processing compost to a Class A residual compare to the cost of
hauling Class B sludge from year-to-year?
Construction on the compost facility began in 2001 and the first sludge was dewatered in 2002. The
compost facility operated in a `test' mode in the time between the completion of construction and the
time the permit to operate a compost facility was received from the NC Department of Environment
and Natural Resources in September of 2003.
This annual report has been assembled as a condition of the Distribution of Residual Solids (503)
Permit, #WQ0021632.
I. DESIGN CRITERIA
Design Flow: 5.5 dry tons feed sludge per day
Equipment Description:
Number Equipment Purpose
2 Grinder pumps Transfer residuals from existing storage tanks
1 2-meter belt press Dewater feed sludge to 16%—20% solids
1 Berth for 2' 2-meter belt press (future)
C:\Documents and Settingstsfletcher\Local Settings\Temporary Internet Files\OLK21Compost_Annual071.doc

- 4 -
1 Conveyor Transfer dewatered sludge to mixing area
1 25,500 ft2 Open area Storing amendment material
1 1,710 ft2 Covered area Blending dewatered residuals and amendment material
1 1,875 ft2 Covered area Storing amendment material
1 Agricultural Feed Mixer Blending dewatered residuals and amendment material
1 35,700 ft2 Covered area Composting blended residuals/amendment material
11 5-Horsepower blowers Aerating static piles (Maximum of 22 static piles)
1 153 yd3 Trammel screen Screening composted product and recovery of amendment
1 15,000 ft2 Open area Final curing and maturation and storage of Class A product
1 900 ft2 biofilter Capture and treat odor-generating compounds in the facility
1 4,900 ft2 biofilter Capture and treat odor-generating compounds in the facility
1 Polymer Feed System Assist with the dewatering of residuals
II. PROCESS DESCRIPTION
The goal of the Compogro compost facility is to consistently produce a Class A EQ material that is
suitable for a variety of uses on land that has no post-application restrictions. Class A residuals have
the greatest degree of pathogen reduction and are considered to be very safe. All domestic residuals
which are to be distributed to the public for use for landscaping must meet one of the alternatives for
Class A pathogen reduction found in 40 CFR Part 503.30.
Class A pathogen reduction must meet one of the following criteria:
1. A fecal coliform density must be less than 1,000 MPN (most probable number) per gram of
total solids (dry weight)
OR
2. A Salmonella sp. bacteria must be less than 3 MPN per 4 grams of total solids (dry weight)
C:\Documents and SettingslstletcherlLocal Settings\Temporary Internet Files\OLK21Compost_Annual071.doc

- 5 -
The City of Burlington has selected the former criteria (fecal coliform <1,000 MPN) as the preferred
method to determine compliance with the pathogen reduction requirements. This is achieved by
following the time and temperature guidelines in 40 CFR 503.
In addition to the pathogen reduction requirements, Compogro must also meet all of the Vector
Attraction Reduction (VAR) requirements of Class A residuals. All domestic residuals which are to be
distributed to the public for landscaping must meet one of the alternatives for vector attraction
reduction listed in 40 CFR 503.33. The City achieves compliance by following the time and
temperature guidelines provided by the USEPA.
The City of Burlington Compogro Compost facility has developed a system for building aerated piles
and collecting and recording data necessary to ensure that all the requirements of Class A compost are
being achieved. A copy of the sampling plan along with all the information necessary to demonstrate
compliance with 40 CFR 503 rules for the Calendar Year 2008 are included with this report.
III. RECORDKEEPING PROCEDURES
A record of the aerated static pile temperatures is enclosed to demonstrate that the piles meet the
required temperatures for the designated time to achieve pathogen reduction and vector attraction
reduction. The document is titled Compost Pile Temperature's. Aerated static piles are assigned an
identifying number that establishes the date that the pile was built, and the blower that was used to
aerate the pile. The format is year, month, day, and blower number. For example, the number
030109-07 would indicate that the pile was started on January 9, 2003 and was aerated using blower 7.
Each pile is monitored for temperature with at least four thermometers. We are satisfying the 40 CFR
C:\Documents and SettingslsfletcherlLocal Settings Temporary Internet Files 10LK21Compost_Annual071.doc

- 6 -
503 pathogen reduction requirements by keeping the compost above 131 degrees F for three (3)
consecutive days (72 hours minimum). We are satisfying the 40 CFR 503 vector attraction reduction
requirements by keeping the compost above 104 degrees F and an average of greater than 113 degrees
F for a minimum of fourteen (14) consecutive days. In reviewing these logs you will see that we are
maintaining the aerated static piles for longer than 21 days, and keeping the temperatures elevated for
longer than the regulations require. The piles on the Compost Pile Temperature log sheet were
followed onto the curing piles and into the finished compost product piles.
The City has included copies of residuals analyses for the finished compost product from A&L
Eastern Agricultural Laboratories, Inc. All of the results support the EQ designation of the compost
and are included in a separate section of this report.
IV. "COMPOGRO"COMPOST SAMPLING PROCEDURES
The Static Aerated Piles
The aerated static piles are constructed under a roof to protect the pile from wind and rain. Before
building the pile, the base or bed is made with a 4 inch perforated airline placed down the center of the
bed. The airline is connected to a blower creating positive or negative pressure so that air can be
forced or pulled through the compost pile. The blowers are controlled by timers that turn them on or
off as needed to supply airflow to the piles. After the biosolids and amendment (wood chips and
leaves) are mixed together, the mixture is placed on the insulating base to build the static aerated pile
and to begin the composting process. The mixture of biosolids and amendment is then covered with a
six to eight(6—8) inch blanket of amendment to insulate the pile.
C:\Documents and Settings\sfletcher\Local Settings\Temporary Internet Files\OLK21Compost_Annual071.doc

- 7 -
After building a pile, a minimum of four (4) thermometers with 48-inch probes are placed at various
locations and depths throughout the pile to monitor the temperatures of the compost pile. The
temperatures are recorded daily to track the composting process. Results are entered into a database to
track each pile with a unique identifier to make sure it meets the regulatory requirements. The
thermometers are left in place during the time required to achieve compliance with the time and
temperature requirements for the process to further reduce pathogens (PFRP) and for vector attraction
reduction. We have not had any trouble reaching the prescribed time and temperatures. We make
sure that the piles achieve 131 degrees Fahrenheit for a minimum of 3 consecutive days and are above
104 degrees F and kept at an average of greater than 113 degrees F for a minimum of 14 consecutive
days. Regardless of the time and temperature requirements, we keep the aerated static piles for a
minimum of 21 days and some are kept up to 50 days depending on storage space and composting
conditions.
Curing and stabilization
After the compost has met the requirements for time and temperature on the static aerated piles, the
compost is moved to the curing pile for a minimum of 21 days for further stabilization. We keep one
thermometer in the curing pile (which can be a combination of several aerated static piles) and record
those temperatures as well. We have found that the curing process often requires more than 21 days
and may take as many as 50 days.
Sampling Finished Compost for Fecal Coliform, Metals and Nutrients
After the curing process is completed the material is screened to separate the reusable amendment
from the compost. At this point the finished compost is ready to be sampled and analyzed for fecal
C:1Documents and SettingslsfletcherlLocal Settings\Temporary Internet FilesIOLK21Compost_Annual071.doc

- 8 -
coliform to demonstrate successful pathogen reduction. The finished compost pile is sampled for fecal
coliform in the following manner.
A core sampler is disinfected for use to collect the samples. The core sampler is used to take core
samples within the compost pile at different depths and locations through out the compost pile to get a
good composite sample of the product. We collect four (4) cores in a sealable plastic bag or sterile
fecal bottle to make one composite sample, and collect a minimum of three (3) composite samples for
each batch of finished compost. That means that we are taking samples of twelve (12) different
locations in the pile.
The fecal samples are collected in sterile fecal bottles and are sent directly to the lab for analysis. The
samples are either hand delivered to the City of Burlington wastewater lab (Certificate No. 188) or
shipped to the Summit Environmental Technologies Lab in Akron, Ohio. A dry solids analysis and
the fecal test require about four days turnaround from sample collection to reporting of the data.
Sample results are recorded and laboratory reports are maintained in the files.
Similar sampling techniques are used to collect samples for nutrient and metals analyses. Those
samples are contained in the sealable plastic bags and sent to A&L Eastern Agricultural Laboratories,
Inc. in Richmond, VA. This data will be used to formulate the information sheets that are given to the
purchaser of the compost. These analyses will be performed within 60 days of distribution of the
finished product, and the results will be maintained on file.
C:IDocuments and SettingslsfletcherlLocal Settings\Temporary Internet Files\OLK21Compost_Annual071.doe

- 9 -
Test for Re-growth of Fecal Coliform
If the compost is not distributed within 60 days of an acceptable analysis, the pile will be resampled
for fecal coliform using the same technique as above immediately (approximately one week) prior to
distribution.
C:1Documents and SettingslsfletcherlLocal Settings\Temporary Internet Files1OLK21Compost_Annual071.doc

r Water-Pollution Control System Operator Designation For
WPCSOCC 14C
MAY 0 2 2006 NCAC .SA SG. .0201
r7.nsc::n-Salem O4=1
e nal ice
erNamc: Harold Owen, City Manager, City of Burlington
Mailing Address: City of Burlington, PO Box 1358
City: Burlington St, 27216 _ 1358 2 2-5 0
---•----•-'ip� Phone It: (336)
Signature:
632
Facility Name: City of Burlington Compogro Composting and 000
pp permit#: WQ0000520
!SUBMIT A SEPARATE,FORM FOR EACH TYPE OF LanSYSTI M ation
Facility Type&Grade:
Grade Grade
Biological WWTP Surface Irrigation N/A
Physical/Chemical Land Application X
Collection System
Operator in Responsible Charge(ORC)
Print Full Name: Everett Shane Fletcher
WWIV 988571
Certificate Type/Grade/Nuinbcr: LA 988745 Work Phone/!: 0 6_ 5_70-6138
Signature: —^� _ - — �z� ��Date:T
"I ceilil'y that I agree to say designation as the Operator in Responsible Charge for the facility noted.I utxlcrstand and will abide by the
rules and regulations pertaining to the responsibilities of the ORC as set forth in I SA NCAC 08G.0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
flack-Up Operator in Responsible Charge(BU OR(.)
Print Full Name: Stephen R. Shoaf
WWIV 9499
Certificate Type/Grade/Number: LA 13260 Work Phone 4: (33cd 222-5133
Signature:_ ie
` Date: W.23/0.8
"I certify that I agree to my designation as a Rae -up Operator in Responsible Charge for the facility noted,I understand and will abide by
the rules and regulations pertaining to the responsibilities of the AU ORC as set forth in 1 SA NCAC 08C;.0205 and failing to do so can
result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Mail or Fax to: WPCSOCC
1618 Mail Service Center
Raleigh,NC 27699-1618
Fax: [phone]
(See next page for designation of additional hark-up upei anoos.Designation of more than one back-up a ator is optional.)
Revised 1-2008

.,dditional Back-up ORC desienations
WQ 0021632
Facility Name: _City of Burlington Compogro Compost and Permit#: WQ 0000520
Land Application - — ---
Back-Up Operator in Responsible Charge(DU ORC)
Print Full Name: Eric A. Davis
---_._...--------- WWIV 15202 Certificate Type/ ade/Number: -_LA -__26305 Work Phone Il: f 33_6 222-5133
•
Signature: --___-- Date:
certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted.I understand and will abide by
the rules and regulations pertaining to the responsibilities of the BU ORC as set forth in ISA NCAC 08G.0205 and tailing to do so can
result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Back-Up Operator in Responsible Charge(BLJ ORC)
Print Full Name: •
Certificate Type/Grade/Number: .._.--- ------ - _ _._..-. Work Phone if: .--___) --
Signature:— --_ Date:---
"1 certify that i agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the nsponsihilitics of the BU ORC as act forth in I5A NCAC 08G.0205 and failing to do so can
result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Back-Up Operator in Responsible Charge(BU ORC)
Print Full Nanic:
Certificate Type/Grade/Number:.__..... Work Phone it:
Signature: Date:
"t certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted.J understand and will abide by
the rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G.0205 and failing to do so can
result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Back-Lip Operator in Responsible Charge(BU ORC)
Print lull Name:
Certificate Type/Grade/Number: Work Phone#t:
Signature:
_....._..,_---- Date:
"I certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted.J understaud and will abide by
the rules and regulations pertaining to the responsibilities of the LW ORC as set forth in I5A NCAC 08G.0205 and failing to do so can
result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Revised 1-2008

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 6,2010
Shane Fletcher
City of Burlington
PO Box 1358
Burlington NC 272161358
SUBJECT: Annual Report Review
City of Burlington
City of Burlington CompoGro Composting Facility and Distribution Program
Permit No: WQ0021632
Alamance County
Dear Mr. Fletcher:
Enclosed please find a copy of the Annual Report Review conducted on June 4,2010. The review was conducted by
Derek Denard of the Winston-Salem Regional Office. The Annual Report was reviewed for the years 2008 and 2009,
which were received on February 12,2009 and February 09, 2010. The facility was found to be in compliance with
permit WQ0021632.
The following was noted from the review of the annual reports for 2008 and 2009:
• Please use form RSSF-B to report Aluminum,Calcium, Magnesium, Potassium, pH, PAN, and Sodium.
• A few typos noted in the temperature/time data that may need correction:
2008:
page 373 1/29/08 pile#080128-06 LOC#1 40°F
page 396 6/14/08 pile#080519-06 LOC#3 10°F
2009:
page 22 11/20/08 pile#081103-05 LOC #4 15°F
page 36 2/17/08 pile#090126-05 LOC#4 15°
page 58 6/6/09 pile#090508-02 LOC #1 0.151°F
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://portal.ncdenr.org/web/wq �
An Equal Opportunity 1 Affirmative Action Employer Natura`l//

.Ar. Fletcher
Page 2 of 2
June 7,2009
Please refer to the enclosed report form for additional observations and comments. If you or your staff have any
questions, please call Derek Denard at 336-771-5286.
Sincerely,
Sherri V. Knight, P.E.
Regional Supervisor, Aquifer Protection Section
cc: Alamance County Health Department
APS Central Office-Permit File WQ0021632
Winston-Salem Regional Office
585 Waughtown Street,Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:[phone] Customer Service:1-877-623-6748 North C aroli na
Internet:http:/lportal.ncdenr.org/weblwq Naturally Equal Opportunity Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0021632 Effective: 01/14/09 Expiration: 12/31/16 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
Facility and Distribution Program
County: Alamance 2471 Boy Wood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Stephen Russell Shoaf Title: Phone:[phone]
Directions to Facility:
Take NC Hw. 87 South off of 1-85(Exit 147). Proceed on NC Hwy. 87 South,and bear left onto Swepsonville Road.At Boywood Road,
bear rightt.The, ntrance to the WWTP is 0.25 miles on the right
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 06/04/2010 Entry Time: 09:00 AM Exit Time: 05:00 PM
Primary Inspector: Derek Denard Phone:[phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type:Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: IN Compliant 0 Not Compliant
Question Areas:
II Miscellaneous Questions Record Keeping II Treatment ■Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit:W00021632 Owner-Facility: City of Burlington
Inspection Date: 06/04/2010 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Inspection Summary:
Annual Report Review Class A Distribution
Reporting Period: 2008-2009
Permit Details:
• Is 503?YES
• Class A or B? A
• Maximum Dry Tons Per Year: From Source—450, Product—2250
• Number of acres permitted: N/A
• Number of fields in permit: N/A
• Counties that land is permitted for: N/A
• Monitoring Frequency for TCLP:Annually for product, once per permit cycle for source
• Monitoring Frequency for Residuals Analysis: =>1,650-<16,500 1/60 days 6 x year, source once per permit cycle
• Monitoring Frequency for Pathogen &Vector Attraction Reduction: Same as residuals analysis
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted?YES
• Was distribution conducted during the reported period?YES
• How many dry tons were produced and distributed?
2008:Amendment/bulking- 3544.8, Residual In—886.3, Product Out—372.7, Distributed—362.9
2009: Amendment/bulking-2228, Residual In—534, Product Out—323, Distributed—270.27
• Were the distributions with the permitted amount?YES
• Were recipients information listed?YES
• Did it indicate compliance?YES
• Was form complete?YES
• Was it signed by the appropriate people?YES
2. Monitoring
• Were the analyses conducted at the required frequency?YES: Both years 5 times
• Was an analyses taken for each source that was distributed?YES
• Were the metals analyses reported on the Residual Sampling Summary Form?YES
Were the results reported in mg/kg?YES
• Were the pH's 6.0 or greater for each residual sample?YES: Finished piles
• Were the heavy metals within ceiling concentration permit limits?YES
• Were the lab analyses attached?YES
• Were all the required parameters tested?YES: Need to use form RSSF-B to report Aluminum, Calcium, Magnesium,
Potassium, pH, PAN, and Sodium.
• Was TCLP analysis conducted?YES
• Were the TLCP contaminants within regulatory limits?YES
• Was a corrosivity, ignitability, and reactivity analysis conducted?YES
3. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?YES
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction alternative and the vector
attraction reduction option used?YES
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the report?YES
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?YES
Class A Pathogen Review
Page: 2

Permit: W00021632 Owner-Facility: City of Burlington
Inspection Date: 06/04/2010 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Typical operation is at>104°F with a average of 113°F for a minimum of 14 days(usually more than 21 days in most
cases).
A few typos noted in the temperature/time data:
2008:
page 373 1/29/08 pile#080128-06 LOC#1 40°F
page 396 6/14/08 pile#080519-06 LOC#3 10°F
2009:
page 22 11/20/08 pile#081103-05 LOC#4 15°F
page 36 2/17/08 pile#090126-05 LOC#4 15°F
page 58 6/6/09 pile#090508-02 LOC#1 0.151°F
To be Class A, residuals shall meet either fecal Coliform density or salmonella density.
Fecal Coliform density
• Was the sampling conducted at the required frequency?YES
• Were multiple samples taken?YES
• Was each sample less than 1000 MPN/gram of total solids?YES
To be Class A, residuals shall meet one of the following alternatives:
Alternative 5—Process To Further Reduce Pathogens
PFRP Composting
• Were the within-vessel method or static aerated pile methods used?YES
• Was the residuals temperature maintained at 55°C (131°F)or higher for three consecutive days or longer in the
within-vessel method or static aerated pile method?YES
Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency?YES
Option 5— 14-Day Aerobic Process
• Were the residuals from aerobically digested treatment(Inspection)?YES
• Were the residuals treated for 14 days?YES
• Was the residuals temperature higher than 40°C (104°F)for a 14-day period?YES
• Was the average residuals temperature higher than 45°C (113°F)?YES
4.General
• Was the report in the proper format?YES
• Was the annual report complete?YES
• Was the report submitted on time?YES
Page: 3

Permit:WO0021632 Owner-Facility: City of Burlington
Inspection Date: 06/04/2010 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Type Yes No NA NE
Land Application ❑
Distribution and Marketing •
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? 0 0 • 0
Are GW samples from all MWs sampled for all required parameters? 0 0 ■ 0
Are there any GW quality violations? ❑ ❑ • 0
Is GW-59A certification form completed for facility? 0 0 ■ 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)? 0 0 ■ 0
Are PAN balances being maintained? 0 0 ■ 0
Are PAN balances within permit limits? 0 0 ■ 0
Has land application equipment been calibrated? 0 ❑ ■ 0
Are there pH records for alkaline stabilization? 0 ❑ ■ 0
Are there pH records for the land application site? 0 0 ■ 0
Are nutrient/crop removal practices in place? 0 ❑ ■ 0
Do lab sheets support data reported on Residual Analysis Summary? ■ ❑ ❑ ❑
Are hauling records available? ■ ❑ ❑ ❑
Are hauling records maintained and up-to-date? 0 0 0 ■
#Has permittee been free of public complaints in last 12 months? ■ ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? ❑ 0 ■ 0
Comment: See summary for comments.
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E(Class A or B) 0 0 ■ 0
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 0
Fecal coliform SM 9222 D(Class B only) 0 0 ■ 0
Page: 4

Permit:W00021632 Owner-Facility: City of Burlington
Inspection Date: 06/04/2010 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram 0
b. pH records for alkaline stabilization(Class A) 00110
c. pH records for alkaline stabilization(Class B) 001. 0
Temperature corrected 0
d. Salmonella(Class A, all test must be<3MPN/4 gram day) 0 0 • 0
e. Time/Temp on: N O 0 0
Digester(MCRT) ❑
Compost •
Class A lime stabilization �
f. Volatile Solids Calculations 0 0 • 0
g. Bench-top Aerobic/Anaerobic digestion results 0 0 • 0
Comment: See summary for comments.
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion �
Anaerobic Digestion Q
Alkaline Pasteurization (Class A) �
Alkaline Stabilization(Class B) 0
Compost •
Drying Beds 0
Other 0
Comment: See summary for comments.
Page: 5

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 9,2009
Mr. Stephen Russell Shoaf
City of Burlington
PO Box 1358
Burlington,NC 27216
SUBJECT: February 11,2009 Compliance Evaluation Inspection
City of Burlington •
Class A Residuals Compost Management Program
City of Burlington CompoGro
Composting Facility and Distribution Program•
Permit No: WQ0021632
Alamance County
Dear Mr. Shoaf:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on February 11,
2009. The Compliance Evaluation Inspection was conducted by Derek Denard of the Winston-Salem Regional Office.
Present for the inspection was Shane Fletcher(ORC)with the City of Burlington.The facility was found to be in
Compliance with permit WQ0000520.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any
questions, please call Derek Denard at 336-771-5286.
Sincerely, �_,,/1"
Sherri V. Knight,P.E.
Regional Supervisor,Aquifer Protection Section
cc: Shane Fletcher, ORC
Alamance County Health Department
APS Central Files
Winston-Salem Regional Office
585 Waughtown Street,Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX'.336-771-4631\Customer Service:1-877-623.6748 NorthCarolina
Internet:www.ncwaterquality.org �irtllrllllr�
An Equal Opportunity i Affirmative Action Employer

Compliance Inspection Report
Permit: WO0021632 Effective: 01/14/09 Expiration: 12/31/13 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
Facility and Distribution Program
County: Alamance 2471 Boy Wood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Stephen Russell Shoaf Title: Phone:[phone]
Directions to Facility:
Take NC Hw. 87 South off of 1-85(Exit 147). Proceed on NC Hwy. 87 South, and bear left onto Swepsonville Road.At Boywood Road,
bear right.The,entrance to the WWTP is 0.25 miles on the right
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 02/11/2009 Entry Time: 03:40 PM Exit Time: 04:00 PM
Primary Inspector: Derek Denard Phone:[phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type:Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
II Miscellaneous Questions $Record Keeping II Treatment ■Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit:WQ0021632 Owner-Facility:City of Burlington
Inspection Date:02/11/2009 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Inspection Summary:
Page: 2

cu n = # > > 0 > > > _ > > > > = E > > E ƒ 0 Q —I
o m o $ a a a s 0 a a Q n -
m 2 o E a a a f a 2 _ Q o \ & m
/ ) Q 2 { j § / / / } at } } Z Z R a) } $ j \ X / k k
E R Cl) m & 5 = 7 0 _ a) CT CT ; a « > m CD ; m a g
0 ® n- 10 / k ] 2 m o = = \ / at @ ¥ CD 3 o § 7 2 & m s 13
] J & a \ § / a a & $ § & o ƒ E J 2 §
® q & ® < o cr ° ° ¥ 8 8 § § cu e ƒ \ 0 t co E ..
f w 0 q ] % } 2 d ƒ ƒ t 7 2 \ 2 \ d 5 ƒ § /
R CA 3 ° 2 / a 2 2 0 o 2 7 ] a. k E ] ® OD CO
a a a = m_ k _ m S. -a a -' % % [ ® \ / / (0 N Iv
) \ § k c at o \ ƒ 2 ° ®_ \ \ j « � ° co
Q / m m E � d o E = a \ . o a £ o s
co o' a. R § © E a ® 0 m
c 7 \ ƒ \ / / CO \ \ t• g \ k k ƒ 2 .N3 la£ / 3 - - 0
0 U) R o = 7 �_ - s a w E E K
J 0 0
o CD
\ 0 / . C o \ 5.ƒ / / co\ (
o. k ° / \ c \ { / K « {
CL - R « \
2 co a �_ ~ \ k ~ : \ % 2
\ 3 f ® 13) ¢ C ) g
ƒ / co - 3 o
§ 0 3
\ \ = c
\ % § ' ƒ $ j
A % / .- ¥ _
e � \
0)
0
c
a
Q
co
3
ca
co
0 0 0 0 "' D ■ 0 0 0 O 0 D 0 0 O O ■ ■ ■ ■ 0 0 0 0 2 ■ O ■ \
0 0 g 0 0 0 0 0 O D O O O 0 O O 0 0 D 0 O O I t
■ ■ > ■ 0 O 0 O ■ ■ ■ ■ ■ ■ ■ O O D 0 ■ ■ ■ ■ f Z {
/ 0 O A 0 0 ■ ■ ■ ❑ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 z z }
P.

Permit:W00021632 Owner-Facility:City of Burlington
Inspection Date: 02/11/2009 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Geometric mean of 7 samples per monitoring period for class B<2.0`10E6 CFU/dry gram 0
b. pH records for alkaline stabilization(Class A) ❑ ❑ ■ ❑
c. pH records for alkaline stabilization(Class B) 0 0 ■ 0
Temperature corrected ❑
d. Salmonella(Class A, all test must be<3MPN/4 gram day) ❑ ❑ ❑ ❑
e. Time/Temp on: ■ ❑ ❑ ❑
Digester(MCRT) 0
Compost ■
Class A lime stabilization 0
f. Volatile Solids Calculations 0 0 • 0
g. Bench-top Aerobic/Anaerobic digestion results 0 0 ■ ❑
Comment:
Treatment Yes No NA NE ,
Check all that apply
Aerobic Digestion - 0
Anaerobic Digestion 0
Alkaline Pasteurization(Class A) 0
Alkaline Stabilization(Class B) ❑
Compost ■
Drying Beds ❑
Other ❑
Comment:
Page: 4

ler
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 9,2009
Mr. Stephen Russell Shoaf
City of Burlington
PO Box 1358
Burlington,NC 27216
SUBJECT: February 11,2009 Compliance Evaluation Inspection
City of Burlington
Class A Residuals Compost Management Program
City of Burlington CompoGro
Composting Facility and Distribution Program
Permit No: WQ0021632
Alamance County
Dear Mr. Shoaf:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on February 11,
2009. The Compliance Evaluation Inspection was conducted by Derek Denard of the Winston-Salem Regional Office.
Present for the inspection was Shane Fletcher(ORC)with the City of Burlington.The facility was found to be in
Compliance with permit WQ0000520.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any
questions, please call Derek Denard at 336-771-5286.
Sincerely,
)1Y' .��
Sherri V. Knight,P.E.
Regional Supervisor, Aquifer Protection Section
cc: Shane Fletcher, ORC
Alamance County Health Department
APS Central Files
APS WSRO Files
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 www.ncwaterquality.org ��turall�
An Equal Opportunity 1 Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0021632 Effective: 01/14/09 Expiration: 12/31/13 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
Facility a Distribution Program
County: Alamance 2471 Boy nd Wood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Stephen Russell Shoaf Title: Phone:[phone]
Directions to Facility:
TTake NC Hw.87 South off of 1-85(Exit 147). Proceed on NC Hwy. 87 South,and bear left onto Swepsonville Road.At Boywood Road,
S ar right.The entr in sto the WWTP is 0.25 miles on the right
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 02/11/2009 Entry Time: 03:40 PM Exit Time: 04:00 PM
Primary Inspector: Derek Denard Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type:Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: ■Compliant 0 Not Compliant
Question Areas:
Miscellaneous Questions II Record Keeping II Treatment ■Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit:WQ0021632 Owner-Facility:City of Burlington
Inspection Date:02/11/2009 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Inspection Summary:
Page: 2

Permit:WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 02/11/2009 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Type Yes No NA NE
Land Application ❑
Distribution and Marketing •
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? ❑ ❑ • 0
Are GW samples from all MWs sampled for all required parameters? 0 0 ■ 0
Are there any GW quality violations? 0 0 • 0
Is GW-59A certification form completed for facility? 0 0 • 0
Is a copy of current permit on-site? U ❑ ❑ ❑
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)? 0 0 • 0
Are PAN balances being maintained? ❑ ❑ 110
Are PAN balances within permit limits? - 0 0 • 0
Has land application equipment been calibrated? 0 0 • 0
Are there pH records for alkaline stabilization? 00 . 0
Are there pH records for the land application site? 0 0 • 0
Are nutrient/crop removal practices in place? ❑ ❑ II 0
Do lab sheets support data reported on Residual Analysis Summary? 0 0 0 •
Are hauling records available? ❑ ❑ ❑ U
Are hauling records maintained and up-to-date? 0 0 0 •
#Has permittee been free of public complaints in last 12 months? ■ ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? 0 0 • 0
Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E(Class A or B) 0 0 ■ 0
Class A, all test must be<1000 MPN/dry gram 0
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) 0 0 ■ 0
Page: 3

Permit:WQ0021632 Owner-Facility:City of Burlington
Inspection Date:02/11/2009 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram 0
b. pH records for alkaline stabilization(Class A) 0 0 ■ 0
c. pH records for alkaline stabilization(Class B) 0 0 ■ 0
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 0 0 ■ 0
g. Bench-top Aerobic/Anaerobic digestion results 0 0 ■ ❑
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion - 0
Anaerobic Digestion 0
Alkaline Pasteurization(Class A) 0
Alkaline Stabilization(Class B) 0
Compost ■
Drying Beds 0
Other ❑
Comment:
•
Page: 4

CITY OF Burlington J�ti„G.,•N ;
Telephone[phone] Fax[phone] = '����,40
P.O.Box 1358 �.J.Ate
Burlington,North Carolina 27216-1358 �'Ea 14.1g9-
STEPHEN R.SHOAF
Director of Utilities
Aril 21,2008 RECEIVED
N.C.Dept of ENR
Sherri V. Knight,P.E. APR 2 3 2008
Regional Aquifer Protection Supervisor Winston-Salem
Regional Office
NCDENR/DWQ/Aquifer Protection Section
Winston Salem Regional Office
585 Waughtown Street
Winston-Salem,NC 27107
RE: Notice of Violation
Annual Report Review
City of Burlington CompoGro Composting Facility and Distribution Program
Permit No. WQ 0021632
Alamance County
Dear Ms. Knight:
David Church retired from the City of Burlington on March 31,2008. His replacement is
Mr. Shane Fletcher. Shane holds a Grade IV Wastewater Treatment Plant Operator
Certificate(No. 988571),and a Land Application Certificate(No. 988745). Shane will
assume the duties as ORC of our land application and composting operations. His title is
Residuals Management Coordinator. I will send you an ORC designation form as soon
as I get the signatures.
We acknowledged the error in TCLP reporting. We contacted NCDENR by phone when
the discovery was made(during preparation of the annual reports). We had requested a
full TCLP on the chain of custody to the commercial lab,and when the data arrived,we
filed the lab reports(4 copies)without realizing the omission of the parameters noted in
your letter. As soon as the omission of data was verified,we pointed out the error to the
commercial lab,resampled the residuals sources,and had these new samples analyzed.
We have no explanation for the laboratory error. Unfortunately,the new samples were
collected after the 2007 reporting period. Samples collected prior to and after 2007
indicate no numerical violations.
The City of Burlington plans two measures to prevent a re-occurrence of this error. We
will sample our residuals far enough in advance of the end of the year so that a resample
is possible if there is an error in the shipping,lab analysis,or reporting. Also,we will
review the data at the first monthly program meeting following receipt of the data to
make sure that all parameters are included.

