WQ0039924_Modification_20210201

Initial Review
Reviewer Thornburg, Nathaniel
Is this submittal an application? (Excluding additional information.)*
r Yes r No
Permit Number (IR)* WQ0039924
Applicant/Permittee von Drehle Corporation
Applicant/Permittee Address von Drehle Corporation - Cordova, INC
Is the owner in BIMS? r Yes r No Is the facility in BIMS? r Yes r No
Owner Type Organization
Facility Name von Drehle Corporation DCAR
County Richmond
Fee Category Major
Is this a complete
application?*
c Yes r No
Signature Authority
Signature Authority Title
Signature Authority Email
Document Type (if non -application)
Email Notifications
Does this need review bythe hydrogeologist?* r Yes r No
Regional Office
CO Reviewer
Admin Reviewer
Fee Amount $395
Complete App Date 02/01/2021
Below list any additional email address that need notification about a new project.
Email Address
Comments to be added to email notfication
Comments for Kendall
Comments for RO

Comments for Reviewer
Comments for Applicant

Submittal Form
Project Contact Information
Rease provide information on the person to be contacted by N B Staff
Name * Robert T. Branch
Email Address*
[e-mail]
electronic subnittal, confirmation of receipt, and other correspondence.
Project Information
........ ......... ..........................................................................................................................................
Application/Document Type* r New (Fee Req ui red)
c Modification - Major (Fee Required)
r Renewal with Major Modification (Fee
Required)
r Annual Report
r Additional Information
r Other
Phone Number*
3363129007
O Modification - Minor
C Renewal
C GW-59, NDMR, NDMLR, NDAR-1,
NDAR-2
r Residual Annual Report
r Change of Ownership
We no longer accept these monitoring reports through this portal. Please click on the link below and it will take you to the correct form.
https://edocs.deq.nc.gov/Forms/NonDischarge_Monitoring_Report
Permit Type:* r Wastewater Irrigation r High -Rate Infiltration
r Other Wastewater r Reclaimed Water
r Closed -Loop Recycle r Residuals
r Single -Family Residence Wastewater r Other
Irrigation
Permit Number:* WO0039924
Fbs Current Existing permt number
Applicant/Permittee * von Drehle Corporation
Applicant/Permittee Address* von Drehle Corporation - Cordova, NC
Facility Name * von Drehle Corporation DCAR
Please provide comments/notes on your current submittal below.
At this time, paper copies are no longer required. If you have any questions about what is required, please contact Nathaniel Thornburg
at [e-mail].
Please attach all information required or requested for this submittal to be reviewed here.*
(Application Form Engineering Rans, Spec'rfications, Calculations, Rc.)
vd_2021_mod Jan 25.pdf 3.09MB
upload only 1 RCF docurrent (less than 250 NS). NL@iple documents nest be corrbined into one RDF file unless file is larger than
upload limit.
* W By checking this box, I acknowledge that I understand the application will not be
accepted for pre -review until the fee (if required) has been received by the Non -
Discharge Branch. Application fees must be submitted by check or money order
and made payable to the North Carolina Department of Environmental Quality
(NCDEQ). I also confirm that the uploaded document is a single PDF with all parts
of the application in correct order (as specified by the application).
Mail payment to:
NCDEQ — Division of Water Resources
Attn: Non -Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Signature
Submission Date 1/25/2021

%
State of North Carolina
Department of Environmental Quality
Division of Water Resources
WATER QUALITY REGIONAL OPERATIONS SECTION
NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
Dlvislon of Water Resources
February 1, 2021
To: FRO-WQROS: Trent Allen / Mark Brantley
From: Erick Saunders, Water Quality Permitting Section - Non -Discharge Branch
Permit Number: WQ0039924
Applicant: von Drehle Corporation
Owner Type: Organization
Facility Name: von Drehle Corporation DCAR
Signature Authority: Justin Dawkins
Address: 126 First St., Cordova, NC 28330
Fee Category: Non -Discharge Major
Permit Type: Distribution of Residual Solids (503 Exempt)
Project Type: Major Modification
Owner in BIMS? Yes
Facility in BIMS? Yes
Title: Plant Manager
County: ' Richmond
Fee Amount: $395 - Major Modification
Comments/Other Information: [e-mail];[e-mail]
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: J •��j�
Date: 3 Z (P /Z/
FORM: WQROSNDARR 09-15 Page 1 of 1

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non-Dischar eg Unit
Attn:' ` Erick Saunders
From: Jim Barber
Fayetteville Regional Office
Application No.: W00039924
Facility name: von Drehle Corporation — Cordova
Class A (503 Exempt) .
Note: This form has been adapted from the non -discharge facilt staff report to document the review of both non
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Z Yes or ❑ No
a. Date of site visit: 9 February 2021
b. Site visit conducted_by: Jim Barber .
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Chris Fowler and'their contact information: 9( 10) 410 - 9131 ext.
e. Driving directions: From Rockingham, take US Hwy 1 South approximately 3 miles and turn right at the
intersection of US 1 and Rosalyn road. Drive approximately 2 miles and the von Drehle plant is on the right.
2. Discharge Point(s): N/A: Both Class A and Class B residuals are stored behind the main production plant,
adiacent to belt press. The coordinates below are the approximate center of the storage area.
Latitude: 34.918454
Latitude:
Longitude:-79.828977
Longitude:
3. Receiving stream or affected surface waters: N/A (Hitchcock Creek is adjacent to the von Drehle production
plant site
Classification: "C"
River Basin and Subbasin No:: Yadkin -Pee Dee dYAD16) `(13-39-10)
Describe receiving stream features and pertinent downstream uses: From the von Drehle plant site to the
Pee Dee River is forest/woodlands on both sides the Hitchcock Creek.
H. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification:
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal, system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain
FORM: WQROSSR 04-14 Page 1 of 6

4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ® N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? ® Yes ❑ No ❑ N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ® Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any. setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas..
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Chris Fowler Certificate #: LA-1003082 'Backup ORC: Bob Branch Certificate #: LA-15676
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: Paper recycling facility that produces press cake residual. At the current.
time, von Drehle has a Class A and Class B permit (WO0005135—12,500 DTs/year) and two land
application farms for residuals that can't meet Class A standards.
Proposed flow: The current modification request is 35,000 DTs/year.
Current permitted. flow: Current Dry Tons allowed to be land applied under the Class A permit is 16,499
DTs/year.
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance; a change in facility ownership,
etc.)
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:
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:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
FORM: WQROSSR 04-14 Page 2 of 6

9. Is the description of the facilities as written in theexisting permit correct? ® Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 3 of 6

11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
O 1 It
O 1 II
O 1 It
O 1 II
O / 11
O I 11
O I If
O / 11
O I 11
O I If
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: Residuals produced are primarily being land
applied under the von Drehle Class B permit on two farms; one located outside of Hamlet and one along
U.S. Hwy 1 south of Cordova near the South Carolina/North Carolina line.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
14. Check all that apply:
® No compliance issues
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, -please explain the status. Has the RO been
working with the Permitfee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been.satisfied? ❑ Yes ❑ No ® N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes -® No ❑ N/A
If yes, please explain:
16. Possible toxic impacts to surface' waters: N/A
17. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 4 of 6

1 i
IV. REGIONAL OFFICE REC01MUNDATIONS
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 the NPDES Unit or Non -Discharge Unit Central Office to obtain through an -
additional information request:
Item Reason
3. ,List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
4. List specific special. conditions or compliance schedules recommended to be included in the permit when issue
Condition Reason
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 superviE
Date: Z
FORM: WQROSSR 04-14
Page 5 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Von Drehle is requesting an increase in tonnage for managing Class A cake residuals, with most of the paper residuals
managed under the Class A permit marketed to farmers in Richmond, Scotland, Anson and Moore counties that have
sandy soil profiles as a'soil amendment (i.e Candor, Wagram, Wakulla, etc.). Some Class A residuals may also be
land applied in South Carolina, as in past history. South Carolina DBEC will require von Drehle or Bionomics to
apply for a industrial land application permit if Class A residual is to be land applied.
Also at this time, Bionomics (residuals contractor for von Drehle) is currently requesting modification of their Class B
permit (W00038570) to add von Drehle as a source, along with other nutrient sources and the von Drehle farm sites.
The other nutrient sources being request in the Bionomics modification also have their own land application permits
that Bionomics administer, hence the von Drehle site will be a secondM permit for residuals management.
Once the von Drehle Class A permit is modified and the Bionomics Class B permit modified; von Drehle intends to
rescind their Class B permit.
Wastewater from belt pressed residuals and domestic flow are discharge to the City of Rockingham collection
system/wastewater treatment plant.
FORM: WQROSSR 04-14 Page 6 of 6

Barber, Jim
From:
Thornburg, Nathaniel
Sent:.
Monday, February 1, 2021 10:31,AM
To:
Allen, Trent; Brantley, Mark, Barber, Jim
Cc:
Williams, Kendall; Saunders, Erickson G
Subject:
[STAFF REPORT REQUEST] WQ0039924 - von Drehle Corporation DCAR, Major
Modification Application
Attachments:
WQ0039924 WQROSNDARR 210201.pdf
RO Supervisors — Please assign this project to one of your staff for review. y
APPLICATION LINK:. ,
https://edocs.dell:nc.gov/Wat'erkesodrees/`DocView.asr)x?id=1577669&dbid=0&repo=WaterResources.
Kendall,
Please process the subject application received February 1, 2021 in BIMS.
I've included the RO review request form for your use. I also included the Applicant email addresses in the comment
section of RO review request form.
Please copy the RO, Reviewer, and myself on the acknowledgement letter that you send to the Applicant.
J
Thank you,
Nathaniel D. Thornburg
Branch Chief
Non -Discharge Branch
Department of Environmental Quality
919 707,3653 office
[e-mail]
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
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Barber, Jim
From: Bob Branch <[e-mail]>
Sent: Tuesday, January 26, 2021 4:44 PM
To: Barber, Jim; Martin Mabe
Subject: [External] von Drehle Permit Modification
Attachments: vd_2021_mod Jan 25.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.<mailto:[e-mail]>
All,
Attached is von Drehle's permit modification for their Class A. I intend to request to rescind the Class B application upon
verification that Bio-Nomic's permit will be accepted.
Hope all are doing well.
M.
1

PERMIT MODIFICATION FOR THE
DISTRIBUTION OF RESIDUAL SOLIDS
WQ0039924
VON DREHLE CORPORATION
CORDOVA, NC FACILITY
FIBER CLAY
CORDOVA, NORTH CAROLINA
Prepared For:
von Drehle Corporation
126 First Street
Cordova, NC 28330
Prepared By:
Branch Residuals & Soils, LLC
1735 Heckle Blvd. — Suite 103-291
Rock Hill, SC 29732
January 2021

BRANCH RESIDUALS & SOILS, LLC
1735 Heckle Blvd. Suite 103-291, Rock Hill, SC 29732
PHONE [phone] • Cell [phone]
January 25, 2021
NCDEQ -Division of Water Resources
Non -Discharge Branch
Mail Service Center 1617
Raleigh, North Carolina 27699-1617
Attention: Mr. Nathaniel Thornburg
Reference: MODIFICATION PERMIT WQ0039924
von Drehle Corporation — Cordova Facility
Cordova, North Carolina
BR&S Job No. 2014-110
Dear Mr. Thornburg:
Branch Residuals & Soils, LLC is under contract with the von Drehle Corporation to prepare to modify
the current Class A distribution permit. von Drehle has transferred land that they own to Bio-Nomics so
that applications can continue to be made and a potential nitrogen source that will aid in the breakdown of
the fiber clay. This land was previously permitted under von Drehle's permit WQ0005135 for the land
application of Class B residual solids. The generated Fiber Clay has no domestic input but is derived from
woody sources that are known to have interference with fecal coliform values (Klebsiella sp.). Based on
the false positive interferences with the fecal coliform testing procedures, von Drehle will be performing
Salmonella testing. Distribution avenues will include application in accordance with soil lime
requirements, distribution as a soil amendment (either alone or in concert with other products), distributed
to facilities that may blend soil amendments and mulch, and as a daily landfill cover.
Please contact me immediately if you require additional information or have questions in the review of
the permit application.
Sinc ,
Robert T. Branch, L. S. S.
Project Manager
cc: Mr. Chris Fowler — von Drehle Corporation — Cordova Facility

TABLE OF CONTENTS
Section No. Title
I DISTRIBUTION OF RESIDUAL SOLIDS APPLICATION FORM
Copy of Existing Permit
II RESIDUALS SOURCE CERTIFICATION ATTACHMENT — FIBER CLAY
Vicinity Map
Process Flow Diagram and Narrative
Justification of Residuals Production Rate
Sampling Plan
Residual Analytical Reports
III MANAGEMENT PLAN
Overview of Process and Residual Solids Handling
Distribution Methods for Reuse
Transportation and Logistics
Monitoring and Recordkeeping
Leachate Collection
IV VON DREHLE CORDOVA FIBER CLAY
LABEL AND PRODUCT INFORMATION SHEET
V VON DREHLE CORDOVA FIBER CLAY
RESIDUALS RECEIPT FORM
VI SPILL CONTROL PLAN
VII APPLICATION RATES

SECTION I
DISTRIBUTION OF RESIDUAL SOLIDS APPLCIATION FORM

State of North Carolina
DWR
Department of Environmental Quality
Division of Water Resources
Division of Water Resources 15A NCAC 02T .1100 — DISTRIBUTION OF CLASS A RESIDUALS
INSTRUCTIONS FOR FORM: DCAR 06-16 & SUPPORTING DOCUMENTATION
Please use the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these
instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of additional
information requested. Failure to submit all of the required items will lead to additional processing and review time for the
permit application. Unless otherwise noted. the Applicant shall submit one original and two copies of the application and
supporting documentation
For more information, visit the Water Quality Permitting Section's Non -Discharge Permitting Unit website
General — This application is for treatment, storage, transport, distribution, land application, and/or marketing of Class A (or Equivalent)
residuals under 15A NCAC 02T .1100.
Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed
below.
A. Distribution of Class A Residuals (FORM: DCAR 06-16):
® Submit the completed and appropriately executed Distribution of Class A Residuals (FORM: DCAR 06-16) form. Please do
not make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachments to
the application may be made, as long as the attachments are numbered to correspond to the section and item to which they
refer.
® The project name should be consistent on the plans, specifications, etc.
® The Applicant's Certification on Page 3 of this form shall be signed in accordance with 15A NCAC 02T .0106(b). An alternate
person may be designated as the signing official if a delegation letter is provided from a person who meets the criteria in 15A
NCAC 02T .0106(b).
❑ If this project is for a modification of an existing permit, submit one copy of the existing permit.
❑ Please submit this application form at least 180 days prior to the expiration date on the existing permit, or 90 days prior to
operation of proposed facility(ies) for application packages involving new or changes to treatment and storage units.
B. Application Fee (New and Major Modification Application Packages)
® Submit a check, money order or electronic funds transfer made payable to: North Carolina Department of Environmental
Quality (NCDEQ).
Facility Classification
New Permit I Major Modification I
Major (residuals permitted for distribution > 3,000 dry tons/year) F $1,310
Minor (residuals permitted for distribution < 3,000 dry tons/year) 1 $810
$395
$245
- A major modification shall be defined as any permit modification that: increases the generating facility's residuals dry tonnage;
adds additional residuals sources; or includes the addition of new treatment or storage units/processes not previously permitted.
There is no fee for minor permit modifications.
C. Cover Letter (All Application Packages)
® List all items included in the application package, as well as a brief description of the requested permitting action.
INSTRUCTIONS FOR FORM: DCAR 06-16 Pagel of 3

D. Program Information (All Application Packages)
® Provide a narrative explaining the following:
® How the materials will be handled and transported from where the residuals were produced to where it will be treated.
® How the residuals will be processed/treated (attach process flow diagram).
® How leachate collection will be handled.
® Where the residuals will be stored until processed.
® How the final product will be distributed (packaging, bulk, etc.)
® What nutrients or other constituents (i.e. nitrogen, phosphorous, aluminum, calcium, etc.) are used or recommended as the
limiting parameter for determination of residuals loading rate to ensure that it does not overload the soil and cause
contravention of surface water or groundwater standards, limit crop growth, or adversely impact soil quality.
® Attach a marketability statement detailing destinations and approximate amounts of the final product to be distributed.
® Provide either a label that shall be affixed to the bagged processed residual or an information sheet that shall be provided to the
person who receives the processed residual. The label or information sheet shall contain, at a minimum, the following
information:
® Name and address of the person who prepared the residual that is sold or given away.
® A statement that application of the residuals to the land shall be in accordance with the instructions on the label or
information sheet.
® A statement that the residuals shall not be applied to any site that is flooded, frozen or snow-covered.
® A statement that adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored
residuals into any surface waters.
® Information on all applicable setbacks in accordance with 15A NCAC 02T . 1108(b).
® A statement that the residuals shall be applied at agronomic or recommended rates for intended uses.
E. Detailed Plans and Specifications (Application Involving New or Changes to Treatment or Storage Units)
❑ Submit detailed plans and specifications that have been signed, sealed, and dated by a NC Professional Engineer per 15A
NCAC 02T .1104(a). Specifications for standard equipment may only be omitted for municipalities with approved standard
specifications, but use of the standard specifications must be noted on each sheet of the plans.
❑ Plans must include the following minimum items: a general location map, a topographic map, plan and profile view of the
residuals treatment and storage units as well as the proximity of the residuals treatment and storage units to other utilities and
natural features within 500 feet of all treatment and storage facilities, and detail drawings of all items pertinent to the residuals
treatment and storage units. Depict minimum separations required in 15A NCAC 02T .I 108(a) on the plans.
❑ Specifications must include, at a minimum, the following for all items pertinent to residuals treatment and storage units:
description of materials to be used, methods of construction, quality of construction testing procedures to ensure the integrity
of the final product in accordance with 15A NCAC 02T .1104(a)(2)(B), including leakage and pressure testing as appropriate.
❑ Plans and specifications must not be labeled with preliminary phrases (e.g., FOR REVIEW ONLY, NOT FOR
CONSTRUCTION, etc.) that indicate that they are anything other than final plans and specifications. However, the plans and
specifications may be labeled with the phrase: FINAL DESIGN -- NOT RELEASED FOR CONSTRUCTION.
F. Engineering Calculations (Application Involving New or Changes to Treatment or Storage Units)
❑ Submit all design calculations that have been signed, sealed, and dated by a NC Professional Engineer per 15A NCAC 02T
.1104(a).
G. Environmental Assessments (Maybe Required— See 15A NCAC 1 C .0300)
❑ Submit a copy of the Findings of No Significant Impact (FONSI) or Environmental Impact Statement (EIS). Also, include
information on any mitigating factor(s) from the Environmental Assessment (EA) that impact the construction of the residuals
treatment and storage facilities. An EA may also be required for private systems if any public funds and/or lands are used for
the construction of the subject facilities.
INSTRUCTIONS FOR FORM: DCAR 06-16 Page 2 of 3

