WQ0039924_Renewal (Application)_20221201

Initial Review
Reviewer Thornburg, Nathaniel D
Is this submittal an application? (Excluding additional information.)*
Yes No
Permit Number (IR) * WQ0039924
Applicant/Permittee von Drehle Corporation
Applicant/Permittee Address 126 First Street Cordova, NC 28330
Is the owner in BIMS? Yes No Is the facility in BIMS?
Owner Type
Facility Name
County
Fee Category
Is this a complete application?*
Yes No
Signature Authority
Signature Authority Title
Signature Authority Email
Document Type (if non -application)
Email Notifications
Organization
von Drehle Corporation Class A Residuals Program
Richmond
Does this need review by the hydrogeologist? * Yes No
Regional Office
CO Reviewer
Admin Reviewer
Yes No
Fee Amount $0
Complete App Date 12/05/2022
Below list any additional email address that need notification about a new project.
... ... ..
Email Address
Comments to be added to email notfication
Comments for Admin
Comments for RO

Comments for Reviewer
Comments for Applicant

Submittal Form
Project Contact Information
Please provide information on the person to be contacted by NDB Staff regarding electronic submittal, confirmation of receipt, and other correspondence.
............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................
Name* Robert T. Branch
Email Address*
[e-mail]
Project Information
Application/Document Type*
New (Fee Required)
Modification - Major (Fee Required)
Renewal with Major Modification (Fee
Required)
Annual Report
Additional Information
Other
Phone Number*
3363129007
Modification - Minor
Renewal
GW-59, NDMR, NDMLR, NDAR-1,
N DAR-2
Residual Annual Report
Change of Ownership
We no longer accept these monitoring reports through this portal. Please click on the link below and it will take you to the correct form.
hftps://edocs.deq.nc.gov/Forms/NonDischarge_Monitoring_Report
Perm it Type:*
Wastewater Irrigation
High -Rate Infiltration
Other Wastewater
Reclaimed Water
Closed -Loop Recycle
Residuals
Single -Family Residence Wastewater
Other
Irrigation
Permit Number: *
WQ0039924
Has Current Existing permit number
Applicant/Permittee*
von Drehle Corporation
Applicant/Permittee Address*
126 First Street Cordova, NC 28330
Facility Name*
von Drehle Corporation Class A Residuals Program
Please provide comments/notes on your current submittal below.
Renewal with no modifications
At this time, paper copies are no longer required. If you have any questions about what is required, please contact Nathaniel Thornburg
at [e-mail].
Please attach all information required or requested for this submittal to be reviewed here.
(Application Form, Engineering Plans, Specifications, Calculations, Etc.)
2022 vd final renewal.pdf 3.15MB
Upload only 1 PDF document (less than 250 MB). Multiple documents must be combined into one PDF file unless file is larger
than upload limit.
* By checking this box, I acknowledge that I understand the application will not be
accepted for pre -review until the fee (if required) has been received by the Non -
Discharge Branch. Application fees must be submitted by check or money order and
made payable to the North Carolina Department of Environmental Quality (NCDEQ).
I also confirm that the uploaded document is a single PDF with all parts of the
application in correct order (as specified by the application).
Mail payment to:
NCDEQ — Division of Water Resources
Attn: Non -Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Signaturej•

Submission Date 12/1/2022

PERMIT RENEWAL FOR THE
DISTRIBUTION OF RESIDUAL SOLIDS
WQ0039924
VON DREHLE CORPORATION
CORDOVA, NC FACILITY
FIBER CLAY
CORDOVA, NORTH CAROLINA
Prepared For:
von Drehle Corporation
126 First Street
Cordova, NC 28330
Prepared By:
Branch Residuals & Soils, LLC
1735 Heckle Blvd. — Suite 103-291
Rock Hill, SC 29732
November 2022

BRANCH RESIDUALS & SOILS, LLC
1735 Heckle Blvd. Suite 103-291, Rock Hill, SC 29732
PHONE [phone] • Cell [phone]
November 30, 2022
NCDEQ -Division of Water Resources
Non -Discharge Branch
Mail Service Center 1617
Raleigh, North Carolina 27699-1617
Attention: Mr. Nathaniel Thornburg
Reference: PERMIT RENEWAL WQ0039924
von Drehle Corporation — Cordova Facility
Cordova, North Carolina
BR&S Job No. 2022-141
Dear Mr. Thornburg:
Branch Residuals & Soils, LLC is under contract with the von Drehle Corporation to prepare to renew the
current Class A distribution permit. von Drehle has transferred land that they own to Bio-Nomics so that
applications can continue to be made and a potential nitrogen source that will aid in the breakdown of the
fiber clay. The generated Fiber Clay has no domestic input but is derived from woody sources that are
known to have interference with fecal coliform values (Klebsiella sp.). Based on the false positive
interferences with the fecal coliform testing procedures, von Drehle will be performing Salmonella testing.
Distribution avenues will include application in accordance with soil lime requirements, distribution as a
soil amendment (either alone or in concert with other products), distributed to facilities that may blend soil
amendments and mulch, and as a daily landfill cover.
Please contact me immediately if you require additional information or have questions in the review of
the permit application.
Si ely,
r
Robert T. Branch, L. S. S.
Project Manager
cc: Mr. Mitchell Luckie— von Drehle Corporation— Cordova Facility

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

;3 01 fl Col 1
DISTRIBUTION OF RESIDUAL SOLIDS APPLCIATION FORM

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

D. Program Information (All Application Packages)
® Provide a narrative explaining the following:
® How the materials will be handled and transported from where the residuals were produced to where it will be treated.
® How the residuals will be processed/treated (attach process flow diagram).
® How leachate collection will be handled.
® Where the residuals will be stored until processed.
® How the final product will be distributed (packaging, bulk, etc.)
® What nutrients or other constituents (i.e. nitrogen, phosphorous, aluminum, calcium, etc.) are used or recommended as the
limiting parameter for determination of residuals loading rate to ensure that it does not overload the soil and cause
contravention of surface water or groundwater standards, limit crop growth, or adversely impact soil quality.
® Attach a marketability statement detailing destinations and approximate amounts of the final product to be distributed.
® Provide either a label that shall be affixed to the bagged processed residual or an information sheet that shall be provided to the
person who receives the processed residual. The label or information sheet shall contain, at a minimum, the following
information:
® Name and address of the person who prepared the residual that is sold or given away.
® A statement that application of the residuals to the land shall be in accordance with the instructions on the label or
information sheet.
® A statement that the residuals shall not be applied to any site that is flooded, frozen or snow-covered.
® A statement that adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored
residuals into any surface waters.
® Information on all applicable setbacks in accordance with 15A NCAC 02T. I 108(b).
® A statement that the residuals shall be applied at agronomic or recommended rates for intended uses.
E. Detailed Plans and Specifications (Application Involving New or Changes to Treatment or Storage Units)
❑ Submit detailed plans and specifications that have been signed, sealed, and dated by a NC Professional Engineer per 15A
NCAC 02T .1104(a). Specifications for standard equipment may only be omitted for municipalities with approved standard
specifications, but use of the standard specifications must be noted on each sheet of the plans.
❑ Plans must include the following minimum items: a general location map, a topographic map, plan and profile view of the
residuals treatment and storage units as well as the proximity of the residuals treatment and storage units to other utilities and
natural features within 500 feet of all treatment and storage facilities, and detail drawings of all items pertinent to the residuals
treatment and storage units. Depict minimum separations required in 15A NCAC 02T A 108(a) on the plans.
❑ Specifications must include, at a minimum, the following for all items pertinent to residuals treatment and storage units:
description of materials to be used, methods of construction, quality of construction testing procedures to ensure the integrity
of the final product in accordance with 15A NCAC 02T A 104(a)(2)(B), including leakage and pressure testing as appropriate.
❑ Plans and specifications must not be labeled with preliminary phrases (e.g., FOR REVIEW ONLY, NOT FOR
CONSTRUCTION, etc.) that indicate that they are anything other than final plans and specifications. However, the plans and
specifications may be labeled with the phrase: FINAL DESIGN — NOT RELEASED FOR CONSTRUCTION.
F. Engineering Calculations (Application Involving New or Changes to Treatment or Storage Units)
❑ Submit all design calculations that have been signed, sealed, and dated by a NC Professional Engineer per 15A NCAC 02T
.1 104a .
G. Environmental Assessments (Maybe Required— See 15A NCAC 1C .0300)
❑ Submit a copy of the Findings of No Significant Impact (FONSI) or Environmental Impact Statement (EIS). Also, include
information on any mitigating factor(s) from the Environmental Assessment (EA) that impact the construction of the residuals
treatment and storage facilities. An EA may also be required for private systems if any public funds and/or lands are used for
the construction of the subject facilities.
INSTRUCTIONS FOR FORM: DCAR 06-16 Page 2 of 3

