WQ0010689_Regional Office Physical File Scan Up To 10/24/2022

chael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
January 26, 2006
MR. TONY LEOPARD, REGIONAL PLANT MANAGER
TRIGEN-BIOPOWER, INC.
302 DUKE STREET
FOREST CITY, NORTH CAROLINA 28043
Subject: Permit No. W00010689
Trigen-BioPower, Inc.
North Cove Steam Generation Plant
Ash Distribution Program
Distribution of Residual Solids (503 Exempt)
McDowell County
Dear Mr. Leopard:
On January 25, 2005, the Division of Water Quality (Division) received a correspondence from
Mr. Jim Henslee, Vice President of Trigen-BioPower, Inc. in support of the above -referenced permit.
This letter, which specifically designates, you as the permit signing official/responsible party, was
submitted to meet the requirement of the 30-calendar day compliance schedule item required by
Condition I. 1. of Permit No. W00010689, issued on December 30, 2005.
The compliance schedule in Condition I. 1. of Permit No. W00010689, issued on December 30,
2005, has now been fully met. Please be aware, however, that nothing in this correspondence should be
construed as removing you from the responsibility for complying with your permit in full.
If you need additional information concerning this correspondence, please do not hesitate to
contact me by telephone at [phone] or via e-mail at [e-mail].
Sincerely,
J�
' Shannon Mohr Thornburg
Environmental Engineer II
Land Application Unit
cc: Ms. Lauren Bilihei
APS Central Files - Permit File WQ0010689
RECEIVED
JAN 3 0 2006
AsheAle Regional Office J
NorthCarolina
JVati rally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: www.ncwaterquality.org 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone] Fax [phone]
An Equal opportunitylAffirmative Action Employer - 50% Recycled110% Post Consumer Paper

TRIGEN-BIOPOWER, INC.
302 Duke Street, Forest City, NC 28043
© Phone: [phone] Fax: (828)'286-1229
TRIGEN
January 20, 2006
VIA FEDERAL EXPRESS # 7907 80971799
NCDENR-DWQ
Aquifer Protection Section
Land Application Unit
c/o LAU Residuals Program Coordinator
1636 Mail Service Center
Raleigh, NC 27699-1636
RE: Delegation of Responsible Official
Trigen-BioPower, Inc.
Marion, NC (McDowell County)
JA N 2 wv i
As an officer of Trigen-BioPower, Inc., I am hereby confirming that Tony Leopard, Plant
Manager of the Marion (North Cove) facility, is the responsible party for permitting and
compliance under the reissued Ash Distribution System Permit (WQ0010689). Mr. Leopard is
responsible for all aspects of the facility including operations, maintenance, compliance, and
business administration functions.
Mr. Leopard's present contact information is as follows:
Tony Leopard
Trigen-BioPower, Inc.
302 Duke Street
Forest City, NC 28043
828-827-5886 (phone)
828-286-1229 (fax)
tri,[e-mail]
Please contact Lauren Billheimer at [phone] or Tony Leopard at [phone] if you
have any questions or comments.
Sincerelv,
Ji R. Henslee
Vice President, Trigen-BioPower, Inc.
cc: Tony Leopard
Ricky Styles
Lauren Billheimer (via e-mail)

tion of Residual Solids - Marion, NC
PPPI
Subject: WQ0010689 Distribution ofResidual Solids - Marion, NC
From: "Pannell, Tom" <[e-mail]>
Date: Fri, 9 Feb 2007 16:09:20 -0600
To: <[e-mail]>
CC: "Leopard, Tony" <[e-mail]>, "Carlsson, Carl"
<Carl. Carlsson@suezenergyna. com>, "Henslee, Jim" <[e-mail]>, "Sumner,
Elliot" <[e-mail]>, "Styles, Ricky" <[e-mail]>
Beverly,
Per your request, please find attached a copy of the correspondence concerning the selection of the type
of onsite ash storage selected for the Marion, NC site. In addition, attached to the correspondence is a copy of the
Standard Operating Procedure (SOP) for the ash handling at the named facility.
If you have any questions, please contact me.
Regards
T. A. Pannell
Suez Energy Biopower, Inc.
423-332-5869
423-595-6051
06 03 14 Marion ash stockpile alternative (�
i
06 03 14 Marion ash
Content -Description: stockpile alternative
(5).pdf
Content -Type: application/octet-stream
Content -Encoding: base64
1 of 1 2/12/2007 7:48 AM

TRIGEN-BIOPOWER, INC.
302 Duke Street, Forest City, NC 28043
Phone: [phone] Fax: [phone]
TRIGEN
March 14, 2006
VIA FEDERAL EXPRESS # 7914 0474 4167
Ms. Shannon Thornburg
NCDENR-DWQ
Aquifer Protection Section
Land Application Unit
c/o LAU Residuals Program Coordinator
1636 Mail Service Center
Raleigh, NC 27699-1636
RE: Ash Stockpile Alternative
Trigen-BioPower, Inc.
Marion, NC (McDowell County)
Permit No. WQ0010689
Dear Ms. Thornburg:
Trigen-BioPower, Inc. (TBP) is hereby providing notification to the Division of Water Quality of
the ash stockpile alternative selected per Condition No. I.2. of the above -referenced permit. TBP
has conducted a feasibility study of several options and has elected to amend the standard
operating procedures (SOPS) such that the ash will remain in the basin until it is loaded directly
onto trucks for distribution under the permit. A copy of the SOPS is attached. In this way, the
facility will no longer maintain an ash stockpile on the ground surface. This storage method was
discontinued as of January 2006.
Please contact Lauren Billheimer at [phone] or me "at [phone] if you have any
questions or require, additional information.
Sincerely,
Tony Leopard
Plant Manager
Attachment
cc: Ricky Styles
Lauren Billheimer (via e-mail)
Tom Pannell (via e-mail)

Ash Distribution and Sampling Procedure
Trigen-BioPower, Inc. — Marion, NC
Purpose
This procedure documents the procedures for preparation and distribution of ash, as well as the
collection of representative samples for environmental permit compliance.
Applicable Facilities
Marion, NC
Ash Preparation and Handling Procedures
• Flyash is obtained from two locations f�
1. The sandbox, which contains dry ash from the dust collector
2. The scrubber ponds, through which the scrubber water is recycled and the ash is
settled
• The scrubber basin is divided into two sides (north and south). The water is generally
recycled through one side while ash from the other side is being prepared for distribution.
• Ash preparation includes air drying the pond to the extent possible, adding dry flyash from
the sandbox, and adding dry wood sawdust as necessary to further reduce the moisture
content. The amount of wood added is tracked in the monthly DSR. After the materials are,
added, the product is mixed inside the basin using a front end loader.
• Samples are collected from the ash after it is prepared and prior to distribution for land
application.
Ash Distribution Procedures
Ash can be distributed for the uses approved in the ash distribution permit, Condition II.3.b,
according to the procedures below.
All ash remains in the basin until the samples have been collected and analyzed. The ash is
loaded directly from the basin into trucks used for transport to the distribution site(s).
Each ash recipient must receive and sign a copy of the Ash Information Sheet prior to
receiving the ash. If a recipient receives more than one shipment/distribution in a calendar
year for the same use, only one form need be completed. The Ash Information Sheet contains
a summary of analysis results as well as procedures and limitations for applying the ash.
The total tons of ash distributed to each recipient on each day, and the use of the, ash, must be
recorded for reporting to NCDENR.
Ash Sampling Procedures
As required by the permit, representative samples must be collected after the ash is prepared and
prior to distribution. The table below documents the parameters and analysis frequency.
Currently, 6 samples per year are required for pH and total metals analyses. The schedule has
been incorporated into the EHS calendar.
3/06

Frequency*
Parameters
Limits
4 times/yr if between 319-
pH & Total Metals (As, Ba, Cd,
See permit condition
1650 dry tons; or
Ca,Cr, Cu, Fe, Pb, Mg, Mn, Hg, Mo,
II.5. Not all parameters
6 times/yr if >1650 dry tons
Ni, P, K, Se, A , Na, Zn)
have limits
Annually
Ignitability, Reactivity, & TCLP
See permit condition
Metals (As, Ba, Cd, Cr, Pb, Hg, Se,
III.3
A)
Once per permit cycle
Full TCLP
See permit condition
III.3
*Sampling frequency for metals & pH is based on the amount of each type distributed (pond ash,
mixed ash, etc.)
Sample Collection Procedures
• Collect samples from the prepared material so that results are obtained prior to distribution.
Because of the current schedule of preparing 3 pond sides per year, two composite samples
will be collected from each side after the ash is prepared. § Could hcwt. •� c�r�ol�S
• Using a clean shovel or a gloved hand, collect the same amount of ash from at least 5
different locations and depths on the pile.
• Place these sub -samples into the same plastic bucket, baggie, or glass jar (approximately 1
gallon total).
• After all the sub -samples are collected, mix the sample thoroughly by rolling or stirring.
Sample Preparation and Shipping
• Conduct pH analysis according to EPA Method 9045D
• Place portions of the mixed sample into the appropriate number of jars for shipment to the
required laboratories (approximately 1 quart to each lab). Prepare one additional jar/baggie to
keep on site until all the results are received and processed.
• Seal all sample containers and label the samples as "composite samples" and provide the
dates the original sub -samples were collected. Note this also on the forms that are sent to the
laboratories.
• Shipping addresses are provided on the ash sampling sheets.
• The original reports will be forwarded to the Environmental Engineer for review and
processing, with a copy to the facility.
Referenced Documents/Forms
• Water Quality Permit No. WQ0010689
• Ash Information Sheet
• Facility Daily Status Report
• EPA Method 9045D
2 3/06

10/23/2014
Bev Price
DENR - Division of Water Resources
Water Quality Regional Operations Section
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
RE: Baxter Healthcare Ash Distribution Program O&M Plan
Permit Number WQ0010689
Enclosed is the updated O&M Plan for the Ash Distribution Program as required by Permit Number
WQ0010689. The enclosed plan will replace the O&M plan submitted with the permit renewal
application.
Please contact me with any questions.
Sincerely,
Amanda Richcreek
Senior Environmental Engineer
cc: Ricky Styles
OCT 2 4 2014
Water ouamy Regional operations
Asheville Renian3l office
Baxter Healthcare Corporation
PO Box 1390, Marion, NC 28752
T 828-756-6809

Baxter Healthcare
Permit Number: WQ0010689
Expires November 30, 2019
Ash Distribution Program O&M Plan
1. Operational Function
Residual ash is created by the wood fuel combustion within an industrial boiler. Dry ash comes
from the grate raking process and is transported, by loader, to the ash ponds. The dry ash is
stored on the apron of the ponds. The wet ash comes from the venturi scrubber. The ash is
piped into the ponds from the scrubber. Baxter Healthcare wood boiler alternates between two
basins for ash accumulation. When the designated active basin is within 24" of the top of the
basin wall, the basin is considered full. At this time the alternative basin is put into service. The
basin that is considered full is then dewatered and the ash is processed. Samples are taken from
each batch of ash created and analyzed prior to any ash leaving the facility. Once the ash is
approved for application it is picked up by truck and transported to the application field. The
ash may be immediately applied to the land or stockpiled in the field.
2. Maintenance Schedule
The ash ponds onsite at the Baxter Healthcare wood boiler are monitored daily. The ash levels
within the ponds dictate when the designated active pond goes out of service. All pumps and
ash handling equipment is maintained within the Baxter Healthcare preventative maintenance
program (MAXIMO).
3. Safety Measures
All ash will be stored in the basins or on the apron in such a way that prevents runoff prior to
distribution and use to prevent contamination of surface waters. During dry conditions,
operators will spray water on stock piles to prevent wind erosion. Handling and loading is
conducted in the basin/apron area. Operators avoid creating nuisance dust to the extent
practicable. Ash Distribution Utilization Agreement will be distributed to each receiver of ash
material outlining transport, storage, and application requirements. This agreement is valid for
the permit cycle (November 30, 2019). Baxter Healthcare Woodboiler operates 24-hours a day,
7-days a week, with personnel onsite at all times. The ash storage apron is illuminated at night
to prevent any security breaches.
4. Spill Response Plan
All ash is contained within the ash ponds and the ash pond apron. Any spill onsite is
immediately contained and cleaned up. Any spill during transportation of the ash will be the
responsibility of the transporter. All transporters must keep spill control provisions on their
vehicles. Baxter Healthcare will be notified of any offsite spill immediately.
5. Inspection Plan
The Wood Boiler Superintendent, Ricky Styles, is overall responsible for all inspections; however,
he' may delegate inspections to operators. A visual inspection of the two basins, ash storage
1 of 2

Baxter Healthcare
Permit Number: WQ0010689
Expires November 30, 2019
piles, and associated piping is performed at least once per day as part of the standard work for
the wood boiler. Mechanical malfunctions, operator errors, and discharges which may cause or
lead to the release of waste to the environment are documented in the operator's daily log kept
in the control room. A documented monthly inspection is conducted; this inspection includes
the date and time, name of inspector, observations, and any corrective actions taken.
Inspection forms are kept in the control room of the wood boiler.
6. Sampling and Monitoring Plan
The Wood Boiler Superintendent, Ricky Styles, is.responsible for the sampling and monitoring
program. Composite samples are taken of material offered for shipment composed of
representative samples at different locations in the storage pile. The ash is analyzed to
demonstrate it is non -hazardous under the Resource Conservation and Recovery Act (RCRA).
The analyses [Corrosivity, ignitability, reactivity, and toxicity characteristic leaching procedure
TCLP)] shall be performed once during the permit cycle. Additional analysis shall be performed
based on the monitoring frequency in Attachment A of the permit for the following parameters:
Arsenic
Magnesium
Selenium
Barium
Manganese
Silver
Cadmium
Mercury
Sodium
Calcium
Molybdenum
Zinc
Chromium
Nickel
Copper
pH
Iron
Phosphorus
Lead
Potassium
Records of all ash distribution activities and sample results are maintained in the Wood Boiler
Superintendent's office.
7. Contact Information:
Wood Boiler
Rick Styles
828-756-6650
Superintendent
Environmental Engineer
Amanda Richcreek
828-756-6809
Plant Manager
Alan Weiler
828-756-6530
NCDENR for
Noncompliance
Asheville Region
828=296-4500
Notification (within 24-
hours)
2of2

�gx kv ovjllkcare Coot-
_
Facility -Tngm BioP-ewer,-iroc'.
NPDES Permit Number
w q�r�
Other Permit Number WQ0001512 - Wastewater Recycling
WQ0010689 - Distribution of Residual Solids (503 exempt)
NCG210028 - Stormwater - Wood, Chip Mills....
Issued Date WQ0001512 - -2,145/99- , , / !" ,
WQ0010689(7 /A010
NCG210028 - 4/1/98
Expiration Date WQ0001512 47 /31 /0$
WQ0010689 1( .3 0 �
NCG210028 - 3/31/05
County McDowell 5-11, -ter ��•
Mailing Address 205-Regeta,,-y-E-xeeutive-Paris-Dr-ivc-
--Suite-305—
,Ghaffotte,-- t-282'f- - g 7
Or
24 5�-tirrvitfu Road
L�Aaric�..- Iry . E.Uf=?
J ` __� - y fir• COM
Responsible Official -David ark —
_ - v p op4o uj-
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Official's Phone Number - Gli�
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ORC Ricky E. Styles
ORC's Phone Number 828.756-4946 P;sari
Location 2859 Old Linville Road (NCSR 1560) i;a8`
North Cove 'J
Stream UT to North Fork of the Catawba River
Class
7Q10

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
February 22, 2019
CERTIFIED MAIL NO.7016 2140 0000 0562 3717
RETURN RECEIPT REQUESTED
TERRY FOXX — PLANT MANAGER
BAXTER HEALTHCARE CORPORATION
65 PITT STATION
MARION, NORTH CAROLINA 28752
Dear Mr. Foxx:
Division or Water Resources
Water Ouaiity Regional Operations
Subject: Notice of Violation
Intent to Enforce
NOV-2019-PC-0106
Permit No. WQ0010689
North Cove Steam Generation
Plant Ash Distribution
Program
Residuals Management System
McDowell County
Division of Water Resources records indicate that the above referenced permit has overdue annual
fees. It is a condition of your permit and required by administrative code 15A NCAC 02T .0105(e)(2) that
the fee be paid annually.
Please remit payment in the form of a check, money order, or electronic funds transfer made
payable to the North Carolina Department of Environmental Quality in the amount of $1,310.00 for the
following overdue annual fee (invoice attached):
Invoice Number
Invoice Date
Due Date
Overdue Fee
2018PR007689
August 3, 2018
September 2, 2018
$1,310.00
Total Due:
$1,310.00
As the Permittee, you are responsible for paying the annual fee for administering and compliance
monitoring. Failure to pay your outstanding annual fees within 30 days of this notice shall result in a civil
penalty assessment in accordance with G.S. 143-215.6A. Please remit payment to the following address:
E
Division of Water Resources
Non -Discharge Branch
ATTN: Nathaniel Thornburg
1617 Mail Service Center
Raleigh, NC 27699-1617
etor:fDF
NORTH CAROUNA Q
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

Page 2 of 2
If the non -discharge system has not been constructed, or if it is no longer active, you may request
to rescind your permit. By rescinding your permit, all overdue annual fees will be waived; however, if in
the future you wish again to operate the subject non -discharge system, you must first apply for and receive
a new non -discharge permit. Permit rescission requests may be emailed 'to Non-
[e-mail].
If you no longer own the non -discharge system, as the Permittee, you are still responsible for the
permit and annual fees. As noted in your permit, the subject permit is not transferrable with the land, and
a change of ownership application must be received, and a permit reissued to the new landowner to release
you from all permit responsibilities. For the most recent permit change of ownership application, please
email [e-mail], and the' forms will be provided. This application shall be
completed by both the current Permittee and the new land owner and sent to the address listed on the
following page.
Thank you in advance for your cooperation and timely response. If you need additional information
regarding this notice, please contact Sonia Graves at [phone] or [e-mail].
Sincerely,
Nathaniel D. Thornburg, Branch Chi
Division of Water Resources
cc: sheville Regional Office, Water Quality Regional Operations Section
Central Files

Permit: WQ0010689 Effective: 12/01/14 Expiratio 11/30/19 Owner: Baxter Healthcare Corporation
SOC: Effective: Expirati Facility: North Cove Steam Generation Plant Ash Distribution
County: McDowell 2859 Old Linville Rd
Region: Asheville
��II_� Marion NC 28752
�O►-L l.A,�'��/per
Contact Person: Mie�Risafi4 Title: Sr Environmental Engineer Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter- North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Ricky Styles
On -site representative
Related Permits:
WQ0001512 B xter Healthcare Corporation - Baxter Healthcare Corporation RLAP
900
Inspection Date: 04Q - Entry Time: 4 e.t`AV' Exit Time: 10:OOAM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling
(See attachment summary)
j„ "�)a' t Sr Vesr[
Page: 1

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary: A4'lk,4,k VILA-1-\
eS (prey I
The inspection was conducted by Beverly Price of the Asheville Regional Office. Ricky Styles and assisted
with the inspection.
The inspection included a review of the site facilities and record keeping.
The storage pad now has concrete barriers to prevent migration of residuals. This area should be monitored during rain
events to ensure leachate does not leave the site.
Dry bottom ash is no longer landfilled, it is now co -mingled with scrubber ash.
All distributions are carried out by Baxter via a local hauler.
A soils analysis is not required per the permit, however, the residuals recipient does get a soils analysis which Baxter then
uses to help determine loading rates.
The ash storage facility appears to be well maintained and operated.
Page: 2

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Yes No NA NE
Land Application
Distribution and Marketing
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
El ❑ E ❑
Are GW samples from all MWs sampled for all required parameters?
El El 0 ❑
Are there any GW quality violations?
❑ ❑ 0 ❑
Is GW-59A certification form completed for facility?
❑ El 0 0
Is a copy of current permit on -site? �i
E ElEl
current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
N❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
❑ 0 ❑ ❑
y�
Are there pH records for alkaline stabilization? h% f
Are there pH records for the land application site? I
❑ ❑ 0 ❑
Are nutrient/crop removal practices in place?
0 ❑ El ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ E
Are hauling records available?
id
❑ ❑
Are hauling records maintained up-to-date?
# Has permittee been free of public complaints in 19st 12 months?
Has application occurred during Seasonal Restriction window?
❑ 0 ❑ ❑
Comment: Calibration of land application equipment is not a requirement of the permit.
Sampling Yes No NA NE
Describe sampling:,?,, L v ) '
Ash is removed from ti'ie basin and stored on the cancrete apron adjacent to the the basin. Numerous grab
samples are collected from the stockpile and composited for analysis. Extra sample is bagged and kept
refrigerated at Baxter until sample results are verified.
Is sampling adequate? M A0 `r �0 11 El El
Is sampling representative? N ❑ ❑ ❑
Comment:
C�lro�
Page: 3

r_
S
July 7, 2017
ROY COOPER°
Governor
MICHAEL S. REGAN
Secretafy
S. JAY ZIMMERMAN
-Director
Jon Rushford, VP of Manufacturing
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: Annual Report (2016) Review Inspection
North -Cove Steam Generation Plant Ash Distribution Program
Permit No: WQ0010689
McDowell County
Dear Mr. Rushford: .
Enclosed please find a copy of the Annual Report Review Inspection Form from the inspection conducted on
6/29/2017. The facility was found to be in compliance with permit WQ0010689.
Please refer to the enclosed inspection report Ifor additional observations and comments. If you or your staff
have any questions, please call me at 828-296-4500.
Sincerely,
Beverly Price
Environmental Senior Specialist
Enclosure: Inspection Report
cc: Michael J. Pisarik, Sr. Environmental Engineer
MSC 1617-Central Files -Basement
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\WQ0010689 - Ash DRS\CEI17.2016 AR Review.doex
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 29778
828 296 4500

Compliance Inspection Report '
Permit: WQ0010689 Effective: 12/01/14 Expiration: 11/30/19 'Owner:- Baxter Healthcare Corporation'
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash Distribution
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC.28752
Contact Person: Michael Joseph Pisarik Title: Sr Environmental Engineer Phone: ' 828-756-6017
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR1560 ( located behind Baxter- North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Michael Joseph Pisarik 828-756-6017
Related Permits:
WQ0001512 Baxter Healthcare Corporation - Baxter Healthcare Corporation RLAP
Inspection Date: 06/29/2017 Entry Time: 10:OOAM Exit Time: 11:OOAM
Primary Inspector: Beverly Price D4 Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503. Exempt)
Facility Status: ® Compliant ❑ Not Compliant
Question Areas:
® Miscellaneous Questions Record Keeping
(See attachment summary)
Page: 1

n
Perrnit: WQ0010689 Owner - Facility: Balder Healthcare Corporation
Inspection Date: 06/29/2017 Inspection Type; Annual, Report Review Reason for Visit: Routine
inspectiori Summary:
The Annual Residuals Review was conducted by Beverly Price of the Asheville. Regional Office.
891.168 dry tons of residuals were distributed in 2016; the permit limit is 3,200 dry tons.
Metals/nutrients analyses were conducted per permit requirements. Based on the volume of residuals distributed, four
sampling events were required. Samples were collected from the north & south wood ash basins. Metals results appeared
to be compliant with permit limits for ceiling concentrations and monthly average concentrations. TCLP metals were
analyzed along with Ignitability, Corrosivity & Reactivity. All results appeared to meet permit requirements.
Reminder: A full TCLP analysis is required once per permit cycle.
Ash Distribution Utilization Agreements were included in the report.
Page: 2

Permit: WQ0010689 Owner- Facility., Baxter Healthcare Corporation
Inspection Date: 06/29/2017 Inspection Type: Annual Report Review Reason for Visit:. Routine
Type,
Land Application
Distribution and Marketing`
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment: The review was done for metals/nutrient analyses performed in 2016.
Yes No NA NE
El
Yes No NA NE
❑❑■❑
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■❑❑❑
■❑❑❑
❑ ❑ ❑--- -
❑ ❑ ❑
❑❑❑■
Page: 3

October 12, 2016
Regional Supervisor
North Carolina Division of Water Resources
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
RE: Delegation of Signature Authority
Baxter Healthcare Corporation
NPDES Permit No. NCO06564
NPDES Stormwater Permit No. NCG060030 and No. NCG210028
Ash Distribution Program Permit No. WQ0.010689
Land Application of Residual Solids Permit No. WQ0031725
This letter is to notify DEQ- Division.of Water Resources of the change in Signature Authority for Baxter
Healthcare North Cove facility in Marion, NC. Jon Rushford replaces Tony Johnson as signature
authority for the above mentioned permits.
Jon Rushford
VP Operations, North Cove
65 Pitts Station Rd., Marion, NC 28752
jon rushfordRbaxter.com
828-756-6530
If you have any questions, please contact Mike Pisarik at 828-756-6017 or michael pisarik(a-)baxter.com.
Sincerely,
Jon Rushford
VP Operations, North Cove
Cc: DEQ- Asheville Office
OCT 2 7 2016
Water Quafifij Regfonef Operations
— AShevifie Reninnat n-R--
Baxter Healthcare Corporation
61 Pitts Station Road / PO Box 1390 / Marion, North Carolina 28752
T 828.756.4151

FILL,
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Water Resources
ENVIRONMENTAL QUALITY
June 13, 2016
Tony Johnson, Interim Plant Manager
Baxter Healthcare Corporation
Post Office Box 1390
Marion, NC 28752
SUBJECT: Compliance Evaluation Inspections
Facility (4/6/16) & Annual Report (2015) Review (6/10/16)
North Cove Steam Generation Plant Ash Distribution Program
Permit No: WQ0010689
McDowell County
Dear Mr. Johnson:
Secretary
S. JAY ZIMMERMAN
Director
Enclosed please fmd a copy of the Compliance Evaluation Inspection Forms from the inspections conducted on
4/6/2016 and 6/10/2016. The facility was found to be in compliance with permit WQ0010689.
Please refer to the enclosed inspection, report for additional observations and comments. The assistance of Mr.
Michael Pisarik and Ricky Styles was appreciate during the facility inspection. If you or your staff have any
questions, please call me at 828-296-4500.
Sincerely,
Beverly P " e
Environmental Senior Specialist
Enc.
cc: Michael Pisarik, Sr. Environmental Engineer
MSC 1617-Central Files -Basement
AsheviI'le File- s��
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\WQ0010689 CEI16 Facility & 2015 AR Review.docx
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28778
828 296 4500

Compliance Inspection Report
Permit: WQ0010689 Effective: 12/01/14 Expiration: 11/30/19 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility:. North Cove Steam Generation Plant Ash Distribution
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Michael Joseph Pisarik Title: Sr Environmental Engineer Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Ricky Styles
On -site representative Michael Joseph Pisarik
Related Permits:
WQ0001512 Baxter Healthcare Corporation - Baxter Healthcare Corporation RLAP
Inspection Date: 04/06/2016 Entry Time: 09:15AM Exit Time: 10:OOAM
Primary Inspector: Beverly Price j�{r Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant Not Compliant
Question Areas:
E Miscellaneous Questions Record Keeping Sampling
(See attachment summary)
Page: 1

Permit: w00010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary. -
The inspection was conducted by Beverly Price of the Asheville Regional Office. Ricky Styles and Michael Pisarik assisted
with the inspection.
The inspection included a review of the site facilities and record keeping.
The storage pad now has concrete barriers to prevent migration of residuals. This area should be monitored during rain
events to ensure leachate does not leave the site.
Dry bottom ash is no longer landfilled, it is now co -mingled with scrubber ash.
All distributions are carried out by Baxter via a local hauler.
A soils analysis is not required per the permit, however, the residuals recipient does get a soils analysis which Baxter then
uses to help determine loading rates.
The ash storage facility appears to be well maintained and operated.
Page: 2

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ 0 ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ 0 ❑
Are there any GW quality violations?
❑ ❑ 0 ❑
Is GW-59A certification form completed for facility?
❑ ❑ 0 ❑
Is a copy of current permit on -site?
0 ❑ ❑ ❑
Are current metals and nutrient analysis available?
N ❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
0 ❑ ❑ ❑
a. TCLP analysis?
N ❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑ ❑ ❑
Are PAN balances being maintained?
❑ ❑ N ❑
Are PAN balances within permit limits?
❑ ❑ 0 ❑
Has land application equipment been calibrated?
❑ E ❑ ❑
Are there pH records for alkaline stabilization?
❑ ❑ 0 ❑
Are there pH records for the land application site?
❑ ❑ E ❑
Are nutrient/crop removal practices in place?
0 ❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ ❑
Are hauling records available?
❑ ❑' ❑
Are hauling records maintained and up-to-date?
❑ ❑ ❑
# Has perrnittee been free of public complaints in last 12 months?
0 ❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑ N ❑ ❑
Comment: Calibration of land application equipment is not a requirement of the permit.
Sampling Yes No NA NE
Describe sampling:
Ash is removed from the basin and stored on the concrete apron adjacent to the the basin. Numerous grab
samples are collected from the stockpile and composited for analysis. Extra sample is bagged and kept
refrigerated at Baxter until sample results are verified.
Is sampling adequate? M ❑ ❑ ❑
Is sampling representative? N ❑ ❑ ❑
Comment:
Type Yes No NA NE
Land Application ❑
Distribution and Marketing
Page: 3

Permit: WO0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/06/2016 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Page: 4

Compliance Inspection Report
Permit: WO0010689 Effective: 12/01/14 Expiration: 11/30/19 owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash Distribution
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Michael Joseph Pisarik Title: Sr Environmental Engineer Phone: [phone]
Directions to Facility.:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Michael Joseph Pisarik 828-756-6017
Related Permits:
WQ0001512 Baxter Healthcare Corporation - Baxter Healthcare Corporation RLAP
Inspection Date: 06/10/2016 EntryTime: 10:OOAM Exit Time: 11:OOAM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
(See attachment summary)
Page: 1

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 06/10/2016 Inspection Type: Annual Report Review Reason for visit: Routine
Inspection Summary:
The inspection was conducted by Beverly Price of the Asheville Regional Office. The inspection consisted of a review of the
2015 Annual Report.
1487.02 dry tons of residuals were distributed in 2015. Based on the volume distributed, 4 samples are required; 6 samples
were analyzed in 2015. Metals limits for Ceiling Concentration and Monthly Average Concentration appeared to have been
met. TCLP metals analyses were conducted on 6 samples. Ignitability/Corrosivity/Reactivity was conducted in October
2015.
*Reminder - Full TCLP analysis is required once per permit cycle*
Signed Utilization Agreements were submitted — Please ensure that a Baxter representative signs every Agreement.
This residuals facility is 503 exempt.
0
Page: 2

Permit: WO0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 06/10/2016 Inspection Type: Annual Report Review Reason for Visit: Routine
r
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Type
Land Application
Distribution and Marketing
Yes No NA NE
❑❑■❑
❑❑■❑
❑ ❑ N ❑
❑ ❑ ❑
❑ ❑ ❑
❑❑■❑
❑ ❑ N ❑
❑❑■❑
❑ ❑ N ❑
❑❑■❑
❑ ❑ ❑
■❑❑❑
■❑❑❑
E ❑ ❑ ❑
❑ ❑ ❑ s.
Yes No NA NE
Page: 3

Compliance Inspection Report
Permit: WQ0010689 Effective: 12/01/14 Expiration: 11/30/19 owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash Distribution
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter- North Cove). The facility is located on the left.
System Classifications:
Primary ORC: ff4 Certification: Phone:
Secondary ORC(s): /1l 4
On -Site Representative(s):
Related Permits:
WQ0001512 Baxter Healthcare Corporation - Baxter Healthcare Corporation RLAP
l l
Inspection Date: 6 Entry Time: Exit Time:
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: 17/1 Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling
(See attachment summary) "V L
V'Cc i•^ sG1/��s � e�SUrP �/� (e�G/�e �ea�c/`
zAWt Pla-1- f/ -I
Sk IMQt`4 bR_ 15 6�-p Ltd tk� M'► 13� �l t � �3 r 's tPs r lBt l �OC�S �il y dY� 14 P
ax- , 0-4 a til �A_ t�1a- �r �t 0_",
a _4; ti
04 Page: 1
�f ���

Permit: WO0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 07/04/1976 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 07/04/1976 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit.on-site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters? 315
a. TCLP analysis? V ►�A?5- 13f Gz)r��/0SI A-e4-c-i .— � s
b. SSFA (Standard Soil Fertility Analysis)?PA Aq'14 "T - 1
Are PAN balances being maintained? P A 6,c rx6jp; 4
Yes No NA NE
❑❑[4❑
❑❑pal❑
❑ ❑ Eff❑
❑❑V1❑
❑ ❑ ❑
Q ❑ ❑ ❑
N ❑ ❑ ❑
MY10
`�_❑❑CO❑
❑❑❑❑
Are PAN balances within permit limits? Pf _ C6 d l S Dirk dl ❑ ❑ ❑ ❑
Has land application equipment been calibrated? NO
Are there pH records for alkaline stabilization? Ji A`
Are there pH records for the land application site? N 10'
Lc Sys / Z-p ❑ ❑ ❑ ❑
d t Pit,rM un i �� �d La 1-<�leJ ❑ ❑ ❑ ❑
Are nutrient/crop removal practices in place? Y
Do lab sheets support data reported on Residual Analysis Summary? tL I tult4j
Are hauling records available? tat j 4 r� � � (z
Are hauling records maintained and up-to-date? �! �t- CA �(
# Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑
Has application occurred during Seasonal Restriction window? tkr> l� Corn S a lq� e El 9 ❑
Comment: sQrn t A l ` S0,V.1 -f e5cik-c�
Yes No NA NE
all that apply
KbDstion ❑
igestion ❑
teurization (Class A) ❑
bilization (Class B) ❑
❑Co
Sampling �A Cy jL BpYes No NA NE
Describe sampling: A_- L 'KC b �' m AO i Tel o�
Is sampling adequate? n I lLWA j'hb� S �� A L��, aL/- Gp vI v" �/y// —" ❑ ❑ ❑ ❑
�9� .`-.J Page: 3
c I h�,✓L ate\ S'•3L � �L►'►'`' p %LS
Gt,vl a 1 S c�"��lv r`L-Su`�1 2'^t "'r ��/'�

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 07/04/1976 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is sampling representative? El El 0
Comment: T
Page: 4

Baxter Biomass - Wood Boiler Ash - Ricky Styles
Please test the sample(s) for the parameters as
listed below.
Send original results to: email: [e-mail] & [e-mail]
Send invoice and copy of results to: email: [e-mail]
Ricky Styles
Baxter Biomass Purchase Order # 108107
2859 Old Linville Rd.
Marion, NC 28752
[phone]
0-w...lAI 1 1 Ielr=n
Sample #
Sample
Sample Date(s)
Grab or
Total Metals -
TCLP Metals
Ignitability,
pH
Total -Arsenic
Full TCLP
Description
and time sample
Composite
As, Ba, Cd,
As, Ba, Cd,
Reactivity
Corrosivity,
collected
Ca, Cr, Cu, Fe,
Cr, Pb, Hg,
Pb, Mg, Hg,
Se, Ag
Mn, Mo,NI, K,
Se, Ag, Na,
Zn, total
Phosphorus
NP33116A
ASH
3-31-16 9:45AM
COMPOSITE
YES
YES
YES
YES
NP33116B
ASH
3-31-16 9:45AM
COMPOSITE
YES
YES
YES
YES
Sample sent to: Pace Analytical Services,
2225 Riverside Drive
Asheville, NC 28804
828-254-7176
Chain of Custody
Project Manager: Tom Williams
9800 Kincey Avenue, Suite 10(
Huntersville, NC 28078
(704) 875 - 9092 ext. 233

Baxter
March 15, 2016
DEQ — Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: N orth Co Steam Generation Ryan- AsAID is rib t`on Progra=
permit#: WQ00�11068'9
Bayer Healthe.aLe LandsApplicationrof9Residu lzSullds
'° rmit#. W0003-%25TO
Baxter Healthcare NPDES Stormwater Permit
Permit#: NCG060030
Baxter Healthcare NPDES Stormwater Permit
Permit#: NCG210028
Baxter Healthcare NPDES Permit
Permit#: NC0006564
This letter is to notify DEQ — Division of Water Resources of the change in Signature Authority for Baxter
Healthcare North Cove facility in Marion, NC. Tony Johnson will be replacing Alan Weiler as signature
authority for the above mentioned permits.
If you have any questions please contact Amanda Richcreek at 828-756-6809.
Sincerely,
Tony Johnson
VP, Ops — US/Canada Area
Enclosures
cc: DEQ-Asheville Office
Baxter Healthcare Corporation
One Baxter Parkway / Deerfield, Illinois 60015
T 847.948.2000
RECEIVED
Vivision of Water Resources
VAR 15 2
Water ouality Regional Operations
Asheville Regional Office

Baxter
August 25, 2015
Ms. Beverly Price
Environmental Specialist
NCDENR Division of Water Resources
Water Quality Program
2090 U.S. Highway 70,
Swannanoa, NC 28778
RE: 2014 Annual Land Application Report — Response to Report Inconsistencies
Permit No. WQ0010689
Baxter Healthcare Corporation
McDowell County
Ms. Price,
This letter is in response to the Annual Report (2014) Review Inspection Baxter Healthcare received on August
20, 2015 in regards to the Inconsistencies between the recipient information sheets (dates, names, volume of
residuals distributed) and the Certification Supplemental Form. The Certification Supplemental Form serves as
the official record of distribution and receipt of the scrubber ash per section IV.6 of the permit dated June 10,
2007. This information includes the date of ash distribution, the name of the initial recipient of the ash and the
amount distributed and the intended use. The recipient information sheets serve as an ash distribution utilization
agreement between Baxter Healthcare and the ash recipient to ensure the transportation, storage and application of
the aforementioned ash is applied according to the permit conditions. These agreements are signed once during
the permit cycle unless there are changes to the property.
Please contact Amanda Richcreek, [e-mail] or 828-756-6809, if you have any questions
Sincerely,
J. Alan Weiler
Plant Manager
Cc: EHS File Copy
Division Water
AUG 2 7 2015
Water Quality Regionaf Operations
Asheville Re�ionaf Office
Baxter Healthcare Corporation
PO Box 1390, Marion, NC 28752
T 828.756.4151

i• (.ry
NCDENR .
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
August 17, 2015
Amanda Richcreek, Environmental Engineer
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
SUBJECT: Annual Report (2014) Review Inspection
North Cove Steam Generation Plant Ash Distribution Program
Permit No: WQ0010689
McDowell County
Dear Ms. Richcreek:
Donald R., van der Vaart
Secretary
Enclosed please find a copy of the Annual Report Inspection Form from the inspection conducted on 8/11/2015.
The facility was found to be in compliance with permit WQ0010689.
There are some inconsistencies between the information.pr6vided on the Certification Supplemental Form and
the recipient's information sheets. Please see the Inspection Summary Page 2 for details: The inconsistencies
should be reconciled and the information submitted to the Asheville Regional office within 10 days of receipt of
this letter. ,
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at 828-296-4685.
Sincerely,
611P /a6lr�
Beverly Price
Environmental Specialist
Enc.
cc: Ricky Styles, ORC
MSC 1617-Central Files -Basement
h �vi�l'le.�F�l e s
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\CEI15 2014 AR Review.doc
Water Quality Regional Operations —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone:[phone] FAX: [phone]
Internet: http://portal.nedenr.org/web/wq
An Equal Opportunity \ Affirmative Action Employer

Compliance Inspection. Report
l
Permit: WQ0010689 Effective: 12/01/14 Expiration: 11/30/19 " Owner : , Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash Distribution
County: McDowell 2859 Old Linville.Rd
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: - Environmental Engineer-. -Phone: [phone] =
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: ` Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Amanda Richcreek 828-756-6809
Related Permits:
WQ0001512 Baxter Healthcare Corporation - North Cove Steam Generation Plant
Inspection Date: 08/11/2015 Entry Time: 04:OOPM Exit Time: 05:OOPM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant Not Compliani
Question Areas:
Miscellaneous Questions Record Keeping
(See attachment summary)
Page: 1

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/11/2015 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
1715.7 dry tons of residuals were distributed in 2014.
TCLP analysis is required once per permit cycle. The current permit became effective on December 1, 2014. The TCLP
analysis is due before November 30, 2019.
Based on, the amount of dry tons distributed in 2014, 6 nutrient/metals analyses were required. Six residuals analyses
were conducted; all parameters appeared to be within permit limits.
Some of the recipient information sheets (dates, names, volume of residuals distributed etc.) do not match the information
given on the Certification Supplemental Form. Specifically: 1) Ray Watson sheet is dated 11-1-12 and the Terry English
sheet is dated 2-25-13(This issue.was noted in the last inspection). The Supplemental Form indicates distributions in
March, April, June and October whereas the recipient sheets show distributions in January, February and July. Please
reconcile the Certification Supplemental Form with the recipient information sheets and re -submit to the Asheville Regional
Ofice.
Page: 2

Permit WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/11/2015 Inspection Type: Annual Report Review Reason for Visit: Routine
Type
Land Application
Distribution. and Marketing
Yes No NA NE
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ ❑
Are there any GW quality violations?
❑ ❑ M El
Is GW-59A certification form completed for facility?
❑ ❑ ❑
Is a copy of current permit on -site?
❑ ❑ 110
Are current metals and nutrient analysis available?
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
M ❑ ❑ ❑
a. TCLP analysis?
❑ ❑ 0 ❑ ,
b. SSFA (Standard Soil Fertility Analysis)?
❑ ❑ 0 ❑
Are PAN balances being maintained?
❑ ❑ ❑
A`reRAN balances within permit limits?
❑ ❑
Has land application equipment been calibrated?
❑ ❑ ❑
Are there pH records for alkaline stabilization?
❑ ❑ ❑
Are there pH records for the land application site?
❑ ❑ ❑
Are nutrient/crop removal practices -in place?
❑ ❑ M ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ ❑
Are hauling records available?
M ❑ ❑ ❑ -
Are hauling records maintained and up-to-date?
❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑ ❑ M ❑
Comment: Two of the residuals recipient data sheets were not current; one was dated 11-1-2012.and the
other was dated 2-25-2013. Updated information sheets will need to be re -submitted.
r'
Page: 3

` SState of North Carolina
Department of )Environment and Natural Resources
Division of Water Resources
August 12, 2014
To: DWR Water Quality Permitting Section Central Office
Attn: David Goodrich
From: Bev Price
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No Annual Compliance Inspections
a. Date of site visit: 1/31/14 Site Inspection & 6/18 /14 Annual Report Review
b. Site visit conducted by: Bev Price
c. Inspection report attached? ® Yes or ❑ No
Water Quality Permitting
Regional Staff Report
Application No.: WQ0010689
Regional Login No.:
d. Person contacted: and their contact information: Amanda Richereek, Environmental Engineer 828-756-
6809
e. Driving directions: Take Hwy. 221 North out of Marion to NCSR 1560 (located behind Baxter — North
Cove). The facility is on the left.
H. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
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:
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)
FORM: APSRSR 04-10 Pagel of 3

III. EXISTING FACILITIES FOR iviLuDIFICATION AND RENEWAL APP'—ATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
ORC: Certificate #: Backup ORC: Certificate #:
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: The final ash storage area located at the North pond was noted in the January inspection as
an area where runoff had occurred. A silt fence and hay bales were installed as a temporary measure to deal with
runoff. See IVA.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No N/A
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: N/A Rates on based on agronomic rate.
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.
9.. Is the description of the facilities as written in the existing 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:
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
0 , 11
0 , it
0 , II
0 , it
0 / it
0 / //
0 , if
0 , f/
0 , „
0 ,
12. Has a review of all self -monitoring data been conducted (e.g., NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review:
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 ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain:
FORM: APSRSR 04-10 Page 2 of 3

16. Are there any issues related t mpliance/enforcement that should be res d before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like APS Central Office to obtain through an additional information request:
Item
Reason
Re -submit the ash The ARO reviewed the 2013 Annual Report. The distribution sheets did
distribution sheets that were not have the correct date; some were dated 2012 & 2009. The ARO requested
submitted with the 2013 corrected distribution sheets be re -submitted. The sheets were re -submitted but
Annual Report. still with the wrong date.
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 issued:
Condition Reason
Ensure that ash is
adequately stored to Runoff was noted during the 1/31/14 site inspection. See attached
prevent runoff prior to inspection report.
distribution.
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 reasp�is: )
6. Signature of report preparer:
Signature of APS regional su
Date: 1�r• i 3 ,
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: APSRSR 04-10 Page 3 of 3