Thank you for catching our error related to the calculation of Plant Available Nitrogen
(PAN). Apparently, David Church entered an incorrect formula onto the excel
worksheet. He did not put a pair of parenthesis(s) in the formula and that changed the
results of the formula. Fortunately,this mistake did not result in an over-application or
other harmful consequences, but the mistake did need to be corrected. We have enclosed
a corrected worksheet based on the correct formula. We will double-check the formulas
in the excel worksheets to make sure there are not other errors.
If you have further comments or observations,please let me know. We look forward to
another successful year with your collaboration.
Sincerely,
Stephen Shoaf
City of Burlington
Director of Utilities
Cc: Alamance County Health Department
Ed Hardee, Land Application Unit
Central Files

City of Burlington CompoGro Composting Facility
PAN Calculation Worksheet
Permit# WQ0021632 Phone: [phone]
Reporting Period: 2007 County:Alamance
Date of Analysis 1/29/2007 3/13/2007 4/10/2007 6/8/2007
TKN 26,100 33,600 24,900 35,300
Ammonia-Nitrogen 3,000 3,500 5,000 6,800
Nitrate and Nitrite 487 255 282 11
PAN* 4,297 5,015 4,772 6,261
Date of Analysis 8/6/2007 10/1/07 12/1 9/2007
TKN 30,500 27,700 21,300
Ammonia-Nitrogen 5,900 4,400 5,400
Nitrate and Nitrite 25 5 4
PAN* 5,435 4,535 4,294
All units are expressed as mg/cg unless indicated otherwise
PAN is a calculated value obtained by using the formula:PAN=[(MR)(TKN-NH3))+(0.5(NH3))+(NO3-NO2-N)
a mineralization rate(MR)of 0.1 was used to make these calculations
The information used to calculate the PAN values were obtained from laboratory analysis.
A&L Laboratories(NC certification#257)provided the TKN,Ammonia and Nitrate/Nitrite values for the seven analysis
conducted during 2007.
File:Compost_Annual PVRF 2007.xls
Tab:PAN

W A Michael F.Easley,GovernorW
0' TF9 William G.Ross Jr.,Secretary
0� QG North Carolina Department of Environment and Natural Resources
Coleen H.Sullins,Director
> Division of Water Quality
o
March 26,2008
CERTIFIED MAIL#7003 3110 0003 7134 0432
RETURN RECEIPT REQUESTED
Mr.David Church
City of Burlington
PO Box 1358
Burlington,NC 27216
Subject: NOTICE OF VIOLATION
Annual Report Review
City of Burlington CompoGro Composting Facility and Distribution Program
Permit No: WQ0021632
Alamance County
Dear Mr. Church:
The annual report for the City of Burlington CompoGro Composting Facility and Distribution Program for
the year 2007 was received by this office on February 26, 2008. Review of the annual report found the
facility to be in violation of permit WQ0021632 for the following:
• The Toxicity Characteristics Leaching Procedure (TCLP) taken for all three sources (East
Burlington WWTP, South Burlington WWTP,and Mackintosh WTP)listed in Permit Condition III.
4. did not include the following parameters: Pesticides: Chlordane, Endrin, Lindane, Heptachlor
(and its hydroxide), Methoxychlor and Toxaphene. Herbicides: 2,4,5-TP(Silvex) and 2,4-D. The
corrosivity,ignitability,and reactivity analysis were also omitted.
It was noted that a full TCLP was taken on January 28, 2008 after the omission was discovered. Review of
this data indicated compliance with the regulatory levels noted in Permit Condition III. 5.
Another issue noted in the review of the annual report was that the calculations for Plant Available Nitrogen
(PAN)did not match our calculations based on the data provided. The equation we used was the following:
PAN= [(MR)x(TKN—NH3)] + [0.5 x(NH3)] + (NO3-NO2-N). (Please see the attached pages from the
Land Application of Residuals Operators Manual April 2005 p. 6-6 and 6-7). It appears that the formula
used in the annual report multiplies 0.5 with NO3-NO2-N, which may explain the results. Attached please
fmd an example copy of a spreadsheet used to check the calculation for data taken on 12/19/07. In addition,
please fmd a copy of the PAN Calculation Worksheet from the 2007 annual report with our results written
below the reported PAN value. If your calculations are in error, please recalculate PAN and resubmit the
worksheet in your response to this letter.
1D
Carolina
,Naturally
Division of Water Quality/Aquifer Protection Section Customer Service
585 Waughtown Street,Winston-Salem NC 27107 1-877-623-6748
Phone: [phone] Fax: [phone] Internet: http://www.ncwwaterqualitv.org
An Equal Opportunity/Affirmative Action Employer—50%Recycledll0%Post Consumer Paper

Mr. Church
March 26,2008
Page 2 of 2
To prevent further action, carefully review these violations and deficiencies and respond in writing to this
office within thirty (30) working days of receipt of this letter. You should address the causes of
noncompliance and all actions taken to prevent the recurrence of similar situations. If you should have any
questions,please do not hesitate to contact Derek Denard or me at 336-771-5286.
Sincerely,
Atfi-
Sherri V.Knight,P. .
Regional Aquifer Protection Supervisor
cc: Alamance County Health Department
Ed Hardee,Land Application Unit
APS Central Files

Compliance Inspection Report
Permit: WQ0021632 Effective: 09/26/03 Expiration: 08/31/08 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
Facility and Distribution Program
County: Alamance 2471 Boy Wood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Harold T. Owen Title: City Manager Phone: [phone]
Directions to Facility:
T
rilgih Take NCttHw.87 South off of 1-85(Exit 147). Proceed on NC Hwy.87 South, and bear left onto Swepsonville Road.At Boywood Road,
bear t.The gicaanc to the WWTP is 0.25 miles on the right
Primary ORC: Certification: Phone:
Secondary ORC(s):
David Church Certification: 13188 Phone: [phone]
On-Site Representative(s):
Related Permits:
Inspection Date: 03/20/2008 Entry Time: 09:00 AM Exit Time: 06:00 PM
Primary Inspector: Derek Denard Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type:Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: 0 Compliant • Not Compliant
Question Areas:
MI Miscellaneous Questions Record Keeping ■Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit:W00021632 Owner-Facility:City of Burlington
Inspection Date: 03/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Follow-up
Inspection Summary:
ANNUAL REPORT REVIEW
Reporting Period: 2007
Permit Details:
• Land Application or Distribution? Distribution
• Is 503?503
ClassAorB?A
• Maximum Dry Tons Per Year: 2,250
Number of acres permitted: N/A
• Counties that land is permitted for: N/A
• Monitoring Frequency for TCLP:Annually
Monitoring Frequency for Residuals Analysis: 540.6 (319<=DT/yr<1,650)gives Once per Quarter
• Monitoring Frequency for Pathogen &Vector Attraction Reduction: Once.per Quarter
Annual Report Review Class A Distribution
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted?YES
• Was distribution conducted during the reported period?YES
• How many dry tons were distributed? 540.6
• Were the distributions with the permitted amount?YES
Were recipients information listed?YES
• Did it indicate compliance? NO, Incomplete TCLP
• Was form complete?YES
• Was it signed by the appropriate people?YES
2. Monitoring
• Were the analyses conducted at the required frequency?YES
• Were the metals analyses reported on the Residual Sampling Summary Form?YES
• Were the results reported in mg/kg?YES
• Were the metals within ceiling concentration permit limits?YES
Were the metals within monthly average concentration permit limits?YES
• If no, were the lab analyses attached?YES
• Were all the required parameters tested?YES (Residuals Analysis), NO (TCLP)
• Was TCLP analysis conducted? Partial TCLP with no Herbicides, Pesticides, Corrosivity, Reactivity, or Ignitability. TCLP
resampled on 1/28/08.
• Were the TLCP contaminants with regulatory limits?YES
Comments: PAN calculations did not match our results.
Page: 2

•
Permit:W00021632 Owner-Facility: City of Burlington
Inspection Date: 03/20/2008 Inspection Type:Compliance Evaluation Reason for Visit: Follow-up
3. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?YES
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction alternative and the vector
attraction reduction option used? YES, Class A: Alternate 5, Option 5
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the report? YES
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?YES
4.General
• Was the report in the proper format?YES
• Were any parts of the annual report missing?YES
• Was the report submitted on time? YES, Received on February 20, 2008
Class A Pathogen Review
To be Class A, residuals shall meet either fecal Coliform density of salmonella density.
Fecal Coliform density
• Was the sampling conducted at the required frequency?YES
• Were multiple samples taken? 21
• Was each sample less than 1000 MPN/gram of total solids?YES
OR
Salmonella density
• Was the sampling conducted at the required frequency? N/A
• Were multiple samples taken? N/A •
• Was each sample less than 3 MPN/4 grams of total solids? N/A
To be Class A, residuals shall meet one of the following alternatives:
Alternative 5—Process To Further Reduce Pathogens
PFRP Composting
• Were the within-vessel method or static aerated pile methods used?YES
• Was the residuals temperature maintained at 55°C (131°C) or higher for three consecutive days or longer in the
within-vessel method or static aerated pile method?YES
OR
• Was the windrow composting method used? N/A
• Was the residuals temperature maintained at 55°C or higher or 15 consecutive days or longer in the windrow method,
and the windrow turned a minimum of five times during this time? N/A
Page: 3

Permit:WO0021632 Owner-Facility: City of Burlington
Inspection Date: 03/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Follow-up
Type Yes No NA NE
Land Application ❑
Distribution and Marketing ■
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? 0 0 • 0
Are GW samples from all MWs sampled for all required parameters? ❑ ❑ ■ ❑
Are there any GW quality violations? 0 0 ■ ❑
Is GW-59A certification form completed for facility? 0 0 ■ 0
•
Is a copy of current permit on-site? 0 0 0 ■
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)? 0 0 • 0
Are PAN balances being maintained? 11000
Are PAN balances within permit limits? ■ ❑ ❑ ❑
Has land application equipment been calibrated? 0 0 • 0
Are there pH records for alkaline stabilization? 0 0 ■ 0
Are there pH records for the land application site? 0 0 ■ 0
Are nutrient/crop removal practices in place? 0 0 ■ 0
Do lab sheets support data reported on Residual Analysis Summary? U ❑ ❑ ❑
Are hauling records available? ■ ❑ ❑ ❑
Are hauling records maintained and up-to-date? ■ ❑ ❑ ❑
#Has permittee been free of public complaints in last 12 months? ■ ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? ■ ❑ ❑ ❑
Comment:
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 0
Fecal coliform SM 9222 D(Class B only) 0 0 ■ 0
Page: 4

Permit: WO0021632 Owner-Facility: City of Burlington
Inspection Date: 03/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Follow-up
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) 0 0 • 0
c. pH records for alkaline stabilization(Class B) 0 0 • 0
Temperature corrected 0
d. Salmonella(Class A, all test must be<3MPN/4 gram day) 0 0 •
e. Time/Temp on: U 0 ❑
Digester(MCRT) 0
Compost •
Class A lime stabilization 0
f. Volatile Solids Calculations 0 0 • 0
g. Bench-top Aerobic/Anaerobic digestion results 001110
Comment:
Page: 5

STEP ONE: Determine the amount of Plant Available Nitrogen (PAN) in
the residuals to be applied.
• First, calculate PAN in residuals using one of the following formulas:
1) PAN for surface application
PAN = [(MR) x (TKN -NH3)] + [.5 x (NH3)] + (NO3-NO2-N)
2) PAN for Subsurface application
PAN = [(MR)x (TKN - NH3)] + (NH3) + (NO3-NO2-N)
Factors and units for the equations are as follows:
PAN =Plant Available Nitrogen in ppm (or mg/kg)
TKN=Total Kjeldahl Nitrogen in ppm (or mg/kg)
NH3 = Ammonia Nitrogen in ppm (or mg/kg)
NO3-NO2-N = Nitrate and Nitrite Nitrogen in ppm (or mg/kg)
MR =mineralization rates (based on type of stabilization technology used at the
wastewater treatment plant that produced the residuals) for the first year's PAN:
Composted = 0.1
Anaerobically Digested =0.2
Aerobically Digested =0.3
Unstabilized Primary and Waste Activated= 0.4 .
Example:
According to the laboratory report, the residuals you plan to land apply contain
following concentrations of TKN, NH3, and NO3-NO2-N:
TKN 52,100 mg/kg
NH3 1,552 mg/kg
NO3-NO2-N 525 mg/kg
Your planned application method is surface application and the residuals were
anaerobically digested. Calculate the pounds of plant available nitrogen (PAN)
per dry ton of residuals.
6-6

Solution:
PAN = [(MR) x (TKN - NH3)] + [.5 x (NH3)] + (NO3-NO2-N)
PAN = [(0.2) x (52,100 - 1,552)] + [.5 x (1,552)] + (525)
PAN = (0.2 x 50,548) + 776 + 525
PAN = 10110 + 776 + 525
PAN = 11,411 mg/kg dry residuals
• Next, convert mg/kg to lbs/dry ton using the following formula:
•
mg/kg x .002 = lbs/dry ton (.002 is from 2000 lbs/ton)
PAN (lbs/dry ton residuals) = 11,411 mg/kg x .002
PAN = 22.82 lbs/dry ton residuals
Thus, there are 22.82 pounds of plant available nitrogen in each dry ton of residuals to be
applied. This figure includes the amount of organic N that will become plant available
during the first year of residuals application.
STEP TWO: Determine the "nitrogen needs" of the crop to be grown.
The following list shows examples of maximum crop utilization rates:
Crop PAN (lb/acre/yr)
Alfalfa 200
Bermuda Grass (Hay, Pasture) 220
Blue Grass 120
Corn (Grain) 160
Corn (Silage) 200
Cotton 70
Fescue 250
Forest (Hardwood and Softwood) 75
Milo 100
Small Grain (Wheat, barley, oats) 100
Sorghum, Sudex (Pasture) 180
Sorghum, Sudex (Silage) 220
Soybeans 200
Timothy, Orchard & Rye Grass 200
STEP THREE: Determine nitrogen "carry-over" for a three-year period.
Remember that, in addition to containing plant available nitrogen or PAN, residuals also
contain organic nitrogen that is not readily available to crops. As organic nitrogen is
mineralized (broken down by microorganisms), more and more nitrogen becomes plant
6-7

PAN
Mineralization as decimal Total dry Acres
Rate TKN NH3 NO3 NO2 % Solids tons/year Applied on
0.1 21300 5400 4
PAN Surface MR(TKN-NH3)+ + .5(NH3)+NO3+NO2 =mg/kg
4294 mg/kg 8.588 lbs/dry ton
0 lbs total PAN mg/kg x .002 =Ibs/dry ton
#DIV/0! lbs PAN/acre
PAN Injection MR(TKN-NH3) + 1(NH3)+NO3+NO2 =mg/kg
6994 mg/kg 13.988 lbs/dry ton
0 lbs total PAN mg/kg x .002 =Ibs/dry ton
#DIV/O! lbs PAN/acre
Dry Tons/1000 gal. 1000 X 8.34 X%solids X sp. gravity "=dry tons/1000gal."
0 2000
1st year PAN lbs./acre
Surface lbs. Surface
0 #DIV/0!
1st year PAN lbs./acre
Injected lbs. Injected
0 #DIV/0!

•
City of Burlington CompoGro Composting Facility
PAN Calculation Worksheet
Permit# W00021632 Phone: [phone]
Reporting Period:2007 County: Alamance
Date of Analysis 1/29/2007 3/13/2007 4/10/2007 6/8/2007
TKN 26,100 33,600 24,900 35,300
Ammonia-Nitrogen 3,000 3,500 5,000 6,800
Nitrate and Nitrite 487 255 282 11
PAN* 4,305 5,212 5,103 6,934
Li ? So/ / 77 25o1
Date of Analysis 8/6/2007 10/1/07 12/19/2007
TKN 30,500 27,700 21,300
Ammonia-Nitrogen 5,900 4,400 5,400
Nitrate and Nitrite 25 5 4
PAN* 6,010 4,972 4,832 -
SW 3s 35-) 4 Zf;y
All units are expressed as mg/kg unless indicated otherwise
*PAN is a calculated value obtained by using the formula: PAN=MR(TKN-NH3)+0.5(NH3+NOTN03-N)
a mineralization rate(MR)of 0.1 was used to make these calculations
The information used to calculate the PAN values were obtained from laboratory analysis.
A&L Laboratories(NC certification#257)provided the TKN,Ammonia and Nitrate/Nitrite values for the seven analysis
conducted during 2007.
File:Compost Annual PVRF 2007.xts
Tab:PAN

TRECEIVED
N.C.Dept.of ENR
AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM MAR 1 4 2008
Winston-Salem
Regional Office
Date: March 12, 2008
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: Alice Wessner, Land Application Unit
Telephone: [phone] Fax: [phone]
E-Mail: [e-mail]
A. Permit Number: WQ0021632
B. Owner: City of Burlington
C. Facility/Operation: City of Burlington Compogro Composting Facility and Distribution Program
❑ Proposed ❑ Existing ❑ Facility ❑ Operation
D. Application:
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation(ND)
❑ Inc - (5QW)closed loop water only geothermal
For Residuals: ® Land App. ❑ D&M ❑ Surface Disposal
® 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ❑ New ❑ Major Mod. ❑ Minor Mod. ® Renewal ❑ Renewal w/Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
•
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,please take the following actions:
® Return a Completed Form APSARR.
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO*.
* Remember that you will be responsible for coordinating site visits, 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 additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office-Aquifer Protection Section contact person
listed above.
RO-APS Reviewer: � CDOA,,�� Date: 3A LI C�
FORM: APSARR 02/06 Page 1 of 1

10 WA1 Michael F.Easley,Governor
CO.
William G.Ross Jr.,Secretary
rNorth Carolina Department of Environment and Natural Resources
0 - Coleen H.Sullins Director
Division of Water Quality
March 6, 2008 I RECEIVED
N.C.Dept.of ENR
HAROLD OWEN MAR 1 4 2008
CITY OF BURLINGTON
PO BOX 1358 Winston-Salem
Regional Office
BURLINGTON,NC 27216-1358
Subject: Acknowledgement of Application No. WQ0021632
City of Burlington CompoGro Composting
Distribution of Residual Solids (503)
Alamance County
Dear MR. OWEN:
The Aquifer Protection Section of the Division of Water Quality(the Division)acknowledges receipt of
your permit application and supporting materials on February 28, 2008. This application package has
been assigned the number listed above and will be reviewed by Alice Wessner.
The reviewer will perform a detailed review and contact you with a request for additional information if
necessary. To ensure the maximum efficiency in processing permit applications,the Division requests
your assistance in providing a timely and complete response to any additional information requests.
Please be aware that the Division's Regional Office,copied below, must provide recommendations prior
to final action by the Division. Please also note at this time,processing permit applications can take as
long as 60-90 days after receipt of a complete application. To check on the status of your application,
you can visit http://h2o.enr.state.nc.us/bims/reports/reportsPermits.html.
If you have any questions,please contact Alice Wessner by phone at(919) 715-5208 or by email at
[e-mail]. If the reviewer is unavailable,you may leave a message and they will respond
promptly. Also note that the Division has reorganized. To review our new organizational chart, go to
http://h2o.enr.state.nc.us/documents/dwq orgchart.pdf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES
ON THIS PROJECT.
Sincerely,
For Kim H. Colson, P.E.
• Supervisor
APS Central Files-Application No.WQ002163
Stephen Shoaf,PO Box 1358,Burlington,NC 27215
No Carolina
7'atura!!y
Aquifer Protection Section 1636 Mail Service Center Raleigh,NC 27699-1636 Telephone: [phone]
Internet:www.ncwaterquality.org Location: 2728 Capital Boulevard Raleigh,NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper Customer Service: [phone]

•
March 6, 2008
Harold Owen
PO Box 1358
Burlington,NC 27216-1358
Subject: Return of Fee, Application No. WQ0021632
City of Burlington CompoGro Composting Facility
Distribution of Residual Solids (503)
Alamance County
Dear Mr. Owen:
Please find enclosed your check submitted with the above referenced permit application
The Division has since received a check for the appropriate amount and returning your
original fee.
If you have any question regarding this letter, please feel free to contact the Aquifer
Protection Section at 919-733-3221.
PLEASE REFER TO THE PROJECT NAME AND DATE SUBMITTED WHEN
INQUIRING ON ANY MATTERS IN QUESTION.
Sincerely,
for Kim H. Colson,P.E.
Supervisor
cc: 'Alston stem Regional Office, Aquifer Protection Section
APS Central Files—Application No. WQ0021632
Stephen Shoaf, PO Box 1358, Burlington, NC 27215

CITY OF Burlington o4vNirr
,�G�, •Ty
Telephone[phone] Fax[phone] `` -
P.O.Box 1358 0 tIla`
Burlington,North Carolina 27216-1358 �E$14.1g9'
STEPHEN R SHOAF
Director of Utilities
February 28, 2008
NC DENR/Division of Water Quality
Non-Discharge Permit Section/Land Application Unit
1636 Mail Service Center
Raleigh,NC 27699-1636
RE: Permit Renewal Application Form DRS 070807 and Form RSCA 070807
City of Burlington,Alamance County
Permit No. WQ 0021632
The City of Burlington is submitting a permit renewal application for the
distribution of residual solids generated from our COMPOGRO compost facility. This
facility is located at the South Burlington Wastewater Treatment Plant and that treatment
facility is the source of the residuals that are composted. The compost is sold for
landscaping and other general uses. A check for$810.00 is included for the processing
fee.
This application package includes the form DRS 070807(1 original and 2 copies);
a copy of existing permit WQ0021632; and several pages of explanations for questions
on the form including a process diagram and an example of our information sheet. In
addition,the package includes form RSCA 070807; site maps;process flow diagrams;
summaries of analytical results; copies of commercial lab reports for TCLPs for the
South Burlington WWTP land application solids and the finished compost product;
copies of lab analysis for the pathogen reduction verification; and copies of the
commercial lab reports for nutrients and metals content of the fmished compost. Also
included is a copy of the 2007 annual report for the COMPOGRO compost operation
which was submitted to the State earlier.
We hope that we have supplied enough information for you to effectively evaluate
the permit renewal request. If you need additional information,please contact me and we
will be glad to provide the information that you need.
;,1 Sincerely,
FEB 2 8 ZO C8 Y..:4
Stephen Shoaf

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
DISTRIBUTION OF RESIDUAL SOLIDS
(FORM: DRS 070807)
(THIS FORM MAYBE PHOTOCOPIED FOR USE AS AN ORIGINAL)
Application Number: (to be completed by DWQ)
E. OWNERSHIP INFORMATION:
1. Specify whether the process facility is owned by:
❑ County; ❑ Federal; IN Municipal; ❑ State; ❑ Non-Government.
2. Owner's name(please specify the name of the municipality,corporation,individual,etc.):
City of Burlington, NC
Mailing address: PO Box 1358
City: Burlington State: NC Zip: 27216-1358
Physical address: 425 S. Lexington Ave.
City: Burlington State: NC Zip: 27215
Telephone number: ( 336 ) 222-5022 Facsimile number: ( 336 ) 513-5452
E-mail address: [e-mail]
3. Signing official's name and title: (See Instruction A)
Harold Owen, City Manager
PO
Mailing address: Box 1358
City: Burlington State: NC Zip: 27216-1358
Physical address: 425 S. Lexington Ave.
City: Burlington State: NC _Zip: 27215
Telephone number: ( 336 ) 222-5022 Facsimile number:( 336 ) 513-5452
E-mail address: [e-mail]
PERMIT INFORMATION:
1. Application is for: ❑ new; ❑ modified; ti renewed permit(check all that apply).
2. Fee Submitted: $ 810.00 (See Instruction B)
3. If this application is being submitted to renew or modify an existing permit,provide the following:
FORM: DRS 070807 Page 3 of 6 Attachment Order 1

Permit number: WQ 0021632 (please attach a copy of the existing permit).
Most recent issuance date: September 26, 2003 ,and the expiration date: August 31, 2008
III. FACILITY INFORMATION:
1. Name of facility where residuals are processed:
South Burlington Wastewater Treatment Plant/Compogro Composting Facility
Physical address: 2471 Boywood Rd.
City: Graham State: NC Zip: 27253
Telephone number: ( 336 ) 570-6138 Facsimile number: ( 336 ) 570-6139
County where facility is located: Alamance
Latitude: 36° 01' 23" N Longitude: 79° 22 16" W of residual process facility.
2. Facility contact(person familiar with residuals preparation):
Stephen Shoaf
Mailing address: PO Box 1358
City: Burlington State: NC Zip: 27216-1358
Physical address: 1302 Belmont St.
City: Burlington State: NC Zip: 27215
Telephone number: ( 336 ) 222-5133 Facsimile number: ( 336 ) 570-6175
E-mail address: [e-mail]
3. Program contact person and/or consulting firm who prepared application(If different from the above):
Same as above
Mailing address:
City: State: Zip:
Physical address:
City: State: Zip:
Telephone number: ( ) Facsimile number: ( )
E-mail address:
4. Is the residual process facility also the generator? Et Yes; ❑ No
5. If the residual process facility is not the same as the generator,please specify delivery frequency and quantity of residual to
be processed:
6. Length of residuals storage at facility: 50 Minimum days (the Division requires a minimum 30 days storage in units
that are separate from treatment system,i.e.not in clarifiers,aeration basins,etc.).
FORM: DRS 070807 Page 4 of 6 Attachment Order 1

IV. RESIDUALS QUALITY INFORMATION:
1. Specify if residuals are regulated under(check one): Et 40 CFR Part 503 or ❑ 40 CFR Part 257.
2. Specify how these residuals will be distributed:
❑ sold or given away in bags or other containers; Et lawn(bulk); 12 home garden(bulk); (flowers)
IA other; Institutional & business landscana:: pasture restoration
3. Complete the following if residuals are to be mixed with other materials:
Amounts to be added
Type of Materials per 1.0 dry ton of residuals(dry ton)
leaves from street collection 1
woodchips 3
2,250 permitted
4. Approximate amounts of the fmal product to be distributed 550 actual dry tons per year.
5. Provide a description of the onsite storage management plan for the treated residuals (including estimated average and
maximum storage times prior to distribution): (See explanation attached)
V. ADDITIONAL REQUIRED INFORMATION:
1. Provide a narrative explaining the following:
a. How will the materials be handled and transported from where the residuals were produced to where it will be
treated?
b. How will the residuals be processed/treated(attach process flow diagram).
c. How will leachate collection be handled?
d. Where will the residuals be stored until processed?
e. How will the final product be distributed(packaging)?
2. Attach a marketability statement detailing destinations and approximate amounts of the final product to be distributed.
3. 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
information:
a. The name and address of the person who prepared the residual that is sold or given away in a bag or other container for
application to the land.
b. A statement that application of the residual to the land is prohibited except in accordance with the instructions on the
label or information sheet.
c. A statement that the residuals shall not be applied to any site that is flooded,frozen or snow-covered.
d. A statement that adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored
residuals into any surface waters.
e. Information on all applicable setbacks in accordance with 15A NCAC 02T.1108(b).
FORM: DRS 070807 Page 5 of 6 Attachment Order 1

Professional Engineer's Certification: (Application Packages Involving New or Changes to Treatment and Storage Units)
I, ,attest that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I 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 2T.0105.
®Yes ❑ No,Explain;
Harold Owen, City Manager ,attest that this application for City of Burlington
Compogro Compost Facility Distribution of Residual Solids Permit
has been reviewed me and is accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are n c mpleted and equired supporting information and attachments are not included,this application package
will be retume o ete.
Signature Ar P Date 2 6 O
THE COMPLETED APPLICATION PACKAGE,
INCLUDING ALL SUPPORTING INFORMATION AND MATERIALS,
SHOULD 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: By Courier/Special Delivery:
1636 MAIL SERVICE CENTER 2728 CAPITAL BOULEVARD
RALEIGH,NORTH CAROLINA 27699-1636 RALEIGH,NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone]
FORM: DRS 070807 Page 7 of 6 Attachment Order 1

pF W A TF9 Michael F. Easley,Governor
\O� QG William G. Ross Jr.,Secretary
63 rC E8P4' North Carolina Department of Environment and Natural Resources
,� COAlan W.Klimek,P.E.,Director
` Coleen H.Sullins,Deputy Director
Division of Water Quality
September 26, 2003
MR. HAROLD OWEN, CITY MANAGER
CITY OF BURLINGTON
POST OFFICE Box 1358
BURLINGTON, NORTH CAROLINA 27216-1358
Subject: Permit No. WQ0021632
City of Burlington
City of Burlington CompoGro Composting Facil.
and Distribution Program
Distribution of Residual Solids (503)
Alamance County
Dear Mr. Owen:
In accordance with the permit application package received on May 21, 2002 as well as the
additional information received on July 26, 2002 and September 18, 2003, we are forwarding herewith
Permit No. WQ0021632, dated September 26, 2003, to the City of Burlington for the subject residuals
composting facility and Class A EQ residuals product distribution program.
This permit shall be effective from the date of issuance until August 31, 2008 and shall be subject
to the conditions and limitations as specified therein. Make note of this permit's expiration date and the
fact that a permit renewal application is due to the Division of Water Quality (Division) no later than six
months prior to that date (i.e., see Condition VI. 8.), as the Division does not send reminders to apply for
permit renewal.
This permit has been issued to approve the construction and operation of the City of Burlington's
residuals composting facility and the operation of a Class A EQ residuals product distribution program for
a five-year cycle.
Please remember to take the time to review this permit thoroughly. Pay particular attention
to the monitoring requirements in this permit. Please be aware that failure to establish an adequate system
for collecting, maintaining, and submitting the required operational information will result in future
compliance problems. Of special interest to you may be the following:
• Because data regarding the pathogen reduction and vector attraction reduction requirements
were not presented in the permit application package, Condition I. 3. requires that the data be
submitted to the Division for review and approval to ensure that the residuals composting
facility is capable of meeting the 40 CFR Part 503 regulations in this regard.
• A draft information sheet was included in the permit application package; however,
Condition I. 4. requires that a final version of this information sheet be submitted to the
Division for review and approval. Note that the list in Condition II. 8. are considered to be
minimum items to be included on the sheet. The City of Burlington is free to expand the
information that is provided on this sheet to be specific to the markets that it is developing.
Be aware that, even though the City of Burlington does lose control of the Class A EQ
residuals product following its distribution to the initial recipient, misuse of the product by
that recipient may reflect negatively on the concept of Class A EQ residuals product use in
the public's eyes.
Non-Discharge Permitting Unit Internet http://h2o.enr.state.nc.us/ndpu �i
1617 Mail Service Center, Raleigh,NC 27699-1617 Telephone [phone] Fax [phone]
DENR Customer Service Center Telephone [phone]
An Equal Opportunity Action Employer 50%recycled/10%post-consumer paper

• Condition I. 5. requires that a sampling/rno p , fd}e:residuals composting facility
be developed and submitted to the Division i i fys. The Division suggests
that the City of Burlington develop a monitoring program to ensure that the Class A EQ
residuals product does not exhibit signs of pathogen regrowth following significant
curing/storage time and immediately prior to distribution for application to the land.Be aware
that EPA's existing guidance states that every particle of the residuals must be subjected to
the required temperature for the required time as stipulated in the composting PFRP (i.e.,
Process to Further Reduce Pathogens).
• During the site visit to the residuals composting facility on August 28, 2002,the open area for
final curing and maturation of the composted residuals/amendment cake and for storing of the
Class A EQ residuals product appeared to be graded such that stormwater had the potential to
wash material off of the asphalt pad and into a drainageway. Condition I. 5. requires that the
pad be retrofitted (e.g., provided with curbing, etc.) to ensure that Condition II. 5. and
Condition II. 6. related to prohibiting movement of residuals, amendment material, and/or
Class A EQ residuals product from moving off-site within 180 calendar days.
If any parts, requirements, and/or limitations contained in this permit are unacceptable, you have
the right to request an adjudicatory hearing upon written request within 30 days following receipt of this
permit. This request shall be in the from 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, North Carolina 27699-6714. Unless such demands are made, this permit shall be fmal
and binding.
One copy of the approved plans and specifications is being forwarded to you. If you need any
additional information concerning this matter, please contact Ms. Shannon Mohr Thornburg by telephone
at(919)733-5083,extension 353,or via e-mail at shannon.thornburg@ncmai net.
Sincere , I/
e______.
[e-mail].
W. Klimek,P.E.
Enclosure
cc: Mtn=Sttli tt R.-Shoat City offkiiiitigttlii
Mr.Michael C.Wicker,P.E.,Hobbs,Upchurch&Associates, P.A.
Winston-Salem Regional Office-Water Quality Section
Winston-Salem Regional Office-Groundwater Section
Central Office-Groundwater Section
Technical Assistance and Certification Unit
Water Quality Central Files
NDPU Files
NDPU Residuals Program Coordinator
2

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF RESIDUAL SOLIDS (503)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
City of Burlington
Alanlance County
FOR THE
construction and operation of a 5.5-dry ton per day facility for the aerated static pile composting of
residuals generated from the treatment of municipal wastewater at the facilities listed in Condition II. 3.
and consisting of the following minimum components: two pump/grinder units for transferring residuals
from the.existing digesters/storage tanks (i.e., permitted for operation under NPDES Permit No.
NC0023876) to dewatering; one two-meter belt filter press, with a berth for a second two-meter belt filter
press for a parallel operation, for dewatering of the residuals; one conveyor for transferring dewatered
residuals to the amendment mixing area; one 25,500-square foot open area for storing amendment
material; one 1,875-square foot covered area for storing amendment material; on 1,710-square foot
covered area for blending of the residuals with the amendment material as well as homogenizing and
uniform mixing of the residuals/amendment cake (i.e., at a three to one amendment material to residuals
ratio); one agricultural feed mixer for blending of the residuals with the amendment material as well as
homogenizing and uniform mixing of the residuals/amendment cake (i.e., at a three to one amendment
material to residuals ratio); one 35,700-square foot covered area for composting of the
residuals/amendment cake in a maximum of 22 aerated static piles, each with a trapezoidal dimensions of
seven feet in height, 12 feet in width, and 80 feet in length; one under-bed aeration system, consisting of
11 five-horsepower blowers (i.e., one blower for every two aerated static piles) as well as a perforated
pipe distribution system that is overlain by eight to 12 inches of amendment material for aerating of the
composting residuals/amendment cake; one 153-cubic yard per/day trammel screen for screening of the
composted residuals/amendment cake and recovering bulking material; one 2,225-square foot bunker for
storing composted residuals/amendment cake; one 625-square foot bunker for storing recovered bulking
material; one 15,000-square foot open area for final curing and maturation of the composted
residuals/amendment cake and for storing of the Class A EQ residuals product; one odor control system,
consisting one 900-square foot biofilter and one 4,900-square foot biofilter, for capturing and treating
odor generating within the residuals composting facility; all necessary measuring devices to ensure that
all of the composted residuals/amendment cake meets the requirements listed in Condition I. 11.; as well
as all associated controls, support structures, piping, and appurtenances necessary for the complete
1

necessary to make a complete and functional residuals composting facility and Class A EQ residuals
product distribution program;
and the continued operation of a program for the distribution of up to 2,250 dry tons per year of a Class A
EQ residuals product marketed as CompoGro.
Both the facility and the program shall be operated such that no discharge of waste to surface
waters occurs, pursuant to the application package received on May 21, 2002 as well as the additional
information received on July 26, 2002 and September 18, 2003, and in conformity with the project plan,
specifications, and other supporting data subsequently filed and approved by the Department of
Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until August 31, 2008 and shall be subject
to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
Div 1. Within&calendar days of this permit's issuance and prior to the initial distribution of any
Class A EQ residuals product, a certification on the attached form shall be received from a
North Carolina-licensed professional engineer certifying that the residuals composting
facility has been installed in accordance with air permit, the approved plans and
specifications, and other supporting materials. Mail shall one copy of the certification to the
NCDENR-DWQ, Water Quality Section, Non-Discharge Permitting Unit, do NDPU
Residuals Program Coordinator, 1617 Mail Service Center,Raleigh,NC 27699-1617.
i2. The Water Quality Section of the Division of Water Quality's (Division) Winston-Salem
Regional Office at telephone number [phone] shall be notified at least 48 hours in
advance of the initial distribution of any Class EQ residuals product so that an in-place
inspection can be made. Such notification to the Regional Water Quality Supervisor shall be
made during normal office hours (i.e., from 8:00 a.m. until 5:00 p.m.) between Monday and
Friday,but excluding State Holidays.
J 3. With' 301 alendar days of this permit's issuance and prior to the initial distribution of any
Class A EQ residuals product, analytical results and operational data that demonstrate that
the residuals composting facility is capable of meeting the required pathogen reduction and
vector attraction reduction requirements, as is required by Condition I. 12., shall be submitted
to the Division for review and approval. Mail two copies of the results/data to the NCDENR-
DWQ,Water Quality Section,Non-Discharge Permitting Unit,do NDPU Residuals Program
Coordinator, 1617 Mail Service Center,Raleigh,NC 27699-1617.
4. Within Gcalendar days of this permit's issuance and prior to the initial distribution of any
Class A EQ residuals product, a final version of the information sheet that will be provided to
the person who receives the Class A EQ residuals product sold or given away in another
container for application to the land, as is required by Condition II. 8., shall be submitted to
the Division for review and approval. Mail two copies of the information sheet to the
NCDENR-DWQ, Water Quality Section, Non-Discharge Permitting Unit, do NDPU
Residuals Program Coordinator, 1617 Mail Service Center,Raleigh,NC 27699-1617.
2

5. Within 90 calendar days of this permit's issuance, a sampling/monitoring plan for the
residuals composting facility shall be submitted to the Division for review. The Permittee
shall ensure that the plan identifies sampling points, sampling frequency, sample type, as
well as the Division-certified laboratory to be used. In addition, the Permittee shall 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 distributed.
6. Within 180 calendar days of this permit's issuance, the open area for final curing and
maturation of the composted residuals/amendment cake and for storing of the Class A EQ
residuals product shall be retrofitted to rectify the slope of the area/pad toward its eastern
corner. The retrofit shall be sufficient to ensure that stormwater is prevented from conveying
stored Class A EQ residuals product and/or amendment from the area/pad, as is required by
Condition II. 5. and Condition II. 6.
7. The residuals composting facility and Class A EQ residuals product distribution program
shall be effectively maintained and operated as a non-discharge system to prevent the
discharge of any wastes to waters of the state resulting from the operation of this facility or
program.
•
8. This permit shall become voidable in the event of failure of the residuals composting facility
or Class A EQ residuals product distribution program to adequately protect the assigned
water quality standards of the surface waters and groundwater.
9. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface water or groundwater resulting from the operation of this residuals composting
facility or Class A EQ residuals product distribution program.
10. In the event that the residuals composting facility or Class A EQ residuals product
distribution program is not operated satisfactorily, including the creation of nuisance
conditions, the Permittee shall take any immediate corrective actions as may be required by
the Division.
11. Diversion or bypassing of untreated residuals or leachate from the residual composting
facility shall be prohibited. All leachate shall be reused as a wetting agent for the processing
of residuals or disposed of through a Division-approved method.
12. When wastewater residuals are sold or given away, one of the Class A pathogen requirements
in 40 CFR Part 503.32(a) and one of vector attraction reduction requirements in 40(2F1(Part
503.33 shall be met. Additionally, an evaluation shall be performed which demonstrates the
residuals' ability to comply with this requirement. Upon request, a copy of this evaluation,
including all test results and calculations, shall be submitted.
13. No Class A EQ residuals product that tests or is classified as a hazardous or toxic waste
under 40 CFR Part 261 shall be sold or given away under the conditions of this permit.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The residuals composting.facility and Class A EQ residuals product distribution program
shall be properly operated and maintained at all times.
3

