WQ0010689_Application_20000427

DIVISION OF. WATER QUALITY
GROUNDWATER SECTION
Croundwate7 Section
Asheville Regional Office J
MEMORANDUM f�
TO: L ILd2i 'h {'�" a-Lfd Ci1'1
j &vi GI € Regional Office
FROM: K id l .0"A4l e-c Y
SUBJECT: Application for Permit Renewal, K Permit Amendment
New Permit Repair/Alteration of Exist Disposal System [DEHJ
COMMENTS:
Facility Name: T rl GJ •ev! Q(sD no re, ee
County: `i G 47 w ell
Type of Project: 45 Y! ) /r7 tr( bL 7 el
APPLICABLE PERMIT NO.s: WQ 0 D 1 D c-9P GW 000 $ 7
DEH AtoC
EPA (CONST. GRANTS) UIC
The Groundwater Section has received ONLY ONE (ll copy of the referenced permit application. A copy of the
application should have been sent to your 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 has received ONLY ONE (11 copy of the referenced permit application. A copy of the
application should have been sent to , DEH's Regional Soil Specialist, 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 tILy / I) 2O& A copy of any formal request for additional information will be
forwarded to you.
If you do notpneed any additional information to complete your review, please provide your final comments by
1=`1 it,1®p l OO . If you request and/or receive additional information, your final comments are due no
y
later than 14 days after you receive the additional information.
\6-98TRAN.SHL (rev. 6/22/98)

44
TRIGEN-36OPOWER, INC.
9140 ARROWPOINT BLVD., SUITE 370, CHARLOTTE, NC 28273
[phone] FAX: [phone]
TRIGEN
March 30, 2000
CERTIFIED MAIL # Z 276 290 028
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
RECE�t'JESED
\�
t' AcE1=.l'JY—.,
IION
aR 0 6, 2G0
Non -Discharge Permitting
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,
/9a,„d A2/„.
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
PAY
Three
TO
THE
ORDER.
OF
TRIGEN-BIOPOWER, INC.
9140 ARROWPOINT BLVD., SUITE 370
CHARLOTTE, NC 28273
Hundred Twenty -Five Dollars
BANK OF AMERICA
WICHITA FALLS, TEXAS
88-130/1119
049236
-vaa:O[:wmcla ecnt wn...434l.eralea+w c sxRcut c.w:un:t>wa�ewa+cr,+at.a,F47+% .xemr ws w.:m•.
DATE CHECK NO. CHECK AMOUNT
03/28/00 49236 $325.00
and 00/100**************************************************
NCDENR Division of Water Quality
Non -Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
TRIGEN-BIOPOWER, INC.
VENDOR NO.
NORT08
VOID AFTER 90 DAYS
TWO SIGNATURES REQUIRED FOR AMOUNTS OVER 55000.00
. TRANSACTION DATE REFERENCE GROSS AMOUNT • DEDUCTION
03/28/00 6890800A $325.00
CHECK DATE CHECK NO.
03/28/00 49236
VENDOR NAME 049236
NET AMOUNT
$325.00
TOTAL GROSS
TOTAL DEDUCTION CHECK AMOUNT
$325.00 $325.00
•