H. Operation and Maintenance Plan (New and Renewal Application Packages)
® For Modification Application, if there are any changes to the existing plan, submit an updated O&M plan.
® Submit the O&M Plan in accordance with 15A NCAC 02T .1110 and include at a minimum:
® Operational functions; describe the operation of the program to show what operations are necessary for the program to function
and by whom the functions are to be conducted.
® Maintenance schedules; may include equipments calibration, maintenance of signs, etc.
® Safety measures; may include safety training program, manuals, signs, etc.
® Spill response plan; including control, containment, remediation, emergency contact information, etc.
® Inspection plan including the following information;
® Names and titles of personnel responsible for conducting the inspections.
® Frequency and location of inspections, including those to be conducted by the ORC, and procedures to assure that the selected
location(s) and inspection frequency are representative of the residuals management program.
® Detailed description of inspection procedures including record keeping and actions to be taken by the inspector in the event
that noncompliance is observed.
® Sampling and monitoring plan including the following information;
® Names and titles of personnel responsible for conducting the sampling and monitoring.
® Detailed description of monitoring procedures including parameters to be monitored.
® Sampling frequency and procedures to assure that representative samples are being collected. Fluctuation in temperature, flow,
and other operating conditions can affect the quality of the residuals gathered during a particular sampling event. The sampling
plan shall account for any foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to meet
pathogen and vector attraction reduction requirements (e.g. facilities that land apply multiple times per year but have an annual
sampling frequency, may need to sample during winter months when pathogen reduction is most likely to be negatively affected
by cold temperatures.
ONE ORIGINAL AND TWO COPIES OF THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL
SUPPORTING INFORMATION AND MATERIALS, SHALL BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service:
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
TELEPHONE NUMBER: [phone]
By Courier/Special Delivery:
512 N. SALISBURY STREET
RALEIGH, NORTH CAROLINA 27604
FAX NUMBER: [phone]
INSTRUCTIONS FOR FORM: DCAR 06-16 Page 3 of 3

State of North Carolina
DWR
Department of Environmental Quality
Division of Water Resources
Division of Water Resources 15A NCAC 02T .1100 — DISTRIBUTION OF CLASS A RESIDUALS
FORM: DCAR 06-16
I. APPLICANT INFORMATION:
1. Applicant's name: von Drehle Corporation
Applicant type: ❑ Individual ® Corporation ❑ General Partnership ❑ Privately -Owned Public Utility
❑ Federal ❑ State ❑ Municipal ❑ County
Signature authority's name per 15A NCAC 02T .0106: Michael Mennin¢ Title: Mill Manager
Applicant's mailing address: 126 First Street
City: Cordova State: NC Zip: 28330-
Telephone number: (2jQ) 410-1327 Email Address: [e-mail]
2. Consultant's name: Branch Residuals & Soils, LLC License Number (for P.E.):
Affiliation: ❑ On Staff ® Retained (Firm: )
Consultant's mailing address: 1735 Heckle Blvd. - Suite 103-291
City: Rock Hill State: SC Zip: 29732-
Telephone number: [phone] Email Address: bbranchAbranchrs.com
3. Fee submitted: 0.00 (See Instruction B)
II. PERMIT INFORMATION:
1. Application is for (check all that apply): ❑ new, ❑ modified, ® renewed permit
2. If this application is being submitted to renew or modify an existing permit, provide the following:
Permit number: W00039924
Date of most -recently issued permit: June 28, 2018
Date of most -recently certified Attachment A (if different than the permit): April 8, 2021
III. FACILITY INFORMATION:
1. Name of residuals processing facility: von Drehle Corporation - Cordova
City: Cordova State: NC Zip: 28330-
Coordinates: Latitude: 34' 55' 2." Longitude: 79. 49' 42"
Datum: NAD 83 Level of accuracy: V
Method of measurement: Map
County where facility is located: Richmond
2. Facility contact (person familiar with residuals preparation):
Name: Mitchell Luckie Title: Process Engineer
Mailing address: 126 First Street
City: Cordova State: NC Zip: 28330-
Telephone number: [phone] E-mail address: mitchell.luckie(a-,vondrehle.com
FORM: DCAR 06-16 Pagel of 3

3. Is the residual process facility also the generator? ® Yes; ❑ No
If No, please specify delivery frequency and quantity of residual to be processed:
4. Length of residuals storage at facility: 5 days (Note: the Division requires minimum 30 days storage in units that are separate
from treatment system, i.e. not in clarifiers, aeration basins, etc.)
IV. RESIDUALS QUALITY INFORMATION:
1. Specify how these residuals will be distributed:
❑ sold or given away in bags or other containers; ❑ lawn (bulk); ❑ home garden (bulk);
® other (explain); See Attached Management Plan
Note: Bulk residuals shall mean residuals that are transported and not sold or giving away in a bag or other receptacles with a
load capacity of one metric ton or less.
2. Complete the following if residuals are to be mixed with other materials:
Type of Materials
Amounts to be added
er 1.0 dry ton of residuals (dry ton
None
None
3. Approximate amounts of the residuals received and processed at the facility: 28,500 dry tons per year.
4. Approximate amounts of the final product (processed residuals) to be distributed: 35,000 dry tons per year.
5. Provide a description of the onsite storage management plan for the treated residuals (including estimated average and
maximum storage times prior to distribution): Residuals are kept on small storage pad prior to loading onto trucks
6. Does the facility have a stormwater management plan? ® Yes; ❑ No
Explain whether the treatment and storage areas are under roof or how stormwater runoff will be handled: Due to % solids,
free water is not generated, rainwater rewets solids.
V. RESIDUALS SOURCE INFORMATION: (Required for all new, renewed, or modified residuals source)
Complete and submit the attached Residuals Source Certification and all associated documentation.
If `r-�
Residuals Source
Certification
FORM: DCAR 06-16 Page 2 of 3

Professional Engineer's Certification: (Application Involving New or Changes to Treatment or Storage Units)
attest that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I further attest that to the best of my knowledge
the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package
may have been developed by other professionals, inclusion of these materials under my signature and seal signifies that I have reviewed
this material and have judged it to be consistent with the proposed design.
North Carolina Professional Engincer's Seal, Signature, and Date:
Applicant's Certification:
The applicant or any affiliate has not been convicted of an environmental crime, has not abandoned a wastewater facility without proper
closure, does not have an outstanding civil penalty where all appeals have been exhausted or abandoned, are compliant with any active
compliance schedule, and do not have any overdue annual fees under Rule 15A NCAC 02T .0105.
® Yes ❑ No, Explain;
I, Michael Menning Mill Manager
(Signature Authority's Name — PLEASE PRINT) (Title)
attest that this application for von Drehle Corporation — Cordova. NC Facility _
(Facility Name)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that the Division of Water Resources
may not conduct a technical review of this program and approval does not constitute a variance to any rules or statutes unless specifically
granted in the permit. Further, any discharge of residuals to surface waters or the land will result in an immediate enforcement action,
which may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the Division of Water
Resources should a condition of this permit be violated. I also understand that if all required parts of this application are not completed
and that if all required supporting information and attachments are not included, this application package will be returned to me as
incomplete.
Note: In accordance with North Carolina General Statutes § 143-215.6A and § 143-215.6B, any person who knowingly makes any false
statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up^to $25,000 per violation.
i n /! c
Signature: Y Date:
FORM: DCAR 06-16 Page 3 of 3

Copy of Existing Permit

Water Resources
ENVIRONMENTAL QUALITY
June 28, 2018
JUSTrN DAWKINS — PLANT MANAGER
vON DREHLE CORPORATION
126 FIRST STREET
CORDOVA, NORTH CAROLINA 28330
Dear Mr. Dawkins:
ROY COOPER
Governor
MICHAEL S. REGAN
.Secretory
I INDA CULPEPPER
Interim Director
Subject: Permit No. WQ0039924
von Drehle Corporation DCAR
Distribution of Class A
Industrial Byproduct
Residuals
Richmond County
In accordance with your permit application request received April 16, 2018, we are forwarding
herewith Permit No. WQ0039924 dated June 28, 2018, to the von Drehle Corporation for the start-up and
operation of the subject residuals management program.
This permit shall be effective from the date of issuance until May 31, 2023, and shall be subject to
the conditions and limitations as specified therein. Please pay particular attention to the monitoring
requirements listed in Attachment A. Failure to establish an adequate system for collecting and maintaining
the required operational information shall result in future compliance problems.
In response to questions raised during the review of the permit, the following responses were given:
1. Q: Condition 11.2. How will the damages be assessed in the event of a "third" party or a
contractor?
A: Condition III.12 comes into play for part of the answer to this question. If the Permittee
knew of the overapplication and did not report it, the Permittee would bear part of the
responsibility. If the Permittee knew of the overapplication and did report it, the Permittee
would bear none of the responsibility. If the Permittee did not know, then it will become a
matter of demonstrating lack of knowledge with a presumption that the Permittee did not know.
2. Q: Condition 11.5. Since von Drehle will have both a Class A and a Class B permit, can Class
A pathogen testing be utilized to meet Class B requirements for the Class B permit?
A: Yes, as long as they are less than a year old and it passes the Class A requirements.
- IP " 1' ot3 big Coinpare
State of North Carolina I Environmental Quality Water Resources I Water Quality Permitting Non -Discharge Permitting
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-807-6332