2. Upon classification of the residuals composting facility and Class A EQ residuals product
distribution program by the Water Pollution Control System Operators Certification
Commission (WPCSOCC), the Permittee shall employ a certified operator to be in
responsible charge(ORC)of the facility and program. The operator shall hold a certificate of
the type classification assigned to the facility and program by the WPCSOCC. The Pernttee
shall also employ a certified back-up operator of the appropriate type to comply with the
conditions of 15A NCAC 8G.0202.
3. a. No residuals other than those generated by the following residuals source-generating
facilities shall be approved for acceptance for treatment in the residuals composting
facility in accordance with this permit:
Residuals Permit Maximum
Permittee Source-Generating County Number Dry Tons
Facility per Year
City of Burlington See Below Alamance See Below 1,380.00
City of Burlington East Burlington WWTP Alamance NC0023868 See Above
City of Burlington South Burlington WWTP Alamance NC0023876 See Above
TOTAL 1,380.00
b. No Class A EQ residuals product other than that generated by the following residuals
source-generating facilities shall be approved for distribution under the Class A EQ
residuals product distribution program in accordance with this permit:
Permittee/Residuals Permit Maximum
Source-Generating Product County Number Dry Tons
Facility per Year
City of Burlington
CompoGro Composting CompoGro Alamance WQ0021632 2,250
Facility
TOTAL 2,250
4. No other residuals or Class A EQ residuals product other than that from the residuals source-
generating facilities specified in Condition II. 3. may be composted and distributed under this
permit. The Permittee shall request and obtain a permit amendment from the Division for
each additional residual source-generating facility prior to acceptance of those residuals for
treatment in the approved residuals composting facility and distribution through the approved
Class A EQ residuals product distribution program.
5. All residuals and Class A EQ residuals product shall be adequately stored to prevent leachate
runoff prior to and following treatment. Following treatment, the Class A EQ residuals
product may be stored in an elevated silo, placed on a concrete pad, kept under shelter,
covered, or stored in a manner as otherwise approved by the Division until such time as it is
distributed to the user. If an alternative storage site is to be used, approval shall first be
obtained from the Division.
6. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from residuals or the Class A EQ residuals product from the residuals
composting facility onto adjacent property or into any surface waters.
4

7. For a Class A EQ residuals product to be sold or given away in bags or other container for
application to the land, the following shall be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations(Dry Weight Basis)shall be maintained:
Ceiling Concentration Monthly Average �6(
Parameter (milligrams per kilogram) 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 36'
Zinc 7,500 2,800
Chren,.'ww, •'3j rid 1,2ce)
8. A label shall be affixed to the bag or other container in which a Class A EQ residuals product
is sold or given away for application to the land, or an information sheet shall be provided to
the person who receives the Class A EQ residuals product sold or given away in another
container for application to the land. The label or information sheet shall contain the
following information:
a. The name and address of the person who prepared the Class A EQ residuals product that
is sold or given away in a bag or other container for application to the land.
b. A statement that application of the Class A EQ residuals product to the land is prohibited
except in accordance with the instructions on the label or information sheet.
c. A statement regarding all buffers from the area to which the Class A EQ residuals
product is applied, including a minimum 10-foot buffer from any public or private water
supply sources (i.e., including wells),streams, lakes,rivers, or drainageways.
d. A statement that the Class A EQ residuals product shall not be applied to any site that is
flooded, frozen, or snow-covered.
e. A statement that adequate procedures shall be provided to prevent surface runoff from
carrying any disposed or stored Class A EQ residuals product into any surface waters.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division to ensure protection of the environment shall be
established and an acceptable sampling and reporting schedule shall be followed.
5

2. Proper records shall be maintained by the Permittee to track all residuals composting and
Class A EQ residuals product distribution activities. These records shall include, but are not
necessarily limited to,the following information:
a. Source, amount, and analysis (as applicable) of residuals accepted for treatment in the
residuals composting facility.
b. Source and amount of each amendment material used for treatment in the residuals
composting facility.
c. Analysis of the Class A EQ residuals product.
d. Name of the initial recipient of the Class A EQ residuals product, the amount distributed,
and the intended use.
3. The Class A EQ residuals product shall be analyzed to demonstrate that they are non-
hazardous under the Resource Conservation and Recovery Act (RCRA). A corrosivity,
ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching Procedure
(TCLP) analysis shall be conducted by the Permittee annually, and the results of the analyses
shall be maintained on file by the Permittee for a minimum of five years.
The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter 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) Lindane(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)
After the Class A EQ residuals product has been monitored for two years at an annual
frequency, the Permittee may submit a request to the Division for a permit modification to
reduce the frequency of this monitoring requirement. In no case, however, shall the
frequency of this monitoring be less than once per permit cycle when the Class A EQ
residuals product is sold or given away during that year.
6

4. An analysis shall be conducted by the Permittee on the Class A EQ residuals product at a
frequency that is dependent on the dry tons of Class A EQ residuals product distributed or
expected to be distributed during the calendar year for application to the land. The
monitoring frequency schedule shall be as stipulated in the following table:
Amount of Product Amount of Product
Distributed for Distributed for
Application to the Land Application to the Land Monitoring Frequency
(metric tons per (short tons per
365-day period) 365-day period)
0<mtT/yr<290 0<DT/yr<319 Once per Year
290<mDT/yr< 1,500 319 <DT/yr< 1,650 Once per Quarter
(Four Times per Year)
1,500<mDT/yr< 15,000 1,650_<DT/yr< 16,500 Once per 60 Days
(Six Times per Year)
15,000<mDT/yr 16,500<DT/yr Once per Month
(12 Times per Year)
The results of all analyses shall be maintained on file by the Permittee for a minimum of five
years. The analysis shall include the following minimum parameters:
Aluminum Magnesium Phosphorus
Ammonia-Nitrogen Mercury Potassium
Arsenic Molybdenum Selenium
Cadmium Nickel Sodium
Calcium Nitrate-Nitrite Nitrogen Total Kjeldahl Nitrogen
Copper pH Total Solids (Percent)
Lead Plant Available Nitrogen
(By Calculation) Zinc
ad mini jFvIS rr.iL
5. The Class A EQ residuals product shall be monitored by the Permittee for compliance with
/ au ,. Condition I. 12. of this permit at a frequency that is dependent on the dry tons of Class A EQ
!/(1v residuals product distributed or expected to be distributed during the calendar year for
application to the land. The monitoring frequency schedule shall be as stipulated in the
Vaitilhr r ait- following table:
/144,-A ._ Amount of Product Amount of Product
Distributed for Distributed for
Application to the Land Application to the Land Monitoring Frequency
(metric tons per (short tons per
365-day period) 365-day period)
0 <mDT/yr<290 0<DT/yr<319 Once per Year
290<mDT/yr< 1,500 319 <DT/yr< 1,650 Once per Quarter
(Four Times per Year)
1,500<mDT/yr< 15,000 1,650<DT/yr< 16,500 Once per 60 Days
(Six Times per Year)
15,000<mDT/yr 16,500<DT/yr Once per Month
(12 Times per Year)
7

The results of all analyses and records of all operational data shall be maintained on file by
the Permittee for a minimum of five years. Data to verify stabilization of the product shall be
maintained by the Permittee. The required data shall be specific to the stabilization process
utilized, but should be sufficient to demonstrate compliance with the Class A pathogen
requirements in 40 CFR Part 503.32(a) and the vector attraction reduction requirements in 40
CFR Part 503.33 clearly. In addition, the Environmental Protection Agency (EPA)
certification statements concerning compliance with pathogen requirements, vector attraction
reduction requirements, and management practices shall be completed at the above frequency
by the proper authority or authorities if more than one is involved, either the person who
generates the residuals or the person who prepares the Class A EQ residuals product to be
sold or given away for application to the land.
emid 6. Laboratory analyses and/or operational data, as required by Condition III. 4., and Condition
III. 5. shall be performed/gathered on the Class A EQ residuals product as it is to be
L,,4- A- distributed. Furthermore, analytical determinations made pursuant to the monitoring and
l reporting requirements of this permit shall be made by a laboratory certified by the Division
for the required parameter(s)under 15A NCAC 2H.0800 or 15A NCAC 2H.1100.
7. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition III. 3., Condition III. 4., Condition III. 5., and Condition III. 6. shall be
submitted annually on or before March 1st of the year following the distribution event to the
following address:
NCDENR-DWQ
Water Quality Section
Non-Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
8. Noncompliance Notification:
The Permittee shall report by telephone to the Water Quality Section of Division's Winston-
Salem Regional Office at 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 residuals composting facility or Class A EQ residuals product
distribution program that results in the land application of significant amounts of wastes
which are abnormal in quantity or characteristic.
b. Any failure of the residuals composting facility or Class A EQ residuals product
distribution program resulting in a release of material to receiving waters.
c. Any time that self-monitoring information indicates that the residuals composting facility
or Class A EQ residuals product distribution program has gone out of compliance with
the conditions and limitations of this permit or the parameters on which the system was
designed.
d. Any process unit failure, due to known or unknown reasons, that render the residuals
composting facility incapable of adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of
residuals or Class A EQ residuals product.
1-r`
8

V ,
•
Persons reporting such occurrences by telephone shall also file a written report in letterform
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.
IV. GROUNDWATER REOUIREMENTS
1. Applicable Boundaries:
a. The COMPLIANCE BOUNDARY for the residuals composting facility shall be as
specified by regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and
Standards"). The Compliance Boundary for a disposal system individually permitted
after December 31, 1983 shall be established at either (1) 250 feet from the waste
disposal area or (2) 50 feet within the property boundary, whichever is closest to the
residuals composting facility. An exceedance of groundwater quality standards at or
beyond the Compliance Boundary shall be subject to immediate remediation action
according to 15A NCAC 2L .0106(d)(2).
b. The REVIEW BOUNDARY shall be established around the residuals composting facility
midway between the Compliance Boundary and the perimeter of the waste disposal area.
Any exceedance of groundwater quality standards at the Review Boundary shall require
action in accordance with 15A NCAC 2L.0106(d)(1).
2. Other Requirements:
a. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
1. The Permittee or his designee shall inspect the residuals composting facility as well as the
facilities related to the Class A EQ residuals product distribution program residuals storage,
transport, and treatment facilities to prevent malfunctions and deterioration, operator errors
and discharges which may cause or lead to the release of wastes to the environment, a threat
to human health, or a nuisance. The Permittee shall maintain an inspection log or summary
including at least the date and time of inspection, observations made, and any maintenance,
repairs, or corrective actions taken by the Permittee. This log of inspections shall be
maintained by the Permittee for a period of five years from the date of the inspection and
shall be made available to the Division or other permitting authority, upon request.
3. Any duly authorized officer, employee, or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to
the residuals composting facility or Class A EQ residuals product distribution program at any
reasonable time for the purpose of determining compliance with this permit; may inspect or
copy any records that must be kept under the terms and conditions of this permit; and may
obtain samples of groundwater, surface water, or leachate.
9

VI. GENERAL CONDITIONS
1. A set of approved plans and specifications for the subject residuals composting facility shall
be retained by the Permittee for the life of the facility.
2. This permit shall become voidable unless the residuals composting facility and Class A EQ
residuals product distribution program are constructed and operated in accordance with the
conditions of this permit, the approved plans, the supporting materials, and in the manner
approved by the Division.
3. This permit shall be effective only with respect to the nature and volume of residuals
described in the application and other supporting data.
4. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina
General Statutes §143-215.6A through §143-215.6C.
5. The annual administering and compliance fee shall be paid by the Permittee within 30 days
after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit, as specified by 15 NCAC 2H.0205 (c)(4).
6. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances that may be imposed by other government agencies
(i.e., local, state, and federal) which have jurisdiction,including,but not limited to, applicable
river buffer rules in 15A NCAC 2B .0200, soil erosion and sedimentation control
requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCG010000,
and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC
.0500.
7. This permit may be modified, revoked, and/or reissued to incorporate any conditions,
limitations and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
8. The Permittee, at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the
residuals composting facility and Class A EQ residuals product distribution program
described therein, and if warranted, shall extend the permit for such period of time and under
such conditions and limitations as it may deem appropriate.
9. This permit shall not be automatically transferable. In the event that there is a desire for the
residuals composting facility and Class A EQ residuals product distribution program to
change ownership or to change the name of the Pernttee, a formal permit request shall be
submitted to the Division documentation from the parties involved and other supporting
materials as may be appropriate. The approval of this request shall be considered on its
merits and may or may not be approved.
10

Permit issued this the twenty-sixth day of September, 2003.
NORTH CAR INA ENV ONMENTAL MANAGEMENT COMMISSION
for Alan W.Klimek,P.E.,Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0021632
11

Permit No.WQ0021632
September 26, 2003
ENGINEER'S CERTIFICATION
Partial Final
l� , as a duly registered Professional Engineer in the State
of North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of
the project,
Project Name Location and County
for the Permittee, do hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of this permit, the approved plans and specifications, and other supporting
materials.
Signature Registration No.
Date
12

<' • . '-d FW z—N )1-_,i '
T 11 :51) ____------14 .4m \ 777-7-:"\--\%Cs1 / /
_ 4
'� �o �, City of Burlington
a' . Distribution of Residual 45
�- ��, Solids
mod♦ /�.� `-�� ,� Permit No. W 21632
a� `�. � Located off Boy Wood Road
z,..:
�.. ;� =� �� Alama�� � ��r► �� �t� c_.
i r nce County
%.—�-/4 e •\ ii Mebane Quad C-21-SE
ei firr:ii.i'
) a; \„ ! tr\ " ..... _ taxi ,. k‘i----" v Yo ci
4) :. _
II sLikiii v. �!1f.
O w •o i 0.r 1� _v__\
0Ig o600
� l'/ �
i. / \
7 iW1-1..-fr.., _Ai)____i_4________-=' 1-1-k ----. 0 I A . /. 6,/2 II
1� J\ 11‘:\.f-.CD\ ... 7 1 ••11 (1�`
600 ‘1 ..,! •A
\N. • \10 (.....
89 latk.4 . //'/' / ping Sta."01 \\ --\•
r__________
�% ' -� ' ` 1 ,
2 ij. ��� - /) j �/ ram,t �
59 �I• �bo° \�; , j' i j • %
� _ ;�
;`
'.j � SSo _ '\\� � Q %/�' .nSch �c �• r (�
. .,J4,
‘1* \\
38
� •���Z \± ,•' avk SSo / I \ e,►
\two. 4
(.ta,u \mil 1 / �'
-0-• -=-V:74;e4!:Se */; .1- 111) \ ‘MiC X/ . \I
2, .,
r /0 47111\\ \t-till /' • 4 0 ,3\) • ..---, :le c
,ff4//'dle
( 4 '',i,‘.,; '2\<)4 r_.,\4'
NO11
' 1 , , -1!/...Afc, '- j Jo__ _
,, ,,,,,,,,
. 7 ,, ,. _._ _
„„....,...„.,. /4 ,
,„.. ,,
(,../. , , , , ,,y
, 55 A ,
,,,,,_,
.7 leargi'i-040,-;--- -..... ._.--...._ ib tA,"/ I 5 ' /11,i ii 11 C
5:-..---palir,fornrlot.AN i: "'"" ' 11. J 1 k 4 Ai .
\*r4°° 71-.,A7/ \l'2' 0 40./V isffr., -;,-*.„,,v4A 3/4r.,.,./
6% ta...,,. //b\ '
\(-- / A:, ',. /
N * / k,
0v/ ,,4\.,,.,s7I,t
li.i.t
t .D-(
--31/*
,11-%7I4
q
0
•..4)
�� � ����� Q _ -_ ',.//� _C��3.�..,;'aTc.�1}.'. •� ra�r; (v.
) A
o ,may, �;;� -� s� . •
.II?_II
0?..,),
_4,.‘)..,z.. ...
r,iil,
.yl,•_
e }' Compost Site •61
ap'll)
\ rib 1411%--4
,, ‘,,,,, 1.:".i..A.,42
I 4 ‘ ki,....: , )1)1, \
i..\ 0 (co Iiii ,,,,,,,,, .0 ,FP . \a.
..* , ,•-•\-\' -- 1 • 1 14,4 4111 6 1
%‘4111 .
\ '•'` \ .f...1)
\\ ':"\,, • -‘ ,./1 \ 0 i Ati
k trivii-NI.-.-.. .::1,041-aill tw l'i k_.._...__.-..._. ,....--.1 a el 0(2-.,---_ pe"\.,° _N......._. .„,....-ks..-----
6 _Z•o_ANI... ..‘1111%------,--..- i: ... l'"°--°-''' a
i.2'30" 1 890''0 FEET 648 649 650 20' '51

IV.. 5. 444 V. I-
V. 2e
EXPLANATIONS OF ITEMS ON APPLICATION FORMS
City of Burlington COMPOGRO Compost Facility
Distribution of Residual Solids Permit No.WQ 0021632
FORM DRS 070807:
Section IV. 5. Treated (stabilized) compost is stored under a covered area on asphalt.
This area is protected from rain and potential runoff. We typically have a waiting list for
persons desiring compost, so some compost is distributed immediately following
acceptable laboratory results. The average storage of finished product is probably 20
days. If storage of finished product exceeds 60 days, the finished product is retested for
fecal coliform to make sure there is not re-growth of potential pathogens.
Section V. 1. The following narrative will answer questions l.a. through 1.e.
In 1999, the Burlington City council agreed to allocate funds to construct a small-
scale compost facility at the South Burlington WWTP capable of processing 5.5 dry tons
of biosolids per day. Construction on the compost facility began in 2001. The permit to
operate a compost facility was received from the NC Department of Environment and
Natural Resources in September of 2003.
DESIGN INFORMATION
Design Flow: 5.5 dry tons feed sludge per day
Equipment Description:
Number Equipment Purpose
2 Grinder pumps Transfer residuals from existing storage tanks
1 2-meter belt press Dewater feed sludge to 16%—20% solids
1 Berth for 2nd 2-meter belt press (future)
1 Conveyor Transfer dewatered sludge to mixing area
1 25,500 ft2 Open area Storing amendment material
1 1,710 ft2 Covered area Blending dewatered residuals and amendment
material
1 1,875 ft2 Covered area Storing amendment material in dry conditions
1 Agricultural Feed Mixer Blending dewatered residuals and amendment
material
1 35,700 ft2 Covered area Composting blended residuals/amendment
material; curing composted material
C:\Documents and Settings\sshoaf\My Documents\Biosolids\Explanations of items WQ0021632 080226.doc

11 5-Horsepower blowers Aerating static piles(Maximum of 22 static
piles)
1 153 yd3 Trammel screen Screening composted product and recovery of
amendment
1 15,000 ft2 Open area Turning curing piles and screening of
Class A product
1 900 ft2 biofilter Capture and treat odor-generating compounds
in the facility
1 4,900 ft2 biofilter Capture and treat odor-generating compounds
in the facility
1 Polymer Feed System Assist with the dewatering of residuals
General Description
The goal of the COMPOGRO compost facility is to consistently produce a Class A EQ
material that is suitable for a variety of uses on land that has no post-application
restrictions. Class A residuals have the greatest degree of pathogen reduction and are
considered to be very safe. All domestic residuals which are to be distributed to the
public for use for landscaping must meet one of the alternatives for Class A pathogen
reduction found in 40 CFR Part 503.30.
Class A pathogen reduction must meet one of the following criteria:
1. A fecal coliform density must be less than 1,000 MPN (most probable number)
per gram of total solids (dry weight); or
2. A Salmonella sp. bacteria must be less than 3 MPN per 4 grams of total solids
(dry weight)
The City of Burlington has selected option 1 (fecal coliform<1,000 MPN) as the
preferred method to determine compliance with the pathogen reduction requirements.
This is achieved by following the time and temperature guidelines in 40 CFR 503.
In addition to the pathogen reduction requirements, Compogro must also meet all of the
Vector Attraction Reduction(VAR)requirements of Class A residuals. All domestic
residuals which are to be distributed to the public must meet one of the alternatives for
vector attraction reduction listed in 40 CFR 503.33. The City achieves compliance by
following the time and temperature guidelines provided by the USEPA.
C:\Documents and Settings\sshoat\My Documents\Biosolids\Explanations of items WQ0021632 080226.doc

The City of Burlington Compogro Compost facility has developed a system for building
aerated piles and collecting and recording data necessary to ensure that all the
requirements of Class A compost are being achieved. A narrative of the process and
sampling plan are included below.
Recordkeeping Procedures
A record of the aerated static pile temperatures is maintained to demonstrate that the piles
meet the required temperatures for the designated time to achieve pathogen reduction and
vector attraction reduction. Aerated static piles are assigned an identifying number that
establishes the date that the pile was built, and the blower that was used to aerate the pile.
The format is year,month, day, and blower number. For example, the number 030109-
07 would indicate that the pile was started on January 9, 2003 and was aerated using
blower 7. Each pile is monitored for temperature with at least four thermometers. We
are satisfying the 40 CFR 503 pathogen reduction requirements by keeping the compost
above 131 degrees F for three(3) consecutive days (72 hours minimum). We are
satisfying the 40 CFR 503 vector attraction reduction requirements by keeping the
compost above 104 degrees F and an average of greater than 113 degrees F for a
minimum of fourteen(14) consecutive days. We are maintaining the aerated static piles
for longer than 21 days, and keeping the temperatures elevated for longer than the
regulations require. The piles on the Compost Pile Temperature log sheet were followed
onto the curing piles and into the finished compost product piles. This is done to create a
traceable process stream.
The City has included copies of the compost pile temperature log sheets, finished
compost fecal coliform analytical results(City of Burlington lab and Summit
Environmental Laboratory), and finished compost nutrient and metals analyses (A&L
Eastern Agricultural Laboratories, Inc.) for the finished compost product in the annual
reports submitted to the US EPA and NC DENR. All of the results support the pathogen
reduction, vector attraction reduction, and EQ designation of the compost and are
available on site as well as in the annual reports.
C:\Documents and Settings\sshoaf\My Documents\Biosolids\Explanations of items WQ0021632 080226.doc

The Static Aerated Piles (see process diagram included)
Wastewater treatment residuals from the City of Burlington's South Burlington
Wastewater Treatment Plant are stored on the plant site in tanks that are mixed. These
residuals are pumped through two grinder pumps and a 1500-foot long, 6-inch ductile
iron force main to the compost dewatering building. There the solids are mixed with
polymer and processed on a gravity belt press for dewatering. The dewatered solids
(approximately 18% solids) are then mixed with a bulking agent(wood chips) and
amendments (leaves)to create the feed stock for the building of static aerated piles.
The aerated static piles are constructed under a roof to protect the pile from wind and
rain. Before building the pile, a six (6)to eight(8) inch deep bed of leaves and wood
chips (amendment) is placed to cover an area larger than the pile. This amendment layer
makes an insulating bed underneath the aerated piles. This base or bed is made with a 4
inch perforated airline placed down the center of the bed. The airline is connected to a
blower creating positive or negative pressure so that air can be forced or pulled through
the compost pile. The blowers are controlled by timers that turn them on or off as needed
to supply airflow to the piles. After the biosolids and amendment(wood chips and
leaves) are mixed together,the mixture is placed on the insulating base to build the static
aerated pile and to begin the composting process. The mixture of biosolids and
amendment is then covered with a six to eight(6—8) inch blanket of amendment to
insulate the pile.
After building a pile, a minimum of four(4)thermometers with 48-inch probes are placed
at various locations and depths throughout the pile to monitor the temperatures of the
compost pile. The temperatures are recorded daily to track the composting process.
Results are entered into a database to track each pile with a unique identifier to make sure
it meets the regulatory requirements. The thermometers are left in place during the time
required to achieve compliance with the time and temperature requirements for the
process to further reduce pathogens (PFRP) and for vector attraction reduction. We have
not had any trouble reaching the prescribed time and temperatures. We make sure that
the piles achieve 131 degrees Fahrenheit for a minimum of 3 consecutive days and are
above 104 degrees F and kept at an average of greater than 113 degrees F for a minimum
C:\Documents and Settings\sshoaf My Documents\Biosolids\Explanations of items WQ0021632 080226.doc

CITY OF BURLINGTON COMPOST FACILITY
COMPOST PROCESSING
BLOCK-FLOW DIAGRAM February 2008
Static Aeration Process (11 aerated piles)
Recycled Screenings
0
Digested Feed
�.___, Stock
1 [11
Polymer Tank
0 Polymer addition
(--- .. 1114----1110
Curing Pile f
(50 days)
..._______.)
1 ON
V
Screen Belt Press
Finished Compost Dewatered Sludge
i
(18%solids)
Lab Test 0 z, 3:1:1 Mixing ratio
x
WI

of 14 consecutive days. Regardless of the time and temperature requirements, we keep
the aerated static piles for a minimum of 21 days and some are kept up to 50 days
depending on storage space and composting conditions.
Curing and stabilization
After the compost has met the requirements for time and temperature on the static aerated
piles, the compost is moved to the curing pile for a minimum of 21 days for further
stabilization. We keep one thermometer in the curing pile(which can be a combination
of several aerated static piles) and record those temperatures as well. We have found that
the curing process often requires more than 21 days and may take as many as 50 days.
Sampling Finished Compost for Fecal Coliform,Nutrients and Metals
After the curing process is completed the material is screened to separate the reusable
amendment from the compost. At this point the finished compost is ready to be sampled
and analyzed for fecal coliform to demonstrate successful pathogen reduction. The
finished compost pile is sampled for fecal coliform in the following manner.
A core sampler is disinfected for use to collect the samples. The core sampler is used to
take core samples within the compost pile at different depths and locations through out
the compost pile to get a good composite sample of the product. We collect four(4)
cores in a sealable plastic bag or sterile fecal bottle to make one composite sample, and
collect a minimum of three(3) composite samples for each batch of finished compost.
That means that we are taking samples of twelve (12) different locations in the pile.
The fecal samples are collected in sterile fecal bottles and are sent directly to the lab for
analysis. The samples are either hand delivered to the City of Burlington wastewater lab
(Certificate No. 188) or shipped to the Summit Environmental Technologies Lab in
Akron, Ohio. A dry solids analysis and the fecal test require about four days turnaround
from sample collection to reporting of the data. Sample results are recorded and
laboratory reports are maintained in the files.
C:\Documents and Settings\sshoat\My Documents\Biosolids\Explanations of items WQ0021632 080226.doc

Similar sampling techniques are used to collect samples for nutrient and metals analyses.
Those samples are contained in the sealable plastic bags and sent to A&L Eastern
Agricultural Laboratories, Inc. in Richmond, VA. This data will be used to formulate the
information sheets that are given to the purchaser of the compost. These analyses will be
performed within 60 days of distribution of the finished product, and the results will be
maintained on file.
Test for Re-growth of Fecal Coliform
If the compost is not distributed within 60 days of an acceptable analysis, the pile will be
resampled for fecal coliform using the same technique as above immediately
(approximately one week)prior to distribution.
Leachate Management
Runoff or leachate from any area that has contacted biosolids before, during, or after the
composting process is directed to a pump station and returned to the wastewater
treatment plant main flow. The area of the asphalt pad that is under the roof has floor
drains that connect to the pump station. The pump station pumps liquids (leachate and
clean up water)back to the main flow of the South Burlington WWTP through a force
main. The area of the asphalt pad that is immediately in front of the roofed area has
grooves cut into the asphalt to direct any runoff(leachate or stormwater) to the same
pump station for return to the main flow of the South Burlington WWTP. This is the area
that is used for turning the curing piles and screening the finished product. The
uncovered asphalt pad that is farther away from the roofed area is not used to store
composted materials or amendment that has contacted the compost. "Virgin"wood chips
and leaves are stored in this area. The stormwater runoff from this area is directed to a
pump station that connects to the larger pump station mentioned above. The"first flush"
from this area is collected in a tank and pumped back to the main wastewater plant flow.
Additional runoff from this area is directed to an engineered stormwater detention pond
for storage and controlled release.
Final Disposition of the Finished Compost
C:\Documents and Settings\sshoaf\My Documents\Biosolids\Explanations of items WQ0021632 080226.doc

The finished product is sold to individuals, landscape companies, and farmers. The
product is sold by the cubic yard and is not packaged. All persons receiving compost get
a copy of the information sheet and sign a form indicating that they have read the
information and agree to abide by the restrictions as stated. Local agriculture extension
agents and NC State University faculty have helped publicize the availability of the
compost and provided recommendations on the suitable use of the product. The largest
portion of the material is sold to landscape companies for their use in plantings and
beautification. We have had inquiries from farmers who want to use the finished product
as a component of their pasture restoration projects. We have sold compost to one farmer
for this purpose,but cannot provide as much compost as he desires. Homeowners have
purchased compost for flower gardens and other plantings. City staff keep records of
every purchase including the name of the purchaser and their address. These records are
available on site.
C:\Documents and Settings\sshoat\My Documents\Biosolids\Explanations of items WQ0021632 080226.doc

V. 3,
CITY OF BURLINGTON
SOUTH BURLINGTON WASTEWATER TREATMENT PLANT
2471 BOYWOOD ROAD, GRAHAM, NC 27253
PO BOX 1358,BURLINGTON,NC 27216-1358
[phone]
"COMPOGRO" COMPOST INFORMATION SHEET
Our"COMPOGRO"compost is manufactured from a controlled blend of biosolids,woody residues,leaves and other
compatible organic wastes. These materials are composted under carefully controlled conditions to assure the highest quality
product suitable for topsoil production,flowerbeds,lawn care, shrubbery,golf courses,parks,cemeteries,greenhouses,and
nurseries. The compost is analyzed routinely and has the following nutrient contents:
Total Nitrogen(TN) 21304 mg/kg Total Solids 60-75%
Total Phosphorus(TP) 8800 mg/kg pH(SU) 6.7—7.5
Total Potassium(K) 4800 mg/kg
Range of values based on the most recent analyses.FP#23
The production of COMPOGRO met all of the temperature requirements for pathogen destruction as required by EPA and the
North Carolina Department of Environment and Natural Resources(NCDENR). The composting process has achieved
temperatures of not less than 131 degrees Fahrenheit for three consecutive days,and has been tested for pathogen indicator
organisms prior to public distribution. This product has been composted for at least 21 days and cured for more than 21 days to
provide additional product quality. The heavy metal content of COMPOGRO is less than or equal to the metals limitations
established by EPA and recognized by NCDENR for classification as exceptional quality biosolids. During the composting and
curing process,this product met the EPA and NCDENR requirements for vector attraction reduction by achieving an average of
113 degrees Fahrenheit for at least 14 consecutive days. COMPOGRO is suitable for distribution to the public for a variety of
agricultural,landscaping,and horticultural uses with the following restrictions:
1. COMPOGRO shall not be applied to land except in accordance with the instructions contained herein.
2. Do not ingest or allow others to ingest COMPOGRO. Wash bands after handling.
3. Root or leaf crops for direct human consumption should not be grown within one(1)year of the last application
of COMPOGRO to the site.
4. COMPOGRO shall not be applied to any site that is flooded,frozen,or snow covered.
5. COMPOGRO shall not be applied within 25 feet of any waterway,stream,river,or lake.
6. COMPOGRO shall not be applied within 100 feet of any wells or private or public water supply sources.
7. Storage of COMPOGRO requires containment of the product Adequate precautions shall be taken to prevent
surface runoff from carrying any disposed or stored compost into any surface waters.
8. COMPOGRO should be applied at agronomic rates or as recommended for intended use.
The end user of this product is expected to use this product as described above. All state and federal regulations are intended for
the protection of the public health and the environment.
Limited Warranty and Disclaimer. The City of Burlington warrants that the product,COMPOGRO,meets the specifications
stated above. Except as stated in the preceding sentence,there are no warranties,express or implied,that extend beyond the
representations herein made. Specifically,there are no warranties of merchantability or fitness or suitability thereof for any
purpose. If for any reason COMPOGRO fails to meet the specifications,the Buyer's sole remedy shall be limited to the recovery
of the purchase price. Under no circumstances shall the City of Burlington be liable for any other damages,including direct,
indirect,consequential or special damages.