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MCDEN
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
June 30, 2014
Terry Foxx, Interim Plant Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
SUBJECT: Compliance Evaluation Inspections
Baxter Healthcare
Land Application of Residual Solids
WQ0031725
North Cove Steam Generation Plant Ash Distribution Program
Permit No: WQ0010689
McDowell County
Dear Mr. Foxx:
Enclosed please find a copy of the Compliance Evaluation Inspection Forms from the inspections conducted on June 18,
2014. The facility was found to be in compliance with permits WQ0010689 & WQ0031725.
Regarding permit WQ0010689, please resubmit the following information to the Asheville Regional Office:
1. Residuals Sampling Summary Form with the correct sample identifier or an
explanation for the sample locations given.
2. Recipient data sheets with the correct information; some sheets were dated 2012 & 2009.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any
questions, please call me at [phone].
Sincerely,
Beverly Price
Environmental Specialist
Enc.
cc: Ricky Styles, ORC
WQ Central Files
WQ Asheville Files
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\WQ0010689 & WQ0031725 CEI14 2013 AR Review.doc
Water Quality Regional Operations —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet: http://portal.ncdenr.orglweb/wq/
An Equal Opportunity 1 Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0010689 Effective: 06/07/10 Expiration: 11/30/14 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash Distribution
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
Related Permits:
Inspection Date: 06/18/2014
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Entry Time: 01:OOPM Exit Time: 02:OOPM
828-756-6809
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: ® Compliant Not Compliant
Question Areas:
® Miscellaneous Questions Record Keeping
(See attachment summary)
Page: 1

permit WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 06/18/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This inspection included a review of the 2013 Annual Report.
1576.12 dry tons of ash were distributed during 2013.
Metals/nutrients samples collected as required by the permit.
The TCLP was done in 2011.
Some of the recipient information sheets were dated 2012 and one was dated 2009. Please resubmit the correct recipient
data sheets - the totals on these sheets should match the Distribution Certification Form.
Residuals Sampling Summary Form - resubmit with correct sample identifier.
Page: 2

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 06/18/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Land Application
Distribution and Marketing
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Yes No NA NE
Yes No NA NE
❑ ❑ W ❑
❑ ❑ M ❑
❑ ❑ H ❑
W ❑ ❑ ❑
® ❑ ❑ ❑
❑ ❑ ❑ N
❑ ❑ W ❑
❑ ❑ 9 ❑
❑❑2R
❑ ❑ N ❑
❑ ❑ ® ❑
❑ ❑ M ❑
❑ ❑ IN ❑
® ❑ ❑ ❑
®❑ ❑ ❑
® ❑ ❑ ❑.
❑ ❑ ❑
❑ ❑ ® ❑
Page: 3

Ain
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder
Governor Director
John E.
Skvarla, III
Secretary
February 7, 2014
Andrea Darsey, Plant Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
SUBJECT: January 31, 2014
Compliance Evaluation Facility Inspections
Baxter Healthcare Corporation
North Cove Steam Generation Plant
Wastewater Recycle System
Permit No: W00001512
Ash Distribution Program
W00010689
North Cove WWTP
Land Application of Residual Solids
W00031725
McDowell County
Dear Ms. Darsey:
Enclosed please find a copy of the Compliance Evaluation Inspection forms from the inspections
conducted on January 31, 2014. The facility was found to be in Compliance with permits W00001512,
WQ0010689 & W00031725.
Silt fencing/straw bales have been placed around the ash storage area to address potential runoff
to surface waters. We appreciate the immediate response to this issue.
Please refer to the enclosed inspection reports for additional observations and comments. The
assistance of Ms. Amanda Richcreek, Mr. Ricky Styles and Mr. Stephen Taylor was greatly appreciated
during the inspection. If you or your staff have any questions, please call me at [phone].
Sincerely,
/2�
�J
Beverly Price
Environmental Specialist
Enclosures
cc: Amanda Richcreek, Environmental Engineer
Water. -Quality Central Files
ua the IN6,14s
G:\WR\WQ\McDowell\Wastewater\Non-discharge\Baxter Healthcare\WQ0010689 & W00001512 &
WQ0031725CEI14 Facility.doc
Water Quality Regional Operations —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet http://portal.nodenrorg/web/wq
An Equal Opportunity 1 Affirmative Action Employer

Compliance Inspection Report
Permit: WO0010689 Effective: 06/07/10 Expiration: 11/30/.14 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located. behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 01/31/2014
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Ricky Styles
Amanda Richcreek
Entry Time: 11:30 AM Exit Time: 12:00 PM
Phone: [phone]
Phone: [phone]'
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions 0 Record Keeping Treatment Sampling
(See attachment summary)
Page: 1

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection included a tour of the facility and review of current data/maintenance records.
The TCLP analysis was conducted in 2011. Analysis is required once per permit cycle.
Inspection questions checked NE will be addressed during the 2013 Annual Report review.
Reminder: The permit expires 11/30/14. A renewal application is due 6 months prioir to expiration.
Silt fencing/straw bales have been put in place around the ash storage area to address runoff during precipitation events.
We appreciate the immediate response to this matter. A long term solution will be developed for this area of the facility.
Page: 2

a
Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application ❑
Distribution and Marketing
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
■
Yes No NA NE
Yes No NA NE
q
Page: 3

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Alkaline Stabilization (Class B)
0
Compost
Q
Drying Beds
Other
Comment: Ash settlement basins
Sampling Yes No NA NE
Describe sampling:
One basin is taken out of production and mixed w/wood chips/sawdust/dry ash and allowed to dry. Several
grab samples are collected from the dry pile and composited for analysis.
Is sampling adequate? 0 O 0 O
Is sampling representative? 0000
Comment:
Page: 4

Price, Bev
From: Richcreek, Amanda K <amanda richcreek [e-mail]>
Sent: Monday, February 03, 2014 1:07 PM
To: Price, Bev
Cc: Styles, Rickey E; Holland, Shane R; Thomas, Ricky W
Subject: North Pond Silt Fence.docx
Attachments: North Pond Silt Fence.docx
Bev,
On Friday January 31, 2014 we constructed a silt fence with hay bales to prevent the sediment runoff of the ash piles
from the North Pond. Attached are the pictures of the final project. This is a temporary fix to this issue. We are going
to meet this week to determine a long term corrective action. I will keep you posted with the final decision.
Amanda Richcreek
Environmental Engineer
Baxter Healthcare Corporation
65 Pitts Station Rd.
Marion, NC 28752
T: 828-756-6809
amanda richcreek(a)baxter.com
www.baxter.com
The information transmitted is intended only for the person(s) or entity to which it is addressed and' may contain
confidential and/or legally privileged material. Delivery of this message to any person other than the intended
recipient(s) is not intended in any way to waive privilege or confidentiality. Any review, retransmission,
dissemination or other use of, or taking of any action in reliance upon, this information by entities other than the
intended recipient is prohibited. If you receive this in error, please contact the sender and delete the material
from any computer.
For Translation:
http://www.baxter.com/email disclaimer

Compliance Inspection Report
Permit: WQ0010689 Effective: 06/07/10 Expirationf�t_ 30 ' _ Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Amanda Richcreek Title: Environmental Engineer Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
Related Permits:
Inspection Date: 1I.3 (1 IL/
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Amanda Richcreek
Entry Time: Exit Time: ra ah Q 40
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
E Miscellaneous Questions 0 Record Keeping Treatment Sampling
(See attachment summary)
u4__ 6Y Jt,t E, ' i Lf
/10 00
Page: 1
a
Ll

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes No NA
NE
Is GW monitoring being conducted, if required?
❑
❑
❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑
❑
Are there any GW quality violations?
❑
❑ im
❑
Is GW-59A certification form completed for facility?
❑
❑ 10
❑
Is a copy of current permit on -site?
❑ ❑
❑
Are current metals and nutrient analysis available? Qi4%j4Lv �D,01 A
0
❑ Cl
❑
Are nutrient and metal loading calculating most limiting parameters?
❑ ❑
n
a. TCLP analysis? cior,e t _ aC44
❑ ❑
❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑
❑
Are PAN balances being maintained?
❑
❑
❑
Are PAN balances within permit limits?
❑
❑
❑
Has land application equipment been calibrated?
❑
❑
❑
Are there pH records for alkaline stabilization?
❑
❑
❑
Are there pH records for the land application site?
❑
❑
n
Are nutrient/crop removal practices in place?
❑
❑
❑
Do lab sheets support data reported on Residual Analysis Summary? AO P.C; j
❑
❑ ❑
10
Are hauling records available? z < <.
❑
❑ ❑
Are hauling records maintained and up-to-date? C. ` c.
❑
❑ ❑
W
# Has permittee been free of public complaints in last 12 months?
5D
❑ ❑
❑
Has application occurred during Seasonal Restriction window?
❑
❑ 0
❑
Comment:
Treatment
Yes
No NA
NE
Check all that apply
Aerobic Digestion
❑
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
❑
Compost
❑
Drying Beds
❑
Page: 3

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routine
Other 5� �� tv� 'P-Oasi ✓ s ❑
Comment:
Sampling II / Yes No NA NE
Describe sampling: Sides v k4#n t7�4 ofi �o a- cl Ec, N �`701
� � Q %Sa� f�.� ., ce/�v Cv �d � ��'' S• �.l C� 4�..�j `Sri - 'rt1'
Is sampling adequate. /
ova cn�ie�-��c�
Is sampling representative? Tor- Qv-NQ. i w 5:❑ ❑ ❑ ❑
lS .
Comment:
Page: 4

Compliance pection Re ort
Permit: WQ0010689 Effective: 06/07/10 Exp' !ration: 11/30/14 ner: Baxter Healthcare Corporation
SOC: Effective: Ex ation: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: .144ekp-St7feT Title: Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/23/2013 Entry Time: 02:00 PM Exit Time: 02:45 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: , Compliant n Not Compliant
Question Areas: ,
0 Miscellaneous Questions N Record Keeping Treatment Sampling
(See attachment summary)
v5
��—�- f l �Cx..�.+< � — j /l c� -2� .� ram' �✓1/►�—
�jD t� UJ - e.7�� , C r e-,
Page: 1

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
O
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Reason for Visit: Routine
Yes No NA NE
D ❑ C`0
❑❑40
❑❑70
❑❑CYO
W ❑ ❑ ❑
�❑❑❑
D❑❑
❑ ❑ ❑ ❑
❑DaD
❑ ❑ 14 ❑
❑ ❑ 91 D
❑ ❑ 1� ❑
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Q ❑ D ❑
M ❑ ❑ ❑
[ D❑❑
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❑❑P❑
Yes No NA NE
Page: 3

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 08/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Other /
Comment:,: 4W, S
Sampling l�1 Yes No NA NE
© `""` s.t JoN
Describe sampling: �J..,I�,-c,-�.. 8 � �. s � � Q-- �S � p
,�LJL pr-odwe-+ s w( 6o44om As�1
Is sampling adequate? f Cdlowzj -6 C6- y 5evz-,�/
Is sampling representative? 5[� rr. (�S q r� l` � WV
P
Comment: CO— oS; 4,P-J ' "-
P
9 n n n
FYI nnn
Page: 4

_AT4
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mike Howell, Plant Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
Dear Mr.Howell:
Division of Water Quality
Charles Wakild, P. E.
Director
October 4, 2012
Dee Freeman
Secretary
SUBJECT: September 12, 2012
Compliance Evaluation Inspection
Baxter Healthcare Corporation
North Cove Steam Generation Plant
Wastewater Recycle System
Permit No: WQ0001512
Ash Distribution Program
WQ0010689
McDowell County
Enclosed please find copies of the Compliance Evaluation Inspection Forms from the
inspections conducted on September 12, 2012. The facility was found to be in compliance with
permit #'s WQ0001512 & WQ0010689.
Please refer to the enclosed inspection report for additional observations and comments.
The assistance of Ms. Amanda Richcreek and Mr. Ricky Styles was greatly appreciated during
the inspection. If you or your staff have any questions, please call me at [phone].
Sincerely,
Beverly !'rice
Environmental Specialist
Enclosures
cc: Amanda Richcreek, Environmental Engineer w/enclosures
APS Central Files
A�I'Srsh-euiIIejF les
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX: [phone]
Internet: www.ncwaterguality.org
NorthCarolina
An Equal Opportunity 1 Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0010689 Effective: 06/07/10 Expiration: 11/30/14 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752-
Contact Person: Mike Howell Title: Plant Manager Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 09/12/2012
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Amanda Richcreek
Ricky Styles
Entry Time: 09:30 AM Exit Time: 10:30 AM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status:' ■ Compliant Q Not Compliant
Question Areas:
0 Miscellaneous Questions 0 Record Keeping Treatment Sampling
(See attachment summary)
Page: 1

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/12/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Baxter is no longer landfilling any product. The SOP should be updated to reflect this.
Page: 2

Compliance Inspection Report
Permit: WQ0001512 Effective: 04/30/10 'Expiration: 01/31/17 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Mike Howell Title: Plant Manager Phone: [phone]
Directions to Facility:
Follow Hwy. 221 north from Marion to NCSR 1573 (Pitts Station Rd.), turn right. At intersection of Pitts Station Rd. & NCSR 1560 (Old
Linville Rd.), turn left. Facility is approximately 0.25 mi. on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 09/12/2012
Primary Inspector: Beverly Price
Secondary Inspector(s):
Amanda Richcreek
Ricky Styles
Amanda Richcreek
Entry Time: 10:30 AM
Reason for Inspection: Routine
Permit Inspection Type: Closed -Loop Recycle
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
0 Miscellaneous Questions E Treatment
(See attachment summary)
Exit Time: 11:00 AM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Inspection Type: Compliance Evaluation
0 Record Keeping
Page: 1

Permit: WQ0001512 Owner -Facility: Baxter Healthcare Corporation
Inspection Date: 09/12/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility is well maintained and records appeared to be complete.
Page: 2

Permit: WQ0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/12/2012 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Infiltration System
0
Reuse (Quality)
n
Single Family Spray, LR
❑
Lagoon Spray, LR
❑
Activated Sludge Spray, LR
❑
Activated Sludge Spray, HR
❑
Activated Sludge Drip, LR
❑
Single Family Drip
❑
Recycle/Reuse
■
Treatment
Yes No
NA NE
Are Treatment facilities consistent with those outlined in the current permit?
■ ❑
❑ ❑
Do all treatment units appear to be operational? (if no, note below.)
■ ❑
❑ ❑
Comment:
Record Keeping
Yes No
NA NE
Is a copy of current permit available?
■ ❑
❑ ❑
Are monitoring reports present: NDMR?
nn■❑
NDAR?
❑❑■❑
Are flow rates less than of permitted flow?
■ ❑
❑ ❑
Are flow rates less than of permitted flow?
■ ❑
❑ ❑
Are application rates adhered to?
❑ ❑
■ ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
❑ ❑
■ ❑
Are all samples analyzed for all required parameters?
❑ ❑
■ ❑
Are there any 2L GW quality violations?
❑ ❑
■ ❑
Is GW-59A certification form completed for facility?
Cl ❑
■ ❑
Is effluent sampled for same parameters as GW?
❑ ❑
■ ❑
Do effluent concentrations exceed GW standards?
Cl ❑
■ ❑
Are annual soil reports available?
❑ ❑
■ ❑
# Are PAN records required?
❑ ❑
❑
# Did last soil report indicate a need for lime?
❑ ❑
■ ❑
Page: 3

Permit: WQ0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/12/2012 Inspection Type:' Compliance Evaluation
Reason for Visit:
Routine
If so, has it been applied?
Q ❑
■
❑
Are operational logs present?
■
Are lab sheets available for review?
Cl ❑
■Cl
Do lab sheets support data reported on NDMR?
r,D■0
Do lab sheets support data reported on GW-59s?
❑ ❑
■
Q
Are Operational and Maintenance records present?
■ Cl
❑
O
Were Operational and Maintenance records complete?
■ ❑
Q
El
Has permittee been free of public complaints in last 12 months?
■ 0
Q
Is a copy of the SOC readily available?
fl ❑
■
❑
No treatment units bypassed since last inspection?
■ Q
❑
❑
Comment:
Page: 4

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/12/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application 11
Distribution and Marketing
■
Record Keeping
Yes No
NA NE
Is GW monitoring being conducted, if required?
0 ❑
■ ❑
Are GW samples from all MWs sampled for all required parameters?
0 0
■ Q
Are there any GW quality violations?
Q 0
■ 0
Is GW-69A certification form completed for facility?
❑ Q
■ 0
Is a copy of current permit on -site?
Q
0 0
Are current metals and nutrient analysis available?
■ 0
0 0
Are nutrient and metal loading calculating most limiting parameters?
■ ❑
Q 0
a. TCLP analysis?
■ O
Q 0
b. SSFA (Standard Soil Fertility Analysis)?
❑ 0
■ 0
Are PAN balances being maintained?
❑ n.
■ n
Are PAN balances within permit limits?
0 0
■
Has land application equipment been calibrated?
Q ❑
■ 0
Are there pH records for alkaline stabilization?
❑ 0
■ Q
Are there pH records for the land application site?
Q 0
■
Are nutrient/crop removal practices in place?
0 Q
■
Do lab sheets support data reported on Residual Analysis Summary?
■ n
0 0
Are hauling records available?
■ 0
n
Are hauling records maintained and up-to-date?
■ n
n Q
# Has permittee been free of public complaints in last 12 months?
■ ❑
❑ Q
Has application occurred during Seasonal Restriction window?
n n
■ 0
Comment:
r....,�..,.,.,�
Yes No
NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Page: 3

Permit: W00010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/12/2012 Inspection Type: Compliance Evaluation
Alkaline Stabilization (Class B)
Compost .
Reason for Visit: Routine
Drying Beds
Other
Comment: Settling ponds
Sampling
Describe sampling:
When one side (settling pond) is taken out of production, the product is then mixed with bottom ash or dry
wood and allowed to dry. Several grab samples (approximately 2.5 gallons) are collected from the dry pile
and composited for analysis.
Is sampling adequate?
Is sampling representative?
Comment:
■❑nn
■nnn
Page: 4

Compliance In - Report
Permit: WQ0010689 Effective: 06/07/10 ExpiratLn: /30/14 ner: Baxter Healthcare Corporation
SOC: Effective: ExpiratFacility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell % 2I859 Old Linville Rd
Region: Asheville �; � p�P�i Ad
tAow e t, � Marion NC 28752
Contact Person: €r44®st—�d Title: Plant Manager Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Amanda Richcreek f'.! `' n-PL nLgJ
J T"
On -site representative Ricky Styles
Related Permits:
Inspection Date: 9 /11 b.). Entry Time:
Primary Inspector: Beverly Price
Secondary Inspector(s):
Exit Time:
Phone: [phone]
Phone: [phone]
6650
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ❑ Compliant Cl Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site ■ Pathogen and Vector
Attraction
(See attachment summary)
C)
P.
.0 _P , , C/
Page: 1

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Record Keeping
Yes No
NA
NE
Is GW monitoring being conducted, if required?
❑
❑
10
❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑
10
❑
Are there any GW quality violations?
❑
❑
❑
Is GW-59A certification form completed for facility?
❑
❑
❑
Is a copy of current permit on -site?
(013
❑
❑
Are current metals and nutrient analysis available? P-01 w� oill h
0
❑
❑
❑
Are nutrient and metal loading calculating most limiting parameters?
W
❑
❑
❑
a. TCLP analysis? Don t v,:, a6
W
❑
-0
❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑
91
❑
Are PAN balances being maintained?
❑
❑
❑
Are PAN balances within permit limits?
❑
❑
❑
Has land application equipment been calibrated?
❑
❑
❑
Are there pH records for alkaline stabilization?
❑
❑
❑
Are there pH records for the land application site?
❑
❑
❑
Are nutrient/crop removal practices in place?
❑
❑
rtA
IV
❑
Do lab sheets support data reported on Residual Analysis Summary?
❑
❑
❑
Are hauling records available? RL,ReW4_� Gott A -FL
❑
❑
❑
Are hauling records maintained and up-to-date?
❑
❑
❑
# Has permittee been free of public complaints in last 12 months?
❑
❑
❑
Has application occurred during Seasonal Restriction window?
❑
❑
(P
❑
Comment:
Pathogen and Vector Attraction
Yes No
NA
NE
a. Fecal coliform SM 9221 E (Class A or B)
❑
❑
❑
❑
Class A, all test must be <1000 MPN/dry gram
❑
Geometric mean of 7 samples per monitoring period for class 13<2.0*10E6 CFU/dry gram
❑
Fecal coliform SM 9222 D (Class B only)
❑
❑
❑
❑
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
❑
b. pH records for alkaline stabilization (Class A)
❑
❑
❑
❑
c. pH records for alkaline stabilization (Class B)
❑
❑
❑
❑
Page: 3

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑
❑
❑
❑
e. Time/Temp on:
❑
❑
❑
❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
❑
Cl
❑
❑
g. Bench -top Aerobic/Anaerobic digestion results
❑
❑
❑
❑
Comment:
Tronfmpnf
Yes
No
NA
NE
Check all that apply
Aerobic Digestion
❑
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
❑
Compost
❑
Drying Beds
❑
Other
00
Comment: 1
Sampling f I ^ ^ �C ) Yes No NA NE
Describe sampling: C3e� �p / Qwa I�j' �C Jl/Q�
�,✓� � s i ��J� Ab+J S
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? 0000
Comment:
Land Application Site kr
Yes
No
NA
NE
Is a copy of the permit on -site during application events?
❑
❑
❑
❑
Is the application site in overall good condition?
❑
❑
❑
❑
Is the site free of runoff/ponding?
❑
❑
❑
❑
If present, is the application equipment in good operating condition?
❑
❑
❑
❑
Are buffers being maintained?
❑
❑
❑
❑
Page: 4

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: Inspection Type: Compliance Evaluation
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment:
Reason for Visit: Routine
Page: 5

February 19, 2013
NCDENR — Division of Water Quality
Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
RE: North Cove Steam Generation Plant Ash Distribution Program
Permit#: W00010689
Baxter Healthcare Land Application of Residual Solids
Permit#: W00031725
Baxter Healthcare
RECEIVE®
FER. 20 2013 /
Asheville Regional Office
A - —
This letter is to notify NCDENR — Aquifer Protection Division of the change in Signature Authority for
Baxter Healthcare North Cove facility in Marion, NC. Andrea Darsey will be replacing Mike Howell as
signature authority for the above mentioned permits.
If you have any questions please contact Amanda Richcreek at 828-756-6809.
Sincerely,
Andrea Darsey
Plant Manager
Enclosures
cc: Bev Price — NCDENR-Asheville Office
Baxter Healthcare Corporation
One Baxter Parkway / Deerfield, Illinois 60015
T 847.948.2000

PW
NCDENR 'L
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
Ernest Shepard, Plant Manager
Baxter Healthcare Corporation
65 Pitts Station Road
Marion, NC 28752
September 28, 2011
Dee Freeman
Secretary
SUBJECT: September 16, 2011
Compliance Evaluation Inspections
Baxter Healthcare Corporation
North Cove Steam Generation Plant
Wastewater Recycle System
Permit No: WQ0001512
Ash Distribution Program
REQUEST FOR ADDITIONAL
INFORMATION
WQ0010689
McDowell County
Dear Mr. Shepard:
On September 16, 2011, 1 conducted a Compliance Evaluation Inspection of the Subject permits.
With regards to Permit No. W00001512 — The facility was found to be in compliance with permit
conditions.
With regards to Permit No. WQ0010689 —The inspection included a review of the 2010 Annual
Report. The following issues were noted in that review and should be addressed:
1) The Distribution of Residuals Solids (DRS) Certification Form did not include the
Recipient Volume (Dry Ton), Intended Use or Total Dry Tons distributed. The DRS
Certification Form should be completed.
2) The Ignitability analysis was not included.
Within 10 days of receipt of this letter, please submit 3 copies of the information referenced above
to:
NCDENR -DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
AQUIFER PROTECTION SECTION — Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX: [phone] One
Customer Service: 1-877-623-6748 NorthCarohna
Internet: www.ncwaterguality.orq
An Equal Opportunity 1 Affirmative Action Employer Awmalltf

Mr. Shepard
September 28, 2011
Page 2
Additionally, it appears that when the permit (WQ0010689) ownership changed from SUEZ
Energy (permit issued 11/29/06) to Baxter Healthcare in 2010, the new permit contained a
modified monitoring schedule for TCLP, corrosivity, ignitability and reactivity. The monitoring
schedule for this permit should not have changed with a change of ownership. Please contact
Mr. Jon Risgaard, Unit Supervisor, to request the reinstatement of the previous monitoring
requirements:
NCDENR-DWQ
Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
The assistance of Ms. Anita Jensen and Mr. Ricky Styles was greatly appreciated during the
inspection. If you or your staff has any questions, please call me at 828/296-4685.
Sincerely,
Beverly Price
Environmental Specialist
Enclosures
cc: Anita Jensen, CSP EHS Manager w/enclosures
APS Central Files
F MAI -1 � Files-'

Permit: WQ0010689
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 06/07/10 Expiration: 11/30/14 Owner: Baxter Healthcare Corporation
Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
2859 Old Linville Rd
Marion NC 28752
Contact Person: Ernest Shepard Title: Plant Manager Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 09/16/2011
Primary Inspector: Beverly Price
Secondary Inspector(s):
Ricky Styles
Ricky Styles
Anita Jensen
Entry Time: 01:30 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Exit Time: 03:30 PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
0 Miscellaneous Questions 0 Record Keeping Treatment Sampling
(See attachment summary)
Page: 1

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection included a tour of the facility and a review of the 2010 Annual Report.
The following issues are related to the review of the 2010 Annual Report:
1) The Distribution of Residuals Solids (DRS) Certification Form did not include the Recipient Volume (Dry Ton) or
Intended Use. The Total Dry Tons distributed was not included.
The DRS Certification Form should be completed and resubmitted.
2) The Ignitability analysis was not included. The Ignitability analysis should be submitted.
It appears that when the permit ownership changed from SUEZ Energy (permit issued 11/29/2006) to Baxter Healthcare
in 2010, the new permit contained a modified monitoring schedule. The monitoring schedule for this permit should not
have changed with a change of ownership. The Central Office should be notified to reinstate the monitoring schedule
under the 2006 permit.
Page: 2

Permit: WO0010689 Owner - Facility: Baxter Healthcare Corporatiorf
Inspection Date: 09/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application ❑
Distribution and Marketing ■
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there 'any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Yes No NA NE
Page: 3

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Alkaline Stabilization (Class B) ❑
Compost ❑
Drying Beds ❑
Other ■
Comment:: Wood ash is stored in concrete basin and eventually mixed with dry fly -ash
and wood chips/sawdust prior to distribution.
Sampling
Describe sampling:
Grab samples are collected from the mixed ash pile and then composited for analysis. When acc,�ptable
results have been-reeeivitd the ash can be distributed.
eJ,�avred_
Is sampling adequate?
Is sampling representative?
Comment:
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Page: 4

Compliance Inspection Report
Permit: WQ0010689 Effective: 06/07/10 Expiration: 11/30/14 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Ernest Shepard Title: Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
Related Permits:
Inspection Date: 09/16/2011
Primary Inspector: Beverly Price
Secondary Inspector(s):
Ricky Styles
Ricky Styles
Entry Time: 01:30 PM
Exit Time: 03:30 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ❑ Compliant ❑ Not Compliant 1
Question Areas:
Miscellaneous Questions 0 Record Keeping Treatment
ab,
I r-I-S lvL�r Dd �v�p �j'2✓w�J�t"
rJ' �� 'S�-U0.C'•:�u�j v �
(See attachment summary`))
d6sl,a Ud
0 , d � rn=. �a
i�
Page: 1
r\A t � � �

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
ck4 Pet v, j 6"1,
cam/ ( /VL 4, �� / /" %�
19 PP4
Q (!k-
Page: 2

Permit: WO0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/16/2011 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes No
N,,,,A NE
Is GW monitoring being conducted, if required?
❑ ❑
N 0
Are GW samples from all MWs sampled for all required parameters?
❑ ❑
0 ❑
Are there any GW quality violations?
❑ ❑
CP ❑
Is GW-59A certification form completed for facility?
❑ ❑ '0 ❑
Is a copy of current permit on -site?
❑
❑
Are current metals and nutrient analysis available? ptVi.u•-t,A 9-blo Ariz-
❑
❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
W ❑
❑
a. TCLP analysis?
10 ❑
❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑ ❑
1 ❑
Are PAN balances being maintained?
❑ ❑
Are PAN balances within permit limits?
❑ ❑
IV
Has land application equipment been calibrated?
❑ ❑
IT ❑
Are there pH records for alkaline stabilization?
❑ ❑
17 ❑
Are there pH records for the land application site?
❑ ❑
Qr ❑
Are nutrient/crop removal practices in place?
❑ ❑
G
Do lab sheets support data reported on Residual Analysis Summary?
[W ❑
❑
Are hauling records available?
❑
❑ ❑
Are hauling records maintained and up-to-date?
❑
❑ ❑
# Has permittee been free of public complaints in last 12 months?
❑
❑ ❑
Has application occurred during Seasonal Restriction window?
❑ ❑
`Y ❑
Comment:
Treatment
Yes No
NA NE
Check all that apply
Aerobic Digestion
❑
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
❑
Compost
❑
Drying Beds
❑
Page: 3

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 09/16/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Other
Comment:
Page: 4

�`•. Central Files: APS_ SWP_
03/03/10
Permit Number WQ0010689 Permit Tracking Slip
Program Category Status Project Type
Non -discharge In review Minor modification ,
Permit Type Version Permit Classification
Distribution of Residual Solids (503 exempt) C Individual
Primary Reviewer
david.goodrich
Coastal SW Rule
Permitted Flow
Fa-cility
Permit Contact Affiliation
Summer Barber
1900 Post Oak Blvd
Houston TX 77056
Facility Name Major/Minor Region
North Cove Steam Generation Plant Ash Major Asheville
Distribution Program
Location Address County
2859 Old Linville Rd McDowell
Marion NC 28752 Facility Contact. Affiliation
Owner Name Owner Type
Suez Energy Biopow,er Inc Non -Government
Owner Affiliation
Ricky Styles
2859 Old Linville Rd
Marion NC 28752
Crates/Events
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
07/07/95 03/02/10
Regulated Activities Reauested/Received Events
Commercial or industrial, other RO staff report received
RO staff report requested
Outfall 1,IULL
Waterbody Name
Stream index Number
Current Class Subbasin

V
P
Baxter Healthcare Corporation
Route 120 and Wilson Road
Round Lake, Illinois 60073
847.546.6311
Baxter
February 25, 2010
Mr. Dave Goodrich
NC Department of.Health and Natural Resources
Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
RE:' j `Permit Number WQ0010689
Name/Ownership Change Request
Current Owner: Suez Energy Biopower, Inc.
New Owner: Baxter Healthcare Corporation
Mr. Goodrich:
RECEIVED /DENR /DWQ
AQUIFER •PRnTFCrj()N SECnON
MAR 02, Z0l
With regard to the request for change of ownership for the above referenced permit number, I
delegate the signing authority for the permit change request and permit liability to Ernest
Shepard, Plant Manager for the Baxter Healthcare Corporation North Cove facility located in
Marion, North Carolina.
Please contact Nanette M. Davis, Human Resources Director at 828-756-6532 if you need
further documentation regarding this permit transfer of ownership.
Sincerely,
Timothy P. Lawrence
Vice .President Medication Delivery Manufacturing
Baxter Healthcare Corporation

I,
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
PERMIT NAME/OWNERSHIP CHANGE FORM
Any changes made to this form will result in the application being returned.
(THIS FORMMAYBE PHOTOCOPIED FOR USE AS AN ORIGINAL)
For more information, visit our web site at. htip://h2o.ennstate.ne.us/latdrnaiti.htntl
1. Submit one original of the completed and appropriately executed Permit Name/Ownership Change Form.
For a change of ownership, the certification must be signed by both the current permit holder and the new
applicant. For a name change only, the certification must be signed by the applicant.
2. Provide legal documentation of the transfer of ownership (such as a contract, deed, article of incorporation,
etc.) for ownership changes.
3. Change of Ownership Applications for Homeowners Associations (HOAs) shall include the HOAs bylaws,
covenants, etc. [15A 2T A115(c)]
4. Submit a properly executed Operation and Maintenance Agreement for all Single Family Residence Surface
Irrigation permits requesting a change of ownership.
II. CURRENT PERMIT INFORMATION
1. Permit number: W00001512
2. Permit holder's name: Suez Energy Biopower, Inc.
3. Permit`s signing official's name and title: Jim Henslee
(Person legally responsible for permit)
Vice President, Commercial Industrial & Solid Fuel
(title)
4. Mailing address: 1990 Post Oak Blvd. Suite 1900
City: Houston State: TX Zip: 77056
Telephone number: (713) 636-10 i8 Facsimile number: [phone]
III. NEW OWNERINAME INFORMATION
1. This request for a permit change is a result of:
X a. Change in ownership of property/company
b. Name change only
c. Other (please explain):
2. New owner's name (name to be used in permit): Baxter Healthcare Corporation
FORM: PNOCF 09-06 . Page 1 of 2

3. New owner's or signing official's name and title: _ Ernest Shepard
(Person legally responsible for permit)
Plant Manager
(title)
4. Mailing address: 65 Pitt Station Road
City: Marion State: NC Zip: 28752
Telephone number: [phone] Facsimile number: [phone]
IV. CERTIFICATION
Current Permittee's Certification:
I, Jim Henslee , attest that this application for name/ownership change has
been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required
parts of this application are not completed and that if all required supporting information and attachments
are not included, thi pplication package will be returned as incomplete. I understand I will continue to be
responsible for co
,olpFance with the current pertryontil a new permit is issued.
Signature:
z z/id
2. Applicant's Certification:
1, 1rYr1f"A- 56feArA attest that this application for name/ownership change has been
reviewed and is accArate and complete to the best of my knowledge. I understand that if all required parts of
this application are not completed and that if all required supporting information and attachments are not
included, this application package will be returned as incomplete.. I finther certify that the applicant or any
affiliate has not been convicted of an environmental crime, has not abandoned a wastewater facility without
proper closure, does not have an outstanding civil penalty where all appeals have been exhausted or
abandoned, are compliant with any active compliance schedule, and do not have any overdue annual fees
under Rule 2T .0105
Signature: t Date:
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION AND
MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
LAND APPLICATION UNIT
Via U.S. Postal Service Via Courier / Special Delivery:
1636 MAIL SERVICE CENTER 2728 CAPITAL BOULEVARD
RALEIGH, NORTH CAROLINA 27699-1636 RALEIGH, NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone]
FORM: PNOCF 09-06 Page 2 of 2

BILL OF SALE
AND
ASSIGNMENT AND ASSUMPTION AGREEMENT
THIS BILL OF SALE AND ASSIGNMENT AND ASSUMPTION AGREEMENT (this
"Agreement") is made and entered into as of this 8a' day of January 2010, by and between Suez
Energy Biopower, Inc., a company organized and incorporated in the State of North Carolina,
with a principal office and place of business located at 1990 Post Oak Blvd., Suite 1900,
Houston, TX 77056-4499 (hereinafter "Seller") and Baxter Healthcare Corporation, a Delaware
corporation having offices at One Baxter Parkway, Deerfield, Illinois 60015, and a
manufacturing facility at North Cove, North Carolina (hereinafter "Buyer").
WHEREAS, Seller and Buyer are parties to that certain Asset Purchase Agreement of
even date herewith (the "Purchase Agreement"), pursuant to which Buyer has purchased certain
assets of Seller;
WHEREAS, the Asset Purchase Agreement provides for, among other things, the transfer
and sale to Buyer of certain assets of Seller, all as more fully described in the Purchase
Agreement, for consideration in the amount and upon the terms provided in the Purchase
Agreement;
WHEREAS, by this instrument Seller is vesting in Buyer all of the properties, assets and .
rights of Seller hereinafter described; and
WHEREAS, pursuant to the Purchase Agreement, Seller has further agreed to assign
certain rights and agreements to Buyer, and Buyer has agreed to assume certain obligations of
Seller, as set forth herein.
NOW, THEREFORE, for and in consideration of the premises and the mutual covenants
contained herein, and for other good and valuable consideration, the receipt, adequacy and legal
sufficiency of which are hereby acknowledged, the parties do hereby agree as follows:
1. Capitalized Terms. Capitalized terms used but not defined herein shall .have the
meanings for such terms that are set forth in the Purchase Agreement.
2. Bill of Sale. Seller does hereby convey, grant, bargain; sell, transfer, set over, assign,
remise, release, and confirm, effective as of I1:59 p.m. local time on January 8, 2010 (the
"Effective Time"), all of Seller's right, title and interest, of every nature and description,
in and to the Purchased Assets, wherever located. To have and to hold all of the
Purchased Assets unto Buyer, its successors and permitted assigns forever, to its and their
own use forever.
3. Assignment and Assumption. Seller does hereby assign, sell, transfer and set over
(collectively, the "Assignment") to Buyer, as of the Effective Time, all of Seller's right,
title, benefit, privileges and interest in and to, and all of Seller's burdens, obligations and
liabilities in connection with, each of the Assumed Liabilities. Buyer does hereby accept
the Assignment and assumes and agrees to observe and. perform all of the duties,
obligations, terms, provisions and covenants, and to pay and discharge all of the liabilities
258584_l

of Seller to be observed, performed, paid or discharged from and after the Closing, in
connection with the Assumed Liabilities. Buyer assumes no Excluded Liabilities, and the
parties hereto agree that all such Excluded Liabilities shall remain the sole responsibility
of Seller.
4. Successors and Assigns; No Third Party Beneficiaries. This Agreement is executed by
Seller and shall be binding upon it and its successors and assigns, for the uses and
purposes set forth above and referred to herein, effective immediately upon its delivery to
Buyer. Nothing in this instrument, express or implied, is intended or shall be construed
to confer upon, or give to, any Person (as defined in the Purchase Agreement) other than
Buyer and its successors and permitted assigns any remedy or claim under or by reason
of this Agreement or any terms, covenants or conditions hereof, and all the terms,
covenants and conditions, promises and agreements contained in this Agreement shall be
for the sole and exclusive benefit of Buyer and its successors and permitted assigns.
5. Purchase Agreement Conflict. In the event of any conflict or inconsistency between the
terms of the Purchase Agreement and the terms hereof, the terms of the Purchase
Agreement shall govern.
6. Further Actions. Each of the parties hereto covenants and agrees, at its own expense, to.
execute and deliver, at the request of the other party hereto, such further instruments of
transfer and assignment and to take such other action as such other party may reasonably
request to more effectively consummate the assignments and assumptions contemplated
by this Agreement.
7. Counterparts; Facsimile. This Agreement may be executed one or more original
counterparts, each of which shall be deemed an original, but both of which together shall
constitute one and the same instrument. One or more counterparts of this Agreement
may be delivered by facsimile, with the intention that delivery by such means shall have
the same effect as delivery of an original counterpart hereof.
Governing Law. This Agreement shall be construed and enforced in accordance with and
governed by the laws of the State of Delaware without regard to the conflicts of laws
provisions thereof.
[Signature Page Follows]
2585841

[Signature Page to Bill of Sale and Assignment and Assumption Agreement]
IN WITNESS WHEREOF, the Parties hereto have caused this Agreement to be executed
by their respective duly authorized officers as of the date first above written.
SUEZ ENERGY BIOPOWER, INC. BAXTER HEALTHCARE
CORPORATION
Y y By:
e.
itle: 1Z
Name:
Title:

[Signature Page to Bill of Sale and Assignment and Assumption Agreement]
IN WITNESS WHEREOF, the Parties hereto have caused this Agreement to be executed
by their respective duly authorized officers as of the date first above written.
SUEZ ENERGY BIOPOWER, INC. BAXTER HEALTHCARE
CORPORATION
By: By:
Name: ame: e M•
Title: Title: Cor or Y 1 l`�1chu��ur ihy

e
MCDE_ -
North Carolina Department of environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H, Sullins
Governor Director
March 3, 2010
Ernest Shepard
Baxter Heathcare Corporation
65 Pitt Station Road
Marion, NC 28752
Subject:. Acknowledgement of Application No. WQ0010689
North Cove Steam Generation Plant Ash Distribution Program
Distribution of Residual Solids (503 exempt)
McDowell
Dear Mr. Shepard:
Natural Resources
Dee Freeman
Secretary
The Aquifer Protection Section of the Division of Water Quality (Division) acknowledges receipt of your permit application and
supporting materials on March 2, 2010. This application package has been assigned the number listed above and will be reviewed by
David Goodrich.
The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To ensure the
maximum efficiency in processing permit applications, the Division requests your assistance in providing a timely and complete
response to any additional information requests.
Please be aware that the Division's Regional Office, copied below, must provide recommendations prior to final action by the
Division. Please also note at this time, processing permit applications can take as long as 60 - 90 days after receipt of a complete
application.
If you have any questions, please contact David Goodrich at 919-715-6162, or via e-mail at [e-mail]. If the
reviewer is unavailable, you may leave a message, and they will respond promptly. Also note that the Division has reorganized. To
review our new organizational chart, goto htti)://h2o.enr.state.nc.us/documents/dwq_orgchartpdf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerely, .
for Jon Risgaard
LAU Supervisor
CC'
AslieV111eoRegional'�Off ce AA'quifer-Pr-otection-Section
Permit Application File WQ0010689
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] FAX 1: 919-715-0588; FAX 2: 919-715-6048 l Customer Service: 1-877-623-6748
Internet: www.ncwaterouality.org
An Equal Opportunity \ Affirmative Action Employer
One
North Caron ina
NatmIraliff

y17 �1
AQUIFER PROTECTION SECT 6N
APPLICATION REVIEW REQUEST FORM MAR 0 4 ? `a
Date: March 3, 2010 s
To: X Landon Davidson, ARO-APS ❑ David May, WaRO APS -
❑ Art Barnhardt, FRO-APS ❑ Charlie Stehman, WiRO-APS
❑ Andrew Pitner, MRO-APS ❑ Sherri Knight, WSRO-APS
❑ Jay Zimmerman, RRO-APS
From: David Goodrich Land Application Unit
Telephone: [phone] Fax: [phone]
E Mail: david.goodricbgncdenr.gov
A. Permit Number: W00010689
B. Owner: Suez Energy Biopower, Inc. transferring to Baxter Healthcare Corporation
C. Facility/Operation: North Cove Steam Generation Plan Ash Distribution Program (503 exempt)
❑ Proposed X Existing X Facility X Operation
D. Application•
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
❑ UIC - (5A7) open loop geothermal
For Residuals: ❑Land App. X D&M ❑ Surface Disposal
❑ 503 X 503 Exempt ❑Animal .
2. Project Type: L1 New ❑ Major Mod. X Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Statutory Date: 05/31 /2010 - Ownership Change Only
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
X Return a Completed APSARR Form. - Please comment as appropriate
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO. *
* Remember that you will be responsible for coordinating site visits and reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional dpJail.
When you receive this reg
of this sheet, and r it to
listed above. 1
nd dates in the spaces below, make a copy
Aquifer Protection Section contact person
Date:
FORM: APSARR 07/06 Page 1• of 1

To: Aquifer Protection Section Central Office
Attn: David Goodrich
From: Ed Williams
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 4/22/2010
b. Site visit conducted by: Ed Williams
c. Inspection report attached? ® Yes or ❑ No
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Aquifer Protection Section
Regional Staff Report
Application No.: WQ0001512
Regional Login No.:
d. Person contacted: Ricky S les and their contact information: (828) 756 - 4946 ext.
e. Driving directions: Hwy 221 North out of Marion to NCSR 1560 (located behind Baxter Health Care,)
H. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
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:
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)
FORM: APSRSR 04-10 Pagel of 3

III. EXISTING FACILITIES FOR iviuDIFICATION AND RENEWAL APPLiLuATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes or ® No
ORC: Certificate #: Backup ORC: Certificate #:
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:
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No N/A
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 N/A
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.
9. Is the description of the facilities as written in the existing 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:
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No Z N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
0 , II
0 , 11
0 , „
0 ,
0 „
0 ,
0 / 11
0 1 11
0 , „
0
12. Has a review of all self -monitoring data been conducted (e.g., NDMR, NDAR, GW)? ❑ Yes or ® No
Please summarize any findings resulting from this review:
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 ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
FORM: APSRSR 04-10 Page 2 of 3

IV. REGIONAL OFFICE RECO1IL.—NDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like APS Central Office to obtain through an additional information request:
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 issued:
Condition Reason
5. Recommendation:
6
❑ 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
❑D
Signature of report preparer:
Signature of APS regional sul
Date: !�-1- ?"byz>
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: APSRSR 04-10 Page 3 of 3

Compliance Inspection Report
Permit: W00001512 Effective: 07/31/08 Expiration: 01/31/16 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant
County: McDowell 302 Duke St
Region: Asheville
Forest City NC 28043
Contact Person: Summer Barber Title: Phone: [phone]
Directions to Facility:
Follow Hwy. 221 north from Marion to NCSR 1573 (Pitts Station Rd.), turn right. At intersection of Pitts Station Rd. & NCSR 1560 (Old
Linville Rd.), turn left. Facility is approximately 0.25 mi. on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Ricky Styles
Related Permits:
Inspection Date: 04/22/2010 Entry Time: 10:00 AM
Primary Inspector: Edward M Williams
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Recycling
Facility Status: ■ Compliant Q Not Compliant
Question Areas:
N Miscellaneous Questions E Record Keeping
(See attachment summary)
Exit Time: 11:00 AM
Phone: [phone]
Phone:
Inspection Type: Compliance Evaluation
0 End Use -Reuse
Page: 1

Permit: WQ0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/22/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The recycle facility appeared to be well maintained and records were in good order.
Page: 2

Permit: WQ0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/22/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes. No NA NE
Infiltration System
❑
Lagoon Spray, LR
❑
Reuse (Quality)
❑
Activated Sludge Spray, LR
❑
Single family Spray, LR _
❑
Activated Sludge Spray, HR
❑
Activated Sludge Drip, LR
❑
Single Family Drip
❑ .
Recycle/Reuse
Record Keeping
Is a copy of current permit available?
Are monitoring reports present: NDMR?
NDAR?
Are flow rates less than of permitted flow?
Are flow rates less than of permitted flow?
Are application rates adhered to?
Is GW monitoring being conducted, if required (GW-59s submitted)?
Are all samples analyzed for all required parameters?
Are there any 2L GW quality violations?
Is GW 59A certification form completed for facility?
Is effluent sampled for same parameters as GW?
Do effluent concentrations exceed GW standards?
Are annual soil reports available?
# Are PAN records required?
# Did last soil report indicate a need for lime?
If so, has it been applied?
Are operational logs present?
Are lab sheets available for review?
Do lab sheets support data reported on NDMR?
■
Page: 3