Mr. Justin Dawkins
June 28, 2018
Page 2 of 2
3. Q: Condition 11.6. Are these setbacks applicable to temporary 60 days' storage and if not are
there any additional requirements? Spelling treatment instead of reatment.
A: Yes the setbacks would apply to the temporary storage as well. The 60 days' storage would
be considered a temporary facility. And thanks for catching spelling error.
4. Q: Condition IV.6f. Application of this material will not be made based on the Agronomic
RYE rates. Use of these rates could provide a false justification of over -application.
A: This is a very valid point. Condition IV.6.f has been modified to account for a non -limiting
nutrient other than nitrogen.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding.
If you need additional information concerning this permit, please contact Troy Doby at (919) 807-
6336 or trov.doby ,ncdenr.goov.
Sinc//e--re��l��y,,,,,cc
:;?Linda Culpepper, Interim Director
Division of Water Resources
cc: Richmond County Health Department (Electronic Copy)
Fayetteville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Bob Branch, LSS — Branch Residuals & Soils, LLC (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
DISTRIBUTION OF CLASS A INDUSTRIAL BYPRODUCT RESIDUALS PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
von Drehle Corporation
Richmond County
FOR THE
operation of a residuals management program for von Drehle Corporation and consisting of the distribution
of Class A industrial byproduct residuals generated by the approved facility listed in Attachment A with no
discharge of wastes to surface waters, pursuant to the application received April 16, 2018, and in conformity
with other supporting data subsequently filed and approved by the Department of Environmental Quality
and considered a part of this permit. The use and disposal of residuals are regulated under Title 40 Code of
Federal Regulations Part 257. This permit does not exempt the Permittee from complying with the federal
regulations.
This permit shall be effective from the date of issuance until May 31, 2023, and shall be subject to the
following specified conditions and limitations:
I. SCHEDULES
No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application.
[15A NCAC 02T .0108(b)(2), 02T .0105(d), 02T .0109]
H. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all times so
there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perform satisfactorily, including the creation of prolonged
nuisance conditions due to improper operation and maintenance, the Permittee shall immediately cease
distribution of residuals, contact the Fayetteville Regional Office supervisor, and take any immediate
corrective actions. [G.S. 143-215.1]
2. This permit shall not relieve the Permittee of responsibility for damages to groundwater or surface
water resulting from the operation of this residuals management program. [15A NCAC 02B .0200,
02L .0100]
WQ0039924 Version 1.0 Shell Version 171.103 Page 1 of 10

3. Only residuals generated by the facility listed in Attachment A are approved for distribution in
accordance with this permit. [G.S. 143-215.1]
4. Pollutant concentrations in residuals distributed or applied to any land application site shall not exceed
the following Ceiling Concentrations or Monthly Average Concentrations (i.e., dry weight basis):
Parameter
Arsenic
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
n/a
Nickel
420
420
Selenium
100
100
Zinc
7,500 I
27800
[15A NCAC 02T .1105]
5. Residuals that are distributed shall meet Class A pathogen reduction requirements in 15A NCAC 02T
.1106 (a) and (b)(2). Exceptions to this requirement shall be specified in Attachment A. [ 15A NCAC
02T .1106]
6. Setbacks for treatment and storage facilities shall be as follows:
Setback Description Setback
_ (feet
Habitable residence or place of public assembly under separate ownership or not to 100
be maintained as part of the project site
Property lines 50
Private or public water supply 100
Surface waters (streams — intermittent and perennial, perennial waterbodies, and 50
-----1--- 1-•
Wells with exception to monitoring wells
[15A NCAC 02T. 1108]
100
WQ0039924 Version 1.0 Shell Version 171103 Page 2 of 10

7. Setbacks for Class A land applied bulk residuals shall be as follows:
Setback by residual type
Setback Description (feet)
Liquid Cake'
Private or public water supply
100
100
Surface waters (streams — intermittent and perennial,
100
25
erennial waterbodies, and wetlands)
Surface water diversions (ephemeral streams,
_ T 25
0
waterways, ditches)
25
0
Groundwater lowering ditches (where the bottom of
the ditch intersects the SHW
Wells with exception to monitoring wells
100
100
Bedrock outcrops
25
0
Unless otherwise noted in Attachment A, "cake" residuals are those that have greater than 15%
solids by weight and can be stacked without flowing, as well as can be handled, transported and
spread as a solid (e.g., using a backhoe, front end loader, stinger spreader, broadcast spreader or
other equipment designed for handling solid materials) without leaving any significant liquid
fraction behind.
[15A NCAC 02T .l 108]
8. Bulk residuals and other sources of Plant Available Nitrogen (PAN) shall not be applied in exceedance
of agronomic rates. Appropriate agronomic rates shall be calculated using expected nitrogen
requirements based on the determined Realistic Yield Expectations (RYE) using any of the following
methods:
a. Division's pre -approved site specific historical data for specific crop or soil types by calculating
the mean of the best three yields of the last five consecutive crop harvests for each field.
b. North Carolina Historical Data for specific crop and soil types as provided by North Carolina State
University Department of Soil Science (Lti.:,Ii'nuti-ients.soil.nesu.edu/vields/index.t)hp). A copy
shall be kept on file and reprinted every five years in accordance with Condition IV.6.
c. If the RYE cannot be determined using methods (a) or (b) above, the Permittee may use the RYE
and appropriate nutrient application rates reported in any of the following documents:
i. Crop management plan as outlined by the local Cooperative Extension Office, the North
Carolina Department of Agriculture. and Consumer Services, the Natural Resource
Conservation Service, or other agronomist.
ii. Waste Utilization Plan as outlined by the Senate Bill 1217 Interagency Group - Guidance
Document: Chapter 1
(littn://www.nea2r.i;ov/SWC/tecli/doctimetits/9th Guidance Doc 100109.Rt).
iii. Certified Nutrient Management Plan as outlined by the Natural Resources Conservation
Services (NRCS). These plans must meet the USDA-NRCS 590 Nutrient Management
Standards (ftp://ftp-fc.sc.eeov.usda.aovNl10 practice-standardslstandards/590.pdfZ
d. If the RYE and appropriate nutrient application rates cannot be determined, the Permittee shall
contact the Division to determine necessary action.
[I 5A NCAC 02T . 1109(b)(1)(k)]
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The Permittee shall not distribute Class A industrial byproduct residuals that have a sodium adsorption
ratio (SAR) of 10 or higher without prior written Division approval. The Permittee may seek approval
by demonstrating that the entity accepting the residuals is: aware of the effects of a high SAR content;
has agreed on proper residual application rates; and has agreed to operational considerations to ensure
that the high SAR content will not adversely impact the receiving sites. Recommendations regarding
sodium application rate, soil amendments (e.g., gypsum, etc.) or a mechanism for maintaining site
integrity and conditions conducive to crop growth, can be obtained from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, a North Carolina Licensed Soil Scientist, or an agronomist. [15A NCAC 02T
.0108(b)(1)]
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards. [15A NCAC 02T .1110]
2. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) Modifications
to the O&M Plan shall be approved by the Division prior to utilization of the new plan. The O&M Plan,
at the minimum, shall include:
a. Operational functions;
b. Maintenance schedules;
c. Safety measures;
d. Spill response plan;
e. Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including record keeping and actions to be taken
by the inspector in the event that noncompliance is observed pursuant to the noncompliance
notification requirements under the monitoring and reporting section of the permit;
f. Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring;
ii. Detailed description of monitoring procedures including parameters to be monitored;
iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for any
foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to
meet pathogen reduction requirements (e.g. facilities that distribute multiple times per year but
have an annual sampling frequency, may need to sample during winter months when pathogen
reduction is most likely to be negatively affected by cold temperatures).
[ 15A NCAC 02T .1100]
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3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in responsible
charge (ORC) and one or more certified operators as back-up ORCs in accordance with 15A NCAC
08G .0201. The ORC or his back-up shall visit the facilities in accordance with 15A NCAC 08G. 0204,
or as specified in the most recently approved O&M plan (i.e., see Condition 111.2.), and shall comply
with all other conditions of 15A NCAC 08G. 0204. For more information regarding classification and
designation requirements, please contact the Division of Water Resources' Protection and Enforcement
Branch at [phone]. At the time of this permit issuance, a certified ORC is not required for the
subject Distribution of Class A Residuals program. [15A NCAC 02T .0117]
4. When the Permittee land applies bulk residuals. a copy of this permit and a copy of O&M Plan shall be
maintained at the land application sites during land application activities. [15A NCAC 02T
.0108(b)(1)]
5. When the Permittee transports or land applies bulk residuals, the spill control provisions shall be
maintained in all residuals transport and application vehicles. [15A NCAC 02T .l 110]
6. When the Pennittee land applies bulk residuals, adequate measures shall be taken to prevent wind
erosion and surface runoff from conveying residuals from the land application sites onto adjacent
properties or into surface waters. [G.S. 143-215.1 ]
7. When the Permittee land applies bulk residuals, a suitable vegetative cover shall be maintained on land
application sites onto which residuals are applied, or application shall be in accordance with the crop
management plan outlined by the local Cooperative Extension Office, the Department of Agriculture
and Consumer Services, the Natural Resource Conservation Service, or an agronomist and as approved
bythe Division. [15ANCAC 02T .1109(b)(1)]
8. Bulk residuals shall not be land applied under the following conditions:
a. If the residuals are likely to adversely affect a threatened or endangered species listed under section
4 of the Endangered Species Act or its designated critical habitat;
b. If the application causes prolonged nuisance conditions;
c. If the land fails to assimilate the bulk residuals or the application causes the contravention of surface
water or groundwater standards;
d. If the land is flooded, frozen or snow-covered, or is otherwise in a condition such that runoff of the
residuals would. occur:
e. Within the 100-year flood elevation, unless the bulk residuals are injected or incorporated within a
24-hour period following a residuals land application event;
f. During a measurable precipitation event (i.e., greater than 0.01 inch per hour), or within 24 hours
following a rainfall event of 0.5 inches or greater in a 24-hour period;
g. If the slope is greater than 10% for surface applied liquid residuals, or if the slope is greater than
18% for injected or incorporated bulk liquid residuals;
h. If the land does not have an established vegetative cover unless the residuals are incorporated or
injected within a 24-hour period following a residuals land application event. Any field that is in a
USDA no -till program shall be exempted from meeting this vegetative cover requirement;
i. If the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
j. If the vertical separation of bedrock and the depth of residuals application is less than one foot,
k. Application exceeds agronomic rates.
[I 5A NCAC 02T. 1109]
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The Permittee shall notify all third -party entities receiving bulk distributed Class A industrial byproduct
residuals that land application activities occurring on the third-party's property shall meet the
requirements in 15A NCAC 02T .1108(b)(1) and 02T .1109(b) (i.e., Conditions II.8. and III.8.,
respectively). [15A NCAC 02T .1103(5)]
10. All residuals shall be adequately stored to prevent untreated leachate runoff. The finished product may
be placed on a concrete pad, placed under shelter or physically covered until it is distributed to a third -
party entity. If bulk residuals are to be applied, the residuals may be staged at the application site for
up to 30 days for biological residuals, and 60 days for non -biological residuals. If an alternate storage
site is used, approval must be obtained from the Division. [15A NCAC 02T .0108(b)(1)]
11. A label shall be affixed to the bag or other container in which residuals are sold or given away for land
application, or an information sheet shall be provided to the person who receives Class A residuals. At
a minimum, the label or information sheet shall contain the following:
a. The name and address of the person who prepared the residuals;
b. A statement that residual land application is prohibited except in accordance with the instructions
on the label or information sheet;
c. A statement identifying that this material shall be prevented from entering any public or private
water supply source (including wells) and any surface water (e.g., stream, lake, river, wetland, etc.);
d. A statement that the residuals shall be applied at agronomic rates and recommended rates for its
intended use.
[ 15A NCAC 02T. I 109(a)]
12. The Permittee shall not distribute bulk residuals to any person or entity known to be applying residuals
contrary to the conditions of this permit. The Permittee shall report to the Fayetteville Regional Office
as per reporting conditions under Condition IV.8. any person or entity known to be applying residuals
contrary to the condition of this permit. [15A NCAC 02T.] 103(a)]
WQ0039924 Version 1.0 Shell Version 171103 Page 6 of 10