V. 3,.
CITY OF BURLINGTON
SOUTH BURLINGTON WASTEWATER TREATMENT PLANT
2471 BOYWOOD ROAD, GRAHAM, NC 27253
PO BOX 1358, BURLINGTON, NC 27216-1358
"COMPOGRO" COMPOST INFORMATION SHEET
Acknowledgement: The undersigned Buyer acknowledges that he or she has read the COMPOGRO
information sheet and is familiar with it contents. The undersigned agrees to abide by the restrictions
concerning use of this product.
Buyer Signature Date
Name:
Quantity: CUBIC YARDS
Address:
Intended use:
Telephone: Purchase price$

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
RESIDUALS SOURCE CERTIFICATION ATTACHMENT EQ 2 8 20'28
(FORM: RSCA 070807)
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
Applicant's name: City of Burlington, NC
Check all that apply: ❑ NEW RESIDUALS PROGRAM I® RENEWED RESIDUALS PROGRAM
❑ INCREASE ❑ DECREASE the maximum permitted annual dry tonnage for this residuals source-
generating facility certified for this residuals program.
Current: 2,250 Dry Tons/yr. and proposed: Same Dry Tons/yr.
❑ ADD ❑ DELETE this residuals source-generating facility to/from those certified for this
residuals program.
❑ OTHER Explain:
I. RESIDUALS SOURCE-GENERATING FACILITY INFORMATION(See Instruction B.):
1. Name of facility: City of Burlington — South Burlington Wastewater Plant
2. Facility permit holder: City of Burlington
Facility permit holder is(check one): ❑ federal, ❑ state, El local government,or ❑ private.
Facility permit number: NPDES NC 0023876
Facility permit issued by(check one):12 Div. of Water Quality, ❑ Div. of Environmental Health, or
❑ other(explain: ).
3. If the facility permit is not issued by the Div. of Water Quality,complete the following:
a. Facility contact person and title:
Facility complete mailing address:
City: State: Zip:
Telephone number: ( ) Facsimile number: ( )
E-mail address:
b. Facility complete location address:
City: State: Zip:
Latitude: and longitude:
4. County where facility is located: Alamance
5. Purpose of the facility(check one):
Et 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,or
(approximate percentages: %industrial and %domestic)
❑ other(explain: )-
FORM: RSCA 070807 Page 2 of 8 Attachment Order 2

6. Does the facility have an approved pretreatment program: Et yes ❑ no
7. Facility permitted/design flow: 12 MGD and facility average daily flow: 6.0 MGD. (2007)
8. Average amount of residuals being generated at this facility 1 r 854 dry tons per year.
9. Specify the following regarding treatment and storage volumes available at the facility:
Type and volume of residuals treatment: See attached explanation
Type and volume of residuals storage(i.e.,outside of residuals treatment units):
II. RESIDUALS QUALITY INFORMATION(See Instruction C.):
1. Specify if residuals are regulated under(check one): ij 40 CFR Part 503 or ❑ 40 CFR Part 257.
2. Specify if residuals are intended for(check one):
13 Land Application/Distribution(Class A or Equivalent). Permit No. WQ0021632
Complete all items EXCEPT Items II. 4b., 7b.,and 7c.
rg Land Application(Class B or Equivalent). Permit No. WQ0000520
Complete all items EXCEPT Items II. 4b., 7a., and 7c.
❑ Surface Disposal.
Complete all items EXCEPT Items II.4a., 5.,7a., 7b.,and 8.
THIS FORM IS FOR CLASS A COMPOST PERMIT RENEWAL.
***FORM:RSCA CONTINUES ON NEXT PAGE***
FORM:RSCA 070807 Page 3 of 8 Attachment Order 2

COMPOST ANALYSIS
3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non-
hazardous under RCRA:
a. Are the residuals are listed in 40 CFR§261.31-§261.33: 0 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 well as those for corrosivity, ignitability, and
Summit Env T@Chnolo i?s, Inc.
reactivity: laboratory: end date of ana�ysts: 1/31/Off
Passed corrosivity test: © yes 0 no. pH: 7.35 s.u. (2<pH< 12.5).
Passed ignitability test: On yes 0 no. Flashpoint: >140 °F(> 140°F).
Passed reactivity test: ® yes 0 no. HCN: <0.5 mg/kg(<250)&H2S: <25 mg/kg(<500).
TCLP Parameter Limit Result TCLP Parameter Limit Result
(mg/L) (mg/L) (mg/L) (mg/L)
Arsenic 5.0 <0.5 Hexachlorobenzene 0.13 <0.1
Barium 100.0 <5.0 Hexachloro-1,3-Butadiene 0.5 <0.1
Benzene 0.5 <0.1 Hexachloroethane 3.0 <0.1
Cadmium 1.0 <0.1 Lead 5.0 <0.5
Carbon Tetrachloride 0.5 <0.1 Lindane 0.4 <0.002
Chlordane 0.03 <0.1 Mercury 0.2 <0.002
Chlorobenzene 100.0 <0.1 Methoxychlor 10.0 <0.002
Chloroform 6.0 <0.1 Methyl Ethyl Ketone 200.0 <2.0
Chromium 5.0 <0.2 Nitrobenzene 2.0 <0.1
m-Cresol 200.0 Pentachlorophenol 100.0 <0.25
o-Cresol 200.0 Pyridine 5.0 <0.25
p-Cresol 200.0 Selenium 1.0 <0.5
Cresol 200.0 <5.0 Silver 5.0 <0.5
2,4-D 10.0 <5.0 Tetrachloroethylene 0.7 <0.1
1,4-Dichlorobenzene 7.5 <0.1 Toxaphene 0.5 <0.1
1,2-Dichloroethane 0.5 <0.1 Trichloroethylene 0.5 <0.1
1,1-Dichloroethylene 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 0.008 <0.002 Vinyl Chloride 0.2 <0.2
FORM:RSCA 070807 Page 4 of 8 Attachment Order 2

4. Metals Determination: Complete one of the following tables (i.e., as applicable) to demonstrate that the
residuals do not violate the ceiling concentrations for metals regulated under 15A NCAC 02T.1105.
a. For Class A or Class B: 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 Eastern Laboratories, Inc. and date of analysis: 12/21/07
Parameter Ceiling Monthly Average Result
Concentration Limits Concentration Limits
(ClassA &ClassB) (For Class A Only) 12/21/07 2007 Avg.
(mg/kg) (mg/kg) (mg/kg)
Arsenic 75 41 2.9 1.9
Cadmium 85 39 <5 1.2
Copper 4,300 1,500 109 124
Lead 840 300 14 19
Mercury 57 17 <0.4 0.5
Molybdenum 75 n/a <5 6
Nickel 420 420 84 41
Selenium 100 100 <1.0 1.5
Zinc 7,500 2,800 259 244
c. For Surface Disposal: 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:
Closest Distance Arsenic Chromium Nickel
to Property Lines
(meters) (mg/kg) (mg/kg) (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
> 125 but< 150 62 450 420
>_ 150 73 600 420
FORM: RSCA 070807 Page 5 of 8 Attachment Order 2

5. Nutrient/Micronutrient Determination: Complete the following:
a. Total solids: 59.9 %.
b. Fill in the following table with the results of the latest analyses (i.e., on a dry weight basis) for the
following nutrient and micronutrient parameters: laboratory: A&L Eastern Laboratories, Inc.
and date of analysis: 12/21/07
Parameter Result
(mg/kg, dry weight)
Aluminum 9,650
Ammonia-Nitrogen 5,400
Calcium 16,500
Magnesium 4,600
Nitrate-Nitrite Nitrogen 4
pH(Standard Unit) 6.69
Phosphorus 8,800
Potassium 4,800
Sodium 900
Total Kjeldahl Nitrogen 21,300
c. Using the results listed in Item II. 5b. above,calculate the sodium adsorption ration(SAR): 2.25
d. Specify the mineralization rate to be used in calculating the plant available nitrogen (PAN) of the
residuals: 10 %. This rate is a ® default value or ❑ 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:
Calculate the PAN for the residuals(i.e.,on a dry weight basis)and list the results in the following table:
Application Method First Year Five-Year
PAN Maximum Adjusted
PAN
(mg/kg) (mg/kg)
•
Surface 4,294 5,719
Injection/Incorporation
e. Are the residuals a registered fertilizer with the NC Department of Agriculture and Consumer Services:
❑ yes 12 no. If yes,provide date of registration approval:
the current registration number:
and the fertilizer equivalent: %, %,and %.
FORM: RSCA 070807 Page 6 of 8 Attachment Order 2

6. Other Pollutants Determination: Specify whether or not there are any other pollutants of concern in the
residuals and list the results of the latest analyses:
7. Pathogen Reduction Determination: Specify which altemative(s) will be used to meet the pathogen
reduction requirements:
a. For Class A or Equivalent:
® 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 following(except for residuals regulated under 40 CFR Part 257 that are to be distributed):
❑ Alternative 1 [40 CFR§503.32(a)(3)] -Time/Temperature Compliance.
❑ Alternative 2 [40 CFR§503.32(a)(4)]-Alkaline Treatment.
❑ Alternative 3 [40 CFR §503.32(a)(5)]-Prior Testing for Enteric Virus/Viable Helminth Ova.
❑ Alternative 4 [40 CFR§503.32(a)(6)] -No Prior Testing for Enteric Virus/Viable Helminth Ova.
a Alternative 5 [40 CFR§503.32(a)(7)] -Process to Further Reduce Pathogens(PFRP).
Specify one: Ei composting, ❑ heat drying, 0 heat treatment, 0 pasteurization,
❑ thermophilic aerobic digestion, 0 beta ray irradiation,or 0 gamma ray irradiation.
❑ Alternative 6 [40 CFR§503.32(a)(8)]-PFRP-Equivalent Process.
Explain:
b. For Class B or Equivalent:
❑ Alternative 1 [40 CFR§503.32(b)(2)]-Fecal Coliform Density Demonstration.
❑ Alternative 2 [40 CFR§503.32(b)(3)] -Process to Significantly Reduce Pathogens(PFRP).
Specify one: ❑ aerobic digestion, ❑ air drying, 0 anaerobic digestion,
0 composting,or ❑ lime stabilization.
❑ Alternative 3 [40 CFR§503.32(b)(4)]-PSRP-Equivalent Process.
Explain:
❑ Not Applicable-Regulated under 40 CFR Part 257 with NO Domestic Wastewater Contribution.
c. For Surface Disposal:
❑ Alternative for Surface Disposal Units Only[40 CFR§503.33 (b)(11)]-Soil/Other Material Cover.
❑ Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item II. 7a.above.
❑ Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item II.7b.above.
❑ Not Applicable-Regulated under 40 CFR Part 257 with NO Domestic Wastewater Contribution.
FORM:RSCA 070807 Page 7 of 8 Attachment Order 2

8. Vector Attraction Reduction Determination: Specify which alternative(s) will be used to meet the vector
attraction reduction requirements:
❑ Alternative 1 [40 CFR§503.33 (b)(1)J-38%Volatile Solids Reduction(Aerobic/Anaerobic Digestion).
❑ Alternative 2 [40 CFR§503.33 (b)(2)J-40-Day Bench Scale Test(Anaerobic Digestion).
❑ Alternative 3 [40 CFR§503.33 (b)(3)]-30-Day Bench Scale Test(Aerobic Digestion).
❑ Alternative 4 [40 CFR§503.33 (b)(4)]-Specific Oxygen Uptake Rate Test(Aerobic Digestion).
fa Alternative 5 [40 CFR§503.33 (b)(5)] - 14-Day Aerobic Processes.
❑ Alternative 6 [40 CFR§503.33 (b)(6)]-Alkaline Stabilization.
❑ Alternative 7[40 CFR§503.33(b)(7)]-Drying of Stabilized Residuals.
❑ Alternative 8 [40 CFR§503.33 (b)(8)] -Drying of Unstabilized Residuals.
❑ Alternative 9 [40 CFR§503.33 (b)(9)] -Injection.
❑ Alternative 10 [40 CFR§503.33 (b)(10)J-Incorporation.
❑ Alternative for Surface Disposal Units Only[40 CFR§503.33 (b)(11)]-Soil/Other Material Cover.
❑ Alternatives for Animal Processing Residuals Only:
Specify one: ❑ injection, ❑ incorporation,or ❑ lime addition to raise pH to 10.
❑ Not Applicable-Non-Biological Residuals with NO Domestic Wastewater Contribution.
FORM: RSCA 070807 Page 8 of 8 Attachment Order 2

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
RESIDUALS SOURCE CERTIFICATION ATTACHMENT
(FORM: RSCA 070807)
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
Applicant's name: City of Burlington
Check all that apply: 0 NEW RESIDUALS PROGRAM ® RENEWED RESIDUALS PROGRAM
0 INCREASE 0 DECREASE the maximum permitted annual dry tonnage for this residuals source-
generating facility certified for this residuals program.
Current: Dry Tons/yr. and proposed: Dry Tons/yr.
❑ ADD ® DELETE this residuals source-generating facility to/from those certified for this
residuals program.
❑ OTHER Explain: We have not used this source as compost feed stock.
I. RESIDUALS SOURCE-GENERATING FACILITY INFORMATION(See Instruction B.):
1. Name of facility: City of Burlington — East Burlington Wastewater Plant
2. Facility permit holder: City of Burlington
Facility permit holder is(check one): 0 federal, ❑ state, ® local government,or 0 private.
Facility permit number: NPDES NC 0023868
Facility permit issued by(check one): Div. of Water Quality, 0 Div. of Environmental Health, or
0 other(explain: ).
3. If the facility permit is not issued by the Div. of Water Quality,complete the following:
a. Facility contact person and title:
Facility complete mailing address:
City: State: Zip:
Telephone number: ( ) Facsimile number: ( )
E-mail address:
b. Facility complete location address:
City: State: Zip:
Latitude: and longitude:
4. County where facility is located:
5. Purpose of the facility(check one):
Ig treatment of municipal wastewater, 0 treatment of 100%domestic wastewater,
❑ treatment of potable water, ❑ treatment of 100%industrial wastewater,
❑ treatment of industrial wastewater mixed with domestic wastewater,or
(approximate percentages: %industrial and %domestic)
❑ other(explain: ).
FORM: RSCA 070807 Page 2 of 8 Attachment Order 2

6. Does the facility have an approved pretreatment program: On yes ❑ no
7. Facility permitted/design flow: 12 MGD and facility average daily flow: 5.1 MGD. (2007)
8. Average amount of residuals being generated at this facility 1,755 dry tons per year. ("7)
9. Specify the following regarding treatment and storage volumes available at the facility:
Type and volume of residuals treatment: 2 40,000 gallon lime stabilization tanks
Type and volume of residuals storage(i.e.,outside of residuals treatment units): 1 storage tank —
412,000 gallons; 1 lime stabilized storage tank — 412,000 gallons; and 1
lime stabilized storage tank — 400,000 gallons
II. RESIDUALS QUALITY INFORMATION(See Instruction C.):
1. Specify if residuals are regulated under(check one): ❑ 40 CFR Part 503 or ❑ 40 CFR Part 257.
2. Specify if residuals are intended for(check one):
❑ Land Application/Distribution(Class A or Equivalent).
Complete all items EXCEPT Items II. 4b.,7b.,and 7c.
Land Application(Class B or Equivalent).
Complete all items EXCEPT Items II. 4b.,7a., and 7c.
❑ Surface Disposal.
Complete all items EXCEPT Items II. 4a., 5.,7a.,7b.,and 8.
***FORM:RSCA CONTINUES ON NEXT PAGE***
FORM:RSCA 070807 Page 3 of 8 Attachment Order 2

EXPLANATIONS OF ITEMS ON APPLICATION FORMS
City of Burlington COMPOGRO Compost Facility
Distribution of Residual Solids Permit No.WQ 0021632
FORM RSCA 070807:
Section I. 8. The amount of residuals generated at the South Burlington WWTP is
based on the amount of biosolids land applied. This is tracked by the land application
logs maintained by the City and Synagro. The compost facility operates in a batch mode
so there is not a steady flow to the facility. The feed to the compost facility is a liquid at
about 3% solids and the finished product includes amendment, so it is not clear how
much of the plant volume is diverted to the compost process. It is a small percentage of
the overall plant sludge volume.
Section I. 9. There is no storage of untreated liquid wastewater treatment plant
residuals at the COMPOGRO compost facility. All liquid sludge is stored on the South
Burlington WWTP site. This site has two (2)tanks for aerobic digestion and storage
holding 592,400 gallons each; and two (2)tanks for holding secondary solids (1) and
lime stabilized solids (1)with a volume of 586,500 gallons each. Most of the solids from
the South Burlington WWTP are land applied as a liquid Class B product.
At the COMPOGRO compost facility there is a two-meter belt press that receives liquid
sludge from the treatment plant site via a 6-inch ductile iron force main. The sludge is
dewatered to about 18% and mixed with amendment. There is enough storage of
dewatered solids to accommodate about one-day's run of the belt press. There is enough
area under the roof to store approximately 1000 cubic yards of finished compost prior to
distribution.

. _......._
/
I c)
„„ --) I' .•
l's, 4, ..-,,,k".•'''' '- " ,
.if rt, ., ,,,-z.,,,--- --. ) \,,,-,,...--- --‘ ..• - --
\-.. " ' , i •
i , N N - 4 1.'.'iri \ '' ,•'? (.----..i." ,!).. ' V".....;.....^%, :---"e7,N'i-2•Cl.-°t:-;s,1g-s--,'1-1tt-"--".P•-._T
\ ,'''-i"r".•,&f\irtah":.V 4'‘.....A,',\..-ak.'‘'.''‘.''".,,‘,.1_,‘,„',,.,--1"i,,1l,/i-''a.•.'./).,, \/) /9,,,/*,,-'''•'''I!.
'
/z',,,\.\,,.•. ",-,,1N•1.1%''/1\1„0./)1.1-N.4. '4--,,,-,,',,,'-\-..-.-.-.N..'..,...*7•-''--,'3'1 7.,-.._— / 1 -__/.--•-.„/ ''*--1 •
I
t\/
- . / 1' I .
1 / / ? " -* •Ii•\f
\
? ,1 . / /V . ‘ .
ta I
'
k0 1,..4 '......,...., ,...4 4..,.NI* . . ' . • - * • ,--
77- .'Ll.". •-•' ...2"), V ' s` , " 1 .. ---'tr.' ,'-' 1.4' . ...,.• , • /
(' II i t(-:' #1011P + \ ' '•. .'--c \'.<4;"71.-1.:44re.,.. ' ' V/ \ ,/''':'4' * • 17'41 II . \'`!------"' i L''''
.....„ I •, I 7„., .;„"..„, NW", , ..,. , .\,.;; iN,...„,„4,; ./,, Y • * ,,;,'
la `. .i; \ 4,. ir.‘ tsV.4., , .,/?.. 4,,,,,r, .,,,,,1, .....le.., ,,,- .. , :"'"'".....- . ,„
‘) W i"'', r , ...\,„ ,..k. ,. 40,,-,,,,, i $ ..4,11ts ,..
) i,
40411/4
....., -7, ,,
-,,,,, ,,, . k .:. , ,-.,•...,), --,,, ,,.. / ..., ,,,... , -, , ,
,,, ,, / , , ,, ,,,,,,„, .4\•.,.: \ ii— ,.,,,,,, ,:-,,e,,•?/,/ _. .& ,,_____7----_-..,_4/ ' ../
,rj (.,,,,• •) - • -t. ,, 1-,s, • ... 4 i,11 . —/-----,
(..,--,,
''''‘ N„)jr1/4\1„-/-s'Nr\, ''‘ ! ''., ''';'tt ', --"S.:e2.4\*//\ • *; ,e.'"'"--:„3:::\1((z -
- --,.
i(-------,
10)
. • ‘ __,_---i', .. „./:., ./. 'N. * :It (2j \it /fl- 0,44
k\,\‘.\▪``,_,' •• I'`)-7 " '''-. . \ r .1 I V.1 ),I ' ', -- (li,*s
1 ..,,,,, 1 .s\ 1
' ,,'• ' if. I
i
,,,,‘.. ,z‘ . , ir
Cmi,„.."'"' '. -'!''''---/.7---•-- C
•--411440ty-,- ' \ /,',, '„t);,..,,,I,4.- . ' a 7 1 ---..._ \
,.,,...,,,...4w47,0,2„tx4.74/,' ' -(414:4-.-''''.••• ",1 ------" \''';',„!„.'''''''', ' ..,A,'' ci: . a l. '-'-
, --
-\\ 4
.„,„---- 0•4•,-.‘...,.-...a...-or,,,;,•• 4-111244"-..."1410,1*,--,,, , , .:..% . '--,„,,, • y it..--:-..---N. i . i.,_ lri s<11-1 •,,,....‘i ''.'..* / A.. A.1\,,,, ".".1* * 114C1"-- ‘'
'''/I''''6- .Sit, ...., .".: • 4 „yr...A ‘ ,,.. * ,•• • • 41,4,,,,,.• ....,....1 , i I
,"...i t '' ".•-•
,,YSI N , ,..." }'
\ ) ''At
N.,„.'..---.,.-_-_,
lit„.,:i \\. c---- ,-, 1.
if/..-,-.- • / ' .2„\,,,7/,, , \
,...... ..••.••.,
i i \/, .,,,---2, /z•---_,.. 1,-- ze,79.!-It-...?4,;‘ ,,,,.-wi. ./.,',,:,J,,e.'-•-m-iirim*ior..P1:74:3•Erf ,----- .. s--'..- . it /44:„-,,,,,,,,\ --,---•\-\\,- r*...%
f i, 'I „ii,/,f 7g.--;,› ,t44,i,i4„;fr,./1k;-,/-i••.!•r.',/ VIlrft?,1';';!.!:',. .:1:./t4•ViAl• ,---/ is--RI' , t1;1`..C.Tr` ) \\
\ /-(7 - flP!P----r i/&443ftio-•--.-' ;''''''"W".'Al. .,t-i`t1.*.t;:"-V'':::::.'-ir-°::,-;-7',WIt.-A i ` r(e) ,„,-,,, .-‘. i;,..4,13jz;;Ticv,„-- \ 4‘
,. , ,;,,,,, \.;f. ,),4r,;;;;:".e447°,. "--4.:.":•.--,...'--1:;;. .";;;;Afeltxrci•K•:),;,",:'!ik,'.44---.4.xi,.,::::-,:i$ ,./ i / ihj ke',..:5...(11; :?,*"..e- '1
, 4 : , --,,,‘ '''. • / $012:0PW.V..„.",,,,S.',/'"-W *13 p;4 i cil ;;..A i';;;,-;,,,:..,,,.,,:,,,,,,, ,:54:4;44 .'- I f" ,." 4.'".7'lv".;fa•zz''.'W •• '
r ' : /-•,,,k1 \..-..,, /, , aii,:ftVr!P,'.:4<:,.'z•-:` ,4441.;:".."*,,Iiikiit'ft"2:12,,•:.,-,ZVtg:tiziA-----• ' f / Tik.:4.4%'-'s, •4%;•.,.?""3,4''
ij it , ,, t .•,,t;i.,4,. / ‘f i f .;.',.....,,,'-," -.. ',...•,. ; ' 4111411,.. • „,""*""--.......) IL'.V...,.,747,.....".•• ,';‘,..,,,„,-idt'
j. ,.,
kik
\ i
''',/. \-1„\. ./*/ '''\:,\'; ‘c .,, i',.f_. It\ • ' * . 1. 4,' • .4 . * "
iiii ._....— i. ',./ ..i ,,- • I,t • .^ %\,,, t .0 ,,,,,..,j .41.0,•.VA. ,,,e......!••ti
))4 4,, Iii ' , ) \ill IC/,‘, ,1 ----,,. ,,,;:-;,:i , 7:it '• - °'* ' , ..."i ,f) , ,,.,, le/ .‘"••.Z., T."'' .1;41.1...,..
, _/''. , , s‘
\ I c,,i li 21 .:,•`/:-, I " i,::'3' ' ( ",‘ ''NI C `---1,,,,'41;it'I i 0 -;?.t1/4%-•-•-•4,- -i, •,,,11.,..14. 1....a.;:,..
r„ . ,,,.. ,c i
... , ,, ; i. ,./7"..-..,,, ---....)/Tri - I ',, / ......, 4.,'...1.1 4&,,,'1'.40;f•it..-
• / 's----. ---....,'",s'',...)) \ k ; - iv . 11 1; ...- / . e„,../ • -'.*..) ) ‘ "7'-•/ 1
.. .'It ...
' r, ' /r
1 t. ...... 4.•,,,, -
‘. \1 t. ,..
4-.';',,','., ' — •-, /•\.. .--- i \ `‘...,\
.•v.- t, / . , , ././....),` s. .\\\...,,
/ \ • rs---.... ---' •-• ,' \
) - :*'4'''.:''''1"- +'''''t, : C,---•,//:',4'', (,....f 1 • e‘ \
. ,,"• ) \ / -v.:----- .--/ (--,-"--", ..* :' i. **Al -",-.-.,-."'
''''' C \\' 7),,..,3 1 ,.,. ,..;,....?!•'-'''''. ' l'"‘c:m.'-'''' ''','' :,',' ''?\\.;..) L... .‘" f"''NN;2) . 11...------/ \ .,,t •
, , r ,,..-__ • i 1----',„:1,\, i. , -.,-. i 1 -.. ,. .0. ( -c-- 4;5- ( t
„ ,,---,:,, •,.,.......xok,_ \ 0,..„ ''•"•,,
I/ , `. '-," , I''\: f ,----V. % / ) I *",`...'. ! \ .•- / '' 7 .., ,/,, \,..7-....,,,,, ---, \ ik, )
"N!
• ..
e.,„,- / c.,„„.../ ,,,,.........,... I ,.,•::,/ Z.,,,,,' I ..,...,+:,' . , "..,' ;1. ,./- ( 1.„,_ ‘ , \ \1
' / --s. --s-' , ,41‘•\.;44,, . \ i ,. .,„
k„ •-•; -..., i ,„.- :: -...s, , , ) \
) 11
• \ \„f- \ .„..) ' A * -' 1 .
.;;-- ''e\-1" '‘ '' I '''". -') • ) n„ '
-,.,. -.\,.„,..,‘...77
.„ ' \\ \ % '\ • 1 ..../j/----N, ) 1, .,_,,..--N,....,) ,.' .. . . , ;;;,,,.1..., ,...,.....,..,...,
,.......
., ,.
--\,... .., , •, --„, '.,:\s ''' I/ ' \.> -7'7' ''' -•'-'-' -, •,, ./.,„.,..-........,
^
City of Burlington Facility
. _, . .. .
Soli thsitle WWTP i.
Sole Cr id,Vinid: ( .'1:->t M,.banc,\‘ Location
not to ‘,..ale
I atitude: if; tr'f,:' N ......__
‘It 1)
1.ongitude: . .
R•cl. Drainage Ilak.in: ( v,,,.'.,..•.! <
Not-th N PlillS Perm C it No N0023876
Stream(*lass: ( \S\k, Sn 11 1)- w i.,,inl 1,) t .,)2, I ,A i.1111 a ticic.±.lc .1 n t,,,.:',
........_.................._....._............... _............ ........... .......... ................ .. ................_..._....... .. .. ..... ..... ....................... .___.........____

)eli... :i 1 li
�� �''� `_. . ._ ,4,-- ,.. '-- . s.....',,4.. . __ \, 4
____________ -- : 4 b( .,v NijjirM ,--\ z.. ....Acz, \LisrNi\__
F!�, ��� • `_ � � \ City of Burlington
�� 70 'rt • �\‘%\ �y Distribution of Residual Solids
W. x.`� it,
\�\ , , 1 j '`�� Permit No. WQ00021632
;� A Located off Boy Wood Road
,E. x...„..,..4,,,\ /
�._' , �.4,,..„ 4 ...; ___________._____ ,,,4L, i...Alamance County ,
�. �'' 40.' Mebane Quad C-21-SE
r.4 i y 0.*7
\,. , - ---- ,,, ,
,,,r ,,, ,,,,,,,
,,,....,
,o„,
7! : b k..1kIN
7
g•
A=,-.)/
D ___ � . boo71°\. 0 _ o .°° '��
\ 41
. ,
7,
\ ,..
_z____) u \\
,/ 6-0
sso
Well
39 Yi-s-,
UZ
`-S--)-rLj___„
�� awftI''/- '}L(-,2f----D.
—/z\-I 1:: -s-o,\,,A\ _.,____\,41\,,'' ,.. .,r
p / p Z \. \III 6,• ' 6/2
® / \\ .i ingSta"p O
)--,
(.0
/i ., . , ,, I _ ,)//
I r\ % l r \ 59 # /� .l• ;�• \�.
� ��, d
r)\--4.),,
,�.` t / /e / \:�J 550. r.\....) " ,,...e..4. „, _ p �.\ • •n Sch j
W....Ai\ 1 ''Ilt i e Nt 4/7..t • IA'' I r ()Y.-/ ,--\ *"Ikt) .441CC ..i X I
n C U• ii CAzz.--;,•-•.H.\ ... /
?.ta" \ ..%..N‘ strie 4,e. ••••_: . ' \ kr( ,,
.1,. ow ) •
Wrt v, s,`.4,‘:,1(:\ .1,4\ ,/,\' 1 - - .
t, st„,,::#,A lir!, . 4,
r ( 3, 49.1 -* 1.1V4TbAl/ e I
() 1 ill ps-----,,,,,,..,,, r--3
itit\4,P -,..vo..7:, t), 1, _40 \
c.,to.j /1°. .d\ \\1(/.. \
07 1 ,.. „. --,,- ,-„...1- 441 1".. ° -.4___:-_ /4 1 VC lik,5 -51 ( (1
.,
sT.. ..v. "Al-An- y• : . \ s 1 / 4, „‘ .
c''°7"7)„....ry A? o 4,1
7\t / .4e• - ih
--.'-vt.gw-,0..N.1. ., ric, "1'6 t4.6-1'.* A .
-----.401.,.,
,‘ ,,/
,,,,,, / - ' 4,'' )_404.
, 4, IG`� �.•� �Pik tit,e I
''V.
0, rl +r 5Gb u� J‘ (• s __'d I_�C�.�q'3� f ,...,
,,,,...i.,''••'•^!i•I • ') •I
ly.4146p./ t9 /0
i(x_ Compost Site '"�_ ',i y •C� 1:._ lit5
�'16 �' s r O) ,Fre -'-\--A '` I/ 4.) -4
, .)
550 )it\ p 1; i.\ y '7.; P
•
P4'\ .c -- ‘4, „co I ,,,. ,,,, ,,
, ,,., t.\„ .. 1 ., \ 4,,,t,y, . , , . u ,.,
- .. r \''t\ _ °et .1 = '.- i
T\\ proNi • E \ so/ i � 't
S - �
1 10.11
14.
�2'30" 1 890 000 FEET 648 649 650 20' 651

/NAO, A
2115 2113N'''..-1-..'----L_ 2206
223A
2239
1 ��
? 2235
W
2. OP4
0 °V°N
u
PIEDMONT CRESCENT
GOLF COURSE
\________
a°9
r.4
2100
A
2117 3
7 o�
0 �0
o
M
2116
a 42157
0
Nu. 2158 2156 '
V : 2243 ./
Y'
2116 !I e....'3.2160
\.0 j{t21
\ CI • t. $1" ‘6P413N
‘ V%Cs.------T)14ei°0 c 7, 4,141.
m O l'� 2160
--A , * SWEPSONvn.L
SOUTH B / RLINGTON 1441140, /S0 BAPT. CM.
\� WASTE TREA MENT PLANT
\-7 [.:._
2159 sp.
. 5 A‘..
n 2116
m C,q _ Wre
DISCHARGE S = RIAL 219
l NUMBER 001 2231
W
_ c
0 TEXFI :41
TVA IND.
73
�� 2232 \///
Location Map: South Burlington WWTP
From: NC.DOT Planning and Research Map cJ223I
Burlington and Vicinity - 1985 j-7
Scale: 1 inch = 1000 feet
2231
/ \ 4.'
....j South Burlington WWTP,Boy Wood Rd.,Graham, NPDES No.NC0023876
) / 2240
,o

•
BACKWASH
I— —1 WATER
I — .
r ANAEROBIC ANOXIC AERATION l SECONDARY
TANKS -' TANKS TANKS if CLARIFIERS SULFUR DIOXIDE
f ADDITION FOR
SWEPSONVILLE I 'AIR f CHLORINE DECHLORINATION
INFLUENT I
1 I MIXED LIQUOR RECYCLE FOR
RETURN DENITRIFICATION
BURLINGTON I FINAL CHLORINE EFFLUENT
INFLUENT L RETURN ACT. EFFLUENT CONTACT ,
BAR GRIT EQUALIZATION PRIMARY I SLUDGE FILTERS TANK DISCHARGE
SCREEN CHAMBER 1 BASIN V CLARIFIERS WASTE ACTIVATED
—T—r . SLUDGE TO DAF
IBLOWERS 1
L _ _ _ _ _ IAIRL. —
ANAEROBIC ANOXIC AERATION SECONDARY
L.,
r _ TANKS TANKS TANKS —' CLARIFIERS
cc
I r
m
MIXED LIQUOR I RECYCLE FOR
I zi-a RETURN DENITRIFICATION
L RETURN ACTIVATED SLUDGE
WASTE ACTIVATED I
SLUDGE
1
- II
I
I I I 1
I I l I I I I
DAF — AERATED SLUDGE I AEROBIC ' �' _ RESIDUALS TO
THICKENER —- HOLDING TANK DIGESTERS —�I LAND APPLICATION
I I 1 1
L_ I_ i
- LAME —STABILIZED SLUDGE
SUPERNATANT STABILIZATION HOLDING TANK
NOTES: I
I. THE BIOLOGICAL NUTRIENT REMOVAL (BNR) PROCESS �,♦ f
SHOWN IN THIS SCHEMATIC IS ONE OF SEVERAL MODES TO COmP!�S'r Schematic of Wastewater Flow
IN WHICH THE PLANT MAY BE OPERATED. OTHER MODES
OF OPERATION MAY INCLUDE OTHER BNR PROCESSES South Burlington
WHICH ARE CURRENTLY IN USE. d.
2. THE PLANT HAS CAPABILITY FOR CHEMICAL PHOSPHOROUS Wastewater Treatment Plant
LEGEND
REMOVAL WITH ALUM AND pH ADJUSTMENT WITH CAUSTIC. Burlington, Alamance County
CHEMICALS CAN BE ADDED AT VARIOUS LOCATIONS — - Intermittent Operation North Carolina
- —
IN THE PLANT
Juno 1991
South Burlington WWTP,Boy Wood Rd.,Graham, NPDES No.NC0023876

CITY OF BURLINGTON COMPOST FACILITY
COMPOST PROCESSING
BLOCK-FLOW DIAGRAM February 2008
Static Aeration Process (11 aerated piles)
Recycled Screenings
0
Digested Feed
♦___, Stock
iliirl '
Polymer Tank
0 Polymer addition
Curing Pile f
(50 days)
1
V
Screen Belt Press
Finished Compost
Dewatered Sludge
V
(18%solids)
Lab Test0 3:1:1 Mixing ratio
x 1V
4WI $,:r-
a I

The Static Aerated Piles (see process diagram included)
Wastewater treatment residuals from the City of Burlington's South Burlington
Wastewater Treatment Plant are stored on the plant site in tanks that are mixed. These
residuals are pumped through two grinder pumps and a 1500-foot long, 6-inch ductile
iron force main to the compost dewatering building. There the solids are mixed with
polymer and processed on a gravity belt press for dewatering. The dewatered solids
(approximately 18% solids) are then mixed with a bulking agent(wood chips) and
amendments (leaves) to create the feed stock for the building of static aerated piles.
The aerated static piles are constructed under a roof to protect the pile from wind and
rain. Before building the pile, a six (6) to eight(8) inch deep bed of leaves and wood
chips (amendment) is placed to cover an area larger than the pile. This amendment layer
makes an insulating bed underneath the aerated piles. This base or bed is made with a 4
inch perforated airline placed down the center of the bed. The airline is connected to a
blower creating positive or negative pressure so that air can be forced or pulled through
the compost pile. The blowers are controlled by timers that turn them on or off as needed
to supply airflow to the piles. After the biosolids and amendment(wood chips and
leaves) are mixed together, the mixture is placed on the insulating base to build the static
aerated pile and to begin the composting process. The mixture of biosolids and
amendment is then covered with a six to eight(6—8)inch blanket of amendment to
insulate the pile.
After building a pile, a minimum of four(4)thermometers with 48-inch probes are placed
at various locations and depths throughout the pile to monitor the temperatures of the
compost pile. The temperatures are recorded daily to track the composting process.
Results are entered into a database to track each pile with a unique identifier to make sure
it meets the regulatory requirements. The thermometers are left in place during the time
required to achieve compliance with the time and temperature requirements for the
process to further reduce pathogens (PFRP) and for vector attraction reduction. We have
not had any trouble reaching the prescribed time and temperatures. We make sure that
the piles achieve 131 degrees Fahrenheit for a minimum of 3 consecutive days and are
above 104 degrees F and kept at an average of greater than 113 degrees F for a minimum

of 14 consecutive days. Regardless of the time and temperature requirements, we keep
the aerated static piles for a minimum of 21 days and some are kept up to 50 days
depending on storage space and composting conditions.
Curing and stabilization
After the compost has met the requirements for time and temperature on the static aerated
piles, the compost is moved to the curing pile for a minimum of 21 days for further
stabilization. We keep one thermometer in the curing pile(which can be a combination
of several aerated static piles) and record those temperatures as well. We have found that
the curing process often requires more than 21 days and may take as many as 50 days.
Sampling Finished Compost for Fecal Coliform,Nutrients and Metals
After the curing process is completed the material is screened to separate the reusable
amendment from the compost. At this point the finished compost is ready to be sampled
and analyzed for fecal coliform to demonstrate successful pathogen reduction. The
finished compost pile is sampled for fecal coliform in the following manner.
A core sampler is disinfected for use to collect the samples. The core sampler is used to
take core samples within the compost pile at different depths and locations through out
the compost pile to get a good composite sample of the product. We collect four(4)
cores in a sealable plastic bag or sterile fecal bottle to make one composite sample, and
collect a minimum of three(3) composite samples for each batch of finished compost.
That means that we are taking samples of twelve(12) different locations in the pile.
The fecal samples are collected in sterile fecal bottles and are sent directly to the lab for
analysis. The samples are either hand delivered to the City of Burlington wastewater lab
(Certificate No. 188) or shipped to the Summit Environmental Technologies Lab in
Akron, Ohio. A dry solids analysis and the fecal test require about four days turnaround
from sample collection to reporting of the data. Sample results are recorded and
laboratory reports are maintained in the files.