•
,,tate of North Carolina
Department of Environment, Health. and Natural Resources
Division of Environmental Management
Non -Discharge Permit Application Forrn
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
DISTRIBUTION OF OTHER RESIDUAL SOLIDS
Tnis application is intended for facilities which are EXEMPT from 40 CFR Part 503
I. GENERAL INFORMATION:
1. Applicant's name (please specify the name of the municipality, corporation, individual, etc.):
Trigen—BioPowe r, Inc.
2. Print owners or signing official's name and title (the person who is legally responsible for the facility and its compliance):
Ralph D. Smith, Vice President - Operations
3. Mailing address: 9140 ArrowPoint B1vr1 . Siii to 170
Cirv: Charlotte State: NC Zip: 28273
Telephone Number: ( 704 ) 525-5819
4. Application Date: March 30, 2000
5. Fee Submitted: S 325.00
[The permit processing fee should be as specified in 15A NCAC 2H .02205(c)(5).]
6. Specify how these residuals will be distributed: sold or given away in bass or other cptltainers; lawn (bulk);
home garden (bulk): X other. bulk or other form for land application
7. if the alter native for residual disposal consists of "surface disposal" as defined under 40 CFR Part 503, please complete the
application titled "SURFACE DISPOSAL OF RESIDUAL SOLIDS. Please identify if there is any storage of residuals in
a surface impoundment or disposal thin landfilling. Explain:
N/A
8. Is the residual prbcess facility also the generator? X Yes; No
9 Latitude: 35 50 10" Longitude: 81° 59' 40" of residual process facility
X
10. Specify whether the process facility is owned by: federal; Private; state; . local government;
11. County where facility is located:
II. PERMIT INFORMATION:
1. Application No. (will be completed by DEM):
2. Specify whether project is: new; g renewal"; x modification •
For renewals, complete all sections included in the. application. Engineering Signature and Seal not required for
renewals or if there is not any construction involved with the subject project
3. If this application is being submitted as a result of a renewal or modification to an existing permit list the existing permit
and its issue date .Tnne 74. 1998
•
McDowell
number_
FORA: DORS 06/94 Pale 1 of 7

FACILITY INFORMATION (al > additional pages for additional soi s of residuals):
. ; ;;dials o=e generated or prepared: Trigen—BioPower, Inc,
Facility permit number: WQ0010689 ; facility permit bolder: Ralph D . Smith
3. Specify whether facility in Section III.1 is owned by: federal; _ X private; state; local government;
4. Specify facility design flow: N/A tried; facility average daily flow: N/A mod;
Tyre of residual storage: Wood Ash
Volume of residual storage: Typically 200 tons
Length of residuals storage at facility: 60
days (the Division requires a minimum 30 days storage in units that
are separate from treatment system, i.e. not in clarifiers, aeration basins, etc.);
Estirr,ated volume of residuals: 2,500 (yy tons/yr ). Facility is requesting increase from
WUO to 2,500 dry tons / year
5. If the residual process facility is not the same as the generator, please specify delivery frequency and quantity of residual to
be processed: N/A
6. Facility contact (person familiar with residuals preparation):
David DeHart
7_ Facility contact's telephone number: ( 704 ) 525-5819
8. Location of treatment facility: NC State; McDowell County
9. Maiint address:
10. Specify the source of the residuals: treatment of water (alum sludges); treatment of industrial wastewater
(100' industrial residuals);
appropriate percentages of
treatment of industrial wastewater mixed with domestic wastewater (please specify
% industrial wastewater, % domestic wastewater);
X other(explain): Rnttnm, fly, and scrubber pond ash produced by the burning of wnnrl
waste and carpet scrap.
Attach an explanation of either the treatment process, manufacturing process, or how the waste is generated. Provide full
and complete details of the entire process.
11. Does the faciliry which generates the residuals have an approved pretreatment program? Yes; n No. X—N/A
ibis includes facilities which are classified as a "Class I" facility (any publicly owned treatment works required, under 40
CFR 403.8, to have an approved pretreatment program or any facility treating domestic sewage that is classified as "Class
I" the appropriate federal or State authority)
IV. RESIDUALS INFORMATION (attach additional pages for additional sources of residuals):
1. Information for Hazardous Waste (RCRA) Determination. The information requested on the 1Wtitations specified below
peraain only to those residuals that are generated from a municipal wastewater treatment facility with industrial contribution
or active pretreatment program and from any other treatment facility with wastewater sources that include industrial sources.
a. Are any of the residuals covered by this application listed in 40 CFR 261.31-261.33? Yes; X No. If Yes,
list the number(s):
b. Do the residuals exhibit any of the four characteristics defined by 40 CFR 261.21-261.24? Yes: X No.
Attacb laboratory results for the Toxicity Characteristic Leaching Procedure Analyses, Reactivity, Ignitability, and
Corrosivity for each residual.
Copy of annual report is attached.
FORM: DORS 06/94 Page 2 of 7