H. Operation and Maintenance Plan (New and Renewal Application Packages)
® For Modification Application, if there are any changes to the existing plan, submit an updated O&M plan.
® Submit the O&M Plan in accordance with 15A NCAC 02T .I 110 and include at a minimum:
® Operational functions; describe the operation of the program to show what operations are necessary for the program to function
and by whom the functions are to be conducted.
® Maintenance schedules; may include equipments calibration, maintenance of signs, etc.
® Safety measures; may include safety training program, manuals, signs, etc.
® Spill response plan; including control, containment, remediation, emergency contact information, etc.
® Inspection plan including the following information;
® Names and titles of personnel responsible for conducting the inspections.
® Frequency and location of inspections, including those to be conducted by the ORC, and procedures to assure that the selected
location(s) and inspection frequency are representative of the residuals management program.
® Detailed description of inspection procedures including record keeping and actions to be taken by the inspector in the event
that noncompliance is observed.
® Sampling and monitoring plan including the following information;
® Names and titles of personnel responsible for conducting the sampling and monitoring.
® Detailed description of monitoring procedures including parameters to be monitored.
® Sampling frequency and procedures to assure that representative samples are being collected. Fluctuation in temperature, flow,
and other operating conditions can affect the quality of the residuals gathered during a particular sampling event. The sampling
plan shall account for any foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to meet
pathogen and vector attraction reduction requirements (e.g. facilities that land apply multiple times per year but have an annual
sampling frequency, may need to sample during winter months when pathogen reduction is most likely to be negatively affected
by cold temperatures.
ONE ORIGINAL AND TWO COPIES OF THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION AND MATERIALS, SHALL BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service: By Courier/Special Delivery:
1617 MAIL SERVICE CENTER 512 N. SALISBURY STREET
RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH, NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone]
FAX NUMBER: [phone]
INSTRUCTIONS FOR FORM: DCAR 06-16 Page 3 of 3

State of North Carolina
DWR
Department of Environmental Quality
Division of Water Resources
Division of Water Resources 15A NCAC 02T .1100 — DISTRIBUTION OF CLASS A RESIDUALS
FORM: DCAR 06-16
I. APPLICANT INFORMATION:
1. Applicant's name: von Drehle Corporation
Applicant type: ❑ Individual N Corporation ❑ General Partnership ❑ Privately -Owned Public Utility
❑ Federal ❑ State ❑ Municipal ❑ County
Signature authority's name per 15A NCAC 02T .0106: Justin Dawkins Title: Plant Manager
Applicant's mailing address: 126 First Street
City: Cordova State: NC Zip: 28330-
Telephone number: [phone] Email Address: iustin.dawkinsavondrehle.com
2. Consultant's name: Branch Residuals & Soils, LLC License Number (for P.E.):
Affiliation: ❑ On Staff N Retained (Firm: )
Consultant's mailing address: 1735 Heckle Blvd. - Suite 103-291
City: Rock Hill State: SC Zip: 29732-
Telephone number: [phone] Email Address: [e-mail]
3. Fee submitted: $395.00 (See Instruction B)
II. PERMIT INFORMATION:
1. Application is for (check all that apply): N new, N modified, ❑ renewed permit
2. If this application is being submitted to renew or modify an existing permit, provide the following:
Permit number: W00039924
Date of most -recently issued permit: June 28, 2018
Date of most -recently certified Attachment A (if different than the permit):
III. FACILITY INFORMATION:
1. Name of residuals processing facility: von Drehle Corporation - Cordova
City: Cordova State: NC Zip: 28330-
Coordinates: Latitude: 34' 55' 2." Longitude: 79 49' 42"
Datum: NAD 83 Level of accuracy: 1'
Method of measurement: Man
County where facility is located: Richmond
2. Facility contact (person familiar with residuals preparation):
Name: Chris fowler Title: Land Application ORC
Mailing address: 126 First Street
City: Cordova State: NC Zip: 28330-
Telephone number: [phone] E-mail address: chris.fowlerna vondrehle.com
FORM: DCAR 06-16 Page 1 of 3

3. Is the residual process facility also the generator? ® Yes; ❑ No
If No, please specify delivery frequency and quantity of residual to be processed:
4. Length of residuals storage at facility: 5 days (Note: the Division requires minimum 30 days storage in units that are separate
from treatment system, i.e. not in clarifiers, aeration basins, etc.)
IV. RESIDUALS QUALITY INFORMATION:
1. Specify how these residuals will be distributed:
❑ sold or given away in bags or other containers; ❑ lawn (bulk); ❑ home garden (bulk);
® other (explain); See Attached Management Plan
Note: Bulk residuals shall mean residuals that are transported and not sold or giving away in a bag or other receptacles with a
load capacity of one metric ton or less.
2. Complete the following if residuals are to be mixed with other materials:
Type of Materials
Amounts to be added
er 1.0 dry ton of residuals (dry ton
None
None
3. Approximate amounts of the residuals received and processed at the facility: 22,500 dry tons per year.
4. Approximate amounts of the final product (processed residuals) to be distributed: 35,000 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): Residuals are kept on small storage pad prior to loading onto trucks
6. Does the facility have a stormwater management plan? ® Yes; ❑ No
Explain whether the treatment and storage areas are under roof or how stormwater runoff will be handled: Due to % solids,
free water is not generated, rainwater rewets solids.
V. RESIDUALS SOURCE INFORMATION: (Required for all new, renewed, or modified residuals source)
Complete and submit the attached Residuals Source Certification and all associated documentation.
Residuals Source
Certification
FORM: DCAR 06-16 Page 2 of 3

Professional Engineer's Certification: (Application Involving New or Changes to Treatment or Storage Units)
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 Engineers 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 15A NCAC 02T .0105.
® Yes ❑ No, Explain;
I, Justin Dawkins Plant Manager
(Signature Authority's Name — PLEASE PRINT) (Title)
attest that this application for von Drelile Corporation— Cordova, NC Facility
(Facility Name)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that the Division of Water Resources
may not conduct a technical review of this program and approval does not constitute a variance to any rules or statutes unless specifically
granted in the permit. Further, any discharge of residuals to surface waters or the land will result in an immediate enforcement action,
which may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the Division of Water
Resources should a condition of this permit be violated. I also understand that if all required parts of this application are not completed
and that if all required supporting information and attacluuents are not included, this application package will be returned to time as
incomplete.
Note: In accordance with North Carolina General Statutes § 143-215.6A and § 143-215.613, any person who knowingly makes any false
statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up to $25,000 per violation.
Signature: Date: a�T 1 2d'L1
FORM: DCAR 06-16 Page 3 of 3

Copy of Existing Permit

Water Resources
ENVIRONMENTAL QUALITY
June 28, 2018
JUSTIN DAWIGINS —.PLANT MANAGER
VON DREHLE CORPORATION
126 FIRST STREET
CORDOVA, NORTH CAROLINA 28330
Dear Mr. Dawkins:
ROY COOPER
Gvvo-no,
MICHAEL S. REGAN
se retury
LINDA CULPEPPER
tnierim Director
Subject: Permit No. WQ0039924
von Drehle Corporation DCAR
Distribution of Class A
Industrial Byproduct
Residuals
Richmond County
In accordance with your permit application request received April 16, 2018, we are forwarding
herewith Permit No. WQ0039924 dated June 28, 2018, to the von Drehle Corporation for the start-up and
operation of the subject residuals management program.
This permit shall be effective from the date of issuance until May 31, 2023, and shall be subject to
the conditions and limitations as specified therein. Please pay particular attention to the monitoring
requirements listed in Attachment A. Failure to establish an adequate system for collecting and maintaining
the required operational information shall result in future compliance problems.
In response to questions raised during the review of the permit, the following responses were given:
1. Q: Condition 11.2. How will the damages be assessed in the event of a "third" party or a
contractor?
A: Condition 111.12 comes into play for part of the answer to this question. If the Permittee
knew of the overapplication and did not report it, the Permittee would bear part of the
responsibility. If the Permittee knew of the overapplication and did report it, the Permittee
would bear none of the responsibility. If the Permittee did not know, then it will become a
matter of demonstrating lack of knowledge with a presumption that the Permittee did not know.
2. Q: Condition 11.5. Since von Drehle will have both a Class A and a Class B permit, can Class
A pathogen testing be utilized to meet Class B requirements for the Class B permit?
A: Yes, as long as they are less than a year old and it passes the Class A requirements.
' ctl irq Compares' ' .,
State of North Carolina ( Environmental Quality Water Resources I Water Quality Permitting I Non -Discharge Permitting
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-807-6332

Mr. Justin Dawkins
June 28, 2018
Page 2 of 2
3. Q: Condition H.6. Are these setbacks applicable to temporary 60 days' storage and if not are
there any additional requirements? Spelling treatment instead of reatment.
A: Yes the setbacks would apply to the temporary storage as well. The 60 days' storage would
be considered a temporary facility. And thanks for catching spelling error.
4. Q: Condition IV.6f. Application of this material will not be made based on the Agronomic
RYE rates. Use of these rates could provide a false justification of over -application.
A: This is a very valid point. Condition IV.6.f has been modified to account for a non -limiting
nutrient other than nitrogen.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding.
If you need additional information concerning this permit, please contact Troy Doby at (919) 807-
6336 or troy dobyL vngdetingov.
Sincerely,
�-mda Culpepper, Interim Director
J Division of Water Resources
cc : Richmond County Health Department (Electronic Copy)
Fayetteville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Bob Branch, LSS — Branch Residuals & Soils, LLC (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL NIANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
DISTRIBUTION OF CLASS A INDUSTRIAL BYPRODUCT RESIDUALS 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
von Drehle Corporation
Richmond County
FOR THE
operation of a residuals management program for von Drehle Corporation and consisting of the distribution
of Class A industrial byproduct residuals generated by the approved facility listed in Attachment A with no
discharge of wastes to surface waters, pursuant to the application received April 16, 2018, and in conformity
with other supporting data subsequently filed and approved by the .Department of Environmental Quality
and considered a part of this pen -nit. The use and disposal of residuals are regulated under Title 40 Code of
Federal Regulations Part 257. This permit does not exempt the Permittee from complying with the federal
regulations.
This permit shall be effective from the date of issuance until May 31, 2023, and shall be subject to the
following specified conditions and limitations:
I. SCHEDULES
I . No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application.
[ 15A NCAC 02T .0108(b)(2), 02T .0105(d), 02T .0109]
II. PERFORMANCE STANDARDS
1. The subject residuals management program shall be effectively maintained and operated at all times so
there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perform satisfactorily, including the creation of prolonged
nuisance conditions due to improper operation and maintenance, the Permittee shall immediately cease
distribution of residuals, contact the Fayetteville Regional Office supervisor, and take any immediate
corrective actions. [G.S. 143-215.1]
2. This permit shall not relieve the Permittee of responsibility for damages to groundwater or surface
water resulting from the operation of this residuals management program. [I SA NCAC 02B .0200,
02L .0100]
WQ0039924 Version 1.0 Shell Version 171103 Page 1 of 10

3. Only residuals generated by the facility listed in Attachment A are approved for distribution in
accordance with this permit. [G.S. 143-215.1]
4. Pollutant concentrations in residuals distributed or applied to any land application site shall not exceed
the following Ceiling Concentrations or Monthly Average Concentrations (i.e., dry weight basis):
Ceiling Concentration
Monthly Average
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
Nickel
75
420
n/a
420
Selenium
l00
100
Zinc
7,500
, 2,800
[15A NCAC 02T .1105]
5. Residuals that are distributed shall meet Class A pathogen reduction requirements in 15A NCAC 02T
.1106 (a) and (b)(2). Exceptions to this requirement shall be specified in Attachment A. [15A NCAC
02T .1106]
6. Setbacks for treatment and storage facilities shall be as follows:
Setback Description
I Setback
Habitable residence or place of public assembly under separate ownership or not to
100
be maintained as part of the prqject site
Property lines
( 50
Private or public water supply
100
Surface waters (streams — intermittent and perennial, perennial waterbodies, and
50
E wetlands)
Wells with exception to monitoring wells
1 100
[15A NCAC 02T. 11081
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7. Setbacks for Class A land applied bulk residuals shall be as follows:
Setback by residual type
Setback Description (feet)
Liquid Cake'
Private or public water supply 100 100
Surface waters (streams — intermittent and perennial, 100 25
perennial waterbodies, and wetlands)
Surface water diversions (ephemeral streams, 25 0
waterways, ditches
Groundwater lowering ditches (where the bottom of 25 0
the ditch intersects the SHWT)
Wells with exception to monitoring wells 100 100
Bedrock outcrops 25 0
Unless otherwise noted in Attachment A, "cake" residuals are those that have greater than 15%
solids by weight and can be stacked without flowing, as well as can be handled, transported and
spread as a solid (e.g., using a backhoe, front end loader, slinger spreader, broadcast spreader or
other equipment designed for handling solid materials) without leaving any significant liquid
fraction behind.
[I 5A NCAC 02T .1 108]
8. Bulk residuals and other sources of Plant Available Nitrogen (PAN) shall not be applied in exceedance
of agronomic rates. Appropriate agronomic rates shall be calculated using expected nitrogen
requirements based on the determined Realistic Yield Expectations (RYE) using any of the following
methods:
a. Division's pre -approved site specific historical data for specific crop or soil types by calculating
the mean of the best three yields of the last five consecutive crop harvests for each field.
b. North Carolina Historical Data for specific crop and soil types as provided by North Carolina State
University Department of Soil Science(littp:,/nutrients.soil.ncsu.edu/vields/index.L�hp). A copy
shall be kept on file and reprinted every five years in accordance with Condition 1V.6.
c. Tf the RYE cannot be determined using methods (a) or (b) above, the Permittee may use the RYE
and appropriate nutrient application rates reported in any of the following documents:
i. Crop management plan as outlined by the local Cooperative Extension Office, the North
Carolina Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, or other agronomist.
ii. Waste Utilization Plan as outlined by the Senate Bill 1217 .Interagency Group - Guidance
Document: Chapter 1
(http://www.ncacr.cov/SWCI'tecli/documctits!9tli Guidance Doc 100109.10).
iii. Certified Nutrient Management Plan as outlined by the Natural Resources Conservation
Services (NRCS). These plans must meet the USDA-NRCS 590 Nutrient Management
Standards (tip:/Mp-fo,sc.e,-,ov.usda.iov,'N[IQ practice-standards/staridards'590. )di .
d. if the RYE and appropriate nutrient application rates cannot be determined, the Permittee shall
contact the Division to determine necessary action.
[15A NCAC 02T .I 109(b)(1)(k)]
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9. The Permittee shall not distribute Class A industrial byproduct residuals that have a sodium adsorption
ratio (SAR) of 10 or higher without prior written Division approval. The Permittee may seek approval
by demonstrating that the entity accepting the residuals is: aware of the effects of a high SAR content;
has agreed on proper residual application rates; and has agreed to operational considerations to ensure
that the high SAR content will not adversely impact the receiving sites. Recommendations regarding
sodium application rate, soil amendments (e.g., gypsum, etc.) or a mechanism for maintaining site
integrity and conditions conducive to crop growth, can be obtained from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, a North Carolina Licensed Soil Scientist, or an agronomist. [15A NCAC 02T
.0108(b)(1)]
Ill. OPERATION AND MAINTENANCE REQUIREMENTS
The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards. [ 15A NCAC 02T .1110]
2. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) Modifications
to the O&M Plan shall be approved by the Division prior to utilization of the new plan. The O&M Plan,
at the minimum, shall include:
a. Operational functions;
b. Maintenance schedules;
c. Safety measures;
d. Spill response plan;
e. Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including record keeping and actions to be taken
by the inspector in the event that noncompliance is observed pursuant to the noncompliance
notification requirements under the monitoring and reporting section of the permit;
f. Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring;
ii. Detailed description of monitoring procedures including parameters to be monitored;
iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for any
foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to
meet pathogen reduction requirements (e.g. facilities that distribute multiple times per year but
have an annual sampling frequency, may need to sample during winter months when pathogen
reduction is most likely to be negatively affected by cold temperatures).
[ 15A NCAC 02T .1100]
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3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in responsible
charge (ORC) and one or more certified operators as back-up ORCs in accordance with 15A NCAC
08G .020 1. The ORC or his back-up shall visit the facilities in accordance with 15A NCAC 08G. 0204,
or as specified in the most recently approved O&M plan (i.e., see Condition IIL2.), and shall comply
with all other conditions of 15A NCAC 08G. 0204. For more information regarding classification and
designation requirements, please contact the Division of Water Resources' Protection and:Enforcement
Branch at [phone]. At the time of this permit issuance, a certified ORC is not required for the
subject Distribution of Class A Residuals program. [15A NCAC 02T .01 17]
4. When the Permittee land applies bulk residuals, a copy of this permit and a copy of O&M Plan shall be
maintained at the land application sites during land application activities. [15A NCAC 02T
.0108(b)(1)]
5. When the Permittee transports or land applies bulk residuals, the spill control provisions shall be
maintained in all residuals transport and application vehicles. [15A NCAC 02T .1110]
6. When the Permittee land applies bulk residuals, adequate measures shall be taken to prevent wind
erosion and surface runoff from conveying residuals from the land application sites onto adjacent
properties or into surface waters. [G.S. 143-215.1 ]
7. When the Permittec land applies bulk residuals, a suitable vegetative cover shall be maintained on land
application sites onto which residuals are applied, or application shall be in accordance with the crop
management plan outlined by the local Cooperative Extension Office, the Department of Agriculture
and Consumer Services, the Natural Resource Conservation Service, or an agronomist and as approved
by the Division. [15A NCAC 02T .1109(b)(1)]
8. Bulk residuals shall not be land applied under the following conditions
a. if the residuals are likely to adversely affect a threatened or endangered species listed under section
4 of the Endangered Species Act or its designated critical habitat;
b. If the application causes prolonged nuisance conditions;
c. If the land fails to assimilate the bulk residuals or the application causes the contravention of surface
water or groundwater standards;
d. If the land is flooded, frozen or snow-covered, or is otherwise in a condition such that runoff of the
residuals would occur;
e. Within the 100-year flood elevation, unless the bulk residuals are injected or incorporated within a
24-hour period following a residuals land application event;
f. During a measurable precipitation event (i.e., greater than 0.01 inch per hour), or within 24 hours
following a rainfall event of 0.5 inches or greater in a 24-hour period;
g. If the slope is greater than 10% for surface applied liquid residuals, or if the slope is greater than
18% for injected or incorporated bulk liquid residuals;
h. if the land does not have an established vegetative cover unless the residuals are incorporated or
injected within a 24-hour period following a residuals land application event. Any field that is in a
USDA no -till program shall be exempted from meeting this vegetative cover requirement;
i. If the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
j. If the vertical separation of bedrock and the depth of residuals application is less than one foot;
k. Application exceeds agronomic rates.
[15A NCAC 02T .l 109]
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9. The Permittee shall notify all third -party entities receiving bulk distributed Class A industrial byproduct
residuals that land application activities occurring on the third-party's property shall meet the
requirements in 15A NCAC 02T .1108(b)(1) and 02T .1109(b) (i.e., Conditions II.8. and III.8.,
respectively). [15A NCAC 02T .1103(5)]
10. All residuals shall be adequately stored to prevent untreated leachate runoff. The finished product may
be placed on a concrete pad, placed under shelter or physically covered until it is distributed to a third -
party entity. If bulk residuals are to be applied, the residuals may be staged at the application site for
up to 30 days for biological residuals, and 60 days for non -biological residuals. if an alternate storage
site is used, approval must be obtained from the Division. [15A NCAC 02T .0108(b)(1)]
11. A label shall be affixed to the bag or other container in which residuals are sold or given away for land
application, or an information sheet shall be provided to the person who receives Class A residuals. At
a minimum, the label or information sheet shall contain the following:
a. The name and address of the person who prepared the residuals;
b. A statement that residual land application is prohibited except in accordance with the instructions
on the label or information sheet;
c. A statement identifying that this material shall be prevented from entering any public or private
water supply source (including wells) and any surface water (e.g., stream, lake, river, wetland, etc.);
d. A statement that the residuals shall be applied at agronomic rates and recommended rates for its
intended use.
[15A NCAC 02T .1109(a)]
12. The Permittee shall not distribute bulk residuals to any person or entity known to be applying residuals
contrary to the conditions of this permit. The Permittee shall report to the Fayetteville Regional Office
as per reporting conditions under Condition W.8. any person or entity known to be applying residuals
contrary to the condition of this permit. [15A NCAC 02T . 1103(a)]
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IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division -required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed. [ 15A NCAC 02'1' .0108(c)]
Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). Residuals that tests or is classified as a hazardous or toxic waste under 40
CFR Part 261 shall not be used or disposed under this permit. The analyses [corrosivity, ignitability,
reactivity, and toxicity characteristic leaching procedure (TCLP)l shall be performed at the
frequency specified in Attachment A, and the Permittee shall maintain these results for a minimum of
five year. Any exceptions from the requirements in this condition shall be specified in Attachment A.
The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
Arsenic (5.0)
I 1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
I 1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
I 1,.1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
j 2.4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
j Hexachloroben-zene (0.13)
Tetrachloroethylene (0.7) I
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0 008)
Toxaphene (0.5) I
Chloroform (6.0)
Chromium (5.0)
I Hexachloro-.l,3-butadiene (0.5)
Hexachloroethane (3.0)
1 Trichloroethylene (0.5)
2,4.5-Trichlorophenol (400.0)
in -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)
Methoxyehlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A, the
Pennittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
[15A NCAC 13A .0102(b), 02T .1 101, 02T .1 105]
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3. An analysis shall be conducted on the residuals from each source generating facility at the frequency
specified in Attachment A, and the Permittee shall maintain the results for a minimum of five years.
The analysis shall include the following parameters:
Aluminum
Mercury
Potassium
Ammonia -Nitrogen
Molybdenum---
---Selenium
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite Nitrogen
I Sodium Adsorption Ratio
(SAR)
Calcium
Percent Total Solids
TKN
Copper
pH
I Zinc
Lead
Phosphorus
Magnesium I
Plant Available Nitrogen
L (by calculation)
[15A NCAC 02T .]101]
4. Residuals shall be monitored for compliance with pathogen reduction requirements at the frequency
specified in Attachment A, and at the time indicated in the sampling and monitoring sections of the
approved O&M plan. The required data shall be specific to the stabilization process utilized, and
sufficient to demonstrate compliance with the Class A pathogen reduction requirements in 15A NCAC
02T .1106 (a) and (b)(2) shall be met. Any exceptions from the requirements in this condition shall be
specified in Attachment A. [15A NCAC 02T .1106, 02T .1107, 02T .l 111(c)]
5. Laboratory parameter analyses shall be performed on the residuals as they are distributed, and shall be
in accordance with the monitoring requirements in 15A NCAC 02B .0505. [15A NCAC 02B .0505]
6. The Permittee shall maintain records tracking all bulk residual distribution or land application events
performed by the Permittee. At a minimum, these records shall include the following:
a. Source of residuals;
b. Date of distribution/land application;
c. Name and address of recipient of residuals;
d. Volume of residuals distributed to each recipient;
e. Intended use of residuals;
f. If land application events performed by the Permittee:
i. When the agronomic rate is on the basis of Nitrogen, then the Nitrogen Application Rate based
on RYEs (if using data obtained from the North Carolina State University Department of Soil
Science Website, the printout page shall be kept on file and reprinted every five years).
ii. When the agronomic rate is on the basis of some other nutrient than Nitrogen, then this shall
be included as part of the Operations & Maintenance Plan required in Condition III.2. A set of
calculations shall be performed to show that the residuals are being applied at an agronomic
rate on the basis of this limiting nutrient. These records shall be kept for a minimum of five
years and shall be available for inspection.
[15A NCAC 02T .0108(a)]
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7. Three copies of an annual report shall be submitted on or before March I". The annual report shall
meet the requirements described in the Instructions for Residuals At1plication Annual Reporting Forms.
Instructions for reporting and annual report forms are available at
Lap:41decl.nc. Lov/aboLiUdivisions!water-resourceshvater-resources-i)erm its!wastewater-brancll!non-
discharae-pernnittins,-unit/rei)ortini,-forms, or can be obtained by contacting the Non -Discharge
Permitting Unit directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[I 5A NCAC 02T .1111(a)]
8. Noncompliance Notification
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone number (910)
433-3300, 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. Distribution of residuals abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to surface waters.
c. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
e. Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure that the problem does not recur. [15A NCAC 02T .0105(l), 02T .0108(b)(1)]
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan. [ 15A NCAC 02T .0108(b)]
2. Prior to each bulk residuals distribution event, the Permittee or his designee shall inspect the residuals
storage, transport and distribution facilities to identify malfunctions, facility deterioration and operator
errors that could result in discharges to the environment, a threat to human health or a public nuisance.
The Permittee shall maintain an inspection log that includes, at a minimum, the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken. The Permittee
shall maintain this inspection log for a period of five years from the date of inspection, and this log
shall be made available to the Division upon request. [15A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the distribution sites or facilities permitted herein at
any reasonable time for the purpose of determining compliance with this permit; may inspect or copy
any records required to be maintained under the terms and conditions of this permit; and may collect
groundwater, surface water or leachate samples. [G.S. 143-215.3(a)(2)]
WQ0039924 Version 1.0 Shell Version 171103 Page 9 of 10

VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit shall become voidable if the residuals distribution events are not carried out in accordance
with the conditions of this permit. [ 15A NCAC 02T .0110]
3. This permit is effective only with respect to the nature and volume of residuals described in the permit
application and other supporting documentation. [G.S. 143-215.1]
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under the Division's General Permit NCGO10000; any requirements pertaining to wetlands under 15A
NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter
143 of the General Statutes. [15ANCAC 02T .0105(c)(6)]
5. 1n the event the residuals program changes ownership or the Permittee changes his name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner. [15A NCAC 02T .0104]
6. This permit is subject to revocation or unilateral modification upon 60-day notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110. [ 15A NCAC 02T .0110]
7. Unless the Division Director grants a variance, expansion of the permitted residuals program contained
herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b).
[15A NCAC 02T .0120]
8. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 281h day of June 2018
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSIONi
?Linda Culpepper, Interim Director
Division of Water Resources
By Authority of the Environmental Ma tipacn ent Commission
Permit Number `'VQ0039924
WQ0039924 Version 1.0 Shell Version 171103 Page 10 of 10

ATTACHMENT A — Approved Residual Sources
Certification Date: June 28, 2018
von Drehle Corporation
Permit Number: WQ0039924
Version: 1.0
Maximum
Monitoring
Monitoring Monitoring
Frequency for
Approved
Owner Facility Name County
Permit Biological
Dry Tons
Frequency for
I Frequency for
Pathogen &
Mineralization
Number Residuals
Per Year 1
Non -hazardous
=
Metals and
s's Vector Attraction
Rate
Characteristics
Nutrients
Reductions' S 6
von Drehle Corporation
von Drehle Corporation W WTP Richmond
WQ0039924 No 1G,499
f
Annually
See Footnote 5 See lbotnote 5
- - _--•
0 1
-—_......_.._.,�.
Total i
16,499
I . Maximum Dry Tons per Year is the amount of residuals approved for distribution from each permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP. ignitability, reactivity, and corrosivity) as stipulated under permit Condition 1V.2
3. Testing of metals and nutrients as stipulated under permit Condition iV.3
4. Analyses of pathogen reductions as stipulated under permit Condition IVA.
5 Monitoring frequencies are based on the actual dry torts applied per year using the table below, unless specified ahove.
Dry Tons Distributed 1 Monitoring Frequency
(short tons per year} (Established in 40 CFR 503 and ISA NCAC 02T.1111)
<319 11 - - _ I/Yedr
=>3I9 - t1,650 _ _ I Quaver i4 times per year
=> 1,650 - <16,500 1/60 Days (6 times per year
=>16,500 I 1/month (l2 times peryutr) —
6. Class A industrial byproduct residuals arc exempt from meeting the vector attraction reduction requirements in Condition IVA, provided they are not mixed with residuals that have been geiierdled
during the treatment of domestic wastewater, the treatment of animal processing wastewater. or die biological treatment of industrial wastewater. The Class A industrial byproduct residuals must
be treated and processed in a manner as to not meet the definition of"Biological Residuals" as defined in 15A NCAC 02T.1102(6).
If no distribution events occur during a required sampling period (e.g. no distribution of residuals occur during an entire year when annual monitoring is required), then no sampling data
is required during the period of inactivity. The annual report shall include an explanation for missing sampling data. Those required to submit the annual report to EPA may be required to
make up the missed sampling, contact the EPA for additional information and clarification.
W00039924 Version 1.0 Attachment A Paae I of I

SECTION II
RESIDUALS SOURCE CERTIFICATION ATTACHMENT - FIBER CLAY

DWR
State of North Carolina
Department of Environmental Quality
Division of Water Resources
Division of Water Resources RESIDUALS SOURCE CERTIFICATION
INSTRUCTIONS FOR FORM: RSC 06-16
Please use the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these
instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of additional
information requested. Failure to submit all of the required items will lead to additional processing and review time for the
permit application. Unless otherwise noted, the Applicant shall submit one original and two conies of the application and
sunportine documentation
For more information, visit the Water Quality Permitting Section's Non -Discharge Permitting
General — This certification provides detailed information of residuals source generating facility and its residuals quality for land
application, distribution, or disposal in accordance with 15A NCAC 02T .1100. Do not submit this certification for review without
a corresponding application form (FORM: RLAP 11-15, FORM: DCAR 11-15, or FORM: SDR 11-15).
Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed
below.
A. Residuals Source Certification (FORM: RSC 11-15):
® Submit the completed and appropriately executed Residuals Source Certification (FORM: RSC 11-15) form. Please do not
make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachments to the
application may be made, as long as the attachments are numbered to correspond to the section and item to which they refer.
❑ For new or renewed permits, submit a separate certification for each source facility.
® For modified permits, submit a separate certification for only those facilities that are affected by the proposed modification.
❑ Complete the residuals source facility summary page. List all new, renewed, or modified facilities.
B. Residuals Source -Generating Facility Information:
® For each source facility, attach the following:
® Vicinity map - A vicinity map that shows the location of the facility and meets all of the criteria in the "Map Guidance for
Residuals Land Application Permits".
® Process flow diagram and/or narrative - A detailed narrative and/or process flow diagram that describes how the residuals
are to be generated, treated, processed, and stored at the facility.
® Quantitative justification for residuals production rate - A quantitative justification for the value provided in Item 1. 8.
Ensure that the amount of residuals listed is the maximum amount expected to be generated by the facility for the life of the
permit. In addition, ensure that this amount is equivalent to that which is actually to be land applied, distributed, and/or
disposed, including any chemicals, amendments, or other additives that are added to the residuals during processing.
® Sampling plan - A detailed sampling plan for the residuals source -generating facility. Ensure that the plan identifies
sampling points, sampling frequency, sample type, as well as the Division -certified laboratory to be used. In addition, ensure
that the plan details how the facility and/or the residuals are monitored for any applicable pathogen reduction and vector
attraction reduction requirements. Note that all sampling and monitoring must be completed on the residuals as they are to
be land applied, distributed, and/or disposed.
C. Residuals Quality Information:
® For each source facility, attach the following:
® Laboratory analytical reports and operational data - reports for all laboratory analyses used to complete this certification.
® Documentation that the facility complies and/or the residuals comply with any applicable pathogen reduction and vector
attraction reduction requirements.
❑ For new facility that may have not yet been constructed and analytical results of residuals cannot be obtained, please attach
analytical results of residuals generated from a similar facility along with the description of similarities of the two facilities.
INSTRUCTIONS FOR FORM: RSC 06-16 Page 1 of 1

RESIDUALS SOURCE FACILITY SUMMARY
Applicant's name: von Drehle Corporation, Cordova, NC facility
Status a
Code
Facility Permit Holder
Facility Name
County
Permit Number
Maximum Dry Tons Per Year
Current b
Proposed
N
Von Drehle Corporation
Cordova, NC
Richmond
16,499
35,000
'Status Code for source facility are: ♦ N (New) ♦ R (Renewed) ♦ M (Modified) ♦ D (Deleted)
b The amount of residuals currently permitted for distribution, land application, or disposal (i.e, not applicable to new facility).
SUMMARY FOR FORM: RSC 06-16 Page 1

Division of Water Resources
I.
II.
State of North Carolina
Department of Environmental Quality
Division of Water Resources
RESIDUALS SOURCE CERTIFICATION
FORM: RSC 06-16
RESIDUALS SOURCE -GENERATING FACILITY INFORMATION (See Instruction B.):
1. Facility Name: von Drehle Corporation
2. Facility permit holder is: ❑ Federal, ❑ State, ❑ Local Government, or ® Private.
Facility permit issued by: ❑ Div. of Water Resources, ❑ Div. of Environmental Health,
or ❑ Other (explain: ).
3. Facility contact person and title: Chris Fowler, Land Application ORC
Complete mailing address: 126 First Street
City: Cordova State: NC Zip: 28330-
Telephone number: [phone] E-mail address: chris.fowler(o-)vondrehle.com
4. Facility physical address: 126 First Street
City: Cordova State: NC Zip: 28330-
Coordinates: Latitude: 34' 55' 2.73" Longitude: 79' 49' 42.77"
Datum: NAD 83 Level of accuracy: 1'
Method of measurement: Man
5. Purpose of the facility:
❑ treatment of municipal wastewater, ❑ treatment of 100% domestic wastewater,
❑ treatment of potable water, ® treatment of 100% industrial wastewater,
❑ treatment of industrial wastewater mixed with domestic wastewater,
(approximate percentages: % industrial and % domestic)
❑ other (explain: ).
6. Does the facility have an approved pretreatment program: ❑ Yes ® No
7. Facility permitted/design flow: 0.395 MGD and facility average daily flow: 0.272 MGD
8. Average amount of residuals being generated at this facility 35,000 dry tons per year.
9. Specify the following regarding treatment and storage volumes available at the facility:
Type and volume of residuals treatment: Separation and Belt Press
Type and volume of residuals storage (i.e., outside of residuals treatment units): Storage pad 150 cubic yards
RESIDUALS QUALITY INFORMATION (See Instruction C.):
1. Specify if residuals are regulated under:
❑ 40 CFR Part 503 or ® 40 CFR Part 257.
Note: Only residuals that are generated during domestic/municipal wastewater treatment processes are regulated under 40
CFR Part 503, otherwise, the residuals are regulated under 40 CFR Part 257.
2. Specify if residuals are defined under 15A NCAC 02T.1102(6) as:
❑ Biological ® Non -Biological
FORM: RSC 06-16 Page 1 of
5

Note: Biological residuals are residuals that have been generated during the treatment of domestic wastewater, animal
processing wastewater, or the biological treatment of industrial wastewater (biological treatment is a system that utilizes
biological processes including lagoons, activated sludge systems, extended aeration systems, and fixed film systems).
3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non -hazardous under
RCRA: (Note - this item does not have to be completed for facilities that are less than 0.5 MGD in design flow that treat
100% non -municipal, domestic wastewater only)
a. Are the residuals listed in 40 CFR §261.31-§261.33: ❑ yes ® no.
If yes, list the number(s):
b. Specify whether or not the residuals exhibit any of the characteristics defined by 40 CFR §261.21-
261.24: ❑ yes ® no.
Fill in the following tables with the results of the latest toxicity characteristic leaching procedure (TCLP) analysis as well
as those for corrosivity, ignitability, and reactivity:
Laboratory: Microbac and Date of analysis: March 6, 2020
Passed corrosivity test: ® yes ❑ no. pH: s.u. (2 < pH < 12.5)
Passed ignitability test: ® yes ❑ no. Flashpoint: WNI IF (> 140°F)
Passed reactivity test: ® yes ❑no. HCN: <10.0 mg/kg (<250) & H2S: <100 mg/kg (<500)
TCLP Parameter
Limit
(mg/1)
Result
(mg/1)
TCLP Parameter
Limit
(m9/1)
Result
(mg/1)
Arsenic
5.0
<0.200
Hexachlorobenzene
0.13
<0.05
Barium
100.0
0.246
Hexachloro-1,3-Butadiene
0.5
<0.05
Benzene
0.5
<0.05
Hexachloroethane
3.0
<0.05
Cadmium
1.0
<0.0200
Lead
5.0
<0.2
Carbon Tetrachloride
0.5
<0.05
Lindane
0.4
<0.0005
Chlordane
0.03
<0.0005
Mercury
0.2
<0.002
Chlorobenzene
100.0
<0.05
Methoxychlor
10.0
<0.0005
Chloroform
6.0
<0.05
Methyl Ethyl Ketone
200.0
<0.10
Chromium
5.0
<0.0500
Nitrobenzene
2.0
<0.05
m-Cresol
200.0
<0.05
Pentachlorophenol
100.0
<0.25
o-Cresol
200.0
<0.05
Pyridine
5.0
<0.25
p-Cresol
200.0
<0.05
Selenium
1.0
<0.35
Cresol
200.0
<0.15
Silver
5.0
<0.10
2,4-D
10.0
<0.02
Tetrachloroethylene
0.7
<0.05
1,4-Dichlorobenzene
7.5
<0.05
Toxaphene
0.5
<0.01
1,2-Dichloroethane
0.5
<0.05
Trichloroethylene
0.5
<0.05
1, 1 -Dichloroethylene
0.7
<0.05
214,5-Trichlorophenol
400.0
<0.05
2,4-Dinitrotoluene
0.13
<0.05
2,4,6-Trichlorophenol
2.0
<0.05
Endrin
0.02
<0.0005
2,4,5-TP (Silvex)
1.0
<0.002
Heptachlor and its Hydroxide
0.008
<0.0005
Vinyl Chloride
0.2
<0.1
FORM: RSC 06-16 Page 2 of 5

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 Distribution/Land Application: Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: Microbac and Date of analysis: November 23, 2020
Parameter
Ceiling
Monthly Average
Result
Concentration Limits
Concentration Limits
(ClassA & ClassB)
(Class A Only)
(mglk-g)
(mglkg)
(mglkg)
Arsenic
75
41
<1.8900
Cadmium
85
39
0.1990
Copper
4,300
1,500
32.0000
Lead
840
300
<1.8900
Mercury
57
17
<0.6580
Molybdenum
75
n/a
<5.6700
Nickel
420
420
<3.7800
Selenium
100
100
<1.8900
Zinc
7,500
2,800
74.3000
b. For Surface Disposal Unit (landfill): Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: and Date of analysis:
Distance from Disposal
Unit to Boundary to
Closest Property Line
(meters, check one)
Arsenic
(mg/kg)
Chromium
(mg/kg)
Nickel
(mg/hg)
❑ > 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
62
450
420
Result (mg/kg)
FORM: RSC 06-16 Page 3 of

5. Nutrient/Micronutrient Determination: Complete the following:
a. Total solids: 42.3 %.
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
micronutnent parameters:
Laboratory: Microbac and Date of analysis: November 23, 2020
Parameter
Result
(mg1kg)
Aluminum
1,3 60.00
Ammonia -Nitrogen
<4.50
Calcium
21,900.00
Magnesium
2,220.00
Nitrate -Nitrite Nitrogen
0.69
pH (Standard Unit)
8.20
Phosphorus
3.50
Potassium
<94.50
Sodium
805.00
Total Kjeldahl Nitrogen
1,940.00
c. Using the results listed in Item II. 5b. above, calculate the sodium adsorption ration (SAR): 0.90
[Note: If residuals contain SAR of 10 or higher, the applicant shall obtain recommendations from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, a
North Carolina Licensed Soil Scientist, or an agronomist, prior to land application of residuals. The recommendations shall
address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a mechanism for maintaining site integrity and
conditions conducive to crop growth].
d. Specify the mineralization rate to be used in calculating the plant available nitrogen (PAN) of the residuals: 0.40 %. This
rate is a (check one): ® 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:
e. Calculate the PAN for the residuals (i.e., on a dry weight basis) and fill the results in the following table:
Application Method
First (111) Year PAN
Five -Year
Maximum Adjusted PAN
(mg1kg)
(mg/kg)
Surface
777
1,164
Injection/Incorporation
779
1,166
6. Other Pollutants Determination: Specify whether or not there are any other pollutants of concern in the residuals and provide
the results of the latest analyses:
FORM: RSC 06-16 Page 4 of