IV. MONITORING AND REPORTING REQUIREMENTS
Any Division -required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed. [15A NCAC 02T .0108(c)]
Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). Residuals that tests or is classified as a hazardous or toxic waste under 40
CFR Part 261 shall not be used or disposed under this permit. The analyses [corrosivity, ignitability,
reactivity, and toxicity characteristic leaching procedure (TCLP)J shall be performed at the
frequency specified in Attachment A, and the Permittee shall maintain these results for a minimum of
five years. Any exceptions .from the requirements in this condition shall be specified in Attachment A.
The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
Arsenic (5.0)
1.4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Heptachlor (and its hydroxide)
(0.008
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
• Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
I Methoxychlor (10.0)
Methyl ethyl ketone (200.0)
Vinyl chloride (0.2)
Cresol (200.0)
2,4-D (10.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A, the
Permittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
[15A NCAC 13A .0102(b), 02T .1101, 02T .1105]
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3. An analysis shall be conducted on the residuals from each source generating facility at the frequency
specified in Attachment A, and the Permittee shall maintain the results for a minimum of five years.
The analysis shall include the following parameters:
Aluminum
Mercury
Potassium
Selenium
Ammonia -Nitrogen
Molybdenum
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite Nitrogen
Sodium Adsorption Ratio
(SAR)
Calcium
Copper
Lead
Percent Total Solids
TKN i
pH
Zinc
W
—
Phosphorus
Magnesium �
Plant Available Nitrogen
(by calculation)
[15A NCAC 02T .1101]
4. Residuals shall be monitored for compliance with pathogen reduction requirements at the frequency
specified in Attachment A, and at the time indicated in the sampling and monitoring sections of the
approved O&M plan. The required data shall be specific to the stabilization process utilized, and
sufficient to demonstrate compliance with the Class A pathogen reduction requirements in 15A NCAC
02T .1106 (a) and (b)(2) shall be met. Any exceptions from the requirements in this condition shall be
specified in Attachment A. [15A NCAC 02T .1106, 02T .l 107, 02T .l l 11(c)j
5. Laboratory parameter analyses shall be performed on the residuals as they are distributed, and shall be
in accordance with the monitoring requirements in 15A NCAC 02B .0505. [15A NCAC 02B .0505]
6. The Permittee shall maintain records tracking all bulk residual distribution or land application events
performed by the Permittee. At a minimum, these records shall include the following:
a. Source of residuals;
b. Date of distribution/land application;
c. Name and address of recipient of residuals;
d. Volume of residuals distributed to each recipient;
e. Intended use of residuals;
f. If land application events performed by the Permittee:
i. When the agronomic rate is on the basis of Nitrogen, then the Nitrogen Application Rate based
on RYES (if using data obtained from the North Carolina State University Department of Soil
Science Website, the printout page shall be kept on file and reprinted every five years).
ii. When the agronomic rate is on the basis of some other nutrient than Nitrogen, then this shall
be included as part of the Operations & Maintenance Plan required in Condition HI.2. A set of
calculations shall be performed to show that the residuals are being applied at an agronomic
rate on the basis of this limiting nutrient. These records shall be kept for a minimum of five
years and shall be available for inspection.
[15A NCAC 02T .0108(a)]
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7. Three copies of an annual report shall be submitted on or before March 11. The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Reporting Forms.
Instructions for reporting and annual report forms are available at
http://'deL.nc.L,ov/about/divisions/water-resourcess/�ater-resources-perm its!wastewater-branch/non-
discharue-termitting-unit/reporting-forms, or can be obtained by contacting the Non -Discharge
Permitting Unit directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .I I I l(a)]
8. Noncompliance Notification
The Pennittee shall report by telephone to the Fayetteville Regional Office, telephone number (910)
433-3300, as soon as possible, but in no case more than 24 hours or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Distribution of residuals abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to surface waters.
c. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
e. Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure that the problem does not recur. [15A NCAC 02T .0105(1), 02T .0108(b)(1)]
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan. [ 15A NCAC 02T .0l 08(b)]
2. Prior to each bulk residuals distribution event, the Pennittee or his designee shall inspect the residuals
storage, transport and distribution facilities to identify malfunctions, facility deterioration and operator
errors that could result in discharges to the environment, a threat to human health or a public nuisance.
The Pennittee shall maintain an inspection log that includes, at a minimum, the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken. The Pennittee
shall maintain this inspection log for a period of five years from the date of inspection, and this log
shall be made available to the Division upon request. [15A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the distribution sites or facilities permitted herein at
any reasonable time for the purpose of determining compliance with this permit; may inspect or copy
any records required to be maintained under the terms and conditions of this permit; and may collect
groundwater, surface water or leachate samples. [G.S. 143-215.3(a)(2)]
WQ0039924 Version 1.0 Shell Version 171103 Page 9 of 10

VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit shall become voidable if the residuals distribution events are not carried out in accordance
with the conditions of this permit. [15A NCAC 02T .0110]
3. This permit is effective only with respect to the nature and volume of residuals described in the permit
application and other supporting documentation. [G.S. 143-215.1]
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under the Division's General Permit NCGO10000; any requirements pertaining to wetlands under 15A
NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter
143 of the General Statutes. [ 15A NCAC 02T .0105(c)(6)]
In the event the residuals program changes ownership or the Permittee changes his name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner. [15A NCAC 02T .0104]
6. This permit is subject to revocation or unilateral modification upon 60-day notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0 l 10. [15A NCAC 02T .0110]
7. Unless the Division Director grants a variance, expansion of the permitted residuals program contained
herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b).
[15A NCAC 02T .0120]
8. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 28" day of June 2018
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
?Linda Culpepper, Interim Director
Division of Water Resources
By Authority of the Environmental Mt"hagi n ent Commission
Permit Number WQ0039924
WQ0039924 Version 1.0 Shell Version 171103 Page 10 of 10