2.
cote• If the folio ,inn. constituent levels (as determined by the Toxicity Characteristic Leaching Procedure Analyses) arc
exceeded in the residuals or if the pH of the residual is not within the ranee listed below, the residual is b_.
deflnition a Hazardous waste. Chemical analyses must be made to Minimum Defection Levels.
PPM PPE
Arsenic 5.0 Barium 100.0
Benzene 0.5 Cadmium 1.0
Carbon tetrachloride - - 0.5- Chlordane ' 0.03
Chiorobenzere 100.0 Chloroform 6.0
Chromium 5.0 o-Cresol 240.0
m-Cresol 200.0 p-Cresol 200.0
Cresol 200.0 2.4-D 10.0
1,4-Dichlorobenzene 7.5 1,2-Dichloroethane 0.5
1,1-Dichloroethylene • 0.7 2,4-Dinitrotoluene 0.13
Endrin 0.02 Heptachlor (and its bydroxide) 0.008
Hexachlorobenzene 0.13 Hexachloro-1,3-butadiene 0.5
Hexachloroethane 3.0 Jpad 5.0
Lindane 0.4 Mercury 0.2
Methexychlor 10.0 Methyl ethyl ketone 200.0
Nitrobenzene 2.0 Pentachlorophenol 100.0
Pyridine 5.0 Selenium 1.0
Silver 5.0 Tetrachloroetbylene 0.7
Toxaphene : 0.5 Trichloroethylene 0.5
2,4,5-Trichlorophenol 400.0 2,4,6-Trichlorophenol 2.0
2,4,5-TP (Silvex) 1.0 Vinyl chloride 0.2
pH (2:1 vol./wt.): >2.0 s.u. - <12.5 s.u.
NOTE: IF ANY OF THE RESIDUALS MEET THE DEFINITIONS OF A HAZARDOUS WASTE,
AS NOTED IN EITHER "A" OR "B" ABOVE, A PERMIT CANNOT BE ISSUED FOR
THAT MATERIAL AND IT SHOULD NOT BE INCLUDED- AS PART OF THIS
APPLICATION.
For each residual, please attach a complete chemical analysis of the material. This analysis must be comprehensive enough
to completely characterize the residual and must be based upon a review of the process that generates the material. If the
facility that will generate the residual is not yet in operation, the characterization must be based on similar existing
facilities and projection based on the type of facility. The analysis must include a minimum of the following parameters
and any other known and suspected contaminants that are tributary to the system.
See attached annual report
Cadmiurn Aluminum pH
Copper Ammonia -Nitrogen Phosphorus
L Calcium Potassium
Nickel Magnesium Sodium
Zinc Nitrate -Nitrite Nitrogen TKN
Plant Available Nitrogen (by calculation)
Total Solids
3. Wastewater residuals can not be sold or given away if the concentration of any pollutant in the residuals exceeds the ceiling
concentrations specified in the table below. Specify the pollutant concentration of these residuals (attach lab analysis):
See attached annual report
Pollutant
Pollutant Ceiling Concentration (mg/kg)
Dry Weight Basis
Pollutant Concentration (mg/kg)
Dry Weight Basis *
C
Cadmium
85
1.98
Copper
4300 . - -
.
Lead
840 •
3 30.4
Nickel
420
9.76
`
Zinc
7500
7 9.8
9cr
onnn n.
FORM: DORS 06/94
Palle 3 of 7