Permit: WQ0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/22/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Do lab sheets support data reported on GW-59s?
❑
❑ ■
❑
Are Operational and Maintenance records present?
■
❑ ❑
❑
Were Operational and Maintenance records complete?
■
❑ ❑
❑
Has permittee been free of public complaints in last 12 months?
■
❑ ❑
❑
Is a copy of the SOC readily available?
❑
❑ ■
Q
No treatment units bypassed since last inspection?
■
❑ ❑
❑
Comment:
End Use -Reuse
Yes
No NA
NE
Is the acreage in the permit being utilized?
❑
❑ ■
❑
Does the acreage specified in the permit correspond to the measured acreage at the site?
❑
❑ ■
❑
Are all essential units provided in duplicate?
❑
❑ ■
❑
Is an automatically activated standby power source available?
❑
❑ ■
❑
Is the equalization capacity adequate?
❑
❑ ■
❑
Is aerated flow equalization present?
❑
❑ ■
❑
Has the turbidity meter been calibrated in the last 12 months?
❑
❑ ■
❑
Does the turbidity meter have recording capabilities?
❑
❑ ■
❑
Is all flow diverted at the appropriate times?
❑
❑ ■
❑
Is all upset wastewater diverted from reuse storage unit?
❑
❑ ■
❑
Is all upset wastewater treated, retreated, or disposed of acceptably?
❑
❑ ■
❑
Is upset wastewater treated prior to discharge to irrigation storage?
❑
Cl ■
❑
Is public access restricted from irrigation area during active site use?
❑
❑ ■
❑
If golf course, is a sign posted in plain sight on the club house?
❑
❑ ■
❑
Is the cover crop acceptable?
❑
❑ ■
❑
Are buffers adequate?
❑
❑ ■
❑
Is the site free of ponding/runoff?
❑
❑ ■
❑
Is the acreage in the permit being utilized?
❑
Cl ■
0
Is the application equipment acceptable?
❑
❑ ■
❑
Is the application area free of limiting slopes?
❑
❑ ■
❑
How close is the closest water supply well?
❑
❑ ■
❑
Are any supply wells within the CB?
❑
❑ ■
❑
Page: 4

Permit: WO0001512 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/22/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Are any supply wells within 250' of the CB?
❑
❑
■ ❑
Is municipal water available in the area?
❑
❑
■ ❑
Are GW monitoring wells required?
❑
❑
■ ❑
Are GW monitoring wells located properly w/ respect to RB and CB?
❑
❑
■ ❑
Are GW monitoring wells properly constructed, including screened interval?
❑
❑
■ ❑
Comment:
Page: 5

To: Aquifer Protection Section Central Office
Attn: David Goodrich
From:, Ed Williams ,
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? Z Yes or ❑ No
a. Date of site visit: 4/22/2010.
b. Site visit conducted by: Ed Williams
c. Inspection report attached? ® Yes or ❑ No
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Aquifer Protection Section
Regional Staff Report
Application No.: M0010689
Regional Login No.:
d. Person contacted: RickySjyles and their contact information: (828) 756 - 4946 ext.
e. Driving directions: Hwy 221 North out of Marion to NCSR 1560 (located behind Baxter Health Care)
H. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
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:
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)
FORM: APSRSR04-10 Pagel U3

M. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes or ® No
ORC: Certificate #: Backup ORC: Certificate #:
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:
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No N/A
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 N/A
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.
9. Is the description of the facilities as written in the existing 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:
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
0 , 11
0 II
0 , //
0 , It
0
0
0
0 ,
0
0 ,
12. Has a review of all self -monitoring data been conducted (e.g., NDMF, NDAR, GW)? ❑ Yes or ® No
Please summarize any findings resulting from this review:
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 ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
If yes, please explain:
FORM: APSRSR 04-10 Page 2 of 3

V. REGIONAL OFFICE RECOT.—._ENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List anv items that you would like APS Central Office to Atnin thrn„ah nn nr1r1;t;nna1;nfnrmn4;nn ran-4-
Item Reason
3. List specific permit conditions recommended to be removed from the permit when issued:
4.
Condition Reason
List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
5. Recommendation: U 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
6. Signature of report preparer
Signature of APS regional s
„o
Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: APSRSR 04-10 Page 3 of 3

Compliance Inspection Report
Permit: WQ0010689 Effective: 11/29/06 Expiration: 11/30/13 Owner: Baxter Healthcare Corporation
SOC: Effective: Expiration:. Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Ricky Styles Title: Phone: [phone]
Directions to Facility:
Take NC Hwy.'221 North out of Marion to NCSR 1560 ( located behind Baxter- North Cove). The facility is located on the left.
-System Classifications: -
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/22/2010 Entry Time: 10:00 AM Exit Time: 11:00 AM
Primary Inspector: Edward M Williams Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions N Record Keeping Treatment Sampling
(See attachment summary)
Page: 1

Permit: WO0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/22/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility appeared to be well maintained and records were in order. A thorough review of the annaual report will follow
this inspection.
Freeboard - 28"
Page: 2

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date:.04/22/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application ❑
Distribution and Marketing ❑
Record Keeping
Yes
No NA NE
Is GW monitoring being conducted, if required?
❑
❑ ■ ❑
Are GW samples from all MWs sampled for all required_ parameters?
❑
❑ ■ ❑
Are there any GW quality violations?
❑
❑ ■ ❑
Is GW 59A certification form completed for facility?
❑
❑ ■ ❑
Is a copy of current permit on -site?
■
❑ ❑ ❑
Are current metals and nutrient analysis available?
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
■
❑ ❑ ❑
a. TCLP analysis?
■
❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
■
❑ ❑ ❑
Are PAN balances being maintained?
❑
❑ ■ ❑
Are PAN balances within permit limits?
❑
❑ ■ ❑
Has land, application equipment been calibrated?
❑
❑ ■ ❑
Are there pH records for alkaline stabilization?
❑
❑ ■ ❑
Are there pH records for the land application site?
❑
❑ ■ ❑
Are nutrienticrop removal practices in place?
❑
❑ ■ ❑
Do lab sheets support data reported on Residual Analysis Summary?
■
❑ ❑ ❑
Are hauling records available?
■
❑ ❑ ❑
Are hauling records maintained and up-to-date?
■
❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
■
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑
❑ ■ ❑
Comment:
Treatment
Yes
No NA NE
Check all that apply
Aerobic Digestion ❑
Anaerobic Digestion ❑
Alkaline Pasteurization (Class A) ❑
Page: 3

Permit: WQ0010689 Owner - Facility: Baxter Healthcare Corporation
Inspection Date: 04/22/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Alkaline Stabilization (Class B) ❑
Compost ■
Drying Beds ❑
Other ❑
Comment:
Sampling Yes No NA NE
Describe sampling:
Storage pond is de -watered. Fine wood fill is added then pile is mixed. Grab samples are collected around
the pile, then composited in a plastic bag. Iced then shipped to Pace.
Is sampling adequate?
Is sampling representative?
Comment:
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Page: 4

April 20, 2009
VIA FEDERAL EXPRESS # 7965 3246 2769
Bev Price
North Carolina Division of Water Quality
Aquifer Protection Section
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
RE: Delegation of Responsible Official and Technical Contact
SUEZ Energy BioPower, Inc. — North Cove
Ash Distribution Permit No. WQ0010689
Wastewater Recycle System Permit No. WQ0001512
APR 21 2C'9
Asheville Regional Office
As an officer of SUEZ Energy BioPower, Inc., I am removing Tony Leopard as the responsible
official and technical contact for the North Cove facility as of April 21, 2009. 1 hereby delegate the
authority of responsible official to Ricky Styles, the plant superintendent. While Mr. Styles is not an
officer of SUEZ Energy BioPower, Inc., he is responsible for the oversight of plant operations,
including all aspects of operation of the business, maintenance, and business administration
functions of the North Cove facility. Ricky's contact information is 2859 Old Linville Road,
Marion, NC 28752 and [phone].
Also, I delegate Summer Barber as the technical contact for the facility. If you have any questions
regarding technical issues please contact her at [phone]. Her physical address is 1990 Post
Oak Blvd., Suite 1900, Houston, TX 77056.
If you have any questions, please call me at [phone].
Sincerely,
Jim Henslee
Vice President, Commercial Industrial & Solid Fuel
GDF SUEZ Energy Generation NA, Inc.
1990 Post Oak Blvd., Suite 1900
Houston, TX 77056
tel. [phone]
fax [phone]
cell [phone]
email: [e-mail]
www.gdfsuezna.com
1

April24, 2009
Division of Water Quality
Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
Subject: Permitting Signature Authority
To Whom It May Concern:
As an appropriate signing official for SUEZ Energy BioPower, Inc. - North Cove
(city/town or business name) as designated by 15A NCAC 2T .0106(c), I hereby delegate authority to sign
and certify all permit applications, reports or other permit related documents to the following staff for the
following permit types (sewer, spray, land application) and/or permit numbers:
Position
Person Currently in Position
Permit Type or Permit Number
Plant Superintendent
Ricky Styles
Ash Distribution
Permit No. WQ0010689
Plant Superintendent
Ricky Styles
Wastewater Recycle System
Permit No. WQ0001512
If you have any questions, please contact me at the following:
Permiee/Applicant name (please print): Jim Henslee
Title: Vice President Commercial Industrial & Solid Fuel
Complete mailing address: 1990 Post Oak Blvd., Suite 1900
City: Houston State: TX Zip: 77056
Telephone number: (_713_) 636-1018 Facsimile number: (_713__) 636-1602
Sincerely,
-a,,;
tn ure
RECEIVED I DENR I DWQ
Aquifer Protection Section
APR 2 8 2009

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Depaurient of Environment and Natural Resources
pp CO
Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION
November 5, 2008
Tony Leopard
Regional Plant Manager
Suez Energy Biopower, Inc.
302 Duke St
Forest City, NC 28043
SUBJECT: October 29, 2008 Compliance
Evaluation Inspection
Suez Energy Biopower, Inc.
North Cove Steam Generation Plant
Wastewater Recycle System
Permit No: WQ0001512
Ash Ditribution Program
Permit No: WQ0010689
McDowell County
Dear Mr. Leopard:
Enclosed please find a copy of the Compliance Evaluation Inspection form from.the inspection
that I conducted on October 29, 2008. The facility was found to be in Compliance with permit
WQ0001512 and WQ0010689.
Your assistance and that of Ms. Summer Barber and Ricky Styles was greatly appreciated.
Please refer to the enclosed inspection reports for additional observations and comments. If you or
your staff has any questions, please call me at [phone].
Sincerely,
Beverly Ar1'C
Environmental Specialist
Enclosure
cc: Ricky Styles, Plant Superintendent (North Cove) Suez Energy Biopower, Inc. 2859 Old Linville
Road Marion NC 28752
APS Central Files
vi' le es
Noe Carolina
Niura(!y
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoi, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

Compliance Inspection Report
Permit: WQ0001512 Effective: 07/31/08 Expiration: 01/31/13
Owner: Suez Energy Biopower Inc
SOC: Effective: Expiration:
Facility: North Cove Steam Generation Plant
County: McDowell
302 Duke St
Region: Asheville ...... • .................:. .
Forest City NC 28043
Contact Person: Tony Leopard Title: Regional Plant Manager Phone: [phone]
Directions to Facility:
Follow Hwy. 221 north from Marion to NCSR 1573 (Pitts Station Rd.), turn right. At intersection of Pitts Station Rd. & NCSR 1560 (Old
Linville R�.), turn left. Facility is approximately 0.25 mi. on the left.
System lassifications:.
Primary ORC: Certification:
Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Tony Leopard
Phone:[phone]
On -site representative Summer Barber
Phone: [phone]
On -site representative Tony Leopard
Phone: [phone]
On -site representative Ricky Styles
Phone: [phone]
Related Permits:
Inspection Date: 10/29/2008
Primary Inspector: Beverly Price
Secondary Inspector(s):
Entry Time: 08:30 AM Exit Time: 09:30 AM
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Recycling
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions 0 Treatment
(See attachment summary)
Phone: [phone]
Inspection Type: Compliance Evaluation
0 Record Keeping
Page: 1

Permit: WQ0001512 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/29/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility is .well maintained and appears to be operating according to permit conditions.
Page: 2

Permit: WQ0001512 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/29/2008 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes
No
NA
NE
Lagoon Spray, LR
❑
_............. ....... ... - ... ...... ..... —
Single Family Spray, LR
❑
Reuse (Quality)
❑
Infiltration System
❑
Activated Sludge Drip, LR
❑
Activated Sludge Spray, HR
❑
Activated Sludge Spray, LR
❑
Single Family Drip
Recycle/Reuse
■
Treatment
Yes
No
NA
NE
Are Treatment facilities consistent with those outlined in the current permit?
■
❑
Cl
❑
Do all treatment units appear to be operational? (if no, note below.)
■
❑
❑
❑
Comment:
Record Keeping `
Yes
No
NA
NE
Is a copy of current permit available?
■
❑
❑
❑
Are monitoring reports present: NDMR?
❑
.❑
■
❑
NDAR?
❑❑■❑
Are flow rates less than of permitted flow?
❑
❑
■
❑
Are flow rates less than of permitted flow?
❑
❑
■
❑
Are application rates adhered to?
❑
❑
■
❑
i
Is GW monitoring being conducted, if required (GW-59s submitted)?
❑
❑
■
❑
Are all samples analyzed for all required parameters?
❑
❑
■
❑
Are there any 2L GW quality violations?
❑
❑
■
❑
Is GW-59A certification form completed for facility?
❑
❑
■
Cl
Is effluent sampled for same parameters as GW?
❑
❑
■
Cl
Do effluent concentrations exceed GW standards?
❑
Cl
■
❑
Are annual soil reports available? ❑ ❑ ■ ❑
# Are PAN records required? ❑ ❑ ■
# Did last soil report indicate a need for lime? ❑ ❑ ■ ❑
Page: 3

Permit: WQ0001512 Owner • Facility: Suez Energy Biopower Inc
Inspection Date: 10/29/2008 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
If so, has it been applied?
Cl
❑
■
❑
Are operational.logs present? ------ -... ._ _.....-..-- :: ._. _-........
■.
❑
❑
.❑ ._...
Are lab sheets available for review?
❑
❑
■
❑
Do lab sheets support data reported on NDMR?
❑
❑
■
❑
Do lab sheets support data reported on GW-59s?
❑
❑
■
❑
Are Operational and Maintenance records present?
0
❑
❑
❑
Were Operational and Maintenance records complete?
■
❑
❑
❑
Has permittee been free of public complaints in last 12 months?
■
❑
Cl
❑
Is a copy of the SOC readily available?
❑
❑
■ -
❑
No treatment units bypassed since last inspection?
■
❑
❑
❑
Comment:
Page: 4

Compliance Inspection Report
Permit: WQ0010689 Effective: 11/29/06 Expiration: 11/30/10 Owner: Suez Energy Biopower Inc
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville .. _...:...
Marion NC 28752
Contact Person: Tony Leopard Title: Regional Plant Manager Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 ( located behind Baxter- North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
On -site representative
Related Permits:
Inspection Date: 10/29/2008
Primary Inspector: Beverly Price
Secondary Inspector(s):
Tony Leopard
Tony. Leopard
Ricky Styles
Summer Barber
Entry Time: 08:30 AM Exit Time: 10:30 AM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling
(See attachment summary)
Page: 1

Permit: vvQ001068e Owner ' Facility: Suez Energy ompone Inc
`
Inspection Date: 10m9/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection �
The inspection consisted ofarecords review, tour of the facilities and site visit toanearby distribution field.
_ ------ ___
Reuordonppearedbobeoompleteandocounate. .
The freeboard inthe ash basin was 28inches. The South Basin iafull and hyscheduled b/becleaned out.
'

Permit: WQ0010689 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10129/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application ❑
Distribution and Marketing ■
Record Keeping
Yes No
NA
NE
Is GW monitoring being conducted, if required?
❑ ❑
■
❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑
■
❑
Are there any GW quality violations?
❑ ❑
■
❑
Is GW-59A certification form completed for facility?
❑ ❑
■
❑
Is a copy of current permit on -site?
■ ❑
❑
❑
Are current metals and nutrient analysis available?
■ ❑
❑
❑
Are nutrient and metal loading calculating most limiting parameters?
■ .❑
❑
❑
a. TCLP analysis?
■ .❑
❑
❑
b. SSFA (Standard Soil Fertility Analysis)?
❑ ❑
E
❑
Are PAN balances being maintained?
❑ ❑
■
❑
Are PAN balances within permit limits?
❑ ❑
■
❑
Has land application equipment been calibrated?
❑ ❑
■
'
Are there pH records for alkaline stabilization?
❑ ❑
■
❑
Are there pH records for the land application site?
❑
■
❑
Are nutrient/crdp.removal practices in place?
J ❑ ❑
■
❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑
❑
■
Are hauling records available?'
■ ❑
❑
❑
Are hauling records maintained and up-to-date?
■ ❑
❑
❑
# Has permittee been free of public complaints in last 12 months?
■ ❑
❑
❑
Has application occurred during Seasonal Restriction window?
❑ ❑
■
❑
Comment:
Sampling Yes No NA NE
Describe sampling:
10 grabs are collected at different locations and depths in the pile. Samples are mixed and then composited.
Is sampling adequate?
Is sampling representative?
Comment:
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Page: 3

Compliance Inspection Report
Permit: WO0010689 Effective: 11/29/06
Expiration: 11/30/10 Owner: Suez Energy Biopower Inc
SOC: Effective:
Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell
2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Tony Leopard
Title: Regional Plant Manager Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 (i.e., located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC:
Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Tony Leopard
Phone: [phone]
Related Permits:
Inspection Date: 10/29/2008 Entry Time: 08:30 AM Exit Time: 10:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: �Compliant Q Not Compliant
Question Areas:
Miscellaneous Questions 0 Record Keeping Sampling
(See attachment summary)
r� S° � J asf< /� � /Jec� c -
Page: 1

Permit: WQ0010689 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/29/2008 Inspection Type: Compliance Evaluation
Inspection Summary:
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Reason for Visit:
i
�C01 r �s VA}-1
to
J Yes No NA NE
n n 0 n
5 nnr0n
Are there any GW quality violations?
14
n n q n
Is GW-59A certification form completed for facility?
yV ` �\�q
�ptt'��M� `
n n [R n
Is a copy of current permit on -site?
n,� r�
J9 n n n
Are current metals and nutrient analysis available? j' ',y�� 1 1 n n n
� 1
1�2AId�Il^I� ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
"j23�°�
a. TCLP analysis? 'ItO�
5��
0,n n
ems
b. SSFA (Standard Soil Fertility Analysis)?
n n x ❑
n n n
190
A5, ro�J�
Are PAN balances being maintained?
q- —
Are PAN balances within permit limits?
n n ❑
1�lb/ tiP
Has land application equipment been calibrated?
❑ ❑ ❑
Are there pH records for alkaline stabilization?
❑ ❑ n
Are there pH records for the land application site?
n n q n
Are nutrient/crop removal practices in place? •
❑ n
�
Do lab sheets support data reported on Residual Analysis Summary? °W �Vl -�,�'��` ®'� �� AA, , rl n n
Are hauling records available? (An n n
Are hauling records maintained and up-to-date? T n ❑ ❑
# Has permittee been free of public complaints in last 12 months? JO n n n
Has application occurred during Seasonal Restriction window?
Comment:
Sampling
Describe sampling: /® retby
Is sampling adequate?
Is sampling representative?
Comment:
C' o `11a G't �Q
COS&pSt�-td' lvJ'l_"t
nnrP1n
i //
%®C�Jo-�S d S a-L /0e11�1_
Page: 2

Energy Generation NA
Marion, North Carolina
Ash Distribution Program Information Sheet
SUEZ Energy BioPower, Inc. (BioPower), 2859 Old Linville Road, Marion, NC 28752 is the generator of
the ash provided, to (Recipient). Application of the
aforementioned ash is prohibited .except in accordance with the instructions on this sheet.
Trdnsport: Adequate provisions shall be taken to ensure that the transportation of ash does not cause
nuisances and hazards to public health and safety or otherwise cause an adverse impact (e.g., transport
wet ash in leak -proof trucks or cover dry ash).
Storage: The ash shall be adequately stored to prevent wind erosion or surface runoff from carrying ash
into any surface waters. Keeping the ash slightly moistened will accomplish this objective under normal
conditions. However, berms, barriers, or tarps, may be necessary under windy or rainy conditions or if
erosion or runoff cannot be controlled. -
Application: When using ash, the following shall apply:
• , The ash application rates shall be limited -to those that can be agronomically justified (i.e., limited to
that needed to meet the liming requirements of the crops being grown on the land).
• Ash shall not be placed within 50 feet of any surface water.
• Ash shall not be placed within one foot of the seasonal high water table.
• Ash shall not be placed within 100 feet of any water supply well or spring unless underlain and
overlain by a liner with a maximum hydraulic conductivity of 10-6 centimeters per second. If such a
liner/cover is provided, ash shall not be placed within 25.feet of any water supply well or spring.
• The ash shall not be applied to any site that is,flooded, frozen, or snow-covered.
A summary of the ash chemical analyses is located on page 2 of the information sheet. Detailed
laboratory results are available upon request.
Title to the ash will transfer from BioPower to Recipient upon delivery thereof. Thereafter, BioPower
will have no responsibility and shall not be held liable by Recipient or any third party for any spill,
misuse, misapplication or other mishandling of the ash. - Recipient acknowledges and agrees that the ash
is being delivered by BioPower to Recipient as an accommodation to Recipient. In exchange therefore,
Recipient agrees to indemnify, save and hold BioPower harmless from and against any and all liability,
damage, loss, cost, expense (including attorneys' fees), claim, demand, suit, action, judgment .or recovery
asserted against BioPower by any third party, including any governmental authority, whether for bodily
injury (including death) or damage to property, arising from or in connection with Recipient's receipt,
transportation, handling or other use, of the ash.
Signed (Ash Recipient): Date:
Ash Recipient's Address:
Intended Use of Ash:
Expected Qty/Yr: Acres of Land:
Page 1:,of 2
Updated: 1 /31 /07

.S**�e z
Energy Generation NA
November 9, 2007
VIA FEDERAL EXPRESS # 792597998240
Landon Davidson
Regional Supervisor
North Carolina Division of Water Quality
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
RE: Notice of Violation — Permit Condition III (3)
SUEZ Energy BioPower, Inc. — North Cove
Marion, North Carolina
McDowell County
Permit No.: WQ0010689
Distribution of Residual Solids (503 Exempt)
Ash Distribution Permit
Dear Mr. Davidson,
D
Cn
�D
CR
®
�'
/0
This letter is in response to the Notice of Violation (NOV) that was issued on November
1, 2007 and received by SUEZ Energy BioPower`s Marion facility on November 6, 2007.
The NOV was issued for failure to conduct the annual ignitability and corrosivity
analyses in 2006 as stipulated in Permit No. WQ0010689, condition 111 (3). Included in
the violation letter was a compliance issue for no analyses of ash distributed in September
of 2006. Also, the inspection summary indicated that the reactivity was not performed in
2006 and that the monthly average arsenic concentration exceeded the permitted
maximum in May 2007. The monthly average arsenic concentration was calculated to be
51 mg/kg, and the allowed amount is 41 mg/kg. In addition, we were issued a civil
penalty of $832.95 for distributing ash with arsenic levels above the permitted limit.
SUEZ regrets the violations and wants to ensure compliance in the future. The company
was going through personnel changes at this time and had just lost our environmental
engineer. The company has made the following changes to prevent future violations:
1. The new environmental representative will conduct quarterly audits of testing and
recordkeeping for compliance with the permit.
2. We have developed an ash distribution approval form which must be reviewed
and signed by the environmental representative and the Plant Manager before ash
distribution. The form includes a checklist for all permit parameters.

SNIIUO�-' Z
Energy Generation NA
3. A training program is being developed to ensure the understanding of the permit
conditions with the plant superintendent.
4. The ash management procedure is being reviewed and updated as necessary to
ensure compliance with the permit.
These enhancements have resulted in significantly improved monitoring and
recordkeeping quality. We will continue to closely monitor our ash distribution program
and update our procedures as necessary to ensure compliance with the permit in the
future.
If you have any questions or comments, please contact Summer Barber at [phone]
or me at [phone].
Sincerely,
li+'
Tony Leopard
Plant Manager
SUEZ Energy Generation NA, Inc.
SUEZ Energy BioPower
302 Duke Street
Forest City, NC, 28043
Tel. [phone] - fax [phone]
Email — tony.leopardgsuezengMa.com
www.suezenergyna.com
cc: Jim Henslee--- SEGNA Houston
Carl Carlsson--SEGNA Houston
Ricky Styles
Tom Pannell
Summer Barber
Melinda Allen -File

FOIL Ei COPY
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION
November 1, 2007
CERTIFIED MAIL 7006 2150 0005 2458 8528
RETURN RECEIPT REQUESTED
Tony Leopard
Regional Plant Manager
Suez Energy Biopower, Inc.
302 Duke St.
Forest City, NC 28043
Subject: NOTICE OF VIOLATION
NOV-2007-PC-0734
Compliance Evaluation Inspection
North Cove Steam Generation Plant
Ash Distribution Program
Permit No. WQ0010689
McDowell County
Dear Mr. Leopard:
Enclosed please find a copy of the Inspection Report from the inspection conducted 2007-10-25.
Beverly Price of the Asheville Regional Office conducted the Compliance Evaluation Inspection. The
facility was found to be in violation of Permit WQ0010689 for the following:
Review of the 2006 Annual Report revealed the following violations:
Parameter
Date
Measuring
Violation
Frequency
Ignitability & Corrosivity
2006
Annual
Analyses not conducted
-
in 2006.
NorthCarolina
�atura«y
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

Mr..Leopard
October 31, 2007
Page 2
Other compliance issues found during the inspection are:
Inspection Area
Compliance Issue
Record Keeping
SOP/Permit requires analysis of prepared material before it is
distributed. There was no analysis of ash distributed in
September 2006.
Please refer to the enclosed Inspection Report for any additional observation and comments.
To prevent further action, carefully review these violations and deficiencies and respond in writing to
this office within fifteen (15) working days of receipt of this letter. You should address the causes of
noncompliance and all actions taken to prevent the recurrence of similar situations. If you should
have any questions, please do not hesitate to contact Beverly Price at 828/296-4500.
Sincerely,
Landon Davidson, L.G.:, Regional Supervisor
Aquifer Protection
Attachment
cc: Ricky Styles Plant Superintendent w/ attachment
APS Central Files w/ attachment
APS Enforcement Files w/ attachment
ARO APS Files

Compliance Inspection Report
Permit: WQ0010689 Effective: 11/29/06 Expiration: 11/30/10 Owner: Suez Energy Biopower Inc
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Tony Leopard Title: Regional Plant Manager Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 (i.e., located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
On -site representative
Related Permits:
Inspection Date: 10/25/2007
Primary Inspector: Beverly Price
Secondary Inspector(s):
Ricky Styles
Summer Barber
Tony Leopard
Entry Time: 10:00 AM Exit Time: 12:00 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: [1 Compliant ® Not Compliant
Question Areas:
® Miscellaneous Questions 0 Record Keeping ® Sampling
(See attachment summary)
Page: 1

Permit: WQ0010689 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/25/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection consisted of a reivew of the current nutrient/metals data as well as a review of the 2006 Annual Report.
2006 Annual Report Issues: The Ignitability and Reactivity analyses were missing. The SOP requires the ash to be
sampled before each distribution event. Although 4 samples were collected which satisfies the permit requirement based
on Dry Tons distributed, a sample was not collected prior to distribution in September 2006.
2007 Sampling Data: Two samples were collected 5/11/07. The Arsenic levels were 71mg/kg and 31 mg/kg. Although
the Ceiling Concentration Limits were not exceeded, the Monthly Average Concentration was exceeded. The Monthly
Average Concentration Limit for Ash distribution for Arsenic is 41 mg/kg. The Monthly Average Concentration Limit as
calculated was 51 mg/kg.
An Notice of Violation/Civil Penalty will follow for the above referenced issues.
Page: 2

Permit: WO0010689 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/25/2007 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes
No
NA
NE
Land Application
❑
Distribution and Marketing
■
Record Keeping
Yes
No
NA
NE
Is GW monitoring being conducted, if required?
❑
❑
■
❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑
■
❑
Are there any GW quality violations?
❑
❑
■
Cl
Is GW-59A certification form completed for facility?
❑
❑
■
❑
Is a copy of current permit on -site?
■
❑
❑
❑
Are current metals and nutrient analysis available?
■
❑
❑
❑
Are nutrient and metal loading calculating most limiting parameters?
■
❑
❑
❑
a. TCLP analysis?
■
❑
❑
❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑
■
❑
Are PAN balances being maintained?
❑
❑
■
❑
Are PAN balances within permit limits?
❑
❑
■
❑
Has land application equipment been calibrated?
❑
❑
■
❑
Are there pH records for alkaline stabilization?
❑
❑
■
❑
Are there pH records for the land application site?
❑
[1,
■
❑
Are nutrient/crop removal practices in place?
❑
❑
■
❑
Do lab sheets support data reported on Residua(Analysis Summary?
❑
❑
❑
■
Are hauling records available?
■
❑
❑
Cl
Are hauling records maintained and up-to-date?
■
❑
❑
❑
# Has permittee been free of public complaints in last 12 months?
.■
❑
❑
❑
Has, application occurred during Seasonal Restriction window?
❑
❑
■
❑
Comment:
Sampling
Yes
No
NA
NE
Describe sampling:
Approximately every five feet of the pile, a grab sample is collected. The grabs are then composited. A
second sample is also collected from the same pile. The samples are collected in a plastic bucket.
Is sampling adequate?
■
❑
❑'
❑
Is sampling representative?
■
❑
❑
❑
Page: 3

Permit: WQ0010689 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/25/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: It is recommended that a soils probe be used to collect the individual grabs
to allow for greater depth of sampling or dividing the pile into halves or thirds and then
collecting the individual grab samples.
Page: 4

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
R C WED
November 15, 2007
NOV 2 12007
Tony Leopard, Regional Plant Manager
SUEZ Energy Biopower, Inc. Asheville Regional O
302 Duke Street _- ,siarrttiral
Forest City, NC 28043
SUBJECT: Acknowledgment of Receipt of Payment
Case No. PC-2007-0085
Distribution of Residual Solids (503 exempt) Ash Distribution Program
Permit No. WQ0010689
McDowell County
Dear Mr. Leopard:
This letter is to acknowledge receipt of your check No. 451 in the amount of $832.95 on
November 15, 2007. This payment satisfies in full the civil assessment levied against the subject
facility and this case has been closed. Payment of this penalty does not preclude further action by
this Division for additional violations of the applicable Statutes, Regulations, or Permits.
If you have any questions, please call me at [phone].
Sincerely,
E. D. Hardee
Aquifer Protection Section
cc: Asheville Region -Aquifer Protection=Regional Supervissr
File # PC-2007-0085
APS Central Files
NortltCarolina
Naturally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone: [phone]
Internet: www.ncwaterguality.00r Location: 2728 Capital Boulevard Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper Customer Service: [phone]

ENFORCEMENT PAYMENTS JOURNAL
11/15/OT
-
-
Page:1
mrt
Fae Typ! Check Number
Cass Number
XwsbaE
Pqw
Acwmrt
Gosi Gnder Gwryaq
Amount County
NG Blalub Number
EMorcemsnlG s 451
P6=O -0065-
11tl6@007
Ttlpw5iopnwxlnc.Menan Plsl
43M00
1B30emi 1601
M.25 NWERNWI
143315.1(e)(8)
Wl Pennon 451
PG20%A085
11115@007
TnOm BlepnmrerOm McSw PYN
43M00025
16306301 1601-
4750.00 Mrpome.Vl
143-215.1(m)(6)
TOWArwu�
ImAs
GmnNTolmlAmwnt
563295.

W A , Michael F. Easley, Governor
�C 61 (� William G. Ross Jr., Secretary
Cq r7 C lfl{ North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
Aquifer Protection
November 1, 2007
Mr. Tony Leopard
Regional Plant Manager CERTIFIED MAIL 7006 2150 0005 2458 8535
SUEZ Energy Biopower, Inc.
302 Duke Street RETURN RECEIPT REQUESTED
Forest City, NC 28043
SUBJECT: Assessment of Civil Penalties
for VIOLATION OF PERMIT CONDITIONS'
McDOWELL County
File No. PC-2007-0085
Dear Mr. Leopard:
This letter transmits notice of a civil penalty assessed against SUEZ Energy Biopower, Inc. in the amount of
$832.95 which includes $82.95 in investigative costs. Attached is a copy of the assessment document'
explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the Secretary of the
Department of Environment and Natural Resources and the Director of the Division of Water Quality. Any
continuing violation(s) may be the subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three items:
1. Submit payment of the penalty:
Payment should be made to the order of the Department of Environment and Natural
Resources.. Payment of the penalty will not foreclose further enforcement action for any
continuing or new violation(s). Do not include the attached waiver form if making
payment.
Please send payment to the attention of -
Mr. Ed Hardee
DWQ%Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
One
NCarolina
�aiurally
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet:. h2o.enr.state.nc:us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

2. Submit a written request for remission or mitigation including a
detailed justification for such request: `
A request for remission or mitigation is limited to consideration of the reasonableness
of the amount of the penalty and is not the proper procedure for contesting the
accuracy of any of the statements contained in the assessment letter. Because a
remission request forecloses the option of an administrative hearing, such a request
must be accompanied by a waiver of your right to an administrative hearing and a
stipulation that there are no factual or legal issues in dispute. You must execute and
return to this office the attached waiver form and the attached "Justification for
Remission Request" which should describe why you believe:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from
the violation;
(c) the violation was inadvertent or a result of an accident;
_. (d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please submit this information .to the attention of:
And to:
Mr. Ed Hardee
DWQ/Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Mr. Landon Davidson
DWQ/Aquifer Protection. Section
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must request an
administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must file your original petition with the:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714

AND
Mail or hand -deliver a copy of the petition to:
And to:
Mary Penny Thompson
NCDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Mr. Ed Hardee
DWQ%Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Failure to exercise one of the options above within thirty days, as evidenced by a date stamp (not
a postmark) indicating when we received your response, will result in this matter being referred
to the Attorney General's Office with a request to initiate a civil action to collect the penalty.
Please be advised that additional assessments may be levied for future violations which occur
after the review period of this assessment.
If you have any questions, please contact me at [phone] or Mr. Ed Hardee at (919) 715-
6189.
Sincerell
G. Landon —Davidson, L.G., Regional Supervisor
Aquifer Protection Section
ATTACHMENTS
cc: Landon Davidson, APS Asheville Regional Office w/ attachments
LAPCU Attn: Ed Hardee w/ attachments
APS Central Files w/ attachments
Susan Massengale, PIO w/ attachments

STATE OF NORTH CAROLINA
COUNTY OF McDOWELL
IN THE MATTER OF
SUEZ ENERGY BIOPOWER, INC.
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
File No. PC-2007-0085
),'
FINDINGS AND DECISIONS
FOR EXCEEDING THE POLLUTANT
MONTHLY AVERAGE CONCENTRATION ),
FOR ARSENIC ) AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of Environment and
Natural Resources and the Director of the Division of Water Quality, I, Landon Davidson, Aquifer
Protection Regional Supervisor for the Asheville Region, of the Division of Water Quality (DWQ),
make the following:
I. FINDINGS OF FACT:
A. SUEZ Energy Biopower, Inc. operates a Distribution of Residual Solids (503 Exempt)
Ash Distribution program under Permit Number WQ0010689 that was issued November
29, 2006 and expires November 30, 2010.
B. A review of the 2007 monitoring data conducted during the annual compliance
inspection by the Asheville Regional Office revealed a violation of the Pollutant
Monthly Average Concentration (Dry Weight Basis) for Arsenic. The May 2007 metals
analyses showed concentrations of 71mg/kg and 31mg/kg. The resulting monthly
average was 51 mg/kg.
C. Condition 11 (5) of permit WQ0010689 states that for ash to be distributed through the
approved ash distribution program, the following shall be maintained:
Monthly Average Concentration (Dry Weight Basis):
Arsenic 41 (mg/kg)
D. The cost to the State of the enforcement procedures in this matter totaled $82.95.
Based upon the above Findings of Fact, I make the following:
H. CONCLUSIONS OF LAW:

A. SUEZ Energy Biopower, Inc. is a "person" within the meaning of G.S. 143-215.6A
pursuant to G.S. 143-212(4).
B. SUEZ Energy Biopower, Inc. violated Condition H (5) of permit WQ0010689 by failing
to maintain a Monthly Average Concentration (Dry Weight Basis) of 41 mg/kg for
Arsenic.
C. SUEZ Energy Biopower, Inc. may be assessed civil penalties pursuant to G.S. 143-
215.6A(a)(2) which provides that a civil penalty of not more than twenty-five thousand
dollars ($25,000.00) per violation may be assessed against a person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit required by
G.S. 143-215.1.
D. The State's enforcement costs in this matter may be assessed against SUEZ Energy
Biopower, Inc. pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
E. The Aquifer Protection Regional Supervisor for the Asheville Regional Office,
Division of Water Quality, pursuant to delegation provided by the Secretary of the
Department of Environment and Natural Resources and the Director of the Division of
Water Quality, has the authority to assess civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
DECISION:
Accordingly, SUEZ Energy Biopower, Inc. is hereby assessed a civil penalty of:
$ 750.00 For the failure to maintain a Monthly Average Concentration
(Dry Weight Basis) of 41mg/kg for Arsenic, which is a violation
of permit WQ0010689, condition 11(5).
$ 750.00
$ 82.95
$ 832.95
TOTAL CIVIL PENALTY
Enforcement Costs
TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have considered the

As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have considered the
factors listed in G.S. 14313-282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
(Date)
G. Landon Davidson, L.G., Regional Supervisor
Aquifer Protection Section
Asheville Regional Office
Division of Water Quality

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: PC-2007-0085 County: McDowell
Assessed Party: SUEZ Energy Biopower, Inc.
Permit No. (if applicable): WQ0010689 Amount Assessed: $ 832.95
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission; Please be aware that, a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences); ,
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance).
EXPLANATION (attach additional pages as necessary):

STATE OF NORTH CAROLINA
COUNTY OF McDOWELL
IN THE MATTER OF ASSESSMENT )
OF CIVIL PENALTIES AGAINST )
SUEZ Energy Biopower, Inc.
ENVIRONMENTAL MANAGEMENT
COMMISSION
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO.' PC-2007-'0085
Having been assessed civil penalties totaling $832.95 for
violation(s) as set forth in the assessment document of the Director of the Division of Water Quality
dated November 1, 2007 , the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Quality within thirty (30)
days of receipt of the civil penalty assessment. No new evidence in support of a remission request
will be allowed after thirty (30) days from the receipt of the civil penalty assessment.
This the day of 20
SIGNATURE
ADDRESS
TELEPHONE

DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT (FILE)
Violator: SUEZ Energy Biopower, Inc.
County: McDowell
Case Number: PC-2007-0085
ASSESSMENT FACTORS
As required by G.S. 143-214.6A(c), in determining the amount of the penalty I considered
the factors set out in G.S.143B-282.1(b), which are:
1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation; Unknown
2) The duration and gravity of the violation; The Pollutant Monthly Average
Concentration was exceeded for the May 2007 sampling event only. Subsequent
samples have shown compliance with permit conditions.
3) The effect on ground or surface water quantity or quality or on air quality;
Unknown
4) The cost of rectifying the damage; Unknown
5) The amount of money saved by noncompliance; We do not believe there was any
monetary savings.
6) Whether the violation was committed willfully or intentionally; The ARO does not
believe the violation was intentional.
7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and; No prior violations. ,
8) The cost to the State of the enforcement procedures. $82.95
Date G. Landon Davidson, L.G.
Regional Supervisor
Aquifer Protection
Asheville Regional Office

Compliance Inspection Report
Permit: WQ0010689 Effective: 11/29/06 Expiration: 11/30/10 Owner: Suez Energy Biopower Inc
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Tony Leopard Title: Regional Plant Manager Phone: [phone]
Directions to Facility: 1573 L Pl"+�5 S'fa�fon
Take NC Hwy. 221 North out of Marion to NCSR 1560 (i.e., located behind Baxter - North Cove). The facility is located on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s): rrn rv�—
On-Site Representative(s):
On -site representative Tony Leopard Phone: [phone]
24 hour contact name Ricky Styles Phone: [phone]
Related Permits:
Inspection Date: 10/25/2007 Entry Time: 10:00 AM Exit Time: 11:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas: - -- _
0 Miscellaneous Questions 0 Record Keeping Sampling
(See attachment summary) f
i
Page: 1

Permit: WQ0010689 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/25/2007 Inspection Type: Compliance Evaluation
Inspection Summary:
WZ
®+ * fAs4-
Reason for Visit: Routine
a
a,
baJ
d /
A,SP� 14�,66Lt 00 boo
a
Page: 2

Permit: WQ0010689 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/25/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application n
Distribution and Marketing
I
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? n n ■ n
Are GW samples from all MWs sampled for all required parameters? n n ■ n
Are there any GW quality violations?
■
Is GW-59A certification form completed for facility? S 0 <<
Cl
n
■
n
Is a copy of current permit on -site?
R
n
n
n
Are current metals and nutrient analysis available? 1131 I0-1 ke;51 S 11100 n
�jr�iorc +tiS��s ---� AS
SRmp%¢ .64c->T 4/0 7 d� p►5� •
Are nutrient and metal loading calculating most limiting parameters? • �' p1�^'�
n
110
v3
%�1
a. TCLP analysis? �I "Oo-) Ree< ' �j"' p�1.jl®�
` J /
0
n
Q
n
L S4^-P14_P
b. SSFA (Standard Soil Fertility Analysis)? � 7� f-17
❑❑■n
Are PAN balances being maintained? �a .-jam j�)
Are PAN balances within permit limits? �1�'�araM1,�r��J d
n
n
■
Cl
Has land application equipment been calibrated?
n
❑
■
11
Are there pH records for alkaline stabilization?
ri
n
■
ri
Are there pH records for the land application site?
n
n
a
n
Are nutrient/crop removal practices in place?
n
n
■
Cl
Do lab sheets support data reported on Residual Analysis Summary? W%\� �v u z b o�
n
n
n
0
Are hauling records available?
B
n
n
n
Are hauling records maintained and up-to-date?
10
n
n
# Has permittee been free of public complaints in last 12 months?
M
Cl
n
n
Has application occurred during Seasonal Restriction window?
❑
n
■
n
Comment:
Sampling
Yes
No
NA
NE
Describe sampling: PI4.s+1e
` ++ q O d
Is sampling adequate? C6 ���cS�_ w-� Sa^`�
n
n
n
Is sampling representative?
�G6 r'►1
Comment:
Page: 3

2007 9:49AM F -ASERJET FAX P.1
Energy Generation NA
FROM: ?cc a r TO. 7'�,vekly Pitt
FAX- 75-6 714.0 FAX- *7041-?
Numberto'caff if fax is kc*mpkfe or NbObikr 828-75849a DATE: /O-Z4-07
W=0=NLA, klm Numb" of
Onck4ng cw-w}
2W9 Old Liftvile Road
Maftm NC 28752
Td. 820-75SAM -fax [phone]
E-?nsa — coin
OCT 2 6 2007
Ashevillib Regional Office
�.k j- � Lp, r - Erp pction ,t ,,,iLtion
The hWmo0vh R* ;;mn%wA%, b and COAMMM, kdomfed oW fw 9w 400 offt nwP&nt dastw~ chasm You w*
hweby MWWd NW MW d�bn, dktbW*m aw or oopybo of d* aammuNta6m IS so** pvhMW. If you how rowh%d &a

WPPP2007 9:49AM H" `.RSERJET FAX p.2
PageArralytical Services, lttc. • Pace Analytical SeMen,,Inc.
9600 Knsey Avenue, Suite 100 2225 Riverside ©rive
Huntersville, NO 28078 Asheville, NC 28804
GeA al i�a�® Phone; 704.8759092 Phone: [phone]M
Fax. 704.8T5.909P Fax: [phone]
www.pacelabs. cam
Lab Project dumber: 92137232
Client Project ID: ASH SAMPLE
Solid results are reported on a dry weight basis
Lab Sample No: 927963546 • Project Sample Number: 92137232-001 Date Collected. 0 1� .40
Client Sample ID: MARION ASH 2O1-1 Matrix: Soil Date Received: OI/31/07 12:00
Parameters
Results
Units
Report Limit
DF Analyzed By
CAS No.
Qual
Reglmt
Metals
Trace ICP Metals, TCLP Leach.
Method: EPA 6010
Date Digested
02/05107 14:00
02/05/07 14:0D
Trace ICP Metals. TCLP Leach.
Prep/Method: EPA 3010 !
EPA 6010 .
Arsenic
mg/i
O.D25�
1.0 02106/07 18:22 SHB
7440-38r2
Barium
0.96
mg/l
0.D25
1.0 02/06/07 18:22 SHB
7440-39.3
Cadmium
ND.
ngJl
0.0050
1.0 02/06/07 18:22. SHB
7440-43-9
Chromium
ND
mg/1
O'.025
1.0 02/06/07 18:22 SHE
7440-47-3
Lead
ND
mgil
0.025
1.0 02/06107 18:22 SHE
7439=92-1
CNJ
Selenium
ND
mg/1
0.050
1.0 02/06/07 18:22 SHE
7782-49-2
©
CU
Silver
ND
mg/i
D.025
1.0 02/06/07 18:22 SHE
7440-22-4
'
Date Digested
02/06/07 09:35
02106107 09:35
Metals. Trace ICP
Pre hod:, EPA 3050
/ EPA 6010
Arsenic
mg/kg
0.46
Barium
1500
mg/kg
..4.6
Cadmium
2.1
mg/kg
0.092
Calcium
b8000
mg/kg
99.
Chromium
44.
mg/kg
0.46
Copper
84.
mg/kg
0.46.
Iron
'28000
mg/kg
46..
Lead.
26
mg/kg
0.46
Magnesium
13000
mg/kg
92.
Manganese
1800
mWkg
4.6
Molybdenum
ND
tug/kg
0,46
Nickel
26.
mglkg
0.46
Potassium
26000.
mg/kg
920
Selenium
NO
mg/kg
0.92
Silver
0.53
mglkg
0,46
Sodium
7800
mglkg
92.
Zino
110
mglkg
0.92
Date Digested
02/07/07 I4:15
Mercury, CVAAS, TCLP Leachate Method: EPA 7470
Mercury w . mg/l
idercury. CVAAS. in Soil Method: EPA 7471
Date: o2/23/07
Asheville Gertiflcation 10s
NC Wastewater
40
NC Drinking Water
37712
SC
99030
•FL NELAP
E87648
0.9-02/07107 18:55 SHE 7440.38-2
9.2 02107/07'18:55 SH8 7440-39-3
.0.9 02/D7/07 18:55 SHB 7440 43.4
9:2 02/07/D7'18:55 SHB 7440-70-2
0.9 02/D7/07 18:55 SHO 7440-47-3
0.9 02/07/07 18:56 SHB 7440-50-8
9.2 02/07/07 18.55 SHE 7439-89-6
0.9 62/07/07 18:55 SHB 7439-92-1
9.2 02/07/07 18:55 SHE 7439-95-4
9.2 02/07/07 18.55 SHB 7439'-96-5
0.9 02/07/07 18:55 SHB. 7439-98-7
0.9 D2107/07 18:55 SHE 7440-02-0
9.2 02/07/07 16:55 SHE 7440-09.7
0.9 02407/01 18:55 SHE 7782-49-2
0'.9 02107/07-18:55 SHE 7440.22-4
0.9 02107107 18:55 SHB 744D-23-5
0.9'02107/07 18:55 SHB .7440-166-6
. 02107/07 14.15
0.00020 1.D 02/06/07 11:17 ALV 7439-97-6
.REPORT Of LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services; Inc.
`� ,n ccoRoy
t'm
Page: I of 4
harlotte Certification IN
NC Wastewater
12
NC Drinking Water
37n6
SC
99006
FL NELAP .
E87627

6 2007 9:49AM F _ASERJET FAX
aceAnalytic at/
www. pa'ceJalls,�eanr
P8cs Analyileal Services, Inc-
9800 KinceyAvenue, Suite 100
HURtersvifle, NC 28678
Phone: [phone]
Fax: [phone],
P•3
Pace Analytical Servlcas, Inc
2225 Riverside !hive
Asheviife, NC 28804
Phone: [phone].
Fax. 826.25Z.4618
Lab Project Number: 92144455
Client Project
IDI Marion Fly Ash
00:00
Lab Sample No- 928377076
Project Sample
Number: 92144455-003
Date Collected: 05/11/67
Client Sample ID: L.MARION
FLY ASH
Matrix:
Soil,
Date Received: 05/11/07
16:OD
Parameters
Results.
Units
Report Limit
DF
Analyzed
ay
CAS No.
Qual`
RtSLmt
Metal s
Metals. Trace ICP
Pre3VWet.�od:
EPA 3050 /
EPA 6010
Arsenic
C 7
mg/kg
0.79
1.6
05J17107
23:49 EWS
7440-38-2
Barium
ADO -
mg/kg
0.79,
1,6
65/17/07
23:49 EWS.
7440-39-3
Cadmium
4.0
Rg/kg
0.16
1.6
05/17/07.23
49 EWS
7440.43.9
Calcium
140000
mg/kg
2600
157
05/17107
23;49 EWS
7440.70.2
Chromium
63.
mg/kg
0.79
1.6
05/17/07
23;49 EWS
7440-47.3
capper
140
mg/kg
0.79
1.6
05/17/07
,23:49 EWS
7440-50-8
iu
Iron
I300D
mg/kg
7.9
1.6
05/17/07
23:49 EWS
7439.89-6
'a
'Lead
71.
mg/kg
0.79
1.6
05/17/07
23:49 EWS
7439-92-1
0
.Q c
Magnesium
12000
mg/kg
16.
1.6
05/17/07
23:49 ENS
7439-95-4
fl
�
Manganese
3800
mg/kg
79.
157
05/17/07
23:49 EWS
7439-96-5
�
Q
Molybdenum
3.1
mg/kg
0.79
1.6
05/17/07
23:49 EWS
7439-98.7
Nickel
21.
mg/kg
0.79
1.6
05/17/07
23:49 EWS
7440.02-0'
Potassium
44060
mg/kg
15000.
157
05117/07
23:49 EWS
7440.09-7
C-).
Selenium
1.6
mg/kg
1.6
1.6
05/17/07
23:49 EWS
7782-49.2
"
Silver
ND.
mg/kg
0,79
1.6
O5/17/07
23:49 EWS
7440-22-4
W, <
Sodium
12000
mg/kg
IN
1.6
05/17/07
23:49 EWS
7440-23-5
Zinc
430
mg/kg
1.6
1.6
D5/17/07
23:49 EWS
744D-66.6.,
Date Digested
05/16/07 13:15
05/16/07
13:15
-
Mercury, CYAAS, in Soil
Method: EPA 7471
Mercury
0.057
mg/kg
0.011
2.2
05/15/07
20.53 ALU
7439-97-6
Wet Chemistry
Percent Moisture
Method: Moisture
Percent liaisture
59.4
X
1.D'05/15/07
18;21 KDF
Phosphorus, Total, Soil
Method: EPA 365.2
Phosphorus
3670'
mg/kg
242.
121
05/22/07
11:16 DMN
7723-14-0
Date; 05/22/07
hevlie Certification 1D
NC Wastewater 40
NC Drinking Water 37712
SC 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproddced; except in full,
without the written consent of Pace Analytical, Services, Inc.
1► AQCa9
Page: 3 of 4
hariette Certification iD
NO Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627 .