Similar sampling techniques are used to collect samples for nutrient and metals analyses.
Those samples are contained in the sealable plastic bags and sent to A&L Eastern
Agricultural Laboratories, Inc. in Richmond, VA. This data will be used to formulate the
information sheets that are given to the purchaser of the compost. These analyses will be
performed within 60 days of distribution of the finished product, and the results will be
maintained on file.
Test for Re-growth of Fecal Coliform
If the compost is not distributed within 60 days of an acceptable analysis, the pile will be
resampled for fecal coliform using the same technique as above immediately
(approximately one week)prior to distribution.

..,, ANNUAL BIOSOLIDS ANALYSIS REPORT
",C AR.-111141"1112007
PARAMETER JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG
PH UNITS 12.27 11.99 12.27 11.9 11.88 12.2 12.4 12.3 12.3 11.98 12.2
% DRY SOLIDS 3.4 3.22 3.24 3.33 3.56 3.8 4.16 3.48 3.70 3.27 3.48 3.51
NITROGEN (TKN) MG/KG 59400 56800 65700 66100 69900 55500 53600 45700. 48400 59900 59800 58255
PHOSPORUS MG/KG 22300 25300 22400 25300 24100 21000 22200 21200 24800 26800 26200 23782
POTASSIUM MG/KG 4200 3600 5100 6300 5900 4100 3400 3500 4000 7300 5400 4800
SULFUR MG/KG 7200 7000 6500 6500 7000 7300 8000 8800 7600, 8100 6500 7318
CALCIUM MG/KG 80400 107800 82200 86200 75800 120100 121700 91100 103000 88800 111000 97100
MAGNESIUM MG/KG 4500 5500 5000 6200 5300 5200 5100 4300 5000 6500 7000 5418
SODIUM MG/KG 4700 2800 4700 4600 4300 4200 4600 6600 6200 8100 6700 5227
IRON MG/KG 9900 10700 8530 11100 9900 9800 9970 10400 9920 , 8490 9090 9800
ALUMINUM MG/KG 14700 18300 11300 12100 11000 16500 18100 23800 23900 16200 17700 16691
MANGANESE MG/KG 244 237 176 198 200 240 229 232 293 2550 198 436
COPPER MG/KG 253 219 198 209 202 215 245 253 222 263 235 229
ZINC MG/KG 408 363 303 322 330 352 385 460 440 465 418 386
AMMONIA NITROGEN MG/KG 1500 7500 2500 3600 4200 2100 5500 4000 2200 1200 2300 3327
ORGANIC NITROGEN MG/KG 57900 49300 63200 62500 65700 53400 48100 41700 46200 58700 57500 54927
NO3-NO2 NITROGEN MG/KG 865 56 43 48 129 50 34 63 41 <1 <1 148
CADMIUM MG/KG 2 3 1 1 1 2 2 <1 1.1 <5 <5 1.6
CHROMIUM MG/KG 140 94 73 67 76 61 68 59 59 78 88 77
NICKEL MG/KG 19 23 12 15 23 21 19 12 12 18 12 17
LEAD MG/KG 34 28 19 16 22 21 20 22 21 20 17 22
ARSENIC MG/KG 1 1.7 1.5 1.1 0.7 1.6 1.4 2.8 4.1 1.6 3.2 1.9
MERCURY MG/KG 0.9 0.5 1.6 0.9 0.9 1.2 1.10 1.40 1.3 1.2 0.8 1.1
SELENIUM MG/KG 3.1 2.2 2.7 0.5 2.5 2.2 2 4.8 1.6 3.8 1.4 2.4
CALCIUM CARBONATE EQ % 12.55 17.55 11.93 11.48 11.58 19.34 22.78 16.24 17.19 13.27 18.24 15.65
VOLATILE SOLIDS % 66.85 61.7 67.67 68.04 71.08 59.71 58.47 60.77 58.91 63.41 61.46 63.46
MOLYBDENUM MG/KG 13 15 5 <5 8 5 7 5 5 7 5 8
CHLORIDE MG/KG 2820 2810 4950 4360 4210 3990 4920 7340 6270 6760 6350 4980 N
SULFATE MG/KG 912 14130 2315 841 2135 737 2716 1031 581 1498 1008 2537 l
*no sample for the month of october-no biosolids*

ANNUAL COMPOST ANALYSIS REPORT
co; '� t CITY OF BURLINGTON .,. OST FACILITY
,i YEAR 2007
PARAMETER JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG
PH UNITS 6.3 6.5 6.9 7.5 7.2 6.8 6.7
% DRY SOLIDS 59.31 62.79 54.16 84.49 74.48 66.35 59.91 63.07
NITROGEN (TKN) MG/KG 26100 33800 24900 35300 30500- 27700 21300 28486
PHOSPORUS MG/KG 10200 - 11200 10900 12600 8400 8300 8800 10057
POTASSIUM MG/KG 5400 7200 5100 7300 4800, 5300 4800 5700
SULFUR MG/KG 3900 4500 4000 4700 3100 4100 3600 3986
`
CALCIUM MG/KG 17800 17900, 17500 21500 14900, 18800 18500 17814
MAGNESIUM MG/KG 4800 4100 3700 4500 2900 4100 4600 4071
SODIUM MG/KG 600 1100 800 1100 1000 1500 900 1000
IRON MG/KG 13500 7390 10100 8280 5090 9890 19400 10521
ALUMINUM MG/KG 14700 9220 10800 7660 5960 15300 9850 10470
MANGANESE MG/KG 824 687 740 716 467 636 755 689
COPPER MG/KG 130 140 128 147 92 119 109 124
ZINC MG/KG 269 254 246 247 208 222 259 244
AMMONIA NITROGEN MG/KG 3000 3500 5000 6800 5900 4400 5400 4857
ORGANIC NITROGEN MG/KG 23100 30100 19900 28500 24600 23300 15900 23629
NO3-NO2 NITROGEN MG/KG 487 255 282 11 25, 5 4 153
CADMIUM MG/KG 2.0 1.0 1.0 1.0 1.1 <5 <5 1.2
CHROMIUM MG/KG 138 108 107 84 41 110 214 115
NICKEL MG/KG 59 25 41 22 14 40 84 41
LEAD MG/KG 28 18 22 22 12 15 14 19
ARSENIC MG/KG 2.0 1.0 1.2 0.8 2.0 3.3 2.9 1.9
MERCURY MG/KG 0.4 0.5 0.8 0.6 0.4 <0.4 <0.4 0.5
SELENIUM MG/KG 1.4 1.6 1.5 0.9 1.7 2.1 <1.0 1.5
CALCIUM CARBONATE EQ % <0.01 <0.01 <0.01 <0.01 0.84 <0.01 <0.01 0.8
VOLATILE SOLIDS % 69.84 78.83 80.63 81.29 85.26 69.16 64.39 75.633
MOLYBDENUM MG/KG 6 <5 5 <5 <5 <5 <5 8 1
CHLORIDE MG/KG 733 1030 652 1160 872 972 700 874
SULFATE MG/KG 1691 212 380 119 2048 823 <1 879

Project: Burlington compost
TKN 21,300 1st Year Org N
NH3 5,400 2nd Year Org N 2nd Year Min N
NO3 4 3rd Year Org N 3rd Year Min N
Mineralization Rate 0.10 4th Year Org N 4th year Min N
Dry tons/year : 5th Year Min N
NDRLAP, top page 4
lbs PAN/dry ton lbs PAN/dry ton lbs PAN/year lbs PAN/year Year Min Rate
Surface Incorp./Injection Surface Incorp./Injection 1
1st Year 2
5 Year 3
4
NDRLAP, bottom page 4 5
acres required acres required
1st Year 5 year Max.
lbs PAN/yr Surface Incorp. Surface Incorp.
50
100
150
200
RSCA, page 6
mg/kg mg/kg
1st Year 5 Year SAR=
Surface
Incorp./Injection
LEGEND
Fill in this area with data from the analysis sheets
This area is from the annual reports, or old permit
These areas are calculated automatically �1

'.c—
gillSUMMIT
ENVIRONMENTAL TECHNOLOGIES,INC.
Analytical Laboratories
32
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#:
Laboratory ID#: 2- 5
Matrix: Solid
Extraction Method: 1311
Date of Analysis: 1/31/2008
TCLP Metals
Reportlmt Limit Results Regulatory Level
Parameter (ms:ll2 (mg/1) (mat
Arsenic 0.50 <0.5 5.0
Barium 5.0 <5.0 100.0
Cadmium 0.10 <0.1 1.0
Chromium 0.20 <0.2 5.0
Lead 0.50 <0.5 5.0
Mercury 0.0020 <0.002 0.20
Selenium . . - . . . 0.50 <Q.5 1.0
Silver 0.50 <0.5 5.0
"Analytical Integrity" • A2LA Accreditation#0724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohlo 44310 • Phone:[phone] • Fax:[phone]
Web Site:www.settek.com

SUMMIT
I
ENVIRONMENTAL TECHNOLOGIES,INC.
Analytical Laboratories
33
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: Compost
Laboratory ID#: 0801232-05
Matrix: Solid
Extraction Method: 1311
Date of Analysis: 2/1/2008
TCLP Volatiles
Reporting Limit Results Regulatory Level
Parameter (me/L) (mg/L) (mg/L)
1,1-Dichloroethene 0.10 <0.1 0.70
1,2-Dichloroethane 0.10 <0.1 0.50
2-Butanone(MEK) 2.0 <2.0 200.0
Benzene 0.10 <0.1 0.50
Carbon Tetrachloride 0.10 <0.1 0.50
Chlorobenzene 0.10 <0.1 100.0
Chloroform 0.10 . <0.1 6,0
Tetrachloroethene 0.10 <0.1 0.70
Trichloroethene 0.10 <0.1 0.50
Vinyl Chloride 0.20 <0.2 0.20
"Analytical Integrity" • A2LA Accreditation 80724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohio 44310 • Phone:[phone] • Fax:[phone]
Web Site:www.settek.com

i
SIli SUMMIT
ENVIRONMENTAL TECHNOLOGIES,INC.
Analytical Laboratories
34
February 06,2008
Client City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: Compost
Laboratory ID#: 0801232-05
Matrix: Solid
Extraction Method: 1311
Date of Analysis: 2/1/2008
TCLP BNA(1311)
Reporting Limit Regulatory Level
Parameter Im2/11 Ima/li lma/ll
1,4-Dichlorobenzene 0.10 <0.1 7.5
2,4,5-T ichlorophenol 0.25 <0.25 400.0
2,4,6-Trichloropbenol 0.25 <0.25 2.0
2,4-Dinitrotoluene 0.10 <0.1 0.13
Cresols 5.0 <5.0 200.0
Hexachloro-1,3-butadiene 0.10 <0.1 0.50
Hexachlorobenzene 0.10 <0.1 0.13.
Hexachloroethane 0.10 <0.1 3.0
Nitrobenzene 0.10 <0.1 2.0
Pentachlorophenol 0.25 <0.25 100.0
Pyridine 0.25 <0.25 5.0
`Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Talimadge Avenue • Akron,Ohio 44310 • Phone:[phone] • Fax:[phone]
Web Site:www.settek.com

II SUMMIT
S
ENVIRONMENTAL TECHNOLOGIES,INC.
Analytical Laboratories
35
February 06,2008
Client City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: Compost
Laboratory ID#: 0801232-05
Matrix: Solid
Extraction Method: 1311
Date of Analysis: 2/1/2008
TCLP Pesticides
jtepordng Limit &BM Reanlatory Level
Parameter fma/D (ma/ll m d
Chlordane 0.010 <0.01 0.030
Endrin 0.0020 <0.002 0.020
Gamma-BHC 0.0020 <0.002 0.40
Heptachlor 0.0020 <0.002 0.0080
Heptachlor Epoxide 0.0020 <0.002 0.0080
Methoxychlor 0.0020 <0.002 10.0
Toxaphene 0.10 <0.1 0.50
•
"Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohio 44310 • Phone:[phone] • Fax:[phone]
Web Site:www.settek.com

F SUMMIT
mini ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
36
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: Compost
Laboratory ID#: 0801232-05
Matrix: Solid
Extraction Method: 1311
Date of Analysis: 2/6/2008
TCLP Herbicides
Reporting Limit Results Rggnlatory Level
Parameter (mg/1) (nig/1)
2,4,5-TP(Silvex) 0.50 <0.5 1.0
2,4,D 5.0 <5.0 10.0
"Analytical Integrity" . A2LA Accreditation #0724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron,Ohio 44310 • Phone:[phone] • Fax: [phone]
Web Site:www.settek.com

SUMMIT
. ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
37
February 06,2008
Client City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: Compost
Laboratory ID#: 0801232-05
Matrix: Solid
Analyst: AE
Parameter pate of Analysis Results Units Reporting Limit Method
PCBs 1/31/2008 BRL mg/kg 0.2 8082
Reactive Cyanide 1/31/2008 BRL mg/kg 0.5 7.3.3.2
Reactive Sulfide 1/31/2008 BRL mg/kg 25.0 7.3.4.2
•
"Analytical integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Talimadge Avenue • Akron, Ohio 44310 • Phone: [phone] • Fax:[phone]
Web Site:www.settek.com

SUMMIT
S
mi ENVIRONMENTAL TECHNOLOGIES,INC.
Analytical Laboratories
38
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: Compost
Laboratory ID#: 0801232-05
Matrix: Solid
Analyst: CRB
Parameter Method Results pate of Analysis
Flash Point 1010 >140F 1/31/2008
Free Liquid 9095 pass 1/31/2008
pH 9040 7.35 su©14.7C 1/31/2008
"Analytical Integrity" • A2LA Accreditation 80724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohio 44310 • Phone:[phone] • Fax:[phone]
Web Site:www.settek.com

SUMMIT
. ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
11
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: 1
Laboratory ID#: 0801232-02
Matrix: Sludge
Extraction Method: 1311
Date of Analysis: 2/1/2008
TCLP Metals
Reporting Limit Results Regulatory Level
Parameter (mg/1) (mg/1) f mg/1)
Arsenic 0.50 <0.5 5.0
Barium 5.0 <5.0 100.0
Cadmium 0.10 <0.1 1.0
Chromium 0.20 <0.2 5.0
Lead 0.50 <0.5 5.0
Mercury 0.0020 <0.002 0.20
Selenium 0.50 <0.5 1.0
Silver 0.50 <0.5 5.0
"Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohio 44310 • Phone: [phone] • Fax: [phone]
Web Site: www.settek.com

111.-"11...
ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
12
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: South Land App.
Laboratory ID#: 0801232-02
Matrix: Sludge
Extraction Method: 1311
Date of Analysis: 1/31/2008
TCLP Volatiles
Reporting Limit Results Regulatory Level
Parameter (mg/L) (mg/L) (mg/L)
1,1-Dichloroethene 0.10 <0.1 0.70
1,2-Dichloroethane 0.10 <0.1 0.50
2-Butanone(MEK) 2.0 <2.0 200.0
Benzene 0.10 <0.1 0.50
Carbon tetrachloride 0.10 <0.1 0.50
Chlorobenzene 0.10 <0.1 100.0
Chloroform 0.10 <0.1 6.0
Tetrachloroethene 0.10 <0.1 0.70
Trichloroethene 0.10 <0.1 0.50
Vinyl Chloride 0.20 <0.2 0.20
"Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohio 44310 • Phone: [phone] • Fax: [phone]
Web Site: www.settek.com

SUMMIT
. ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
13
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: South Land App.
Laboratory ID#: 0801232-02
Matrix: Sludge
Extraction Method: 1311
Date of Analysis: 2/1/2008
TCLP BNA
Reporting Limit Results Regulatory Level
Parameter (mg/I) img/12 (me/I)
1,4-Dichlorobenzene 0.10 <0.1 7.5
2,4,5-Trichlorophenol 0.25 <0.25 400.0
2,4,6--Trichlorophenol 0.25 <0.25 2.0
2,4-Dinitrotoluene 0.10 <0.1 0.13
Cresols 5.0 <5.0 200.0
Hexachloro-1,3-butadiene 0.10 <0.1 0.50
Hexachlorobenzene 0.10 <0.1 0.13
Hexachloroethane 0.10 <0.1 3.0
Nitrobenzene 0.10 <0.1 2.0
Pentachlorophenol 0.25 <0.25 100.0
Pyridine 0.25 <0.25 5.0
"Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Tailmadge Avenue • Akron, Ohio 44310 • Phone: [phone] • Fax: [phone]
Web Site: www.settek.com

SUMMIT
. ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
14
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: South Land App.
Laboratory ID#: 0801232-02
Matrix: Sludge
Extraction Method: 1311
Date of Analysis: 2/1/2008
TCLP Pesticides
Reporting Limit Results Regulatory Level
Parameter (mg/I) (mg/I) !mz/l)
Chlordane 0.010 <0.01 0.030
Endrin 0.0020 <0.002 0.020
Gamma-BHC 0.0020 <0.002 0.40
Heptachlor 0.0020 <0.002 0.0080
Heptachlor Epoxide 0.0020 <0.002 0.0080
Methoxychlor 0.0020 <0.002 10.0
Toxaphene 0.10 <0.1 0.50
"Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Talimadge Avenue • Akron, Ohio 44310 • Phone: [phone] • Fax: [phone]
Web Site: www.settek.com

gigSUMMIT
. ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
15
February 06,2008
Client: City of Burlington,NC
Address: P.O. Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: South Land App.
Laboratory ID#: 0801232-02
Matrix: Sludge
Extraction Method: 1311
Date of Analysis: 2/1/2008
TCLP Herbicides
Reporting Limit Results Regulatory Level
Parameter (me/11 (mg/1) (mg/il
2,4,5-TP(Silvex) 0.50 <0.5 1.0
2,4,D 5.0 <5.0 10.0
"Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohio 44310 • Phone: [phone] • Fax: [phone]
Web Site: www.settek.com

ill UMMIT
ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
16
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: South Land App.
Laboratory ID#: 0801232-02
Matrix: Sludge
Analyst: AE
Parameter Date of Analysis Results Units Reporting Limit Method
PCBs 1/31/2008 BRL mg/kg 0.2 8082
Reactive Cyanide 1/31/2008 BRL mg/kg 0.5 7.3.3.2
Reactive Sulfide 1/31/2008 BRL mg/kg 25.0 7.3.4.2
"Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohio 44310 • Phone: [phone] • Fax: [phone]
Web Site: www.settek.com

SUMMIT
. ENVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
17
February 06,2008
Client: City of Burlington,NC
Address: P.O.Box 1358
Burlington,NC 27216
Date Collected: 1/28/2008
Date Received: 1/30/2008
Project#: TCLP
Client ID#: South Land App.
Laboratory ID#: 0801232-02
Matrix: Sludge
Analyst: CRB
Parameter Method Results Date of Analysis
Flash Point 1010 >140F 1/31/2008
Free Liquid 9095 Fail 1/31/2008
pH 9040 11.47 su@12.8C 1/31/2008
"Analytical Integrity" • A2LA Accreditation #0724.01 • NELAP Certified
595 East Tallmadge Avenue • Akron, Ohio 44310 • Phone: [phone] • Fax: [phone]
Web Site:www.settek.com

2 - tee
City of Burlington
Laboratory Services
[phone]
Certificate of Analysis
Report Date: 2/16/20107
Sample ID: Finished Pile#17
ID #: 070125
Sample #: D E F F-DUP
Sample Date: 2/12/2007 2/12/2007 2/12/2007 2/12/2007
Sample Time: 740 745 750 750
pH: 7.1 7.0 7.1 7.1
Z Solids: 72.4 71.6 72.0 72.6
Fecal Co/iform: 3 <3 3 6
("f " "_ __ I grin) t tt ¢ a ��'rl v� r^'
Y 4 !A. .�'}r�P �' f.J� � � 1
� .�ue�ua.a<iufvl.'' p"'�+n�1��,,,c .�,...rv»�`',.,...�i;,.� id...., e ,,';i +
Certified by:70G T7
6/ean Mc j rt
Laboratory Supervisor
NC Wastewater Certification #188 NC Water Supply Certification #37612
425 S. Lexington Avenue • P.O. Box 1358 • Burlington,N.C.27216 • [phone] J

Report Number:
R07031-8006 A&L EASTERN LABORATORIES INC.
Account Number:
7621 Whitepine Road•Richmond,Virginia 23237-2296
45475 intL
Phone[phone] • Fax [phone]
Website: www.al-labs-eastern.com•E-mail: [e-mail]
0
TO: CITY OF BURLINGTON FOR: COMPOST FACILITY COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
LAB NUMBER: 40624 REPORT OF ANALYSIS DATE SAMPLED: 1/29/2007 0810
DATE RECEIVED: 1/31/2007 1 100
SAMPLE ID: FT17-070125 DATE REPORTED: 2/6/2007 PAGE: 1
RESULT RESULT DETECTION LIMIT ANALYSIS ANALYSIS
PARAMETER ANALYST METHOD
("' ) (mg/kg) (mg/kg ) DATE TIME
Solids, Total (As is) 59.31 593100 100 KM 02/01/07 16:00 SM 2540G
Nitrogen, Total Kjeldahl 2.61 26100 100 KS 02/01/07 16:00 EPA 351.3
Phosphorus 1.02 10200 100 PC 02/01/07 16:00 SW 846-6010B
Potassium 0.54 5400 100 PC 02/01/07 16:00 SW 846-6010B
Sulfur 0.39 3900 100 PC 02/01/07 16:00 SW 846-6010B
Calcium 1.78 17800 100 PC 02/01/07 16:00 SW 846-6010B
Magnesium 0.46 4600 100 PC 02/01/07 16:00 SW 846-6010B
Sodium 0.06 600 100 PC 02/01/07 16:00 SW 846-6010B
Iron 13500 1 PC 02/01/07 16:00 SW 846-6010B
Aluminum 14700 10 PC 02/01/07 16:00 SW 846-6010B
Manganese 824 1 PC 02/01/07 16:00 SW 846-6010B
Copper 130 1 PC 02/01/07 15:00 SW 846-6010B
Zinc 269 1 PC 02/01/07 16:00 SW846-60106
Nitrogen, Ammonia (as N) 0.30 3000 10 KS 02/01/07 14:00 EPA 350.2
Nitrogen, Organic (N) 2.31 23100 100 DCH CALCULATION
Nitrogen, NO3+NO2 487 1 KS 02/02/07 15:00 SM 4500-NO3F
Cadmium 2.0 1 PC 02/01/07 16:00 SW 846-6010B
Chromium 138 5 PC 02/01/07 16:00 SW 846-6010B
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made P�
to the work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization. """
PAUL C.H.CHU

Report Number:
R07031-8006 A&L EASTERN LABORATORIES INC.
Account Number:
7621 Whitepine Road•Richmond, Virginia 23237-2296
45475 AtL
Phone [phone] • Fax[phone]
Website: www.al-labs-eastern.com • E-mail: [e-mail]
TO: CITY OF BURLINGTON FOR: COMPOST FACILITY COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 1/29f2007 0810
LAB NUMBER: 40624 DATE RECEIVED: 1/31/2007 1100
SAMPLE ID: FT17-070125 DATE REPORTED: 2/6/2007 PAGE: 2
RESULT RESULT DETECTION ANALYSIS ANALYSIS
PARAMETER ANALYST METHOD
( °,„ ) (mgikg) LIMIT (mgikg) DATE TIME
Nickel 59 5 PC 02/01/07 16:00 SW 846-6010B
Lead 28 5 PC 02/01/07 16:00 SW 846-6010B
Arsenic 2.0 0.2 KM 02/05/07 15:00 SW 846-7061A
Mercury 0.4 0.4 KM 02/05/07 15:00 SW 846-7471A
Selenium 1.4 0.2 KM 02/05/07 15:00 SW 846-7741A
pH (Std. Unit, As is) 6.3 0.01 MW 02/01/07 12:30 SW 846-9045C
Calcium Carbonate Equiv (CCE) < 0.01 0 100 MW 02/01/07 15:00 AOAC 955.01
Solids, Volatile(Organic Matter) 69.84 698400 100 KS 02/01/07 16:00 SM 2540G
Molybdenum 6 5 PC 02/01/07 16:00 SW 846-6010B
Chloride 733 10 MW 02/01/07 15:50 SM 4500CL-D
Sulfate SO4 1691 1 JM 02/05/07 15:00 SM 4500 SO4E
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made
to the work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization.
t
PAUL C. H..CHU CHU

City of Burlington
Laboratory services
[phone]
Certificate of Analysis
Report Date: 3/22/2007
Sonipk ID: Finished Pile#18
ID #:070301
Sample #: A B C C-OIJP
Sample Date: 3/19/2007 3/19/2007 3/19/2007 3/19/2007
Sample l7me: 0745 0750 0755 0755
pH: 7.2 7.3 7.3 7.3
Z Solids: 61.5 61.7 62.5 61.2
Fecal Co/ifam: 28 21 80 54
( d'),9n)
1 "----
Certified by: L)(.LL.._ 17
Glenn Mc6irt 1f
Laboratory Supervisor
NC Wastewater Certification 0188 MC Water Sgoply Csrt#fkotian 037612
425 S. Lexington Avenue • P.O. Box 1358 • Burlington,N.C.27216 • [phone]

Report Number:
R07074-8009 A&L EASTERN LABORATORIES, INC.
Account Number:
7621 Whitepine Road•Richmond,Virginia 23237-2296
45475 gitL
Phone[phone] • Fax[phone]
Website: www.al-labs-eastern.com • E-mail: [e-mail]
0
TO: CITY OF BURLINGTON FOR: COMPOST FACILITY COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 3/13/2007 1000
LAB NUMBER: 41466 DATE RECEIVED: 3/15/2007 1130
SAMPLE ID: FP18-070301 DATE REPORTED: 3/21/2007 PAGE: 1
RESULT RESULT DETECTION LIMIT ANALYSIS ANALYSIS
PARAMETER ANALYST METHOD
( io ) (mg/kg) (mg/kg') DATE TIME
Solids, Total (As is) 62.79 627900 100 JM 03/15/07 16:00 SM 2540G
Nitrogen, Total Kjeldahl 3.36 33600 100 JM 03/16/07 16:00 EPA 351.3
Phosphorus 1.12 11200 100 JM 03/16/07 16:00 SW 846-6010B
Potassium 0.72 7200 100 JM 03/16/07 16:00 SW 846-6010B
Sulfur 0.45 4500 100 JM 03/16/07 16:00 SW 846-6010B
Calcium 1.79 17900 100 JM 03/16/07 16:00 SW 846-6010B
Magnesium 0.41 4100 100 JM 03/16/07 16:00 SW 846-6010B
Sodium 0.11 1100 100 JM 03/16/07 16:00 SW 846-6010B
Iron 7390 1 JM 03/16/07 16:00 SW 846-6010B
Aluminum 9220 10 JM 03/16/07 16:00 SW 846-6010B
Manganese 687 1 JM 03/16/07 16:00 SW 846-6010B
Copper 140 1 JM 03/16/07 15:00 SW 846-6010B
Zinc 254 1 JM 03/16/07 16:00 SW846-6010B
Nitrogen, Ammonia (as N) 0.35 3500 10 JM 03/16/07 14:00 EPA 350.2
Nitrogen, Organic (N) 3.01 30100 100 DCH CALCULATION
Nitrogen, NO3+NO2 255 1 DH 03/16/07 15:00 SM 4500-NO3F
Cadmium 1.0 1 JM 03/16/07 16:00 SW 846-6010B
Chromium 108 5 JM 03/16/07 16:00 SW 846-6010B
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made to the work. the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization. ?aj--.
PAUL C. H.CHU

Report Number:
R
8009
A count Number:
A&L EASTERN LABORATORIES, INC.
Account Number:
45475 7621 Whitepine Road•Richmond,Virginia 23237-2296AtIL
Phone [phone] • Fax [phone]
Website: www.al-labs-eastern.com •E-mail: [e-mail]
0
TO: CITY OF BURLINGTON FOR: COMPOST FACILITY COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 3/13/2007 1000
LAB NUMBER: 41466 DATE RECEIVED: 3/15/2007 1 130
SAMPLE ID: FP18-070301 DATE REPORTED: 3/21/2007 PAGE: 2
RESULT RESULT DETECTION ANALYSIS ANALYSIS
PARAMETER ( �, ) (mg/kg) LIMIT(mg/kg) ANALYST DATE TIME METHOD
Nickel 25 5 JM 03/16/07 16:00 SW 846-6010B
Lead 18 5 JM 03/16/07 16:00 SW 846-6010B
Arsenic 1.0 0.2 KM 03/19/07 15:00 SW 846-7061A
Mercury 0.5 0.4 KM 03/16/07 15:00 SW 846-7471A
Selenium 1.6 0.2 KM 03/19/07 15:00 SW 846-7741A
pH (Std. Unit, As is) 6.5 0.01 RD 03/16/07 12:30 SW 846-9045C
Calcium Carbonate Equiv (CCE) < 0.01 0 100 JM 03/16/07 15:00 AOAC 955.01
Solids, Volatile(Organic Matter) 78.83 788300 100 JM 03/20/07 16:00 SM 2540G
Molybdenum < 5 5 JM 03/16/07 16:00 SW 846-6010B
Chloride 1030 10 MW 03/20/07 15:50 SM 4500CL-D
Sulfate SO4 212 1 RD 03/19/07 15:00 SM 4500 SO4E
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made
to the work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization.
PAUL C.H.CHU

City of Burlington
Laboratory Services
[phone]
Certificate of Analysis
Report Date: 5/3/2007
San iv ID: Finished Pile#19
ID #: 070404
Sample #: 6 H I I-DU°
Sample Dole: 4/30/2007 4/30/2007 4/30/2007 4/30/2007
Sample 77ms: 0735 0740 0745 0745
pH: 7.7 7.8 7.7 7.7
X Solids: 60.1 58.5 59.3 60.1
Fecal Col/form: 180 85 840 180
(MPN/d y gvvn)
Certified by:
Glenn •
Laboratory Supervisor
NC Wastewater Certification#188 NC Water Supply CCrNficeWan 037612
425 S. Lexington Avenue • P.O.Box 1358 • Burlington,N.C. 27216 • [phone]

Report Number:
R07107-8003 A&L EASTERN LABORATORIES, INC.
Account Number: 7621 Whitepine Road•Richmond,Virginia 23237-2296
45475 Phone[phone] • Fax[phone] glitIL
Website: www.al-labs-eastern.com •E-mail: [e-mail]
c)
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE#19 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 4/10/2007 0930
LAB NUMBER: 42173 DATE RECEIVED: 4/17/2007 1000
SAMPLE ID: FP 19 070404 DATE REPORTED: 4/20/2007 PAGE: 1
RESULT RESULT DETECTION LIMIT ANALYSIS ANALYSIS
PARAMETER ANALYST METHOD
(% ) (mg/kg) (mg/kg') DATE TIME
Solids, Total (As is) 54.16 541600 100 JM 04/17/07 16:00 SM 2540G
Nitrogen, Total Kjeldahl 2.49 24900 100 MW 04/19/07 16:00 EPA 351.3
Phosphorus 1.09 10900 100 JM 04/18/07 16:00 SW 846-6010B
Potassium 0.51 5100 100 JM 04/18/07 16:00 SW 846-6010B
Sulfur 0.40 4000 100 JM 04/18/07 16:00 SW 846-6010B
Calcium 1.75 17500 100 JM 04/18/07 16:00 SW 846-6010B
Magnesium 0.37 3700 100 JM 04/18/07 16:00 SW 846-6010B
Sodium 0.08 800 100 JM 04/18/07 16:00 SW 846-6010B
Iron 10100 1 JM 04/18/07 16:00 SW 846-6010B
Aluminum 10800 10 JM 04/18/07 16:00 SW 846-6010B
Manganese 740 1 JM 04/18/07 16:00 SW 846-6010B
Copper 128 1 JM 04/18/07 15:00 SW 846-6010B
Zinc 246 1 JM 04/18/07 16:00 SW846-6010B
Nitrogen, Ammonia (as N) 0.50 5000 10 JM 04/18/07 14:00 EPA 350.2
Nitrogen, Organic (N) 1.99 19900 100 DCH CALCULATION
Nitrogen, NO3+NO2 282 1 DH 04/18/07 15:00 SM 4500-NO3F
Cadmium 1.0 1 JM 04/18/07 16:00 SW 846-6010B
Chromium 107 5 JM 04/18/07 16:00 SW 846-6010B
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made O/
to the work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization. ' l-
PAUL C. H.CHU

Report Number:
R07107-8003 A&L EASTERN LABORATORIES, INC.
Account Number: 7621 Whitepine Road•Richmond,Virginia 23237-2296
45475 Phone[phone] • Fax [phone] in
Website: www.al-labs-eastern.com•E-mail: [e-mail]
0
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE#19 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 4/10/2007 0930
LAB NUMBER: 42173 DATE RECEIVED: 4/17/2007 1000
SAMPLE ID: FP 19 070404 DATE REPORTED: 4/20/2007 PAGE: 2
RESULT RESULT DETECTION ANALYSIS ANALYSIS
PARAMETER (°„ ) (mg/kg) LIMIT(mg/kg) ANALYST DATE TIME METHOD
Nickel 41 5 JM 04/18/07 16:00 SW 846-6010B
Lead 22 5 JM 04/18/07 16:00 SW 846-6010B
Arsenic 1.2 0.2 KM 04/18/07 15:00 SW 846-7061A
Mercury 0.8 0.4 KM 04/19/07 15:00 SW 846-7471A
Selenium 1.5 0.2 KM 04/18/07 15:00 SW 846-7741A
pH (Std. Unit, As is) 6.9 0.01 RD 04/18/07 12:30 SW 846-9045C
Calcium Carbonate Equiv (CCE) < 0.01 0 100 JM 04/20/07 15:00 AOAC 955.01
Solids, Volatile(Organic Matter) 80.63 806300 100 JM 04/18/07 16:00 SM 2540G
Molybdenum 5 5 JM 04/18/07 16:00 SW 846-6010B
Chloride 652 10 MW 04/19/07 15:50 SM 4500CL-D
Sulfate SO4 380 1 RD 04/20/07 15:00 SM 4500 SO4E
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made P
to the work. the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization.
PAUL C. H. CHU

c City of Burlington
Laboratory Services PI-.
4..,_. ...,k,[phone] d� D
Certificate of Analysis
Report Date: 6/22/Zi007
Sample ID: Finished Pile#20
ID #: 070530
Sample #: D E F F-DUP
Sample Date: 6/18/2007 6/18/2007 6/18/2007 6/18/2007
Sample Time: 730 735 740 740
pH: 7.5 7.4 7.5 7.5
Z Solids: 65.9 66.8 78.1 65.9
Fecal Co/iform: 530 420 450 531
(MPN/dry grm)
Certified by: / xt7z_
4-
/ Glenn M Tit
Laboratory Supervisor
A!C Wastewater Certification #188 MC Water Supply Certification#37612
425 S. Lexington Avenue • P.O. Box 1358 • Burlington,N.C.27216 • [phone] J