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ROY COOPER
Governor
DIONNE DELLPGATTI
Secretory
S. DANIEL SMITH
Director
JUSTIN DAIWKINS — PLANT MANAGER
VON DREHLE CORPORATION
126 FIRST STREET
CORDOVA, NORTH CAROLINA 28330
Dear Mr. Dawkins
NORTH CAROLINA
Environmental Quality
April 8, 2021
Subject: Permit No. WQ0039924
von Drehle Corporation DCAR
Attachment A Certification
Richmond County
In accordance with your pen -nit major modification request received February 1, 2021, we are
forwarding herewith a modified Attachment A certified April 8, 2021, to the von Drehle Corporation for
the subject residuals management program.
Modifications to the subject Attachment are as follows: Increasing the permitted dry tonnage of
residuals from the von Drehle Corporation WWTP from 16,499 dry tons per year (DT/yr) to 35,000 DT/yr.
The modified Attachment A shall be effective from the date of certification until May 31, 2023
(i.e., expiration date of the current permit), shall void Attachment A of Pen -nit No. WQ0039924 issued June
28, 2018, and shall be subject to the conditions and limitations as specified therein, as well as those specified
in the above -referenced pennit. Please replace Attachment A of Permit No. WQ0039924 that was issued
June 28, 2018 with the modified Attachment A. Please note that the Permittee shall submit a renewal
application no later than December 2, 2022.
If any parts, requirements or limitations contained in this certification are unacceptable, the
Permittee has the right to request an adjudicatory hearing upon written request within 30 days following
receipt of this permit. This request shall be in the form of a written petition, conforming to Chapter 150B
of the North Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail
Service Center, Raleigh, NC 27699-6714. Otherwise, this certification shall be final and binding.
If you need any additional infonriation concerning this matter, please contact Erick Saunders at
[phone] or erickson.saunders umcdenr.lrov.
Sincerely,
S. Daniel Smith, Director
Division of Water Resources 1
cc: Richmond County Health Department (Electronic Copy)
Fayetteville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
North Carolina Department of Envkronmental Quality I Division of Water Resources
512 North Salisbury Street 1617 Mail Service Center I Raleigh, North Carolina 27699 1611
919.707,9000

Mr. Justin Dawkins
April 8, 2021
Page 2 of 2
Bob Branch, LSS — Branch Residuals & Soils, LLC (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)

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SECTION II
RESIDUALS SOURCE CERTIFICATION ATTACHMENT - FIBER CLAY

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

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

Note: Biological residuals are residuals that have been generated during the treatment of domestic wastewater, animal
processing wastewater, or the biological treatment of industrial wastewater (biological treatment is a system that utilizes
biological processes including lagoons, activated sludge systems, extended aeration systems, and fixed film systems).
3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non -hazardous under
RCRA: (Note - this item does not have to be completed for facilities that are less than 0.5 MGD in design flow that treat
100% non -municipal, domestic wastewater only)
a. Are the residuals listed in 40 CFR §261.31-§261.33: ❑ yes ® no.
If yes, list the number(s):
b. Specify whether or not the residuals exhibit any of the characteristics defined by 40 CFR §261.21-
261.24: ❑ yes ® no.
Fill in the following tables with the results of the latest toxicity characteristic leaching procedure (TCLP) analysis as well
as those for corrosivity, ignitability, and reactivity:
Laboratory: Environmental Chemists Inc. and Date of analysis: Feb 09, 2022
Passed corrosivity test: ® yes ❑ no. pH: s.u. (2 < pH < 12.5)
Passed ignitability test: ® yes ❑ no. Flashpoint: <0.8 mm/sec (> 140°F)
Passed reactivity test: ® yes ❑no. HCN: 1.36 mg/kg (<250) & H2S: 0.56 mg/kg (<500)
TCLP Parameter
Limit
(mg/1)
Result
(mg/1)
TCLP Parameter
Limit
(mg/1)
Result
(mg/1)
Arsenic
5.0
<1.00
Hexachlorobenzene
0.13
<0.05
Barium
100.0
<1.00
Hexachloro-1,3-Butadiene
0.5
<0.05
Benzene
0.5
<0.01
Hexachloroethane
3.0
<0.05
Cadmium
1.0
<1.00
Lead
5.0
<1.00
Carbon Tetrachloride
0.5
<0.01
Lindane
0.4
<0.0005
Chlordane
0.03
<0.02
Mercury
0.2
<0.0002
Chlorobenzene
100.0
<0.01
Methoxychlor
10.0
<0.0005
Chloroform
6.0
<0.01
Methyl Ethyl Ketone
200.0
<0.05
Chromium
5.0
<1.00
Nitrobenzene
2.0
<0.05
m-Cresol
200.0
<0.05
Pentachlorophenol
100.0
<0.05
o-Cresol
200.0
<0.05
Pyridine
5.0
<0.05
p-Cresol
200.0
<0.05
Selenium
1.0
<1.00
Cresol
200.0
<0.05
Silver
5.0
<1.00
2,4-D
10.0
<0.003
Tetrachloroethylene
0.7
<0.01
1,4-Dichlorobenzene
7.5
<0.05
Toxaphene
0.5
<0.05
1,2-Dichloroethane
0.5
<0.01
Trichloroethylene
0.5
<0.01
l,l-Dichloroethylene
0.7
<0.01
2,4,5-Trichlorophenol
400.0
<0.05
2,4-Dinitrotoluene
0.13
<0.05
2,4,6-Trichlorophenol
2.0
<0.05
Endrin
0.02
<0.0005
2,4,5-TP (Silvex)
1.0
<0.003
Heptachlor and its Hydroxide
0.008
<0.0005
Vinyl Chloride
0.2
<0.01
FORM: RSC 06-16 Page 2 of 5

4. Metals Determination: Complete one of the following tables (i.e., as applicable) to demonstrate that the residuals do not violate
the ceiling concentrations for metals regulated under 15A NCAC 02T .1105.
a. For Distrihution/Land Application: Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: Waypoint Analytical and Date of analysis: July 26, 2022
Parameter
Ceiling
Concentration Limits
(ClassA & C1assB)
(mglkg)
Monthly Average
Concentration Limits
(Class A Only)
(mglkg)
Result
(mglkg)
Arsenic
75
41
<1.56
Cadmium
85
39
<0.312
Copper
4,300
1,500
27.0
Lead
840
300
2.08
Mercury
57
17
<0.452
Molybdenum
75
n/a
3.64
Nickel
420
420
2.08
Selenium
100
100
<1.56
Zinc
7,500
2,800
93.8
b. For Surface Disposal Unit (landrll): Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: and Date of analysis:
Distance from Disposal
Unit to Boundary to
Closest Property Line
(meters, check one)
Arsenic
(mg/k-g)
Chromium
(mg/kg)
Nickel
(mg/kg)
❑ > 0 but < 25
30
200
210
❑ > 25 but < 50
34
220
240
❑ > 50 but < 75
39
260
270
❑ > 75 but < 100
46
300
320
❑ > 100 but < 125
53
360
390
❑ > 125
62
450
420
Result (mg/kg)
FORM: RSC 06-16 Page 3 of

FORM: RSC 06-16 Page 4 of

5. Nutrient/Micronutrient Determination: Complete the following:
a. Total solids: 32.1 %.
b. Fill in the following table with the results of the latest analyses (i.e., on a dry weight basis) for the following nutrient and
micronutrient parameters:
Laboratory: Waypoint Analytical and Date of analysis: July 26, 2022
Parameter
Result
(mg/k-9)
Aluminum
1680.00
Ammonia -Nitrogen
330.00
Calcium
110,000.00
Magnesium
1,400.00
Nitrate -Nitrite Nitrogen
<3.12
pH (Standard Unit)
7.80
Phosphorus
127.00
Potassium
66.70
Sodium
595.00
Total Kjeldahl Nitrogen
2,830.00
c. Using the results listed in Item II. 5b. above, calculate the sodium adsorption ration (SAR): 0.28
[Note: If residuals contain SAR of 10 or higher, the applicant shall obtain recommendations from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, a
North Carolina Licensed Soil Scientist, or an agronomist, prior to land application of residuals. The recommendations shall
address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a mechanism for maintaining site integrity and
conditions conducive to crop growth].
d. Specify the mineralization rate to be used in calculating the plant available nitrogen (PAN) of the residuals: 0.40 %. This
rate is a (check one): ® default value, or ❑ actually established.
If the residuals are not generated from the treatment of municipal or domestic wastewater, explain or provide technical
justification as to why the selected default value is appropriate to be applied to these residuals: N/A
e. Calculate the PAN for the residuals (i.e., on a dry weight basis) and fill the results in the following table:
Application Method
First (15`) Year PAN
Five -Year
Maximum Adjusted PAN
(mg1kg)
(mg/kg)
Surface
1,168
1,668
Injection/Incorporation
1,333
1,833
6. Other Pollutants Determination: Specify whether or not there are any other pollutants of concern in the residuals and provide
the results of the latest analyses:
FORM: RSC 06-16 Page 5 of