6 2007 9:49AM K _ASERJET FAX p:4
Pace Anafyftai Services, Inca
9800 KlnceyAvenue, Suite 106
Huntersville, NO 28078
naV/ 1`�+Eaj Phone [phone]
i 1 Fax. 704.875, 9091
wWW paceJabs.eonr
Pace Anaiyifeal Services, inc.
2225 Riverside, Drive
Asheville, NC 28864
Phone_ 828254.7176
r=ax: 828.252.4618
Lab Project Number: 921W65
Client
Project
I0; Marion Fly Ash
Lab Sample No:
928377068
Project Sample
Number: 92144455-002
Rate Collected:
05/11/07 00:00
Client Sample
IQ: K MARION FLY ASH
Matrix: Soil
Date Received:
05111f07 16:0D
'Parameters
Results
Units
Report Limit
OF
Analyzed
By
CAS No.
ual
RegLmt
Metal s
Metals. Trace
ICP - Prep/Method:,EPA
3050 /
EPA 6010,.
Arsenic
6)_
rig/kg
0.78
1.6
05/18/07
00:39 EWS
7440-38-2
Barium
2600
mg/kg,
78.
156
05118107
00:39 EWS
7440-39-3
Cadmium
2.6
rmglkg
0.16
1.6
05/18/07
00:39 EWS
7440-43-9
Calcium
130000
mg/kg
1600
156
05/18/07
00:39 EWS
7440.70-2
Chromium
44,
mg/kg
0.78
1.6
05/18/07
00:39 EWS
7440-47.3
Copper
110
mg/kg
0.78
1.6
05/18/07
00:39 EWS
7440-50-8
Q)
U
Iran
31000
mg/kg
780
156
05118/07
D0:39 EWS
7439-89-6
Lead
32.
mg/kg'
0.78
1.6
05/18/07
00:39 EWS
7439.92-1
®
C
MagnesiuA.
23000
mg/kg
1600'
156
05/18/07
00:39 EWS
7439-95-4
co:-'
Manganese
34M
mg/kg
78.
156
05/18/07
00:39 EWS
7439-96-5
Halybdenum
ND
mg/kg
0:78
1.6
05/18/07
00:39 EWS
7439-98-7
0150
VA
Nickel
23.
mg/kg
0.78
1.6
05/18/07
00:39 EWS
744D-02-0
Potassium
37000
mglkg
16000
156
05/18/07
00:39 EWS
7440-09-7
�T
®
0J
Selenium
ND
mg/kg
1.6
1.6
05/18107
00:39 EWS
7782 49 2
Silver
ND
mg/kg
0.78
1.6
05/18/07
00:39 EWS
'7440-22.4
ct:
Sodium
. X'
9900
mg/kg'
160
1.6
05/18/07
00:39 EWS
7440-23.5
inc
280 mg/kg
1.6 1.6 05/18/07
00:39 EWS 7440-66-6
Date Digested
05/16/07 13:15
05/16/07
13:15
Mercury, CVAAS, in Soil
Method: EPA 7471
Mercury
0.015 Rig/kg
0.0079 1.6 05/15/07
10:55 ALV 7439-97.6
Wet Chemistry
Percent Moisture
Method: k Moisture
Percent Moisture
50.2 %
1.0 05/16/D7
09:13 TW4
Date: D5/22/47 Page: 2 of 4
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Gharlottd Certification'11)
NC Wastewater . 40 NC Wastewater 12 '
NC Drinking Water 37719 This report steal! not be reproducetl, except in full, NC Drinking Water 37706
SC 99030 without the written consent of Pace Analytical Servtces, Inc, gC "99006
FL NELAP E87648 htos ncsogo�¢
�, FL NELAP E87627

r _
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JJ sV • 1 v�1✓ 1 n Vi:�'� � �1,�/'l.�l.li'i
;(, , �--/) ` d, �''- �' _ '��- j- (•�� _ G'-Z�' G` i•'-C dlfiv w�./4 ���1,/�'%-. L-A'-Cy ,�-��'.t;�.
ZI
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i Y C--, iw• � '�

w ArF9
North Carolina Department i
Michael F. Easley, Governor
William G. Ross Jr., Secretary
ronment and Natural Resources
AQUIFER PROTECTION
November 6, 2006
Tony Leopard, Plant Manager
Suez Energy Biopower,, Inc.
302 Duke Street
Forest City, North Carolina 28043
Alan W. Klimek, P.E. Director
Division of Water Quality
Asheville Regional Office
SUBJECT: October 27, 2006 Compliance
Evaluation Inspection
Suez Energy Biopower, Inc
Marion Facility
Distribution of Residual Solids
Permit No: WQ0010689
Scrubber Recycle System
Permit No: WQ0001512
McDowell County
Dear Mr. Leopard:
. On October 27, 2006 1 conducted a Compliance Evaluation Inspection of the Suez Energy
Biopower, Marion facility in McDowell County. The purpose of this inspection was to determine the
compliance status of each of your Water Quality Permits. The assistance of Mr. Ricky Styles was greatly
appreciated.
With regards to Permit No. WQ0001512 — The facility appeared to be well maintained with no discharge to
surface waters. The freeboard and maintenance records were excellent. The freeboard at the time of
inspection was 34 inches. The recycle system appeared to be operating according to permit conditions.
With regards to Permit NO. WQ0010689 — A review of the 2005 Annual Report was conducted along with
this inspection and all was found to be in order. The ash distribution program appears to be operating in
compliance with permit conditions.
Please refer to the enclosed inspection report for additional observations and comments. If you or your
staff has any questions, please call me at [phone].
Sincerely,
Ed Williams
Environmental Specialist
Enclosure
cc: Ricky Styles, Plant Superintendent Suez Energy Biopower, Inc.
APS Central Files
PS`-'A5' eVlfle�F�i'15 NorthCarolina
Natura!!11
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Compliance Inspection Report
Permit: WQ0010689 Effective: 12/30/05 Expiration: 11/30/10
Owner: Suez Energy Biopower Inc
SOC: Effective: Expiration:
Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell
2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Tony Leopard
Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 (i.e., located behind Baxter - North Cove). The facility is located on the left.
Primary ORC: Certification:
Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Tony Leopard
Phone: [phone]
24 hour contact name Tony Leopard
Phone: [phone]
Related Permits:
Inspection Date: 10/27/2006 Entry Time: 09:00 AM Exit Time:
10:30 AM
Primary Inspector: Beverly Price
Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ! Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions E Record Keeping Sampling
(See attachment summary)
Page: 1

Permit: WQ0010689 owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/27/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Maintenance records were very good.
No evidence of discharge from .system.
Review of 2005 Annual Report shows compliance with permit monitoring reporting conditions.
The facility is no longer maintaining an ash stockpile on the ground surface. Ash will remain in the basin until it is loaded
directly onto trucks for distribution (per Condition No. 1.2. of the non -discharge permit).
a
Page: 2

Permit: WQ0010689 Owner - Facility: Suez Energy Biopower Inc
Inspection Date: 10/27/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Land Application n
Distribution and Marketing ■
Record Keeping
res
No
NA
Nt
Is GW monitoring being conducted, if required?
❑
n
■
n
Are GW samples from all MWs sampled for all required parameters?
n
n
■
n
Are there any GW quality violations?
n
❑
■
n
Is GW-59A certification form completed for facility?
n
n
®
n
Is a copy of current permit on -site?
■
❑
0
❑
Are current metals and nutrient analysis available?
■
n
n
n
Are nutrient and metal loading calculating most limiting parameters?
n
n
■
n
a. TCLP analysis?
■
n
n
n
b. SSFA (Standard Soil Fertility Analysis)?
n
n
■
❑
Are PAN balances being maintained?
n
n
■
❑
Are PAN balances within permit limits?
n
n
■
n
Has land application equipment been calibrated?
n
n
■
Are there pH records for alkaline stabilization?
n
n
■
n
Are there pH records for the land application site?
n
n
■
Are nutrient/crop removal practices in place?
n
n
■
n
Do lab sheets support data reported on Residual Analysis Summary?
❑
n
■
El
Are hauling records available?
■
n
n
n
Are hauling records maintained and up-to-date?
■
❑
n
n
# Has permittee been free of public complaints in last 12 months?
■
n
n
n
Has application occurred during Seasonal Restriction window?
❑
n
■
n
Comment:
Sam P . ling
_
Yes
No
NA
NE
Describe sampling:
Is sampling adequate? ■ n ❑ n
Is sampling representative? ■ n ❑ ❑
Comment:
Page: 3

Compliance Inspection Report
Permit: WQ0010689 Effective: 12/30/05 Expiration: 11/30/10
Owner: Trigen-Biopower Inc
SOC: Effective: Expiration:
Facility: North Cove Steam Generation Plant Ash
Distribution Program
County: McDowell
2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Tony Leopard
Phone: [phone]
Directions to Facility:
Take NC Hwy. 221 North out of Marion to NCSR 1560 (i.e., located behind Baxter - North Cove). The facility is located on the left.
Primary ORC: Certification:
Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Tony Leopard
Phone: [phone]
24 hour contact name Tony Leopard
Phone: [phone]
Related Permits:
Inspection Date: 10/27/2006 Entry Time: 09:00 AM Exit Time: 10:30 AM
Primary Inspector: Beverly Price
Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
E Miscellaneous Questions 0 Record Keeping Treatment Sampling
(See attachment summary) f / 1
2
6{!� 4EbP �� ��,�•a/� f'ega'r4'�� l.�U�u`tdJ"l �, a
-4V UDC J
--) L II `_
(k' 6,,'
X,
Page: 1

Permit: WQ0010689 Owner - Facility: Trigen-Biopower Inc
Inspection Date: 10/27/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0010689 Owner - Facility: Trigen-Biopower Inc
Inspection Date: 10/27/2006 Inspection Type: Compliance Evaluation
Type
Land Application
Distribution and Marketing
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Treatment IvA
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Reason for Visit: Routine
nnMn
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❑❑n❑
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9000
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0090
❑❑n❑
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9❑❑111
W❑❑❑
nnn❑
Yes No NA NE
Page: 3

Permit: W00010689 Owner - Facility: Trigen-Biopower Inc
Inspection Date: 10/27/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Alkaline Stabilization (Class B) n
Compost n
Drying Beds n
Other
Comment:
Sampling Yes No NA NE
Descr e sampling: l 1
� 1 � ��6 n n
Is sampling adequate.? � ��� Ca f
Is sampling representative?
Comment:
CJL
s
Page: 4

Marlon Physicals Data
Item
Units
Marion Facility
2008 YTD
JAN I FEB I MARCH I APRIL I MAY I JUNE I JULY I AUG I SEPT OCT NOV DEC
TOTALS
Materials Consumed
Fuel Oil Combusted in Boilers
gallons
Fuel Oil Combusted In Equipment
allons
2111
2,308
1,979
1,768
2,186
2,192
1 653
2,098
2,118
18,413
Wood Combusted GTB
tons
8,787
8187
9,047
7,755
8,052
7,913
5 958
8,286
7,699
71,684
Wood Combusted calculated
mmBtu
79,083
73.690
81,420
69,798
72,469
71,215
53 624
74 537
69 290
645125
Sludge Received
wet tons
Sludge Combusted
wet tons
White Wall Grindin s Combusted
tons
Tire Chips Combusted
tons
Carpet Combusted
tons
Used Oil Combusted 1
gallons
30.0
30.0
30.0
35.0
30.0
30.0
30.0
30.0
30.0
275.0
Electrlcit Used
MWh
402.20
376.40
395.00
364.00
429.60
428.60
275.20
360.40
331.00
3,362.4
Public Utility Water Used
gallons
Suface Water Used
gallons
Ground Water Used
nallons
Production
Steam Generated
I mib
57 994.0
164,039.0
159,708.0
151,185.0
1 53144.0
1 52 224.0
141,119.0
154,687.0
160.813.0
1
1
1
1 474,913
Steam Sold
I mlb
1 54 968.0
152,628.0
155,885.0
146,369.0
1 49141.0
148,746.0
139,324.0
149,530.0
146,347.0
1
1
1
1 442,938
Waste Reuse/Disposal
Ash Disposed In Landfill
actual tons
37.7
61.8
55.5
38.8
42.7
36.0
52.5
64.7
30.0
410
Ash Used Commercial) 2
actual tons
Sandbox Ash Land Applied 3
actual tons
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0
Sandbox Ash Moisture as hauled
%
#DIV/01
Scrubber/sandbox Ash Land A II
actual tons
264
1,210.0
28.0
21
0
810.0
0
576
0
0
0
0
2 909
Scrubber Ash Moisture as hauled
%
52
52.0
62.0
31
0
31.0
0.0
44
33
Sludge Isposed
Iwet tons
Waste Oil Disposed
gallons
0
0
0
0
0
0
0
0
0
0
0
0
0
All Other Industrial Waste Dis . (41
tons
1 0
1 0
1 0
1 0
1 0
1 0
1 0
0
1 0
1 0
1 0
0
0
Notes: (1) Only for facllitlespermitted for used oil combustion
(2) Includes ash sold to commercial operations as soil amendment, etc. Does not Include land applied ash.
(3) Only Includes quantity directly applied to land, Only Marion, Forest City, and Eden are permitted to land apply ash.
(4) Includes process waste streams not tracked above (not including plant trash).
Greyed cells are not applicable to this facility. No tracking required,
(5) Wood added has been deducted

ioPower Name Change]
PV Subject: Re: [Fwd: Trigen-BioPower Name Change]
From: David Goodrich <[e-mail]>
Date: Wed, 01 Nov 2006 07:00:56 -0500
To: Bev Price <[e-mail]>
Bev Price wrote:
Hi David,
There should also be a name change for permit WQ001689 -Ash Distribution for Trigen-Biopower
in Marion , NC. My copy of their letter references this permit as well as the other three. Call if you
have questions. Thanks
Bev
David Goodrich wrote:
------- Original Message--------
Subject:Trigen-BioPower Name Change
Date:Tue, 31 Oct 2006 09:17:25 -0500
From:David Goodrich <David.Goodrich(ancmail.net>
To:beverly.pricep,ncmail.net
Beverly,
The Central Office is in receipt of correspondance from Tony Leopard
regarding the name change of Trigen-BioPower, Inc. to SUEZ Energy
BioPower, Inc.
The ONLY requested change is the name on the three permits, which are:
WQ0003449 Wastewater Recycling System for the Forest City Steam
Generation Plant
WQ0001512 Wastewater Recycling System for the North Cove Steam
Generation Plant
WQ0010690 Distribution of Residual Solids (503 exempt) for the
Forest City Steam Generation Plant
We will proceed to re -issue these three permits under the new name. The
respective expiration dates and other details of each permit
will not be changed.
David Goodrich
1 of 2 11/3/2006 2:36 PM

.dioPower Name Change]
Bev Price - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Hi Bev,
Yes, I just received that request also. This makes a total of four permits for them that are going
to have name changes. Thank you for the additional information about them!
David
2 of 2 11/3/2006 2:36 PM

October 23, 2006
VIA Federal Express # 7995 23991075
John Risgaard
NC Division of Water Quality
Aquifer Protection Section
Land Application Unit. .
1636 Mail Service Center
Raleigh, NC 27699-1636
Energy Generation NA
J
OCT 2 6
1
.22666
u�y
RE: Name Change
Trigen-BioPower, Inc. to SUEZ Energy BioPower, Inc.
2859 Old Linville Rd., Marion, NC 28752
Permit WQ0041512 — Scrubber Recycle System
Permit WQ001689 — Ash Distribution
Dear Mr. Risgaard:
This letter and attached application forms are being submitted to document that Trigen-
BioPower, Inc. has changed its name from to SUEZ Energy BioPower, Inc. We request that the
water quality permits above be reissued to reflect this new name..
Please note that this is a change in name only, and does not reflect a change in ownership or
change in structure. The legal entity, as well as all other information such as addresses, state of
incorporation, etc., remains the same.
Thank you for your patience and assistance during this transition. If you have any questions or
concerns, please do not hesitate to contact me.
Sincerely
Ton eopard
Plant Manager
Cc: Bev Price, Asheville Regional Office
Ricky Styles
file: 2.2 & 4.2
Tony Leopard
Plant Manager
SUEZ Energy BioPower, Inc.
302 Duke Street
Forest City, NC 28043
Tel. [phone] - fax [phone]
tonv.leooard cD..suezenergvna.com
www s11P7Pnamvnn mm

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
PERMIT NAME/OWNERSHIP CHANGE FORM
Any changes made to this form will result in the application being returned.
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
For more information, visit our web site at: http://h2o.enr.state.nc.usllaulmain.html
I. REQUIRED ITEMS
1. Submit one original of the completed and appropriately executed Permit Name/Ownership Change Form.
For a change of ownership, the certification must be signed by both the current permit.holder and the new
applicant. For a name change only, the certification must be signed by the applicant.
2. Provide legal documentation of the transfer of ownership (such as a contract, deed, article of incorporation,
etc.) for ownership changes.
3. Change of Ownership Applications for Homeowners Associations (HOAs) shall include the HOAs bylaws,
covenants, etc. [15A 2T .0115(c)]
4. Submit a properly executed Operation and Maintenance Agreement for all Single Family Residence Surface
Irrigation permits requesting a change of ownership.
II. CURRENT PERMIT INFORMATION
1. Permit number: W00010689
2. Permit holder's name: Trigen-BioPower, Inc
3. Permit's signing official's name and title: Tony Leonard
(Person legally responsible for permit)
Plant Manager
(title)
4. Mailing address: 302 Duke Street
City: Forest City State: NC Zip: 28043
Telephone number: (_828_) 287-5886 Facsimile number: (_828_) 286-1229
III. NEW OWNER/NAME INFORMATION
1. This request for a permit change is a result of
a. Change in ownership of property/company
X b. Name change only
c. Other (please explain):
2. New owner's name (name to be used in permit): SUEZ Energy BioPower, Inc.
FORM: PNOCF 09-06 Page 1 of 2

3. New owner's or signing official's name and title: Tony Leopard
(Person legally responsible for permit)
4. Mailing address: same as above
City:
State:
Plant -Manager
(title)
Zip:
Telephone number: Facsimile number: (_ _ )
IV. CERTIFICATION
Current Permittee's Certification:
I, , attest that this application for name/ownership change has been
reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of
this application are not completed and that if all required supporting information and attachments are not
included, this application package will be returned as incomplete. I understand I will continue to be
responsible for compliance with the current permit until a new permit is issued.
Signature:
2. Applicant's Certification:
I, Tony Leonard attest that this application for name/ownership change has been
reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of
this application are not completed and that if all required supporting information and attachments are not
included, this application package will be returned as incomplete.. I further certify that the applicant or any
affiliate has not been convicted of an environmental crime, has not abandoned a wastewater facility without
proper closure, does not have an outstanding civil penalty where all appeals have been exhausted or
abandoned, are compliant with any active compliance schedule, and do not have any overdue annual fees
under Rule 2T .0105
Signature: Date:® !�
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION AND
MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
LAND APPLICATION UNIT
Via U.S. Postal Service
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636
Via Courier /Special Delivery:
2728 CAPITAL BOULEVARD
RALEIGH, NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone]
FORM: PNOCF 09-06 Page 2 of 2

Michael F Easley, Governor
William G Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
October 20, 2006
5472
Mr. Ricky Styles
Trigen-Bio Power, Inc. - Marion
2859 Old Linville Rd.
Marion, NC 28752-
SUBJECT: Initial Laboratory Certification Inspection
Dear Mr. Styles:
Alan W Klimek, P E Director
Division of Water Quality
. d i
OC ! 2 [i 900V
L--r...s...-.--
LEABORATORY SECTION
ASHVILLE. REGip.NAL'iir FIG
Enclosed is a report for the inspection performed on October 17, 2006 by Mr. Gary
Francies. Where deficiencies are cited in this report, a response is required as well as for all
lettered comments and/or recommendations. Within 30 days of receipt, please supply this
office with a written item for item description of how these deficiencies, comments and/or
recommendations were corrected.. For certification maintenance, your laboratory must continue
to carry out the requirements set forth in 15A NCAC 2H ..0800.
Copies of the checklists completed during the inspection 'may be requested from this
office,. Thank you for your cooperation during the inspection. If you wish to obtain an electronic
copy of this report by email, or if you have questions or need additional information please
contact us at 919-733-3908.
Sincerely,
Ae-7-V^;_4
Pat Donnelly
Branch Manager
Enclosure
cc: Gary Francies
Noll hCarolina
North Carolina Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 Phonc [phone] Customer Service
Internet: www dwglab prg Location: 4405 Reedy Creek Rd Raleigh, NC 27607 Fax [phone]
An Equal OpportunitylAffirrnative Action Employer— 50% Recyc[W10% Post Consumer Paper

LABORATORY NAME:
ADDRESS:
CERTIFICATE NO:
DATE OF INSPECTION:
TYPE OF INSPECTION:
EVALUATOR:
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
Trigen — Bio Power, Inc. - Forest City
2859 Old Linville Road
Marion, NC 28752
5472
10/17/06
Initial - Field
Mr. Gary Francies
Mr. Ricky Styles., Mr. Tony Leopard
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
GENERAL COMMENTS:
The staff is congratulated for doing a good job of implementing the Field Testing Certification program.
The facility has all the equipment necessary to perform the analyses.,Most data appeared accurate.
Some further quality control procedures need to be implemented..
DEFICIENCIES, REQUIREMENTS. COMMENTS AND RECOMMENDATIONS:.
NOTE: The following comments are new requirements or policies that have been recently implemented.
PH -
A. COMMENT: The laboratory needs to verify the Automatic Temperature Compensator (ATC) of the
pH meter annually..
REQUIREMENT: There have been some changes made by the Certification Program. We have new
policies for ATC verification of pH meters. The following must be performed on an annual (12 month)
basis:
Automatic Temperature Compensator Check (ATC) for pH meter, performed every 12 months:
1. Take a buffer solution and cool to below 101'C and read the temperature. Analyze the buffer solution
at that temperature. Document the temperature and the measured pH value obtained on the log sheet.
2. Raise the temperature of the buffer solution to approximately 251C.Document the temperature and
the measured pH value on the log sheet.
3. Raise the temperature of the buffer solution to approximately 35°C. Document the temperature and
the measured pH, value on the log sheet.
4. Repeat with additional temperature adjustments and pH readings as necessary to ensure the
temperature usually measured for samples has been bracketed. As the temperature increases or
decreases the value of the buffer must be within ± 0.1 S.U. of the true value of the buffer.
Ref: NC Certification Policy Statement February 2006

v
Page Z
B. COMMENT (New Policy): The' temperature sensing device on the pH meter has not been
calibrated against a certified thermometer annually (every 12 months).
REQUIREMENT: All temperature sensing devices on meters must meet MIST specifications for
accuracy or must be calibrated against a MIST or MIST traceable thermometer annually (every 12
months) and proper corrections made and documented. The thermometer reading must be less than
1°C from the NIST certified reading to be acceptable. Ref: Standard Methods, 18th Edition - Method
2550 131.
IV. PAPER TRAIL INVESTIGATION:
A review of data was conducted. This consisted of comparing field testing records and contract lab
reports to the Annual Ash Report submitted to this Division.. Data were reviewed for the 2005 report. No
errors were noted.. It appears the facility is doing a good job of accurately transcribing data.
V. CONCLUSIONS:
This facility is doing a good job overall. Correcting the above items should help to produce quality data
and meet certification requirements. The inspector would like to thank the staff for their assistance in
the inspection and data review process. Please submit a written reply to all lettered comments
Report prepared by: Gary Francies Date: 10/20/06
Reviewed by: Chet Whiting Date: 10/20/06

WA]'F
�CF R
`oQG s
5472
Mr. Ricky Styles
Trigen-Bic, Power, Inc. - Marion
2859 Old Linville Rd.
Marion, NC 28752
SUBJECT: Updated Certificate
Dear Mr. Styles:
Michael F Easley, Governor
William G Ross Jr, Secretary
North Carolina Department of Enviromnent and Natural Resources
April 27, 2006
Alan W Klimek, P E Director
Division of Water Quality
LAPR 8RATORY SECTION
ASHEUILLE REGIONAL OFFICE
Enclosed is a new certificate that includes the update of the pH solids methods to SW846 9040C
and 9045D. The same requirements applying to your present certification are applicable to the
corrected parameter change(s). Please review this certificate to insure that your laboratory is
certified for all parameters required to properly meet your certification needs_
Contact us at 919-733-3908, if you have questions or need additional information.
Sincerely,
James W. Meyer
Laboratory Section
Enclosure
cc: Gary Francies
No ihCau
Nawn
Laboratory Section 1623 Mail Service Center, Raleigh, NC 27699-1623
4405 Rcedy Creek Road; Raleigh, NC 27607
Phone [phone] / FAX [phone] / Internet: www dwglab org
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certifled Parameters Listing
FIELD PARAMETERS ONLY
Lab Name: Trigen-Bio Power, Inc - Marion Certificate Number. 5472
Address: 2859 Old Linville Rd Effective Date: 03/22/2006
Marion, NC 28752- Expiration Date: 12/31/2006
Date of Last Amendment: 04/27/2006
The above named laboratory, having duly met the requirements of 15A NCAC 2H 0800. is hereby certified for the measurement of the parameters listed below
I1 CERTIFIED PARAMETERS
INORGANICS
pH
SW846 Method 9040C
SW846 Method 9045D
This certification requires mainlance of an acceptable quality assurance program, use of approved methodology. and satisfactory performance on evaluation samples Laboratories are
subject to civil penalties and/or decertification for Infractions as set forth in 15A NCAC 2H 0807

A rF9QG
co r
5472
Mr. Ricky Styles
Trigen-Bio Power, Inc. - Marion
2859 Old Linville Rd
Marion, NC 28752-
Michael F Easley, Governor
William G Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
Alan W Klimek, P E Director
Division of Water Quality
_ t �
March 23, 2006
4
4
SUBJECT: Initial Wastewater/Groundwater Laboratory Certification
FIELD PARAMETERS ONLY
Dear Mr. Styles:
The Department of Environment and Natural Resources, in accordance with the provisions of NC GS '143-
215 3(a) (10), 15 NCAC 2H 0800, is pleased to certify your laboratory to perform specified environmental
analysis required by EMC monitoring and reporting regulations 15 NCAC 26 .0500 and 2H .0900 and 2L
0100, .0200, .0300, and 2N .0100 through .0800.
A certificate acknowledging the certification of your laboratory is enclosed for your use. The certificate
describes the requirements and limits of your certification. Please review this certificate to insure that your
laboratory is certified for all parameters required to properly meet your certification needs.
Please contact us at 919-733-3908 if you have questions or need additional information.
Sincerely,
Yames W. Meyer
Laboratory Section
Enclosure
?�',`.';;�!'G•.'g�1ti �r� 3i1~S9,i;s4� (r.lr�;�?_y;_.�
NOnehCar
l7�lll
Laboratory Section 1623 Mail Service Center, -Raleigh, NC 27699-1623
4405 Reedy Creek Road; Raleigh, NC 27607
Phone [phone] / FAX [phone] / Intemet: www dwglab org
An Equal OpportunitylAffirmafive Action Employer- 50% Recycled110% Post Consumer Paper

STATE OF NORTH CAROLINA DEPARTMENT OF THE
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
LABORATORY CERTIFICATION PROGRAM
In accordance with ,the provisions of N.C.G.S. 143-215.3 (a) (1), 143-215.3 (a)(10) and NCAC 2H.0800:
Field Parameter Only
5AZ6
y y.7ti MA-1 u� rTis
1"
FssE QUAM
TRIGEN-1310 POWER, INC. - MARION
Is hereby certified to perform environmental analysts"as listed on Attachment I and report monitoring data to DWQ for
compliance with NPDES effluent, surface water, groundwater, and pretreatment regulations. _
By reference 15A NCAC 2H .0600 is made a part of this certificate.
This certificate does not guarantee validity of data generated, but indicates the methodology, equipment, quality control procedures,
records, and proficiency of the laboratory have been examined and found to be acceptable.
This certificate shall be valid until December 31,12006
Certificate No. 5472 /
James W. Meyer

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
FIELD PARAMETERS ONLY
Lab Name: Trigen-Bio Power, Inc - Marion Certificate Number:
5472
Address: 2859 Old Linville Rd Effective Date:
03/22/2006
Marion, NC 28752- Expiration Date:
•12131/2006
Date of Last Amendment:
03/23/2006
The above named laboratory_ having duly met the requirements of 15A NCAC 2H 0800, Is hereby certified for the measurement of the parameters listed below
CERTIFIED PARAMETERS
INORGANICS
pH
SW846 Method 9040E
SW846 Method 9045C
This certification requires malntance of an acceptable quality assurance program, use of approved methodology. and satisfactory performance on evaluation samples Laboratories are
subject to civil penalties and/or decertirication for infractions as set forth in 15A NCAC 2H 0807

s
TRIGEN
March 14, 2006
.MGE�I-BIOPOWEP, INC.
302 Duke Street, Forest City, NG 28043
Phone: [phone] Fax: [phone]
VIA, FEDERAL EXPRESS # 7914 0474 4167
Ms. Shannon Thornburg
NCDENR DWQ
Aquifer Protection Section -
Land Application Unit
clo LAU Residuals Program Coordinator
1636 Mail Service Center
Raleigh, NC 27699-1636
RE: Ash Stockpile Alternative
Trigen BioPower, Inc.
Marion, NC (McDowell County)
Permit No. WQ0010689
Dear Ms. Thornburg:
Trigen-BioPower, Inc. (TBP) is hereby providing notification to the Division of Water Quality of
the ash stockpile alternative- selected per Condition No_ I.2- of the above -referenced permit. TBP
has conducted, a feasibility study of several options and has elected to amend the..standard
operating procedures (SOPS) such that the ash will remain in the basin until it is loaded directly
onto trucks for distribution under the permit. A copy of the SOPs is attached_ In this way, the
facility will no longer maintain an ash stockpile on the ground surface. This storage method was
discontinued as of January 2006.
Please contact Lauren Billheimer at [phone] or me at [phone] if you have any
questions or require additional information.
Sincerely,
Ton opazd
Plant Manager
Attachment
cc: Ricky Styles
Lauren Billheimer (via -e-mail)
Tom Pannell (via e-mail)

r Ash Distribution and Sampling Procedure
Trigen-BioPower, Inc. — Marion, NC
Purpose
This procedure documents the procedures for preparation and distribution of ash; as well as the
collection of representative samples for environmental permit compliance.
Applicable Facilities
Marion, NC
Ash Preparation and Handling Procedures
• Fyyash is obtained from two locations
1. The sandbox, which contains dry ash from the dust collector
2. The scrubber ponds, through which the scrubber water is recycled and the ash is
settled
• The scrubber basin is divided into two sides (north and south). The water is generally
recycled through one side while ash from the other side is being prepared for distribution.
• Ash preparation includes air drying the pond to the extent possible, adding dry flyash from
the sandbox, and adding dry. wood sawdust as necessary to further reduce the moisture
content. The amount of wood added is tracked in the monthly DSR_ After the materials are
added, the product is mixed inside the basin using a front end loader.
• Samples are collected from the ash after it is prepared and prior to distribution for land
application.
Ash Distribution Procedures
Ash can be distributed for the uses approved in the ash distribution permit, Condition II.3.b,
according to the procedures below.
• All ash remains in the basin until the samples have been collected and analyzed. The ash is
loaded directly from the basin into trucks used for transport to the distribution site(s).
• Each ash recipient must receive and sign a copy of the Ash Information. Sheet prior to
receiving the ash. If a recipient receives more than one shipment/distribution in a calendar
year for the same use, only one form need be completed. -The Ash information Sheet contains
a summary of analysis results as well as procedures and limitations for applying the ash.
• The total tons of ash distributed to each recipient on each day, and the use of the ash, must be
recorded for reporting to NCDENR.
Ash Sampling Procedures
As required by the permit, representative samples must be collected after the ash is prepared and
prior to distribution. The table below documents the parameters and analysis frequency.
Currently, 6 samples per year are required for pH and total metals analyses. The schedule has
been incorporated into the EHS calendar.
VnA

Frequency*
Parameters
Limits_
4 times/yr if between 319-
pH & Total Metals (As, Ba, Cd,
See permit condition
1650 dry tons; or
Ca,Cr, Cu, Fe, Pb, Mg, Mn, Hg, Mo,
11.5. Not all parameters
6 times/yr if >1650 dry tons
Ni, P, K, Se, A , Na, Zn) `
have limits
Annually
Ignitability, Reactivity, & TCLP
See permit condition
Metals (As, Ba, Cd, Cr, Pb, Hg; Se,
111.3
A)
Once per permit cycle
Full TCLP
See permit condition
111.3
*Sampling frequency for metals & pH is based on the amount of each type distributed (pond ash,
mixed ash, etc.)
Sample Collection Procedures
• Collect samples from the prepared material so that results are obtained prior to distribution.
Because of the current schedule of preparing 3 pond sides per year, two composite samples
will be collected from each side after the ash is prepared.
• Using a clean shovel or a gloved hand, collect the same amount of ash from at least 5
different locations and depths on the pile.
• Place these sub -samples into the same plastic bucket, baggie, or glass jar (approximately 1
gallon total).
• After all the sub -samples are collected, mix the sample thoroughly by rolling or stirring.
Sample Preparation and Shipping
• Conduct pH analysis according to EPA Method 9045D
• Place portions of the mixed sample into the appropriate number of jars for shipment to the
required laboratories (approximately 1 quart to each lab). Prepare one additional jar/baggie to
keep on site until all the results are received and processed.
• Seal all sample containers and label the samples as "composite samples" and provide the
dates the original sub -samples were collected. Note this also on the forms that. are sent to the
laboratories.
• Shipping addresses are provided on the ash sampling sheets.
• The original reports will be forwarded to the Environmental Engineer for review and
processing, with a copy to the facility.
Referenced Documents/Forms
• Water Quality Permit No. WQ0010689
• Ash Information Sheet
• Facility Daily Status Report
• EPA Method 9045D
2 3/06

TRIGS' 1310130WER, INC.
TRIGEN
February 21, 2006.
VIA FEDERAL EXPRESS # 7903 27801776
NCDEIITR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: 2005 Annual Ash Report
Permit No. WQ0010689
Trigen-BioPower, Inc. (TBP), North Cove; NC
&OR
VEINED
Ftt� 2 2 2006
W oFER QUA6 ry
rillation Process9oN
ing Unit
Enclosed is the annual ash distribution report for calendar year 2005, using the forms provided
by NCDENR-DWQ. During 2005, ash was distributed in only one form. Flyash that was settled
in the scrubber ponds was mixed with flyash from the multicyclone and dry wood to reduce the
moisture content. The ash was distributed for land application in this form.
An average moisture content was obtained from several samples collected and analyzed
periodically throughout the year. A composite sample was collected for chemical analysis from
the final product prior to distribution. All samples were analyzed by Pace Analytical Services,
Inc., a North Carolina -certified laboratory.
If you have questions or require additional information, please contact Lauren Billheimer at 704-
510-4372 or Tony Leopard at 864-374-3386.
Sinc ,
Ji R. Henslee
Vice President
Enclosures — DWQ Reporting Forms
Ash Distribution Records
1/23/06 Pace Analytical Services,`Inc. report
cc: NC Divisions of Water Quality (2 additional copies w/ enclosures) .
Ricky Styles
Lauren Billheimer (via e-mail, w/o enclosure)
T.A:"Pannell (via e-mail, w/o enclosure)
File: Marion ash reuse

ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
PERMIT #: WQ0010689 FACILITY NAME: Trigen-Biopower, Inc. - North Cove
PHONE: [phone] COUNTY: McDowell OPERATOR: Trigen-BioPower, Inc.
FACILITY TYPE (please check one): ❑ Surface Disposal (complete Part A (Source(s) and "Residual In" Volume only) and Part C)
0 Distribution and Marketing (complete Parts A, B, and C)
Wac the facility in nnerntinn during the nast calendar vear? R Yes ❑10 No If No skip parts A, B, C and certify form below
Part A*:
Part B*:
Volume (dry tons)
Recipient Information
Month
Sources(s) (include NPDES # if
applicable)
Amendment/
Residual In
Product Out
Name(s)
Volume (dry
Intended use(s)
Bulking.Agent
tons)
January
February
Flyash with wood
277
Henry Brown
277
Land Appli
March
Flyash with wood
273
Henry Brown
273
Land Appliu.
April
May
June
Flyash with wood
309
Glen Aldridge
309
Land Applic.
July
August
Flyash with wood
383
S. Carpenter, H. Brown
383
Land Applic.
September
October
November
December
Totals:
Annual (d tons):
0
0
1242
1242
Amendment s) used:
NA
Bulking Agent(s)
used:
NA
* If more space than given is required, please attach additional information sheet(s). ❑p ChecK box it additional sneegs) are auacnCu
Part C:
Facility was compliant during calendar year 2005 with all conditions of the permit (including but not limited to items 1-3 below) issued by the
Division of Water Quality. 0 Yes ❑ No If No, please provide a written description why the facility was not compliant.
1. All monitoring was done in accoraance with the permit and reported for the year as required and three (3) copies of certified laboratory results are attached.
2. All operation and maintenance requirements were compiled with or, in the case of a deviation, prior authorization was received from the Division of Water
Quality.
3. No contravention of Ground Water Quality Standards occurred at a monitoring well.
"I cer-tif , under penalty of law, that the above information is, to the best of my knowledge and belief, true, accurate and complete. I am aware
th t th re are si n' scant�peniesor submitting false information, including the possibility of fines and imprisonment for knowing violations."
Sign re of Permittee Date Signature of Preparer** Date
(if different from Permittee) **Preparer is defined in 40 CFR Part 503.9(r)
DENR FORM DMSDF (11/2005)

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding Annual Report
Please note that your permit may contain additional parameters to be analyzed than those required to be summarized on this form.
Permit Number: WQ0010689 Laboratory: 1) Pace Analytical Services, Inc.
Facility Name: Trigen-BioPower, Inc. - North Cove 2)
NPDES # or WQ0010689 3)
WQ#:
4)
WWTP Name: 5)
7?nei���.il An.�lveie llafa
Sample • CompositeDate
�--
PercentSolids
-�u
i i
--_--_-_--_
MiNne0674 '
®-----------
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. 1 am aware that there are
Sig ' is nt penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
,L
Sig tore of Preparer Date
DENR FORM RSSF (5/2003)

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding Annual Report
Please note that your permit may contain additional parameters to be analyzed than those required to be summarized on this form.
Permit Number: WQ0010689 Laboratory: 1) Pace Analytical Services, Inc.
Facility Name: I Trigen-BioPower, Inc. - North Cove 2)
NPDES # or WQ0010689 3)
WQ#:
4)
WWTP Name: 5)
DaviAxia] Arnalveie data
Sample or
CompositeDate
-��--
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. 1 am aware that there are
Sig n'fi nt penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
�_ Z/_v -6
Si attire of Preparer Date
DENR FORM RSSF-B (5/2003)