Report Number:
R07163-8007 A&L EASTERN LABORATORIES, INC.
Account Number: 7621 Whitepine Road•Richmond,Virginia 23237-2214
45475 Phone[phone] • Fax[phone] At
Website: www.al-labs-eastern.com•E-mail:[e-mail]
n
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE#20 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 6/8/2007 1300
LAB NUMBER: 43100 DATE RECEIVED: 6/12/2007 1000
SAMPLE ID: FINISHED COMPOST PILE 20 DATE REPORTED: 6/15/2007 PAGE: 1
RESULT RESULT DETECTION LIMIT ANALYSIS ANALYSIS
PARAMETER m Ik m Ik ANALYST DATE TIME METHOD
(`)b ) ( 9 y) ( 9 g'l
Solids, Total (As is) 64.49 644900 100 JM 06/12/07 16:00 SM 2540G
Nitrogen, Total Kjeldahl 3.53 35300 100 JM 06/13/07 16:00 EPA 351.3
Phosphorus 1.26 12600 100 JM 06/13/07 16:00 SW 846-3051/6010B
Potassium 0.73 7300 100 JM 06/13/07 16:00 SW 846-3051/6010B
Sulfur 0.47 4700 100 JM 06/13/07 16:00 SW 846-3051/6010B
Calcium 2.15 21500 100 JM 06/13/07 16:00 SW 846-3051/6010B
Magnesium 0.45 4500 100 JM 06/13/07 16:00 SW 846-3051/6010B
Sodium 0.11 1100 100 JM 06/13/07 16:00 SW 846-3051/6010B
Iron 8280 1 JM 06/13/07 16:00 SW 846-3051/6010B
Aluminum 7660 10 JM 06/13/07 16:00 SW 846-3051/6010B
Manganese 716 1 JM 06/13/07 16:00 SW 846-3051/6010B
Copper 147 1 JM 06/13/07 15:00 SW 846-3051/6010B
Zinc 247 1 JM 06/13/07 16:00 SW 846-3051/6010B
Nitrogen, Ammonia (as N) 0.68 6800 10 JM 06/13/07 14:00 EPA 350.2
Nitrogen, Organic (N) 2.85 28500 100 DCH CALCULATION
Nitrogen, NO3+NO2 11 1 KS 06/14/07 15:00 SM 4500-NO3F
Cadmium 1.0 1 JM 06/13/07 16:00 SW 846-3051/6010B
Chromium 84 5 JM 06/13/07 16:00 SW 846-3051/6010B
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made 64
to the work. the results,or the company in any advertising,news release, or other public announcements without obtaining our prior written authorization. -
PAUL C. H.CHU

Report Number:
R07163-8007 A&L EASTERN LABORATORIES, INC.
Account Number: 7621 Whitepine Road•Richmond,Virginia 23237-2214
45475 Phone[phone] • Fax[phone] gm
Website: www.al-labs-eastern.com•E-mail: [e-mail]
n
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE #20 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 6/8/2007 1300
LAB NUMBER: 43100 DATE RECEIVED: 6/12/2007 1000
SAMPLE ID: FINISHED COMPOST PILE 20 DATE REPORTED: 6/15/2007 PAGE: 2
RESULT RESULT DETECTION ANALYSIS ANALYSIS
PARAMETER ( `',;, ) (mg/kg) LIMIT(mg/kg) ANALYST DATE TIME METHOD
Nickel 22 5 JM 06/13/07 16:00 SW 846-3051/6010B
Lead 22 5 JM 06/13/07 16:00 SW 846-3051/6010B
Arsenic 0.8 0.2 KM 06/14/07 15:00 SW 846-7061A
Mercury 0.6 0.4 KM 06/13/07 15:00 SW 846-7471A
Selenium 0.9 0.2 KM 06/14/07 15:00 SW 846-7741A
pH (Std. Unit, As is) 7.5 0.01 RD 06/13/07 12:30 SW 846-9045C
Calcium Carbonate Equiv (CCE) < 0.01 0 100 MW 06/13/07 15:00 AOAC 955.01
Solids, Volatile(Organic Matter) 81.29 812900 100 KS 06/13/07 16:00 SM 2540G
Molybdenum < 5 5 JM 06/13/07 16:00 SW 846-3051/6010B
Chloride 1160 10 JM 06/13/07 15:50 SM 4500CL-D
Sulfate SO4 119 1 RD 06/13/07 15:00 SM 4500 SO4E
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part,nor may any reference be made n P�,
to the work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization. •elA """
PAUL C. H. CHU

i City of Burlington
Labo ata y Services
[phone]
Certificate of Analysis
Report Date: 8/17/2007
Sample ID: Finished Pile#21
ID #: 070724
Sample #: D E F F--DL/P
Sample Date: 8/14/2007 8/14/2007 8/14/2007 8/14/2007
Sample Tune: 730 735 740 740
pH: 7.4 7.4 7.4 7.4
Z Solids: 71.9 72.2 73.0 72.0
Fecal Co/ifa m: <3 11 <3 3
(14PN/dry grm)
Certified by: p '
AIp1 f
, _
6Aenh i•t
Laboratory Supervisor
NC Wastewater Certification #188 MC Water Supply Certification #37612
425 S. Lexington Avenue • P.O. Box 1358 • Burlington,N.C.27216 • [phone]

Report Number:
R07221-8004 A&L EASTERN LABORATORIES, INC.
Account Number: 7621 Whitepine Road•Richmond,Virginia 23237-2214
45475 Phone[phone] • Fax[phone] gitoisi
Website: www.al-labs-eastern.com•E-mail:[e-mail]
n
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE #21 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 8/6/2007 0745
LAB NUMBER: 44028 DATE RECEIVED: 8/9/2007 1030
SAMPLE ID: 070724-FP21 DATE REPORTED: 8/15/2007 PAGE: 1
RESULT RESULT DETECTION LIMIT ANALYSIS ANALYSIS
PARAMETER a (mg/kg) m ikc ANALYST DATE TIME METHOD
(°` 1 { 9 J�)
Solids, Total (As is) 74.48 744800 100 DH 08/09/07 16:00 SM 2540G
Nitrogen, Total Kjeldahl 3.05 30500 100 MW 08/10/07 16:00 EPA 351.3
Phosphorus 0.84 8400 100 DH 08/10/07 16:00 SW 846-3051/6010B
Potassium 0.48 4800 100 DH 08/10/07 16:00 SW 846-3051/6010B
Sulfur 0.31 3100 100 DH 08/10/07 16:00 SW 846-3051/6010B
Calcium 1.49 14900 100 DH 08/10/07 16:00 SW 846-3051/6010B
Magnesium 0.29 2900 100 DH 08/10/07 16:00 SW 846-3051/6010B
Sodium 0.10 1000 100 DH 08/10/07 16:00 SW 846-3051/6010B
Iron 5090 1 DH 08/10/07 16:00 SW 846-3051/6010B
Aluminum 5960 10 DH 08/10/07 16:00 SW 846-3051/6010B
Manganese 467 1 DH 08/10/07 16:00 SW 846-3051/6010B
Copper 92 1 DH 08/10/07 15:00 SW 846-3051/6010B
Zinc 208 1 DH 08/10/07 16:00 SW 846-3051/6010B
Nitrogen, Ammonia (as N) 0.59 5900 10 MW 08/10/07 14:00 EPA 350.2
Nitrogen, Organic (N) 2.46 24600 100 DCH CALCULATION
Nitrogen, NO3+NO2 25 1 DH 08/10/07 15:00 SM 4500-ND3F
Cadmium 1.1 1 DH 08/10/07 16:00 SW 846-3051/6010B
Chromium 41 5 DH 08/10/07 16:00 SW 846-3051/6010B
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made O/
to the work. the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization. l
PAUL C. H.CHU

Report Number:
R07221-8004 A&L EASTERN LABORATORIES, INC.
Account Number: 7621 Whitepine Road•Richmond,Virginia 23237-2214
45475 Phone[phone] • Fax[phone] At
Website: www.al-labs-eastern.com•E-mail:[e-mail]
0
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE #21 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 8/6/2007 0745
LAB NUMBER: 44028 DATE RECEIVED: 8/9/2007 1030
SAMPLE ID: 070724-FP21 DATE REPORTED: 8/15/2007 PAGE: 2
RESULT RESULT DETECTION ANALYSIS ANALYSIS
PARAMETER ( °/ ) (mg/kg) LIMIT(mg/kg) ANALYST DATE TIME METHOD
Nickel 14 5 DH 08/10/07 16:00 SW 846-3051/6010B
Lead 12 5 DH 08/10/07 16:00 SW 846-3051/6010B
Arsenic 2.0 1.0 DH 08/10/07 15:00 SW 846-6010B
Mercury 0.4 0.4 JM 08/10/07 15:00 SW 846-7471A
Selenium 1.7 1.0 DH 08/10/07 15:00 SW 846-6010B
pH (Std. Unit, As is) 7.21 0.01 RD 08/10/07 12:30 SW 846-9045C
Calcium Carbonate Equiv (CCE) 0.84 8400 100 KS 08/14/07 15:00 AOAC 955.01
Solids, Volatile(Organic Matter) 85.26 852600 100 KS 08/10/07 16:00 SM 2540G
Molybdenum < 5 5 DH 08/10/07 16:00 SW 846-3051/6010B
Chloride 872 10 MW 08/13/07 15:50 SM 4500CL-D
Sulfate SO4 2048 1 RD 08/10/07 15:00 SM 4500 SO4E
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made P
to the work. the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization.
PAUL C. H.CHU

r City of Burlington
Laboratory Services
[phone]
Certificate of Analysis
Report Date: 10/9/2007
Sample ID: Finished Pile#22
ID #: 070925
Sample #: A B C C-OUP
Sample Daft: 10/2/2007 10/2/2007 10/2/2007 10/2/2007
Sample Time: 0735 0740 0745 0745
pH: 6.9 6.9 6.9 6.9
Z Solids: 62.8 62.7 61.7 62.6
Decal Co/iforin: 3 175 6 <3
(MPN/dry grin)
Certified by:A(i , P
Glenn Mc6irt
Laboratory Supervisor
NC Wastewater Certification#188 NC Water Syga/y Certification#37612
425 S. Lexington Avenue • P.O. Box 1358 • Burlington,N.C.27216 • [phone]

Report Number:
R07276-8004 A&L EASTERN LABORATORIES, INC.
Account Number: 7621 Whitepine Road•Richmond,Virginia 23237-2214
45475 Phone[phone] • Fax[phone] eltiC
Website: www.al-labs-eastern.com•E-mail:[e-mail]
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE #22 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 10/1/2007 0830
LAB NUMBER: 44880 DATE RECEIVED: 10/3/2007 1200
SAMPLE ID: FINISHED COMPOST PILE 22 DATE REPORTED: 10/10/2007 PAGE: 1
RESULT RESULT DETECTION LIMIT ANALYSIS ANALYSIS
PARAMETER (mg/kg ANALYST DATE TIME METHOD
( °�. ) (mg/kg) Ikc( 9 J�1
Solids, Total (As is) 66.35 663500 100 JM 10/03/07 16:00 SM 2540G
Nitrogen, Total Kjeldahl 2.77 27700 10 DH 10/04/07 16:00 EPA 351.3
Phosphorus 0.83 8300 100 JM 10/04/07 16:00 SW 846-3051/6010B
Potassium 0.53 5300 100 JM 10/04/07 16:00 SW 846-3051/6010B
Sulfur 0.41 4100 100 JM 10/04/07 16:00 SW 846-3051/6010B
Calcium 1.86 18600 100 JM 10/04/07 16:00 SW 846-3051/6010B
Magnesium 0.41 4100 100 JM 10/04/07 16:00 SW 846-3051/6010B
Sodium 0.15 1500 100 JM 10/04/07 16:00 SW 846-3051/6010B
Iron 9890 1 JM 10/04/07 16:00 SW 846-3051/6010B
Aluminum 15300 10 JM 10/04/07 16:00 SW 846-3051/6010B
Manganese 636 1 JM 10/04/07 16:00 SW 846-3051/6010B
Copper 119 1 JM 10/04/07 15:00 SW 846-3051/6010B
Zinc 222 1 JM 10/04/07 16:00 SW 846-3051/6010B
Nitrogen, Ammonia (as N) 0.44 4400 10 DH 10/04/07 14:00 EPA 350.2
Nitrogen, Organic (N) 2.33 23300 100 DCH CALCULATION
Nitrogen, NO3+NO2 5 1 KS 10/05/07 15:00 SM 4500-NO3F
Cadmium < 5 5 JM 10/04/07 16:00 SW 846-3051/6010B
Chromium 110 5 JM 10/04/07 16:00 SW 846-3051/6010B
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made
to the work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization.
PAUL C.H.CHU

Report Number:
R07276-8004 A&L EASTERN LABORATORIES, INC.
Account Number: 7621 Whitepine Road•Richmond,Virginia 23237-2214
45475 Phone[phone] • Fax[phone] At
Website: www.al-labs-eastem.com•E-mail:[e-mail]
IJ
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE #22 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 1O/1/2007 0830
LAB NUMBER: 44880 DATE RECEIVED: 10/3/2007 1200
SAMPLE ID: FINISHED COMPOST PILE 22 DATE REPORTED: 10/10/2007 PAGE: 2
RESULT RESULT DETECTION ANALYSIS ANALYSIS
PARAMETER LIMIT m /kc ANALYST DATE TIME METHOD
( `i„ I (mg/kg) l 9 �1
Nickel 40 5 JM 10/04/07 16:00 SW 846-3051/6010B
Lead 15 5 JM 10/04/07 16:00 SW 846-3051/6010B
Arsenic 3.3 1.0 JM 10/04/07 15:00 SW 846-6010B
Mercury < 0.4 0.4 KM 10/10/07 15:00 SW 846-7471A
Selenium 2.1 1.0 JM 10/04/07 15:00 SW 846-6010B
pH (Std. Unit, As is) 6.84 0.01 RD 10/04/07 12:30 SW 846-9045C
Calcium Carbonate Equiv (CCE) < 0.01 0 100 MW 10/05/07 15:00 AOAC 955.01
Solids, Volatile(Organic Matter) 69.16 691600 100 DH 10/04/07 16:00 SM 2540G
Molybdenum < 5 5 JM 10/04/07 16:00 SW 846-3051/6010B
Chloride 972 10 RD 10/05/07 15:50 SM 4500CL-D
Sulfate SO4 823 1 RD 10/05/07 15:00 SM 4500 SO4E
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made P�
to the work. the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization. ,
PAUL C. H.CHU

City of Burlington
Laboratory Services
[phone]
Certificate of Analysis
Report Date: 12/20/2007
Sample ID: Finished Pile#23
ID #: 071206
Sample #: A B C C-DUP
Sample Daft: 12/17/2007 12/17/2007 12/17/2007 12/17/2007
Sample Time: 800 805 810 810
pH: 7.4 7.6 7.5 7.5
X Solids: 73.6 75.2 73.5 73.2
Fecal Co/iform: 12 5 10 10
(MPN/dry grin)
Certified by: LCIA o
Glems Mc6irt 61&/24-)(1P &L/
Laboratory Supervisor l 0//(\1
AIC Wastewater Certification 0188 MC Water 5iq p lr Csrtifkaticn#37612
425 S. Lexington Avenue • P.O.Box 1358 • Burlington,N.C.27216 • [phone] J

Report Number:
R07354-8003 A&L EASTERN LABORATORIES, INC.
Account
Account Number: t
454757621 Whitepine Road•Richmond,Virginia 23237-2214 gi
Phone[phone] • Fax[phone]
Website: www.al-labs-eastern.com•E-mail:[e-mail]
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE#23 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 12/19/2007 0900
LAB NUMBER: 46101 DATE RECEIVED: 12/20/2007 1000
SAMPLE ID: FINISHED COMPOST DATE REPORTED: 1/4/2008 PAGE: 1
RESULT RESULT DETECTION LIMIT ANALYSIS ANALYSIS
PARAMETER m Ik m /kc j ANALYST DATE TIME METHOD
(°,i, ) ( 9 g) ( 9 .�
Solids, Total (As is) 59.91 599100 100 JM 12/20/07 16:00 SM 2540G
Nitrogen, Total Kjeldahl 2.13 21300 10 JM 12/21/07 16:00 EPA 351.3
Phosphorus 0.88 8800 100 KM 12/21/07 16:00 SW 846-3051/6010B
Potassium 0.48 4800 100 KM 12/21/07 16:00 SW 846-3051/6010B
Sulfur 0.36 3600 100 KM 12/21/07 16:00 SW 846-3051/6010B
Calcium 1.65 16500 100 KM 12/21/07 16:00 SW 846-3051/6010B
Magnesium 0.46 4600 100 KM 12/21/07 16:00 SW 846-3051/6010B
Sodium 0.09 900 100 KM 12/21/07 16:00 SW 846-3051/6010B
Iron 19400 1 KM 12/21/07 16:00 SW 846-3051/6010B
Aluminum 9650 10 KM 12/21/07 16:00 SW 846-3051/6010B
Manganese 755 1 KM 12/21/07 16:00 SW 846-3051/6010B
Copper 109 1 KM 12/21/07 15:00 SW 846-3051/6010B
Zinc 259 1 KM 12/21/07 16:00 SW 846-3051/6010B
Nitrogen, Ammonia (as N) 0.54 5400 10 JM 12/21/07 14:00 EPA 350.2
Nitrogen, Organic (N) - 1.59 15900 100 DCH CALCULATION
Nitrogen, NO3+NO2 4 1 KS 12/21/07 15:00 SM 4500-NO3F
Cadmium < 5 5 KM 12/21/07 16:00 SW 846-3051/6010B
Chromium 214 5 KM 12/21/07 16:00 SW 846-3051/6010B
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made
to the work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization.
PAUL C.H.CHU

Report Number:
R07354-8003 A&L EASTERN LABORATORIES, INC.
Account Number: L
454757621 Whitepine Road•Richmond,Virginia 23237-2214 git
Phone[phone] • Fax[phone]
Website: www.al-labs-eastern.com•E-mail:[e-mail]
TO: CITY OF BURLINGTON FOR: FINISHED COMPOST PILE#23 COPY: DAVID CHURCH
POB 1358
BURLINGTON, NC 27216-1358 NC CERT#257
ATTN: DAVID CHURCH
REPORT OF ANALYSIS DATE SAMPLED: 12/19/2007 0900
LAB NUMBER: 46101 DATE RECEIVED: 12/20/2007 1000
SAMPLE ID: FINISHED COMPOST DATE REPORTED: 1/4/2008 PAGE: 2
RESULT RESULT DETECTION ANALYSIS ANALYSIS
PARAMETER m /k LIMIT mclk I ANALYST DATE TIME METHOD
( 'r ) ( g gl ( g g
Nickel 84 5 KM 12/21/07 16:00 SW 846-3051/6010B
Lead 14 5 KM 12/21/07 16:00 SW 846-3051/60106
Arsenic 2.9 1.0 KM 12/21/07 15:00 SW 846-6010B
Mercury < 0.4 0.4 KM 12/21/07 15:00 SW 846-7471A
Selenium < 1.0 1.0 KM 12/21/07 15:00 SW 846-6010B
pH (Std. Unit, As is) 6.69 0.01 RD 12/21/07 12:30 SW 846-9045C
Calcium Carbonate Equiv (CCE) < 0.01 0 100 JM 12/21/07 15:00 AOAC 955.01
Solids, Volatile(Organic Matter) 64.39 643900 100 JM 12/21/07 16:00 SM 2540G
Molybdenum < 5 5 KM 12/21/07 16:00 SW 846-3051/6010B
Chloride 700 10 JM 12/21/07 15:50 SM 4500CL-D
Sulfate SO4 < 1 1 JM 01/03/08 15:00 SM 4500 SO4E
All values are on a dry weight basis except as noted. *Detection Limit on all N series is on a wet basis
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or in part.nor may any reference be made p,,L
.. e,,,_
to the work, the results, or the company in any advertising, news release,or other public announcements without obtaining our prior written authorization.
PAUL C. H.CHU

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Date: March 26, 2008 County: Alamance
To: Aquifer Protection Section Central Office Permittee: City of Burlington
Central Office Reviewer: Alice Wessner, Land Application UnitProject Name: City of Burlington
Compogro Composting Facility and Distribution Program
Regional Login No: Application No.: W00021632
I. GENERAL INFORMATION
1. This application is(check all that apply): ❑New ® Renewal
❑ Minor Modification❑ Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
[' Land Application of Residuals ❑Attachment B included ® 503 regulated ❑ 503 exempt
® Distribution of Residuals ❑ Surface Disposal
❑ Closed-loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or❑No.
a. Date of site visit: 02/20/2008
b. Person contacted and contact information: David Church, Residuals Management Coordinator, City of
Burlington Composting Facility, Phone [phone]. Since David Church will be retiring soon the new
facility contact will be Stephen Shoaf, PO BOX 1358, Burlington,NC 27216,phone [phone]
c. Site visit conducted by: Derek Denard, APS-WSRO
d. Inspection Report Attached: ® Yes or❑No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ®No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location: Correct
b. Driving Directions: Correct
c. USGS Quadrangle Map name and number: Correct
d. Latitude: 36 01' 23" Longitude: 79 22' 16"
e. Regulated Activities/Type of Wastes(e.g., subdivision, food processing, municipal wastewater):
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s): N/A
b. Driving Directions: N/A
c. USGS Quadrangle Map name and number: N/A
d. Latitude: N/A Longitude: N/A
IL NEW AND MAJOR MODIFICATION APPLICATIONS(this section not needed for renewals or minor
modifications,skip to next section)
Description Of Waste(S)And Facilities
FORM: Burlington Compost WQ0021632 03-26-08 APSRSR 0904.doc 1

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
1. Please attach completed rating sheet. Facility Classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
❑ Yes ❑No ❑N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑No ❑N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑No ❑N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient)acceptable?
❑ Yes ❑No ❑N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or ❑No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions(Certification B?)
III. RENEWAL AND MODIFICATION APPLICATIONS(use previous section for new or major modification
systems)
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or❑No.
Operator in Charge: N/A Certificate#:
Backup-Operator in Charge: N/A Certificate#:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ® Yes or ❑ No.
If no,please explain:
FORM: Burlington Compost WQ0021632 03-26-08 APSRSR 0904.doc 2

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or❑No. If no, please explain: N/A
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain: NO
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
® Yes or ❑No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable?. ❑ Yes or ❑ No. If no, please
explain: N/A
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ® N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑No ®N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ® No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct?
Yes or ❑No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ® N/A. If no, please explain:
12. Has a review of all self-monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑No ❑N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; ® Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV,NOD etc): See attachment of NOV for the 2007 Annual Report for
Partial TCLP with no Herbicides, Pesticides, Corrosivity, Reactivity, or Ignitability.
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ® Yes
❑No ❑Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ®No ❑ N/A. If yes, please explain:
FORM: Burlington Compost WQ0021632 03-26-08 APSRSR 0904.doc 3

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
IV. INJECTION WELL PERMIT APPLICATIONS(Complete these two sections for all systems that use injection
wells, including closed-loop groundwater remediation effluent injection wells, in situ remediation injection wells,and heat
pump injection wells.)
Description Of Well(S) And Facilities—New, Renewal,And Modification
1. Type of injection system:
❑ Heating/cooling water return flow(5A7)
❑ Closed-loop heat pump system(5QM/5QW)
❑In situ remediation(5I)
❑ Closed-loop groundwater remediation effluent injection(5L/"Non-Discharge")
❑ Other(Specify: )
2. Does system use same well for water source and injection? ❑ Yes ❑No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ❑No
What is/are the pollution source(s)? . What is the distance of the injection well(s) from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? ft.
5. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site(property lines, wells, surface drainage)? ❑ Yes or❑No. If
no or no map,please attach a sketch of the site. Show property boundaries, buildings, wells,potential pollution
sources,roads, approximate scale, and north arrow.
Injection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation(e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑No. If yes, explain:
2. For closed-loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? LI Yes ❑No. If yes, explain:
3. For renewal or modification of groundwater remediation permits(of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑No. If yes, explain:
4. Drilling contractor: Name:
FORM: Burlington Compost WQ0021632 03-26-08 APSRSR 0904.doc 4

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
FORM: Burlington Compost WQ0021632 03-26-08 APSRSR 0904.doc 5

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
V. EVALUATION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: According to the application the
City Burlington wishes to delete the East Burlington Wastewater Plant NPDES NC0023868 as a source
generating facility for this permit.
2. Attach Well Construction Data Sheet-if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ®No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s): �..J 1e/:e.
Signature of APS regional supervisor: 1't{/N-t
Date: 3/2 Pik
.
FORM: Burlington Compost WQ0021632 03-26-08 APSRSR 0904.doc 6

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
• FORM: Burlington Compost WQ0021632 03-26-08 APSRSR 0904.doc 7

NIAMichael F Easley,Governor
re 9oG William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
Coleen H.Sullins,Director
Division of Water Quality
0
March 12, 2008
Mr.David Church
City of Burlington
PO Box 1358
Burlington,NC 27216
SUBJECT: February 20,2008 Compliance Evaluation Inspection
City of Burlington Residuals Land Application Program
Permit No: WQ0000520
City of Burlington CompoGro Composting Facility and Distribution Program
Permit No: WQ0021632
J.D.Mackintosh,Jr. WTP—Burlington Agri Supplement Distribution Program
Permit No: WQ0021534
Alamance County
Dear Mr. Church:
Enclosed please find copies of the Compliance Evaluation Inspection forms from the inspection conducted
on February 20,2008. The Compliance Evaluation Inspection was conducted by Derek Denard of the
Winston-Salem Regional Office. Present for the inspection was David Church,Residuals Management
Coordinator. Also present for the inspection was Marshall Puryear and Harry Stanfield with Synagro
Southeast. The facilities were found to be in Compliance with permits WQ0000520, WQ0021632, and
WQ0021534.
Please refer to the enclosed inspection reports for additional observations and comments. If you or your
staff have any questions,please call Derek Denard at 336-771-5286.
Sincerely,
G`L Y i 4--
Sherri V.Knight,P.E.
Regional Aquifer Protection Supervisor
cc: Marshall Puryear,Technical Services Manager,
Synagro Southeast,284 Boger Rd.,Mocksville,NC 27028
Alamance County Health Department
APS Central Files
Winston-Salem Files
Noy` Carolin
)aturallb
Division of Water Quality/Aquifer Protection Section Customer Service
585 Waughtown Street,Winston-Salem NC 27107 1-877-623-6748
Phone: [phone] Fax: [phone] Internet: http://www.ncwaterqualitv.org
An Equal Opportunity/Affirmative Action Empbyer—50%Recycled/10%Post Consumer Paper

Compliance Inspection Report
Permit: WQ0021632 Effective:09/26/03 Expiration:08/31/08 Owner:City of Burlington
SOC: Effective: Expiration: Facility:City of Burlington CompoGro Composting
County:Alamance Epilitig6A9Wrkftion Program
Region:Winston-Salem
Graham NC 27253
Contact Person: Harold T. Owen Title: City Manager Phone:[phone]
Directions to Facility:
Take NC Hw. 87 South off of 1-85(Exit 147). Proceed on NC Hwy. 87 South, and bear•left onto Swepsonville Road.At Boywood Road,
iRe19rtagifieliffittio the VVV TP is 0.25 miles on the right
Primary ORC: Certification: Phone:
Secondary ORC(s):
David Church Certification:13188 Phone:[phone]
On-Site Representative(s):
Related Permits:
Inspection Date: 02/20/2008 Entry Time:01:00 PM Exit Time:02:00 PM
Primary Inspector: Derek Denard Phone:[phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type:Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: • Compliant 0 Not Compliant
Question Areas:
■Miscellaneous Questions ■Record Keeping •Treatment ■Sampling
■Pathogen and Vector ■Storage
Attraction
(See attachment summary)
Page: 1

Permit:W00021632 Owner-Facility:City of Burlington
Inspection Date: 02/20/2008 inspection Type:Compliance Evaluation Reason for Visit:Routine
Inspection Summary:
PERMIT
Distribution of Residual Solids (503) Permit W00021632 if for the construction and operation of a 5.5-dry ton per day
facility for the aerated static pile composting of residuals generated from the treatment of municipal wastewater at the
facilities listed in Condition II. 3. and consisting of the following minimum components: two pump/grinder units for
transferring residuals form the existing digestors/storage tanks (i.e., permitted for operation under NPDES Permit No.
NC0023876)to dewatering; one two meter belt filter press, with a berth for a second two-meter belt filter press for a
parallel operation, for dewatering of the residuals; one conveyor for transferring dewatered residuals to the amendment
mixing area;one 25,500-square foot open area for storing amendment material; one 1,875-square foot covered are for
storing amendment material; one 1,710-square foot covered area for blending for the residuals with the amendment
material as well as homogenizing and uniform mixing of the residuals/amendment cake (i.e., at a three to one amendment
material to residuals ratio); one agricultural feed mixer for blending of the residuals with the amendment material as well as
homogenizing and uniform mixing of the residuals/amendment cake(i.e., at three to one amendment material to residuals
ratio); one 35,700-square foot covered area for composting of the residuals/amendment cake in a maximum of 22 aerated
static piles, each with a trapezoidal dimensions of seven feet in height, 12 feet in width, and 80 feet in length; one
under-bed aeration system, consisting of 11 five-horsepower blowers (i.e., one blower for every two aerated static piles) as
well as perforated pipe distribution system that is overlain by eight to 12 inches of amendment material for aerating of the
composting residuals/amendment cake; one 153-cubic yard per/day trammel screen for screening of the composted
residuals/amendment cake and recovering bulking material; one 2,225-square foot bunker for storing composted
residuals/amendment cake; one 625-square foot bunker for storing recovered bulking material; one 15,000-square foot
open area for final curing and maturation of the composted residuals/amendment cake and for storing of the Class A EQ
residuals product; one odor control system, consisting one 900-square foot biofilter and one 4,900-square foot biofilter, for
capturing and treating odor generating within the residuals composting facility; all necessary measuring devices to ensure
that all of the composted residuals/amendment cake meets the requirements listed in Condition I. 11.; as well as all
associated controls, support structures, piping, and appurtenances necessary to make a complete and functional residuals
composting facility and Class A EQ residuals product distribution program; and continued operation of a program for the
distribution of up to 2,250 dry tons per year of a Class A EQ residuals product marketed as CompoGro.
RECORD KEEPING AND SELF-MONITORING
The City of Burlington had the 2007 Annual Report on file and available for review. The 2007 Annual Report will be
reviewed and addressed in separate correspondence from this inspection.
The most current metals and nutrient analysis was on 12/17/07. The last TCLP analysis was taken on 1/28/08 and was
available for review. Hauling records were up-to-date with 2/15/08 being the last record of a load being hauled from the
compost facility.
PATOGEN AND VECTOR ATTRACTION
Class A:Alternative 5& Option 5-Compost
Noted during the inspection was that the compost piles had temperatures ranging from 135 to 155 F. Thermometers were
kept in 4 locations in each compost pile and the piles were flagged that had met the pathogen/vector method to be ready
for hauling.
TREATMENT
Compost. As noted in the previous inspection,the belt press, treatment and storage area for composting was very well
kept and very clean which far exceeded other facilities of this type.
Page: 2

Permit:WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 02/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Routine
STORAGE
Dry stack on covered concrete. See facility description above for more details.
SAMPLING
Four grab samples are taken to produce a composite sample. This procedure is repeated to produce 3 composite
samples.
TRANSPORT
The City of Burlington uses a delivery invoice/pickup receipt to document the distribution of compost.A spill plan is also
kept that applies to all the City's residuals permits.
LAND APPLICATION SITE
N/A
OTHER
The previous inspection of the facility was conducted by Derek Denard of this office on 04/19/2007.
Page: 3

Permit:WO0021632 Owner-Facility:City of Burlington
Inspection Date: 02/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Routine
Type Yes No NA NE
Land Application 0
Distribution and Marketing ■
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? 0 0 • 0
Are GW samples from all MWs sampled for all required parameters? 0 0 ■ 0
Are there any GW quality violations? ❑ 0 • 0
Is GW-59A certification form completed for facility? 0 0 ■ 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)? 0 0 • 0
Are PAN balances being maintained? 0 0 ■ 0
Are PAN balances within permit limits? 0 0 • 0
Has land application equipment been calibrated? ❑ ❑ ■ 0
Are there pH records for alkaline stabilization? 0 0 ■ 0
Are there pH records for the land application site? ❑ ❑ ■ 0
Are nutrient/crop removal practices in place? 0 0 ■ 0
Do lab sheets support data reported on Residual Analysis Summary? 0 0 0 ■
Are hauling records available? . 000
Are hauling records maintained and up-to-date? ■ ❑ ❑ ❑
#Has permittee been free of public complaints in last 12 months? ■ ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? 0 0 ■ 0
Comment: See summary for comments.
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E(Class A or B) 00 . 0
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) 0 0 • 0
Page: 4

Permit:WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 02/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Routine
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) 0 0 ■ 0
c. pH records for alkaline stabilization(Class B) 0 0 ■ 0
Temperature corrected 0
d. Salmonella(Class A, all test must be< 3MPN/4 gram day) ❑ ❑ ■ ❑
e. Time/Temp on: ■ ❑ ❑ ❑
Digester(MCRT) 0
Compost . . ■
Class A lime stabilization 0
f. Volatile Solids Calculations ❑ ❑ ■ ❑
g. Bench-top Aerobic/Anaerobic digestion results 0 0 • 0
Comment: See summary for comments.
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion ■
Anaerobic Digestion ❑
Alkaline Pasteurization(Class A) ❑
Alkaline Stabilization(Class B) ❑
Compost ■
Drying Beds ❑
Other ❑
Comment: See summary for comments.
Sampling Yes No NA NE
Describe sampling:
Four grab samples are taken to produce a composite sample. This procedure is repeated to produce 3
composite samples.
Is sampling adequate? U ❑ ❑ ❑
Is sampling representative? U ❑ ❑ ❑
Comment: See summary for comments.
Page: 5