7. Pathogen Reduction: Per 15A NCAC 02T.1106, specify how residuals will meet the pathogen reduction requirements:
a. For Distribution/Land Application of 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 followings (except for non -biological residuals):
❑ Alternative 1 [15A NCAC 02T.I 106(b)(3)(A)] - Time/Temperature Compliance.
❑ Alternative 2 [15A NCAC 02T.I 106(b)(3)(B)] - Alkaline Treatment.
❑ Alternative 3 [15A NCAC 02T.I 106(b)(3)(C)] - Prior Testing for Enteric Virus/Viable Helminth Ova.
❑ Alternative 4 [15A NCAC 02T.1106(b)(3)(D)] - No Prior Testing for Enteric Virus/Viable Helminth Ova.
❑ Alternative 5 [15A NCAC 02T.I 106(b)(3)(E)-(K)] - Process to Further Reduce Pathogens (PFRP).
Specify one: ❑ composting, ❑ heat drying, ❑ heat treatment,
❑ thermophilic aerobic digestion, ❑ beta ray irradiation,
❑ gamma ray irradiation, or ❑ pasteurization.
b. For Land Application of Class B:
❑ Alternative 1 [15A NCAC 02T. 1 106(c)(1)] - Fecal Coliform Density Demonstration.
❑ Alternative 2 [15A NCAC 02T.I 106(c)(2)] - Process to Significantly Reduce Pathogens (PSRP).
Specify one: ❑ aerobic digestion, ❑ air drying, ❑ anaerobic digestion,
❑ composting, or ❑ lime stabilization.
c. For Surface Disposal:
❑ 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.
❑ Exempt -If Daily Cover Alternative is chosen in Item II.8. below [15A NCAC 02T.1106(a)(2)].
❑ Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
8. Vector Attraction Reduction (VAR): Per 15A NCAC 02T.1107, specify how residuals will meet the VAR requirements:
❑ Alternative 1 [15A NCAC 02T. I 107(a)(1)] - 38% Volatile Solids Reduction (Aerobic/Anaerobic Digestion).
❑ Alternative 2 [15A NCAC 02T.1107(a)(2)] - 40-Day Bench Scale Test (Anaerobic Digestion).
❑ Alternative 3 [15A NCAC 02T.1107(a)(3)] - 30-Day Bench Scale Test (Aerobic Digestion).
❑ Alternative 4 [15A NCAC 02T. 1 107(a)(4)] - Specific Oxygen Uptake Rate Test (Aerobic Digestion).
❑ Alternative 5 [15A NCAC 02T.1107(a)(5)] - 14-Day Aerobic Processes.
❑ Alternative 6 [15A NCAC 02T. 1 107(a)(6)] - Alkaline Stabilization.
❑ Alternative 7 [15A NCAC 02T.I 107(a)(7)] - Drying of Stabilized Residuals.
❑ Alternative 8 [15A NCAC 02T.I 107(a)(8)] - Drying of Unstabilized Residuals.
❑ Alternative 9 [15A NCAC 02T.1107(a)(9)] -Injection. .
❑ Alternative 10 [15A NCAC 02T.1107(a)(10)] -Incorporation.
❑ Alternative for Surface Disposal Units Only - Soil/Other Material Cover [I 5A NCAC 02T. 1107(b)(2)].
® Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
Note: For animal processing residuals, only alternatives 9 or 10 may be chosen due to the nuisance conditions that typically occur
when these residuals are applied and left on the land surface.
FORM: RSC 06-16 Page 5 of

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DRAWN BY: RESIDUALS
DATE:
1/8/2021 81 SOILS, LLC Project No. 2014-110

Process Flow Diagram and Narrative

FIBER CLAY PROCESS NARRATIVE
Recycled paper in bales is released and placed in the pulping process. There, mixed with water, the
recycled paper is reduced to pulp. The pulp is sent through a de -trashing system, where large
metals and plastics such as plastic bags or soda cans are removed. These large rejects are deposited
in an indoor pit to be removed to landfill. From here, the accepted material is sent to a holding
chest where it is fed into the pulp cleaning and screening system. The first stage of the cleaning
and screening system is responsible for the removal of dense contaminants such as glass and small
metal pieces such as staples. The next stage is the coarse screening stage which removes smaller
plastics that are slightly larger than .06 inches in diameter; these plastics, as well as the glass and
small metals, are ultimately deposited in the previously mentioned indoor pit. Following this
stage is the centrifugal forward cleaning stage. In this stage, lighter, but still relatively dense
particles, such as sand and dirt, are separated by centrifugal force from pulp and ultimately rejected
to the mill sump. The final stage of cleaning and screening is the fine screening stage.
In the fine screening stage, very small (slightly larger than. 005 inches), light contaminants s u c h
a s s t i c k i e s, ink particles and smaller dirt particles are removed and ultimately sent to the mill
sump as well. From the mill sump, these rejected solids are sent to a Krofta DAF clarifier where
they are coagulated, floated and skimmed off the surface and sent to a belt press where it is
dewatered to approximately 40% solids and deposited onto the fiber clay pad outside. The
accepted material from the fine screening stage is sent to a Variosplit washing system where
through a dewatering process of the pulp, very fine ash and fiber fines are removed. These rejects
are sent to a Tauro DAF clarifier where they are removed in a similar fashion as with the Krofta
and sent to the belt press to be dewatered and deposited on the fiber clay pad. Accepted pulp
from the washing stage is sent to a screw press for further dewatering, and the pulp is then fed
into a high temperature dispersion system, where any remaining small contaminants such as dirt
and stickies are pulverized to a size smaller than what can be seen with the human eye.
The pulp is also mixed with a bleaching agent at high temperature and is sent to a bleaching tower
to allow the bleaching process to take place and increase pulp brightness. The pulp is then mixed
with water and diluted to 5% solids and sent to the paper machines. At the paper machines, the
pulp is applied to a press felt, while simultaneously being dewatered with a poly wire belt; a
sheet of paper is formed, which is pressed, dried, and rolled up to be shipped. In this process,
more ash and fines are removed and are ultimately sent to a Megacell DAF clarifier where, as
with the other DAF units, a fiber clay blanket is formed, sent to the belt press and then the fiber

clay pad. The water from each of these DAF units is generally re -used in the process, with the
excess being discharged to the City of Rockingham wastewater treatment system.
Following is the process flow schematic diagram for the water and solids in von Drehle Corporation
Cordova's Paper Process.

Recycled Paper Process for von Drehle Corporation
Recycled
Paper in
Bales
Fail
Dump
Chest
HD
Cleaner
Coarse
Screen
Fail Fine
Screens
Chemicals
Pulping Water
Process
Trash & Size Pass
Screens
Fail
Pass
VarioSplit Screw Press
Tauro
rifical
Krofta
Reject Fail Centrifugal DAF
Chest
t
Cleaning
Landfill Belt Press
Fiber Clay
,and Applicatioi
Or Distribution
Process Water
Recycled or sent to
City of Rockingham
Bleaching
Tower
Paper
Machines

Justification of Residuals Production Rate

JUSTIFICATION OF RESIDUALS PRODUCTION RATE
von Drehle Corporation produces approximately 22,500 dry tons of the Fiber Clay annually. In order
to account for variability, the dry ton permit limit will be set at 35,000 dry tons.

Sampling Plan

FIBER CLAY SAMPLING PLAN
von Drehle Fiber Clay is transported by conveyor from the belt presses to the storage pad in the back
at von Drehle's facility in Cordova. Fiber Clay will be distributed by placement onto sealed trailers that
will be routed to one of several marketing sites, non-specific receiver sites or to the landfill as daily
cover.
Based on the amount of residual to be distributed, von Drehle Fiber Clay will be sampled monthly from
the belt presses. Representative samples of von Drehle Fiber Clay will be collected and composited
prior to the beginning of the preceding monthly cycle so that data will be made available prior to that
distribution period. Seven independent grab samples will be collected monthly for Salmonella analysis.
These samples will be immediately placed on ice and delivered to a lab certified in the testing protocol.
Since there are no labs that are certified for the state of North Carolina for the Salmonella testing, at a
minimum this lab has certification such as Nation Environmental Laboratory Accreditation Conference
(NELAC). If at an any point, North Carolina has a lab that becomes accredited and is close enough to
meet the necessary hold times, they will be used. All samples will be sent to qualified laboratories that
are familiar with the environmental sample preparation and standards required. Annually, a residuals
solid sample will be analyzed for toxicity characteristics leaching procedure (TCLP). TCLP parameters
are listed below:
Arsenic
Cadmium
Chlorobenzene
o-Cresol
Cresol
1,2-Dichloroethane
Endrin
Hexachloroethane
Lindane
Methyl ethyl ketone
Pyridine
Tetrachloroethylene
2,4,5-Trichlorophenol
Vinyl chloride
Barium
Benzene
Carbon tetrachloride
Chlordane
Chloroform
Chromium
m-Cresol
p-Cresol
2, 4-D
1,4-Dichlorobenzene
1, 1 -Dichloroethylene
2,4-Dinitrotoluene
Hexachlorobenzene
Heptachlor (and its hydroxide)
Lead
Hexachloro-1,3-butadiene
Mercury
Methoxychlor
Nitrobenzene
Pentachlorophenol
Selenium
Silver
Toxaphene
Trichloroethylene
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)

Monthly (prior to the end of the preceding monthly period,) a composite Fiber Clay residual solid
sample will be collected and analyzed for: Cadmium, Copper, Lead, Nickel, Zinc, Aluminum,
Ammonia — Nitrogen, Nitrate -Nitrite, Nitrogen, % Total Solids, pH, Phosphorus, Potassium, TKN,
and Calcium Carbonate Equivalency (CCE). From this information, the Plant Available Nitrogen
(PAN) and Agricultural Lime Equivalency (ALE) will be calculated. This will be the basis for the
application rates that will be used in the next monitoring period and changes will be made to the
product label to reflect the most recent analytical data.

Residual Analytical Reports

VMICROBAC
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Project Description
Residuals Sample -Annual
For:
Mr. Chris Fowler
Von Drehle Corporation
126 First Street
Cordova, NC 28330
Administration
Brittany Smith
Friday, March 6, 2020
Please find enclosed the analytical results for the samples you submitted to Microbac Laboratories. Review and compilation of
your report was completed by Microbac Laboratories, Inc. - Fayetteville. If you have any questions, comments, or require further
assistance regarding this report, please contact your service representative listed above.
I certify that all test results meet all of the requirements of the accrediting authority listed within this report. Analytical results are
reported on a 'as received' basis unless specified otherwise. Analytical results for solids with units ending in (dry) are reported
on a dry weight basis. A statement of uncertainty for each analysis is available upon request. This laboratory report shall not be
reproduced, except in full, without the written approval of Microbac Laboratories. The reported results are related only to the
samples analyzed as received.
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com
Page 1 of 14

��0MICROBAC°
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOBO372
Von Drehle Corporation Project Name: Residuals Sample - Annual
Mr. Chris Fowler Project / PO Number: 2030767
126 First Street Received: 02/25/2020
Cordova, NC 28330 Reported: 03/06/2020
Sample Summary Report
Sample Name Laboratory ID Client Matrix Sample Type Sample Begin Sample Taken Lab Received
Residual from paper plant KOB0372-01 Solid Grab 02/25/20 12:09 02/25/20 14:57
Page 2 of 14

IMICROBAC
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Analytical Testing Parameters
Client Sample ID: Residual from paper plant
Sample Matrix: Solid Collected By: Wright
Lab Sample ID: KOB0372-01 Collection Date: 02/25/2020 12 0
Analyses Subcontracted to: Microbac Laboratories Inc., - Marietta, OH
Inorganics Total
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
EPA 9045D
pH
8.4
S.U.
1
H4
03/05/20 1526
03/05/20 1630
EPT
SW-846 7.3.3.2
Reactive Cyanide
<10.0
10.0
mg/kg
1
y
03/06/20 1110
03/06/20 1146
JRH
SW-846 7.3.4.1
Reactive Sulfide
<100
100
mg/kg
1
y
03/06/20 1006
03/06/20 1048
EPT
General Parameters
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
ASTM D2216-10
Percent Solids
38.0
1.00
% (by wt.)
1
y
03/03/20 1327
03/04/20 0609
CEi
EPA 1030
Ignitability of Solids
�2 2
2.2
mm/sec
1
y
03/04/20 0000
CSH
Metals TCLP by AA
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
EPA 7470A
Mercury
<0.00200
0.00200
mg/L
1
03/02/20 0656
03/03/20 1013
TMM
Metals TCLP by ICP
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
EPA 6010E
Arsenic
<0.200
0.200
mg/L
1
y
03/02/20 0714
03/02/20 1640
KHL
Barium
0.246
0.100
mg/L
1
y
03/02/20 0714
03/02/20 1640
KHL
Cadmium
<0.0200
0.0200
mg/L
1
y
03/02/20 0714
03/02/20 1640
KHL
Chromium
<0.0500
0.0500
mg/L
1
y
03/02/20 0714
03/02/20 1640
KHL
Lead
<0.200
0.200
mg/L
1
y
03/02/20 0714
03/02/20 1640
KHL
Selenium
<0.350
0.350
mg/L
1
y
03/02/20 0714
03/02/20 1640
KHL
Silver
<0.100
0.100
mg/L
1
y
03/02/20 0714
03/02/20 1640
KHL
Volatile Organic Compounds TCLP
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
by GCMS
EPA 8260B
Benzene
<50.0
50.0
uglL
10
03/04/20 1723
ZTL
2-Butanone
<100
100
ug/L
10
03/04/20 1723
ZTL
Carbon tetrachloride
<50.0
50.0
ug/L
10
03/04/20 1723
ZTL
Chlorobenzene
<50.0
50.0
ug/L
10
03/04/20 1723
ZTL
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NIC 28306 1910.864.1920 p I www.microbac.com I Page 3 of 14

(t-DMICRORAC'
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Client Sample ID: Residual from paper plant
Sample Matrix: Solid Collected By: Wright
Lab Sample ID: KOB0372-01 Collection Date: 02/25/2020 12 '9
Volatile Organic Compounds TCLP
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
by GCMS
Chloroform
<50.0
50.0
ug/L
10
03/04/20 1723
ZTL
1,2-Dichloroethane
<50.0
50.0
ug/L
10
y
03/04/20 1723
ZTL
1,1-Dichloroethene
<50.0
50.0
ug/L
10
y
03/04/20 1723
ZTL
Tetrachloroethene
<50.0
50.0
ug/L
10
03/04/20 1723
ZTL
Trichloroelhene
<50.0
50.0
ug/L
10
03/04/20 1723
ZTL
Vinyl chloride
<100
100
ug/L
10
03/04/20 1723
ZTL
Surrogate: 4-Bromofluorobenzene
104
Limit: 86-115
% Rec
10
03/04/20 1723
ZTL
Surrogate: Dibromofluoromethane
95.9
Limit: 86-118
% Rec
10
03/04/20 1723
ZTL
Surrogate:1,2-Dichloroethane-d4
93.5
Limit: 80-120
% Rec
10
03/04/20 1723
ZTL
Surrogate: Toluene-d8
104
Limit: 88-110
% Rec
10
03/04/20 1723
ZTL
Herbicides TCLP by GC/ECD
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
EPA 8151A
2,4,5-TP (Silvex) [2C]
<2.00
2.00
ug/L
1
03/02/20 1600
03103120 2006
ECL
2,4-D [2C]
<20.0
20.0
ug/L
1
03/02/20 1600
03/03/20 2006
ECL
Surrogate: 2,4-Dichloropenylacetic acid
53.7
Limit: 20-144
% Rec
1
03/02/20 1600
03/03/20 2006
ECL
[2C]
Pesticides TCLP by GC/ECD
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
EPA 8081A
alpha -Chlordane
<0.500
0.500
ug/L
1
03/02/20 0910
03/04/20 2152
ECL
Endrin
<0.500
0.500
ug/L
1
03/02/20 0910
03/04120 2152
ECL
gamma Chlordane
<0.500
0.500
ug/L
1
03/02/20 0910
03/04120 2152
ECL
gamma-BHC (Lindane)
<0.500
0.500
ug/L
1
03/02/20 0910
03/04120 2152
ECL
Heptachlor
<0.500
0.500
ug/L
1
03/02/20 0910
03/04120 2152
ECL
Heptachlor epoxide
<0.500
0.500
ug/L
1
03/02/20 0910
03/04/20 2152
ECL
Methoxychlor
<0.500
0.500
ug/L
1
03/02/20 0910
03/04/20 2152
ECL
Toxaphene
<10.0
10.0
ug/L
1
03/02/20 0910
03/04/20 2152
ECL
Surrogate: 2,4,5,6-Tetrachloro-m-xylene
74.0
Limit: 20-130
% Rec
1
03102/20 0910
03/04/20 2152
ECL
Surrogate: Decachlorobiphenyl
49.9
Limit: 25-140
% Rec
1
03/02/20 0910
03/04/20 2152
ECL
(BZ-209)
Semivolatile Organic Compounds
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
TCLP by GCMS
EPA 8270C
Pyridine
<250
250
ug/L
1
y
03/02/20 1350
03/03120 1716
SCB
1,4-Dichlorobenzene
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03120 1716
SCB
2-Methylphenol
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03120 1716
SCB
3-,4-Methylphenol
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03/20 1716
SCB
Hexachloroethane
<50.0
50.0
ug/L
1
y
03/02/20 1350
03103/20 1716
SCB
Nitrobenzene
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03/20 1716
SCB
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 4 Of 14