Trigen-BioPower, Inc. - North Cove (Marion)
Ash Distribution Tracking
Permit No. WQ0010689
Ash Invento
Approx. Amt.
Tons Dry
Tons Ash
Remaining in
Ash
Date
Reused
Type Ash
Recipient
Inventory
Comments
% DryAsh
Distributed
1/1/05
FI ash w/ wood
most of pile carried over
2/5/05
South side prepared
/26t
( `astr wJroo
Hef i Brown
x
42°f77
y
FI
; Eown
em
4,.
3 Q
rs w/ yrro©d
,Hen , ,
... , .F.a"
North side prepared
6/5/05
6/13JE
2
I=I
Glen<Aldrl
7i32 . -.
,ashy/wd6d�;,
South side prepared
8/4/05
8/410
gg 4 2
6
,
-.. ,f.F
FIsshwJood
Hen .rIibwn,e2; ;�
e ..... ..
�� ..,.
" .. 29705'.
12/31/05
irry over to 2006
1054.9 Total tons as hauled 2005
Total dry ash
"w12W2
Note: Flyash with wood includes flyash from both sandbox and pond plus wood added to lower moisture content
roan ruIIu r+a.uvu
Ash Moisture as
Tons Water
Pond Side
Tons Wood
Wood Moisture as
Hauled
+ Wood dry
Tons Dry
Date
Prepared
Added
added
(measured)
Tons Distributed
matter
Ash
% Dry Ash
11/30/04
North
60.
36% ..
53.1%
765
445
320
42%
3/5/05
South
100
10%
53.1 %
780.71
505
276
35%
6/5/05
, North
80.
10%
45.8%
702.21
394
309
44%
8/5/051
South
60
10%
51.9%
9121
527
385
42%
To get dry ash:
- Subtract out water from total moisture
- Subtract out wood (dry matter)
- Remaining is dry ash

ace Analytical
www.pacelabs.com
January 23, 2006
Ms. Lauren Billheimer, P.E.
Trigen-BioPower, Inc.
1931 Winsted Ct.
Charlotte, NC 28262
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone; 704.875.9092
Fax., 704.875.9091
RE: Lab Project Number: 92110938
Client Project ID: Marion Fly Ash
Dear Ms. Billheimer, P.E.:
Enclosed are the analytical results for sample(s) received by the laboratory on January 9, 2006. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
Kate Knauff
[e-mail]
Project Manager
Enclosures
Asheville Certification i IN
NC Wastewater
' 40
NC Drinking Water
37712
SC Environmental
99030
FL NELAP
E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
o,p ACCCq,
l f.
nE -sl
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627

ace Analytical °
www,pacelabs.cam
Solid results are reported on a dry weight basis
Lab Sample No: 926520818
Client Sample ID: MARION FLY ASH
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax: [phone]
Lab Project Number: 92110938
Client Project ID: Marion Fly Ash
Project Sample Number: 92110938.001 Date Collected: 01/06/06 00:00
Matrix: Soil Date Received: 01/09/06 11.00
Parameters Results Units Report Limit DF Analyzed By CAS No. Qual RegLmt
Metals
Trace ICP Metals, TCLP Leach. Method: EPA 6010
Date Digested 01/12/06 12:00 01/12/06 12:00
Trace ICP Metals, TCLP Leach
Arsenic
Barium
Cadmium
Chromium
Lead
Selenium
Silver
Date Digested
Metals, Trace ICP
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Molybdenum
Nickel
Potassium
Selenium
Silver
Sodium
Zinc
Date Digested
Prep/Method: EPA 3010 / EPA 6010
0.030
mg/l
0.025
.3.2
mg/l
0.025
ND
mg/l
0.0050
0.015
mg/l
0,010
ND
mg/1
0.025
NO
mg/l
0.025
NO
mg/1
0.010
01/13/06 09:40
Prep/Method: EPA 3050 / EPA 6010
7.5
mg/kg
0.92
1300
mg/kg
0.92
NO
mg/kg
0.18
70000
mg/kg
37.
34.
mg/kg
0.37
87.
mg/kg
0.37
21000
mg/kg
18.
19.
mg/kg
0.92
14000
mg/kg
18.
2100
mg/kg
1.8
1.5
mg/kg
0.92
26.
mg/kg
0.92
24000
mg/kg
1800
NO
mg/kg
0.92
ND
mg/kg
0.37
6700
mg/kg
370
170
mg/kg
1.8
01/12/06 10:30
1.0
01/14/06
JDA1
7440-38-2
1.0
01/14/06
JDA1
7440.39.3
1.0
01/14/06
JDA1
7440-43-9
1.0
01/14/06
JDA1
7440-47.3
1.0
01/14/06
JDA1
7439.92-1
1.0
01/14/06
JDA1
7782.49-2
1.0
01/14/06
JDA1
7440-22-4
01/13/06 09:40
1.8 01/14/06 14:17 ALV 7440-38-2
1.8 01/14/06 14:17 ALV 7440.39-3
1.8 01/14/06 14:17 ALV 7440-43-9
3.7 01/14/06 14:17 ALV 7440-70.2
1.8 01/14/06 14:17 ALV 7440-47-3
1.8 01/14/06 14:17 ALV 7440-50-8
3.7 01/14/06 14:17 ALV 7439.89-6
1.8 01/14/06 14:17 ALV 7439.92-1
1.8 01/14/06 14:17 ALV 7439-95-4
3.7 01/14/06 14:17 ALV 7439.96-5
1.8 01/14/06 14:17 ALV 7439-98-7
1.8 01/14/06 14:17 ALV 7440.02-0
18.4 01/14/06 14:17 ALV 7440.09.7
1.8 01/14/06 14:17 ALV 7782-49.2
1.8 01/14/06 14:17 ALV 7440-22.4
3.7 01/14/06 14:17 ALV 7440-23-5
1.8 01/14/06 14:17 ALV 7440-66-6
01/12/06 10:30
Mercury, CVAAS, TCLP Leachate Method: EPA 7470
Mercury ND mg/l 0.00020 1.0 01/13/06 11:30 ALV 7439-97-6
Mercury, CVAAS, in Soil
Date: 01/23/06
Asheville Certification IDs
NC Wastewater 40
NC Drinking Water 37712
SC Environmental 99030
FL NELAP E87648
Method: EPA 7471
Page: 1 of 3
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full, Charlotte Certification IDs
without the written consent of Pace Analytical Services, Inc. NC Wastewater 12
N ACCOgo^ NC Drinking Water 37706
SC 99006
nc = FL NELAP E87627

ace Analytical
www.pacelabs.com
Lab Sample No: 926520818
Client Sample ID: MARION FLY ASH
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax. [phone]
Lab Project Number: 92110938
Client Project ID: Marion Fly Ash
Project Sample Number: 92110938-001 Date Collected: 01/06/06 00:00
Matrix: Soil Date Received: 01/09/06 11:00
Parameters
Results
Units
Report Limit
DF
Analyzed
By
CAS No. Qual ReciLmt
Mercury
ND
mg/kg
0.0088
1.8
01/17/06
15:37
ALV
7439.97-6
Wet Chemistry
Percent Moisture
Method: X Moisture
Percent Moisture
51.5
M
1.0
01/10/06
16:22
TNM
Total Kjeldahl Nitrogen, Soil
Method: EPA
351.2
Nitrogen. Kjeldahl, Total
920
mg/kg
21.
2.1
01/11/06
19:20
CD1
Nitrogen, Nitrate plus Nitrite
Method: EPA
353.2 Modified
Nitrate as N
ND
mg/kg
21.
2.1
01/11/06
20:11
CD1
Nitrate -Nitrite (as N)
ND
mg/kg
21.
2.1
01/11/06
20:11
CD1
7727.37-9
Nitrite as N
ND
mg/kg
21.
2.1
01/11/06
20:11
CD1
Phosphorus, Total, Soil
Method: EPA
365.2
Phosphorus
1420
mg/kg
468.
46.8
01/19/06
23:D5
ARE
7723-14.0
PH
Method: EPA
9045
PH
10.3
units
1.0
01/17/06
14:00
TMR
Date: 01/23/06
Asheville Certification IDs
NC Wastewater 40
NC Drinking Water 37712
SC Environmental 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
,n ACC,,
mems.
Page: 2 of 3
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
Sc
99006
FL NELAP
E87627

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Analytical' Huntersville, NC 28078
Phone: [phone]
www.pacelabs.com fax: [phone]
Lab Project Number: 92110938
Client Project ID: Marion Fly Ash
PARAMETER FOOTNOTES
Dilution factor shown represents the factor applied to the reported result and reporting limit due to changes
-in sample preparation, dilution of the extract, or moisture content
Method 9071B modified to use ASE.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 01/23/06
Asheville Certification IDs
NC Wastewater 40
NC Drinking Water 37712
SC Environmental 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
,N ACCpq�
O
f nelac
Page: 3 of 3
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

Jan, 11. 2006 3:36AM
No.0399 P. 1
PRECISION PETROLEUM LASS, INC.
5915 Star Lane Houston, TX 77057
Ph.713-680-9425 Fax:[phone]
CERTIFICATE OF ANALYSIS
COM]?ANY: PACE .ANALYTICAL
INVOICE No.: 28776
LAB REFERENCENo.: 2006-01-297
PRODUCT ID: 929620818 / MARION FLY ASH 01-06-2006
DATE RECEIVED: 01-10-2006
AUTHORIZED BY: KATE KNAUFF
PAREkMETER
Sulfzu, W/O
TEST
D-4294
REPORTING TEST
LMT RESULT
0.001 0,0138
BRL=BELOW REPORTING LEVM
PRECISION PETROLEUM LASS, WC.'S RESPONSMRXfY FOR THE ABOVE ANALYSIS,
OPMONS OR WrWRETA.TIONS IS LIMITED TO THE INVOICE AMOUNT.

TRIGEN-BIOPOWER, INC.
m
TRIGEN
Please test the sample(s) for the parameters as listed in the below table.
Send invoice and copy of results to:
Ricky Styles
Trigen-BioPower, Inc.
2859 Old Linville Rd.
Marion, NC 28752
(828) 7564946
(fax) 756-7160
Send original results to:
Lauren Billheimer
Trigen-BioPower, Inc.
1931 Winsted Ct
Charlotte, NC 28262
[phone]
(fax) 510-4230
4- 1 a _
q 1)D913�
Sample #
Sample Description
Sample Date(s)
Grab or
Composite
pH
Total Metals - As, Ba,
Cd, Cr, Cu, Fe, Pb, Mg,
Hg, Mn, Mo, NI,g Se,
TCLP Metals - As,
Ba, Cd, Cr, Pb, Hg,
Se, Ag
1
Marion Fly Ash
Composite
X
X
X
Sample sent to: Kate Knauff
Pace Analytical
9800 Kincey Ave., Suite 100
Huntersville, NC 28078
(704) 875 - 9092
�'�vs- 1 is ICE

�i�en ZiopoLU No, Vh �G B/t
Annual Report Review SOP
1.. Annual Land Application Certification Form
-
• Was a certification form submitted?Y&S
• Was land application conducted during the reported year? N A 6-A- 04-161-n
• How many dry tons and dry tons per acre were applied? NA
• Were the applications within the permitted amount? N A .
• Verify PAN if more than 10 tons/acre N.4
• Did it indicate compliance? yes
• Was it signed by the appropriate people? ,qe,S
2. Monitoring
• Were the analyses conducted at the required frequency? I-eS
• Were the metals analyses reported on the Residual Sampling Summary Form? Y.e'
• Were the results reported in mg/kg?
• , _ Were the heavy metals within ceiling concentration permit limits?* j4s 10Ai u-
• If no, were the lab analyses attached? o POI n '
• Were all the required parameters tested? `� �� w+� �%� t I o ,
• Was TCLP analysis conducted? �S b" no 3 rS��adl 0' �--�Y r �yo
. R���3✓4 ��a�ddL . �
3. Field Summary M Pt 't svi- fide
• Were the land applicationevents recorded on the Field Summary Forms?-#
• Was a Field Summary Form submitted for each field?
• Were all the residuals applied to permitted land?
• Were all the residuals applied from permitted sources?
• Were the field loading rates for each metal and PAN calculated (year to date)?
• Were the cumulative pollutant loading rates calculated?
• Were the calculations correct?
• Were the PAN loading rateswithin permit limits?
• Were the heavy metal cumulative pollutant loading rates within permit limits?
• Were the residuals applied on a suitable crop?
• Were the applications conducted during the crop's growing season?
• Were the Field Summary Forms complete?
4. Pathogen and Vector Attraction Reduction gR
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?
• Did the ,form indicate the period of coverage, the residual class, and the pathogen reduction alternative and the
vector attraction reduction option used?
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the report?
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?
5. Soil Tests N A
• Was a Standard Soil Fertility Analysis conducted for each application field?
• Were the soil pH's 6.0 or greater for each application field?
• Were the copper and zinc indexes in the soil less than 3000 for each application field?
6. General
• Was the report in the proper format? nLui S
• Were any parts of the annual report missing? Na
• Was the report submitted on time? �,C,g
* Any violations of ceiling concentrations should be reported to Pretreatment for municipalities only.

C�O� WA rqp r Michael F. Easley, Governor
\� G William G. Ross Jr. Secretary
�q North Carolina Department of Environment and Natural Resources
r
1 Alan W. Klimek, P.E., Director
Division of Water Quality
t t l lW 1 t't iL s i j'
• •.December 28 .2005-
In 0
MR. TONY LEOPARD, REGIONAL PLANT MANAGER' C 1=3,02 p
i D EC ', 005.
TRIGEN-BIOPOWER, INC
302 DUKE STREET
FOREST CITY, NORTH CAROLINA 28043 ,
IsQ.
Subject., 2004 Annual Report Review
Permit No. WQ0010689.
- In
. . Trigeri BioPower,c."
North Cove Steam Generation Plant
Ash;Distribution Program
•
Distribution of Residual Solids (503 Exempt)
McDowell County
Dear Mr. Leopard:
The Division of Water Quality (Division)'s Land Application Unit acknowledges receipt of the
annual report for the 2004 calendar year submitted in support, of the above -referenced permit on February` -
24, 2005..
The Division has performed athorough, technical review of the information presented in this
annual report. Based on this review, the Division cannot state that the ash distribution program is in
compliance . with the conditions of .Permit No. WQ001"0689, issued on July 7, 2000.. At. this time,
however, the Division has decided .-not to take any, compliance or enforcement action' against Trigen
BioPower, Inc. in relation to this annual report review.:.This correspondence does not preclude further
action by the Division for additional violations of any applicable statutes, regulations; or permits..
The following review comments are being provided for informational purposes only so that future
operations and annual reports preparation procedures may ,be adjusted to avoid potential compliance
r problems:.
1. .The proper 'certification and; summary form, that details the annual ash marketing and-
distribution activities (i.e., Form DMSDF) was not prepared and submitted. A copy -of this. "
form is'enclosed herein for review and reference. An electronic version of this form is,also
available for download from www.ncwaterquality.org/lau/main.htinl
2. , Condition III. 2. of the existing permit requires that the source, volume, and analysis"'of each
ash be recorded and, included in the' annual report. As ,the information .was presented, the .
Division cannot discern which ashes (i.e., scrubber; fly, bottom ashes) were distributed, to
whom they were distributed, and whether or not these were distributed as a mixed product or
three separate products or even under both scenarios. Since the results of only one analytical .
sample was presented, the Division assumes -that the ashes were distributed as a mixture such
that , this sample was representative of what was distributed. Please . ensure that this ,
information is recorded and that sampling is conducted such that it is representative of the.
product distributed in the future:. The"proposed.,renewed/modified draft permit attempts to" ;
address this issue as well.,. N°nhC o arolina
NatmallY
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: www.ncwaterquality.org 2728 Capital Boulevard . , 'Raleigh, NC, 27604 Fax [phone], ,
L Fax [phone] `.
An Equal Opportunity/Affirmative Action Employer - 50% Recycled110% Post Consumer Paper

Mr..Tony Leopard
December 28, 2005
Page 2
3. Condition "III. 3 of" the- existing permit requires that the ash be analyzed `-`using the TCLP
method" for several parameters. The results presented in the annual reports include total
concentrations for all of the parameters listed in this condition and TCLP analyses for the
metal parameters only. Therefore, there were several parameters not analyzed in the leachate
generated by the TCLP. Although the Division understands that there was some confusion on
�hcppart of the Permittee as to what was intended by this condition, Trigen-BioPower, Inc.
should have requested clarification from the Division and not assumed an intent.. The
proposed renewed/modified draft permit attempts to clarify the desired monitoring scheme.
Be aware that Form RSSF and Form RSSF-B should be prepared to summarize the results of
all of the residuals analysis for the annual report (i.e., except for TCLP results which may be
presented simply by -including the laboratory report). A copy of .each of these forms is
enclosed herein for review and reference. Electronic versions of these forms are also
available for download from www.ncwaterquality.org/lau/main.html.-
4. Much of, the analytical work presented in the annual report was completed by the NC
- Department of Agriculture and Consumer- Services laboratory. This laboratory is not
currently certified by the Division to complete analytical work required for the purposes of
compliance with a Division -issued permit (i.e., with the exception : of animal waste
management permits).. Please ensure that a laboratory that has been Division -certified for the
- particular parameter being analyzed is used in the future. The proposed renewed/modified
draft permit attempts to address this issue as well.
5. The laboratory report prepared by Pace Analytical Services, Inc. states that the pH analysis
was "conducted outside of . EPA recommended immediate hold time." The Division
recommends that this issue be discussed with the Division -certified laboratory to ensure that a
valid analytical result is received in the future.
Please be aware that nothing in this correspondence should be construed as removing Trigen-
BioPower, Inc. from the responsibility for complying with its permit in full. If you need any additional
information concerning this correspondence, please do not hesitate to contact me by telephone at (919)
715-6167 or via e-mail at [e-mail].
Si erely,
Shannon Mohr Thornburg
Environmental Engineer II
Land Application Unit
Enclosures
cc: Ms. Lauren Billheimer, T rigen-BioPower, Inc.
Ms: Bev Price,AshevillelRegional Office==Aquifer ProtectioriRSecti_on
APS Central Files - Permit File WQ0010689

ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
PERMIT,#: FACILITY NAME:
. PHONE: COUNTY: OPERATOR:
FACILITY TYPE (please check one): ❑ Surface Disposal (complete Part A (Source(s) and "Residual In" Volume only) and Part C) .
❑ Distribution and Marketing (complete Parts,A, B, and C)
Was the facility in operation during the past calendar _year? ❑ Yes ❑ No No If No skin Darts A. B. C and certifv form below
Part A*:
Part B*:.
Month
Sources s include NPDES # if
(
applicable)
Volume (dry tons)
Recipient Information
Amendment/
Bulking Agent
Residual In
Product Out
Name(s) .' ,
Volume (dry
tons)
Intended use(s)
January
February
March
April .
May'
June
July
August
September
October .
November
December
Totals:
Annual (dry tons):
Amendment(s) used:
Bulking Agent(s)used:
OF It more space than given is required, please attach additional information sheet(s). ❑ Check box if additional sheet(s) are attached .
Part C:
Facility was compliant during calendar year with all conditions of the permit (including but "not limited to items 1-3 below) issued by the
Division of Water Quality., ❑ Yes ❑ No If No, please provide a written description why the facility was not compliant.
1. All monitoring• was done in accordance with the permit and reported for the year as required and three (3) copies of certified laboratory results are attached
2. All operation and maintenance requirements were compiled with or, in the case of a deviation, prior authorization was received -from the Division of Water
Quality.
3. No. contravention of Ground Water Quality Standards occurred at a monitoring well.
"I certify, under penalty of law, that the above information is, to the best of my knowledge and belief, true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations:"
Signature of Permittee ; Date Signature of Preparer** Date
(if different from Permittee) **Preparer is defined in 40 CFR Part 503.9(r)
DEN FORM DMSDF (11/2005)

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding Annual Report
Please note that your permit may contain additional parameters to be analyzed than those required to be summarized on this form
Permit Number: _
Laboratory: 1)
Facility Name:
2)
NPDES # or
3)
WQ#:
4)
WWTP Name:
5)
Residual Analvsis Data
Sample or
one R. no
"I certify, under.penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Signature of Preparer
Date
DENR FORM RSSF (5/2003)

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding Annual Report
Please note that your permit may contain additional parameters to be analyzed than those required to be summarized on.this form.
Permit Number: Laboratory: 1)
Facility Name: 2)
NPDES # or 3)
WQ#:
4)
WWTP Name: 5)
Residual Analvsis Data
Sample or
M, 'Composite Date
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Signature of Preparer
Date
DENR FORM RSSF-B (5/2003)

Re: DRAFT Permit No. WQ0010689 (Trigen-BioPower, Inc. - North...
Subject: Re: DRAFT Permit No. WQ0010689 (Trigen-BioPower, Inc. - North Cove Steam Generation
Plant Ash Distribution Program)
From: Shannon Mohr Thornburg <[e-mail]>
Date: Tue, 27 Dec 2005 13:29:39 -0500
To: "Billheimer, Lauren" <[e-mail]>
CC: Bev Price <[e-mail]>
Lauren:
It was no problem! I, too, enjoy working through issues ahead of time so that all parties know what is
expected. I've attached a revised draft of the permit for your review. As we discussed on the telephone
before the holidays, here are the changes that I have made:
* I changed the mailing address for the permit. This has also been changed in our
database.
* Condition I.2. has been added to the permit to require you to conduct an
assessment/feasibility study of alternatives to the on -site storage/stockpile site. There are
three options from which to choose, each of which have subsequent compliance schedule
deadlines ... I added one that we didn't discuss, which was to simply change the SOPs for the
facility such that the site does not have to be used at all.
* Condition III. 3. has been modified to require analysis of metal constituents in leachate
from TCLP on annual basis and full TCLP once a permit cycle.
* Condition 111. 4. has been modified to allow you to request a permit modification to
reduce monitoring frequency after two years of monitoring at the specified frequency.
The permit for the Forest City program is very similar except, of course, there is no similarly worded
Condition I.2. or optional groundwater monitoring program because there is not an on -site ash
storage/stockpile site.
Let me know what you think!
Shannon
Billheimer, Lauren wrote:
Shannon,
Thanks for discussing our issues yesterday and for your help in making the modifications needed to
make this a good, workable permit. Would you mind sending me another draft when you have it
complete, just so I can look over it before it goes for signature? I've found that it's always a smoother
transition if we get a chance to review and comment before the permit goes final.
Thanks,
Lauren
1 of 3 12/28/2005 1:02 PM

Re: DRAFT Permit No. WQ0010689 (Trigen-BioPower, Inc. -North...
Lauren Billheimer
Trigen-BioPower, Inc.
1931 Winsted Ct.
Charlotte, NC 28262
[phone] phone
(704) 9534398 mobile
lauren.billheimera-suezenergyna.com
From: Shannon Mohr Thornburg[mailto:[e-mail]
Sent: Tuesday, December 13, 2005 2:30 PM
To: Billheimer, Lauren
Cc: Bev Price; TED LYON
Subject: DRAFT Permit No. WQ0010689 (Trigen-BioPower, Inc. - North Cove Steam
Generation Plant Ash Distribution Program)
Lauren:
Thanks again for your help understanding things this morning!
I talked to Ted Lyon after our conversation, and he said- that he had no objection to our
covering the dry ash under this permit so that you can manage all of the ash under one
program.
As per our discussion, I've attached a draft of the proposed permit for North Cove's program.
The one for Forest City's program will be substantially the same. As you will see, this is
vastly different than the last permit we issued.
Please let me know what you think or if you have any questions, comments, or suggestions. It
would be great to hear back by close of business. tomorrow so that I can turn these permits in
for signature. '
Thanks!
Shannon
Shannon Mohr Thornburg, Environmental Engineer
Land Application Unit
Aquifer Protection Section
NCDENR-DWQ
Telephone: [phone]
Fax: [phone]
shannon.thornburg(ancmail.net
Mailing Address:
1636 Mail Service Center
Raleigh, NC 27699-1636
Physical Address:
2728 Capital Boulevard, Room No. 1C 130
Raleigh, NC 27604
http://h2o.enr.state.nc.us/ndpu
Q0010689p051230.doc Content -Type: application/msword
W
Content -Encoding: base64
;i
2 of 3 12/28/2005 1:02 PM

AQUIFER PR,-, - ECTION .REGIONAL S1 _-_FF REPORT
�, tDate-I 12/05/05 Coun McDowel == ,:
To: Aquifer Protection Central Office Permittee: Trigen-Biopower, Inc.
Central Office Reviewer: Shannon Thornburg ProjectWame: North Cove Steam
Generation Plant Ash Reuse
Regional Login No: Application No.: W00010689
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New 0 Renewal
❑ Minor Modification N Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration.Lagoon
❑ Land Application of Residuals ❑ Attachment B included 0 503'regulated ® 503 exempt
® Distribution of Residuals ❑ Surface Disposal
❑:Closed -loop Groundwater Retnediation ❑ Other Injection Wells. (including in situ remediation)
Was: a site visit conducted inorder to prepare this report? ® Yes or ❑ No.
a. Date, of site visit: 10/11/05
b.. Person contacted and contact information: Ricky Stiles, Plant Superintendent 828-756-4946
c. Site visit conducted by:. Beverly Price
d. . Inspection Report Attached:.® Yes or ❑ No.
2. Is the following information entered into the BIAS record for this application correct? .
N Yes or' JZNo.: If no, please complete the following or indicate.that it is correct on the current application. .
For Treatment Facilities:
a.- Location:
b. Driving Directions: 'Take Hwy. 221 N out of Marion to SR 1560 (located behind Baxter, North Cove).
Trigen is located on the left.
c. USGS Quadrangle Map name and number: Ashford, NC D11SW
d. Latitude: Correct Longitude: Correct
.0. ' Regulated Activities / Type of Wastes (e.g., subdivision, food processing; municipal wastewater): Bottom,
a Location(s):
b. >Driving Directions:
c USGS Quadrangle Map name and number:
d. Latitude: Longitude:
II. NEW AND MAJOR MODIFICATIONAPPLICATIONS (this section not needed for renewals or minor
modifkatiom,'skio to next section).
Description Of Waste(S) And Facilities
FORM: WQ0010689 Staff Report05.doc 1

AQUIFER PR#tECTION REGIONAL SF REPORT
1. Please attach completed rating sheet. Facility Classification: N/A
2. Are the new treatment facilities adequate for the type of waste and disposal system?
❑ Yes ❑ No ® N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ® N/A. If no, please explain:
4. _ Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑ No ® N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ® Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
❑ Yes ❑ No ® N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes. ❑ No ® N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there. any buffer conflicts (new treatment facilities or new disposal sites)? [:]:Yes'or Z. No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the . applicant to be
incorporated into the permit:
9. Is,..proposed and/or existing groundwater monitoring program (numberof wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ® N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain: and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ® N/A 'If yes, attach list of sites
with restrictions (Certification B?)

AQUIFER Pik.-'ECTIGN REGIONAL ST = _J F REPORT
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain:
5. Is the residuals management plan.for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate.the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or .❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply:..❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined .❑ N/A.. If no, please explain:
15. Are there.any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes,, please explain:
FORM: WQ0010689 Staff Report05.doc 3

AQUIFER PRo A ECTION REGIONAL S'i xFF REPORT
IV INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.) N/A
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
❑ In situ remediation (51)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: )
2. Does system use same well for water source and injection? ❑ Yes ❑ No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ❑ No
What is/are the pollution source(s)? What is the distance of the injection wells from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? ft.
5. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ❑ Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Infection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If Yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If ems, explain:
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. If explain:
4. Drilling contractor: Name:
FORM: WQ0010689 Staff Report05.doc 4

AQUIFER PR _ 'ECTION REGIONAL S1___FF REPORT
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
FORM: WQ0010689 Staff Report05.doc

AQUIFER PR9ECTION REGIONAL STtF REPORT
V EVAEUATIONAND RECOM11ENDATIONS
1. Provide any additional narrative regarding your review of the application.:
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6., List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information;
Issue;, ❑ Deny. If deny, please state reasons:.
8. Signature of report preparer(s)
Signature of APS regional sups
Date: i.-2 -S' 07
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQ0010689 Staff Report05.doc 6

Jr�"H/F
Michael F. Easley, Governor
ID William G. Ross Jr., Secretary
> i�V V� r North Carolina Department of Environment andNatura] Resources
p Alan W. Klimek, P.E. Director
Division of Water Quality
Aquifer Protection Section,
e
October 11, 2005
Mr. Tony Leopard, Regional Plant Manager
Trigen-Biopower, Inc.
Post Office Box 422
Hodges, SC 29653
Subject: Compliance Evaluation Inspection
Status: In Compliance
Trigen-Biopower-Marion Facility
Distribution of Residual Solids
Permit No. W00010689
McDowell County
Dear Mr. Leopard:
I conducted a routine compliance inspection of the distribution of residual solids system serving the Trigen-
Biopower-Marion Facility on October 4, 2005. The assistance of Mr. Ricky Styles was greatly appreciated during the
inspection. The following observations are offered: -
1. The maintenance and inspection records were very good.
2. A subsequent review of the 2004 Annual Report showed compliance with permit monitoring and reporting
conditions.
3.. There was no evidence of a discharge from the system.
4. You are currently operating under an expired permit — permit renewal application was submitted
3/26/2004. Permit is in review status.
5.: Land application was not occurring at the time of the inspection. As such, it is requested that you contact
me before the next residuals application in order that I might inspect the actual land application process.
Should you or your staff•have any questions regarding'this or any other water quality issues; please contact me
at [phone].
Sincerely, fJ'
Beverly Price
Environmental Specialist
Enclosure
Cc: Ricky Styles, Plant Superintendent Trigen-Biopower, Inc., 2859 Old Linville Road Marion, NC 28752
Lauren Billheimer, PE, Project Engineer Trigen-Biopower, Inc. 1931 Winsted Court Charlotte, NC 28262
McDowell County Health Department 408 Spaulding Road Marion, NC 28752.
Not thCarolina
• ✓1�a�irrallf
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Hi,ghway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

comp lance nspCLAIon f'XVport
. Permit: . VVQ0010089 Effective: 07/07/00 Expiration: 06/30/05 Owner: Trigen-Biopower, Inc.
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Reuse Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Marion NC 28752
Contact Person: Tony Leopard Phone: [phone] Ext.
Directions to Facility:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Ricky Styles Phone: [phone]
24 hour contact name Ricky Styles Phone: [phone]
Related Permits:
Inspection Date: 10/04/2005 Entry Time: 10:30 AM Exit Time: 11:25 AM
Primary Inspector: Beverly Price Phone:
Secondary Inspector(s):
Phone:
Phone:
Reason for Inspection: Routine . Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
Inspection Summary:
Maintenance/inspection records were very good.
No evidence of discharge from the system.
Review of the 2004 Annual Report shows compliance with permit monitoring reporting conditions.
Land application was not occurring at the time of inspection.
Permit expired June 30, 2005 - Permit renewal application submitted March 26, 2004.. Permit is in review status.
Approximately 2 months sandbox.ash currently stockpiled on site.
Page: 1

Permit: WQ0010689 Owner- Facility: Trigen-Biopower, Inc.
Inspection Date: 10/04/2005 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Record Keeping
Yes
No
NA NE
Is GW monitoring being conducted, if required?
n
n
NO
Are GW samples from all MWs sampled for all required parameters?
n
n
■ n
Are there any GW quality violations?
n
❑
■ n
Is GW-59A certification form completed for facility?
n
n
■
Is a copy of current permit on -site?
■
n
n n
Are current metals and nutrient analysis available?
■
n
Cl 0
Are nutrient and metal loading calculating most limiting parameters? `
n
n
■ n
a. TCLP analysis?
■
❑
n 11
b. SSFA (Standard Soil Fertility Analysis)?
n
n
■
Are PAN balances being maintained?
■ n .
Are PAN balances within permit limits?
n
Fj
■ n
Has land application equipment been. calibrated?
n
❑
■ n
Are there pH records for alkaline stabilization?
n
n
■
Are there pH records for the land application site?
n
n
■ rl
Are nutrient/crop removal practices in place?
n
n
■ n
Do lab sheets support data reported on Residual Analysis Summary?
n
n
■ n
Are hauling records available?
■
n
n n
Are hauling records. maintained and up-to-date?
■
❑
n n
Has permittee been free of public complaints in last 12 months?
■
, n
n n
Has application occurred during Seasonal Restriction window?
n
n
■ n
Comment:
a

Michael F. Easley, Governor
William G.Ross Jr., Secretary
North Carolina Department of Environment andNatural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Aquifer Protection Section
October 11, 2005
Mr. Tony Leopard, Regional Plant Manager
Trigen-Biopower, Inc.
Post Office Box 422
Hodges, SC 29653
Subject: Compliance Evaluation Inspection
Status: In Compliance
Trigen-Biopower-Marion Facility
Distribution of Residual Solids
Permit No. W00010689
McDowell County
Dear Mr. Leopard:
I conducted a routine compliance inspection of the distribution of residual solids system serving the Trigen-
Biopower-Marion Facility on October 4, 2005. The assistance of Mr. Ricky Styles was greatly appreciated during the
inspection. The following observations are offered:
1. The maintenance and inspection records were very good.
2. A subsequent review of the 2004 Annual Report showed compliance with permit monitoring and reporting
conditions.
3. There was no evidence of a discharge from the system.
4. You are currently operating under an expired permit - permit renewal application was submitted
3/26/2004. Permit is in review status.
5. Land application was not occurring at the time of the inspection. As such, it is requested that you contact
me before the next residuals application in order that I might inspect the actual land application process.
Should you or your staff have'any questions regarding this or any other water quality issues, please contact me
at [phone].
Sincerely,
14
G<. P"V-�-t
Beverly Price
Environmental Specialist
Enclosure
Cc: Ricky Styles, Plant Superintendent Trig en-Biopower, Inc., 2859 Old Linville Road Marion, NC 28752
Lauren Billheimer, PE, Project Engineer Trigen-Biopower, Inc. 1931 Winsted Court Charlotte, NC 28262
McDowell County Health Department 408 Spaulding Road Marion, NC 28752 One
NorthCarolina
,Naturally
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

Compliance Inspection Report
Permit: WQ0010689 Effective: 07/07/00 Expiration: 06/30/05 Owner: Trigen-Biopower, Inc.
SOC: Effective: Expiration: Facility: North Cove Steam Generation Plant Ash
Reuse Program
County: McDowell 2859 Old Linville Rd
Region: Asheville
Contact Person: Tony Leopard
Directions to Facility:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
24 hour contact name
Related Permits:
Inspection Date: 10/04/2005
Primary Inspector: ' Beverly Price
Secondary Inspector(s):
Ricky Styles
Ricky Styles
Entry Time: 10:30 AM
Marion NC 28752
Phone: [phone] Ext.
Certification:
Exit Time: 11:25 AM
Phone:
Phone: [phone]
Phone: [phone]
Phone:
Phone:
Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
0 Miscellaneous Questions 0 Record Keeping
Inspection Summary:
Maintenance/inspection records were very good.
No evidence of discharge from the system.
Review of the 2004 Annual Report shows compliance with permit monitoring reporting conditions.
Land application was not occurring at the time of inspection.
Permit expired June 30, 2005 - Permit renewal application submitted March 26, 2004. Permit is in review status.
Approximately 2 months sandbox ash currently stockpiled on site.
Page: 1

Permit: WQ0010689 owner - Facility: Trigen-Biopower, Inc.
Inspection Date: 10/04/2005 Inspection Type: Compliance Evaluation
Type
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Reason for Visit: Routine
Page: 2

ComplianceInspection Report
Permit: WQ0068j Effective: -88 5e Expiration: t7f3t M-0- Owner: garrRiver-kw
SOC: Effective: Expiration: Facility: ver-Inc-ftarrisFinislfiirtg-R}ertt-B9RS
M.,.S�`) of
County:--Rtathefferd_ NV-bz,,W A =P6-S`M1
Region: Asheville
Contact Person: _ _G,e�- Phone:-8ft__ 2�Xt.
p
Directions to Facility:
Primary ORC: rDennis-Key R`�k`'I Certification: 457ja4. Phone: ` 3ir957 909
Secondary ORC(s): J
On -Site Representative(s):
24 hour contact name `f3a+rid-1AI-Kew R,c _�j +6 Cr-5 Phone: 336=957-99U
On -site representative Da�Nvi c J'�' d�� Phone: 336--957_-89A9
Related Permits: _
_69688.2--5 Qpfi4 veHner --F a"i% as
Inspection Date: io l i{1®S Entry Time: (� � Exit Time:
Primary Inspector: Beverly Price Phone:
Secondary Inspector(s):
Phone:
Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 exempt)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site Storage Transport
Inspection Summary'
�slrlit,i�� l:..l,��p--'� � c�d>�n��r'ir-.'�•-�Z.Ifl�✓.�9� �
I,Uq 0oIc) 15I ,- 12�1liLDC, C � S42,,"
Page: 1

Permit: WQ0008799 Owner - Facility: Dan River Inc
Inspection Date: Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes
No
NA
NE
Is GW monitoring being conducted, if required?
n
n
01
n
Are GW samples from all MWs sampled for all required parameters?
fl
❑
n
Are there any GW quality violations?
n
n
n
n
Is GW-59A certification form completed for facility?
n
n
W
n
Is a copy of current permit on -site?
❑
n
n
n
Are current metals and nutrient analysis available?
n
n
1=l
n
Are nutrient and metal loading calculating most limiting parameters?
n
n
n
n
a. TCLP analysis?
❑
❑
❑
❑
b. SSFA (Standard Soil Fertility Analysis)?
n
n
R1
n
Are PAN balances being maintained?
n
n
n
n
Are PAN balances within permit limits?
[I
n
'h
Has land application equipment been calibrated?
n
n
Fi11
n
Are there pH records for alkaline stabilization?
n
n
n
n
Are there pH records for the land application site?
n
n
p%
Are nutrient/crop removal practices in place?
n
n
n
n
Do lab sheets support data reported on Residual Analysis Summary?
n
n
❑ .
Are hauling records available?
n
n
Are hauling records maintained and up-to-date?
n
n
Has permittee been free of public complaints in last 12 months?
n
n
n
Has application occurred during Seasonal Restriction window?
❑
n
n
Comment:
Treatment
Yes
No
NA
NE
Check all that apply
Aerobic Digestion
n
Anaerobic Digestion
n
Alkaline Pasteurization (Class A)
n
Alkaline Stabilization (Class B)
n
Compost
n
Drying Beds
n
Other
rl
Comment:
Sampling
Yes
No
NA
NE
JJ
�escribe
sampling:
Is s'4 pling adequate?
n
n
F1
n
Is Jmpling representative?
n
n
n
n
Comment:
Tra�nspo�rt '
Yes
No
NA
NE
Is a Ropy of the permit in the transport vehicle?
Is
n
n
n
n
n
n
n
n
a copy\of\thespill control plan in the vehicle?
Is
the spill cottol Alan satisfactory?
n
n
n
f1
Page: 2

Permit: WQ0008799 Owner - Facility: Dan River Inc
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routine
Does transport vehicle appear to be maintained?
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation? .
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment:
V.. Aln AIA AIC
nnnn
n n n n
nnnn
nnnn
nnnn
nnnn.
nnnn
nnnn
nnnn
nnnn
nnnn
nnnn
nnnn
nnnn
nnnn
nnnn
Page: 3

TRIGEN-BIOPOWER, INC.
TRIGEN
Marion, North Carolina
Ash Reuse Program
Information Sheet
Trigen-BioPower, Inc. (Trigen), 2859 Old Linville Road, Marion, NC 28752 is the generator of
the ash provided to (Recipient). Application of the
aforementioned ash is prohibited except in accordance with the instructions on this sheet.
The ash will not be applied to any applicable buffer, including a 100 foot buffer between an
application site and any public or private water supply source (including wells) and any stream,
lake, or river. The ash shall not be applied to any site that is flooded, frozen, or snow-covered.
No ash is to be applied in inclement weather or until 24 hours following a precipitation event
equal to a rainfall event of 16-inch or greater in 24 hours. Land areas, which exhibit a seasonal
high water table within 3 feet of the surface, shall not be utilized for application of ash.
Adequate procedures shall be provided to prevent surface runoff from carrying any disposal or
stored ash into any surface waters.
The volume of ash application shall be limited to 4 tons/acre/year, unless a demonstration is
made which indicates that a higher application of this material will not exceed the liming
requirements of the crops being grown on the application site, if applicable to crops. A chemical
analysis of the ash is located on page 2 of the information sheet. The most recent analysis
performed by the North Carolina Department of Agriculture is also attached.
No ash shall be used as pipe bedding for sewer or potable water lines.
Signed (Ash Recipient):
Ash Recipient's Address:
Intended Use of Ash:
Expected Qty/Yr:
Page 1 of 2
Updated: 2/23/04
Date:
Acres of Land:

Marion, North Carolina.
Ash Reuse Program
Historical Analysis Average
Soil Amendment Properties
Parameter Concentration
Calcium Carbonate Equivalent 50.7%
Potash (K2O) 3.3%
20-Mesh % 90.1 %
100-Mesh % 60.2%
Metals (Total Concentration)
Parameter
Concentration (mgft)
Arsenic
5.6
Barium
951
Cadmium
1.48
Calcium
122,800
Chromium
29.0
Copper
60.4
Lead
19.8
Magnesium
11,600
Manganese
1,600
Mercury
0.013
Nickel
11.2
Nitrogen
458
Phosphorus
2,300
Potassium
16,000
Selenium
0.29
Silver
0.93
Sodium
6,410
Zinc
105
TCLP RCRA Toxicity Metals
(Lecahable Concentrations)
Parameter
Concentration (mg�L�
,,Arsenic
0.07
v Barium
8.5
'Cadmium
Less than 0.0075
Chromium
0.23
,,/ Lead
.0.11
, Mercury
Less than 0.0002
Selenium
Less than 0.025
,/Silver
0.002
Page 2 of 2
Updated: 2/23/04

TRICEN-13I0POWER, INC.
P.O. 'Box 422, 5501 Highway 25 N., Hodges, SC 29653
Phone: [phone] Fax: [phone]
0
TRIGEN
February 23, 2005
VIA FEDERAL EXPRESS # 792212922969
NC Division of Water Quality
Attn: Information Processing Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Permit No. WQ0010689
Trigen-BioPower, Inc. (TBP), Marion, NC
Steam Generating Plant Ash Reuse Program Report
Permit Condition III 5
MAR 0 9 2005
A �D
WATER QUALITY SEVION
Ncnakharge CQrrptiance Ent.
i< Z3
Cc�I
-7
G 71
—
O
o
7
CSI
, •
'r•i f ------
Per permit condition III 5, please find enclosed the information specified in permit conditions III
2 and III 3.
Permit Condition
Comment
III 2a
The source of the ash is a wood -fired boiler located at TBP's Marion, NC
facility. The g4ntity of ash applied during 2004 was approximately 1772
dry tons.
III 2b
Name of recipient: Henry Brown, 15956 US Hwy 221 North, Marion, NC
28752
Quantity received: 947 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Ricky Styles, 1429 Burma Road, Nebo, NC 28761
Quantity received: 14 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Rom English, Highway 221 North, Marion, NC 28752
Quantity received: 757 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Andrews Trucking, Ray Andrews, Old Linville Road,
Marion, NC 28752
Quantity received: 54 dry tons
Intended use: The wood ash was land applied.