O� W A Ti Michael F.Easley,Governor
WWilliam G.Ross Jr.,Secretary
0� OG North Carolina Department of Environment and Natural Resources
rColeen H.Sullins,Director
7 Division of Water Quality
o
March 26, 2008
CERTIFIED MAIL#7003 3110 0003 7134 0432
RETURN RECEIPT REQUESTED
Mr. David Church
City of Burlington
PO Box 1358
•
Burlington,NC 27216
Subject: NOTICE OF VIOLATION
Annual Report Review
City of Burlington CompoGro Composting Facility and Distribution Program
Permit No: WQ0021632
Alamance County
Dear Mr. Church:
The annual report for the City of Burlington CompoGro Composting Facility and Distribution Program for
the year 2007 was received by this office on February 26, 2008. Review of the annual report found the
facility to be in violation of permit WQ0021632 for the following:
• The Toxicity Characteristics Leaching Procedure (TCLP) taken for all three sources (East
Burlington WWTP, South Burlington WWTP, and Mackintosh WTP)listed in Permit Condition III.
4. did not include the following parameters: Pesticides: Chlordane, Endrin, Lindane, Heptachlor
(and its hydroxide), Methoxychlor and Toxaphene. Herbicides: 2,4,5-TP(Silvex) and 2,4-D. The
corrosivity, ignitability,and reactivity analysis were also omitted.
It was noted that a full TCLP was taken on January 28, 2008 after the omission was discovered. Review of
this data indicated compliance with the regulatory levels noted in Permit Condition III. 5.
Another issue noted in the review of the annual report was that the calculations for Plant Available Nitrogen
(PAN)did not match our calculations based on the data provided. The equation we used was the following:
PAN= [(MR)x(TKN—NH3)] + [0.5 x(NH3)] +(NO3-NO2-N). (Please see the attached pages from the
Land Application of Residuals Operators Manual April 2005 p. 6-6 and 6-7). It appears that the formula
used in the annual report multiplies 0.5 with NO3-NO2-N, which may explain the results. Attached please
fmd an example copy of a spreadsheet used to check the calculation for data taken on 12/19/07. In addition,
please fmd a copy of the PAN Calculation Worksheet from the 2007 annual report with our results written
below the reported PAN value. If your calculations are in error, please recalculate PAN and resubmit the
worksheet in your response to this letter.
No`hCarolina
,NafurallM
Division of Water Quality/Aquifer Protection Section Customer Service
585 Waughtown Street,Winston-Salem NC 27107 1-877-623-6748
Phone: [phone] Fax: [phone] Internet: http:/I mvw.ncwaterqualitv.ore
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

Mr. Church
March 26,2008
Page 2 of 2
To prevent further action, carefully review these violations and deficiencies and respond in writing to this
office within thirty (30) working days of receipt of this letter. You should address the causes of
noncompliance and all actions taken to prevent the recurrence of similar situations. If you should have any
questions, please do not hesitate to contact Derek Denard or me at 336-771-5286.
Sincerely,
PA-r. f�
Sherri V.Knight,P.
Regional Aquifer Protection Supervisor
cc: Alamance County Health Department V
Ed Hardee,Land Application Unit
APS Central Files
Winston-Salem Files

Compliance Inspection Report
Permit: WQ0021632 Effective: 09/26/03 Expiration: 08/31/08 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington CompoGro Composting
Facility and Distribution Program
County: Alamance 2471 Boy Wood Rd
Region: Winston-Salem
Graham NC 27253
Contact Person: Harold T. Owen Title: City Manager Phone: [phone]
Directions to Facility:
Take NC Hw. 87 South off of 1-85(Exit 147). Proceed on NC Hwy. 87 South,and bear left onto Swepsonville Road.At Boywood Road,
bear n htt. The ntrance to the WWTP is 0.25 miles on the right
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
David Church Certification: 13188 Phone:[phone]
On-Site Representative(s):
Related Permits:
Inspection Date: 03/20/2008 Entry Time: 09:00 AM Exit Time: 06:00 PM
Primary Inspector: Derek Denard Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type:Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids(503)
Facility Status: 0 Compliant • Not Compliant
Question Areas:
11 Miscellaneous Questions Record Keeping ■Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit:WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 03/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Follow-up
Inspection Summary:
ANNUAL REPORT REVIEW •
Reporting Period: 2007
Permit Details:
• Land Application or Distribution? Distribution
• Is 503? 503
• Class A or B?A
• Maximum Dry Tons Per Year: 2,250
• Number of acres permitted: N/A
• Counties that land is permitted for: N/A
• Monitoring Frequency for TCLP:Annually
• Monitoring Frequency for Residuals Analysis: 540.6 (319<=DT/yr<1,650) gives Once per Quarter
• Monitoring Frequency for Pathogen &Vector Attraction Reduction: Once per Quarter
Annual Report Review Class A Distribution
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted?YES
• Was distribution conducted during the reported period?YES
• How many dry tons were distributed?540.6
• Were the distributions with the permitted amount?YES
• Were recipients information listed?YES
• Did it indicate compliance? NO, Incomplete TCLP
• Was form complete?YES
• Was it signed by the appropriate people?YES
2. Monitoring
• Were the analyses conducted at the required frequency?YES
• Were the metals analyses reported on the Residual Sampling Summary Form?YES
Were the results reported in mg/kg?YES
• Were the metals within ceiling concentration permit limits?YES
• Were the metals within monthly average concentration permit limits?YES
• If no, were the lab analyses attached?YES
• Were all the required parameters tested?YES (Residuals Analysis), NO (TCLP)
• Was TCLP analysis conducted? Partial TCLP with no Herbicides, Pesticides, Corrosivity, Reactivity, or Ignitability. TCLP
resampled on 1/28/08.
• Were the TLCP contaminants with regulatory limits?YES
Comments: PAN calculations did not match our results.
Page: 2

Permit:WQ0021632 Owner-Facility: City of Burlington
Inspection Date: 03/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Follow-up
3. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?YES
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction alternative and the vector
attraction reduction option used?YES, Class A: Alternate 5, Option 5
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the report?YES
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503? YES
4.General
• Was the report in the proper format?YES
• Were any parts of the annual report missing? YES
Was the report submitted on time?YES, Received on February 20, 2008
•
Class A Pathogen Review
To be Class A, residuals shall meet either fecal Coliform density of salmonella density.
Fecal Coliform density
• Was the sampling conducted at the required frequency?YES
• Were multiple samples taken? 21 •
• Was each sample less than 1000 MPN/gram of total solids? YES
OR
Salmonella density
• Was the sampling conducted at the required frequency? N/A
• Were multiple samples taken? N/A
• Was each sample less than 3 MPN/4 grams of total solids? N/A
To be Class A, residuals shall meet one of the following alternatives:
Alternative 5—Process To Further Reduce Pathogens
PFRP Composting
• Were the within-vessel method or static aerated pile methods used?YES
• Was the residuals temperature maintained at 55°C (131°C) or higher for three consecutive days or longer in the
within-vessel method or static aerated pile method? YES
OR
Was the windrow composting method used? N/A
• Was the residuals temperature maintained at 55°C or higher or 15 consecutive days or longer in the windrow method,
and the windrow turned a minimum of five times during this time? N/A
Page: 3

Permit:WO0021632 Owner-Facility:City of Burlington
Inspection Date: 03/20/2008 Inspection Type:Compliance Evaluation Reason for Visit: Follow-up
Type Yes No NA NE
Land Application
Distribution and Marketing ■
Record Keeping Yes No NA NE
Is GW monitoring being conducted,if required? 0 0 •
Are GW samples from all MWs sampled for all required parameters? 0 0 ■ 0
Are there any GW quality violations? 0 0 •
Is GW-59A certification form completed for facility? 0 0 • 0
Is a copy of current permit on-site? 0 0 0 •
Are current metals and nutrient analysis available? ■ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters? ■ 0 0 0
a. TCLP analysis? U ❑
00
b. SSFA(Standard Soil Fertility Analysis)? 0 0 • 0
Are PAN balances being maintained? • 0 0
0
Are PAN balances within permit limits? • 0 0 0
Has land application equipment been calibrated? 0 0 • 0
Are there pH records for alkaline stabilization? 0 0 • 0
Are there pH records for the land application site? 0 0 • 0
Are nutrient/crop removal practices in place? 0 0 • 0
Do lab sheets support data reported on Residual Analysis Summary? U 0 ❑
Are hauling records available? U 0 ❑ 0
Are hauling records maintained and up-to-date? ■ ❑ ❑
#Has permittee been free of public complaints in last 12 months? ■ ❑ ❑ 0
Has application occurred during Seasonal Restriction window? U 0 0 ❑
Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E(Class A or B) ❑ ❑ U ❑
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 0
Fecal coliform SM 9222 D(Class B only) 0 0 • 0
Page: 4

Permit:W00021632 Owner-Facility: City of Burlington
Inspection Date: 03/20/2008 Inspection Type:Compliance Evaluation Reason for Visit:Follow-up
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 001110
Comment:
Page: 5

STEP ONE: Determine the amount of Plant Available Nitrogen (PAN) in
the residuals to be applied.
• First, calculate PAN in residuals using one of the following formulas:
1) PAN for surface application
PAN = [(MR) x (TKN- NH3)] + [.5 x (NH3)] + (NO3-NO2-N)
2) PAN for Subsurface application •
PAN = [(MR) x (TKN-NH3)] + (NH3) + (NO3-NO2-N)
Factors and units for the equations are as follows:
PAN= Plant Available Nitrogen in ppm (or mg/kg)
TKN=Total Kjeldahl Nitrogen in ppm (or mg/kg)
NH3 = Ammonia Nitrogen in ppm (or mg/kg)
NO3-NO2-N =Nitrate and Nitrite Nitrogen in ppm (or mg/kg)
MR = mineralization rates (based on type of stabilization technology used at the
wastewater treatment plant that produced the residuals)for the first year's PAN:
Composted = 0.1
Anaerobically Digested = 0.2
Aerobically Digested = 0.3
Unstabilized Primary and Waste Activated= 0.4
Example:
According to the laboratory report, the residuals you plan to land apply contain
following concentrations of TKN, NH3 and NO3-NO2-N:
TKN 52,100 mg/kg
NH3 1,552 mg/kg
NO3-NO2-N 525 mg/kg
Your planned application method is surface application and the residuals were
anaerobically digested. Calculate the pounds of plant available nitrogen (PAN)
per dry ton of residuals.
6-6

Solution:
PAN = [(MR) x (TKN - NH3)] + [.5 x (NH3)] + (NO3-NO2-N)
PAN = [(0.2) x (52,100 - 1,552)] + [.5 x (1,552)] + (525)
PAN = (0.2 x 50,548) + 776 + 525
PAN = 10110 + 776 + 525
PAN = 11,411 mg/kg dry residuals
• Next, convert mg/kg to lbs/dry ton using the following formula:
mg/kg x .002 = lbs/dry ton (.002 is from 2000 lbs/ton)
PAN (lbs/dry ton residuals) = 11,411 mg/kg x .002
PAN = 22.82 lbs/dry ton residuals
Thus, there are 22.82 pounds of plant available nitrogen in each dry ton of residuals to be
applied. This figure includes the amount of organic N that will become plant available
during the first year of residuals application.
STEP TWO: Determine the "nitrogen needs" of the crop to be grown.
The following list shows examples of maximum crop utilization rates:
Crop PAN (lb/acre/yr)
Alfalfa 200
Bermuda Grass (Hay, Pasture) 220
Blue Grass 120
Corn (Grain) 160
Corn (Silage) 200
Cotton 70
Fescue 250
Forest (Hardwood and Softwood) 75
Milo 100
Small Grain (Wheat, barley, oats) 100
Sorghum, Sudex (Pasture) 180
Sorghum, Sudex (Silage) 220
Soybeans 200
Timothy, Orchard & Rye Grass 200
STEP THREE: Determine nitrogen "carry-over" for a three-year period.
•
Remember that, in addition to containing plant available nitrogen or PAN, residuals also
contain organic nitrogen that is not readily available to crops. As organic nitrogen is
mineralized (broken down by microorganisms), more and more nitrogen becomes plant
6-7

PAN
Mineralization as decimal 'Total dry Acres
Rate TKN NH3 NO3 NO2 % Solids tons/year Applied on
0.1 21300 5400 4
PAN Surface MR(TKN-NH3)+ + .5(NH3)+NO3+NO2 =mg/kg
4294 mg/kg 8.588 lbs/dry ton
0 lbs total PAN mg/kg x .002 =Ibs/dry ton
#DIV/0! lbs PAN/acre
PAN Injection MR(TKN-NH3) + 1(NH3)+NO3+NO2 =mg/kg
6994 mg/kg 13.988 lbs/dry ton
0 lbs total PAN mg/kg x.002 =Ibs/dry ton
#DIV/0! lbs PAN/acre
Dry Tons/1000 gal. 1000 X 8.34 X %solids X sp. gravity "=dry tons/1000gal."
0 2000
1st year PAN Ibs./acre
Surface lbs. Surface
0 #DIV/0!
1st year PAN lbs./acre •
Injected lbs. Injected
0 #DIV/0!

sc-
City of Burlington CompoGro Composting Facility
PAN Calculation Worksheet
Permit# W00021632 Phone: [phone]
Reporting Period:2007 County: Alamance
4 Date of Analysis 1/29/2007 3/13/2007 4/10/2007 6/8/2007
TKN 26,100 33,600 24,900 35,300
Ammonia-Nitrogen 3,000 3,500 5,000 6,800
Nitrate and Nitrite 487 255 282 11
PAN* 4,305 5,212 5,103 6,934
Lr2” SC.)/ 197/ -- (22Li
Date of Analysis 8/6/2007 10/1/07 12/19/2007
TKN 30,500 27,700 21,300
Ammonia-Nitrogen 5,900 4,400 5,400 .
Nitrate and Nitrite 25 5 4
PAN* 6,010 4,972 4,832 _
units are expressed as mg/kg unless indicated otherwise
*PAN is a calculated value obtained by using the formula: PAN=MR(TKN-NH3)+0.5(NH3+NO2-NO3-N)
a mineralization rate(MR)of 0.1 was used to make these calculations
The information used to calculate the PAN values were obtained from laboratory analysis.
A&L Laboratories(NC certification#257)provided the TKN,Ammonia and Nitrate/Nitrite values for the seven analysis
r: conducted during 2007.
File:Compost Annual PVRF 2007.xls
ri
Tab:PAN

O�O�(W A TF9G Michael F.Easley,Governor
RECEIVED
N.C.Dept.of ENR William G.Ross Jr.,Secretary
r� North Carolina Department of Environment and Natural Resources
MAR I 2008
-c Coleen H.Sullins Director
inston-Salom Division of Water Quality
Regional Office
March 6, 2008
HAROLD OWEN
CITY OF BURLINGTON
PO BOX 1358
BURLINGTON,NC 27216-1358
Subject: Acknowledgement of Application No. WQ0021632
City of Burlington CompoGro Composting
Distribution of Residual Solids(503)
Alamance County
Dear MR. OWEN:
The Aquifer Protection Section of the Division of Water Quality(the Division)acknowledges receipt of
your permit application and supporting materials on February 28,2008. This application package has
been assigned the number listed above and will be reviewed by Alice Wessner.
The reviewer will perform a detailed review and contact you with a request for ad&cional information if
necessary. To ensure the maximum efficiency in processing permit applications,the Division requests
your assistance in providing a timely and complete response to any additional information requests.
Please be aware that the Division's Regional Office,copied below,must provide recommendations prior
to final action by the Division. Please also note at this time, processing permit applications can take as
long as 60-90 days after receipt of a complete application. To check on the status of your application,
you can visit http://h2o.enr.state.nc.us/bims/reports/reportsPermits.html.
If you have any questions,please contact Alice Wessner by phone at(919)715-5208 or by email at
[e-mail]. If the reviewer is unavailable,you may leave a message and they will respond
promptly. Also note that the Division has reorganized. To review our new organizational chart, go to
http://h2o.enr.state.nc.us/documents/dwq orgchart.pdf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES
ON THIS PROJECT.
Sincerely,
For Kim H. Colson, P.E.
Supervisor
cc: iliimion-Salem Regional Office,Aquifer Protection Section
APS Central Files-Application No.WQ0021632
Stephen Shoaf,PO Box 1358,Burlington,NC 27215
One
N Carolina
%atura!!y
Aquifer Protection Section 1636 Mail Service Center Raleigh,NC 27699-1636 Telephone: [phone]
Internet:www.ncwaterquality.org Location: 2728 Capital Boulevard Raleigh,NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper Customer Service: [phone]

BURLINGTON-WQ0021632-COMPOST imap://[e-mail]:143/fetch%3EUID%3E/INB...
Subject: BURLINGTON-WQ0021632-COMPOST
From: Steve Mauney <[e-mail]>
Date: Tue, 12 Aug 2003 15:03:03 -0400
To: Shannon Thornburg <[e-mail]>
CC: Kim Colson<[e-mail]>, Mike Mickey <[e-mail]>
SHANNON-Steve Shoaf called to complain about our recent enforcement against the City which he said
could likely have been avoided if the compost permit had been issued. Who knows, he may be right. He
indicated that the compost application was submitted over a year ago and the additional information
was provided timely. He also expressed concern that the letters to Dennis Ramsey from the City Mgr.
dated April 3, 2003 and May 20, 2003 were never answered. They did reference the wrong permit
(WQ0021534). His quote of the day, " Fines come out faster than permits." Any help with this one
will certainly be appreciated.
As a side note he also asked about the status of the application for land applying residuals which was
submitted October 2002. We have not gotten a copy of that one to review.-Steve
Steve Nauney
NC DENR Winston-Salem Regional Office
Division of Water Quality, " ater Quality Section
585 1•:auchtown Street
Winston-Salem, NC 27107
Voice: (336) 771-3608 ext 262
FAX: (336) 771-4630
1 of 1 8/13/2003 3:58 PM

,GIONN043 City of Burlington
• n
t,-w POST OFFICE Box 1358 HAROLD OWEN
O BURLINGTON, NORTH CAROLINA 27216-1358o CITY MANAGER
RECEIVED
TELEPHONE:[phone]
.14169- FACSIMILE: [phone] N.C. Dept. of F-HNR
E-MAIL: [e-mail]
MAY 2 2 2003
May20, 2003 Winst :l-; aiem
Rego
it
Mr. Dennis Ramsey
Py
NCDENR/DWQ/Non-Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
ko3_
Subject: Application for Non-Discharge Permit WQ0021.5S.4._
City of Burlington Compost Facility— South Burlington Wastewater Plant
Burlington, NC; Alamance County
Dear Mr. Ramsey,
In July 2002, the City of Burlington completed the submittal of a permit
application for a non-discharge permit. The intent of the permit application was to cover
the production of, and distribution of a compost material made of yard waste, wood
chips, and dewatered biosolids. This material is being processed to meet the 40 CFR 503
Class A requirements for biosolids disposal.
Enclosed is a copy of a letter that we sent to you during the first week of April
2003. In that letter we asked that the permit for our compost operation be signed and
issued to the City. We also requested that any problems with the application or requests
for further information be addressed in a letter and not be used as a reason to further
delay the permit.
It has now been over 10 months since our permit application was submitted as
complete. The failure to process our application is having an economic impact on the
City. We had included some revenue from the sale of compost in our budget to offset the
cost of operating the compost facility. Springtime is the time for maximum interest in the
purchase of compost by landscapers and homeowners. We felt that we had submitted our
application in time to meet the expected demand that we are now witnessing.
The City understands the constraints of tight budgets and inadequate staffing.
This letter in no way is intended to reflect negatively on the capabilities or performance
of the reviewing engineer. However, this type of permit should notbe difficult to review
and process. Essentially the federal regulations dictate the requirements. Much if not the
entire permit should be boilerplate. On March 12, 2003 the City was told that the permit
application review would be completed by the following week.

With this letter the City is asking that you expedite the completion of the review
and send us a signed permit immediately. If there are any questions that have arisen
during the review, we are requesting that they be included in a letter as items to be
addressed, and that they do not further delay the issuance of the permit.
We anticipated that our previous letter would have elicited some response. We
have delayed the sale of compost while waiting for your reply to that letter. The lack of a
response on the part of NCDENR is disturbing.
Thank you for your cooperation in the past. The City does feel that our request is
fair and does not endanger the public health of our community nor the environment. I
look forward to your rapid response.
Since ,
Harold Owen
City Manager
CC. Kim H. Colson, Supervisor, Non-Discharge Permitting Unit
Shann Thornbur - • ermitting Unit
Stephen Shoaf, Director of Utilities, City of Burlington NC
Robert Ward, Attorney, City of Burlington

Re:Burlington Compost? imap /Mike.Micke"isms.ncmail.net:143/fetch%3EUID%3E/INB...
Subject: Re: Burlington Compost?
From: Shannon Thornburg <[e-mail]>
Date: Wed, 12 Mar 2003 16:49:36-0500
To: Mike Mickey <[e-mail]>
Mike (I have always wanted to ask you if you have ever considered the
nickname M3?) ,
Steve and I have, unfortunately been playing telephone tag for about two
weeks. I e-mailed him about this very issue earlier today. I told him that
I was about halfway through my review and should have comments to him by the
end of next week. I only have very minor issues that require resolution at
this point, so I think that we can proceed to permit issuance very quickly.
I am sorry that you got cornered. . .
Shannon
Mike Mickey wrote:
Hi Shannon - I am writing to inquire about the status of Burlington's
Compost permit. (Yep - you guessed it. ) Steve Shoaf cornered me today
with that question during a water plant inspection. I just checked our
file and didn't see anything since the staff report dated 8/28/02. Can
they consider their 90 days to be up and go ahead and start distributing
without the permit? Thanks, Mike.
Mike Mickey
NC DENR Winston-Salem Regional Office
Division of Water Quality, Water Quality Section
585 Waughtown Street
Winston-Salem, NC 27107
Voice: (336) 771-4608 ext 264
FAX: (336) 771-4630
1 of 1 3/12/2003 5:12 PM

°.,° . 4) City of Burlington
hit..17:a1W
n9POST OFFICE BOX1358 HAROLD OWEN
OCITY MANAGER
�. V \ BURLINGTON, NORTH CAROLINA 27216-1358
TELEPHONE:[phone]
•14 'a9� FACSIMILE: [phone]
E-MAIL: [e-mail]
April 3, 2003
I:MCC eutSik Pie
,VSO CO
Mr. Dennis Ramsey N.C•
NCDENR/DWQ/Non-Discharge Branch ppR - 1 2003
1617 Mail Service Center
Raleigh, NC 27699-1617 NjfSt0 _ a1�t'�
c iggiOtia4 Q
f� _
Subject: Application for Non-Discharge Permit WQ0021N4
City of Burlington Compost Facility—South Burlington Wastewater Plant
Burlington, NC; Alamance County
Dear Mr. Ramsey,
In July 2002, the City of Burlington completed the submittal of a permit
application for a non-discharge permit. The intent of the permit application was to cover
the production of, and distribution of a compost material made of yard waste, wood
chips, and dewatered biosolids. This material is being processed to meet the 40 CFR 503
Class A requirements for biosolids disposal.
We started the test batches last September and continued testing and processing
through the winter to learn how to process the compost and to demonstrate to ourselves
that we could meet the Class A requirements of both process description and final
product testing. We now have finished compost that meets the regulations as a Class A
product.
It has now been over 8 months since our permit application was submitted as
complete. The failure to process our application is starting to have an economic impact
on the City. We had included some revenue from the sale of compost in our budget to
offset the cost of operating the compost facility. Springtime is the time for maximum
interest in the purchase of compost by landscapers and homeowners. We felt that we had
submitted our application in time to meet the expected demand that we are now
witnessing.
Stephen Shoaf, Utilities Director for the City has spoken to several employees of
NCDENR about the delays in receiving a permit. He reports that there are severe
personnel constraints in your agency. However, the contacts he has made also say that
this type of permit should not be difficult to review and process. Essentially the federal
regulations dictate the requirements. Much if not the entire permit should be boilerplate.

The City understands the constraints of tight budgets and inadequate staffing.
This letter in no way is intended to reflect negatively on the capabilities or performance
of the reviewing engineer. The reviewer has been contacted and made aware of our
interest. On March 12, 2003 the City was told that the permit application review would
be completed by the following week. Again we feel that the delays are due to problems
with state funding and personnel constraints. The City does however want to receive a
signed permit in a timely manner.
With this letter the City is asking that you expedite the completion of the review
and send us a signed permit immediately. If there are any questions that have arisen
during the review, we are requesting that they be included in a letter as items to be
addressed, and that they do not further delay the issuance of the permit. Also, with this
letter the City is informing you that we are beginning to use the finished compost for
demonstration purposes at some of our City-owned facilities. We have records showing
that the product met Class A requirements and we are maintaining records of where that
compost is being used. If we have not received a response from you before the end of
April 2003, we will begin the sale of compost to outside entities as availability allows.
Thank you for your cooperation in the past. The City does feel that our request is
fair and does not endanger the public heath of our community nor the environment. I
look forward to your rapid response.
Sincerely,
tarold7Owen
City Manager
CC: Kim H. Colson, Supervisor, Non-Discharge Permitting Unit
Shannon Thornburg, EE II, Non-Discharge Permitting Unit
tep en Sho. i erector o I ies, ity of Burlington NC
Robert Ward. Attorney, City of Burlington

I Hobbs, Upchurch & Associates, P.A.
Ul
11110 Consulting Engineers
300 S.W.Broad Street • Post Office Box 1737 • Southern Pines,NC 28388
C.
November'29,2002 �- r- • .GT E H N
DEC _2 �;.,
Mrs. Shannon Thornburg,P.E.
Non-Discharge Permit Group Winston-:
Division of Water Quality :r.'-'
1617 Mail Service Center Raglflna/ Ch}ce
Archdale Building
• Raleigh,NC 27699-1617
Re: City of Burlington
Permit No.WQ0021632
NPDES Permit No.NC000023876
Alamance County,NC
Dear Mrs.Thornburg:
Please find attached my professional engineer's certification for construction of the City of
Burlington Sludge Compost Facility at the South Burlington Wastewater Treatment Plant.
English Construction Company,Inc. and Electrical Construction,Inc. are both substantially
complete with this project and the City of Burlington has accepted the Sludge Compost Facility
construction and placeditheproject into operation�l 'he City is currently making compost, testing
the amen ents and inixttfes•and momtorii sults to determine when the compost meets
the Class A uirements`of the 503 re ation will report the results to your office with the
appropriate documentation.
If you have any questions about this matter please contact me at our Southern Pines office.
Sincerely,
HOBBS, UPCHURCH&ASSOCIATES, P.A.
Michael Wicker,P.E.
Project Manager
End:
cc: Steve Shoaf,City of Burlington
Larry Coble,Winston-Salem Regional Office a
Allen Hamblen,English Construction Company,Inc.
Terry Nichols,Electrical Construction,Inc.
Steve Breedlove,HUA
BU9802/Permits/300
Southern Pines,NC • Telephone [phone] • Fax [phone] • e-mail:[e-mail]
Myrtle Beach • Nags Head • Raleigh • Charlotte • Beaufort

PROFESSIONAL ENGINEER'S STATEMENT
I, Michael C. Wicker, P.E. , as a duly registered Professional
Engineer in the State of North Carolina, having been authorized to observe
FULL TIME the construction of the project.
City of Burlington,N.C. Sludge Composting Facility
(PROJECT NAME)
South Burlington WWTP, Burlington, NC
(PROJECT LOCATION)
WQ0021632
(PERMIT NO.)
for the CITY OF BURLINGTON
(OWNER)
hereby states that with the best of my abilites, due care and diligence was used in
the observation of the project construction such that the construction was observed
to be built within substantial compliance and intent of the approved plans and
specifications.
SIGNATURE 0. L ` -
REGISTRATION NO. 11325 DATE 11/29/02
N
. r-
'4,

Permits Pending Layout 2 11/20/02
Permit Permit
Number Facility Name Owner Type Permit Type Project Type Status App Rec County Primary Reviewer Region
WO0021121 Abbotts Creek Interceptors and Force Mai Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 02/28/02 Forsyth bennie.goetze Winston-Salem
County Sewer Extensions
WO0021120 Abbotts Creek Pumping Station Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 02/28/02 Forsyth bennie.goetze Winston-Salem
County Sewer Extensions
WO0022035 Annexation-Area'B'Sewer Improvements Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 11/04/02 Davidson kristin.miguez Winston-Salem
Municipal Sewer Extensions
WO0013263 Boone Town-A Sludge/Drs Government- Distribution of Residual Solids(503) Renewal In review 07/12/02 Watauga shannon.thornburg Winston-Salem
Municipal
WO0022014 Breckenridge Subdivision Phase IV Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 10/28/02 Randolph kristin.miguez Winston-Salem
Municipal Sewer Extensions
WO0006751 Burlington Ind-Highland/Infil Non-Govemmen Groundwater Remediation,Non-discharge Renewal In review 11/15/02 Forsyth sue.homewood Winston-Salem
00021892 Castle Pines at Hickswood Forest Subdivi Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 09/27/02 Guilford kristin.miguez Winston-Salem
Municipal Sewer Extensions
WO0021996 Central Carolina Products Site Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 10/24/02 Alamance kristin.miguez Winston-Salem
Municipal Sewer Extensions
WO0021534 City of Burlington Alum Residuals Distri Government- Distribution of Residual Solids(503 exempt) New Project In review 06/27/02 Alamance shannon.thomburg Winston-Salem
Municipal
WO0021632 City of Burlington Composting Facility& Government- Distribution of Residual Solids(503) jiliPro ect In review 07/26/02 Alamance shannon.thomburg Winston-Salem
;, .%>.' _; . , . .,,; '.. }.. � ; Municipal1 -_ :,�,:� -,ira^ TeM
WO0001897 City of High Point Residuals Land Applic Government- Land Application of Residual Solids(503) Renewal with In review 07/09/01 Guilford jaya.joshi Winston-Salem
Municipal modification
WO0002376 City of Reidsville Residuals Land Applic Government- Land Application of Residual Solids(503) Major modification In review 04/29/02 Rockingham jaya.joshi Winston-Salem
Municipal
WO0021666 Colfax Furniture Non-Govemmen Pump and Haul New Project In review 08/01/02 Guilford corey.basinger Winston-Salem
WO0021238 Contract 1-Regional Wastewater Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 04/09/02 Rockingham cecil.madden Winston-Salem
Pumping Municipal Sewer Extensions
WO0021240 Contract 4 Mayo River Outfall Replacemen Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 04/09/02 Rockingham cecil.madden Winston-Salem
Municipal Sewer Extensions
)0007378 Danville,VA WTP Alum Residuals Land Non-Govemmen Land Application of Residual Solids(503 exempt) Renewal with In review 07/19/02 Caswell shannon.thornburg Winston-Salem
APP modification
WO0010583 Davie County Residuals Program Government- Land Application of Residual Solids(503) Major modification In review 01/15/99 Davie jaya.joshi Winston-Salem
County
WO0022015 Deep River Plantation Phase I Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 10/28/02 Guilford kristin.miguez Winston-Salem
Municipal Sewer Extensions
WO0022016 Deep River Plantation Phase I Non-Govemmen Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 10/28/02 Guilford kristin.miguez Winston-Salem
Sewer Extensions
WO0021946 Frye Street Government- Gravity Sewer Extension,Pump Stations,&Pressure New Project In review 09/27/02 Randolph kristin.miguez Winston-Salem
Municipal Sewer Extensions
WO0005681 Gold Kist Incorporated-Staley Feed Non-Govemrnnn Surface Irrigation Major modification In review 09/17/02 Randolph sue.homewood Winston-Salem
1

DIVISION OF WATER QUALITY
GROUNDWATER SECTION
September 12, 2002
P7C172iVED
MEMORANDUM
S E P 1 8 2002
To: Kim Colson ;_.Sa
F=. i �roalOffLCat
cc:
Through: Debra Watts •
From: Brian Wootton/61/7
Subject: Burlington, City of
Alamance County
WQ0021632/GW02123
Shannon Thornburg, WQS—CO Reviewer
The Groundwater Section has reviewed the subject permit application for the construction and
operation of a residual composting facility to accomodate some of the residuals produced from the South
Burlington WWTP and East Burlington WWTP.The residuals will be mixed with organic matter(yard
waste,wood chips,etc.)and treated to Class A specifications,then distributed to the general public.The
composting process will occur mostly under a covered building and on an asphalt pad.Leachate will be
collected and routed back to the WWTP. The final cured product will be stored on an asphalt pad
(uncovered) until it is removeafrom the site. Due to the design factors of the facility, impact to
groundwater is minimal, therefore monitoring is not necessary at this time.
The Groundwater Section recommends issuance of the permit with the following conditions:
1. Applicable Boundaries:
a. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A
NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary for the
disposal system individually permitted on or after December 30, 1983 is established at either 250
feet from the waste disposal area,or 50 feet within the property boundary,whichever is closest to
the waste disposal area. An exceedance of Groundwater Quality Standards at or beyond the
Compliance Boundary is subject to immediate remediation action according to 15A NCAC 2L
.0106(d)(2).
b. The REVIEW BOUNDARY is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area.Any exceedance of standards
at the Review Boundary shall require action in accordance with 15A NCAC 2L .0106(d)(1).
Page 1 ofl. GW02123.doc

2. Additional Requirements:
Any groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
If there are any questions please call Brian Wootton at(919) 715-6164.
Page 2 of a GW02123.doc

September 9, 2002
MEMORANDUM
To: Brian Wootton
Groundwater Permit Group
From: Sherri Knight, Groundwater Supervisor`°"
Subject: City of Burlington Composting and Residuals Distribution
WQ0021632/GW02123
Alamance County
I have reviewed the subject permit application package. The City of Burlington is proposing to add a
composting facility to process Class A residuals to compliment their existing land application program.
Since the composting process will occur under roof and on a pad, groundwater concerns are minimal.
All fluids associated with the treatment process are to be routed back to the wastewater treatment
plant. The final product will also be stored on pavement (uncovered). I recommend the application
be approved.
If you have any questions, please give me a call.

cc: Alamance County Health Dept.
Sherri Knight/GWS/WSRO
Central Files
MMIte
To: Shannon Thornburg
Permits and Engineering Unit
Water Quality Section
August 28, 2002
NON DISCHARGE STAFF REPORT AND RECOMMENDATION
County: Alamance
Permit No. WQ0021632
PART I - GENERAL INFORMATION
1. Facility and Address: City of Burlington
Class A Residuals Composting Facility
2471 Boy Wood Road (facility location)
P. O. Box 1358 (mailing address)
Burlington, NC 27216
2. Date of Investigation: August 28, 2002
3. Report Prepared by: Mike Mickey, Environmental Specialist II
4. Persons Contacted and Telephone Number:
Steve Shoaf, Director of Utilities, [phone]
Jay Sykes, Chief Operator/ORC/South Burlington POTW, [phone]
David Church, Residuals Mgmt. Coord., ph [phone], or cell [phone]
5. Directions to Site: Take Hwy 87 South off of 1-85 (exit#147). Proceed on Hwy 87
South and bear left onto Swepsonville Road. At Boy Wood Road bear right and the
entrance to the WWTP is 0.25 mile on right.
6. Size (land available for expansion and upgrading): Adequate
7. Topography (relationship to 100 year flood plain included): NA
Attach a U.S.G.S. map extract and indicate facility site.
U.S.G.S. Quad No. C-21-SE U.S.G.S. Quad Name: Mebane
Latitude: 36° 01'22" Longitude: 79° 22' 15"

8. Any buffer conflicts with location of nearest dwelling and water supply well? No X
9. Watershed Stream Basin Information: Haw River
a. Watershed Classification: C-NSW
b. River Basin and Subbasin No.: CPF-03
c. Distance to surface water from disposal system: The compost site and asphalt pad
drain to the east toward the Haw River.
Part II - DESCRIPTION OF WASTES AND TREATMENT WORKS
1. a. POTW Volume: 12.0 MGD (Design Capacity) South Burlington/NC0023876.
Compost Facility Design Capacity: 5_5 dry tons per day.
b. Types and quantities of industrial wastewater: Industrial, commercial, domestic.
c. Pretreatment Program (POTWs only): approved X .
2. Treatment Facilities:
a. What is the current permitted capacity of the facility? The compost facility is
designed to produce 5.5 dry tons per day.
b. Please provide a description of the existing compost facility: The 5.5 dry ton/day
composting facility consists of the following: 15 HP grinder pump in digester
basement, 1,500 L.F. of 6 inch force main, 2 meter belt filter press, polymer feed
system, sludge cake screw conveyor, 1 acre composting building for 22 aerated
static piles with 11 blowers, screening equipment, outside asphalt storage pad for
amendment and final composted material and two biofilters for odor treatment.
3. Residuals handling and utilization/disposal scheme: Burlington currently holds non-
discharge permit No. W00000520 for land application of Class B biosolids from the East
and South Burlington POTW's. (Please note that Burlington has also applied for a
distribution Class A permit for their Mackintosh WFP alum sludge- WQ0021534).
4. Treatment plant classification: Requires land application of residuals certificate.
5. SIC Code(s): 4952 POTW Main Treatment Unit Code: 1 1 7= 5
PART III - EVALUATION AND RECOMMENDATIONS
The City of Burlington has built a 5.5 dry ton/day aerated static pile composting facility. The
project will treat 30-40% of the South Burlington WWTP (NC0023876) sludge that is currently
land applied as Class B residuals under WQ0000520. This compost permit should also list the
East Burlington WWTP (NC0023868) as a possible source so it's residuals could be trucked to
the South facility for composting if necessary.