('-.VMICROBAC`�
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Client Sample ID: Residual from paper plant
Sample Matrix: Solid Collected By: Wright
Lab Sample ID: K060372-01 Collection Date: 02/25/2020 12
Semivolatile Organic Compounds
TCLP by GCMS
Hexachlorobutadiene
2,4, 6-Trichlorophenol
2,4, 5-Trichlorophenol
2,4-Dinitrotoluene
Hexachlorobenzene
Pentachlorophenol
Surrogate: 2-FI uorophenol
Surrogate: Phenol-d5
Surrogate: Nitrobenzene-d5
Surrogate: 2-Fluorobi phenyl
Surrogate: 2,4,6-Tribromophenol
Surrogate: p-Terphenyl-d14
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03/20 1716
SCB
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03/20 1716
SCB
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03/20 1716
SCB
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03/20 1716
SCB
<50.0
50.0
ug/L
1
y
03/02/20 1350
03/03/20 1716
SCB
<250
250
ug/L
1
y
03/02/20 1350
03/03/20 1716
SCB
59.0
Limit: 19-119
% Rec
1
03/02/20 1350
03/03/20 1716
SC8
36.0
Limit: 10-120
% Rec
1
03/02/20 1350
03/03/20 1716
SCB
89.7
Limit: 35-114
% Rec
1
03/02/20 1350
03/03120 1716
SCB
94.9
Limit: 43-116
% Rec
1
03/02/20 1350
03/03120 1716
SCB
149
Limit: 22-142
% Rec
1
S1
03/02/20 1350
03/03/20 1716
SCB
84.3
Limit: 10-130
% Rec
1
03/02/20 1350
03/03/20 1716
SCB
Microbac Laboratories. Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 5 0 14

ff >,y M i f' Irl R, A C
1_..;
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Batch Quality Control Summary: Microbac Laboratories Inc., - Marietta, OH
Spike Source %REC RPD
Inorganics Total Result RL Units Level Result %REC Limits RPD Limit Notes
Batch B00O292 - Wet Chem -Default Prep - EPA 9045D
LCS (B00O292-BS1)
Prepared &Analyzed: 03/05/2020
pH
6.0
S.U. 6.03 99.6 0-200
LCS (B00O292-BS2)
Prepared & Analyzed: 03/05/2020
pH
9.0
S.U. 9.01 100 0-200
Duplicate (B00O292-DUP1)
Source: KOB0372-01
Prepared &Analyzed: 03/05/2020
pH
8.6
S.U. 8.4 1.89 5
Batch B000321 - Wet Chem -Default Prep - SW-846 7.3.4.1
Blank (B000321-BLK1)
Prepared &Analyzed: 03/06/2020
Reactive Sulfide
<100
100
mg/kg
LCS (B000321-BS1)
Prepared &Analyzed: 03/06/2020
Reactive Sulfide
<100
100
mg/kg 474 50-150
LCS (B000321-BS2)
Prepared & Analyzed: 03/06/2020
Reactive Sulfide
1250
100
mg/kg 1580 79.1 50-150
Duplicate (B000321-DUP1)
Source: MOB2142-01
Prepared &Analyzed: 03/06/2020
Reactive Sulfide
<100
100
mg/kg ND 50
Batch B000326 - Reactive Cyanide/Sulfide - SW-846 7.3.3.2
LCS (B000326-BS1)
Prepared &Analyzed: 03/06/2020
Reactive Cyanide
<500
500
mg/kg 0.5-100
Duplicate (B000326-DUP7)
Source: MOB2142-01
Prepared &Analyzed: 03/06/2020
Reactive Cyanide
<10.0
10.0
mg/kg ND
50
Spike Source %REC
RPD
General Parameters
Result
RL
Units Level Result %REC Limits RPD
Limit Notes
Batch B000130 - Wet-Solids-S - ASTM D2216-10
Blank (B000130-BLK1)
Prepared: 03/03/2020 Analyzed: 03/04/2020
Percent Solids
100
1.00
% (by
wt.)
LCS (B000130-BS1)
Prepared: 03/03/2020 Analyzed: 03/04/2020
Percent Solids
77.6
% (by 80.0 97.0 90-110
wt.)
Duplicate (B000130-DUP1)
Source: KOB0372-01
Prepared: 03/03/2020 Analyzed: 03/04/2020
Percent Solids
38.2
1.00
% (by 38.0 0.499
10
wt.)
Batch B000168 - Ignitability Prep - EPA 1030
LCS (B000168-BSI) Prepared &Analyzed: 03/04/2020
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com
Page 6 of 14

Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Spike Source %REC RPD
General Parameters Result RL Units Level Result %REC Limits RPD Limit Notes
Batch B000168 - Ignitability Prep - EPA 1030
LCS (B000168-BSI)
Ignitability of Solids 2.5
Metals TCLP by AA Result
Batch B000010 - EPA 245.1 & EPA 7470A - EPA 7470A
Prepared & Analyzed: 03/04/2020
2.2 mm/sec 2.4 102 88-111
Spike Source %REC RPD
RL Units Level Result %REC Limits RPD Limit Notes
Blank (B000010-BLK1)
Prepared: 03/02/2020 Analyzed: 03/03/2020
Mercury
<0.000200 0.000200
mg/L
LCS (B000010-BSI)
Prepared: 03/02/2020 Analyzed: 03/03/2020
Mercury
0.00388
0.000200
mg/L 0.00400 96.9 80-120
Matrix Spike (B000010-MS1)
Source: MOB1975-03
Prepared: 03/02/2020 Analyzed: 03/03/2020
Mercury
0.0378
0.00200
mg/L 0.0400 ND 94.4 75-125
Matrix Spike Dup (B000010-MSD1)
Source: MOB1975-03
Prepared: 03/02/2020 Analyzed: 03/03/2020
Mercury
0.0373
0.00200
mg/L 0.0400 ND 93.2 75-125 1.31
Post Spike (B000010-PS1)
Source: MOB1975-03
Prepared: 03/02/2020 Analyzed: 03/03/2020
Mercury
0.965
ug/L 1.00 0.00927 95.6 85-115
20
Spike Source %REC RPD
Metals TCLP by ICP Result RL Units Level Result %REC Limits RPD Limit Notes
Batch B000013 - 3015A 6010 -EPA 6010E
Blank (B000013-BLK1)
Prepared & Analyzed: 03/02/2020
Arsenic
<0.0250
0.0250
mg/L
Barium
<0.0125
0.0125
mg/L
Cadmium
<0.00250
0.00250
mg/L
Chromium
<0.00625
0.00625
mg/L
Lead
<0.0250
0.0250
mg/L
Selenium
<0.0438
0.0438
mg/L
Silver
<0.0125
0.0125
mg/L
LCS (B000013-BS1)
Prepared & Analyzed: 03/02/2020
Arsenic
0.242
0.0250
mg/L 0.250 97.0
80-120
Barium
0.627
0.0125
mg/L 0.625 100
80-120
Cadmium
0.0311
0.00250
mg/L 0.0313 99.6
80-120
Chromium
0.314
0.00625
mg/L 0.313 101
80-120
Lead
0.321
0.0250
mg/L 0.313 103
80-120
Selenium
0.236
0.0438
mg/L 0.250 94.5
80-120
Silver
0.247
0.0125
mg/L 0.250 98.9
80-120
Matrix Spike (B000013-MS1)
Source: MOB1971-02
Prepared & Analyzed: 03/02/2020
Arsenic
0.243
0.0250
mg/L 0.250 ND 97.3
75-125
Barium
0.666
0.0125
mg/L 0.625 0.0255 103
75-125
Cadmium
0.0313
0.00250
mg/L 0.0313 ND 100
75-125
Chromium
0.319
0.00625
mg/L 0.313 ND 102
75-125
Lead
0.323
0.0250
mg/L 0.313 ND 103
75-125
Selenium
0.239
0.0438
mg/L 0.250 ND 95.6
75-125
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com
Page 7 oE471

l,�).)MICROBAC'`
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Metals TCLP by ICP Result
Batch B000013 - 3015A 6010 - EPA 6010E
RL
Units
Spike
Level
Source
Result
%REC
%REC
Limits
RPD
RPD
Limit Notes
Matrix Spike (B000013-MS1)
Source: MOB1971-02
Prepared &Analyzed: 03/02/2020
Silver
0.252
0.0125
mg/L
0.250
ND
101
75-125
Matrix Spike Dup (B000013-MSD1)
Source: MOB1971-02
Prepared & Analyzed: 03/02/2020
Arsenic
0.248
0.0250
mg/L
0.250
ND
99.1
75-125
1.75
20
Barium
0.662
0.0125
mg/L
0.625
0.0255
102
75-125
0.617
20
Cadmium
0.0311
0.00250
mg/L
0.0313
ND
99.6
75-125
0.681
20
Chromium
0.318
0.00625
mg/L
0.313
ND
102
75-125
0.133
20
Lead
0.321
0.0250
mg/L
0.313
ND
103
75-125
0.590
20
Selenium
0.245
0.0438
mg/L
0.250
ND
97.9
75-125
2.40
20
Silver
0.249
0.0125
mg/L
0.250
ND
99.6
75-125
1.13
20
Post Spike (B000013-PS1)
Source: MOB1971-01
Prepared &Analyzed: 03/02/2020
Arsenic
0.193
mg/L
0.200
0.000963
95.9
75-125
Barium
0.512
mg/L
0.500
0.0143
99.5
75-125
Cadmium
0.0247
mg/L
0.0250
0.000036(
98.7
75-125
Chromium
0.249
mg/L
0.250
0.000450
99.4
75-125
Lead
0.252
mg/L
0.250
0.00155
100
75-125
Selenium
0.189
mg/L
0.200
-0.000378
94.5
75-125
Silver
0.196
mg/L
0.200
-0.000288
98.2
75-125
Spike Source %REC RPD
Volatile Organic Compounds Result RL Units Level Result %REC Limits RPD Limit Notes
TCLP by GCMS
Batch B000167 - 5030 8260 - EPA 8260E
Blank (B000167-BLK1)
Benzene
2-Butanone
Carbon tetrachloride
Chlorobenzene
Chloroform
1,2-Dichloroethane
1,1-Dichloroethene
Tetrachloroethene
Trichloroethene
Vinyl chloride
Surrogate: 4-Bromo tl uorobenzene
Surrogate: Dibromolluoromethane
Surrogate: 1, 2-Dichloroethane-d4
Surrogate: Toluene -dB
LCS (B000167-BSI)
Benzene
2-Butanone
Carbon tetrachloride
Chlorobenzene
Chloroform
Prepared & Analyzed: 03/04/2020
<5.00
5.00
ug/L
<10.0
10.0
ug/L
<5.00
5.00
ug/L
<5.00
5.00
ug/L
<5.00
5.00
ug/L
<5.00
5.00
ug/L
<5.00
5.00
ug/L
<5.00
5.00
ug/L
<5.00
5.00
ug/L
<10.0
10.0
ug/L
24.4
ug/L 25.0 97.6
86-115
23.7
ug/L 25.0 94.7
86-118
23.4
ug/L 25.0 93.6
80-120
24.5
ug/L 25.0 98.1
88-110
Prepared & Analyzed: 03/04/2020
20.6
5.00
ug/L 20.0 103
80-121
20.5
10.0
ug/L 20.0 103
10-170
18.5
5.00
ug/L 20.0 92.5
65-140
20.6
5.00
ug/L 20.0 103
80-120
18.8
5.00
ug/L 20.0 94.1
80-125
Microbac Laboratories, Inc.
2592 Hope Mills
Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com
Page 8 of 14

?iMICR0RA!�
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Volatile Organic Compounds Result
TCLP by GCMS
Batch B000167 - 5030 8260 - EPA 8260B
LCS (B000167-BSI)
1,2-Dichloroethane
1,1-Dichloroethene
Tetrachloroethene
Trichloroethene
Vinyl chloride
Surrogate: 4-Bromofluorobenzene
Surrogate: Dibromoiluoromethane
Surrogate: 1, 2-Dichloroethane-d4
Surrogate: Toluene-d8
LCS Dup (B000167-BSD1)
Benzene
2-Butanone
Carbon tetrachloride
Chlorobenzene
Chloroform
1,2-Dichloroethane
1,1-Dichloroethene
Tetrachloroethene
Trichloroethene
Vinyl chloride
Surrogate: 4-Bromofluorobenzene
Surrogate: Dibromofluoromethane
Surrogate: 1, 2-Dichloroethane-d4
Surrogate: Toluene-d8
18.4
20.1
19.0
19.1
16.8
20.6
20.9
18.2
20.8
18.7
18.2
19.7
19.2
19.1
16.7
Herbicides TCLP by GC/ECD Result
Batch B000069 - 8151 WATER - EPA 8151A
Blank (B000069-BLK_I))
2,4,5-TP (Silvex) [2C] <0.200
2,4-D [2C] <2.00
Spike Source %REC RPD
RL Units Level Result %REC Limits RPD Limit Notes
Prepared & Analy_zed: 03/04/2020 _
�92.0
---
5.00
ug/L
20.0
80-129
5.00
ug/L
20.0
100
80-132
5.00
ug/L
20.0
94.8
80-124
5.00
ug/L
20.0
95.6
80-122
10.0
ug/L
20.0
84.2
50-170
23.0
ug/L
25.0
92.1
86-115
23.8
ug/L
25.0
95.2
86-118
23.0
ug/L
25.0
91.8
80-120
24.2
ug/L
25.0
97.0
88-110
Prepared & Analyzed: 03/04/2020
5.00
ug/L
20.0
103
80-121
0.215
20
10.0
ug/L
20.0
104
10-170
1.58
20
5.00
ug/L
20.0
91.0
65-140
1.61
20
5.00
ug/L
20.0
104
80-120
1.11
20
5.00
ug/L
20.0
93.7
80-125
0.441
20
5.00
ug/L
20.0
91.2
80-129
0.825
20
5.00
ug/L
20.0
98.3
80-132
2.13
20
5.00
ug/L
20.0
96.0
80-124
1.23
20
5.00
ug/L
20.0
95.4
80-122
0.236
20
10.0
ug/L
20.0
83.6
50-170
0.711
20
23.9
ug/L
25.0
95.6
86-115
24.5
ug/L
25.0
98.2
86-118
23.9
ug/L
25.0
95.4
80-120
24.7
ug/L
25.0
99.0
88-110
Spike
Source
%REC
RPD
RL
Units
Level
Result %REC
Limits
RPD
Limit Notes
Prepared: 03/02/2020 Analyzed: 03/03/2020
0.200 ug/L
2.00 ug/L
Surrogate: 2,4-Dichloropenylaceticacid [2C] 4.90 ug/L 5.00 98.1 20-144
LCS (B000069-BS1) _ Prepared: 03/02/202OAnalyze__d: 03/03/2020
2,4,5-TP (Silvex) [2C] 0.427 0.200 ug/L 0.500 85.4 25-120
2,4-D [2C] 4.34 2.00 ug/L 5.00 86.8 20-110
Surrogate: 2,4-Dichloropenylacetic acid (2C) 5.03 ug/L 5.00 101 20-144
LCS Dup (B000069-BSD1) Prepared: 03/02/2020 Analyzed: 03/03/2020
2,4,5-TP (Silvex) [2C] 0.354 0.200 ug/L 0.500 70.7 25-120 18.9 30
2,4-D [2C] 3.74 2.00 ug/L 5.00 74.8 20-110 14.8 30
Surrogate 2,4-Dichloropenylacetrc acid [2C] 4.19 ug/L 5.00 83.9 20-144
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 9 of 14

"0IVIWRO 3AC'-
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Spike Source
Pesticides TCLP by GC/ECU Result RL Units Level Result
Batch B000027 - 351 OC 8081 -EPA 8081A
%REC
%REC
Limits
RPD
RPD Limit Notes
Blank (B000027-BLK1)
Prepared: 03/02/2020 Analyzed: 03/04/2020
alpha -Chlordane
<0.0500
0.0500
ug/L
Endrin
<0.0500
0.0500
ug/L
gamma Chlordane
<0.0500
0.0500
ug/L
gamma-BHC (Lindane)
<0.0500
0.0500
ug/L
Heptachlor
<0.0500
0.0500
ug/L
Heptachlor epoxide
<0.0500
0.0500
ug/L
Methoxychlor
<0.0500
0.0500
ug/L
Toxaphene
<1.00
1.00
ug/L
Surrogate:2,4,5,6-Tetrachloro-m-xylene
0.141
ug/L 0.200
70.4
20-130
Surrogate: Decachlorobiphenyl (BZ-209)
0.155
ug/L 0,200
77.4
25-140
LCS (B000027-BSI)
Prepared: 03/02/2020 Analyzed: 03/04/2020
alpha -Chlordane
0.536
0.0500
ug/L 0.500
107
40-120
Endrin
0.544
0.0500
ug/L 0.500
109
40-138
gamma Chlordane
0.543
0.0500
ug/L 0.500
109
40-136
gamma-BHC (Lindane)
0.559
0.0500
ug/L 0.500
112
30-134
Heptachlor
0.519
0.0500
ug/L 0.500
104
40-130
Heptachlor epoxide
0.473
0.0500
ug/L 0.500
94.7
40-120
Methoxychlor
0.558
0.0500
ug/L 0.500
112
40-150
Surrogate: 2,4,5,6-Tetrachloro-m-xylene
0.153
ug/L 0.200
76.6
20-130
Surrogate. Decachlorobiphenyl (BZ-209)
0.154
ug/L 0.200
76.9
25-140
LCS (B000027-BS2)
Prepared: 03/02/2020 Analyzed: 03/04/2020
Toxaphene
1.71
1.00
ug/L 2.00
85.3
41-126
Surrogate: 2,4,5,6-Tetrachloro-m-xylene
0.147
ug/L 0.200
73.7
20-130
Surrogate: Decachlorobiphenyl (BZ-209)
0.147
ug/L 0.200
73.7
25-140
LCS Dup (B000027-BSD1)
Prepared: 03/02/2020 Analyzed: 03/04/2020
alpha -Chlordane
0.566
0.0500
ug/L 0.500
113
40-120
5.44 30
Endrin
0.563
0.0500
ug/L 0.500
113
40-138
3.40 30
gamma Chlordane
0.558
0.0500
ug/L 0.500
112
40-136
2.80 30
gamma-BHC (Lindane)
0.589
0.0500
ug/L 0.500
118
30-134
5.18 30
Heptachlor
0.543
0.0500
ug/L 0.500
109
40-130
4.63 30
Heptachlor epoxide
0.492
0.0500
ug/L 0.500
98.3
40-120
3.81 30
Methoxychlor
0.578
0.0500
ug/L 0.500
116
40-150
3.49 30
Surrogate: 2,4,5,6-Tetrachloro-m-xylene
0.164
ug/L 0.200
82.1
20-130
Surrogate Decachlorobiphenyl (BZ-209)
0.158
ug/L 0.200
79.1
25-140
Matrix Spike (B000027-MS1)
Source: MOB1987-01
Prepared: 03/02/2020 Analyzed: 03/04/2020
alpha -Chlordane
5.30
0.500
ug/L 5.00 ND
106
40-120
Endrin
5.54
0.500
ug/L 5.00 ND
111
40-138
gamma Chlordane
5.38
0.500
ug/L 5.00 ND
108
40-136
gamma-BHC (Lindane)
5.65
0.500
ug/L 5.00 ND
113
30-134
Heptachlor
4.70
0.500
ug/L 5.00 ND
93.9
40-130
Heptachlor epoxide
4.74
0.500
ug/L 5.00 ND
94.7
40-120
Methoxychlor
5.44
0.500
ug/L 5.00 ND
109
40-150
Surrogate: 2,4,5,6-Tetrachloro-m-xylene
1.39
ug/L 2.00
69.3
20-130
Microbac Laboratories,
Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p ) www.microbac.com
Page 10 of 14

t4 �)M1CROBAC�-
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Spike Source %REC RPD
Pesticides TCLP by GC/ECU Result RL Units Level Result %REC Limits RPD Limit Notes
Batch B000027 - 3510C 8081 - EPA 8081A
Matrix Spike (B000027-MS1) Source: MOB1987-01 Prepared: 03/02/2020 Analyzed: 03/04/2020
Surrogate: Decachlorobiphenyl (BZ-209) 0.849 ug/L 2.00 42.5 25-140
Semivolatiie Organic
Result
Compounds TCLP by GCMS
Batch B000055 - 3510C 8270 - EPA 8270C
Blank (B000055-BLK1)
Pyridine
<25.0
1,4-Dichlorobenzene
<5.00
2-Methylphenol
<5.00
3-,4-Methylphenol
<5.00
Hexachloroethane
<5.00
Nitrobenzene
<5.00
Hexachlorobutadiene
<5.00
2,4,6-Trichlorophenol
<5.00
2,4,5-Trichlorophenol
<5.00
2,4-Dinitrotoluene
<5.00
Hexachlorobenzene
<5.00
Pentachlorophenol
<25.0
Surrogate, 2-Fluorophenol
Surrogate, Phenol-d5
Surrogate: Nitrobenzene-d5
Surrogate: 2-Fluorobiphe n yl
Surrogate: 2,4, 6-Tribromophenol
Surrogate: p-Terphenyl-d 14
Blank (B000055-BLK2)
Pyridine
<25.0
1,4-Dichlorobenzene
<5.00
2-Methylphenol
<5.00
3-,4-Methylphenol
<5.00
Hexachloroethane
<5.00
Nitrobenzene
<5.00
Hexachlorobutadiene
<5.00
2,4,6-Trichlorophenol
<5.00
2,4,5-Trichlorophenol
<5.00
2,4-Dinitrotoluene
<5.00
Hexachlorobenzene
<5.00
Pentachlorophenol
<25.0
Surrogate: 2-Fluorophenol
Surrogate: Phenol-d5
Surrogate: Nitrobenzene-d5
Surrogate: 2-FI uo ro b i p h e n yl
Surrogate: 2, 4, 6-Tribromophenol
Surrogate. p-Terphenyl-d14
Spike Source %REC RPD
RL Units Level Result %REC Limits RPD Limit Notes
Prepared: 03/02/2020 Analyzed: 03/03/2020
25.0
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
25.0
ug/L
58.4
ug/L
100
58.4
19-119
36.8
ug/L
100
36.8
10-120
41.1
ug/L
50.0
82.3
35-114
44.1
ug/L
50.0
88.2
43-116
124
ug/L
100
124
22-142
53.5
ug/L
50.0
107
10-130
Prepared: 03/02/2020 Analyzed: 03/04/2020
25.0
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
5.00
ug/L
25.0
ug/L
58.4
ug/L
100
58.4
19-119
35.8
ug/L
100
35.8
10-120
41.5
ug/L
50.0
82.9
35-114
43.9
ug/L
50.0
87.9
43-116
128
ug/L
100
128
22-142
52.2
ug/L
50.0
104
10-130
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 11 of 14