7. Pathogen Reduction: Per 15A NCAC 02T.11061 specify how residuals will meet the pathogen reduction requirements:
a. For Distribution/Land Application of Class A or Equivalent:
® A fecal coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry solids,
or
® A salmonella sp. density that is demonstration to be less than 3 MPN per 4 grams of total dry solids.
AND one of the followings (except for non -biological residuals):
❑ Alternative 1 [15A NCAC 02T.I 106(b)(3)(A)] - Time/Temperature Compliance.
❑ Alternative 2 [15A NCAC 02T.I 106(b)(3)(B)] - Alkaline Treatment.
❑ Alternative 3 [15A NCAC 02T.I 106(b)(3)(C)] - Prior Testing for Enteric Virus/Viable Helminth Ova.
❑ Alternative 4 [15A NCAC 02T.I 106(b)(3)(D)] - No Prior Testing for Enteric Virus/Viable Helminth Ova.
❑ Alternative 5 [15A NCAC 02T.I 106(b)(3)(E)-(K)] - Process to Further Reduce Pathogens (PFRP).
Specify one: ❑ composting, ❑ heat drying, ❑ heat treatment,
❑ thermophilic aerobic digestion, ❑ beta ray irradiation,
❑ gamma ray irradiation, or ❑ pasteurization.
b. For Land Application of Class B:
❑ Alternative 1 [15A NCAC 02T.1106(c)(1)] -Fecal Coliform Density Demonstration.
❑ Alternative 2 [15A NCAC 02T.I 106(c)(2)] - Process to Significantly Reduce Pathogens (PSRP).
Specify one: ❑ aerobic digestion, ❑ air drying, ❑ anaerobic digestion,
❑ composting, or ❑ lime stabilization.
c. For Surface Disposal:
❑ Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item II. 7a. above.
❑ Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item II. 7b. above.
❑ Exempt -If Daily Cover Alternative is chosen in Item II.8. below [15A NCAC 02T.1106(a)(2)].
❑ Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
8. Vector Attraction Reduction (VAR): Per 15A NCAC 02T.1107, specify how residuals will meet the VAR requirements:
❑ Alternative 1 [15A NCAC 02T. I 107(a)(1)] - 38% Volatile Solids Reduction (Aerobic/Anaerobic Digestion).
❑ Alternative 2 [15A NCAC 02T.I 107(a)(2)] - 40-Day Bench Scale Test (Anaerobic Digestion).
❑ Alternative 3 [15A NCAC 02T.I 107(a)(3)] - 30-Day Bench Scale Test (Aerobic Digestion).
❑ Alternative 4 [15A NCAC 02T.I 107(a)(4)] - Specific Oxygen Uptake Rate Test (Aerobic Digestion).
❑ Alternative 5 [15A NCAC 02T.I 107(a)(5)] - 14-Day Aerobic Processes.
❑ Alternative 6 [15A NCAC 02T.I 107(a)(6)] - Alkaline Stabilization.
❑ Alternative 7 [15A NCAC 02T.I 107(a)(7)] - Drying of Stabilized Residuals.
❑ Alternative 8 [15A NCAC 02T.I 107(a)(8)] - Drying of Unstabilized Residuals.
❑ Alternative 9 [15A NCAC 02T.I 107(a)(9)] - Injection.
❑ Alternative 10 [15A NCAC 02T.I 107(a)(10)] - Incorporation.
❑ Alternative for Surface Disposal Units Only - Soil/Other Material Cover [ 15A NCAC 02T. 1107(b)(2)].
® Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
Note: For animal processing residuals, only alternatives 9 or 10 may be chosen due to the nuisance conditions that typically occur
when these residuals are applied and left on the land surface.
FORM: RSC 06-16 Page 6 of

Vicinity Map

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DATE: 1 8, 2021 SOLILS, LLC Project No. 2014-110

Process Flow Diagram and Narrative

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

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

Von Drehle Paper Process Flowchart
aste Paperl_J Pulper
Bails in
Dump L accepts I Detrasher
Tank Scavenger
accepts rejects
Coarse
Screen creene
accepts
Ho
Cleaner
accepts
:Coarsereen
accepts
Cleaners
accepts
Fine
Screens
accepts
Washer
accepts
Screw
Press
accepts
�ate�
accepts
Drum
Screen
rejects
Tailings reje� Pit Landfill
accepts
rejects
Mill Krofta rejects Sludge
'um
OAF Press
accepts
Water to
City or
return to Process
IBleach
Tower
egacel
OAF
rejects
Paper
Machine
Product
Belt Press Fiber Clay to
Land Application or
Landfill

Justification of Residuals Production Rate

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von Drehle Corporation produces approximately 28,500 dry tons of the Fiber Clay annually. In order
to account for variability, the dry ton permit limit will be set at 35,000 dry tons.

Sampling Plan

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

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

Residual Analytical Reports

Facility:
Source:
Location:
Contractor:
Type of Analysis:
Report No:
Date Sampled:
Date Reported:
Reporting Period:
von Drehle Corporation
Fiber Clay
Cordova, NC
Bio-Nomic Services
Industrial Residual Solids
22-195-0047
7/13/2022
7/26/2022
July -Aug 2022
Parameter
%
PPM
Dry Weight
EPA
Monthly Limits
Solids
32.10
Nitrogen (TKN)
0.283
2,830.000
Phosphorus
0.01270
127.000
Potassium
0.007
66.700
Sulfate
Calcium
11.000
110,000.000
Magnesium
0.144
1,440.000
Sodium
0.060
595.000
Iron
---
1,140.000
Aluminum
---
1,680.000
Manganese
---
Copper
---
27.000
1,500
Zinc
---
93.800
2,800
Ammonia Nitrogen
0.033
330.000
Nitrate N / Nitrite N
---
3.120
Cadmium
---
0.312
39
Chromium
---
1,200
Nickel
---
2.080
420
Lead
---
2.080
300
Arsenic
---
1.560
41
Mercury
---
0.452
17
Selenium
---
1.560
100
pH
7.800
Calcium Carbonate Eq.
28.100
281,000.000
Organic Nitrogen
0.250
Molybdenum
3.640
75
Volatile Solids
Boron
TOC
0.000

Industrial Residual Solids
Fiber Clay
Cordova, NC
Bio-Nomic Services
July -Aug 2022
Date Reported: 7/26/2022 Report No: 22-195-0047
Note All Units in Pounds Per Dry Ton
Macro Nutrients Physical Characteristics
PAN Surf.
2.336
PAN Inj.
2.666
P
0.254
K
0.133
Lime
562.000
Secondary Nutrients
Calcium
220.000
Magnesium
2.880
Sodium
1.190
SAR
0.276
Chloride
0.000
Iron
2.280
Alumium
3.360
Manganese
0.000
Boron
0.000
Sulfur
0.000
% Solids
32.10
pH
7.800
Min Rate
0.400
C:N Ratio 0.000
N Needed for 30:1 0.000
Metals
Arsenic
0.003
Cadmium
0.001
Chromium
0.000
Copper
0.054
Lead
0.004
Mercury
0.001
Molybdenum
0.007
Nickel
0.004
Seleniun
0.003
Zinc
0.188

Waypointo
ANALYTICAL
7/26/2022
Branch Residuals and Soils LLC
Mr. Bob Branch
1735 Heckle Blvd
Suite 103-291
Rock Hill, SC, 29732
Ref: Analytical Testing
Lab Report Number: 22-195-0047
Client Project Description: Von Dizehle
Cordova, NC
Project #2014-110
2790 Whitten Road, Memphis, TN 38133
Main 901.213.2400 0 Fax [phone]
www.waypointanalytical.com
Dear Mr. Bob Branch:
Waypoint Analytical, LLC. received sample(s) on 7/14/2022 for the analyses presented in the following report.
The above referenced project has been analyzed per your instructions. The analyses were performed in
accordance with the applicable analytical method. Where the laboratory was not responsible for the sampling
stage (refer to the chain of custody) results apply to the sample as received.
The analytical data has been validated using standard quality control measures performed as required by the
analytical method. Quality Assurance, method validations, instrumentation maintenance and calibration for all
parameters (NELAP and non-NELAP) were performed in accordance with guidelines established by the USEPA
(including 40 CFR 136 Method Update Rule May 2021) and NELAC unless otherwise indicated. Any parameter
for which the laboratory is not officially NELAP accredited is indicated by a'—' symbol. These are not included in
the scope because NELAP accreditation is either not available or has not been applied for. Additional
certifications may be held/are available for parameters, where NELAP accreditation is not required or applicable.
A full list of certifications is available upon request.
Certain parameters (chlorine, pH, dissolved oxygen, sulfite...) are required to be analyzed within 15 minutes of
sampling. Usually, but not always, any field parameter analyzed at the laboratory is outside of this holding time.
Refer to sample analysis time for confirmation of holding time compliance.
The results are shown on the attached Report of Analysis(s). Results for solid matrices are reported on an as -
received basis unless otherwise indicated. This report shall not be reproduced except in full and relates only to
the samples included in this report.
Please do not hesitate to contact me or client services if you have any questions or need additional information.
Sincerely,
4rjo P. A~
Randy Thomas
Project Manager
Laboratory's liability in any claim relating to analyses performed shall be limited to, at laboratory's option, repeating the
analysis in question at laboratory's expense, or the refund of the charges paid for performance of said analysis.
Page 1 of 8