"• ' provi j . an applicable. pilot studies and any bend]_ scale tests perio,�zed On ee�:i si .ua] source and the results. inc]udin.
the a; -,proximate fertilizer equivalent. N/A
5. Wastewater residuals can't be sold or given away in ba£s or other containers for application to the land unless one of the
following options is satisfied.
A Specify either A or B. Please be advised. if the residuals are to be sold or given away in bulk for application tc
lawn or home garden -then Option A is the only option. - -
A . The pollutant concentration of the residuals must be less than Pollutant Monthly Avera2e Concentrations
listed in the table below.
Pollutant
Monthly Avera2e Concentrations
Dry Weight Basis (mg./kg)
Pollutant Concentration
Dry Weight Basis (m :2)*
Cadmium
39
1 .98
Copper
1500
65.3
Lead
300
30.4
Nickel
420
_
9.76
Zinc
2800
_
79.8
*January 2000 Results
B . The product of the concentration of each pollutant in the residual and the annual .whole residual application
rate for the residual shall not cause the Annual Pollutant Loading Rate to be exceeded.
In order for the Annual Whole Residual Application Rate (AWRAR) to be calculated the Annual Pollutant
Loading Rate (APLR) is divided by the pollutant concentration (PC) times 0.001 (a conversion factor) as
follows:
AWRAR = APLR
PC * 0.001
Pollutant
Pollutant
Concentration
Dry Weight Basis -
(mg/kg)
Annual Pollutant '
Loading Rates
(APLR)
kg/hectare
Annual Whole Residual
Application Rate
(AWRAR)
kg/hectare
Cadmium
1.9
Copper
75
Lead
15
Nickel
21
.
Zinc
140
The AWRAR for the residual is the lowest AWRAR calculated. This is the maximum rate at which the
subject residual can be applied (to convert kg/hectare to lbs/acre multiply by 0.8924).. Please specify
ks/bectare or lbs/acre:
AWRAR
V . PATHOGEN REDUCTION INFORMATION (attach add. pages for additional sources of residuals)
In accordance with 15A NCAC 2H .0200, pathogen reduction can be achieved using either 40 CFR Part 257 or 40 CFR Part
503. Since the pathogen reduction requirements found in 40 CFR Part 257 (note, "Processes to Further Reduce Pathogens" or
PFRP) are incorporated into 40 CFR Part 503. only Part 503 is listed below. Please check which of the following applies to
the subject residual: N/A
FORM: DORS 06/94 Pate 4 of 7

1. In order for the residuals to be Class A, in accordance with the pathogen requirements in 40 CFR 503.32(a), either Pan a or
Part b 2nd one of the options in Pan c must be completed (please submit all lab analysis, test results and calculations):
a. A F: c-' cnt, form density less than 1000 Most Probable Number per gram of total dry sol; ds, or
b. A SairrinnPlla sp. density less than 3 Most Probable Number per 4 grams of total dry solids.
c. In addition to Pan a or Part b being met, one of the following ahematives must also be completed. Please
specify 1, 2, 3„ 4, 5a, 5b, 5c, 5d, 5e, 5f, 5g or 6 below being met:
1. Lime/ter^` erature - an increased residuals temperature should be maintained fur a pres:.:ibed period of time, in
accordance with the following guidelines. The results (D) shall be the amount of time, in days, that the residuals
shall remain at the given temperature:
lines
Total Solids
Temperature (0
Minimum Time
Equation
Notes
No beating of small
> or = 7%
> or = 50° C
> or = 20 minutes
D=131.700.000
particles by warmed
100.14 t
gases or immiscible
liauid.
> or = 7%
> or = 50° C
> or = 15 seconds
D.=131.700.000
Small particles heated by
,
100.14 t
w•arme,d gases or
immiscible liauid.
< 7%
> or = 50° C
> or = 15 seconds
D =1;1.700.000
100.14 t
to
< 30 minutes
< 7%
> or = 50° C
>or = 30 minutes
D = 50.070.00Qt
100.14 t -
2. alkaline treatment - the pH of the residuals is raised to greater than 12 for at least 72 hours. During this time, the
temperature of the residuals should be greater than 52° C for at least 12 hours. In addition, after the 72 hour
period, the residuals are to be air dried to at least 50% total solids.
3. prior testing for Enteric Virus/Viable Helminth Ova the residuals are analyzed for the presence of enteric viruses
(Plaque -forming units) jpfu] and viable helminth ova. If the residuals are analyzed before the pathogen reduction
process and found to have densities of enteric virus <1 pfu/4 grams of total solids and viable belminth dva <1/4g
total solids, the residuals are Class A with respect to enteric virus and viable belminth ova until the next
monitoring episode. If the residuals are analyzed before the pathogen reduction process and found to have densities
of enteric virus > or =1 pfu/4 g total solids or viable helminth ova > or = 1/4 g total solids, and tested again after
processing and found to meet the enteric virus and viable belminth ova levels listed under "4" below, then the
processed residuals will be Class A with respect to enteric viruses and viable helminth ova when the operating
parameters for the pathogen reduction process are monitored and shown to he consistent with the values or ranges
of values documented.
4. no prior testing for Enteric Virus/Viable Helminth Ova - if the residuals are not analyzed before pathogen reduction
processing for enteric viruses and viable belminth ova, the density of enteric viruses must be less than 1 pfu/4 g of
total dry solids and the density of viable helminth ova must be less than 1/4 g of total dry solids, or the residuals
must be treated by a "Process to Further Reduce Pathogens" or a "Process to Further Reduce Pathogens" equivalent
process.
5. lire "Processes to Further Reduce Pathogens" (PFRP) are described as follows:
a. Composting - using either the within -vessel or static aerated pile composting methods, the temperature of the
residuals are raised to 55° C or higher for three days. Using the windrow composting method, the residuals are
raised to 55° C or higher for fifteen days. During the high temperature period, there will be a minimum of five
turnings of the windrow.
FORM: DORS 06/94 Page 5 of 7