III 3 & See enclosed reports from the North Carolina Department of Agriculture
III 4 and Pace Analytical Services, Inc.
Please contact Lauren Billheimer at 704-510-4372 or me at 864-374-3386 if you have questions
or require additional information.
Sincerely,
Tony Leopard
Plant Regional Manager
Enclosures — 1/15/04 NCDA report
1/28/04 Pace Analytical Services, Inc. report
cc: NC Division of Water Quality (2 additional copies w/ enclosure)
Ricky Styles — TBP
T.A. Pannell - TBP (via e-mail, w/o enclosures)
Lauren Billheimer - (via e-mail, w/o enclosures)

aceAnalXical ,u
vnvw pacelabs.com
1
December 21, 2004
Ms. Lauren Billheimer, P.E.
Trigen-BioPower, Inc.
1931 Winsted Ct.
Charlotte, NC 28262
RE: Lab Project Number: 9283725
Client Project ID: Marion Fly Ash
Dear Ms. Billheimer, P.E.:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Hunters ville, NC28078
Phone: [phone]
far.• 704.875.9091
Enclosed are the analytical results for eample(s) received by the laboratory on December 14, 2004. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
Bonnie McKee
[e-mail]
Project Manager
Enclosures
Asheville Certification IDS REPORT OF LABORATORY ANALYSIS Charlotte Certification IDS
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 Sc 99006
FL NELAP E87648 FL NELAP E87627

aceAnalyical "
wtwv pacelabs.com
Solid results are reported on a dry weight basis
Lab Sample No: 925081028
Client Sample ID: MARION FLY ASH
Pace Analytical Services, Inc.
9800 Kinceykenue, Suite 100
Nuntersville, NC28078
Phone: [phone]
Fax.- 704.875.9091
Lab Project Number: 9283725
Client Project ID: Marion Fly Ash
Project Sample Number: 9283725-001 Date Collected: 12/13/04 00:00
Matrix: Other Date Received: 12/14/04 10:00
Parameters Results Units Report Limit DF Analyzed By CAS No. Qual ReaLmt
Metals
Trace ICP Metals, TCLP Leach. Method: EPA 6010
Date Digested 12/16/04 04:15 12/16/04 04:15
Trace ICP Metals, TCLP Leach
°'Arsenic
\,✓Barium
Cadmium
e,,Chromium
t,Lead
y,,Selenium
t,,,Silver
Date Digested
Metals, Trace ICP
Arsenic
Barium,
Chromium
Molybdenum
Selenium
Silver
Date Digested
Mercury, CVAAS, TCLP Leachate
VMercury
Mercury, CVAAS, in Soil
Mercury
Wet Chemistry
Percent Moisture
Percent Moisture
L./pH
PH
Date: 12/21/04
Prep/Method: EPA 3010 / EPA 6010
0.038
mg/1
0.025
3.1
mg/l
0.025
ND
mg/1
0.0050_
0.052
mg/l
0.010
ND
mg/1
0.025
0.028
mg/1
0.025
ND
mg/1
0.010
12/17/04 01:45
Prep/Method: EPA 3050 / EPA 6010
1.4
mg/kg
0.49
380
mg/kg
0.49
4.0
mg/kg
0.20
1.1
mg/kg
0.49
ND
mg/kg
0.49
ND
mg/kg
0.20
12/15/04 04:00
1.0 12/20/04 19:03 ALV 7440-38-2
.1.0 12/20/04 19:03 ALV 7440-39-3
1.0 12/20/04 19:03 ALV 7440-43-9
1.0 12/20/04 19:03 ALV 7440-47-3
1.0 12/20/04 19:63 ALV 7439-92-1
1.0 12/20/04 19:03 ALV 7782-49-2
1.0 12/20/04 19:03 ALV 7440-22-4
12/17/04 01:45
1.0 12/19/04 19:31 ALV 7440-38-2
1.0 12/19/04 19:31 ALV 7440-39-3
1.0 12/19/04 19:31 ALV 7440-47-3
1.0 12/19/04 19:31 ALV 7439-98-7
1.0 12/19/04 19:31 ALV 7782-49-2
1.0 12/19/04 19:31 ALV 7440-22-4
12/15/04 01:00
Method: EPA 7470
ND mg/l 0.00020 1.0 12/17/04 05:42 ALV 7439-97-6
Method: EPA 7471
ND mg/kg 0.0045 0.9 12/15/04 06:04 ALV 7439-97-6
Method: % Moisture
0 % 1.0 12/14/04 12:46 DHW
Method: EPA 9045
11.9 units 1.0 12/15/04 20:40 CD1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not he reproduced, except in full,
NC Drinking Water 97712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
$C
99006
FL NELAP
E87627
1
Page: 1 of 2

aceAnalXical:u
wvArt pacetabs.com
PARAMETER FOOTNOTES
Pace Analytical Services, Inc.
9800 Kincey A venue, Suite 100
Huntersville, NC28078
Phone. [phone]
Fax- 704.875.9091
Lab Project Number: 9283725
Client Project ID: Marion Fly Ash
Dilution factor shown represents the factor applied to the reported result and reporting limit due to changes
in sample preparation, dilution of the extract, or moisture content
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic
testing was performed at our Pace Charlotte laboratory unless otherwise footnoted.
Method 9071B modified to use ASE.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
ND Not detected at or above adjusted reporting limit
NO Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Ill Analysis conducted in excess of EPA recommended holding time.
Date: 12/21/04
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NO Wastewater 40 This report shall not he reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
tLl C
Charlotte Certification IDs
NO Wastewater
12
NO Drinking Water
37706
SC
99006
FL NELAP
E87627
Page: 2 of 2

j ��
TRIGEN-BIOPOWER, INC.
TRIGEN
Please test the'sample(s) for the parameters as listed in the below table.
Send invoice and copy of results to:
Send original results to:
Ricky Styles
Lauren Billheimer
Tdgen-BioPower, 'Inc.
Trigen-BioPower, Inc.
2859 Old Linville Rd.
1931 Winsted Ct.
Marion, NO 28752
Charlotte, NO 28262
[phone]
(fax) 756-7160
[phone]
(fax) 510-4230
Sample #
Sample Description
Sample Date(s)
Grab or
Composite
pH
Total Metals - As,
Ba, Cr, Hg, Mo, Se,
Aq
TCLP Metals - As,
Ba, Cd, Cr, Pb, Hg,
A
1
Marion Fly Ash 5
Composite
X
X
X
rA
Sample sent to: Bonnie Kamla
Pace Analytical
9800 Kincey Ave., Suite 100 `
Huntersville, NO 28078
(704) 875 - 9092
n. •- •l-A-- ..-l.--h/Cte rcn -4-

NCDA Agronomic Division 4300 Reedy Creek Road Raleigh, NC 27607-6465 [phone] Report No: W04647 W
Grower: Trigen-BioPower Copies To: Trigen - BioPower Inc.
c/oRicky Styles
. 2857 Old Linville Road
Marion, NC 28752
Waste Analysis Rerort Farm: McDowell
12/20/04 McDowell County
Sample Info.
Laboratory
Results (pa ts er million unless otherwise noted)
Sample ID:
N
P v K V Ca vMq S
Fe
L Mn ✓ Zn
Cu
B
Mo
CI C
MCDOWB
Total
0.00
1285 9870 36350 6988 742
6584
748 140
55.1
33.6
IN -N
Waste Code:
-NH4
SAR
-NO3
v Na ✓Ni U Cd J Pb Al
Se
Li pH
SS
C:N
DM%
CCE% ALE tons
Description:
OR-N
3418 8.58 0.68 9.96
12.07
99.66
11.25 8.00
Indust. -Stack Ash
I Urea
Recommendations:
Nutrients Available for First Crop
Ibs/ton (wet basis)
Other Elements
Ibs/ton (wet basis)
Application Method
N P205
K20 Ca Mg S Fe Mn Zn Cu
B
Mo CI
Na
Ni Cd
Pb
Al Se Li
Broadcast
0.00
4.1 18.9 50.7 9.8 1.0 9.2 1.0 0.19 0.08
0.05
6.8
0.02 T
0.02
Soil Incorp
0.00
4.7 21.3 58.0 11.1 1.2 10.5 1.2 0.22 0.09
0.05
6.8
0.02 T
0.02
I UI 1 [re) dl IU IVldI lydI ItlJe [IVII I) W IWI IU dUUf IS did 5Uf f leWf ldl eIUUM In UOin samples. Monitoring or [nese elemen[s wim soil sampling Is recommended. Neutralizing value is very
economically used as a liming material. Application rates should be based on crop nutrient requirement.
low, The waste product cannot be
;olleen Hudak -Wise
lgronomist
Sample Info.
Laborato Results (pa ts er million unless otherwise noted)
Sample ID:
N
P K Ca Mg S
Fe Mn Zn
Cu B
Mo CI C
MCDOWS
Total 0.00
2598 20581 62252 12230 674
11555 1514 124
106 64.6
IN -N
Waste Code:
-NH4
SAR
-NO3
Na Ni Cd Pb Al
Se Li pH
SS C:N
DM% CCE% ALE(tons)
Description:
OR-N
5161 14.2 1.59 9.48
12.32
99.66 24.75 3.70
Indust, -Stack Ash
Urea
Recommendations: Nutrients Available for First Crop
Ibs/ton (wet basis)
Other Elements
Ibs/ton (wet basis)
Application Method N P205 K20 Ca Mg S Fe Mn Zn Cu
B Mo CI
Na Ni
Cd Pb Al Se Li
Broadcast 0.00 8.3 39.4 86.9 17.1 0.94 16.1 2.1 0.17 0.15
0.09
10.3 0.03
T 0.02
Soil Incorp 0.00 9.5 44.3 99.3 19.5 1.1 18.4 2.4 0.20 0.17
0.10
10.3 0.03
T 0.02
leutralizing value is low but the material should still be applied at rates needed to adjust soil pH to the desired range, The ALE indicates the amount of the waste required to equal the neutralizing value of one ton of
:ommercial agricultural lime,

_ 04/07/04
Permit Number WQ0010689
Permit Tracking Slip
Program Category
Status Project Type
Non -discharge
In review Renewal with modification
Permit Type
Version Permit Classification
Distribution of Residual Solids (503 exempt)
Individual
Primary Reviewer
Permit Contact Affiliation
shannon.thornburg
Ta Pannell
Permitted Flow
205 Regency Ex Park
Charlotte NC 28217
Facili
Facility Name
Trigen Biopower Inc-N Cove As
Location Address
205 Regency Ex Park
Charlotte NC 28217
Owner
Owner Name
Trigen-biopower Inc
Major/Minor Region
Minor Asheville
County
McDowell
Facility Contact Affiliation
Owner Type
Non -Government
Owner Affiliation
Dates/Events
-Scheduled
Orig Issue App Received
Draft Initiated Issuance Public Notice Issue Effective" Expiration
07/07/95 03/26/04
Regulated Activities
Requested/Received Events
Ash pond & coal pile operation
RO staff report requested
Additional information requested
Additional information received
Groundwater comments requested
Groundwater comments received
RO staff report received
Outfall NULL.
i5ki diode = oco) QWZ004-
Waterbody Name
Stream Index Number Current Class Subbasin

DIVISION OF WATER QUALITY
GROUNDWATER SECTION
Cn
XM
May 27, 2004
MEMORANDUM
Lnv
To:
Kim Colson
CO
cc:
.Landon Da�i� do
Through:
Debra Watts
From:
Thomas E. Cadwallader, RE7
Subject:
Trigen-Biopower, Inc.- North Cove / Steam Generating Plant
- Ash Reuse Program
McDowell County
WQ0010689/GW04037
Shannon Thornburg, WGS — CO Reviewer
This application is for the renewal of an ash reuse program of up to 2,500 tons per year of scrubber
residue and boiler bottom ash resulting from the burning of wood in the production of steam for the
Baxter Laboratory plant near Marion, NC (see Figure 1). Saw dust is received from lumberyards and
furniture operations and stored uncovered until fed to the traveling grate boiler. Inert materials from the
boiler are scraped to a quench area and transported to an outside storage area for pickup by local farmers.
Scrubber residues are stored in concrete basins until excavated to the outside storage area, as well.
The storage of ash at this site is less than ideal because there is limited control of when it leaves to be
used on fields and therefore fairly large overflow areas are needed to store the ash awaiting pickup. This
expanded storage area is of concern because of the free exposure to rainwater and the resulting flow to
the surficial aquifer. Accordingly, it is recommended herein that three monitoring wells be located at this
site in order to assess the impact of prolonged -external on -site storage on the groundwater. Other new
permit conditions in this regard include a sampling program for the wells and the definition of
compliance and review boundaries associated with the ash storage area.
Containment of stored ash would be an acceptable alternative to the placement of wells, should the
applicant demonstrate a desire to construct such facilities. However, until such containment is offered,
the permit renewal will be modified. Other requirements of the permit remain the same as the previous
permit.
The Groundwater Section has reviewed the subject renewal permit application and recommends re -
issuance of the permit with the following conditions:
GW04037.doc Page 1 of 4 Rev. 12-03

1. Well Construction Criteria:
a. Within ninety (90) days of permit issuance, three (3) monitor well(s), one upgradient and two
downgradient shall be installed to monitor groundwater quality. The wells shall be constructed
such that the water level in the well is never above or below the screened (open) portion of the
well at any time during the year. The general location and name for each well is marked on
Figure 2. Each monitoring well shall be located at the Review boundary, constructed in
accordance with this permit, and approved by the Ashville Regional Office.
b. The wells must be constructed by either a North Carolina Certified Well Contractor, the
property owner, or the property lessee according to General Statutes 87-98.4(b)(2). If the
construction is not performed by a certified well contractor, the property owner or lessee,,
provided that they are a natural person, must physically perform the actual well construction
activities. All well(s) must be constructed according to the North Carolina Well Construction
Standards (15A NCAC 2C .0108) and any local county rules.
c. The Ashville Regional Office, telephone number [phone], shall be notified at least forty-
eight (48) hours prior to the construction of any monitoring well so that an inspection can be
made of the monitoring well location. Such notification to the regional groundwater supervisor
shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through
Friday, excluding state holidays.
d. Within thirty (30) days of completion of all well construction activities, a certification must be
received from a professional engineer or a licensed geologist certifying that the monitoring wells
are located according to this permit.
2. Sampling Criteria:
a. Monitor wells MW-1, MW-2 and MW-3 shall be sampled initially after constriction, and
thereafter every March, July and November for the parameters listed below. Prior to sampling
the parameters, the measurement of water levels must be taken. The depth to water in each well
shall be measured from the surveyed point on the top of the casing. The measuring points (top of
well casing) of all monitoring wells shall be surveyed relative to a common datum.
Nitrate (NO3-N)
Chemical oxygen demand
Total Phosphorous
Water Level
Total organic carbon (TOC)
Chromium
Lead
Nickel
Total Dissolved Solids (TDS)
Sulfate
pH (field)
Arsenic
Barium
Copper
Manganese
Coc1 rr -, -'—.
b. For Total Organic Carbon (TOC), if concentrations greater than 10 mg/1 are detected in any
down -gradient monitoring well, additional sampling and analysis must be conducted to identify
the individual constituents comprising this TOC concentration. If the TOC concentration as
measured in the background monitor well exceeds 10 mg/1, this concentration will be taken to
represent the naturally occurring TOC concentration. Any exceedances of this naturally occurring
GW04037.doc Page 2 of 4 Rev. 12-03

TOC concentration in the down -gradient wells shall be subject to the additional sampling and
analysis as described above.
c. Any laboratory selected to analyze parameters must be Division of Water Quality (DWQ)
certified for those parameters required.
3. Reporting / Documentation:
a. All reports and documentation (GW-1, GW-30, GW-59) shall be mailed to the following
address:
Groundwater Section
Permits and Compliance Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
Updated blank forms (GW-1, GW-30, GW-59) may be downloaded from the Groundwater
Section's website at http://gw.ehnr.state.nc.us/ or requested from the address mentioned above.
b. For the initial sampling of the well(s), the permittee shall submit a copy of the GW-I Form (Well
Construction Record) with the Compliance Monitoring Form (GW-59) for each well to the
address listed in the "Reporting / Documentation" section of the Groundwater Requirements.
Initial Compliance Monitoring Forms that do not include copies of the GW-1 form may be
returned to the permittee without being processed. Failure to submit these forms as required by
this permit may result in the initiation of enforcement activities pursuant to NC General Statutes
143-215.6A.
b. The results of the sampling and analysis must be received on Form GW-59 (Groundwater
Quality Monitoring: Compliance Report Form) by the Groundwater Section (address listed in the
"Reporting / Documentation" section of the Groundwater Requirements), on or before the last
working day of the month following the sampling month. The data of all groundwater sampling
analyses required by the permit conditions must be reported using the most recent GW-59 form.
along with attached copies of the laboratory analyses.
c. Within sixty (60) days of completion of the monitoring wells, the permittee shall submit two
original copies of a scaled site map (scale no greater than 1 "=100'). The map must include
the following information:
1) The location and identity of each monitoring well.
2) The location of major components of the waste storage system.
3) The location of property boundaries within 500 feet of the storage areas.
4) The latitude and longitude of the established horizontal control monument.
5) The elevation of the top of the well casing (which shall be known as the "measuring point")
relative to a common datum.
6) The depth of water below the measuring point at the time the measuring point is established.
7) The location of Review and Compliance boundaries.
8) The date the map is prepared and/or revised.
GW04037.doc Page 3 of 4 Rev. 12-03

Control monuments shall be installed in such a manner and made of such materials that the
monument will not be destroyed due to activities that may take place on the property. Maps and
any supporting documentation shall be sent to the Groundwater Section as addressed in the
"Reporting / Documentation" above.
The permittee is responsible for the geographic accuracy of any map submitted, however
produced.
4. Vertical Separation Requirements:
Land areas which exhibit a seasonal high water table within 3 feet of the surface shall not be
utilized for the application of ash.
5. Applicable Boundaries:
a. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A
NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary for the
disposal system individually permitted on or after December 30,1983 is established at either 250
feet from the waste disposal area, or 50 feet within the property boundary, whichever is closest to
the waste disposal area. An exceedance of Groundwater Quality Standards at or beyond the
Compliance Boundary is subject to remediation action according to 15A NCAC 2L .0106(d)(2).
b. The REVIEW BOUNDARY is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of standards
at the Review Boundary shall require action in accordance with 15A NCAC 2L .0106(d)(1).
6. Additional Requirements:
Any additional groundwater quality monitoring, as deemed necessary by the Division, shall
be provided.
If there are any questions please call Tom Cadwallader at 715-6173.
Attachment: Figure 1 - Vicinity Map
Figure 2 - Layout of Monitoring Wells
GW04037.doc Page 4 of 4 Rev. 12-03

Trigen-Biopower, Inc. - North Cove Plant
Figure 1. Vicinity Map
3000 0 3000 6000 Feet
® ,..--
WO0010689/G W04037

Trigen Biopower - North Cove
Figure 2 Layout of Ash Storage
by tec in 5/04 from 93 dogq Iswitz2 and ashforl
200 0 200 400 Feet
N
W Q0010689/GW 04037
Q Mmmr Well
Q Ash Slorage UmI-

GROUNDWATER SECTION
MEMORANDUM
May 5, 2004
TO: Tom Cadwallader
Permits Group
Raleigh Central Office _ ----
THROUGH: Landon Davidson, Regional Groundwater S ervi'sor
Asheville Regional Office
FROM: Qu Qi
Asheville Regional Office
SUBJECT: Permit Application Review
Wood Ash Distribution for Land Application
WQ0010689
GW 04037
McDowell County, North Carolina
I have reviewed the subject permit application and visited site. Issuance of the permit is
recommended with the condition that three groundwater -monitoring wells be installed at the site and
groundwater -monitoring program be implemented (see attached RO-Staff-Report). If you have any
questions about the site, please do not hesitate to call me at [phone].

It f
PS.-V �S-le
e- ID , S V- i 1 -P,
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Groundwater Section Regional.Of#ice Staff Report
page 1 of
Non -Discharge Permit Application Review
A. Header Information
-
Date
Permit No. GW Action No. Permittee Name
Facili Name
4-May-04
WQ0010689 IGWO4037 Trigen-Biopower, Inc.
Trigen Biopower Inc.
Regional Office
RO Reviewer Type of Disposal System
System Capacity
Waste Source.
ASHEVILLE
Qu Qi �) '� Ash pond for storage
3,200 dry tons/years
Industrial
RO Staff Report

Groundwater Section Regional Office Staff Report page _of _
Non -Discharge Permit Application Review
Date Permit No.
4-Ma -04 IWQ0010689
B. Site Inspection
Site Identification (name, number,etc). County Inspection Date
Trigen Biopower, Inc. IMcDowell 4-Ma -04
No site inspection performed at this time
Agencies represented during Inspection: Characterize the artificial drainage network and update map(s) accordingly
Name
Distance between application,fields and nearest:
Streams . . ,
50 feet
Residences o
1000feet
Supply wells .
1000 feet
Property Lines
50 feet
Verify site & soil conditions with application documents. (Note any
observable differences in
topography, geology, wetlands,etc). Update
map(s) accordingly.
N/A
RO Staff Report
stanamg water
Other site concerns:
Sluge (30% solid) is moved out from the concrete basin and mixed with saw dust to
stabalize before the product is distributed. The mixture is piled on site next to a large saw
dust/wood chip pile. There is no pad beneath the pile and leachate is not contained. The
leachate is potentially possible to impact groundwater quality. PH value is a concern based
on the ash/sluge analysis results submitted by the permitee. However, on the day of
inspection, the PH values measured from the standing water next to the product pile were
all near 7. This may be the result of recent rain events.

Groundwater Section Regional Office Staff Report
Non -Discharge Permit Application Review
Date Permit No.
4-Ma -04 IWQ0010689
C. Well Construction
Well ID
Synonym
GPS Location Data
(degrees/min/sec)
Latitude
Longitude
Does GW Section have a GW-1
for this well ?.
If yes, then skip to the next well,
otherwise complete remainder of form.
Construction Date
Depth of Well .
MP Elevation
MP to.LS
Grout Interval
Screened Interval
Casing Material
Casing Diameter
black steel
8" dia
If other, specify
If other, specify
Well Contractor
Certification No.
Comments
No GW monitoring wells on site.
mr = measuring romr
RO Staff Report
Ia = Lana burrace
ttach as r,
M
Synonym
GPS Location Data
(degrees/min/sec)
Latitude
Longitude
Does GW Section have a GW-1 for this well ?
If yes, then skip to the next well,
' otherwise complete remainder of form.
Construction Date
Depth of Well
MP Elevation •
MP to LS
Grout Interval
Screened Interval
Casing Material
Casing Diameter
black steel
8" dia
If other, specify
If other, s ecify
Well Contractor
Certification No.
Comments
• MP = Measuring Point LS = Land Surface
page _of _
)
Well ID
Synonym
GPS Location Data
(degrees/min/sec)
Latitude Longitude
Does GW Sectlon have a GW-1 for this well?
If yes, then skip to the next well,
otherwise complete remainder of form.
Construction Date Depth of Well
MP Elevation • MP to LS
Grout Interval Screened Interval
Casing Material Casing Diameter
Pack steel 8" dia
If other, specify If other, specify
Well Contractor
Certification No.
Comments
MP = Measuring Point Ls = Land

Groundwoater, Section Regional Office Staff Report
Non -Discharge Permit Application Review
Date Permit No.
4-Ma -04 WQ0010689
D. Compliance Historv,
Summarize any non-compliance, special operating conditions, or enforcement actions taken by the Division
(2L exceedances, NOV's, NORR's, etc).
INo known non-compliance and/or violations on records.
page _of
E. Recommendations
..
GW monitoring wells
GW monitoring parameters
(check the appropriate box(s))
(check the appropriate box(s)).
1) No change in existing monitoring wells
1) No change in existing sampling parameters
2) Additional wells needed 0
2) Additional parameters needed
I A
3) Existing wells to be abandoned
3) Existing parameters to be deleted
F
4) List all active wells and justification for any change(s) above..
4)'Change in sampling frequency
0
Indicate whether well abandonment is permanent ortemporary.
Also attach, map showing proposed locations of new wells
5) List justification for selected change(s) above
referencing Review and Compliance boundaries.
GW monitoring should be required at the down gradient side of the storage area.
Leachates from saw dust pile and ash mixture pose potential threat to the quality of
and nearby stream. Two down gradient wells and one upper gradient well should be
installed at the site.
RO Staff Report
(Color, TOC, TDS, Ph, Alkalinity...

Groundwater Section Regional Office Staff Report .
Non -Discharge Permit Application Review
Date Permit No.
4-Ma -04 W-QO010689
E. Recommendations (continued)
Other points of concern (history of facility, political issues,etc)..
page _of _
would consider to waive the GW monitoring well installation and sampling requirement, if the permitee agrees to provide proper storage area and stabilization process area,
areas are paved and leachates are contained.
List of sites covered by this permit application:
(attach additional sheet(s):If necessary)
Site ID
Number Property Owner Name County
Site Restrictions
(Applicable to land application sites only)
OfficeRegional
Please :attach any other forms•.of documentation (maps, GW-1's etc).. ;
-O Staff Report

Groundwater Section Regional Office Staff Report
[don -Discharge Permit Application Review
A. Header Information
page 1 of _
Date
Permit No.
GW Action No. Permittee Name
Facility Name
4-May-04
WQ0010689
IGWO4037 I I Trigen-Biopower, Inc.
Trigen Biopower Inc.
Re ional Office
RO Reviewer
Type of Disposal System
System Capacity Waste Source
ASHEVILLE I
JQU Qi
jAsh pond for storage
1 13,200 dry tons/years 11ndustrial
DQ
cr
•'3- ,
v
RO Staff Report

DIVISION OF WATER QUALITY
GROUNDWATER SECTION
April 15, 2004
MEMORANDUM
TO�� L na don DaFidson, Ashevi 1e: Regional Off ce �,
FROM: Tom Cadwallader
SUBJECT: Application for ® Permit Renewal, ❑ Permit Amendment
❑ New Permit
COMMENTS:
Facility Name: Trigen-R'iopoW r
County: McDowell
Type of Project: Land Application of Wood Ash
APPLICABLE PERMIT NOs: WQ0010689
GW04037
ANIMAL WASTE (DWQ)
�r $
6
^
v.
iF1
LQ
IV
.—
'a
❑ The Groundwater Section has received ONLY ONE (1-1 copy of the referenced permit application. A copy of the
application should have been sent to vour Regional Water Quality Supervisor, so please use that copy for
your review - IF A COPY HAS NOT BEEN RECEIVED IN THE REGIONAL OFFICE, PLEASE LET ME
KNOW.
® The Groundwater Section received two (2) copies of the referenced permit application. One copy of the
application documents we received is attached.
Please review the application materials for completeness. If you feel additional information is necessary, please
let me know no later than 4/26/2004. A copy of any formal request for additional information
will be forwarded to you.
If you do not need any additional information to complete your review, please provide your final comments
by 5/7/2004. If you request and/or receive additional information, your final comments
are due no later than 14 days after you receive the additional information.
(rev. 10/24/03) '

NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
Date: April 12, 2004
To: ®
Forrest Westall, ARO-WQS
❑
Paul Rawls, FRO-WQS
❑
Rex Gleason, MRO-WQS
❑
Ken Schuster, RRO-WQS
❑
Jim Mulligan, WaRO-WQS
❑
Rick Shiver, WiRO-WQS
❑
Steve Tedder, WSRO-WQS
fflD_ b_ra�Watts,-CO=GWS
opies-Sent to��O�GW . 2
Copies Sent to RO-WQS: 1
❑ Distribute 0 Copies to RO-GWS
From: Shannon Mohr Thornburg , Non -Discharge Permitting Unit
Telephone: [phone] ext. 353 Fax: [phone]
E-Mail: [e-mail]
7 n
f'�l 7t
:I tJ
R1
=0
co
"!
o
i
fd
A. Permit Number: W00010689
B. Owner: Tri_ en-Biopower, Inc.
C. Facility/Operation: North Cove Steam Generation Plant Ash Reuse Program
❑ Proposed ® Existing ❑ Facility ® Operation
D. Application:
1. Permit Type: ❑ CS (O&M) ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
For Residuals: ❑ Land App. ® D&M ❑ Surface Disposal
❑ 503 ® 503 Exempt ❑ Animal
2. Project Type: ❑ New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ® Renewal w/ Mod.
E. Comments/Other Information: ® I would like to accompany you on a site.visit.
IS-date-is-06/24/2004.:.'
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
For RO-WQS:
® Return a Completed Form NDSRR. ❑ Attach Attachment B for Certification by the NDPU.
❑ Issue an Attachment B Certification from the RO*.
* Remember that you will be responsible for coordinating site visits, reviews, as well as additional
information requests with other RO-WQS and RO-GWS representatives in order to prepare a complete
Attachment B for certification. Refer to the RPP SOP for additional detail.
For CO-GWS:
123 Memoxandum�with Permit Condition-Recommendatons.'1
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 Non -Discharge Permitting Unit contact person listed above. k )
RO-WQS Reviewer: Date:
1'
CO-GWS Reviewer: �� i Date: S
FORM: NDARR 09/02 Page 1 of 1

_ 04/07/04
Permit Number WQ0010689
Permit Tracking Slip
Proqram Category
Status Project Type
Non -discharge
In review Renewal with modification
Permit Type
Version Permit Classification
Distribution of Residual Solids (503 exempt)
Individual
Primary Reviewer
Permit Contact Affiliation
shannon.thornburg
Ta Pannell
Permitted Flow
205 Regency Ex Park
Charlotte NC 28217
Facility
Facility Name Major/Minor Reqion
Trigen Biopower Inc-N Cove As Minor Asheville
Location Address County
205 Regency Ex Park McDowell
Charlotte NC 28217 Facility Contact Affiliation
Owner
Owner Name
Owner Type
Trigen-biopower Inc
Non -Government
Owner Affiliation
Dates/Events.
Scheduled
Orig Issue App Received
Draft Initiated Issuance Public Notice Issue Effective" Expiration
= 07/07/95 . 03/26/04
ROulated Activities
Requested/Received Events
Ash pond & coal pile operation
RO staff report requested, .
Additional information requested
Additional information received
-
Groundwater comments requested
Groundwater comments received
RO-staff report received
Outfall NULL
s�0-A dcde = 061 gW02004-
Waterbody Name
Stream Index Number '' Current Class Subbasin

A-01 1 6,;%, � -, ,
-"Dr -9 Vh
CL c -Z C-
O's mil"
. -ev\

W A T�,p
Michael F. Easley, Governor
��Ir
William G. Ross Jr., Secretary
�O
p
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
April 7, 2004
Tony Leopard
Regional Plant Manager
PO Box 422
Hodges, SC 29653
Subject: Acknowledgement of Application No. WQ0010689
Trigen-BioPower, Inc.
Distribution of Other Residual Solids
McDowell County
Dear Mr. Leopard:
The Non -Discharge Permitting Unit of the Division of Water Quality (Division) acknowledges receipt of
your permit application and supporting materials on March 26, 2004. This application package has been
assigned the number listed above and will be reviewed by Shannon Thornburg.
The reviewer will perform a detailed review and contact you with a request for additional information if
necessary. To ensure the maximum efficiency in processing permit applications, the Division requests
your assistance in providing a timely and complete response to any additional information requests.
Please be aware that the Division's Regional Office, copied below, must provide recommendations prior to
final action by the Division. Please also note at this time, processing permit applications can take as long
as 60 - 90 days after receipt of a complete application.
If you have any questions, please contact Shannon Thornburg at 919-733-5083, extension 353, or via e-
mail at [e-mail]. If the reviewer is unavailable, you may leave a message, and
they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS
PROJECT.
Sincerely,
Kim H. Colson, P.E.
Supervisor
cc: Asheville Regional Office, Water Quality Section
Permit Application File WQ0010689
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
OVA
Internet http://h2o.enr.state.nc.us/ndpu INM
Telephone [phone] Fax [phone]
DENR Customer Service Center
An Equal Opportunity Action Employer
Telephone [phone]
50% recycled/10% post -consumer paper

TRIGEN-BIOPOWER, INC.
P.O. Box 422, 5501 Highway 25 N., Hodges, SC 29653
Phone: [phone] Fax: [phone]
TRIGEN
March 24, 2004
VIA FEDERAL EXPRESS # 790588520277
Ms. Shannon Thornburg
NC Division of Water Quality
Non Discharge Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Permit Modification and Renewal
Permit No. WQ0010689 — Ash Reuse
Trigen-BioPower, Inc., — Marion, NC
Dear Ms. Thornburg:
Enclosed is a permit application for modification and renewal of the ash reuse permit for the
Trigen-BioPower, Inc. (TBP) facility in North Cove (Marion). The modification was prepared to
increase the annual amount of ash reused from 2500 to 3200 dry tons per year. The following
information is included with this permit application:
• Completed permit application form for "Distribution of Other Residual Solids"
• Most recent analytical data depicting TCLP, reactivity, ignitability, and corrosivity analyses
• Most recent annual analysis, as required by existing permit
• Most recent Ash Information Sheet, which is distributed to users of the ash
• $325 permitting fee
TBP also requests that the new permit clarify the testing requirements in permit condition III.3.
The permit indicates that the listed parameters shall be tested using the TCLP method. However,
permit condition IIIA specifically addresses, TCLP testing. It is assumed that the parameters in
condition III.3 are based on total concentrations.
Please contact Lauren Billheimer at 704-510-4372 or me at 864-374-3386 if you have questions
or require additional information.
Sincerely,
7neopard
Regional Plant Manager
cc: NC Division of Water Quality (3 additional copies) Ricky Styles
T.A. Pannell Lauren Billheimer
File: Marion Ash Reuse Permit

A
� i
TRIGEN-BIOPOWER, INC.
P.O. Box 422, 5501 Highway 25 N., Hodges, SC 2
Phone: [phone] Fax: [phone]
1
TRIGEPI
February 27, 2004
VIA FEDERAL EXPRESS # 791784194344
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Permit No. WQ0010689
Trigen-BioPower, Inc. (TBP), Marion, NC
Steam Generating Plant Ash Reuse Program Report
Permit Condition III 5
��fl � 2 b00Z
Per permit condition III 5, please find enclosed the information specified in permit conditions III
2 and III 3.
Permit Condition
Comment
III 2a
The source of the ash is a wood -fired boiler located at TBP's Marion, NC
facility. The quantity of ash applied during 2003 was approximately 2360
dry tons.
III 2b
Name of recipient: Jeffery J. Banks, 5138 Old Linville Road, Marion, NC
28752
Quantity received: 97 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Rom English, Highway 221 North, Marion, NC 28752
Quantity received: 431 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Frank Queen, 5351 Patton Road, Morganton, NC
28655
Quantity received: 1832 dry tons
Intended use: The wood ash was land applied

NC Division of Water Quality
February 23, 2004
Page 2 of 2
III 3 & See enclosed reports from the North Carolina Department of Agriculture
III 4 and Pace Analytical Services, Inc.
Please contact Lauren Billheimer at 704-510-4372 or me at 864-374-3386 if you have questions
or require additional information.
Sincerely,
Tony eopard
Plant Regional Manager
Enclosure — (1/15104 NCDA report, 1/28/04 Pace Analytical Services, Inc. report)
cc: NC Division of Water Quality (2 copies w/ enclosure)
T.A. Pannell - TBP (via e-mail, w/o enclosure)
Ricky Styles — TBP
Lauren Billheimer - (via e-mail, w/o enclosure)

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
NC 28262
RE: Lab Project Number: 9257411
Client Project ID: Marion Ash
Dear Ms. Billheimer, P.E.:
Enclosed are the analytical results for sample(s) received by the laboratory on January 12, 2004. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
Bonnie Kamla
[e-mail]
Project Manager
Enclosures
REPORT OF. LABORATORY ANALYSIS
Asheville Certification IDs
This report shall not be reproduced, except in full,
Charlotte Certification IDs
NC Wastewater
40
without the written consent of Pace Analytical Services, Inc.
NC Wastewater
12
NC Drinking Water
37712
NC Drinking Water
37706
SC Environmental
99030
SC
99006
FL NELAP
E87648
`on�iCT
FL NELAP
E87627

ceAnalytical °
www.pacelabs.com
Solid results are reported on a
Lab Sample No: 923713077
Client Sample ID: MARION FLY>,ASN`
Parameters
Results
Units
Report Limit
Arsenic
NO
mg/l
0.025
Barium
2.3
mg/l
0.025
Cadmium
ND
mg/l
0.0050
Chromium
0.018
mg/1
0.010
Lead
NO
mg/l
0.015
Selenium,"
mg/l
0.025
Si lyer"
NO
mg/l
0.010
Arsenic
4.3
mg/kg
0.47
Barium
750
mg/kg
0.47
Chromium.
24.
mg/kg
0.19
Molybdenum
1.1
mg/kg
0.47
Selenium
NO
mg/kg
0.47
Silver
NO
mg/kg
0.19
Mercury
NO
mg/l
0.00020
Mercury
NO
mg/kg
0.0050
Percent Moisture
0.1
%
pH
12.3
units
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax., 704.875.9091
O1/09/04 00:00
Lab Sample No: 923713085 Date Collected: 01/09/04 00:00
Client Sample ID: MARION BOTTOM ASH s pf—'a ex y-94r f Ai d
Parameters
Results
Units
Report Limit
Arsenic
ND
mg/l
0.0050
Barium
0.13
mg/l
0.0050
Cadmium
NO
mg/l
0.0010
Chromium
0.0025
mg/l
0.0020
Lead
ND
mg/l
0.0050
Selenium
NO
mg/l
0.0050
Silver
NO
mg/l
0.0020
Mercury
NO
mg/l
0.00020
Date: 01/28/04 Page: 1 of 1
REPORT OF LABORATORY ANALYSIS
Asheville Certification IDs
This report shall not be reproduced, except in full,,
Charlotte Certification IDs
NC Wastewater
40 '
without the written consent of Pace Analytical Services, Inc.
NC Wastewater
12
NC Drinking Water
37712
'"`F£
NC Drinking Water
37706
SC Environmental
99030
�'
SC
99006
FL NELAP
E87648
FL NELAP
E87627

q ���Lf'dl
j UK,TRIGEN-1310POWER, INC.
Please test the sample(s) for the parameters as listed in the below table
Send invoice and copy of results to:
Send original results to:
Ricky Styles
Lauren Biliheimer
Trigen-BioPower, Inc.
Trigen-BioPower, Inc.
2859 Old Linville Rd.
1931 Winsted Ct.
Marion, NC 28752
Charlotte, NC 28262
[phone]
[phone]
(fax) 756-7160
(fax) 510-4230
Sample #
Sample Description
pH
Total Metals - As,
TCLP Metals - As,
SPLP Metals - As,
Ba, Cr, Hg, Mo, Se,
Ba, Cd, Cr, Pb, Hg,
Ba, Cd, Cr, Pb, Hg,
Ag
Se-9 Ag
Se A
1
Marion Fly Ash
X
X
X
2
Marion B om Ash
I Ca
X
Sample sent to: Bonnie Kamla
Pace Analytical
9800 Kincey Ave., Suite 100
Huntersvilie, NC 28078
(704) 875 - 9092
03%2012%2023%20Marion%20ash%20analysis%20request%20(Pace)[1]

NCDA:A ronomic Division .4300 Reed° Creek -Road "Ralet h",:'NC 27607 6405, 919, -733 2655 °' ..., : , .., - .
Re ort No: W05272 W
Grower: Trigen-BioPower
Copies To: Trigen - BioPower Inc.
'
c/oRicky Styles
2857 Old Linville Road
Wasteortt
Marion, NC 28752
" ,
Trigen - BioPower Inc.
na ysis e
Farm: McDowell
Attention: Lauren Billheimer
1931 Winsted Ct
1/15/04
McDowell County
Charlotte, NC 28262
Sam le Info: "
Laborato -Results ,::arts:.
"er"million u dess.offierwise.noted
Sample ID:
N
P K Ca Mg
S Fe Mn Zn Cu
B Mo Cl C
MCDOWE .
Total 0.00
2046 13495 40728 8350
440 11000 942 67.1 45.1
40.5
IN -N
Waste Code:
-NH4
Na Ni Cd Pb
Al Se Li pH SS
_
C.N DM% CCE% ALE(I
SAR
-NO3
2577 9.11 0.86 13.1
12.52
99.61 14.75 6.10
Description:
OR-N
Indust. -Stack Ash F7 4s
Urea
Recommendations:
Nutrients Available for..Pirst_Cro :,.
lklton wet &asks .r,< .:
Qther Elements, lbs/ton wet basis
Application Method
Fe Mn
N P20.5 K20 Ca., Mg S., Zn
Cu B Mo Cl
Na�.
",Ni Cd Pb Al Se" " Li
Broadcast
0.00 6.5'. , .. 25.8 56.8 1 F.7 0 6f. 15.3 1'.3 0-09
0' 06 0;:06 ".:
S:k
0,:,02 • T 0.03
Soil lncor
0.00' 7:5 29'.,0 64.9= , 13:3 _ 0.70;' _1, 5 .1.5 011,
., ,0 07 ,... ,a0:06 =_ _ r
. 5.:1
0.02'" T 0,03
eutralizing.,v u16 is ver 'low. The waste proLd cannof be econom�call ;:used as a htning'material.;Application rates'shoul"d lie based"on cro nutnerit re 9
uirement. `
o.c PeC.t.
6-3

TRIGEN-BIOPOWER, INC.
P.O. Box 422, 5501 Highway 25 N., Hodges, SC 29653
® Phone: [phone] Fax: [phone]
TRIGEN
December 12, 2002
CERTIFIED MAIL # 7099 3400 0001 '1766 5163
RETURN RECEIPT REQUESTED
Mr. Larry Frost
North Carolina Department of Environment
and Natural Resources
59 Woodfin,Place
Asheville, NC 28801
RE: Change of Address and Responsible Person
Trigen-BioPower, Inc. Facilities
Marion and Forest City, North Carolina
Dear Mr. Frost:
This letter `documents the -change, of responsible person for the water quality permits at our
Marion ,aiid�-F'orest 'City, NC facilities. Tony Leopard, Plant Manager for both facilities, will be
the new responsible party. Lauren Billheimer will remain the technical contact. Please note, for
your records, the following changes:
Responsible Party:
Tony Leopard, Plant Manager
Trigen-BioPower, Inc.
P.O. Box 422
5501 Highway 25 N.
Hodges, SC 29653
Phone: [phone]
Fax: [phone]
Technical Contact:
Lauren Billheimer, Project Engineer
Trigen-BioPower, Inc.
302 Duke St.
Forest City, NC 28043
Phone: [phone]
Fax: [phone]
Please note that all other information, including the facility contact, facility addresses, and
facility processes, remains unchanged. This information is applicable to three water quality
permits at each of the following facilities:
Ricky Styles, Plant Superintendent
Trigen-BioPower, Inc.
2859 Old Linville Road
1Vlanon, NC 28752
Ash Reuse Permit No. WQ0010689
..Scrubber Recycle System Permit No. WQ0001512
Storimwater Permit No. NCG210028
6
MC � 6
� � 2002
Y'YATER NJr,r err• n':`,T JYi

And
Frankie Fox, Plant Superintendent
Trigen-BioPower, Inc.
302 Duke Street
Forest City, NC 28043
Ash Reuse Permit No. WQ0010690
Scrubber Recycle System Permit No. WQ0003449
Stormwater Permit No. NCG210029
For questions or comments, please contact Tony Leopard or me at the above numbers.
Sincerely,
Lauren Billheimer
Project Engineer
cc: Jim Henslee, via e-mail
Tom Pannell, via e-mail
Tony Leopard
Ricky Styles
Frankie Fox

NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley,'Governor
WATER QUALITY SECTION
May 22, 2002
Mr. David B. Dehart, PE
Manager of Engineering and Environmental,
Health and Safety
Trigen-Biopower, Inc.
205 Regency Executive Park Drive
Suite 305
Charlotte, North Carolina 28717-2957
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D.
Acting Director
Di.v:ision of Water Quality
Subject: Routine Inspection
Permit Number WQ0010689 —
Distribution of Residual Solids
Ash Reuse Program
Trigen-Biopower, Inc.
cDowell County
Dear Mr. Dehart:
On May 13, 2002 1 performed a Routine Inspection of the Trigen-Biopower Ash Reuse
Program in McDowell County. Mr. Ricky Styles assisted me during this inspection. The
assistance given during the inspection was greatly appreciated. The purpose of the inspection
was to determine the compliance status of the Program. Attached is a copy of the inspection
report for your records.
I found the program to be well maintained and effective. The product stored on=site was
not discharging and the surrounding area showed no signs of previous discharges. The
application fields were well maintained, with adequate buffers to prevent surface and ground
water contamination. Therefore, it was determined that the. program meets all permit
requirements and is compliant.
Asheville Regional Office, 59 Woodfrn Place, Asheville, North Carolina 28801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled\110% Post Consumer Paper

9 a
Mr. Dehart
May 22, 2002
Page 2
Again, thank you for your cooperation during the inspection. Should you have any
questions regarding this or other water quality issues, please contact me at [phone].
Since ely,
Lar r st
Environmental Technician
Enclosure
xc: Lauren Billheimer —Staff Engineer
Ricky Styles — Plant Manager
McDowell County Health Department
Asheville Regional Office, 59 Woodfin Place, Asheville, North Carolina 2$801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled\l 10% Post Consumer Paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary NCDENR
Gregory J. Thrope, Ph.D., Acting Director NCnTH CA70- NA DErArITWENT OF'
EWV1QCV%rrr:KffAN1! N,&TAP._&L Pr7lnt]�(ICt'
Non -Discharge Compliance Inspection,
WQ Permit Number WQ0010689 County McDowell
Permittee Trugen Blogower Inc-N Come As Npdes Number(s)
Issuance Date 7/7/2000
Expiration Date 6/30/2005
Soc Issuance Date Soc ExpirationDate
Permittee Contact David DeHart Phone Permittee Contact 704.665.0117
ORC Certification #
ORC Name Ricky Styles Phone ORC 828.756.4946
24hr Contact Name Phone 24hr
Reason For Inspection (Select One) 10 Routine 0 Complaint 0 Follow -Up 0 Other...
Type Of Inspection (Select One) 10 Collection System 0 Spray Irrigation 0 Residual
Inspection Summary AghR O.Usgy ..ro gram ...........................................
.........................................................................................................................................
..................................................................................................................................................................................................... *­ ....... *­...........
...... **'**' The-vermi-ttee-has-a-w6ll maintained and effective system and was not discharninct at the time
Inspector's Name Larry Frost
Phone Inspector 828.251..6208
Inspection Date 5/13/2002
.... Appi1e.0 ..
......................................................................................................................................................................
........................................................................................ I .............................................................................
Inspector's Title Environmental Technician
Fax Inspector 828.251.6452 -
page