Waypoint . N
ANALYTICAL
2790 Whitten Road, Memphis, TN 38133
Main 901.213.2400 0 Fax [phone]
www.waypointanalytical.com
Certification Summary
Laboratory ID: WP MTN: Waypoint Analytical, LLC., Memphis, TN
State
Program
Lab ID
Expiration Date
Alabama
State Program
40750
02/28/2023
Arkansas
State Program
88-0650
02/07/2023
California
State Program
2904
06/30/2023
Florida
State Program - NELAP
E871157
06/30/2023
Georgia
State Program
C044
02/18/2023
Georgia
State Program
04015
06/30/2023
Illinois
State Program - NELAP
200078
10/10/2022
Kentucky
State Program
80215
06/30/2022
Kentucky
State Program
KY90047
12/31/2022
Louisiana
State Program - NELAP
LA037
12/31/2022
Louisiana
State Program - NELAP
04015
06/30/2023
Mississippi
State Program
MS
02/11/2023
North Carolina
State Program
415
12/31/2022
Pennsylvania
State Program - NELAP
68-03195
05/31/2023
South Carolina
State Program
84002
06/30/2022
Tennessee
State Program
02027
02/11/2023
Texas
State Program - NELAP
T104704180
09/30/2022
Virginia
State Program
00106
06/30/2023
Virginia
State Program - NELAP
460181
09/14/2022
Page 1 of 1 00001 /22-195-0047
Page 2 of 8

ry
� ,f
Waypoint 2790 Whitten Road, Memphis, TN 38133
Main 901.213.2400 0 Fax [phone]
ANALYTICAL www.waypointanalytical.com
Sample Summary Table
Report Number: 22-195-0047
Client Project Description: Von Dizehle
Cordova, NC
Project #2014-110
Lab No Client Sample ID
99086 VD
Matrix Date Collected Date Received
Solids 07/13/202213:00 07/14/2022
Page 3 of 8

Wa y p dio n t CR
ANALYTICAL
2790 Whitten Road, Memphis, TN 38133
Main 901.213.2400 ° Fax [phone]
www.waypointanalytical.com
Client: Branch Residuals and Soils LLC CASE NARRATIVE
Project: Von Dizehle
Lab Report Number: 22-195-0047
Date: 7/25/2022
Metals Analysis Method 6010D
Sample 86731 (SB27-2-4)
Analyte: Aluminum
QC Batch No: 1-628020/1-627265
The matrix spike and/or the matrix spike duplicate was outside quality control acceptance ranges. A dilution test
was performed and passed quality control acceptance ranges. No matrix interference is suspected.
Sample 86731 (SB27-2-4)
Analyte: Arsenic
QC Batch No: 1-627787/1-627265
The matrix spike and/or the matrix spike duplicate was outside quality control acceptance ranges. A post
digestion spike was performed and passed quality control acceptance ranges. No matrix interference is
suspected.
Sample 86731 (SB27-2-4)
Analyte: Iron
QC Batch No: 1-627787/1-627265
The matrix spike and/or the matrix spike duplicate was outside quality control acceptance ranges. A dilution test
was performed and passed quality control acceptance ranges. No matrix interference is suspected.
Sample 86731 (SB27-2-4)
Analyte: Potassium
QC Batch No: 1-627787/1-627265
The matrix spike and/or the matrix spike duplicate was outside quality control acceptance ranges. A dilution test
was performed and passed quality control acceptance ranges. No matrix interference is suspected.
Page 4 of 8

0 Waypoint. 2790 Whitten Road, Memphis, TN 38133
Main 901.213.2400 0 Fax [phone]
ANALYTICAL www.waypointanalytical.com
22972
Branch Residuals and Soils LLC Project Von Dizehle
Mr. Bob Branch Report Date : 07/26/2022
1735 Heckle Blvd Information : Cordova, NC Received : 07/14/2022
Suite 103-291 Project #2014-110
Rock Hill , SC 29732
Report Number: 22-195-0047 REPORTOFANALYSIS
Lab No : 99086 Matrix: Solids
Sample ID: VD Sampled: 7/13/2022 13:00
Test Results Units MQL DF Date / Time By Analytical
Analyzed Method
Neutralizing Value (%CCE)
28.1
%
0.1
1
07/20/22 16:34
DXT
AOAC 955.01
Moisture
67.9
%
0.010
1
07/20/2216:09
FMM
254OG-2011
Ammonia Nitrogen
330
mg/Kg - dry
312
1
07/25/22 12:30
JPJ
4500NH3C-2011
Nitrate (NC3-N)
<3.12
mg/Kg - dry
3.12
1
07/15/22 19:40
JCA
9056A
Nitrite (NO2-N)
<3.12
mg/Kg - dry
3.12
1
07/15/22 19:40
JCA
9056A
Nitrate+Nitrite-N
<3.12
mg/Kg - dry
3.12
1
07/15/22 19:40
9056A
pH
7.8
s.u.
1
07/21/2216:06
DRS
9045D
Total Solids
32.1
%
0.010
1
07/20/22 16:09
FMM
2540G-2011
Total Kjeldahl Nitrogen
2830
mg/Kg - dry
458
1
07/19/22 12:36
CLP
4500NORGD-2011
Phosphorus
127
mg/Kg - dry
15.6
1
07/20/22 22:30
EAL
6010D
Aluminum
1680
mg/Kg - dry
15.6
1
07/20/22 22:30
EAL
6010D
Arsenic
<1.56
mg/Kg - dry
1.56
1
07/20/22 22:30
EAL
6010D
Cadmium
<0.312
mg/Kg - dry
0.312
1
07/20/22 22:30
EAL
6010D
Calcium
110000
mg/Kg - dry
779
5
07/21/22 13:21
EAL
6010D
Copper
27.0
mg/Kg - dry
1.56
1
07/20/22 22:30
EAL
6010D
Iron
1140
mg/Kg - dry
31.2
1
07/20/22 22:30
EAL
6010D
Lead
2.08
mg/Kg - dry
0.934
1
07/20/22 22:30
EAL
6010D
Magnesium
1440
mg/Kg - dry
15.6
1
07/20/22 22:30
EAL
6010D
Mercury
<0.452
mg/Kg - dry
0.452
1
07/21/22 16:32
JTR
7471A
Molybdenum
3.64
mg/Kg - dry
0.778
1
07/20/22 22:30
EAL
6010D
Nickel
2.08
mg/Kg - dry
0.778
1
07/20/22 22:30
EAL
6010D
Potassium
66.7
mg/Kg - dry
31.2
1
07/20/22 22:30
EAL
6010D
Selenium
<1.56
mg/Kg - dry
1.56
1
07/20/22 22:30
EAL
6010D
Qualifiers/ DF
Dilution Factor
MQL
Method Quantitation Limit
Definitions
Page 5 of 8

0 Waypoint. 2790 Whitten Road, Memphis, TN 38133
Main 901.213.2400 0 Fax [phone]
ANALYTICAL www.waypointanalytical.com
22972
Branch Residuals and Soils LLC Project Von Dizehle
Mr. Bob Branch Report Date : 07/26/2022
1735 Heckle Blvd Information : Cordova, NC Received : 07/14/2022
Suite 103-291 Project #2014-110
Rock Hill , SC 29732
Report Number: 22-195-0047
REPORT OPANALYSIS
Lab No : 99086
Matrix: Solids
Sample ID : VD
Sampled: 7/13/2022 13:00
Test
Results Units MQL
DF Date / Time By Analytical
Analyzed Method
Sodium
595 mg/Kg - dry 77.9
1 07/20/22 22:30 EAL 6010D
Zinc
93.8 mg/Kg - dry 3.89
1 07/20/22 22:30 FAL 6010D
Qualifiers/ DF Dilution Factor
Definitions
MQL Method Quantitation Limit
Page 6 of 8

r'�W
Waypoint 2790 Whitten Road, Memphis, TN 38133
Main 901.213.2400 ° Fax [phone]
ANALYTICAL www.waypointanalytical.com
Shipment Receipt Form
Customer Number: 22972
Customer Name: Branch Residuals and Soils LLC
Report Number: 22-195-0047
Shipping Method
0 Fed Ex 0 US Postal 0 Lab
UPS - 0 Client 0 Courier
Other:
Thermometer ID:
r102�
Shipping container/cooler uncompromised?
0 Yes
No
Number of coolers/boxes received
1
Custody seals intact on shipping container/cooler?
0 Yes
0 No
0 Not Present
Custody seals intact on sample bottles?
0 Yes
0 No
0 Not Present
Chain of Custody (COC) present?
# Yes
0 No
COC agrees with sample label(s)?
(# Yes
0 No
COC properly completed
(# Yes
0 No
Samples in proper containers?
# Yes
0 No
Sample containers intact?
(# Yes
0 No
Sufficient sample volume for indicated test(s)?
Yes
0 No
All samples received within holding time?
Yes
0 No
Cooler temperature in compliance?
Yes
0 No
Cooler/Samples arrived at the laboratory on ice.
Samples were considered acceptable as cooling
process had begun.
Yes
0 No
Water - Sample containers properly preserved
0 Yes
0 No
N/A
Water - VOA vials free of headspace
0 Yes
0 No
N/A
Trip Blanks received with VOAs
0 Yes
0 No
N/A
Soil VOA method 5035 — compliance criteria met
0 Yes
0 No
# N/A
High concentration container (48 hr) [_ Low concentration EnCore samplers (48 hr)
j High concentration pre -weighed (methanol -14 d) F_ Low conc pre -weighed vials (Sod Bis -14 d)
Special precautions or instructions included?
Comments:
0 Yes (# No
Signature: IMakayla Weaver Date & Time: 7/14/2022 11:18:53
Page 7 of 8