'h :..a 1 in;, - reside ;re dried by direct or indirect con 2ct with ! ascs to reduce the moi Slli, re
COnL^nt
l;he residuals to 10cic or lower. Either the temperature of the as in Cvu cut with the residuals exceedc 80° C o
the .. . h::'.h tefmneratur- of the ras in contact v: ith the residuals. when the residuals leave the dryer. exceer
80° C.
c. Hen: T re3LTnent - liquid residuals are heated to a temperature of 180° C or higher for thirty minutes.
d 1 :. ' o- hflic At.rohic - liouid residuals are 2gi1aled with air or oxygen to maintain aerobic condition:
a: residence times of ten days at temperatures of 55° C to 60° C.
e. Bey Ray Irradiation - residualszre liradiated with beta rays from an accelerator at 4osa2es of 21 least 1.(
Lee Barad at room temperature (ca. 20° C).
f. Gar^ ^'e Ray irradiation - residuals are irradiated with £ammo rays from certain isotopes such as 50Co ant
1' 7Cc, at dosagcs of at least 1.0 megarad at roots temperature (ca. 20° C).
g. Pasteurization - the temperature of the residuals is maintained at 70° C or higher for at least thirty minutes.
6. The residuals shall be treated in a process that is equivalent to a 'Processes to Further Reduce Pathogens" (P'RP),
as determined by the permitting authority based on evaluations of the recommendations provided by the Pathogen
Equivalency Committee.
VI. GENERAL INFORMATION:
1. Please provide a brief narrative concerning materials handling, includins the following:
a. How will the materials will be handled and transported from where the residuals were produced to where it will be
treated? Material is not treated. Material is transported on -site using front-end
b. Where wiutueT siduals be stored until processed? On -Site
c. How will leachatc collection be handled? In accordance with permit NCG210028
d What will be the duration of treatment? Material is not treated. Material may be screened to
remove nails, staples, etc.
e. Where will the final product be stored. On -Site
f. How long will the final product be stored before being distributed?
g. How will the final product be distributed (packaging)? , Bulk
Approximately 60 days
2. Please attach a marketability statement detailing destinations and approximate amounts of the final product to be
dis-buted. See attached annual report and attached information sheet.
3. Please provide either a label which shall be affixed to the bagged processed residual or an information sheet which shall be
provided to the person who receives the processed residual. The label or information sheet shall contain, at a minimum, the
following information:
See attached information sheet
a. The name and address of the person who prepared the residual that is sold or given away in a bag or other container for
application to the land.
b. A statement that application of the residual to the land is prohibited except in accordance with the instructions on the
label or information sheet.
c. A statement that the residuals shall not be applied to any site that is flooded, frozen or snow-covered..
d .A statement that adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored
residuals into any surface waters.
e. information on all applicable buffers including a 10 foot buffer between application site and any public or private water
supply source (including wells) and any stream, lake, river, or natural drainage way.
f. The Annual Whole Residual Application Rate (AWRAR) for the residual that does not cause any of the annual
pollutant loading rates to be exceeded (if necessary).
FORM: DORS 06/94 Pa2e 6 of 7