7-)}MICROBAC
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Spike Source %REC
Semivolatile Organic Result RL Units Level Result %REC Limits
Compounds TCLP by GCMS
Batch B000055 - 351 OC 8270 - EPA 8270C
RPD
RPD Limit Notes
LCS (B000055-BS1)
Prepared: 03/02/2020 Analyzed: 03/03/2020
Pyridine
<25.0
25.0
ug/L
50.0
48.8
10-100
1,4-Dichlorobenzene
38.9
5.00
ug/L
50.0
77.7
29-112
2-Methylphenol
43.3
5.00
ug/L
50.0
86.5
30-120
3-,4-Methylphenol
40.4
5.00
ug/L
50.0
80.9
20-130
Hexachloroethane
38.1
5.00
ug/L
50.0
76.2
21-115
Nitrobenzene
46.1
5.00
ug/L
50.0
92.2
40-120
Hexachlorobutadiene
47.8
5.00
ug/L
50.0
95.5
22-124
2,4,6-Trichlorophenol
55.3
5.00
ug/L
50.0
111
50-135
2,4,5-Trichlorophenol
55.6
5.00
ug/L
50.0
111
53-123
2,4-Dinitrotoluene
58.4
5.00
ug/L
50.0
117
57-128
Hexachlorobenzene
57.9
5.00
ug/L
50.0
116
53-125
Pentachlorophenol
60.5
25.0
ug/L
50.0
121
35-138
Surrogate:2-Fluorophenol
57.5
ug/L
100
57.5
19-119
Surrogate. Phenol-d5
38.4
ug/L
100
38.4
10-120
Surrogate: Nitrobenzene-d5
41.8
ug/L
50.0
83.6
35-114
Surrogate:2-Fluorobiphenyl
44.1
ug/L
50.0
88.1
43-116
Surrogate. 2,4,6-Tribromophenol
129
ug/L
100
129
22-142
Surrogate: p-Terphenyl-d14
53.7
ug/L
50.0
107
10-130
LCS Dup (B000055-BSD1)
Prepared: 03/02/2020Analyzed: 03/03/2020
Pyridine
<25.0
25.0
ug/L
50.0
48.6
10-100
0.528
30
1,4-Dichlorobenzene
38.8
5.00
ug/L
50.0
77.6
29-112
0.125
30
2-Methylphenol
43.2
5.00
ug/L
50.0
86.5
30-120
0.0516
30
3-,4-Methylphenol
39.7
5.00
ug/L
50.0
79.5
20-130
1.70
30
Hexachloroethane
38.9
5.00
ug/L
50.0
77.9
21-115
2.16
30
Nitrobenzene
47.7
5.00
ug/L
50.0
95.5
40-120
3.54
30
Hexachlorobutadiene
47.6
5.00
ug/L
50.0
95.3
22-124
0.267
30
2,4,6-Trichlorophenol
56.6
5.00
ug/L
50.0
113
50-135
2.42
30
2,4,5-Trichlorophenol
55.1
5.00
ug/L
50.0
110
53-123
0.943
30
2,4-Dinitrotoluene
59.1
5.00
ug/L
50.0
118
57-128
1.24
30
Hexachlorobenzene
60.1
5.00
ug/L
50.0
120
53-125
3.71
30
Pentachlorophenol
62.8
25.0
ug/L
50.0
126
35-138
3.62
30
Surrogate:2-Fluorophenol
58.3
ug/L
100
58.3
19-119
Surrogate: Phenol-d5
38.9
ug/L
100
38.9
10-120
Surrogate: Nitrobenzene-d5
42.1
ug/L
50.0
84.2
35-114
Surrogate:2-Fluorobiphenyl
44.8
ug/L
50.0
89.6
43-116
Surrogate: 2,4,6-Tribromophenol
132
ug/L
100
132
22-142
Surrogate: p-Terphenyl-d14
54.2
ug/L
50.0
108
10-130
Microbac Laboratories. Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 12 of 14

lt�) M I(-R0BAC`
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOB0372
Definitions
% (by wt.): Percent by Weight
1-114: The test was performed outside of the EPA recommended holding time of 15 minutes.
mg/kg: Milligrams per Kilogram
mg/L: Milligrams per Liter
mm/sec: Millimeter per Second
03: LCS recovery is below acceptance limits. The reported value is estimated.
04: ICV recovery is above acceptance limits. The reported value is estimated.
R1: Duplicate RPD is outside of acceptance limits.
RL: Reporting Limit
RPD: Relative Percent Difference
S.U.: Standard Units
S1: Surrogate recovery is above acceptance limits.
ug/L: Micrograms per Liter
ug/mL: Micrograms per Milliliter
Y: This analyte is not on the laboratory's current scope
of accreditation.
Cooler Receipt Log
Cooler ID: Default Cooler Temp:
8.3IC
Cooler Inspection Checklist
Ice Present or not required?
Yes Shipping containers sealed or not required?
Yes
Custody seals intact or not required?
Yes Chain of Custody (COC) Present?
Yes
COC includes customer information?
Yes Relinquished and received signature on COC?
Yes
Sample collector identified on COC?
Yes Sample type identified on COC?
Yes
Correct type of Containers Received
Yes Correct number of containers listed on COC?
Yes
Containers Intact?
Yes COC includes requested analyses?
Yes
Enough sample volume for indicated tests received?
Yes Sample labels match COC (Name, Date & Time?)
Yes
Samples arrived within hold time?
Yes Correct preservatives on COC or not required?
Yes
Chemical preservations checked or not required?
Yes Preservation checks meet method requirements?
Yes
VOA vials have zero headspace, or not recd.?
Yes
Project Requested Certification(s)
Microbac Laboratories Inc., - Marietta, OH
583
NC Dept. of the Environment and Natural Resources
Microbac Laboratories, Inc. - Fayetteville
11
North Carolina DENR NPDES
Report Comments
Reviewed and Approved By:
Samples were received in proper condition and the reported results conform to
applicable accreditation standard unless otherwise noted.
The data and information on this, and other accompanying documents, represents only the
sample(s) analyzed. This report is incomplete unless all pages indicated in the footnote are Brittany Smith
present and an authorized signature is included. The services were provided under and
subject to Microbac's standard terms and conditions which can be located and Administration
reviewed at<httos://www.microbac.com/standard•terms-conditions>. Reported: 03/06/2020 19:15
Microbac Laboratories. Inc
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com
Page 13 of 14

'K060372'
Microbae-Fayetteville
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C&MICROBAC�
2592 Hope Milts Rd.
CHAIN OF CUSTODY RECOR ION
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Fayetteville, NC 25305
Number
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Lab Report Address
Invoice Address
Turnaround Time TO BE COMPLETED BYMICA
Client Namc: 1i0401 n ]r
Client Name:
❑ Routine (5 to 7 business days) Temp. Upon Receipt rC)E. 3 Therm 10
Address:
Address:
[] RUSH' (notify lab) Holding Time
City, State, Zip: eke v4
City, Sate, Zip:
(needed by) Samples Received on to s No N/A ..
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Contact:
Report Type Custody Seals Intact? es o WA
Telephone No.: _
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' Matrix Types: Soil/Solid (S), Sludge, Oil, Wipe, Drinking Water (OW), eundvater(OW), Surlece Water (SW), Waste Water (WW), Other (specify)
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Paae 14 0[ 14

VMICROBAC r
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJ0203
Project Description
Residuals Sample - 60 day
For:
Mr. Chris Fowler
Von Drehle Corporation
126 First Street
Cordova, NC 28330
Administration
Brittany Smith
Monday, November 23, 2020
Please find enclosed the analytical results for the samples you submitted to Microbac Laboratories. Review and compilation of
your report was completed by Microbac Laboratories, Inc. - Fayetteville. If you have any questions, comments, or require further
assistance regarding this report, please contact your service representative listed above.
I certify that all test results meet all of the requirements of the accrediting authority listed within this report. Analytical results are
reported on a 'as received' basis unless specified otherwise. Analytical results for solids with units ending in (dry) are reported
on a dry weight basis. A statement of uncertainty for each analysis is available upon request. This laboratory report shall not be
reproduced, except in full, without the written approval of Microbac Laboratories. The reported results are related only to the
samples analyzed as received.
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com
Page 1 of 12

{f'D � I C R O B A C"
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO2O3
Von Drehle Corporation Project Name: Residuals Sample - 60 day
Mr. Chris Fowler Project / PO Number: N/A
126 First Street Received: 10/12/2020
Cordova, NC 28330 Reported: 11/23/2020
Sample Summary Report
Sample Name Laboratory ID Client Matrix Sample Type Sample Begin Sample Taken Lab Received
Residual from Paper Plant, KOJ0203-01 Solid Grab 10/12/20 12:23 10/12/20 15:57
Grab
Page 2 of 12

Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
Analytical Testing Parameters
Client Sample ID: Residual from Paper Plant, Grab
Sample Matrix: Solid Collected By: Wright
Lab Sample ID: KOJO203-01 Collection Date: 10/12/2020 12 23
Inorganics Total
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
Calculation
Sodium Adsorption Ratio, SAR
0.330
NA
1
11/09/20 1943
BNS
EPA 9045D
pH at 25 °C
8.2
1.0
S.U.
1
H
11/03/20 1151
11/02/20 1527
TBM
SM 4500-NH3 G-2011
Ammonia as N
<4.50
4.50
mg/kg
1
y
11/02/20 1701
Jo
SM 4500-P F-2011
Phosphorus, Total (as P)
3.5
0.59
mg/kg dry
1
10/22/20 0024
10/22/20 0044
JAW
General Parameters
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
Calculation
Plant Available Nitrogen
582
mg/kg
1
11/06/20 1324
11/06/20 1324
BNS
EPA 300.0, Rv. 2.1 (1993)
Nitrate as N
0.685
0.0591
mg/kg dry
1
11/03120 1246
11/03/20 1251
JDW
Nitrite as N
<1.18
1.18
mg/kg dry
1
11/03/20 1246
11/03/20 1251
JDW
SM 2540 G-2011
Solids
42.3
1,00
%
1
10/14/20 0954
TBM
Analyses Subcontracted to:
ECI
General Parameters
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
EPA 351.2, Rv. 2 (1993)
Total Kjeldahl Nitrogen
1940
0.5
mg/kg
1
10/12/20 1223
11/05/20 0000
RP
Analyses Subcontracted to: Microbac Laboratories Inc., - Marietta,
OH
General Parameters
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
ASTM D2216-10
Percent Solids
36.2
1.00
% (by wt.)
1
y
10/16/20 0719
10/19/20 0710
JMH
Metals Total by AA
Result
RL
Units
Dilution
Note
Prepared
Analyzed
Analyst
EPA 7471 A
Mercury
<0.658
0.658
mg/kg dry
1
10/19/20 0724
10/20120 1212
TMM
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 3 of 12

Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
Client Sample ID: Residual from Paper Plant. Grab
Sample Matrix: Solid Collected By: Wright
Lab Sample ID: KOJO203-01 Collection Date: 10/12/2020 12:23:
Metals Total by ICP
Result
EPA 601 OB
Aluminum
1360
Arsenic
<1.89
Cadmium
0.199
Calcium
219000
Copper
32.0
Lead
<1.89
Magnesium
2220
Molybdenum
<5.67
Nickel
<3.78
Phosphorus
142
Potassium
<94.5
Selenium
<1.89
Sodium
805
Zinc
74.3
RL
Units
Dilution Note
Prepared
Analyzed
Analyst
37.8
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
1.89
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
0.189
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
9450
mg/kg dry
100 D3
11/05/20 0540
11/09/20 1203
KHL
1.89
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
1.89
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
47.2
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
5.67
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
3.78
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
94.5
mg/kg dry
1 Y
11/05/20 0540
11/09/20 1032
KHL
94.5
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
1.89
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
47.2
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
1.89
mg/kg dry
1
11/05/20 0540
11/09/20 1032
KHL
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 4 of 12

MICR0B.AC'.
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
Batch Log Summary
Method Batch Laboratory ID Client I Source ID
EPA 351.2, Rv. 2 (1993) (none] BATCH-BLK1 (Solid)
BATCH-BS1 (Solid)
BATCH-BS1 (Solid)
BATCH-MS1 (Solid)
BATCH-MS1 (Solid)
KOJO203-01
KOJO203-01
BATCH-BLK1 (Solid)
Residual from Paper Plant Grab
Residual from Paper Plant, Grab
Method Batch Laboratory ID Client I Source ID
ASTM D2216-10 BOJO893 BOJO893-DUP1 KOJO203-01
BOJO893-BS1
BOJO893-BLK1
KOJO203-01 Residual from Paper Plant, Grab
Method Batch Laboratory ID Client I Source ID
EPA 7471A BOJ1022 BOJ1022-BLK1
130J1022-13S1
B0J1022-BSD1
BOJ1022-MRL1
BOJ 1022-PS 1
MOJ0921-01
BOJ1022-PS2
MOJ0922-01
BOJ1022-PS4
MOJ0995-02
BOJ1022-PS5
MOJ1117-02
KOJO203-01
Residual from Paper Plant Grab
BOJ1022-PS6
KOJO203-01
BOJ1022-PS7
MOJ1192-01
BOJ1022-PS8
MOJ1282-04
BOJ1022-PSA
MOJ1364-01
BOJ1022-PS9
MOJ1307-01
BOJ1022-PSB
MOJ1117-01
BOJ1022-SRL1
MOJ1307-01
Method Batch Laboratory ID Client I Source ID
EPA 601 OB BOK0235 BOK0235-MRL1
BOK0235-BLK1
BOK0235-BS1
KOJO203-01 Residual from Paper Plant, Grab
KOJO203-01 Residual from Paper Plant, Grab
BOK0235-PS1 KOJO203-01
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 5 of 12

t ;t (`I I C R O B A '
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
EPA 601 OB
BOK0235 BOK0235-SRL1
KOJO203-01
BOK0235-MS1
MOK0141-20
BOK0235-MSD1
MOK0141-20
KOJO203-01 RE 1
Residual from Paper Plant, Grab
Method
Batch Laboratory ID
Client / Source ID
SM 2540 G-2011
KJO1306 KOJO203-01
Residual from Paper Plant, Grab
KOJO203-01
Residual from Paper Plant, Grab
KJO1306-DUP1
KOJO203-01
KJO1306-BLK1
KJO1306-BLK1
KJO1306-DUP1
KOJO203-01
Method
Batch Laboratory ID
Client / Source ID
EPA300.0, Rv. 2.1 (1993)
KJO1410 KOJO203-01
Residual from Paper Plant, Grab
KOJO203-01
Residual from Paper Plant, Grab
Method
Batch Laboratory ID
Client / Source ID
SM 4500-P F-2011
KJ02103 KOJO203-01
Residual from Paper Plant, Grab
KOJO203-01
Residual from Paper Plant, Grab
Method
Batch Laboratory ID
Client / Source ID
EPA 9045D
KKO0309 KOJO203-01
Residual from Paper Plant, Grab
KOJO203-01
Residual from Paper Plant, Grab
Method Batch Laboratory ID Client / Source ID
SM 4500-NH3 G-2011 KKO0310 KOJO203-01 Residual from Paper Plant, Grab
KOJO203-01 Residual from Paper Plant, Grab
Method Batch Laboratory ID Client / Source ID
Calculation KKO0528 KOJO203-01 Residual from Paper Plant, Grab
KOJO203-01 Residual from Paper Plant, Grab
Method Batch Laboratory ID Client / Source ID
Calculation KKO0906 KOJO203-01 Residual from Paper Plant, Grab
KOJO203-01 Residual from Paper Plant, Grab
Batch Quality Control Summary: Microbac Laboratories, Inc. - Fayetteville
Spike Source %REC RPD
General Parameters Result RL Units Level Result %REC Limits RPD Limit Notes
Batch KJ01306 - Wet Chem Solid - SM 2540 G-2011
Blank (KJO1306-BLK1) Prepared &Analyzed: 10/14/2020
% Solids <1.00 1.00 %
Duplicate (KJO1306-DUP1) Source: KOJO203-01 Prepared &Analyzed: 10/14/2020
% Solids 41.9 1.00 % 42.3 1 10
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 6 0 12

Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
Spike
Source
%REC
RPD
General Parameters Result RL Units
Level
Result %REC
Limits
RPD Limit Notes
Batch Quality Control Summary: Microbac Laboratories Inc., - Marietta, OH
Spike
Source
%REC
RPD
General Parameters Result RL Units
Level
Result %REC
Limits
RPD Limit Notes
Batch BOJO893 - Wet-Solids-S -ASTM D2216-10
Blank (BOJO893-BLK1)
Percent Solids
LCS (BOJ0893-BSI)
Percent Solids
Duplicate (BOJO893-DUP1)
Percent Solids
Metals Total by AA
Batch BOJ1022 - 7471 - EPA 7471A
100
80.2
1.00
Source: KOJO203-01
36.2 1.00
Prepared: 10/16/2020 Analyzed: 10119/2020
(by
wt.)
Prepared: 10/16/2020 Analyzed: 10/19/2020
% (by 80.0 100 90-110
wt.)
Prepared: 10/1612020 Analyzed: 10/19/2020
% (by 36.2 0.145 20
wt.)
Spike Source %REC RPD
Result RL Units Level Result %REC Limits RPD Limit Notes
Blank (BOJ1022-BLK1)
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
<0.250
0.250
mg/kg
wet
LCS (BOJ1022-BS1)
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
0.315
0.250
mg/kg 0.267 118 80-120
wet
LCS Dup (BOJ1022-BSD1)
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
0.314
0.250
mg/kg 0.267 118 80-120 0.318
wet
Post Spike (BOJ1022-PSI)
Source: MOJ0921-01
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
2.98
ug/L 1.00 1.77 121 80-120
Post Spike (BOJ1022-PS2)
Source: MOJ0922-01
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
1.50
ug/L 1.00 0.318 119 80-120
Post Spike (BOJ I 022-PS4)
Source: MOJ0995-02
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
4.68
ug/L 1.00 3.33 136 80-120
Post Spike (BOJ1022-PS5)
Source: MOJ1117-02
Prepared. 10/19/2020 Analyzed: 10/20/2020
Mercury
1.52
ug/L 1.00 0.252 127 80-120
Post Spike (BOJ1022-PS6)
Source: KOJO203-01
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
1.05
ug/L 1.00-0.0221 105 80-120
Post Spike (BOJ1022-PS7)
Source: MOJ1192-01
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
0.752
ug/L 1.00 -0.133 75.2 80-120
Post Spike (BOJ 1 022-PS8)
Source: MOJ1282-04
Prepared: 10/19/2020 Analyzed: 10/2012020
Mercury
3.06
ug/L 1.00 1.66 140 80-120
Post Spike (BOJ1022-PS9)
Source: MOJ1307-01
Prepared: 10/19/2020 Analyzed: 10/21/2020
Microbac Laboratories,
Inc.
20
M5
M5
M5
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com I Page 7 of 12