Non Dischar -} Compliance Residual' spection
Permittee ITrigen Biopower Inc-N Cove As
Permit Number IWQ0010689
Inspection Date 5/13/2002
Type
O Land Application OQ Distribution and Marketing
Was a copy of current permit available? OQ Yes O No
Were current metals and nutrient analysis available? (see permit for frequency) 10 Yes O No N/A
a. TCLP analysis? Oi Yes O No O N/A
b. SSFA ( Standard Soil Fertility Analysis)? 10 Yes O No O NIA
Were nutrient and metal loading calculated to determine most limiting parameters? YTD 10 Yes O No O N/A
Were hauling records available? OQ Yes O No O N/A
How many gallons / tons hauled during the calendar year to date? 12608 tons
Were field loading records available? 10 Yes O No O N/A
Were records of lime purchased available? JOYes O No O N/A
❑ Fields
❑ Pathogen and Vector Attraction Reduction (if applicable)
Were Operation and Manintance records present? JoYes O No .O N/A
Were Operation and Manintance records Complete? O Yes O No O NIA
Has the land application equipment been calibrated? 10 Yes O No O NIA
Pathogen and Vector Attraction (if applicable):
a. Fecal coliform SM 9221 E ( Class A or B 10 Yes O No OQ N/A
O ( Class A, all test must be <1000 MPN / dry gram )
O (Geometric mean of 7 samples per monitoring period for Class B <2.0*106 CFU / dry gram )
Fecal coliform SM 9222 D ( Class B only) 10 Yes O No OQ NIA
O ( Geometric mean of 7 samples per monitoring period for Class B <2.0*106 CFU / dry gram )
b. Salmonella ( Class A, all tests must be < 3MPN / 4 grams dry) O Yes O No OQ NIA
c. Time / Temp on: 10 Yes O No OQ N/A
❑ Digester (MCRT) ❑ Compost ❑ Class A lime stabilization
d. Volatile Solids Calculations. 10 Yes O No Q N/A
e. Bench -Top Aerobic/ Anaerobic digestion results. 10 Yes O No - N/A
f. pH records fo Lime Stabilization (Class A or B). 10 Yes O No NIA
Treatment
Equipment
Additional
Equipment
❑ Aerobic Digestion ❑ Alkaline Stabilization (Other)
❑ Auto Thermophilic Aerobic Digestion ❑ Compost (Windrow)
❑ Anaerobic Digestion ❑ Compost (Aerated Static Pile)
❑ Drying Beds ® Other
❑ Alkaline Stabilization (Lime)
page 2

a t
Non Dischai Compliance Residua' ispection
Permittee Trigen Biopower Inc-N Cove As
Permit Number WQ0010689
Inspection Date 5/13/2002
Transport
Was a copy of the permit in transport vehicle? 0 Yes No NIA
Was a copy of the spill control plan in vehicle? Q Yes' No N/A
Did transport vehicle appear to be maintained? 0 Yes O No N/A
Storage
❑ Lagoon ❑ AST ❑ UST ❑Septic Tank ❑ Drying Beds [:]Concrete Storage Pads
How many months storage?
Was a copy of the spill control plan on site? 10 Yes 0 No 0 N/A
If Applicable:
Is lagoon lined? 0 Yes Q No 0 N/A
Above Ground Tank ❑ Aerated ❑ Mixed Aerated Hp: Mixed Hp:
Under Ground Tank ❑ Aerated ❑ Mixed Aerated Hp: Mixed Hp:
Sampling
Describe Sampling:
Several points in the pile.
Was sampling adequate?
Was sampling representative?
Were buffers adequate?
Is the cover crop type specified in permit?
Were.exceedence of PAN limits documented?
Was the application site in good condition?
Was the site free of runoff / ponding? ,
Was the acreage specified in the -permit being utilized?
Was the application equipment present and operational?
Were there any limiting slopes on disposal field?
(10% for surface application)
(18% for subsurface application)
Are monitoring wells called for in permit?
Was there access restrictions and / or signage?
Was a copy of the permit on site during application events?
Was the application site free of odors or vectors?
Were nutrient / crop removal practices in place?
OO Yes 0 No 0 N/A
DQ Yes O No . 0 N/A
Yes 0 No
Q Yes 0 No DQ Wk]
0 Yes 0 No NIA
Yes 0 No 0 N/A
Yes 0 No 0 N/A
O Yes 0 No * N/A
O Yes * No 0 N/A
0 Yes DQ
O Yes * No O N/A
O Yes 0 No DQ N/A
O Yes 0 No DQ N/A
O Yes 0 No 0 N/A
DQ Yes O No 0 N/A
0 Yes 0 No * N/A
page 3

North Carolina Department of Environment and Natural Resources
Michael F. Easley, Gwvernor
Mr. David B. Dehart, PE
Manager of Engineering and Environmental,
Health and Safety
Trigen-Biopower, Inc.
205 Regency Executive Park Drive
Suite 305
Charlotte, North Carolina 28717-2957
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
Subject: Compliance Evaluation Inspection
Permit Number WQ0001512 —
Wastewater Recycling
Permit Number WQ0010689 —
Distribution of Residual Solids
Permit Number NCG210028 —
Industrial Stormwater
Trigen-Biopower, Inc.
McDowell County
Dear Mr. Dehart:
On April 16, 2002 1 performed a Compliance Evaluation Inspection of the Trigen-Biopower
Facility in McDowell County. You, Ms. Lauren Billheimer and Mr. Ricky Styles assisted me during
this inspection. It was a pleasure meeting you and your folks. The assistance given during the
inspection was greatly appreciated. The purpose of the inspection was .to determine the
compliance status of each of your Division of Water Quality Permits. The following observations,
notes and inspection report were made on site.
With regards to Permit Number WQ0001512 — Wastewater Recycling; A records review for
the last three (3) .years revealed no permit violations. I found the facility to be well maintained,
including; piping, pumps, basins and appurtenances. One basin was in a condition of having the
Asheville Regional Office, 59 Woodfin Place, Asheville, North Carolina 28801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled\110% Post Consumer Paper

David Dehart
May 1, 2002
Page Two
water decanted and the solids removed, the other was in use. The maintenance records and
recorded inspections were excellent. I saw no evidence of discharge of wastewater from the
system. My only recommendation was that you record a daily freeboard level. Your permit
requires that the freeboard in the two (2) settling basins shall not be less than two (2) feet at any
time. All records should be maintained for a minimum of three (3) years. Therefore, the facility
was determined to be in compliance with its wastewater recycling permit.
With regards to Permit Number Permit Number WQ0010689 — Distribution of Residual
Solids; A records review for the last three (3) years revealed no permit violations. There was no
application being done at the time of the inspection. Therefore, it is requested that you contact
me before the next application of residual solids, in order that I might inspect the actual land
application process.
With regards to Permit Number NCG210028 — Industrial Stormwater; I have attached a
copy of my report for your records. I was very pleased to see that Trigen-Biopower is in
substantial compliance with its stormwater permit. I do, however, recommend that measures be
taken to remove wood chips from the adjacent stream banks. I, also, recommend the
establishment of a fifteen (15) foot riparian buffer zone. The buffer zone should extend fifteen
(15) feet from the normal stream bank height and should be planted with native vegetation to
prevent wood chips from reaching the adjacent stream and prevent stream bank erosion. These
recommendations are made for all riparian areas, especially areas where wood chips are stored.
Finally, I want to thank you again for your cooperation during the inspection. Should you
have any questions regarding this or other water quality issues, please contact me at (828) 251-
6208.
Sincerely,
11 �42��
Larry Frost
Environmental Technician
Enclosure
xc: Lauren Billheimer —Staff Engineer
Ricky Styles — Plant Manager
McDowell County Health Department
Asheville Regional Office, 59 Woodfin Place, Asheville, North Carolina 28801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled\110% Post Consumer Paper

Au
TRIGEN-BIOPOWER, INC.
205 REGENCY EXECUTIVE PARK DRIVE, SUITE 305, CHARLOTTE, NC 28217-2957
[phone] FAX: [phone] _
TRIGEN
February 27, 2002
CERTIFIED MAIL # 7099 3400 00017765 6314
RETURN RECEIPT REQUESTED
NC Division of Water Quality -
Water Quality Section
Non -Discharge Compliance Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Permit No. WQ0010689
Trigen-BioPower, Inc. (TBP), Marion, NC
Steam Generating Plant Ash Reuse Program Report
Permit Condition III 5
'Y It
r N
PIP,�.
o .
°oi 0
i
Per permit condition III 5, please find enclosed the information specified in permit conditions III
2 and III 3.
Permit Condition Comment
III 2a The source of the ash is a wood -fired boiler located at TBP's Marion, NC
facility. The quantity of ash produced during 2001 was approximately 2,260
tons. The quantity of ash applied during 2001 was approximately 2608 dry
tons, which includes ash that was present in inventory on January 1, 2001.
III 2b Name of recipient: Jeffery J. Banks, 5138 Old Linville Road, Marion, NC
28752 ,
Quantity received: 494 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Ricky Styles, 1429 Burma Road, Nebo, NC 28761
Quantity received: 117 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Alan Wilson, 4862 Old Linville Road, Marion, NC
28752
Quantity received: 597 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Terry English, Rt. 3, Highway 221 North, Marion, NC
28752
Quantity received: 1,400 dry tons
Intended use: The wood ash was land applied.
/0/

NC Division of Water Quality
February 27, 2002
Page 2 of 2
III 3 & See enclosed reports from the North Carolina Department of Agriculture
III 4 1 and Pace Analytical Services, Inc.
Please contact me at 704-665-0116 if you have questions or require additional information.
Sincerely,
Lauren Billheimer, P.E.
EHS Engineer
Enclosure — (1/31/02 NCDA report, 2/8/02 Pace Analytical Services, Inc. report)
cc: NC Division of Water Quality (2 copies w/ enclosure)
Jim Henslee - TBP (via e-mail, w/o enclosure)
T.A. Pannell - TBP (via e-mail, w/o enclosure)
Tony Leopard — TBP
Ricky Styles — TBP
Jim Qin — TWP

Grower: Trigen-BioPower Copies To: Trigen-BioPower Inc.
c%Ricky Styles
2857 Old Linville Road
Marion, NC 28752
Trigen-BioPower Inc.
Waste Analysis R..,,ort Farm: attn:Lauren Blllheimer
205 Regency Executive Park Dr. #305
1/31/02 McDowell County Charlotte, NC 28217
::,: � x - a»:. r n .... .Fr ,. , ^:M'. k. b.F..,. , w.r5 ,.�. .. 5 : i a... w.. r. x Z' k 9+v "'.s9n> ✓: „.
Sam ile LO: N P R ' 'Ca mg S Fe Mn Zn Cu B Mo Cl C
Total 678 1753 11970 84185 7033 975 10187 1143 83.6 68.1 101
Waste Code:
SAR
Description:
Indust. -Stack Ash
IN-N
NH4
NO3
OR-N
Urea
Al Se Li
6426 12.1 1.21 19.7
rL . 'p!o is �
17 �
3 1�
12.38
SS ON
80.20 48.75 2.30

ce Analytical
www.pacelabs.com
Trigen-BioPower. Inc.
205 Regency Executive Park Dr.
Suite 305 Ad
Charlotte; NC 28217
Attn: Ms. Lauren Bi §ffiemer. P.E.
Phone: [phone]'.
Solid result.509-reported on a dry weight basis
,t:Y
Lab Sample No: 922056627
ent:T Clia'MDle ID: MARION, NC -WOOD ASH
Metals
Trace ICP Metals, TCLP Leach
Date Digested
Trace ICP Metals, TCLP Leach
Arsenic
Barium
Cadmium
Chromium
Lead
Selenium
Silver
Date Digested
Metals, Trace ICP
Aluminum
Arsenic
Barium
Beryllium
Chromium
Molybdenum
Selenium
Silicon
Silver
Titanium
Date Digested
Pace Analytical Services, Inc.
9800KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax.' 704.875.9091,
Lab Project Number: 9229669
Client Project ID: Marion, NC -Wood Ash
Project Sample Number: 9229669-001 Date Collected: 12/18/01 13:38
Matrix: Soil Date Received: 01/25/02 10:00
Results Units Report Limit Dilution Analyzed CAS No. Ftnote Re4 Limit
Prep/Method: EPA 1311 / EPA 6010
Prep/Method: EPA 3010 / EPA 6010
0.48
mg/l
0.025
42.
mg/1
0.025
ND
mg/l
0.0050
1.6
mg/l
0.010
0.74
mg/l
0.015
ND
mg/l
0.025
0.016
mg/l
0.010
Prep/Method: EPA 3050 / EPA 6010
36000
mg/kg
11.
9.7
mg/kg
0.55
940
mg/kg
0.55
1.5
mg/kg
0.11
39.
mg/kg
0.22
1.3
mg/kg
0.55
ND
mg/kg
0.55
13000
mg/kg
11.
0.37
mg/kg
0.22
1600
mg/kg
0.55
01/28/02
0.8 01/31/02 18:40 RWF 7440-38-2
0.8 01/31/02 18:40 RWF 7440-39-3
0.8 01/31/02 18:40 RWF 7440-43-9
0.8 01/31/02 18:40 RWF 7440-47-3
0.8 01/31/02 18:40 RWF 7439-92-1
0.8 01/31/02 18:40 RWF 7782-49-2
0.8 01/31/02 18:40 RWF 7440-22-4
01/29/02.
0.9 02/04/02 16:04 DJR 7429-90-5
0.9 02/04/02 16:04 DJR 7440-38-2
0.9 02/04/02 16:04 DJR 7440-39-3
0.9 02/04/02 16:04 DJR 7440-41-7
0.9 02/04/02 16:04 DJR 7440-47-3
0.9 02/04/02 16:04 DJR 7439-98-7
0.9 02/04/02 16:04 DJR 7782-49-2
0.9 02/04/02 16:04 DJR 7440-21-3
0.9 02/04/02 16:04 DJR 7440-22-4
0.9 02/04/02 16:04 DJR 7440-32-6
01/28/02
Mercury, CVAAS, TCLP Leachate Prep/Method: EPA 7470 / EPA 7470
Mercury ND mg/l 0.00020 0.8 01/30/02
Date: 02/08/02
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 12 This report shall not be reproduced, except in full,
NC Drinking Water 06
990
Sc 99006 without the written consent of Pace Analytical Services, Inc.
,N ACCpRO
44,
WO F
DJR 7439-97-6
Page: 1
Laboratory Certification IDs
KY Drinking Water 90090
VA Drinking Water 213
FL NELAP E87627

Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
ce Analytical'
`� Huntersville, NC 28078
Phone: [phone]
www.pacelabs.com s`Fax:[phone].
Lab Project Number: 9229669
Client Project ID: Marion, NC -Wood Ash
Lab Sample No: 922056627. Project Sample Number: 9229669 001 Date Collected: 12/18/01 13:38
Client Sample ID: MARIONI :'OOD ASH Matrix: Soil Date Received: 01/25/02 10:00
Parameters .«zt'' Results Units Report Limit Dilution Analyzed CAS No. Ftnote Reg Limit
Mercury, CVAAS,
Prep /Method: EPA 7471 / EPA 7471
Mercury „;j�
'ON NO mg/kg 0.0042 0.9 01/30/02 DJR 7439-97-6
��3,==:-r
Wet
oisture Method: % Moisture
Moisture 17.1 %
0.8 01/25/02 HEH
pH
Prep/Method:
EPA 9045 /
EPA 9045
pH
12.4
units
0.8
02/04/02
CDE
Paint Filter Liquids Test
Prep/Method:
EPA 9095 /
EPA 9095
Free Liquids
ND
ml/5min
1.0
0.8
02/05/02
AST
GUMS Semivolatiles
Semivolatile Organics, TCLP
Prep/Method:
EPA 3510 /
EPA 8270
1,4-Dichlorobenzene
ND
mg/l
0.75
0.8
02/06/02
05:41
CWA
106-46-7
2,4-Dinitrotoluene
ND
mg/l
0.013
0.8
02/06/02
05:41
CWA
121-14-2
Hexachloro-1,3-butadiene
NO
mg/1
0.050
0.8
02/06/02
05:41
CWA
87-68-3
Hexachlorobenzene
ND
mg/1
0.013
0.8
02/06/02
05:41
CWA
118-74-1
Hexachloroethane
ND
mg/l
0.30
0.8
02/06/02
05:41
CWA
67.72-1
2-Methylphenol (o-Cresol)
ND
mg/1
20.
0.8
02/06/02
05:41
CWA
95-48-7
3&4-Methylphenol
NO
mg/1
20.
0.8
02/06/02
05:41
CWA
Nitrobenzene
ND
mg/1
0.20
0.8
02/06/02
05:41
CWA
98-95-3
Pentachlorophenol
ND
mg/1
10.
0.8
02/06/02
05:41
CWA
87-86-5
Pyridine
ND
mg/l
0.50
0.8
02/06/02
05:41
CWA
110-86-1
2,4,5-Trichlorophenol
ND
mg/l
40.
0.8
02/06/02
05:41
CWA
95-95-4
2,4,6-Trichlorophenol
ND
mg/l
0.20
0.8
02/06/02
05:41
CWA
88-06-2
Nitrobenzene-d5 (S)
72
%
1.0
02/06/02
05:41
CWA
4165-60-0
2-Fluorobiphenyl (S)
63
%
1.0
02/06/02
05:41
CWA
321-60-8
Terphenyl-d14 (S)
110
%
1.0
02/06/02
05:41
CWA
1718-51-0
Phenol-d5 (S)
37
%
1.0
02/06/02
05:41
CWA
4165-62-2
2-Fluorophenol (S)
47
%
1.0
02/06%02
05:41
CWA
367-12-4
2,4,6-Tribromophenol (S)
94
%
1.0
02/06/02
05:41
CWA
Date Extracted
02/01/02
GC Semivolatiles
Pesticides, TCLP Leachate
Prep/Method:
EPA 3510 /
EPA 8081
gamma-BHC (Lindane)
NO
mg/l
0.00050
0.8
02/05/02
CWA
58-89-9
Date: 02/08/02
Laboratorkcertification IN REPORT OF LABORATORY ANALYSIS
NC Wastewater 12 This report shall not be reproduced, except in full,
NC Drinking Water 37706 without the written consent of Pace Analytical Services, Inc.
Sc 99006
W� C�
Page: 2
Laboratory Certification IDs
KY Drinking Water 90090
VA Drinking Water 213
FL NELAP E87627

TM
ceAnalytical
www.pacelabs.com
Lab Sample No: 922056627�
U.
Client Sample ID: MARION,NGbOD ASH
Chlordane (Techn= )"
Endri n
Heptachlorww°
Heptachl�o{epoxi de
Met flpyeftl or
XShene
etrachloro-m-xylene (S)
Decachlorobiphenyl (S)
Date Extracted
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 109
Huntersville, NC 28078
Phone: [phone]
Fax [phone].
Lab Project Number: 9229669
Client Project ID: Marion, NC -Wood Ash
Project Sample Number: 9229669-001 Date Collected: 12/18/01 13:38
Matrix: Soil Date Received: 01/25/02 10:00
Results
Units
Report Limit
Dilution Analyzed
CAS No. Ftnote Reg Limit
NO
mg/l
0.00050
0.8
02/05/02
CWA
57-74-9
NO
mg/l
0.00050
0.8
02/05/02
CWA
72-20-8
NO
mg/l
0.00050
0.8
02/05/02
CWA
76-44-8
NO
mg/l
0.00050
0.8
02/05/02
CWA
1024-57-3
NO
mg/l
0.00050
0.8
02/05/02
CWA
72-43-5
NO
mg/1
0.00050
0.8
02/05/02
CWA
8001-35-2
48
%
1.0
02/05/02
CWA
877-09-8
94
%
1.0
02/05/02
CWA
2051-24-3
02/02/02
Acid Herbicides, TCLP Leachate Prep/Method: EPA 3510 / EPA 8151
2.4-D ND mg/l 1.0 0.8 02/07/02 CBE 94-75-7
2,4.5-TP (Silvex) NO mg/l 0.10 0.8 02/07/02 CBE 93.72-1
2.4-DCPA (S) 131 % 1.0 02/07/02 CBE 19719-28-9
Date Extracted 02/04/02
GUMS Volatiles
Volatile Organics. TCLP Leach
Benzene
2-Butanone (MEK)
Carbon tetrachloride
Chlorobenzene
Chloroform
1.2-Dichloroethane
1.1-Dichloroethene
Tetrachloroethene
Trichloroethene
Vinyl chloride
Toluene-d8 (S)
4-Bromofluorobenzene (S)
Dibromofluoromethane (S)
1,2-Dichloroethane-d4 (S)
Date: 02/08/02
Prep/Method:
EPA 8260 /
EPA 8260
ND
mg/l
0.020
0.8
02/05/02
18:42
RWS
ND
mg/l
0.40
0.8
02/05/02
18:42
RWS
NO
mg/l
0.020
0.8
02/05/02
18:42
RWS
ND
mg/l
0.020
0.8
02/05/02
18:42
RWS
ND
mg/l
0.020
0.8
02/05/02
18:42
RWS
ND
mg/l
0.020
0.8
02/05/02
18:42
RWS
ND
mg/l
0.020
0.8
02/05/02
18:42
RWS
ND
mg/l
0.020
0.8
02/05/02
18:42
RWS
ND
mg/l
0.020
0.8
02/05/02
18:42
RWS
ND
mg/l
0.020
0.8
02/05/02
18:42
RWS
98
X
1.0
02/05/02
18:42
RWS
92
%
1.0
02/05/02
18:42
RWS
96
%
1.0
02/05/02
18:42
RWS
94
X
1.0
02/05/02
18:42
RWS
Laboratory Certification IDS REPORT OF LABORATORY ANALYSIS
NC Wastewater 12 This report shall not be reproduced, except in full,
NC Drinking Water 37706 without the written consent of Pace Analytical Services, Inc.
SC 99006 ,N Acco, �
71-43-2
78-93-3
56-23-5
108-90-7
67-66-3
107-06-2
75-35-4
127-18-4
79-01-6
75-01-4
2037-26-5
460-00-4
17060-07-0
Page: 3
Laboratory Certification IDs
KY Drinking Water 90090
VA Drinking Water 213
FL NELAP E87627

..
Pace Analytical Services, Inc.
ceAnalytical'm
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone. [phone]
www.pacelabs.com
Fax: [phone].
Lab Project Number: 9229669
Client Project ID: Marion, NC -Wood Ash
PARAMETER
4a=
ND Not detected .a,`oc above adjusted reporting limit
NC Not Calcul ViN
J Estimat--l"', centration above the adjusted method detection limit and below the adjusted reporting limit
(S) Surroa.
[1] Ana lys$ conducted in excess of EPA recommended holding time.
Date: 02/08/02
Laboratoryy Certification IN REPORT OF LABORATORY ANALYSIS
NC Wastewater 12 This report shall not be reproduced, except in full,
NC Drinking Water 37706 without the written consent of Pace Analytical Services, Inc.
Sc 99006
µ ACCOgo
4tC � c
W �
o `i
Page: 4
Laboratory Certification IDs
KY Drinking Water 90090
VA Drinking Water 213
FL NELAP E87627

Aeo
TRIGEN-BIOPOWER, INC.
205 REGENCY EXECUTIVE PARK DRIVE, SUITE 305, CHARLOTTE, NC 28217-2957
[phone] FAX; [phone]
TRIGEN
February 26, 2001
CERTIFIED MAIL # 7099 3400 0001 7766 5644
RETURN .RECEIPT REQUESTED
NC Division of Water Quality
Water Quality' Section
Non -Discharge Compliance Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Permit No. WQ0010689
Trigen-BioPower, Inc. (TBP), Marion, NC
Stearn Generating Plant Ash Reuse Program Report
Permit Condition III 5
Per permit condition III 5, please find enclosed the informati
2 and III 3.
AdD
R
NomOsFRQ�
°ha�9 cC�T YSF�T
ma//1?/7,0e ant.'
©1
Permit Condition Comment
III 2a The source of the ash is a wood -fired boiler located at TBP's Marion, NC
facility. The quantity of ash applied during 2000 was approximately 1811
dry tons.
III 2b Name of recipient: Jeffery J. Banks, Route 3, Route 199, Marion, NC
28752
Quantity received: 104 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Ricky Styles, 1429 Burma Road, Nebo, NC 28761
Quantity received: 77 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Alan Wilson, 4862 Old Linville Road, Marion, NC
28752
Quantity received: 230 dry tons
Intended use: The wood ash was land applied.
Name of recipient: John English (McCall property), Highway 221 North,
Marion, NC 28752
Quantity received: 1,400 dry tons
Intended use: The wood ash was land applied.

NC Division of Water Quality
February 26, 2001
Page 2 of 2
III 3 See enclosed reports from the North Carolina Department of Agriculture
and Pace Analytical Services, Inc.
Please contact me at 704-665-0116 if you have questions or require additional information.
Sincerely,
Lauren Billheimer, P.E.
Staff Engineer
Enclosure — (12/14/00 NCDA report, 2/29/00 Pace Analytical Services, Inc. report)
cc: Cvilion='of -a er ua1%ty (copis3ww/ enclo�te)--
Jim Henslee - TBP (via e-mail, w/o enclosure)
T.A. Pannell - TBP (via e-mail, w/o enclosure)
Ricky Styles - TBP
Jim Qin — TWP

Im
W02
WGG21
_.ort N _.�
�7.
Grower: Trigen-BioPower Copies To: County Extension Director
c%Ricky Styles USDA-NRCS-McDowell
Rt. 3 Box 142 Trigen-BioPower Inc.
t Marion, NC 28752
Trigen-BioPower Inc.
07
Waste Analysis Relhort Farm: McDowell attn:Lauren Billheimer
1 205 Regency Executive Park Dr. #305
12/14/00 McDowell County Charlotte, NC 28217
Sam le Info,
Laborato" ResnLts
million : nless`otherwse
., ,
arfs
er
notes _. ... ._s_ , .
Sample ID:
N
P K Ca mg S Pe Mnyngo Cu B Mo Cl C
M�
Total 1046
2G3-'4 21133 116690 10658 1248 8739 14 4r OW fa 31.5
IN N
Waste Code:
NH4
Na Ni Cd A Al Se Li pH SS C•N DM% CCE% ALE ton_
SAR
NO3
7094 25:3 5.11 28.1 12.49 78.64 45.50 2.50
Description:
OR-N
Indust. -Stack Ash
Urea
,'. ',.'3 - , .u,.,3tdxh:. $> .4 a. .. s.R 1"�: "i 4'. 'r , .. _. `f
Recommendafi�on
b.�m�..
=, 4dY ., ..a.s. ..f, .X.6. .�, ., ... .'t:: •1 .> ... �. t yr
Nutrients< a Y ble for First. -ro A rUs ton :wetbaszs=
,.
_ `aher <Lle eats llis to ' :wet bu s"
„� u.. ,.....:. ..
. �.. ... ...as
A lzc Ca _u,
C
Pb Lt�.`
,...�
... ....�-: §� ..I....,. », ...ax ,�. .:^Y*..... ... . � ...:. ,...; . .-3
t, ,may . a ,?. 2. ,,.,, r �., :.. .. _ .>: ..... ,>. ,.,, x ::
...Al
001....� 0:04::�
...a'.. . ;, :,.,:.. ,... ..
.. ,»: » ti
. ,... . F. '..,,... .,.,.. :. ,.. .,:.x._x ',...,,z .: ., .,.,�.. �. ,:. ,... ., ,:,,,
SolIncor ., ,.. 0 ru ........ _., _...�. s...��._. ...�9�, �.�.7�6�����,3�.�:....,7.46�w....��3��,",R.�.�._���< 1�,A ,1,8� ,O,1,4,,�, 01,b
�. r
eut 'ahzi ., n wis v : oo ,_ , e:wasfe. rnda t.s u d:,. e re . ,.,' s- e e �a ; 1 a Ide ire ran .1 0 : r w .
. _� al� a ..d_.- . c0 1.. l ..d,�t.rate d . A a ust o H. o ie, s d c or cr , oduction .The.. l; tnd�cafi=s he mount.of the .aste..roduct:necdedto.e ualthe
.. ". ., .,. ,;... . ,. .w, ..
eutrahzin ue of. f �comtnciat, r�cultur Mime.
,a nerto �,.
y✓Ios7��, G6. d(����v RC r
N ( 7eb�
wf�'fZ ,z:yq
PR �L'$
25,
2-
-2

aceAnalyticalm
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax:.[phone]
DATE: 12/29/00
PAGE: 1
Trigen-'BioPower. Inc. .:Pace Project Number:"9219138
205'Regency Executive Park Dr. Client Project ID: Marion,:NC Wood Ash
Suite 305
Charlotte, AC 28217
Attn:°.Ms..Lauren'Billheimer, P.E.
Phone: [phone]
Solid results are reportedon a dry weight 'basis
Pace Sample No: 921363875 Date Collected:, 12/04/00 _ Matrix: Soil
Client Sample ID: MARION NC WOOD ASH Date Received: 12/08/00
Parameters Results Units PRL App. OF Analyzed Analyst CAS# Footnotes
Inorganics Prep .
Trace ICP Metals, TCLP Leach.
Method: EPA 6010
Prep Method: EPA
1311
Date Digested
12/10/00
Volatile Organics, TCLP Leach.
Method: EPA 8260
Prep Method: EPA
1311
Date Leached
'0.00
0.79
12/15/00 LYS
Metals
Trace ICP Metals, TCLP Leach.
Method: EPA 6010
Prep Method: EPA
3010
Arsenic
NO
mg/l
0.025
0.79
12/14/00 RWF
7440-38-2
Barium
6.0
mg/l
0.025
0.79
12/14/00 RWF
7440-39-3
Cadmium
ND
mg/l
0.005
0.79
12/14/00 RWF
7440-43-9
Chromium
0.019
mg/l
0.01
0.79
12/14/00 RWF
7440-47-3
Lead
ND
mg/1.
0.025
0.79
12/14/00RWF
7439-92-1
Selenium
ND
mg/1'
0.025•
0.79
12/14/00 RWF
7782-49-2
Silver
NO
mg/l
0.01
0.79
12/14/00 RWF
7440-22-4
Date Digested
12/11/00
Metals, Trace ICP
Method: EPA 6010
Prep Method: EPA
3050
Aluminum
32000
mg/kg.
12
0.98
12/11/00 RWF
7429-90-5
Arsenic
7.3
mg/kg
0.62
0.98
12/11/00 RWF
7440-38-2
Barium
1200
mg/kg
0.62
0.98
12/11/00 RWF
7440-39-3
Beryllium
1.8
mg/kg
0.12
0.98
12/11/00 RWF
7440-41-7
Chromium
34
mg/kg
0.25
0.98
12/11/00 RWF
7440-47-3
Molybdenum
1.7
mg/kg
0.62
0.98
12/11/00 RWF
7439-98-7
Selenium
1.1
mg/kg
0.62
0.98
12/11/00 RWF
778249-2
Silicon
26000
mg/kg
12
0.98
12/11/00 RWF
7440-21-3
Laboratory Certification IDs
REPORT OF
LABORATORY
ANALYSIS
Laboratory Certification IDs
NC Wastewater 12
KY
Drinking Water 90090
NC Drinking Water 37706
This report shall
not be reproduced,
except in full,
TN
UST List
Sc 99006
without the written
consent of
Pace Analytical Services, Inc.
VA
Drinking Water 213

Pace Analytical Services, Inc.
Analytical 9800 Ki00
Hunt Avenue, Suite 78
� Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
DATE: 12/29/00
PAGE: 2
Pace Project"Number: 9219138
Client'Project ID: flarion, NC Wood Ash
Pace Sample No:
921363875
Date Collected:
12/04/00
Matrix: Soil
Client Sample ID:
MARION NC WOOD ASH
Date
Received:
12/08/00
'Parameters
Results
Units
PRL
App.'OF
Analyzed
Analyst CAS# footnotes
Silver
0.34
mg/kg
0.25
0.98
12/11/00
iRWF
7440-22-4
Titanium
2200
mg/kg
0.62
0.98
12/11/00
RWF. _
7440-32-6
'Date Digested
12/11/00
Mercury, CVAAS,
TCLP Leachate Method:
'EPA 7470
Prep Method: EPA
7470
Mercury
ND
mg/l
0.0002
0.79
12/11/00
DJR
7439-97-6
Mercury, CVAAS, in Soil
Mercury
Wet Chemistry
Percent Moisture
Percent Moisture
pH
PH
Paint Filter Liquids Test
Free Liquids
GC Semivolatiles
Method: EPA 7471
ND mg/kg O.005
Method: X Moisture
21.4 X
Method: EPA 9045
12.8 units 0
Method: EPA 9095
ND m1/5min 1
Pesticides, TCLP Leachate
Chlordane (Technical)
ND
Endrin
ND
Heptachlor
ND
Heptachlor Epoxide
ND
gamma-BHC (Lindane)
ND
Methoxychlor
ND
Toxaphene
ND
Decachlorobiphenyl (S)
80
Tetrachloro-meta-xylene (S)
55
Date Extracted
Acid Herbicides, TCLP Leachate
2,4-D
ND
2,4,5-TP(Silvex)
ND
Di chl orophenyl Acetic Acid (S)
59
Date Extracted
GQ.OMrVWM%dification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
Prep Method: EPA 7471
0.98 12/11/00 DJR 7439-97-6
Prep Method:
0.79 12/12/00 MLH
Prep Method: EPA 9045
0.79 12/11/00 MLH
Prep Method: EPA 9095
0.79 12/20/00 YLJ
Method: EPA 8081
Prep Method: EPA
3510
mg/l
0.0005
0.79
12/13/00
TSG
57-74-9
mg/l
0.0005
0.79
12/13/00
TSG
72-20-8'
mg/l
0.0005
0.79
12/13/00
TSG
76-44-8
m4/1
0.0005
0.79
12/13/00
TSG
1024,-57-3
mg/l
0.0005
0.79
12/13/00
TSG
58-89-9
mg/l
0.0005
0.79
12/13/00,
JSG
72743-5
mg/1
0.0005
0.79
12/13/00
TSG
8001-35-2
%
0.79
12/13/00
TSG
2051-24-3
%
0.79
12/13/00
TSG
877-09-8
12/12/00
Method: EPA 8151
Prep Method: EPA
3510
mg/l
1
0.79
12/18/00
TSG
94-75-7
mg/l
0.1
0.79
12/18/00
TSG
93-72-1
%
0.79
12/18/00
TSG
19719-28-9
12/12/00
REPORT OF
LABORATORY
ANALYSIS
KY
Laboratory Certification IDs
Drinking Water 90090
This report shall not be
reproduced, except in full,
TN
UST List
without the written consent of Pace Analytical Services, Inc.
VA
Drinking Water 213

aceAnalytical~
Pace Sample No: .
Client Sample ID:
'921363875
MARION NC WOOD ASH
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax. [phone]
DATE: 12/29/00
'PAGE: 3
Pace 'Project Number: '9219138
Client Project ID: Marion, NC Wood Ash
Date Collected: 12/04/00 Matrix: Soil
Date Received: . 12/08/00
Parameters
Results
Units
PRL
App.'DF
Analyzed
Analyst CAS#
Volatile Organics, TCLP'Leach.
Method:
EPA 8260
Prep Method: EPA
8260
Vinyl Chloride
NO
mg/l
0.02
'0.79
12/21/00
JRS
75-01-4
1,1-Dichloroethene
ND
mg/l
0.02
0.79
12/21/00
JRS
75-35-4
2-Butanone
ND
mg/l
0.4
0.79
12/21/00
JRS
78-93-3
Chloroform
NO
mg/l
0.02
0.79
12/21/00
JRS
67-66-3
1,2-Dichloroethane
ND
mg/l
0.02
0.79
12/21/00
JRS
107-06-2
Carbon Tetrachloride
ND
mg/l
0.02
0.79
12/21100
JRS
56-23-5
Benzene
ND
mg/l
0.02
0.79
12/21/00
JRS
71-43-2
Trichloroethene
ND
mg/l
0.02
0.79
12/21/00
JRS
79-01-6
Tetrachloroethene
ND
mg/l
0.02
0.79
12/21/00
JRS
127-18-4
Chlorobenzene
ND
mg/l
0.02
0.79
12/21/00
JRS
108-90-7
Dibromofluoromethane (S)
100
%
0.79
12/21/00
JRS
1868-53-7
1,2-Dichloroethane-d4 (S)
103
X
0.79
12/21/00
JRS
17060-07-0
Toluene-d8 (S)
101
X
0.79
12/21/00
JRS
2037-26-5
4-Bromofluorobenzene (S)
96
%
0.79
12/21/00
JRS
460-00-4.
GC/MS Semivolatiles
Semivolatile Organics, TCLP
Method: EPA 8270
Prep Method: EPA
3510
Pyridine
ND
mg/l
0.5
0.79
12/19/00
DHJ
110-86-1
1,4-Dichlorobenzene
ND
mg/l
0.75
0.79
12/19/00
DHJ
106-46-7
2-Methylphenol (C,asell
MD
mg/l
20
0.79
12/19/00
DHJ
95-48-7
Hexachloroethane
ND
mg/1
0.3
0.79
12/19/00
DHJ
67-72-1
3&4-Methyl phenol { C
ND
mg/1
20
0.79
12/19/00
DHJ
Nitrobenzene
ND
mg/l
0.2
0.79
12/19/00.
DHJ
98-95-3
Hexachloro-1,3-butadiene
ND
mg/l
0.05
0.79
12/19/00
DHJ
87-68-3
2,4,6-Trichlorophenol
ND
mg/l
0.2
0.79
12/19/00
DHJ
88-06-2
2,4,5-Trichlorophenol
ND
mg/l
40
0.79
12/19/00
DHJ
95-95-4
2,4'-Dinitrotoluene
ND
mg/l
0.013�
0.79
12/19/00
DHJ
121-14-2
Hexachlorobenzene
ND
mg/l
0.013
0.79
12/19/00
DHJ
118-74-1
Pentachlorophenol,
ND
mg/l
10
0.79
12/19/00
DHJ
87-86-5
Nitrobenzene-d5 (S)
63
%
0.79
12/19/00
DHJ
4165-60-0
2-Fluorobiphenyl (S)
66
%
0.79
12/19/00
DHJ
321-60-8
Terphenyl-d14 (S)
91
X
0.79
12/19/00
DHJ
1718-51-0
Phenol-d6 (S)
21
%
0.79
12/19/00
DHJ
13127-88-3
2-Fluorophenol (S)
34
X
0.79
12/19/00
DHJ
367-12-4
2,4,6-Tribromophenol (S)
84
X
0.79
12/19/00
DHJ
118-79-6
Date Extracted
12/16/00
Footnotes
1
Laboratory Certification IDs Laboratory Certification IN
NC Wastewater 12 REPORT OF LABORATORY ANALYSIS KY Drinking Water 90090
NC Drinking Water 37706 This report shall not be reproduced, except in full, TN UST List
Sc 99006 without the written consent of Pace Analytical Services, Inc. VA Drinking Water 213

aceAnalyticaln
PARAMETER FOOTNOTES
ND Not Detected
NC Not Calculable
PRL Pace Reporting Limit
(S) Surrogate
App. DF Applied Dilution Factor
[1] Acid surrogate recovery outside of control limits.
acid surrogates.
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
DATE: 12/29/00
PAGE: 4
Pace Project Number: 9219138
Client,Project ID: Marion, NC Wood Ash
The data was accepted based on valid recovery of the two remaining
Laboratory Certification IDs Laboratory Certification IDs
NC Wastewater 12 REPORT OF LABORATORY ANALYSIS KY Drinking Water 90090
NC Drinking Water 37706 This report shall not be reproduced, except in full, TN UST List
Sc 99006 without the written consent of Pace Analytical Services, Inc. VA Drinking Water 213

GROUNDWATER SECTION
May 18, 2000
MEMORA NbUM:
TO: David Goodrich
THROUGH: Landon Davidsonr J
FROM: Kay Dechant
SUBJECT: Permit Amendment Review
Trigen-Biopower North Cove
WQ0010690 GW00087
McDowell County
The Asheville Regional Office has no objection to issuance of the subject permit amendment.
The amendment 'request is for an increase in the maximum ash quantity to be reused.

L1t '�grvH Oct
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
May 22, 2000
MEMORANDUM
To: Kim Colson
Through: Ted Bus j
From: David Goodrich
Subject: Trigen-BioPower, Inc. - North Cove
Modification and Renewal of Existing Permit
for the Distribution of Residual Wood Ash
Rutherford County
WQ0010689/GW00087
(Susan Cauley: DEM SERG Review Engineer)
The Groundwater Section is in receipt of the subject application to modify existing Permit
Number WQ0010689, issued on June 24, 1998. The existing application allows ash which is
generated by the operation of the Trigen-Biopower, Inc. steam generation plant in North Cove
to be distributed to the public at unspecified locations. The applicant proposes to renew the
existing permit and to modify it by increasing the maximum allowable volume of residuals from
900 tons of ash per year to 2,500 tons of ash per year. It is the understanding of the
Groundwater Section that individual recipients of the ash are required to sign an agreement form
which states the restrictions of ash application and states the typical chemical composition of the
ash (see attached) .
The Groundwater Section has reviewed the subject application for permit modification and
renewal, and recommends reissuance of the permit with the following conditions:
1. Any groundwater quality monitoring, as deemed necessary by the Division, shall be proNided.
*2. No ash is to be applied in inclement weather or until 24 hours following a precipitation event
equal to a rainfall event of one-half inch or greater in 24 hours.
*This language differs from that of the shell document.
D
U
MAY 2 4 2000
Groundwater Seetioe
Asheville

*3. Land areas which exhibit a seasonal high water table within 3 feet of the surface shall not
be utilized for the application of ash.
If there are any questions please .let me know.
cc: Landon Davidson
Permit Files
--TRIGENNC--
*This language differs from that of the shell document.
2

AdMIk TRIGEN-BIOPOWER, INC.
MWINEW
TRIGEN
Marion, North Carolina
2000 Ash Reuse Program
Information Sheet
Trigen-BioPower, Inc. (Trigen), Route #3, Box 142, Old Linville Highway, Marion, NC 28752 is
the generator of the ash provided to (Recipient).
Application of the aforementioned ash is prohibited except in accordance with the instructions on
this sheet.
The ash will not be applied to any applicable buffer, including a 100 foot buffer between an
application site and any public or private water supply source (including wells) and any stream,
lake, or river. The ash shall not be applied to any site that is flooded, frozen, or snow-covered.
No ash is to be applied in inclement weather or until 24 hours following a precipitation event
equal to a rainfall event of 1/2-inch or greater in 24 hours. Land areas, which exhibit a seasonal
high water table within 3 feet of the surface, shall not be utilized for application of ash.
Adequate procedures shall be provided to prevent surface runoff from carrying any disposal or
stored ash into any surface waters.
The volume of ash application shall be limited to 4 tons/acre/year, unless a demonstration is
made which indicates that a higher application of this material will not exceed the liming
requirements of the crops being grown on the application site, if applicable to crops. A chemical
analysis of the ash is located on page 2 of the information sheet. The most recent analysis
performed by the North Carolina Department of Agriculture is also attached.
No ash shall be used as pipe bedding for sewer or potable water lines.
Signed (Ash Recipient):
Ash Recipient's Address:
Intended Use of Ash:
Expected Qty/Yr:
Date:
Acres of Land:
Page 1 of 2
Updated: 02/21/00

Marion, North Carolina
2000 Ash Reuse Program
Historical Analysis Average
Soil Amendment Properties
Parameter
Calcium Carbonate Equivalent
Potash (K2O)
20-Mesh %
100-Mesh %
Parameter
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Lead
Magnesium
Manganese
Mercury
Nickel
Phosphorus
Potassium
Selenium
Silver
Sodium
Zinc
Metals (Total Concentration)
Concentration
47.0%
2.45%
67.2%
42.8%
Concentration (m
3.79
1,630
1.41
130,000
64.5
65
31.0
12,000
2,230
0.0133
11.1
2,150
15,700
0.401
0.900
5,930
119
TCLP RCRA Toxicity Metals (Lecahable Concentrations)
Parameter
Concentration (mg!)
Arsenic
Less than 0.05
Barium
2.59
Cadmium
Less than 0.01
Chromium
Less than 0.05
Lead
Less than 0.05
Mercury
Less than 0.002
Selenium
Less than 0.01
Silver
Less than 0.05
Page 2 of 2
Updated: 02/21/00

State of North Carolina -
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
April 10, 2000
RALPH D. SMITH; VICE PRESIDENT -OPERATIONS
TRIGEN-BIOPOWER
9140 ARROWPOINT BLVD, STE 370
CHARLOTTE, NORTH CAROLINA 28273
Dear Mr. Smith:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Application No. WQ0010689
Trigen-Biopower, Inc.
Ash Reuse
McDowell County
The Division's Permits and Engineering Unit acknowledges receipt of your permit application and
supporting materials on April 4, 2000. This application has been assigned the number listed above.
Your project has been assigned to Ms. Susan Cauley for a detailed engineering review. Should there be
any questions concerning your project, the review will contact you with a request for additional information.
r
Be aware that the Division's Regional Office, copied below, must provide recommendations from the
Regional Supervisor or a Procedure Four Evaluation for this project, prior to final action by the division.
If you have any questions, please contact Ms. Susan Cauley at 919/733-5083 ext. 546. If the engineer is
unavailable, you may leave a message on their voice mail and they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRES ON
THIS PROJECT.
cc: a �. �llt 'leg1 .film Wate alit,,,
Sincerely,
Mr. Kim H. Colson, .E.
Supervisor, Non -Discharge Permitting Unit
2 N � V <N
Pn
If 2 7 2000 .. L'..
bgATFR fltlALl ' SFUFI%,'
1617 Mail Service Center, Raleigh North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

a
TRIGEN-1310POWER, INC.
9140 ARROWPOINT BLVD., SUITE 370, CHARLOTTE, NC 28273
[phone] FAX: [phone]
TRIGEIN
March 30, 2000'�
CERTIFIED MAIL # Z 276 290 028c;,_g'`�'
RETURN RECEIPT REQUESTED
N.C. Division of Water Quality
Non Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Renewal of Permit No. WQ0010690 — Ash Reuse
Trigen-BioPower, Inc. — North Cove (Marion), NC
McDowell County
Trigen-BioPower, Inc. (Trigen) requests renewal of the above referenced permit. Please note the
following:
• One original and three copies (total four copies) of the "Non -Discharge Permit
Application" with attachments are enclosed.
• The permitted facility does not have treatment works.
• The facility is requesting an increase in the maximum ash quantity to be reused. Check
no. 049236 in the amount of $325 (major modification fee for a major nondischarge
facility) is enclosed.
Please contact me if you have any questions or comments.
Sincerely,
X�� 0�, oo�z�-
David B. DeHart, PE
Staff Engineer
Enclosures
cc: Jerry Caughman (Trigen) — one copy of enclosures
Ricky Styles (Trigen) — one copy of enclosures
Ralph Smith (Trigen) — one copy of enclosures
Jim Qin (TWP) — one copy of enclosures

TRIGEN-BIOPOWER, INC. BANK OF AMERICA 049236
9140 ARROWPOINT BLVO„ ,T
SUITE 370 WICHITAFAU.SEKAS
631SM118
® CHARLOTTE, NC 28273
TRIGEN
DATE CHECK NO. CHECKAMOUNT
PAY 03/28/00 49236, $325.00
Three Hundred Twenty -Five Dollars and 00/100*************************************k****kk******
TO NCDENR Division of Water Quality
ORDER Non -Discharge Branch
OF 1617 Mail Service Center
Raleigh,,NC 27699-1617
TRIGEN-BIOPOWER, INC.
VOID AFTER 80 DAYS
VENDOR NO. VENDOR NAME 049236
NORT08
TRANSACTION GATE REFERENCE GROSS AMOUNT DEDUCTION NET PMOUNi
03/28/00 6890800A $325.00 $325.00
GHECK OATS CHECK NO. TOTALOROSS TOTAL DEDUCTION CHECK AMOUNT
03/28 00 49236 $325.00 $325.00

awl ci
TRIGEN-BIOPOWER, INC.
9140 ARROWPOINT BLVD., SUITE 370, CHARLOTTE, NC 28273
[phone] FAX: [phone]
February 29, 2000
CERTIFIED MAIL # P 053.513 785
RETURN RECEIPT REQUESTED
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance Unit
PO Box 29535
Raleigh, NC 27626-0535
RE: Permit No. WQ0010689, Trigen-BioPower, Inc. (TBP), North Cove Steam Generation Plant, Ash
Reuse Program Report, Permit Condition III 5
Per permit condition III 5, please find enclosed the information specified in permit conditions III 2, III 3,
and III 4.
Permit Condition
Comment
III 2a
The source of the ash is a wood -fired boiler located at TBP's North Cove, NC
facility. The quantity of ash produced during 1999 was approximately 1,110
dry tons'.
III 2b2
Name of recipient: Jeffery J. Banks, Route 3, Route 199, Marion, NC 28752
Quantity received: 612 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Ricky Styles, Route 3, Box 233, Nebo, NC 28761
Quantity received: 53 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Rom English, Route 3, Box 283, Marion, NC 28752
Quantity received: 517 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Henry Brown, Highway 221 North, Marion, NC 28752
Quantity received: 168 dry tons
Intended use: The wood ash was land applied.
' Trigen-BioPower, Inc. plans to ask for a permit modification when the permit application extension is filed neat month. The
original permit ash production estimate was based on text book ash analysis (1% ash) and was too low.
The quantity of ash land applied during 1999 was greater than the quantity of ash produced during 1999 because an ash
inventory_ was present on January 1; 1999. No ash inventory was present on December 31. 1999.