, arne any Comp ,etc Address of Engineering Firm: Not completed by Engineering Firm
City:
State: Zip:
Telephone Number: (
Professional Engineer's Certification:
I. David B. DeHart
of wood ash
. attest that this application for
Land application
has been reviewed by me and is accurate and complete to the best of my Imowledge. I further anest that to the best of my knowledge
the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal
packa°e may have been developed by other professionals, inclusion of these materials under my signature and sea) signifies that I have
reviewed this material and have judged it to be consistent with the proposed design.
North Carolina Professional Engineer's Seal, Signature, and Date:
Applicant's Certification:
I,
Ralph D. Smith
of wood ash
has been reviewed by me and is accurate and complete to the best of my knouiledce. I understand that if all required pans of this
application are not completed and that if all required support.in_• information -and attachments are not included, this application package
will be returned to me as incomplete. •
•
. attest that this application for Land Application
Signature
Date
March 30, 2000
THE COMPLETED APPLICATION PACKAGE. INCLUDING ALL SUPPORTING INFORMATION AND
MATERIALS, SHOULD BE SENT TO THE FOLLOWLNG ADDRESS:
NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
PERMITS AND ENGINEERING UNIT
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA 2762 6-0535
TELEPHONE NUMBER: [phone]
FORM: DORS 0 ►i9.1 P _c 7 of 7

TRIGEN-BIOPOWER, INC.
9140 ARROWPOINT BLVD., SUITE 370, CHARLOTTE, NC 28273
[phone] FAX: [phone]
TRIGEN
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
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.
1 Trigen-BioPower, Inc. plans to ask for a permit modification when the permit application extension is filed next 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
(continued)
-
Name of recipient: Jack 011is, 2070 Stamey Branch Road, Newland, NC
28657
Quantity received: 240 dry tons
Intended use: The wood ash was land applied.
Name of recipient: Bill Phillips, Route 3, Marion, NC 28752
Quantity received: 132 dry tons
Intended use: The wood ash was land applied.
Name of recipient: John English, Route 3, Box 283, Marion, NC 28752
Quantity received: 60 dry tons
Intended use: The wood ash was land applied.
III 3
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,
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 Creek Road Raleigh, NC 27607.6465
[phone]
Llnderstanding the ste Analysis Report
Waste products must be disposed of in ways that protect soil and water resources. The keys to proper disposal include analyzing the waste product and 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, specifically the sample identification number, waste code, and description. These data are
supplied by the grower on the information sheet submitted with each sample.
Laboratory Results Wastes are analyzed for up to 21 elements. Some are essential for plant growth—C, major nutrients (N, P, K), secondary nutrients
(Ca, Alg; S), and micronutrients (Fe, Mn, Zn, Cu, B, Mo, CI); others can permanently damage the soil or significantly impact production if allowed to
increase to toxic levels (Na, Ni, Cd, Pb, Al, Se, Li). Results are reported in parts per million, and these amounts are ranked as very high (1''II), high (11),
medium (NI), low (I,), or very low (VI,) in relation to nil other waste. of that type. If the sample is a compost or compost ingredient, values for p11, SS, and
C:.\' are reported. DrM% is reported for solid samples. CC1;% and ALE are reported for waste products That have neutralizing value.
Reconunendations This section can have three parts: (1) Nutrients Available for First Crop based on application method; (2) Other Elements that
may impact application; and (3) agronomic comments indicating precautions that should be taken when using the music.
(1) Predictions of nutrients available for the fist crop are based on estimates of mineralization rale and nutrient loss, depending on application method.
Estimates are reported in Ibs/Ion for solid 'wastes and Ibs/1000 gallons for liquid wastes. '"l' indicates that an clement is present in a ''trace"
quantity (< 0.005 lb per measured unit).
Within the first month after waste application, 50-75% of the nutrient quantities listed will become available for the crop. Therefore, plan to apply
wastes near the time that plants will require nutrients. The remaining nutrients gradually become available over the next three months.
Nutrients not available for the first crop are mineralized to available forms over lime, usually year's. Significant gttan titles of nutrients can accumulate
in soils that do not leach readily with heavy rainfall. If waste is routinely applied, lake soil samples al least once every Iwo years io monitor prurient
accumulation. Some cropping systems and metal levels may necessitate annual sampling.
ALE and CCE% are reported for wastes that may have neutralizing value. ALE indicates the amount of the waste product required to equal 1 Ion of
good gllalityagr'icultural lime (CCIi%=90). 11'Waste materials have significant neutralizing value, apply them only at rates necessary to optimize pll.
For flexibility, the information sheet provides two choices for application method. Predictions of available nutrients are based on the hype of waste
and the method of application. 11 you decide to change the application method after the analysis is complete, contact your local regional agronomist
or the Agronomic Division al [phone] for a revised recommendation.
(2) Quantities of other elements that are potentially harmful—Na, ;Ni, (,d Ph, Al, Se, and Li —indicate the likelihood of toxic buildup i11 the soil. Like
nutrients, they are reported in Ibs/Ion for solid wastes and Ibs/1(100 gallons for liquid wastes.
Soniclinles the r'ccon1111elldaUiofls section includes agronomic comments. These provide general information on the waste product and alert the IISCI'
when heavy metals or other elements are high enough to warrant special precautions when applying the waste. For diagnostic samples, silo -specific
recommendations are provided based on information sheet data. The more thoroughly the problem and its unique conditions are described on the
information sheet, the more pertinent and site specific the recommendations will be.
(3)
Key to Abbreviations
Al Aluminum
r11,E Agricultural lime equivalent
B Boron
C Carbon
Ca Calcium
CCIM i CaCO, egll ivalcnce
Cd Cadmium
CI - Chlorine
Cu Copper
I),1l% Percent dry matter
Fr Iron
K Potassium
K,O Potash
Li Lillrinnl
\Ig 11agn('siunr
"(n langan('s('
io lloltb(lennnl
Nitrogen
Na Sodium
NI14 Ammonium nitrogen
Ni Nickel
NO, Nitrate nitrogen
P " Phosphorus
P.,O, Phosphate
Pb Lead
pl l 'Ieasure of acidity or alkalinity
S Sulfur
Se S('1('flilllll
SS Soluble salts
T I Trace
Zri Zinc
10,000 copies of this public document were printed at a cost o1' $204.22 or $0.02 per copy.