��'iM1CROsAC
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
Spike Source %REC
RPD
Metals Total by AA
Result
RL
Units Level Result %REC Limits RPD
Limit Notes
Batch BOJ1022 - 7471 -EPA 7471A
Post Spike (BOJ1022-PS9)
Source: MOJ1307-01
Prepared: 10/19/2020 Analyzed: 10/21/2020
Mercury
6.93
ug/L 1.00 3.92 301 80-120
M5
Post Spike (130J1022-PSA)
Source: MOJ1364-01
Prepared: 10/19/2020 Analyzed: 10/20/2020
Mercury
1.19
ug/L 1.00 0.338 85.5 80-120
Post Spike (BOJ1022-PSB)
Source: MOJ1117-01
Prepared: 10/19/2020 Analyzed: 10/21/2020
Mercury
5.04
ug/L 1.00 4.10 93.9 80-120
Spike Source %REC
RPD
Metals Total by ICP
Result
RL
Units Level Result %REC Limits RPD
Limit Notes
Batch BOK0235 - 3051 A6010 -EPA 6010E
Blank (BOK0235-BLK1)
Prepared: 11/05/2020 Analyzed: 11/09/2020
Aluminum
<20.0
20.0
mg/kg
wet
Arsenic
<1.00
1.00
mg/kg
wet
Cadmium
<0.100
0.100
mg/kg
wet
Calcium
<50.0
50.0
mg/kg
wet
Copper
0.00
1.00
mg/kg
wet
Lead
0.00
1.00
mg/kg
wet
Magnesium
<25.0
25.0
mg/kg
wet
Molybdenum
<3.00
3.00
mg/kg
wet
Nickel
<2.00
2.00
mg/kg
wet
Phosphorus
<50.0
50.0
mg/kg
wet
Potassium
<50.0
50.0
mg/kg
wet
Selenium
0.00
1.00
mg/kg
wet
Sodium
<25.0
25.0
mg/kg
wet
Zinc
<1.00
1.00
mg/kg
wet
LCS (BOK0235-BS1)
Prepared: 11/05/2020 Analyzed: 11/09/2020
Aluminum
238
20.0
mg/kg 250 95.2 80-120
wet
Arsenic
9.05
1.00
mg/kg 10.0 905 80-120
wet
Calcium
255
50.0
mg/kg 250 102 80-120
wet
Copper
12.3
1.00
mg/kg 12.5 98.3 80-120
wet
Microbac Laboratories. Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 8 of 12

.'MICROBAC"
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
Spike
Source
%REC
RPD
Metals Total by ICP
Result
RL
Units
Level
Result
%REC
Limits RPD
Limit Notes
Batch BOK0235 - 3051A 6010 - EPA 6010E
LCS (BOK0235-BS1)
Prepared: 11/05/2020 Analyzed: 11/09/2020
Lead
12.4
1.00
mg/kg
12.5
98.9
80-120
wet
Magnesium
260
25.0
mg/kg
250
104
80-120
wet
Molybdenum
26.1
3.00
mg/kg
25.0
105
80-120
wet
Nickel
12.4
2.00
mg/kg
12.5
99.2
80-120
wet
Phosphorus
234
50.0
mg/kg
250
93.7
80-120
wet
Potassium
1270
50.0
mg/kg
1250
101
80-120
wet
Selenium
9.27
1.00
mg/kg
10.0
92.7
80-120
wet
Sodium
1270
25.0
mg/kg
1250
101
80-120
wet
Zinc
24.2
1.00
mg/kg
25.0
96.9
80-120
wet
Matrix Spike (BOK0235-MS1)
Source: MOK0141-20
Prepared: 11/05/2020 Analyzed: 11/09/2020
Aluminum
11600
18.6
mg/kg
233
11100
196
75-125
dry
Arsenic
11.3
0.932
mg/kg
9.32
3.58
83.3
75-125
dry
Calcium
1870
46.6
mg/kg
233
1100
330
75-125
dry
Copper
20.5
0.932
mg/kg
11.6
10.3
88.2
75-125
dry
Lead
21.8
0.932
mg/kg
11.6
13.3
72.4
75-125
dry
Magnesium
696
23.3
mg/kg
233
405
125
75-125
dry
Molybdenum
23.7
2.79
mg/kg
23.3
ND
102
75-125
dry
Nickel
14.8
1.86
mg/kg
11.6
1.63
114
75-125
dry
Phosphorus
462
46.6
mg/kg
233
249
91.6
75-125
dry
Potassium
1500
46.6
mg/kg
1160
330
101
75-125
dry
Selenium
10.7
0.932
mg/kg
9.32
5.30
58.4
75-125
dry
Sodium
1140
23.3
mg/kg
1160
ND
97.9
75-125
dry
Zinc
43.4
0.932
mg/kg
23.3
13.3
129
75-125
dry
Matrix Spike Dup (BOK0235-MSD1)
Source: MOK0141-20
Prepared: 11/05/2020 Analyzed: 11/09/2020
Aluminum
12200
19.8
mg/kg
247
11100
437
75-125 5.23
20
dry
Arsenic
11.3
0.989
mg/kg
9.89
3.58
78.2
75-125 0.233
20
dry
Microbac Laboratories,
Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com I Page 9 of 12

Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
Spike Source %REC RPD
Metals Total by ICP Result RL Units Level Result %REC Limits RPD Limit Notes
Batch BOK0235 - 3051A 6010 - EPA 6010E
Matrix Spike Dup (BOK0235-MSD1)
Source: MOK0141-20
Prepared: 11/05/2020 Analyzed: 11/09/2020
Cadmium
1.26
0.0989
mg/kg
1.24
102
75-125
200
20
dry
Calcium
1480
49.4
mg/kg
247
1100
153
75-125
23.3
20
dry
Copper
18.6
0.989
mg/kg
12.4
10.3
67.7
75-125
9.70
20
dry
Lead
21.3
0.989
mg/kg
12.4
13.3
64.2
75-125
2.34
20
dry
Magnesium
767
24.7
mg/kg
247
405
147
75-125
9.69
20
dry
Molybdenum
24.6
2.97
mg/kg
24.7
ND
99.4
75-125
3.46
20
dry
Nickel
14.5
1.98
mg/kg
12.4
1.63
104
75-125
2.13
20
dry
Phosphorus
435
49.4
mg/kg
247
249
75.5
75-125
5.93
20
dry
Potassium
1600
49.4
mg/kg
1240
330
102
75-125
6.00
20
dry
Selenium
10.6
0.989
mg/kg
9.89
5.30
53.3
75-125
1.62
20
dry
Sodium
1190
24.7
mg/kg
1240
ND
96.4
75-125
4.45
20
dry
Zinc
39.6
0.989
mg/kg
24.7
13.3
106
75-125
9.24
20
dry
Post Spike (BOK0235-PS1)
Source: KOJO203-01
Prepared: 11/05/2020Analyzed:
11/09/2020
Aluminum
17.9
mg/L
5.00
12.9
99.6
80-120
Arsenic
0.199
mg/L
0.200
0.00154
99.0
80-120
Cadmium
0.0262
mg/L
0.0250
0.00190
97.0
80-120
Copper
0.545
mg/L
0.250
0.305
96.1
80-120
Lead
0.245
mg/L
0.250
0.00846
94.5
80-120
Magnesium
26.0
mg/L
5.00
21.2
96.3
80-120
Molybdenum
0.560
mg/L
0.500
0.0454
103
80-120
Nickel
0.242
mg/L
0.250
0.0109
92.5
80-120
Phosphorus
6.32
mg/L
5.00
1.35
99.3
80-120
Potassium
26.4
mg/L
25.0
0.529
104
80-120
Selenium
0.198
mg/L
0.200
0.000117
99.1
80-120
Sodium
33.1
mg/L
25.0
7.67
102
80-120
Zinc
1.18
mg/L
0.500
0.707
93.7
80-120
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 10 of 12

LI1MICROBAC`
Microbac Laboratories, Inc. - Fayetteville
CERTIFICATE OF ANALYSIS
KOJO203
Definitions
%: Percent
% (by wt.): Percent by Weight
D3: Dilution was performed due to high
target analyte concentration.
H: Analyte was prepared and/or analyzed outside of the analytical method holding time
M5: Post digestion spike is outside of acceptance limits.
MDL: Minimum Detection Limit
mg/kg: Milligrams per Kilogram
NA: Not Applicable
RL: Reporting Limit
RPD: Relative Percent Difference
S.U.: Standard Units
Y: This analyte is not on the laboratory's current scope of accreditation.
Cooler Receipt Log
Cooler ID: Default Cooler
Temp- 7.3°C
Cooler Inspection Checklist
Ice Present or not required?
Yes Shipping containers sealed or not required?
Yes
Custody seals intact or not required?
Yes Chain of Custody (COC) Present?
Yes
COC includes customer information?
Yes Relinquished and received signature on COC?
Yes
Sample collector identified on COC?
Yes Sample type identified on COC?
Yes
Correct type of Containers Received
Yes Correct number of containers listed on COC?
Yes
Containers Intact?
Yes COC includes requested analyses?
Yes
Enough sample volume for indicated tests received?
Yes Sample labels match COC (Name, Date & Time?)
Yes
Samples arrived within hold time?
Yes Correct preservatives on COC or not required?
Yes
Chemical preservations checked or not required?
Yes Preservation checks meet method requirements?
Yes
VOA vials have zero headspace, or not recd.?
Yes
Project Requested Certification(s)
Microbac Laboratories Inc., - Marietta, OH
583
NC Dept. of the Environment and Natural Resources
Microbac Laboratories, Inc. - Fayetteville
11
North Carolina DENR NPDES
Report Comments
Reviewed and Approved By:
Samples were received in proper condition and the reported results conform to
applicable accreditation standard unless otherwise noted.
The data and information on this, and other accompanying documents, represents only the
sample(s) analyzed. This report is incomplete unless all pages indicated in the footnote are Brittany Smith
present and an authorized signature is included. The services were provided under and Administration
subject to Microbac's standard terms and conditions which can be located and
reviewed at <httos:/Avww.microbac.com/standard-terms-conditions>. Reported: 11I23I2020 08:20
Microbac Laboratories, Inc.
2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com
Page 11 of 12

-KOJO203`
Fayetteville Division 2592 Hope Mills Road - Fayetteville, NC 28306 [phone] / 864-8774 fE
CHAIN OF CUSTODY RECORD
PAGE 1 OF 1
CLIENTNAME a ADDRESS:
VonDrehle Corp.
126 First Street
Cordova, NC 28330
Por
PROJECT I LOCATION:
Cordova - 60-day Series
NOF
B
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TYPE OF
ANALYSIS
PRESERVATION CODE
E
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CODE: A = None
B = HNO3 (pH<2) + <4°C
C = H2SO4 (pH<2) + <4°C
D=NaOH+c4°C
E= zN Acetate + <4°C
F= HG
CONTACT PERSON.
Mr. Chris Fowler
PHONE:
910-410-9131
SAMPLER.
�1,fk�o (/r;stil
DATE I METHOD OF SHIPMENT:
Microbac
LAB ID R
SAMPLE
TYPE
DATE
TIME
COMP
GRAB
pH
D.C.
TEMP •C
CH ORINE
Residual from paper plant
1 O�r t Z°
11,13
X
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Re s (Signature)
ogle
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Time
Received by: (Signature)
Due
Time
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Dare
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Re -Ned by. (Signature)
Cate
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5
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Camm is or SDecal Hazards:
l5 `5�
REVIIEE\WED ^X
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Page 12 of 12

inc. BIOLOGICAL CONSULTING SERVICES
OF NORTH FLORIDA, /NC.
December 01, 2020
Robert Branch
Branch Residuals and Soils
1735 Heckle Blvd. Suite 103-291
Rockhill SC 29732
336-312-9007
[e-mail]
Client ID: VD-1, VD-2, VD-3, VD-4, VD-5, VD-6, VD-7
BCS ID: 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011368
Dear Robert Branch,
We have completed the analysis of the submitted samples as outlined below.
Project Name: Von Drehle Cordova NC
alysis _ Method
monella JEPA 1682; BCS SOP M-4 (ISO17025 and TNI Accredited)
Following, you will find our report on the results of the analysis conducted on the referenced samples.
Should you have any questions, please do not hesitate to contact me.
Sincerely,
Bonnie Mull, MPH
Laboratory Operations Manager
Page 1 of 8
Final Report BCS ID 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011368
BCS LABORATORIES, INC. — GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
llama=:�1RA'

Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD-1 Sample Date/Time: November 23, 2020 13:48
BCS Sample ID: 2011362 Sample Description: Biosolid
Date Received: November 24, 2020 10:14 Amount Submitted:100 mL bottle % Solids: 36.1
Amount Analyzed: 30.02 g Receipt Temperature: 2.7 deg C Preserved: Yes
Analysis Start: November 24, 2020 11AS Analysis Stop Date: December 01, 2020 9:15
Analyst: Robert Pimentel Qualifier: U
Primary Value: 150.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.7 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD-2 Sample Date/Time: November 23, 2020 13:50
BCS Sample ID: 2011363 Sample Description: Biosolid
Date Received: November 24, 2020 10:14 Amount Submitted:100 mL bottle % Solids: 40.0
Amount Analyzed: 29.96 g Receipt Temperature: 2.7 deg C Preserved: Yes
Analysis Start: November 24, 2020 11:45 Analysis Stop Date: December 01, 2020 9:15
Analyst: Robert Pimentel Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.7 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Page 2 of 8
Final Report BCS ID 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011368
BCS LABORATORIES, INC. - GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]
VWWV.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
PC-r-%F,
ilaC-WA A1`16

Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD-3
Sample Date/Time: November 23, 2020 13:52
BCS Sample ID: 2011364 Sample Description: Biosolid
Date Received: November 24, 2020 10:14 Amount Submitted:100 mL bottle % Solids: 41.0
Amount Analyzed: 30.00 g Receipt Temperature: 2.7 deg C Preserved: Yes
Analysis Start: November 24, 2020 11:45 Analysis Stop Date: December 01, 2020 9:15
Analyst: Robert Pimentel Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: :50.6 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Client:
Branch Residuals and Soils
Analysis:
Salmonella
Project Name:
Von Drehle Cordova NC
Client Sample ID:
VD-4
Sample Date/Time: November 23, 2020 13:54
BCS Sample ID: 2011365 Sample Description: Biosolid
Date Received: November 24, 2020 10:14 Amount Submitted:100 mL bottle % Solids: 46.5
Amount Analyzed: 29.96 g Receipt Temperature: 2.7 deg C Preserved: Yes
Analysis Start: November 24, 2020 11:45 Analysis Stop Date: December 01, 2020 9:15
Analyst: Robert Pimentel Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.6 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Page 3 of 8
Final Report BCS ID 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011368
BCS LABORATORIES, INC. - GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
►"ft'
:lac=eAAAB

Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD-5 Sample Date/Time: November 23, 2020 13:56
BCS Sample ID: 2011366 Sample Description: Biosolid
Date Received: November 24, 2020 10:14 Amount Submitted:100 mL bottle % Solids: 42.5
Amount Analyzed: 29.92 g
Analysis Start: November 24, 2020 11:45
Analyst: Robert Pimentel
Receipt Temperature: 2.7 deg C Preserved: Yes
Analysis Stop Date: December 01, 2020 9:15
Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.6 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD-6
Sample Date/Time: November 23, 2020 13:58
BCS Sample ID: 2011367 Sample Description: Biosolid
Date Received: November 24, 2020 10:14 Amount Submitted:100 mL bottle % Solids: 41.2
Amount Analyzed: 30.08 g Receipt Temperature: 2.7 deg C Preserved: Yes
Analysis Start: November 24, 2020 11:45 Analysis Stop Date: December 01, 2020 9:15
Analyst: Robert Pimentel Qualifier: U
Primary Value: 50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.6 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Page 4 of 8
Final Report BCS ID 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011368
BCS LABORATORIES, INC. - GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES

Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD-7 Sample Date/Time: November 23, 2020 14:00
BCS Sample ID: 2011368 Sample Description: Biosolid
Date Received: November 24, 2020 10:14 Amount Submitted:100 mL bottle % Solids: 41.0
Amount Analyzed: 30.00 g Receipt Temperature: 2.7 deg C Preserved: Yes
Analysis Start: November 24, 2020 11:45 Analysis Stop Date: December 01, 2020 9:15
Analyst: Robert Pimentel Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.6 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Page 5 of 8
Final Report BCS ID 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011368
BCS LABORATORIES, INC. - GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
Mom

Client: Branch Residuals and Soils
Project: Von Drehle Cordova NC
Method Detection Limit: 1 microorganism/ unit weight or volume analyzed
Practical Quantitation Limit: 1 microorganism/ unit weight or volume analyzed
Report Notes: Custody Seal Condition: Not Present
Sample(s) were received well preserved and in excellent condition. Sample(s) were analyzed following receipt
as per the described analytical methodology. End of report notes.
Page 6 of 8
Final Report BCS ID 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011368
BCS LABORATORIES, INC. - GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
Via'` . .