Yard waste will be ground off site but stored on the asphalt pad for use as amendment
material. The estimated dewatered sludge to amendment ratio would be 3:1. The aerated static
piles will be processed for approximately 21 days with the temperature>55°c for at least 3 days
and then be torn down and moved off the aeration system for additional curing. After screening,
the final product will be stored on site for distribution.
WSRO recommends issuance.
1•61, (‘\\\KrAL,
Signature of report prefer
46)c
Water Quality Regional Sup isor
9/----Ct 2
Date
Non-Discharge Permit Staff Report
Version 10/92
Page 3

fi)
h5.......„,
.., , I ,,,,„ (.,...._____
• " "ii
ik
-1 A - L'j ------VA -— 11\
7 � City of Burlington
\ ' , 4111 ;10.:I.1
/�•► Distribution of Residual Solids
it . \
z .0/, 550 ` 1 Permit No. WQ00021632
f �.� • % � Located off Boy Wood Road
�`� °r ` ��` Alamance County
o��`__5p0 � ,4 . ..E+ ti.:7:7 4 , it, � Mebane Quad C-21-SE
l v\'
`99-07 i ie
)„,.., , ' U dos„/�i .v - , ,441(j.-- =o
0 . r.v ii.„,
----------=
� 600_
. �,� �� �v\:„___.i �` boo ��nn , 7_1J° `�
40
..f2 2,1 \ , , / x / - );
l/ , , �$.) ��\ \ �_ .. . °'• \ ill •
/,,
,`IPAJ c /,-.J 6 2. • r 1 l _ l - _ - '' �l �. \ \ I� •s• 6/7 \ /
..\-. =
... ,o,
_.r
a989 . `\''i / r�!)• \� •-Purkijiiryg Sta"p \• �1
\ /.. ,... \ \ I >5,-,:f:\
7
• •...._ ...4
i ------- ,____ _,.... - ,„,. - -, ,,, - ,_______ / • ,,,.. -
,.. , .., ',E.-4 \
I •/ (...., // I. c..,.C2_,„° ___ ''-,,,, /.
(-\ I — i"- > i--1 C*7 \\ i A
59
--1 ,,,,s, ,..,, (;--,,,,,z, .\\ . • .3) ,,,-- \ \ ir\„ , , ),v. , , / -,4 0--
�� // / \�� 550_��� -\.' ' •n Sch� i
.\ \--/ /- ..--) 7/ l_z ' i- '_._ ---/ / \411101 \ nO ),_ •"IfIPPI* ile./(:.
----," \ VT11 N ' i. . .1. j / 1-1111*/likmit:, 't4tlir S'/./*'-) ' \::j I 1 ... \....i
14 01 .,- --7•7-/1/6
( ta,n u) `�i 1‘10-i7ri,Si
./•.•i.Xl,,"-----:.t:g,\y,l ,#
74„ c - , -__...),.\..•
; J
1xi,LA
fil (0 . \ \' '',it.;"/ 7,2 •
2)
,or______,/ ( 1 . , , 1 . •V • I
.A.,-7,, /b, . 49 eNN.,,,,, \... , ,.s. Ion _.,7( \\ r.
.off \� / � . ; \
*;\st). . LhIt • r.,
./\-,p (,_ _\ i pis.-: L ( •.-, ► \ \.
• --'- '-• -.•,, .5:5 */ 44,,,,...\(,,
,98, _ _ j l .1 __ �,�;
.., • /,_, L.,,,,:,,,..„,...
5.
,,
\.,.._:,„
, \.____,
'''' --Ii^/- o 'il ---.--AVO,. ',v.v.,. :47A•. •,,, rii - \ .t.
/'". / \, Ailf.ar .4:1;64.,,ikSte>r,f7 ' )
1 jai► ., ,a �� �• ,,: ,'
` i'4 CI , • ,\ �ii �14. ,S.V.: h+ £ �� 2i;i� \I
'. `,\ ` 4�` .5.'3 F1 -' "/.4F1,...1,1st-,1; 1
4'
/067,,� 3 570 C •,!� , '�.e' tr,r ,,, fir '.,c , )K C
A, ii
rogg 0 *\ \ Compost Site I ,,•4 ,o \i........
�r } II[C1--\
5 :�7, �. o
114 VA\y `/ i�i moo. �'f
��3 �� Aii\ /.i /� 550 t '��4�•A 5� 6iisiptii
11"
��
41A1
560
)00
ET \---- , ' )/1 \ .' AO&NN\ ? (-/---. -?/4441t\o C
14 \\ ''''.4'4',15,, ..,
))/.1'L'.. !kO k-";i'_,\.)• - °'-' 1('/4r/t t\mlik..*'-° /- \ \
J2'30" 1 890•00 FEET 648 649 650 20' 651
Produced by the United States Geological Survey

OF W ATF9 Michael F.Easley,Governor
[� p William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
> Alan W.Klimek,P.E.,Director
N- Division of Water Quality
r.
RECEIVED
July 31, 2002 N.C. Dept. cif EHNf
AUG - 5 2002
CITY OF BURLINGTON
N'ILLIAM R. BAKER Winston-Salem
P.O.BOX 1358 agakinal Office.
BURLINGTON NC 27216
Subject: Acknowledgement of Application No.WQ0021632
City of Burnlington Composting Facility &
• Residuals Distribution Program
Distribution of Residual Solids(503)
Alamance County
Dear Mr.Baker, III:
The Non-Discharge Permitting Unit of the Division of Water Quality (Division) acknowledges
receipt of your permit application and supporting materials on July 26, 2002. This application package
has been assigned the number listed above.
Your application package has been assigned to Shannon Thornburg, for a detailed review. The
reviewer will contact you with a request for additional information if there are any questions concerning
your submittal.
Please be aware that the Division's Regional Office, copied below, must provide
recommendations prior to final action by the Division.
If you have any questions, please contact Shannon Thornburg at 919-733-5083, extension 353,
or via e-mail at [e-mail]. If the reviewer is unavailable, you may leave a
message, and they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES
ON THIS PROJECT.
Sincerely,
'Kim H. Colson, P.E.
Supervisor,Non-DO ,, :e Permittin: Unit
cc:
Hobbs,Upchurch &Associates,P.A. P.O. Box 1737, Southern Pines NC 28388 -
Permit Application File W90021632 „
ASSIGNEQ
DUE DATE cat
bro
Non-Discharge Permitting Unit Internet http://h2o.enr.state.nc.us/ndpu
1617 Mail Service Center,Raleigh,NC 27699-1617 Telephone [phone] Fax [phone]
DENR Customer Service Center Telephone [phone]
An Equal Opportunity Action Employer 50%recycled/10%post-consumer paper

•
07/31/02
Permit Number A Permit Tracking S]
Program Category Status Project Type
Non-discharge In review New Project
Permit Type Version Permit Classification
Distribution of Residual Solids (503) Individual
Primary Reviewer Permit Contact Affiliation
shannon.thornburg
Permitted Flow
Facility
Facility Name Major/Minor Region
City of Burlington Composting Minor Winston-Salem
getliriyA&di iduals Distribution County
PrAga ox 1358 Alamance
Burlington NC 27216 Facility Contact Affiliation
Owner
Owner Name Owner Type
City of Burlington Government - Municipal
Owner Affiliation
William Baker
l8gdddffice Box 1358
Burlington NC 27216
Dates/Events
Draft Scheduled Public
Orig Issue App Received Initiated Issuance Notice Issue Effective Expiration
07/26/02
Regulated Activities Requested/Received Events
NULL RO staff report received
11111111111 RO staff report requested
11.1111111111111111, Additional information requested
Additional information received
Groundwater comments requested
Groundwater comments received
:A -i.......r-v.Y_Y-ram t-v..,-,-.V....-..._,r - _ _ _ _ / . .
Out fall _. xJ��`�tlto�yG,� CITY OFTBURLINGTON `/) ' -• 140
y154661 °"
.--�' P.o.Box 1358
B�+
Waterbody --•^�!'' , ubbasin
O N-7 y BURLINGTON.N"C.27216 VOID AFTER 6O OATS
N.A.; 41. 0 1336,222.5060
4 a
DATE AMOUNT OF CHECK '
1417i6° $1,090 DOLLARS AND 00 CENTS 07/19/02 .
F
S1,090.00
HE ORDER OF `�O
3 O T PROVISION FOR THE PAYMENT OF THIS CHECK 11AS!EEN MADE
+ BY AN APPROPRIATION DULY MADE.PURSUANT TO THE LOCAL
r 1 GOVERNMENT BUDGET AND FISCAL CONTROL ACT.
CITY Of BURLINGTON
GENERAL PUND
a NC DEPT ENVIR/HAT RESOURCES 4
DIV WATER QUAL-PERMITS ._._- -- -. -- ---
: 1617 MAIL SERVICE CENTER
q L RALEICH NC 27699 J rrr .I•
•
r WACHOVIA SANT AND TRUST CO 0 °J71 4.eari «
r 15466 it C053 1004941:0 1144 2 2 i i 76 1n' " -

CITY OF Burlington ea
GTONN
Telephone [phone] Fax [phone] mP.O. Box 1358 r •Burlington, N.C.27216-1358 r .
STEPHEN R.SHOAF a. 14 10
DIRECTOR OF ITILITIE,
July 23, 2002
Ms. Shannon Thornburg
Non-Discharge Permit Section
NCDENR/DWQ
1617 Mail Service Center
Raleigh, NC 27699-1617
,DCHARCE PEP
Subject: Compost Class A Permit Application
City of Burlington
Alamance County
Dear Ms. Thornburg:
Enclosed, please find three additional copies of the permit application for our new
compost facility. Also, I've enclosed the check for the application fee. I apologize for
the delay and my confusion. It took this long to get a check out of finance once I realized
my mistake.
If you need anything else please let me know.
Sincerely,
Stephen Shoaf

CITY OF Burlington ��GTONA+O4T
�'
Telephone [phone] Fax [phone] m . 1
P.O. Box 1358C�►tip, 0
Burlington,N.C.27216-1358 �ivq s 1I
STEPHEN R.SHOAF
CB. 14 10
DIRECTOR OF UTILITIES
May 17, 2002
NCDENR/DWQ/Non-Discharge Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Permit Application for Compost Facility WATFP r ALIT " czFor.-`!
South Burlington WWTP, NPDES NC0023876
Alamance County _ _
Dear Sir or Madam: i NON_DiSCHAF GE PERMT:
Enclosed,please find the permit application for the operation of the new compost
facility at the South Burlington WWTP. It did not state that it needed to be submitted in
triplicate, so I only sent one original to the NCDENR/DWQ/Non-Discharge unit. I am
also sending one to the Winston-Salem Regional Office for their review and files.
I did not include the design calculations or the compost process alternatives
documents in the copy sent to the Winston-Salem Regional Office due to their length. I
did include those documents in the permit application that I sent to the Raleigh Non-
discharge unit.
As we generate supporting data for the Class "A" designation of the product,we
will forward that information to you. If you have any questions, please call me at(336)
222-5130.
Sincerely,
Stephen Shoaf
r)f,
- r � N

CITY OF Burlington ��G'fONly�*
y
Telephone [phone] Fax [phone] P. }
P.O. Box 1358 Or. re;lbv
Burlington, N.C.27216-1358 V." •
� .1
4 1ag3
STEPHEN R.SHOAF
DIRECTOR OF LTILITIES
May 17,2002
Mr.Mike Mickey R E C E E V E-D
NCDENR/DWQ/WSRO N.C. Dept. of EHNR
585 Waughtown Street
Winston-Salem, NC 27107 MAY 2 1 2002
Subject: Permit Application for Compost Facility
South Burlington WWTP, NPDES NC0023876 Winston TS a i e In
AlamanceCounty Regional Office
Dear Mr.Mickey:
Enclosed,please find the permit application for the operation of the compost facility at the South
Burlington WWTP. It did not state that it needed to be submitted in triplicate,so I only sent one original to
the NCDENR/DWQ/Non-discharge unit. I am sending you one for the Winston-Salem files.
I did not include the design calculations or the compost process alternatives documents in your
copy due to their length and questionable usefulness. I did include those documents in the permit
application that I sent to the Raleigh Non-discharge unit.
If you are not the right person in Winston-Salem to have a copy of the permit application,would
you please pass it along to the right person? I would appreciate it. If you have any questions,please call
me at(336)222-5130.
Sincerely,
Stephen Shoaf

Re:Compost
Subject: Re: Compost
Date: Wed, 13 Mar 2002 17:33:16 -0500
From: Mike Templeton <[e-mail]>
To: Mike Mickey <[e-mail]>
Hi, Mike - I asked Shannon about it yesterday, and she said she hasn't
had a chance to look for it since she got back from WSRO last week. Your
best bet is to keep checking with her or have Steve or Larry call Kim
about it. It shouldn't be that hard to find it (easy for me to say,
eh?) ; if it hasn't been reviewed yet, getting that done will be the real
challenge. Good luck to you both. - Mike T
Mike Mickey wrote:
> Hi Mike,
> Any news on the status of Burlington's compost review?
1 of 1 3/15/2002 8:54 AM

'post
Subject: Re: Burlington Compost
Date: Mon, 25 Feb 2002 17:01:27 -0500
From: Mike Mickey <[e-mail]>
Organization: NC DENR Water Quality
To: Mike Templeton <[e-mail]>
Please check with Shannon. She said on Friday that she thought the NPDES Unit would
have
handled it. Doesn't make sense to me. It's a WQ permit.
Anyway, let me know what you dig up. Hey, if the plans have yet to be reviewed, no
problem. We can just go tour the facility! Thanks, MMM.
Mike Templeton wrote:
> Mike -
> Did you have any luck catching Shannon last week? I can try again from here if
> you want.
> I found a note in our tracking system that we acknowledged the package 8-25-00
> (as you said) and that I handed it over to her soon after that because of the
nature
> of the project: NDU usually gets anything to do with sludge handling, pump station/
> force mains, and collection systems. Didn't have it long enough to remember it, I
> guess.
> In our old numbering system for ATCs, we started with xxxxxxAC or ACA. Then the
> next projects for that facility were ACB, ACC, ACD, etc. (The system is changing
with
> the arrival of BIMS: the first package will be A0lxxxxx, followed by A02xxxxx, etc.
> It wasn 't our idea to make the change, but apparently it 's rooted in the BIMS
> programming so we can't change it back. )
> - Mike T
> Mike Mickey wrote:
> > The South Burlington permit No. is NC0023876.
> >
> > Good luck with the NDU. I've called Shannon T. twice and e-mailed her once and
> > have yet to hear a thing. She will be at WSRO this morning for residuals
> > permitting training. Maybe she can shed some light on the issue.
> >
> > I'm wondering if the influent pump station and composting plans were submitted
> > in the same package - causing some confusion. You are listed as the contact on
> > the 8-25-00 acknowledgment letter (ATC Number 023876ACD) .
> >
> > The engineers certification was just submitted for the completed pump station
> > upgrade, with the ATC Number 023876ACC. Is there any significance to the ACD
> > and ACC distinction? Good luck.
> >
> >
> > Mike Templeton wrote:
> >
> > > Hi, Mike -
> > >
> > > All I know right now is that Steve Shoaf asked me about the status of the
> > > ATC last month, I passed his question to the Nondischarge Unit, and I
> > > haven't heard anything back yet. Tell me what permit number you are working
> > > with and I'll see what I can find out.
> > > - Mike T
> > >
1 of 2 2/26/2002 8:54 AM

Jost
> > > Mike Mickey wrote:
> > >
> > > > Hi Mike,
> > > >
> > > > I'm trying to find out if the composting plans for the City of
> > > > Burlington were reviewed and if an AtC was issued. The plans were
> > > > received on 8-25-00.
> > > > WSRO comments were dated 9-13-00. An AtC was issued 2-9-01 for the
> > > > influent pump station part of the upgrade, but the AtC makes no mention
> > > > of the compost operation part. The compost facility is now under roof
> > > > and Burlington has yet to apply for the class A distribution permit.
> > > > Can you help me out on this? Thanks, Mike.
> > >
> > > --
> > > Michael E. Templeton, P.E.
> > > North Carolina Division of Water Quality
> > > NPDES Unit
> > > 1617 Mail Service Center, Raleigh, NC 27699-1617
> > > 919-733-5083 x541 FAX: [phone]
> > > pailto:mike. templetonencmail.net
> --
> Michael E. Templeton, P.E.
> North Carolina Division of Water Quality
> NPDES Unit
> 1617 Mail Service Center, Raleigh, NC 27699-1617
> 919-733-5083 x541 FAX: [phone]
> mailto:mike. templetonencmail.net
Mike Mickey <[e-mail]>
Environmental Specialist II
North Carolina Department of Environment and Natural Resources
Division of Water Quality
2 of 2 2/26/2002 8:54 AM

.nit
•
Subject: Re: Burlington Permit
Date: Fri, 18 Jan 2002 09:29:07 -0500
From: Mike Mickey <[e-mail]>
Organization: NC DENR Water Quality
To: Barnes Bierck<[e-mail]>
Myron Whitley, AQ Supervisor, said that no action (permit) by their section is
necessary. In regards to the compost permit, I just faxed an application form to
Steve Shoaf this morning to get the ball rolling on that end.
Barnes Bierck wrote:
> Mike, just checking in to see if you 've heard something about
> a compost permit and any air requirements. One thing
> is, Burlington does not recall a compost permit, and they are
> pretty sharp. Could it have slipped between the cracks?
> Thanks very much,
> Barnes
> At 12:34 PM 1/16/2002 -0500, you wrote:
> >I'll check with Myron Whitley in our Air Quality Section and let you know.
> >
> >I cannot find a compost permit in Burlington's file. I have a call into the
> >review engineer in our Central Office that looked at the Hobbs, Upchurch's
> >plans back in 2000. I will let you know as soon as I hear something.
> >
> >Mike.
> >
> >Barnes Bierck wrote:
> >
> » Mike, thanks very much for your help on the city of Burlington's biosolds
> » permit.
> »
> » I forgot to ask you. . . they will have two biofilters. . .do you know if they
> » would need any type of air permit on that?
> »
> » Thanks again.
> »
> » Barnes Bierck
> »
> » Barnes Bierck, P.E.
> » Tetra Tech
> » Cape Fear Building, Suite 105
> » 3200 Chapel Hill-Nelson Highway
> » P.O. Box 14409
> » Research Triangle Park, NC 27709
> >> Phone: (919) 485-8278, ext. 114
> » eFax: (419) 781-1992
> >
> >
> >Attachment Converted:
> "c: \eudora\mailaccts\bbierck_tetratech\attach\mike.mickey.vcf"
> >
> Barnes Bierck, P.E.
> Tetra Tech
> Cape Fear Building, Suite 105
> 3200 Chapel Hill-Nelson Highway
> P.O. Box 14409
1 of 2 1/18/2002 3:52 PM

,nit
> Research Triangle Park, NC 27709
> Phone: (919) 485-8278, ext. 114
> eFax: (419) 781-1992
Mike Mickey <[e-mail]>
Environmental Specialist II
North Carolina Department of Environment and Natural Resources
Division of Water Quality
2 of 2 1/18/2002 3:52 PM

cc: County Health Department
Central Files
To: Permits and Engineering Unit
Water Quality Section
Attention: Shannon Thornburg
AUTHORIZATION TO CONSTRUCT NUMBER: 023876ACD
NPDES PERMIT REPORT AND RECOMMENDATIONS
Date: September 13, 2000
County: Alamance
PART I GENERAL INFORMATION
1. Facility Location: Mailing Address:
South Burlington WWTP Mr. Steve Shoaf
Boy Wood Road City of Burlington
Alamance County P.O. Box 1358
Burlington, N.C. 27216-1358
2. Date of most recent NPDES Staff Report: No recent staff report in file.
3. Changes since previous action on NPDES Permit: None
4. Verify Discharge Point on plans with current NPDES Permit. No change in outfall location.
5. Treatment plant classification: Class IV
PART II- DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Existing treatment facility:
a. What is the current permitted capacity of the facility? 12.0 MGD.
b. Construction activities allowed by AtC's issued in the previous two years: None
c: What is the actual treatment capacity of the current facility? 12.0 MGD.
d. Please provide a description of existing or substantially constructed wastewater
treatment facilities. The existing 12 MGD WWTP consists of grit removal,
screening,influent pump station,equalization basins,primary clarifiers,phosphorus
removal tanks, aeration basins, secondary clarifiers, tertiary filters,chlorination and
dechlorination.

2. Please provide a description of proposed wastewater treatment facilities: The proposed
compost facility will consist of the following: 1)replacement of two existing 3 HP pumps
with new 15 HP grinder pumps (0-200 gpm each) to transfer sludge to the new compost
facility. 2) new prefabricated building for dual 140 gpm belt filter presses, polymer feed
system, sludge cake screw conveyor, covered mixing area, plus space for 22 aerated static
piles with blowers and screening.
3. Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied,please specify DWQ permit no. Residuals from
the East and South Burlington WWTP's are land applied under Permit. No.
WQ0000520 on 2,750 acres.
Residual Contractor: Synagro Telephone No. [phone]
b. Residuals stabilization: PSRP X for land application
PFRP X for the proposed compost operation.
PART III -EVALUATION AND RECOMMENDATIONS
The City of Burlington wants to construct a 5.5 dry ton/day composting facility at the South
Burlington WWTP. The proposed composting method would be an aerated static pile to produce
Class A residuals (approximately 21 days at 131°F). Yard waste collected by the City will be used
as the amendment material. The final product will be mechanically screened prior to distribution.
Please note that the application package indicates that a permit for the class A residuals will not be
applied for until construction is complete and operation has commenced. Shouldn't the non-
discharge permit be issued before compost is produced?
WSRO recommends processing of the ATC.
mi J /,
Signature of report l eparer
c £ . C �-
Water Q&Ality Section Supervisor
Date

State of North Carol] •
Department of Environment
and Natural Resources Airbir
Division of Water Quality A
James B. Hunt, Jr., Governor
Bill Holmann, Secretary NeDgp,ATA
Kerr T. Stevens, Director
N.C. Dept. of EHNA
August 25, 2000 AUG 2 9 2000
Mr. Stephen R. Shoaf
City of Burlington Winston-Salem
P.O. Box 1358 Regional Office
Burlington, North Carolina 27216-1358
Subject: ATC Request Acknowledgment
NPDES Permit NC0023876
ATC Number 023876ACD
South Burlington WWTP
Alamance County
Dear Mr. Shoaf:
The Division of Water Quality's NPDES Unit hereby acknowledges receipt of your request for
Authorization to Construct (ATC) in accordance with NPDES Permit Number NC0023876 on
August 25, 2000. This application has been assigned the number highlighted above.
Please be aware that the Division's regional office, copied below, must provide recommendations
from the Regional Supervisor prior to final action by the Division.
The ATC review process generally takes 90 days from the date your complete submittal is
received, however, due to current staff shortages that review period may take longer. Should any
additional information be required, the review engineer will contact you. If you have any
questions, please contact Mr. Mike Templeton at [phone], extension 541.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING ANY
INQUIRIES ABOUT THIS APPLICATION.
Sincerely,
M 3 fit. '
ASSIGNED TO C _�
DUE DATE — David A. Goodrich
Supervisor, NPDES Unit
cc:
NPDES Unit Permit File
Mr. Michael C. Wicker, P.E. Hobbs, Upchurch & Associates, P.A.
P.O. Box 1737
Southern Pines, NC 28388
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/10%post-consumer paper

CITY OF Burlington ��yGTON1V�
Telephone [phone] Fax [phone] • / y
P.O. Box 1358 0 ���►t _�
• Burlington, N.C.27216-1358 t�v s
STEPHEN R.SHOAF • 14 0'
DIRECTOR OF UTILITIES
August 1, 2000
Mr. Dave Goodrich
NPDES Permit Group AUG 0 2 2000
Division of Water Quality
512 North Salisbury Street,
Archdale BuildingSCS
M
Raleigh,NC 27626 Q
Re. Authorization to Construct Permit O v
City of Burlington
South Burlington WWTP o�p`�n
NPDES Permit No. NC0023876 0-0WU��6RpNCH
Alamance County,NC �`NT so
Dear Mr. Goodrich:
We are requesting an Authorization to Construct Permit from the Division of Water Quality for
the construction of a new sludge dewatering facility and compost producing building and storage
area at the South Burlington Wastewater Treatment Facility.
The sludge composting facility includes the following:
• Replacement of two (2) existing 3 HP progressive cavity pumps and grinder units in
the existing digester basement pump room with new 15 HP progressive cavity pumps
and grinder units to transfer sludge from the WWTP to the new sludge handling
building. The installation of approximately 1500 l.f. of 6 inch DIP sludge line.
• The construction of a new prefabricated sludge handling building with dual belt filter
presses, automatic polymer feed system, belt wash pump station, pneumatic air
compressors, polymer feed pumps, sludge cake screw conveyor, control room, office,
restroom facilities, potable and nonpotable water systems.
• The construction of a new compost producing and storage facility with asphalt
amendment storage pad, prefabricated metal building to cover the mixing area and
equipment, 22 aerated static piles w/radial wheel blowers, screening equipment, and
compost and recycle screening storage, a new asphalt storage area for final compost
distribution.
• The construction of two biofilters to treat off gases from the sludge handling building
and compost pile area for odor control.

The facility is designed to initially compost 5.5 dry tons of sludge during an 8 hour day. This
represents approximately 40% of the current sludge production of the South Burlington WWTP.
The sludge composting facility is being constructed to supplement the existing lime stabilization
and land application sludge program at the WWTP in order to provide operational and regulatory
flexibility for the City of Burlington wastewater treatment program.
Following the construction of this facility and the production of a product capable of producing a
Class A sludge the City of Burlington will perform the necessary testing required to verify the
product pathagen and vector reduction and nutrient content for obtaining a Class A permit from
the Non-discharge Permitting Unit of the Division of Water Quality. A marketing and
distribution plan will be developed and submitted at such time.
Please find attached three sets.of plans, specifications, design calculations and construction
sequence. A separate copy has been forwarded to the Winston Salem Regional Office. Hobbs,
Upchurch& Assoc., P.A. are our consulting engineers on the project and should be copied on all
correspondence.
If you have any further questions about this matter, please contact myself at 336-222-5133 or
Michael Wicker, P.E., of Hobbs, Upchurch& Assoc.,P.A. at 910-692-5616.
Sincerely,
City of Burlington Public Utilities Department
Stephen R. Shoaf
Director
Encl:
cc: Larry Coble ,Winston Salem Regional Office
Michael Wicker, Hobbs, Upchurch& Associates, P.A.

, .
I Hobbs, Upchurch & Associates, P.A.
Consulting Engineers
290 S.W.Broad Street • Post Office Box 1737 • Southern Pines,NC 28388
August 23, 2000
Mr. Dave Goodrich
NPDES Permit Group
Division of Water Quality
512 North Salisbury Street, �n
Atchdale Building En
Raleigh,NC 276262000 LYJ
RECEOV
Re: Authorization to Construct Permit AUG 2 5
City of Burlington
South Burlington WWTP DENR-WATER QUALM
NPDES Permit No.NC0O23876 POINT SOURCE BRANCH
Alamance County,NC
Dear Mr. Goodrich:
We are forwarding a request from the City of Burlington for an Authorization to Construct
Permit from the Division of Water Quality for the construction of a new sludge dewatering
facility and compost producing building and storage area at the South Burlington Wastewater
Treatment Facility. The sludge composting facility includes the following:
• Replacement of two (2)existing 3 HP progressive cavity pumps and grinder units in
the existing digester basement pump room with new 15 HP progressive cavity pumps
and grinder units to transfer sludge from the WWTP to the new sludge handling
building. The installation of approximately 15001.f. of 6 inch DIP sludge line.
• The construction of a new prefabricated sludge handling building with dual belt filter
presses,automatic polymer feed system,belt wash pump station,pneumatic air
compressors,polymer feed pumps, sludge cake screw conveyor, control room, office,
restroom facilities,potable and nonpotable water systems.
• The construction of a new compost producing and storage facility with asphalt
amendment storage pad,prefabricated metal building to cover the mixing area and
equipment, 22 aerated static piles w/radial wheel blowers, screening equipment, and
compost and recycle screening storage, a new asphalt storage area for final compost
distribution.
• The construction of two biofilters to treat off gases from the sludge handling building
and compost pile area for odor control.
Southern Pines,NC • Telephone [phone] • Fax [phone] • e-mail:[e-mail]
Myrtle Beach • Kill Devil Hills • Raleigh

The facility is designed to initially compost 5.5 dry tons of sludge during an 8 hour day. This
represents approximately 40%of the current sludge production of the South Burlington WWTP.
The sludge composting facility is being constructed to supplement the existing lime stabilization
and land application sludge program at the WWTP in order to provide operational and regulatory
flexibility for the City of Burlington wastewater treatment program.
Following the construction of this facility and the production of a product capable of producing a
Class A sludge the City of Burlington will perform the necessary testing required to verify the
product pathagen and vector reduction and nutrient content for obtaining a Class A permit from
the Non-discharge Permitting Unit of the Division of Water Quality. A marketing and
distribution plan will be developed and submitted at such time.
Please find attached three sets of plans, specifications,design calculations and construction
sequence. A separate copy has been forwarded to the Winston Salem Regional Office.
The appropriate Erosion Control Permit Application will be forwarded to the Land Quality
Section of the Winston Regional Office for approval of the sedimentation controls onsite and we
will copy DWQ with this correspondence.
If you have any further questions about this matter,please contact me.
Sincerely,
HOBBS,UPCHURCH&ASSOCIATES, P.A.
•
‘4011/446%IA ILA/
Michael C. Wicker,P.E.
Project Manager
End:
cc: Larry Coble,Winston Salem Regional Office
Stephen R. Shoaf, City of Burlington

Subject: Re: 023876ACD
Date: Fri, 15 Sep 2000 10:10:31 -0400
From: Mike Templeton<[e-mail]>
To: Mike Mickey<[e-mail]>
CC: Shannon Thornburg<[e-mail]>
That ATC originally came to the NPDES Unit, but the Non-Discharge Unit has
hit now, since they normally do the permitting for solids handling projects.
I can give you my opinion but it won't get you anywhere - not my permit - so
I'm forwarding your question to Shannon Thornburg, who I believe will be
doing the review.
By the way, the other South Burlington project also went to Non-Discharge
for review.
Mike Mickey wrote:
> Mike,
> I was reviewing the South Burlington AtC for their new compost facility
> and had one question. The package states that they plan to build the
> compost facility,
> generate material, test for pathogens and then apply for a non-discharge
> permit. Shouldn't they have to apply for a permit for the class A
> residuals before they start composting? MMM.
1 of 1 9/15/2000 1:48 PM

U.S. Postal Service,,,
m CERTIFIED MAIL„., RECEIPT
- (Domestic Mail Only;No lnsur^-..•. :7-verage Provided)
For delivery information visa- • a•-= 'www.i.sps.rom
1Ati71
O
�,�. ,;W % tt
ra
Postage $ 3 07 0"- 0 V
Certified Fee (Jo5
RsegtFee n f
(Endorsement
Required) �.
t7 Restricted Delivery Fee ,
rR (Endorsement Required)
c .
r1 R) %
r1l Total Posta°e&Fees
"'
p sent To Mr. David Church
r ;- City of Burlington
oiPO84* P.O. Box 1358
Cdy,State
Burlington,NC 27216
PS Form. .21j I

SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY
• Complete items 1,2,and 3.Also complete A. Signature
item 4 if Restricted Delivery is desired. 0Agent
• Print your name and address on the reverse X ./, a,. / ❑Addressee
so that we can return the card to you. B. -- eived bI(Printed Name) C. Date,,of Delivery
• Attach this card to the back of the mailpiece, I =
or on the front if space permits.
D. Is delivery address different from item 1? ❑Yes
1. Article Addressed to: If YES,enter delivery address below: El No
Mr. David Church
City of Burlington
P.O. Box 1358 3. Se ceType
Burlington, NC 27216 I Certified Mail Elfrcpress Mall
❑Registered ICJ Return Receipt for Merchandise
❑Insured Mail ❑C.O.D.
4. Restricted Delivery?(Extra Fee) ❑Yes
V
7003 3110 0003 7134 0432 V 376, NOGJ6)06 /(4p3�
PS Form 3811,February 2004 Domestic Return Receipt LI—1 Q'frx9C.- 102595-02-M-1540

«r. nu.NetvN.nl.h•.n)rux.W.:.�rlunu!<wuuvt.Y.nnrrlri NnfH•.
UNITED STAKES PDSTAL`S'SE tV RV=i;x,f�'. ,L&7t. ..�- : d�::: i=a;rt•� { �63 :�irta�0ia�sl�daiPP:: ..i•.,,��,�; .^? ' 'f:.(' .. ?4 f Postage&Fees Pain
• Sender: Please print your name, address, and ZIP+4 in this box •
Datwiec_+-mil
Aquifer Protection Section
Department of Environment and Natural Resources
585 Waughtown Street
Winston-Salem,NC 27107-2241
r7S i„i,ii,,,i„ liii,,,i,,,i,11,,I,ii,•,i,l,i,i,ii,,i,l,.i„ii
I