1/20/00
;ample Info.
(duple ID:
1CDOWE
Vote Code:
)escrlption:
ndusl.•Stack Ash
DivisionSCDA Agronomic Lnnn Reedy Creek Road Raleigh, NC 27h117-h4h5 t,fl'll I -GO))
Groiver: Styles, Ricky
Rt. 3 Box 142 Old Linville Ihvy.
Marion, NC 28752
aste Analysis R eport Farm:
McDowell County
Copies 7'o: County Extension Director
USDA-NRCS-McDowell
Trigen-Biopower
Trigen-Biopower
attn:David Detlart
9140 Arrowpoint Blvd.
Charlotte, NC 28273
tecommendations:
pplicalion Method
1lroadcSsl
Soil lncorp
le waste product has a high
le Ion of agricultural lime.
Laboratory Results (parts per million unless otherwise noted)
P K Ca Mg ' S Fe
620 8450 1596 97.2 75.2 94.6
N
Total 64.0 VL
IN -N
-NH4
-NO3
Urea
2247 17299 131576 11974
M 11 11 H L
1/
Mn
Na Ni G(l Pb Al
OR-N
6936 15.4 0.94 11.2
VH M M M
Nutrients Available for First Crop lbs/ton (wet basis) Other Elements lbs/ton (wet basis)
N P205 K20 Ca Mg S Fe Mn Zn Cu 13 Mo CI
0.06 6.6 30.4 168.8 15.4 0.79 10.8 2.1 0.12 0.10 0.12
0.07 7.5 34.2 192.9 17.6 0.91 12.4 2.3 0.14 0.11 0.14
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
Se
Zn Cu 13
11
Mo Cl C
Li pH SS CN DM% CCE% ALE(tons)
12.12 91.63 69.25 1.40
Na Ni
12.7 0.03
12.7 0.03
Cd Pb Al Se Li
T 0.02
T 0.02