I certify that I have examined and I am familiar with the information submitted herein. The results pertain only
to sample(s) identified and their condition at time of receipt. Based on my inquiry of the individuals
responsible for the analysis, I believe the data to be true, accurate, and complete. Sampling and field data was
obtained from submitted documents. The analysis was authorized and commissioned by the client. The
resulting data are representative of the analysis conducted on the material/samples/articles provided by the
client (or client's representative) and it's/their condition at the time of analysis. The sample(s) were analyzed
in accordance with the appropriate method , however due to the inherent limitations of the methods,
microorganisms may avoid detection. BCS Laboratories offers no express or implied warranties concerning
the quality, safety, and/or purity of any sample, batch, source, or the process they are derived from. Quality
assurance controls were performed as outlined in the method and as per Good Laboratory Practices. The
analysis and results presented in this report meet the requirements of the standards of The NELAC Institute
(TNI), ISO 17025, and the FL DOH Environmental Laboratory Certification Program, as applicable unless
otherwise noted.
Signature of Laboratory Director/Authorized Rep.
Date: December 01, 2020
Page 7 of 8
Final Report BCS ID 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011369
BCS LABORATORIES, INC. — GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAx. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES

DATA QUALIFIER CODES
SYMBOL MEANING
B Results based on counts outside the acceptable range.
X Sample received without prior notification ordelayed delivery. Analysis performed outside of
associated method required QC data set (1 QC data set per 20 samples per 168 hours).
I Value is between the laboratory method detection limit &the practical quantitation limit.
J1 The sample matrix interfered with the ability to make any accurate determination.
J2 No Quality Control criteria exist forthe component.
J3 The data are questionable because of improper laboratory orfield protocols.
L Off scale high. Actual value is known to be greaterthan value given.
N Presumptive evidence forthe presence of material. There is an indication that the analyte is
present, but the confirmation requirement was not met.
O Sampled, but analysis not performed.
Q Sample held beyond the accepted holding time.
U Indicates that the compound was analyzed for but not detected. The specified component was
not detected. The reported value is the method detection limit.
V Analyte was detected in both sample and the method blank. Data may not be accurate.
Y Laboratory analysis was from an improperly preserved sample; the data may not be accurate
Z Too many colonies present (TNTC); the numeric value given represents the upper end of the
value that can be determined based on the volume.
7 Data are rejected and should not be used. QC data for analyte did not meet acceptance criteria.
Presence or absence of analyte could not be confirmed.
** Not reported due to interference.
A Sampling container supplied by client. Sterility can not be confirmed by BCS.
# BCS Lab specific qualifier. See laboratory analysis notes.
Page 8 of 8
Final Report BCS ID 2011362, 2011363, 2011364, 2011365, 2011366, 2011367, 2011368
BCS LABORATORIES, INC. — GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]
VWVW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
F'
ilac-MRA AP6

K
CHAIN OF CUSTODY RECORD
BCS Laboratories
www.microbioservices.com
4609 NW 6th street, Building A
inc
FL DOH Laboratory #E82924,
EPA# FLO1147
Gainesville, FL 32609
4a S %fit
Tel. [phone], Fax. [phone]
Client Name and Address:
K PI (J 7
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Compliance Monitoring? CYes❑
No
City/Slate/Zip:
202
Project ID:
Z L)tq —I1
Project Manager:
9'),
Facility/Site:
1--44-v,, lyL
Telephone Number:
336 'i2 �Ct'} Fax No.:
Report To:
-till�
Sampler Name: (Print)
Email:
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Sampler Signature:
L, {�
Invoice To:
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SECTION III
MANAGEMENT PLAN

von Drehle Corporation produces Fiber Clay from its Cordova, North Carolina facility as a bi-product
of paper towel production using recycled paper. These residual solids are produced by non -biological
processes that separate clay non -suitable fibers out during the production processes. Plastics are also
separated and are sent to the land fill and are not to be considered as part of this Class A permit
application. These residuals have no domestic contribution. Based on the pathogen testing and the
no -biological nature of the treatment process, vector attraction reduction testing is not required.
von Drehle wishes to distribute their Fiber Clay in the following ways:
• Use as a landfill daily cover,
• Admixture for composts, soil amendments, and potting soils, and
• As a replacement for commercial lime (or most limiting application factor) on nonspecific
agricultural receiver sites.
For direct application, von Drehle Corporation or it's assigned representative will identify local
landowners and/or other property as receiver sites. Application made to all sites will be based on the
ability of the crop and the land to properly assimilate the residual solids. Application thickness of the
application rate, percent solids of the residuals applied, the type, whether the field can or will be
incorporated, thickness of the vegetative cover, and the lime requirement of the soil will be
predominant application factors. The nitrogen needs of the crop will be secondary since it is expected
that additional nitrogen will need to be applied to correct the carbon -nitrogen ratio to all the proper
growth of the crop. von Drehle, plans to take all of these into account to be conservative and will
distribute these residuals based on the most restrictive of these application rates.
For uses of these residuals in other processes other than direct application, von Drehle makes no claim
for their consistency or properties. Use by other entities will be without their responsibility to
determine and accept as is, with no liability or other implication to von Drehle Corporation.

Overview of Process and Residual Solids Handling

Overview of Process and Residual Solids Handling
von Drehle Corporation Cordova facility is located at 126 First Street in Richmond County, North
Carolina. This facility produces, approximately 22,500 dry tons of Fiber Clay annually through
separation and fractionation processes from their feed stock recycled paper. The processes remove all
plastics which are sent to the landfill. The majority of the recycled paper is repulped for von Drehle's
paper making process. The clay and short fibers that are separated out in the various screening and
fractionation processes are run through a belt press and Fiber Clay is made. Fiber Clay is a product
of non -biological processes and has no domestic contribution.
Fiber Clay can be placed in sealed trucks have three potential types of destinations:
• To a landfill for use as daily cover,
• To an offsite blending operation for the inclusion in composts, soil amendments, and potting
soils or
• As a replacement for commercial lime (or most limiting application factor) on nonspecific
agricultural receiver sites.

Distribution Methods for Reuse

Distribution Methods for Reuse
The Fiber Clay may be distributed in the following manner:
• Use as a landfill daily cover,
• Admixture for composts, soil amendments, and potting soils, and
• As a replacement for commercial lime on nonspecific agricultural receiver sites.
For direct application to nonspecific receiver sites, von Drehle Corporation or its assigned
representative will identify local landowners and/or other property as receiver sites. Application made
to all sites will be based on the ability of the crop and the land to properly assimilate the residual
solids. Application thickness of the application rate, percent solids of the residuals applied, and the
type and thickness of the vegetative cover will be the determining factors. These materials have very
little nitrogen value so application will be based on:
• application thickness or
• lime needs of the soil.
whichever of these accounts for the most restrictive application rate.
Application thickness of the application rate, percent solids of the residuals applied, the type, whether
the field can or will be incorporated, thickness of the vegetative cover, and the lime requirement of
the soil will be predominant application factors. The nitrogen needs of the crop will be secondary
since it is expected that additional nitrogen (above what is required for crop growth) will need to be
applied to correct the carbon -nitrogen ratio to all the proper growth of the crop. von Drehle, plans to
take all of these into account to be conservative and will distribute these residuals based on the most
restrictive of these application rates.
For other distribution points regarding the use of this residual in other processes or as admixtures, von
Drehle makes no claim for their consistency or properties. Use by other entities will be without their
responsibility to determine and accept as is with no implication to von Drehle.

Transportation and Logistics

Transportation and Logistics
von Drehle Corporation Fiber Clay will be loaded into sealed sludge trailers. These trailers will be
routed to various points for distribution, land application to nonspecific receiver sites, or sent a landfill
as daily cover. Trucks will travel on major traffic routes to the application and or distribution sites.
Individuals, agencies, or companies wishing to receive either of the von Drehle Fiber Clay will be
issued a product information sheet, the most recent copy of the analytical information, and Product
Receipt Form. The product information sheet will specify the buffer requirements for von Drehle's
Fiber Clay as well as application restrictions. Each Product Receipt Form will document:
• Amount of Fiber Clay received,
• The name, address and telephone number of the person who prepared the Fiber Clay,
• The name, address and telephone number of the person distributing/land applying the
residuals,
• A description of the processes that generated the residuals,
• A summary of the results from the most recent residuals sampling event,
• A summary of the type and volume of residuals distributed/land applied per acre,
• A summary of the nutrients land applied per acre, and
• A list of recommendations to the recipient of the residual regarding field use, soil testing,
pH adjustment, and other relevant agronomic information.
Both the Product Label and the Product Receipt Form will be required to ensure receipt of this
information and for the removal volume. Copies of this information will be retained by the von Drehle
Cordova and will be available for review upon request
The distribution receiver, the land applier, and the site receiver will be instructed as to the proper use
of this material as listed below:
• Applications should be made in accordance with approved application standards.
• Application shall not be made to land that is flooded, frozen, or snow covered.
• Application and storage must be performed to prevent runoff from the application or
storage site to any surface water.

• Buffer or "no application" zones as described in the approved permit and Product
Information Sheet.
• Applications must not be applied so thick as to cover existing vegetation.
Additional nitrogen may need to be applied to offset nitrogen deficient symptoms due to
improper carbon to nitrogen ratio.

Monitoring and Recordkeeping

Monitoring and Recordkeeping
The von Drehle Corporation Cordova facility requests that the Fiber Clay (Fiber Clay) be monitored
monthly for residuals analysis based on the amount of these residuals expected to be distributed. A
set of seven (7) Salmonella analyses will be performed prior to the end of the preceding month. A
TCLP analysis will be performed annually. Fiber Clay samples will be collected and delivered to a
laboratory qualified to analyze residual solids and that is familiar with routine environmental sample
preparation and standards.
Records pertinent to the successful management of the land applications program will be maintained
for the benefit of the farm operator, DWR, land applicator, and permittee. These records will contain
at a minimum:
• Source of the residuals,
• Type of the residuals,
• Date of the residual application/ distribution receiver,
• Information regarding the location of the residual application / distribution receiver ( i.e. field
owner name, address, and telephone number, approximate field location, and field number)
• Method of application / intended distribution,
• Weather conditions (if applicable),
• Soil conditions (if applicable),
• Type of crop or crops to be grown on the field or type of distribution receiver and intended
use,
• Volume or weight of residuals applied to the field or provided to distribution receiver,
• Annual totals of dry tons per acre of residuals, annual pounds of plant available nitrogen, and
annual pounds of phosphorus applied to the field or annual total of dry tons given to
distribution receiver if distributed as a non -land application alternative.

Each year an annual summary of the activities of the program will be prepared and delivered to the
appropriate agencies and participants on or before the 1 st of March. The Fiber Clay annual summary
will include:
A) Summary of the Fiber Clay,
B) Volume/Weight of the distributed amount of Fiber Clay,
C) Name of the receiver of the distributed Fiber Clay,
D) Intended use(s) of the Fiber Clay,
E) Volume/Weight of other Amendments or Bulking Agents,
F) Annual totals of dry tons/acre of the Fiber Clay,
G) pounds of plant available nitrogen (PAN), phosphorus, and lime applied from the
Fiber Clay, if distributed to non-specific receiver sites and
H) pounds of nitrogen needed to offset organic carbon applied through Fiber Clay.
2. Monthly - nutrients and metals will be analyzed of. Aluminum, Ammonia, Arsenic,
Cadmium, Calcium, Copper, Lead, Magnesium, Mercury, Molybdenum, Nickel,
Nitrate -Nitrite, Zinc, % Total Solids, CCE, pH, Phosphorus, Potassium, TKN, Selenium,
and Sodium will be collected and analyzed by a qualified laboratory. From this
information, the Plant Available Nitrogen (PAN) will be calculated. If land application
occurs at a frequency of less than monthly, nutrient and metal analyses will be required
for each distribution event.
3. Once a permit cycle a Toxicity Characteristics Leaching Procedure (TCLP) analysis with
ignitability, reactivity, and corrosivity of the von Drehle Fiber Clay will be collected and
analyzed by a qualified laboratory.

Leachate Collection

Leachate Collection
No provision is made for leachate collection since the residuals are not designed to undergo any
mixing with other productions on -site. The storage pad at the facility is sloped to the back to the
drainage feature. Below the drainage feature is a screen to capture any solids that are washed to the
drain.
Once these residuals have been transported to the potential application sites or for other uses, the fiber
clay can be stockpiled in a covered facility or covered on the ground similar to other Class A products.
Once covered this material will remain covered until the time of application.

SECTION IV
VON DRHLE CORDOVA FIBER CLAY LABEL
AND PRODUCT INFORMATION SHEET

The von Drehle Corporation Cordova
Fiber Clay Label
Produced By Preparer
von Drehle Corporation Chris Fowler [phone]
Wastewater Treatment Plant 126 First Street
Cordova, North Carolina 28330 Cordova, North Carolina 28330
For information on this product contact von Drehle Corporation
Cordova, NC facility at [phone]
Fiber Clay from the von Drehle Corporation Cordova NC are the clay and short fibers excluded from the repulping
process of recycled paper production. The generated residuals have no domestic source percentage and are an exceptional
quality residual solid that is permitted for bulk distribution.
Approved used for von Drehle Fiber Clay:
• Amendment for creation of soil mixture to be further distributed to the public,
• Amendment for compost to be further distributed to the public,
• Use as a daily landfill cover,
• Application to potential receiver sites for use as a soil amendment or replacement for agricultural lime.
Provisions for application are listed below.
Provisions for Application
Application of von Drehle Fiber Clay are prohibited except in accordance with the provisions specified in the Application
Information Sheet. Application must conform to standards identified in Permit No. WQ0039924 and include but are not
limited to:
Maximum slope for the land application of these residuals is 10 % for surface applications and 18% for subsurface
applications
Distance
Buffer Items (feet)
Public or private water supply source, waters classified as SA or SB, and any Class I or Class 11 impounded
reservoir used as a source of drinking water for both surface and subsurface methods 100
Surface waters (intermittent streams, perennial streams, perennial surface water bodies and wetlands) 100
Surface water diversions (ephemeral streams, ditches, groundwater lowering ditches, or waterways) 0
Application can not occur to:
• adversely affect a threatened or endangered species or it's critical habitat,
• within the 100-year flood plain unless solids are incorporated within a 24-hour period,
• cause prolonged nuisance conditions,
• create conditions where runoff will occur,
• within the 100-year flood plain unless solids are incorporated within a 24-hour period, or
• during a measurable rainfall event or 24-hours following a 0.5 inch cumulative rainfall event (over 24-hours).

Application Information Sheet von Drehle Fiber Clay
1. von Drehle Fiber Clay shall not be applied to flooded, frozen, or snow-covered areas.
2. Application and storage of von Drehle Fiber Clay must be conducted in such a way as to prevent runoff or
erosion from the application or storage site to any surface water.
3. Applications of von Drehle Fiber Clay must not be applied so thick as to cover existing vegetation. Application
that is made to sites with less than 50 percent ground cover should be incorporated unless incorporation will result
in violation of other federal program.
4. Applications of von Drehle Fiber Clay shall be applied uniformly at a rate equal to amount that can be
adequately assimilated into the soil through incorporation, will not smother any current living crop on the surface
of the soil if material will not be incorporated, or the agronomic rate of the crop as specified by the permit and
the most recent residual analysis, or the lime requirement of the soil and most recent residuals analysis; whichever
is most limiting.
5. An acceptable soil pH (greater than 6.0) see appropriate state extension service for crop specific optimal soil pH
on individual receiver sites. The soil pH should be verified annually with a soil sample with recommendations.
These recommendations should be followed as they relate to optimal crop growth, monitoring and adjustment of
the exchangeable sodium percentage, potential for calcium and magnesium deficiency, as well as other relevant
agronomic information. Additional fertilizer, lime, or other nutrients may need to be added as directed by the soil
sample results.
6. Applications and loading rates of von Drehle Fiber Clay shall be applied at rates that comply with realistic yield
expectations based on the soil series and crops found at: http://nutrients.soil.ncsu.edu/yields/
von Drehle Corporation Cordova Fiber Clay
Approximately Contain:
42.30
Percent Solids
1.55
Plant Available Nitrogen
surface land applied) pounds per dry ton
1.56
Plant Available Nitrogen (incorporated
or injected pounds per dry ton
0.02
Phosphate 205pounds
per dry ton
0..4
Potash K2Opounds per
dry ton
802
Liming agent pounds per
dry ton
8.2
pH of Fiber Clay
See von Drehle Corporation Cordova WWTP for a copy of the most recent residuals analysis
and loading rates.

SECTION V
WON DREHLE FIBER CLAY RECEIPT FORM

VON DREHLE CORPORATION CORDOVA
FIBER CLAY RECEIPT FORM
I , (printed name) have received wet
tons of von Drehle Corporation Cordova Fiber Clay, a von Drehle Fiber Clay product label,
and a copy of the most recent analysis of the product. I have read these documents and agree
to adhere to the directions specified on the Application Information Sheet and the Product
Label. My intended use of this product is
Contact Information:
Name
Address
City, State, Zipcode
Phone Number
Email Address
Signature of Receiver Date of Receipt

SECTION VI
SPILL CONTROL PLAN

SPILL CONTROL PLAN
VON DREHLE CORPORATION CORDOVA
FIBER CLAY
CORDOVA, NORTH CAROLINA
In the case of a spill, the following actions shall be taken immediately:
Halt the source of the spill: Damaged truck or trailer tank unit.
2. Contain spill: Use straw bales to form a barrier. Straw hay bales can be obtained from
several sources for this purpose. Soil near the site can also be used to form a barrier for
containment.
3. Clean up: Use residual solids application equipment to recover as much of the material as
possible. After the application equipment has recovered as much material as possible, it
will be land applied as per operation plan.
4. Final Clean up: Any unrecoverable material will be scraped and swept from the road
surface and incorporated into an adjacent tillable area.
5. Notification: As soon as possible after a spill occurs notify:
A. von Drehle Corporation - [phone]
B. Department of Environment and Natural Resources
Fayetteville Regional Office at [phone] or appropriate regional office
C. The appropriate County Sheriffs Department
D. Fire Department if assistance is required for washdown
6. Management of clean-up efforts: The ORC or applicator shall take immediate charge of
the clean-up activities. Additional labor will be requested from the treatment plant and
other departments as needed.
7. Reporting: Within 5 days of notifications, a written report will be prepared detailing the
cause of the spill, all actions taken in response to the spill, and proposed actions to be taken
to ensure spill does not recur..

APPLICATION RATES

APPLICATION RATES
Prior to a distribution event, a private land owner will contact von Drehle Corporation Cordova to
initiate an application. This land owner will indicate the type of crop to be grown and the size of the
field to have the residuals distributed. A recent soil sample will be needed to determine lime
requirements.
A recent sample of Fiber Clay generated from von Drehle Corporation Cordova will be used to
calculate the application rates for the crop based on the soil liming needs and the crop and soil
assimilation characteristics. Prior to the distribution event, the potential receiver sites will be
reviewed to insure the crop has been identified correctly and the field size is correct. Soils data will
be checked at that time. Application rates will be determined based on the solids content of the
residuals, the height of the crop on the receiver site, smothering potential of the crop, the lime
requirement of the soil, lime requirements of the soils analysis, and nitrogen needs of the crop to be
grown.
Application rates will be limited based on either: application thickness, lime needs of the soil, or
nitrogen needs of the crop; whichever of the three accounts for the most restrictive application rate.
Based on my knowledge of potential receiver sites, application thickness should be no more than 10
wet tons per acre if it is to be spread on the surface of the soil with an actively growing crop, depending
on the percent solids of the residuals. The incorporated amount will be reduced if the incorporation
equipment fail to properly turn the residual under depending on slope, cover, soil assimilation.
Application should not occur at a rate that the residuals may experience runoff or erosion from the
receiver site. Re -application of sites will be based on these same factors. If there are questions
concerning an individual application rate for a receiver site, consult a licensed soil scientist.
Application of Fiber Clay has been shown to create an imbalance in the soil carbon to nitrogen ratio.
This is particularly important as it relates to specific time periods in a crop's growth cycle. It may
be necessary to apply additional nitrogen to achieve the crop results. The application rates listed

below outline the lime -added values from the following applications. At this point application rates
should be limited to lime needs of the soil.
Wet Tons/
Acre
Dry Tons/
Acre
PAN
#/Acre
Lime
Tons/Acre
1
0.42
0.66
0.17
2
0.85
1.31
0.34
3
1.27
1.97
0.51
4
1.69
2.63
0.68
5
2.12
3.29
0.85
6
2.54
3.94
1.02
7
2.96
4.60
1.19
8
3.38
5.26
1.36
9
3.81
5.92
1.53
10
4.23
6.57
1.70
11
4.65
7.23
1.87
12
5.08
7.89
2.04
13
5.50
8.55
2.21
14
5.92
9.20
2.37
15
6.35
9.86
2.54
16
6.77
10.52
2.71
17
7.19
11.18
2.88
18
7.61
11.83
3.05
19
8.04
12.49
3.22
20
8.46
13.15
3.39