NC Division of Water Quality
February 29, 2000
Page 2 of 2
Permit Condition
Comment
III 2b
Name of recipient: Jack 011is, 2070 Stamey Branch Road, Newland, NC
(continued)
28657
Ouantity received: 240 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Bill Phillips, Route 3, Marion, NC 28752
Ouantity received: 132 dry tons
Intended use: The wood ash was land applied.
Name of recipient: John English, Route 3, Box 283, Marion, NC 28752
Ouantity received: 60 dry tons
Intended use: The wood ash was land applied.
1113
See attached reports from the North Carolina Department of Agriculture and
Par Laboratories, Inc.
III 4
See attached reports from the North Carolina Department of Agriculture and
Par Laboratories, Inc.
Please contact me if you have questions or require additional information.
Sincerely,
SO4,1
David DeHart, P.E.
Staff Engineer
Enclosures (1/20/00 NCDA report and 2/4/00 Par Laboratories, Inc. report)
cc: NC Division of Water Quality (2 additional copies with enclosure)
Jerry Caughman - TBP (w/o enclosure)
Ralph Smith - TBP (w/o enclosure)
Ricky Styles - TBP (w/o enclosure)
Jim Qin — TWP (w/o enclosure)

NCDARCS Agronomic Division 4300 Reedy Creel: Road Raleigh, NC 27607-6465 [phone]
nderstanding the rite Analysis RP-hort
Waste products must be (lisposed of in ways that protect soil an(( water resources. The keys to proper (lisposal inch(cle analyzing the waste product an(( planning application
rates based on crop requirements. The Waste Analysis Report provides information necessary to use these materials as a resource while protecting the environment.
Sample Info This section contains sample identifiers, specifical1v the sample idelliffcatfon number, waste code, and description. Ttlese data arc
Key to Abbreviations
su fillied by the grower oil the information shCCl submitted wilh each sample.
Al
Ahrininuni
Laboratory Results Wastes arc analyzed for up to 21 elements. Sonic are essential for plant growth—{;, major nutrients (N, P, K), secondhuy ntildents
ALE
Agricultural lisle equivalent
(Ca, Afg, S), and micronutrients (Fe, Mn, Zn, Cu, B, Nlo, Cl); others can permanently damage the soil or significantly impact production if allowed to
B
Boron
increase (o,toxic levels (Na, Nf, Cd, Pb, Al, Se, LE). Results are reported in parts per million, and these amounts are ranked as very high (M), high (11),
C
Carbon
llledillill (,II), low (L), of very low (VL) ill relation to all other' Nvasle of Thal type. 11the salnple is a compost of compost ingredicnl, Tallies for pf 1, SS, and
(,a
Calcillnl
(; .N are reported. DM% is reported l'or solid samples. CCE% and ALE are reported for waste products Ihal have neut-alizing value.
MIN
CaCO3 equivalence
Cd
Cadnliunl
Reconvuendations This section call have Ihree parts: (1) Nutrients Available for First Crop based oil application method; (2) Other Elements Ihat
CI
Chlorine
-11i;1V fnlpacl application; and (3) agronomic comments indicating precautions Thal should be lakes when using [Ile waslC.
Cn
Cli
Copper
(1) Predicliolls of nutrients available for (he filth clop arc based oil esliillales of nlillel'aliza(ioll fate and nutrient loss, depending oil application Illelllod.
Ve
Percent dryplatter
Iron
lislimales are reported ill lbs/loll for solid wastes and lbs/1000 gallons for liquid wastes. "I'" indicates that in element is present in a 'Mace"
K
POtassinlll
qu'MINIV (< 0.005 lb Permcasurc(l unit).
K„O
Potash
willlill the first mollill alter Ivasle application, 50-75% of the nutrient (111(1I11111Cs listed Will become available for Ille (Top. 'I'licrefore, plan to apply
Li
Lilllllllll
wasles lical' Ille Ii111C that planlS will. IVILllre I1L111'IC1115. T11C relllailling 11111den(s gradually become available over ll1C nut Ilirce nlolllhs.
Nlg
;Magnesitllll
.NL1117Cnts not available for the first clop al'C nlille'aliZCd to available forills over (i111e, usllallvVeais. Significant (plalllilies of Illllricills call accili11lllale
Mn
J(o
Manganese
;1(U11'I)(Il'nlllll'icill
in soils dial do not leach readily with heals rainfall. II' Ivasle is rolitineh- applied, take soil samples ell /east once every Iwo weals to illoiliiol. rltlt
N
Nitrogen
accumulation. Some cropping systems and metal levels Inav nccessfMIC annual sampling.
Na
Sodium
ALE; and CCE% are reported for wastes Ihat may have neutralizing wattle. ALE indicates the amount of the Ivasle product required to equ<d 1 Ion of
`III
Anrmorliunl nitrogen
good glialityagricultural lime (CC M=90). If \%'lisle 111tttcrials have significantneutralizingvapid, apply ahem 0111y al rates necessitr,to optimize PI
Ni
NI('k('I
For flexibility, the information slice( provides two choices for appli(allon method. Predictions of available nutrients are based on (he type of waste
NO,
Nitrate nitrogen
and IhC method ol'application. ll you decide to cliallgc [lie application ll1CIllod after (fie analysis is complete, conlacl your local regional agl'ollonlisl
1)
Phosphorus
or the ;Agronomic Division al [phone] fora revised reconiniend`tlion.
I).,0 5
Phos )hate
Ph
l.radl
(2) <u;ultides of, okra' elenienls Iluu are potenlially harmful—Na, Ni, Cd, Pb, Al, tie, and Li—indicalc Ilse likelihood of toxic buildup in Ilse soil. Like
fill
1leastw of acidify or alkalinil%-
nulricnls, Ihey are reported in Ibs/Ion for solid Ivas(cs and Ibs/I000 gallons for ligtlid wastes.
S
Sulfur
(3) Solllclillles (he reco111111Clldaholls section illcllldeS agrollonlic ('(1mlilcllls.'I'hcse provide general ilil ri-nalion oil IhC \vasle product and ales -I file Inset'
Se
Selonilllll
\%'hell llcavv niclals of (pier elclllellls are high eloligll to lyarlallt special precautions whell applying (he %VastC. For diaglloslic samples, sile-sPcHic
SS
Soluble sills
reconllllCndali011s are provided based oil information slicel Bala. 'I'hC Inore thoroughly IhC problem and its U111gLIC conditions are described oil file
r -
Trace
infornlalion slieel, Ilse more periincnl alid site specific Idle reconl[lie 11dalions will be.
Zn
Zinc
io,000 copies orti,is public document were printed at ;, cost ors204,22 or $0.02 per copy.

,NCDA Agronomic Division 4300 Reedy Creek Road Raleigh, NC 27607-6465 919733-L05>-
Grower: Styles, Ricky Copies To: County Extension Director
Rt. 3 Box 142 Old Linville 1-hvy. USDA-NRCS-McDowell
Marion, NC 28752 Trigen-Biopower
' Trigen-Biopower
a.r _....... ...� - aste nalys2sRP-hort ram attn:David DeH�trt
9140 Arrowpoint Blvd.
1/20/00 McDowell County Charlotte, NC 28273
;ani ple Info. LaboratoryResults arts per million unless otherwise noted
'ample ID: N P K Ca M 'S Jr. Mn Zrt Ctt B MO
iCD011rC Total 64.0 VL 2247 17299 131576 11974 620 8450 1596 97.2 75.2 94.6
IN-N M H H H L H H M 11 11
Vaste Code: -NH4
M .lyp3 Na Ni (,d PG AI Se Li If SS ON DM36 CCC% ALB fats
)escrlptiatr: OR-N 6936 15.4 0.94 11.2 12.12 91.63 69.25 1.40
ndust.-stack Ash Urea VH M M M lbs/ton wet bast. Other Elements lbs/ton wet basis
recommendations: Nutrients Available for First Crop
pplicatiar A9clGod N P205 K20 Ca Mg S Fe Mn Zn Cu B Mo Cl 12a7 0.03 T d 0 02 Al Se Li
Broadcast 0.06 6.6 30.4 168.8 15.4 0.79 10.8 2.1 0.12 0.10 0.12 12.7 0.03 T 0.02
Soillncor 0.07 .7.5 34.2 192. 17.6 0.91 12.4 2.3 0.14 0.11 0.14
ie ,iste product has a high.neutralizing value and should only be applied at rates needed to increase soil pH to the desired range. The ALE indicates the amount of the waste required to equal the neutralizing value of
a�
ie Ion of aericultural lime.

��� PAR Laboratories, Inc.
2217 Graham Park Drive
LABORATORIES• INC. PO Box 411483
Charlotte, NC 28241-1483
Phone: [phone]; Fax: [phone]
NC Cert 020, SC Cert 099003001
REPORT OF ANALYSES
Attn: DAVID DeHART
TRIGEN-BIOPOWER, INC. PROJECT NAME: JAN 00
9140 ARROWPOINT BLVD DATE:
SUITE 370 2/4/00
CHARLOTTE, NC 28273-
MARION, NC FACITLITY (Page 1 of 2)
SAMPLE DELIVERY TO LAB
LAB No. DATE TIME SAMPLER DATE TIME MATRIX
19480 01/14/00 LINK UNK 01/14/00 1020 OT
CLIENT STATION ID: MARION, NC
WOOD ASH
LAB #:
19480
c
v •
pH VALUE
S U.
8� 4l t 5. t S
/0
CORROSIVITY
12.2
-Z
par
PAINT FILTER TEST
NON
Nc�q
REACTIVITY
NFL
e, r
IGNITABILITY
NON
Par 88.3 -t 7 2- = 8l • $
FLASH POINT
degrees F
NON`
> 200
'Z
ALUMINUM, TOTAL
mg/kg
37,049
f oA
ARSENIC, TOTAL
mg/kg
7.03
BARIUM, TOTAL
BERYLLIUM, TOTAL
mg/kg
1,466
Y
CADMIUM, TOTAL
mg/kg
mg/kg
3.53
pa` Z
CHROMIUM, TOTAL
mg kg
8.41
I„c0�
COPPER, TOTAL
mg/kg
-----
LEAD. TOTAL
n;g/kg
88.2
.3
73.8
Z �3G -f-s fit' a r
'
MANGANESE, TOTAL
mg/kg
2,436
Pam Z
MERCURY, TOTAL
mg/kg
MOLYBDENUM, TOTAL
mg/kg
< .02
16.7
NICKEL, TOTAL
SELENIUM, TOTAL
mg/kg
mg/kg
.7
38.4
t o �q 1 g 4 (e �3L _ gr ct Z7
SILICON, TOTAL
mg/kg -
103
2
SILVER, TOTAL
mg/kg
104
104
SODIUM, TOTAL
mg/kg
4.87
10,918
TITANIUM, TOTAL
ZINC, TOTAL
mg/kg
2,234
Z ; "�'
ARSENIC
mg/kg
137
,1 L
t 3 7 -+ q � • _ 7
BARIUM
mg/L
<,50
Z
BENZENE
mg/L
< 10
Par
CADMIUM
mg/L
< .05
mg/L
< .10

PAR Laboratories, Inc-
2217 Graham Park Drive
ATORI
L—i
PO Box 411483
Charlotte, NC 28241-1483
Phone: [phone]; Fax: [phone]
NC Cert 020. SC Cert # 99003001
MARION, NC FACITLITY (Page 2 of 2)
SAMPLE DELIVERY TO LAB
LAB No. DATE TIME SAMPLER DATE TIME
19480 01/14/00 UNK UNK 01/14/00 1020
CLIENT STATION ID: MARION, NC
WOOD ASH
LAB #:
19480
CARBON TETRACHLORIDE
mg/L
< 05
CHLORDANE
mg/L
<
CHLOROBENZENE
mg/L
.003
< 10
CHLOROFORM
mg/L
< 6
CHROMIUM
mg/L
<
m-CRESOL
mg/L
.50
< 20
o-CRESOL
mg/L
< 20
p-CRESOL
mg/L
< 20
2,4-D
mg/L
< 1
1,4-DICHLOROBENZENE
mg/L
< 75
1,2-DICHLOROETHANE
mg/L
<
1,1-DICHLOROETHYLENE
mg/L
.05
< 07
2,4-DINITROTLUENE
mg/L
<
ENDRIN
mg/L
.013
<
HEPTACHLOR (AND ITS HYDROXIDE)
mg/L
.002
<
HEXACHLOROBENZENE
mg/L
.0008
HEXACHLOROBUTDIENE
mg/L
< .013
HEXACHLOROETHANE
mg/L
< .05
LEAD
mg/L
< 3
<
LINDANE
mg/L
.50
<
MERCURY
mg/L
.04
<
METHOXYCHLOR
mg/L
.02
< 1
METHYL ETHYL KETONE
mg/L
< 20
NITROBENZENE
mg/L
< 2
PENTACHLOROPHEN'OL
;r,g/L
< 10
PYRIDINE
mg/L
< 5
SELENIUM
mg/L
< 10
SILVER
mg/L
<
TETRACHLORETHYLENE
mg/L
.50
< 07
TOXAPHENE
mg/L
<
TRICHLOROETHYLENE
mg/L
.05
<
2,4,5-TRICHLOROPHENOL
mg/L
.05
2,4,6-TRICHLORPHENOL
mg/L
< 40
2,4,5-TP(SILVEX)
mg/L
< 2
VINYL CHLORIDE
mg/L
< .1
< 02
LABORATORY DIRECTOR ��
MATRIX
OT

TRIGEN-8I0POWER, INC.
TRIGEN
Marion, North Carolina
2000 Ash Reuse Program
Information Sheet
Trigen-BioPower, Inc. (Trigen), Route #3, Box 142, Old Linville Highway, Marion, NC 28752 is
the generator of the ash provided to (Recipient).
Application of the aforementioned ash is prohibited except in accordance with the instructions on
this sheet.
The ash will not be applied to any applicable buffer, including a 100 foot buffer between an
application site and any public or private water supply source (including wells) and any stream,
lake, or river. The ash shall not be applied to any site that is flooded, frozen, or snow-covered.
No ash is to be applied in inclement weather or until 24 hours following a precipitation event
equal to a rainfall event of 1/2-inch or greater in 24 hours. Land areas, which exhibit a seasonal
high water table within 3 feet of the surface, shall not be utilized for application of ash.
Adequate procedures shall be provided to prevent surface runoff from carrying any disposal or
stored ash into any surface waters.
The volume of ash application shall be limited to 4 tons/acre/year, unless a demonstration is
made which indicates that a higher application of this material will not exceed the liming
requirements of the crops being grown on the application site, if applicable to crops. A chemical
analysis of the ash is located on page 2 of the information sheet. The most recent analysis
performed by. the North Carolina Department of Agriculture is also attached.
No ash shall be used as pipe bedding for sewer or potable water lines.
Signed (Ash Recipient):
Ash Recipient's Address:
Intended Use of Ash:
Expected Qty/Yr:
Date:
Acres of Land:
Page 1 of 2
Updated: 02/21/00

Marion, North Carolina
2000 Ash Reuse Program
Historical Analysis Average
Soil Amendment Properties
Parameter
Calcium Carbonate Equivalent
Potash (KZO)
20-Mesh %
100-Mesh %
Metals (Total Concentration)
Concentration
47.0%
2.45%
67.2%
42.8%
Parameter
Concentration (mg&g)
Arsenic
3.79
Barium
1,630
Cadmium
1.41
Calcium
130,000
Chromium
64.5
Copper
65
Lead
31.0
Magnesium
12,000
Manganese
2,230
Mercury
0.0133
Nickel
11.1
Phosphorus
2,150
Potassium
15,700
Selenium
0.401
Silver
0.900
Sodium
5,930
Zinc
119
TCLP RCRA Toxicity Metals (Lecahable Concentrations)
Parameter
Concentration (mgU
Arsenic
Less than 0.05
Barium
2.59
Cadmium
Less than 0.01
Chromium
Less than 0.05
Lead
Less than 0.05
Mercury
Less than 0.002
Selenium
Less than 0.01
Silver
Less than 0.05
Page 2 of 2
Updated: 02/21/00

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
RALPH SMITH
TRIGEN-BIOPOWER, INC.N COVER
9140 ARROW POINT BLVD STE 370
CHARLOTTE, NC 28273
Dear Permittee:
,&4
r
D E N R
February 28, 2000
Subject: PERMIT NO. WQ0010689
TRIGEN-BIOPOWER, INC.N COVER
MCDOWELL COUNTY
Our files indicate that the subject permit issued on 6/24/98 expires on 9/30/00. We have not received a
request for renewal from you as of this date.
A renewal request shall consist of a letter asking for permit renewal and four (4) copies of a completed
application. For permitted facilities with treatment works, a narrative description of the residuals management
plan, which is in effect at the permitted facility, must also be submitted with the renewal application.
Applications may be returned to the applicant if incomplete.
The General Assembly passed legislation incorporating renewal fees into the annual fee.
Please be advised that this permit must not be allowed to expire. You must submit the renewal request at
least 180 days prior to the permit's expiration date, as required by the 15 NCAC 2H .0211. Failure to request a
renewal at least 180 days prior to the permit expiration date and/or operation of a facility without a valid permit
may result in the assessment of civil penalties. NCGS 143-215.6A allows for the assessment of Civil penalties
up to $10,000 per violation per day.
to:
The letter requesting renewal, along with the completed Non -Discharge Permit Application must be sent
N.C. DIVISION OF WATER QUALITY
NON DISCHARGE BRANCH
1.617 MAIL SERVICE CENTER
RALEIGH, NC 27699-16-17
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

If you have any questions concerning this matter, please contact Ms. Kimberly Young at
919 733-5083 extension 574.
Sincerelv,
Kim H. Colson, P.E., Supervisor
Non -Discharge Permitting Unit
cc: Asheville Regional Office
Central Files

FILE$
/ SOC PRIORITY PROJECT,: YES NO X
/ IF YES, SOC NUMBER
TO : � PERMITS AND ENGINEERING UNIT
VV
WATER QUALITY SECTION
ATTENTION: Susan Cauley
DATE: June 8,•2000
NON -DISCHARGE STAFF REPORT AND RECOMMENDATION
McDowell County
PERMIT.NUMBER WQ0010689
PART I - GENERAL INFORMATION
1. Facility and Address: Trigen-Biopower
9140 Arrowpoint Blvd., Suite 370
Charlotte, NC 2-8273
2. Date of Investigation: June 7, 2000
3.. Report Prepared By: D.'Keith Haynes
4. Persons Contacted and TelephoneaNumber: Ricky Stiles
828-756-4946
5. Directions to Site: `The site is located 0.25 mile north of the
intersection of,NCSR 1560 and 1573, north Marion off of US Hwy 221
6. Size (land available for expansion and upgrading)`: NA
7. Topography (-relationship to 100 year -flood plain included): Some of
the fields would be subject to flooding during a 100 yr flood.
Attach a U.S.G.S. map extract and indicate facility site.
U.S.G.S. Quad No. D11SW U.S.G.S. Quad Name Ashford, NC
° °
Latitude: 3549' 55 Longitude: 8159' 5511
-1-

8. Any buffer conflicts with location of nearest dwelling and water
supply well? Yes No X If Yes, explain:
9. Watershed Stream Basin Information:.
a. Watershed Classification:."B" Trout
b. River'Basin and Subbasin No.: CTB30
C. Distance to surface water from disposal system: NA
PART II - DESCRIPTION OF WASTES AND TREATMENT WORKS
1. a. volume: MGD (Design Capacity)
Residuals: 2500 tons per year
b. Types and quantities of industrial wastewater:
C. Pretreatment Program (POTWs only): NA
in development approved
should be required not needed
2. Treatment Facilities:
a. What is the current permitted capacity of the facility?
b. What is the actual treatment capacity of the current facili
(design volume)?
C. Please provide a description of existing or substantially„
constructed wastewater treatment facilities:
d. Please provide a description of proposed wastewater treatu
facilities:
3. Residuals handling and utilization/disposal scheme:
t
-2-

a. If Residuals are being land applied, please specify DWQ Permit
Number
Residual Contractor
Telephone Number
b. Residuals stabilization: PSRP. PFRP OTHER -X
c. Landfill:
r
d. Other disposal/utilization scheme (Specify): Land Application
4. Treatment plant classification (attach completed rating sheet): NA
5. SIC Code(s): 4911
Wastewater Code(s) of'actual wastewater., not particular facilities
i.e., non -contact cooling water discharge from a metal plating
company would be 14, not 56.
Primary: Secondary:
Main Treatment Unit Code: 50003
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant funds
(municipals only)? NA
2. Special monitoring requests: NA,
3. Important SOC, JOC or Compliance Schedule dates: (Please indicate)
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
4. Other Special Items:
-3-

PART IV - EVALUATION AND RECOMMENDATIONS
The facility is requesting an increase from 900 Dry Tons/Yr to 2500 Dry
Tons/Yr. It is recommended that the Permit be reeissuedn nas requested.
Si ture of R or Pep r
t
wa/
ter Qu�yLlity,Regional Supervisor
Date
-4-

February 25, 1999
TRIGEI BIOPOWER, INC.
9140 AR OWPOINT BLVD., SUITE 370, CHARLOTTE, NC 28273
(704) 52 -a81 FAX: [phone]
�I
' MAR 4 1999
CERTIFIED MAIL #, P 053 513 977
RETURN RECEIPT REQUESTED
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance Unit
PO Box 29535
Raleigh, NC 27626-0535
514 V ogles ir'a"U _ ail
1
AUGIN
!�, ASHE"V rfORl
RE: Permit No. WQ0010689, Trigen-BioPower, Inc. (TBP), North Cove Steam Generation Plant, Ash
Reuse Program Report, Permit Condition III 5�+�,,���
Per permit condition III 5, please find enclosed the information specified in permit conditions III 2, III
3, and III 4.
Permit Condition I Comment
III 2a The source of the ash is a wood -fired boiler located at TBP's North Cove, NC
facility. The quantity of ash produced was approximately the amount outlined
in the hermit (1.000 dry tons).
III 2b Name of recipient: L.J. Wiseman, P.O. Box 302, Marion, NC 28752
Quantity received: 1,041 dry tons (42 % moisture).
Intended use: The wood ash was land applied.
Name of recipient: Jeffery J. Banks, Route 3, Route 199, Marion, NC 28752
Quantity received: 76 dry tons (42 % moisture).
Intended use: The wood ash was land applied.
Name of recipient: Donald Wilson, Route 3, Box 177, Marion, NC 28752
Quantity received: 28 dry tons (42 % moisture).
Intended use: The wood ash was land applied.
Name of recipient: Marilyn Evans, P.O. Box 2331, Marion, NC 28752
Quantity received: 7 dry tons (42 % moisture).
Intended use: The wood ash was land applied.
Name of recipient: Ricky Styles, Route 3, Box 233, Nebo, NC 28761
Quantity received: 7 dry tons (42 % moisture).
Intended use: The wood ash was land applied.

NC Division of Water Quality
February 25, 1999
Page 2 of 2
Permit Condition
Comment
III 3
See attached report from Prism Laboratories, Inc.
III 4
See attached report from Prism Laboratories, Inc.
Please contact me if you have questions or require additional information.
Sincerely,
David,DeHart, P.E.
Staff Engineer
Enclosure (1 copy of February 12, 1999 Prism Laboratories, Inc. ash report for the North Cove facility)
Jerry Caughman - TBP (w/o enclosure
Ralph Smith - TBP (w/o enclosure)
Ricky Styles - TBP (w/o enclosure)
Jim Qin — TWP (w/o enclosure)

:ab Report
�_ x
�
ISM-
r
-PER ..
From: NC Certification No.
402
ti�
LASORa70RIESINC,
SC Certification
No. 99012
utions
Full Service Analytical8 Environmental Solutions
NC Drinking . Water
Cert. No. 37735
FL Certification
No., E87519
February 12, 1999
To: Trigen'- Bio Power
Attn: David Dehart
9140 Arrowpoint Blvd. Ste 370
Charlotte, NC 28273
Project: Marion Ash
a
The following'analytical,results have been obtained for the
indicated sample which was submitted.to this laboratory:
Sample I.D. AB17553 Customer Code: POWER
Login Group #: 3213E1 Customer Reference: TRIGEN
Phone Number: [phone]/fax[phone],
Customer Sample I.D#: WOOD ASH Sample collection date: 01/22/99
Lab submittal date: 01/25/99 Time 15:30
Received by: KJE Validated by: ADO
Parameter: CORROSIVITY AS PH
Method reference: 9040/9045
Result: 13 UNITS
Date started: 02/01/99
Time started: 14:27
Parameter: PAINT FILTER TEST
Method reference:
Result: Passed
Date started: 02/01/99
.Time started: 14:32
Parameter: IGNITIBILTY
MDL. or sensitivity, :. '
Date finished: 02/01/99
Analyst: TAR
Unit: P/F
MDL or sensitivity:
Date finished: 02/01/99
Analyst: TAR
Method reference: SW-846 #1020 Unit:
Result: Passed MDL-or sensitivity:
Date started: 02/02/99` Date finished: 02/02/99
Time started: 22:00, Analyst: LNH
Parameter: REACTIVITY
Method reference: SW-846 7.3 Unit:
Result -.'Negative MDL o.r sensitivity:
Date started: 02/04/99 Date finished: 02/04/99
Time started: 14:27 Analyst: CEM
Parameter: CY.ANIDE,,REACTIVITY
Method reference: SW-846 9010 Unit: ppm
Result: -Less than MDL or sensitivity: 0.10
Date started: 02/03/99 Date finished: 02/03/99
Time started: 18:.15 - Analyst': CEM
449 Springbrook Road � P.O. Box 240543 &, Charlotte, NC 28224-OS43
Phnnr• 7n4/S7q-4;gF4 — Tnll Free Nnmhnr: 1 •R(ltl/57.9-63F4 ., Fax: [phone]

Trigen -
Page: 2
February
Bio Power
12, 1999
Sample I. D. AB17553 (continued)
Parameter: SULFIDE, REACTIVITY
Method reference: SW-846 9030
Result: Less than
Date started: 02/03/99
Time started: 19:04
,
Full Service Analytical & Environmental Solutions
Unit: ppm
MDL or sensitivity: 2.00
Date finished: 02/03/99
Analyst: CEM
Parameter: METALS DIGESTION METHOD 3050
Method reference: 3050 Unit:
Result: Completed MDL or sensitivity:
Date started: 02/03/99 Date finished: 02/03/99
Time started: 12:45 Analyst: MSP
Parameter: ARSENIC, TOTAL
Method reference: G010
Result: 1.7 mg/kg
Date started: 02/05/99
Time started: 14:00
Parameter: BARIUM, TOTAL
Method reference: 6010
Result: 690 mg/kg
Date started: 02/09/99
Time started: 14:00
Parameter: CADMIUM, TOTAL
Method reference: 6010
Result: Less than
Date started: 02/05/99
Time started: 14:00
Parameter: CHROMIUM, TOTAL
Method reference: 6010
Result: 8.9 mg/kg
Date started: 02/05/99
Time started: 14:00
Parameter: COPPER, TOTAL
Method reference: 6010
Result: 42 mg/kg
Date started: 02/05/99
Time started: 14:00
Parameter: LEAD, TOTAL
Method reference: 6010
Result: 12 mg/kg
Date started: 02/05/99
Time started: 14:00
MDL or sensitivity: 1.0
Date finished: 02/05/99.
Analyst: DR2
MDL .or sensitivity: 2.5
Date finished: 02/09/99
Analyst: DR2
Unit: mg/kg
MDL or sensitivity: .1.0
Date finished: 02/05/99
Analyst: DR2
MDL or sensitivity: 1.0
Date finished: 02/05/99
Analyst: DR2
MDL or sensitivity: 2.0
Date finished: 02/05/99
Analyst: DR2
MDL or sensitivity: 1.0
Date finished: 02/05/99
Analyst: DR2
Parameter: MANGANESE, TOTAL
Method reference: 6010
Result: 1300 mg/kg MDL or sensitivity: 2.5
Date started: 02/09/99 Date finished: 02/09/99
Time started: 14:00 Analyst: DR2
449 Springbrook Road A. P.O. Box 240543 � Charlotte, NC 28224-05443

_--ab Report
Trigen - Bio Power Sample I.D. AB17553 (continued)
Page: 3
February 12, 1999
Parameter: MERCURY, TOTAL
Method reference: 7471
Result: 0.08 mg/kg
Date started: 02/03/99
Time started: 09i45
Parameter: MERCURY DIGESTION
Method reference: 7471
Result: Completed
Date started: 02/02/99
Time started: 13:00
Parameter: MOLYBDENUM, TOTAL
Method reference:
Result: Less than
Date started: 02/05/99
Time started: 14:00
Parameter: NICKEL, TOTAL
Method reference: 6010
Result: 7.4 mg/kg
Date started: 02/05/99
Time started: 14:00
Parameter: SELENIUM, TOTAL
Method reference: 6010
Result: 0.52 mg/kg
Date started: 02/05/99
Time started: 14:00
Parameter: SILVER, TOTAL
Method reference: 6010
Result: Less than
Date started: 02/05/99
Time started: 14:00
Parameter: SODIUM, TOTAL
Method reference: 6010
Result: 4400 mg/kg
Date started: 02/09/99
Time started: 14:00
Parameter: ZINC, TOTAL
Method reference: 6010
Result: 49 mg/kg
Date started: 02/05/99
Time started: 14:00
tr
RISM:.
"
LABORATORIES INC..
Full Service
Analytical & Environmental Solutions
MDL or sensitivity: 0.02
Date finished: 02/03/99
Analyst: MSP
Unit:
MDL or sensitivity:
Date finished: 02/02/99
Analyst: MSP
Unit: mg/kg
MDL or sensitivity: 1.0
Date finished: 02/05/99
Analyst: DR2
MDL or sensitivity: 1.0
Date finished: 02/05/99
Analyst: DR2
MDL or sensitivity: 0.20
Date finished: 02/05/99
Analyst: DR2
Unit: mg/kg
MDL or sensitivity: 2.0
Date finished: 02/05/99
Analyst: DR2
MDL or sensitivity: 1250
Date finished: 02/09/99
Analyst: DR2
MDL or sensitivity: 1.0
Date finished: 02/05/99
Analyst: DR2
Parameter: TCLP EXTRACTION (VOLATILES ONLY)
Method reference: 1311 Unit:
Result: Completed MDL or sensitivity:
Date started: 02/01/99 Date finished: 02/02/99
Time started: 16:00 Analyst: LAC
449 Springbrook Road &� P.O. Box 240543 � Charlotte, NC 28224-0543
Phone: 704/S79-6164 , Tnll Freo Nnmhrr: 1-Ron/579-6'AF4 ,. FaY- 704/e7s-n4no

Trigen - Bio Power Sample I.D. AB17553 (continued)
Page: 4
February 12, 1999
Parameter: METALS DIGESTION
Method reference: EPA 3010
Result: Completed
Date started: 02/02/99
Time started: 11:20
Parameter: PREP. METHOD 3510
Method reference: 3510
Result: Completed
Date started: 02/02/99
Time started: 11:30
4 rS�'t r r
ust�=ORATORIE$,1NC
Full Service Analytical & Environmental Solutions
Unit:
MDL or sensitivity:
Date finished: 02/02/99
Analyst: MSP
Unit.
MDL or sensitivity:
Date finished: 02/02/99
Analyst: LAC
Parameter: PREP. METHOD 3510 WITH EXCHANGE
Method reference: 3510 Unit:
Result: Completed MDL or sensitivity:
Date started: 02/02/99 Date finished: 02/02/99
Time started: I Analyst: SA
Parameter: PREP. METHOD 3510 WITH EXCHANGE
Method reference: 3510 Unit:
Result: Completed MDL or sensitivity:
Date started: 02/02/99 Date finished: 02/02/99
Time started: Analyst: SA
Parameter: SELENIUM, LEACHABLE
Method reference: 6010
Result: Less than
Date started: 02/03/99
Time started: 11:00
Parameter: ARSENIC, LEACHABLE
Method reference: 6010
Result: Less than
Date started: 02/03/99
Time started: 11:00
Parameter: CADMIUM, LEACHABLE
Method reference: 6010
Result: Less than
Date started: 02/03/99
Time started: 11:00
Parameter: CHROMIUM, LEACHABLE
Method reference: 6010
Result: Less than
Date started: 02/03/99
Time started: 11:00
Parameter: LEAD, LEACHABLE
Method reference: 6010
Result: 0.063 mg/L
Date started: 02/03/99
Time started: 11:00
Unit: mg/L
MDL or sensitivity.: 0.010
Date finished: 02/03/99
Analyst: DHJ
Unit: mg/L
MDL or sensitivity: 0.010
Date finished: 02/03/99
Analyst: DHJ
Unit: mg/L
MDL or sensitivity: 0.005
Date finished: 02/03/99
Analyst: DHJ
Unit: mg/L
MDL or sensitivity: 0.005
Date finished: 02/03/99
Analyst: DHJ
MDL or sensitivity: 0.005
Date finished: 02/03/99
Analyst: DHJ
449 Springbrook Road &, P.O. Box 240543 -A, Charlotte, NC 28224-0543
T)l , , inn iQoo,Z1rn . m.,n r._,, , rare I__.. 11.. .- ----

-Adl. • • 22
Trigen - Bio Power
Page: 5
February 12, 1.999
`4 � t
��i�
i't'Y'
.'.�• i
tLABO�ORIESj
�aF
Sample I. D. AB17553 (continued)`.
%%+
Parameter: SILVER, LEACHABLE
Method reference: 6010
Result: Less than
Date started: 02/03/99
Time started: 11:00
Parameter: MERCURY, LEACHABLE
Method reference: 7471
Result: 0.0014 mg/L
Date started: 02/03/99
Time started: 09:45
Parameter: BARIUM, LEACHABLE
Method reference: 6010
Result: 8.1 mg/L
Date started: 02/03/99
Time started: 11:00
Full Service Analytical & Environmental Solutions
Unit: mg/L
MDL or sensitivity: 0.005
Date finished: 02/03/99
Analyst:.DHJ
MDL or sensitivity: 0.0002
Date finished: 02/03/99
Analyst: MSP
MDL or sensitivity: 0.010
Date finished: 02/03/99
Analyst: DHJ
Parameter: TCLP VOLATILES BY 8260
Method reference: SW846-8260 Unit: mg/L
Result: see below
Date started: 02/09/99 Date finished: 02/09/99
Time started: 11:52 Analyst: MP
Parameter: TCLP SEMI-VOLATILES BY 8270
Method reference: SW846-8270 Unit: mg/L
Result: see below
Date started: 02/08/99 Date finished: 02/09/99
Time started: 22:58 Analyst: HWC
Parameter: TCLP PESTICIDES
Method reference: SW-84G 8081
Result: see below
Date started: 02/07/99
Time started: 16:39
Parameter: TCLP HERBICIDES
Method reference: SW-846 8150
Result: see below
Date started: 02/08/99
Time started: 09:47
Parameter: MERCURY DIGESTION
Method reference: 7471
Result: Completed
Date started: 02/02/99
Time started: 13:30
Parameter: TCLP EXTRACTION.
Method reference: 1311
Result: Completed
Date started: 02/01/99
Time started: 16:00
Unit: mg/L
Date finished: 02/07/99
Analyst: SA
Unit: mg/L
Date finished: 02/08/99
Analyst: SA .
Unit:
MDL or sensitivity:
Date finished: 02/02/99
Analyst: MSP
Unit:
MDL or sensitivity:
Date finished: 02/02/99
Analyst: MSP
449 Springbrook Road.,*, P.O. Box 240543 Charlotte, NC 28224-0543
Phone: 704/.S29-6364 a Tnll Frrr Nnmhr•r- Fes..- Inn is,)c.nnnn

PPE�b Report
Trigen
Page: 6
February
Bio Power
12, 1999
Sample 'I. D. AB17553
Parameter: CALCULATIONS BASED ON
Method reference: SM 2540 G
Result: 100 %.DRY WT.
Date started: 02/01/99-
Time started: 15:00
Parameter: ASH ANALYSIS
Method reference:
Result: see below
Date started: 02/12/99
Time started: 09:34
(continued)
Full Service Analytical & Environmental Solutions
DRY WEIGHT
Data for TCLP VOLATILES BY 8260 mg/L:
Component Name
BENZENE
CARBON TETRACHLORIDE
CHLOROBENZENE
CHLOROFORM -
1,4-DICHLOROBENZENE
1,2-DICHLOROETHANE .
1,1-DICHLOROETHENE
METHYL ETHYL KETONE
TETRACHLOROETHENE
TRICHLOROETHENE
VINYL CHLORIDE
MDL or sensitivity: 0.01
Date finished: 02/02/99
Analyst: BNC
Unit:
Date finished: 02/12/99
Analyst: ADO
Result
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
Hot detected
Not detected
Not detected
Not detected
Data for TCLP SEMI-VOLATILES BY 8270 mg/L:
Component Name
CRESOLS
1,4-DICHLOROBENZENE
2,4-DINITROTOLUENE
HEXACHLOROBENZENE
HEXACHLOROBUTADIENE
HEXACHLOROETHANE
NITROBENZENE
PENTACHLOROPHENOL
PYRIDINE
2,4,5-TRICHLOROPHENOL
2, 4, 6-TRICHLOROPHENOL
'Data for TCLP PESTICIDES mg/L:
Result
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
Component Name
Result
CHLORDANE
Not
detected"
ENDRIN
Not
detected
HEPTACHLOR
Not
detected
LINDANE
Not
detected
METHOXYCHLOR
Not
detected
TOXAPHENE
Not
detected
449 Springbrook Road � P.O. Box 240S43 ,'Charlotte, NC 28224-0543
Phone: 704/S29-6364 ^� Toll FreeNtimbor• 1-R(lrtGn
Component_ NDL
0. 01
0.01
0.01
0.01
0.014
0.01
0.01
0.04
0.012
0.01
0.02
Component MDL
0.050
0.050
0.012,
0.010
0.050
0.050
0.050
0.25
0.25
0.25
0.10

�-"b Report
Trigen - Bio Power
Page: 7
February 12, 1999
QORA;ORiES`��
Sample I. D. AB17553 (continued)
Full Service Analytical & Environmental Solutions
Data for TCLP HERBICIDES mg/L:
Component Name
2, 4-D
SiLVEX
Data for ASH.ANALYSIS:
Units Parameter
Result
Not detected
Not detected
Result
Component NDL
0.5
0.05
Detecton_Limit
ph (Corrosivity)
13
Paint Filter Test
Pass
,Reactivity
Negative
Ignitibility
Pass
mg/kg
Arsenic
1.7
1.0
mg/kg
Barium
690
1.0-
mg/kg
Cadmium
ND
1.0
mg/kg.
" Chromium
8.9
1.0
mg/kg
Copper
42
2.0
mg/kg
Lead
mg/kg
Manganese
1300
1.0
mg/kg
Mercury
0.08
mg/kg
Molybdenum
ND
1.0
mg/kg
Nickel
7..4
1.0
mg/kg
Selenium
0.52
0.20
mg/kg
,Silver
ND
2.0
mg/kg
Sodium
4400
1.0
mg/kg
Zinc
49
1.0
TCLP
mg/L
'Arsenic
ND
0.05
mg/L
Barium
8.1
1
mg/L
Benzene
ND
0.010
mg/L
Cadmium
ND
0.01
mg/L
Carbon tetrachloride
ND
0.010
mg/L
Chlordane
ND
0.001
mg/L
Chlorobenzene
ND
1-
mg/L
Chloroform-
ND
0.'06
mg/L
Chromium
ND
' 0.05
mg/L
o-Cresol
ND
2
mg/L
m-Cresol
ND
2
mg/L
gip -Cresol
ND
2
mg/L
Cresol (total)
ND
2
mg/L
.2, 4-D
ND
0.,5
mg/L
1, 4-Dichlor.obenzene
ND
0.075
mg/L
1,2-Dichloroethane
ND
0.010
. mg/L
1, 1-Dichloroethylene
ND
0.010
mg/L
2,4-Dinitrotoluene
ND
0.012
mg/L
Endrin
ND
0.0005
mg/L
Heptachlor (and 'its hydroxide)ND '
0.0003
mg/L
Hexachlorobenzene
ND
0.010
mg/L
Hexachloro-1,3-butadiene,
ND
0.050
mg/L
•Hexachloroethane
ND
0.050
449 Springbrook Road ,� P.O. Box 240543 � Charlotte, NC 28224-0543
Phony: 7t14/57.9-fi3f4 .. Toll FYrrNnmher- l.Ann/S79-6RF4
,. Fav 7n4ie9r-n4no

Lab Report
Trigen - Bio Power Sample I.D. AB17553 (continued) a
Page: 8 Full Service Analytical & Environmental Solutions
February 12, 1999
Data for ASH ANALYSIS (continued):
mg/L
Lead
0.063
0.05
mg/L
Lindane
HD
0.010
mg/L
Mercury
ND
0.002
mg/L
Methoxychlor
ND
0.1
mg/L
Methyl ethyl ketone
ND
2
mg/L
Nitrobenzene
ND
0.050
mg/L
Pentachlorophenol
ND
1
mg/L
Pyradine
ND
0.25
mg/L
Selenium
ND
0.01
mg/L
Silver
ND
0.05
mg/L
Tetrachloroethylene
ND
0.012
mg/L
Toxaphene
ND
0.013
mg/L
Trichloroethylene
ND
0.010
mg/L
2, 4, 5-Trichlorophenol
ND
4
mg/L
2, 4, 6-Trichlorophenol
ND
0.10
mg/L
2, 4, 5-TP ( Silvex )
ND
0.05
mg/L
Vinyl Chloride
ND
0.020
Sample comments:
PO#: 990125MarionDeHartB
Project name: Marion Ash
If there are any questions regarding this data, please call.
Angela D. Overcash
Laboratory Director
449 Springbrook Road &, P.O. Box 240S43 A, Charlotte, NC 28224-OS43
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