PAR Laboratories, Inc.
2217 Graham Park Drive
PO Box 411483
Charlotte, NC 28241-1483
Phone: [phone]; Fax: [phone]
NC Cer1 # 20.• SC Cert # 99003001
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 UNK UNK 01/14/00 1020 OT
CLIENT STATION ID: MARION, NC
WOOD ASH
LAB #: 19480
lt
pH VALUE S U. 12.2 /'Rg. 41 t v S
.9 I _ . I a
CORROSIVITY par Z
PAINT FILTER TEST
REACTIVITY �� r NON z, �_ _ - �r c q
NFL pys. /
NON
IGNITABILITY NON Par 2,8.3.1- 7 Z = Sk•$
FLASH POINT degrees F > 200 2--
ALUMINUM, TOTAL mg/kg 37,049 oc-oA
ARSENIC, TOTAL mg/kg 7.03 L� ,!
BARIUM, TOTAL mg/kg 1,466g 3.53 Par- 3 84 I t - 2-
BERYLLIUM, TOTAL mg/kg Z _Li .' CADMIUM, TOTAL mg/kg 8.41
CHROMIUM, TOTAL NcO�
COPPER, TOTAL mg/kg 39.3 f>7 ""�4`'G
LEAD TOTALmglk9 88.3 z1 ci. -f- i s ��
mg/kg 73.8 a r o ! C
MANGANESE, TOTALP�� 2_,
mg/kg
MERCURY, TOTAL .02
<
MOLYBDENUM, TOTAL mg/kg 02
NICKEL, TOTAL mg/kg 16.7 So trA
SELENIUM, TOTAL mg/kg 38.4 I o t g I g-/C. 13 L+ 8, q 2-7
SILICON, TOTAL mg/kg .103 Pam
SILVER, TOTAL mg/kg 104
mg/kg 4.87
SODIUM, TOTAL
mg/kg 10,918
TITANIUM, TOTAL �� °'�
ZINC, TOTAL mg/kg 2,234 Z' 0/ I I l
ARSENIC mg/kg 137
BARIUM mg/L < .50 r 2
mg/L < 10 ear
BENZENE mg/L < 05
CADMIUM mg/L < .10

[PAR.
s
LABORATORIES. INC.
PAR Laboratories, Inc.
2217 Graham Park Drive
PO Box 411483
Charlotte, NC 28241-1483
Phone: [phone]; Fax: [phone]
NC Cert 4'20; SC Cert dr99003001
MARION, NC FACITLITY (Page 2 of 2)
SAMPLE DELIVERY TO LAB
LAB No. DATE TIME SAMPLER DATE TIME MATRIX
19480 01/14/00 UNK UNK 01/14/00 1020 OT
CLIENT STATION ID: MARION, NC
WOOD ASH
LAB #: 19480
CARBON TETRACHLORIDE mg/L < .05
CHLORDANE mg/L < .003
CHLOROBENZENE mg/L < 10
CHLOROFORM mg/L < g
CHROMIUM mg/L < .50
m-CRESOL mg/L < 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 < .05
1,1-DICHLOROETHYLENE mg/L < 07
2,4-DINITROTLUENE mg/L < .013
ENDRIN mg/L < .002
HEPTACHLOR (AND ITS HYDROXIDE) mg/L < .0008
HEXACHLOROBENZENE mg/L < .013
HEXACHLOROBUTDIENE mg/L < .05
HEXACHLOROETHANE mg/L < .3
LEAD mg/L < .50
LINDANE mg/L < .04
MERCURY mg/L < 02
METHOXYCHLOR mg/L < 1
METHYL ETHYL KETONE mg/L < 20
NITROBENZENE mg/L < .2
PENTACHLOROPHENOL rrg/L < 10
PYRIDINE mg/L < 5
SELENIUM mg/L < .10
SILVER mg/L < .50
TETRACHLORETHYLENE mg/L < 07
TOXAPHENE mg/L < .05
TRICHLOROETHYLENE mg/L < .05
2,4,5-TRICHLOROPHENOL mg/L < 40
2,4,6-TRICHLORPHENOL mg/L < .2
2,4,5-TP(SILVEX) mg/L < 1
VINYL CHLORIDE mg/L < 02
LABORATORY DIRECTOR

TRIGEN-BIOPOWER, INC.
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): Date:
Ash Recipient's Address:
Intended Use of Ash:
Expected Qty/Yr: 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 Concentration
• Calcium Carbonate Equivalent 47.0%
Potash (K20) 2.45%
20-Mesh % 67.2%
100-Mesh % 42.8%
Metals (Total Concentration)
Parameter Concentration (mg/kg)
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 (mg/L)
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

1