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Page 8 or 8

inc. BIOLOGICAL CONSULTING SERVICES
OF NORTH FLORIDA, INC.
July 19, 2022
Robert Branch
Branch Residuals and Soils
1735 Heckle Blvd. Suite 103-291
Rockhill SC 29732
336-312-9007
[e-mail]
Client ID: VD 1, VD 2, VD 3, VD 4, VD 5, VD 6, VD 7
BCS ID: 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
Dear Robert Branch,
We have completed the analysis of the submitted samples as outlined below.
Project Name: Von Drehle Cordova NC
Analysis Method
Salmonella EPA 1682; BCS SOP M-4 (ISO17025 and TNI Accredited)
Following, you will find our report on the results of the analysis conducted on the referenced samples.
Should you have any questions, please do not hesitate to contact me.
Sincerely,
Bonnie Mull, MPH
Laboratory Operations Manager
Page 1 of 8
Final Report BCS ID 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
BCS LABORATORIES, INC. - GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAx. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
IGMEAAAAB

Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD 1 Sample Date/Time: July 13, 2022 12:44
BCS Sample ID: 2207109 Sample Description: Biosolid
Date Received: July 14, 2022 9:52 Amount Submitted:100 mL Bottle % Solids: 33.0
Amount Analyzed: 29.98 g Receipt Temperature: 3.0 deg C Preserved: Yes
Analysis Start: July 14, 2022 10:20 Analysis Stop Date: July 19, 2022 10:40
Analyst: Erika DiPasquale, B.S. Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.8 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD 2
BCS Sample ID: 2207110
Sample Date/Time: July 13, 2022 12:46
Sample Description: Biosolid
Date Received: July 14, 2022 9:52 Amount Submitted:100 mL Bottle % Solids: 38.0
Amount Analyzed: 30.03 g Receipt Temperature: 3.0 deg C Preserved: Yes
Analysis Start: July 14, 2022 10:20 Analysis Stop Date: July 19, 2022 10:40
Analyst: Erika DiPasquale, B.S. Qualifier: U
Primary Value: 150.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.7 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Page 2 of 8
Final Report BCS ID 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
BCS LABORATORIES, INC. - GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAx. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO17025:2017 L2422, PADEP: 6&03950, AZDHS:AZO820, EPA FLO1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
r.rn

Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD 3
Sample Date/Time: July 13, 2022 12:48
BCS Sample ID: 2207111 Sample Description: Biosolid
Date Received: July 14, 2022 9:52 Amount Submitted:100 mL Bottle % Solids: 28.7
Amount Analyzed: 30.10 g Receipt Temperature: 3.0 deg C Preserved: Yes
Analysis Start: July 14, 2022 10:20 Analysis Stop Date: July 19, 2022 10:40
Analyst: Erika DiPasquale, B.S. Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.9 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD 4
Sample Date/Time: July 13, 2022 12:51
BCS Sample ID: 2207112 Sample Description: Biosolid
Date Received: July 14, 2022 9:52 Amount Submitted:100 mL Bottle % Solids: 31.4
Amount Analyzed: 30.00 g Receipt Temperature: 3.0 deg C Preserved: Yes
Analysis Start: July 14, 2022 10:20 Analysis Stop Date: July 19, 2022 10:40
Analyst: Erika DiPasquale, B.S. Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.8 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Page 3 of 8
Final Report BCS ID 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
BCS LABORATORIES, INC. — GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAx. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 6&03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
Mac- AAMB

Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD 5 Sample Date/Time: July 13, 2022 12:53
BCS Sample ID: 2207113 Sample Description: Biosolid
Date Received: July 14, 2022 9:52 Amount Submitted:100 mL Bottle % Solids: 29.1
Amount Analyzed: 30.00 g Receipt Temperature: 3.0 deg C Preserved: Yes
Analysis Start: July 14, 2022 10:20 Analysis Stop Date: July 19, 2022 10:40
Analyst: Erika DiPasquale, B.S. Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: 50.9 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD 6 Sample Date/Time: July 13, 2022 12:55
BCS Sample ID: 2207114 Sample Description: Biosolid
Date Received: July 14, 2022 9:52 Amount Submitted:100 mL Bottle % Solids: 27.1
Amount Analyzed: 30.00 g Receipt Temperature: 3.0 deg C Preserved: Yes
Analysis Start: July 14, 2022 10:20 Analysis Stop Date: July 19, 2022 10:40
Analyst: Erika DiPasquale, B.S. Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: _<1.0 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Page 4 of 8
Final Report BCS ID 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
BCS LABORATORIES, INC. - GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAx. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:201 7 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHJUT THE WRITTEN CONSENT OF BCS LABORATORIES
J18G:h7RAA&B
"oa

Client: Branch Residuals and Soils
Analysis: Salmonella
Project Name: Von Drehle Cordova NC
Client Sample ID: VD 7 Sample Date/Time: July 13, 2022 12:57
BCS Sample ID: 2207115 Sample Description: Biosolid
Date Received: July 14, 2022 9:52 Amount Submitted:100 mL Bottle % Solids: 29.1
Amount Analyzed: 30.01 g Receipt Temperature: 3.0 deg C Preserved: Yes
Analysis Start: July 14, 2022 10:20 Analysis Stop Date: July 19, 2022 10:40
Analyst: Erika DiPasquale, B.S. Qualifier: U
Primary Value: :50.07 Salmonella MPN/mL sample analyzed
Secondary Value: :50.9 Salmonella MPN/4 dry grams
Analysis Notes: Undetected: Analyte was not detected in the sample analyzed; Value represents the method's
detection limit for the amount of sample analyzed as per the method's standard reporting units
Page 5 of 8
Final Report BCS ID 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
BCS LABORATORIES, INC. — GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAx. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 68-03950, AZDHS:AZ0820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
ac-luA&B

Client: Branch Residuals and Soils
Project: Von Drehle Cordova NC
Method Detection Limit: 1 microorganism/ unit weight or volume analyzed
Practical Qua ntitation Limit: 1 microorganism/ unit weight or volume analyzed
Report Notes: Custody Seal Condition: Not Present
Sample(s) were received well preserved and in excellent condition. Sample(s) were analyzed following receipt
as per the described analytical methodology. End of report notes.
Page 6 of 8
Final Report BCS ID 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
BCS LABORATORIES, INC. — GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]C
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO 17025:2017 L2422, PADEP: 6&03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
Aac r AA19M

I certify that I have examined and I am familiar with the information submitted herein. The results pertain only
to sample(s) identified and their condition at time of receipt. Based on my inquiry of the individuals
responsible for the analysis, I believe the data to be true, accurate, and complete. Sampling and field data was
obtained from submitted documents. The analysis was authorized and commissioned by the client. The
resulting data are representative of the analysis conducted on the material/samples/articles provided by the
client (or client's representative) and it's/their condition at the time of analysis. The sample(s) were analyzed
in accordance with the appropriate method , however due to the inherent limitations of the methods,
microorganisms may avoid detection. BCS Laboratories offers no express or implied warranties concerning
the quality, safety, and/or purity of any sample, batch, source, or the process they are derived from. Quality
assurance controls were performed as outlined in the method and as per Good Laboratory Practices. The
analysis and results presented in this report meet the requirements of the standards of The NELAC Institute
(TNI), ISO 17025, and the FL DOH Environmental Laboratory Certification Program, as applicable unless
otherwise noted.
Signature of Laboratory Director/Authorized Rep.
Date: July 19, 2022
Page 7 of 8
Final Report BCS ID 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
BCS LABORATORIES, INC. — GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAX. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO17025:2017 L2422, PADEP: 6&03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES
A I�Y� B qpww
;�

DATA QUALIFIER CODES
SYMBOL MEANING
B Results based on counts outside the acceptable range.
X Sample received without prior notification ordelayed delivery. Analysis performed outside of
associated method required QC data set (1 QC data set per 20 samples per 168 hours).
I Value is between the laboratory method detection limit &the practical quantitation limit.
J1 The sample matrix interfered with the abilityto make any accurate determination.
J2 No Quality Control criteria exist forthe component.
J3 The data are questionable because of improper laboratory orfield protocols.
L Off scale high. Actual value is known to be greaterthan value given.
N Presumptive evidence forthe presence of material. There is an indication that the analyte is
present, but the confirmation requirement was not met.
O Sampled, but analysis not performed.
Q Sample held beyond the accepted holding time.
U Indicates that the compound was analyzed for but not detected. The specified component was
not detected. The reported value is the method detection limit.
V Analyte was detected in both sample and the method blank. Data may not be accurate.
Y Laboratory analysis was from an improperly preserved -sample; the data may not be accurate
Z Too many colonies present (TNTC); the numeric value given represents the upper end of the
value that can be determined based on the volume.
7 Data are rejected and should not be used. QC data for analyte did not meet acceptance criteria.
Presence or absence of analyte could not be confirmed.
** Not reported due to interference.
A Sampling container supplied by client. Sterility can not be confirmed by BCS.
# BCS Lab specific qualifier. See laboratory analysis notes.
Page 8 of 8
Final Report BCS ID 2207109, 2207110, 2207111, 2207112, 2207113, 2207114, 2207115
BCS LABORATORIES, INC. — GAINESVILLE
4609 NW 6TH STREET, STE. A, GAINESVILLE, FLORIDA 32609
TEL. [phone], FAx. [phone]
WWW.MICROBIOSERVICES.COM
FLDOH E82924, ISO17025:2017 L2422, PADEP: 68-03950, AZDHS:AZO820, EPA FLO 1 147
THIS REPORT SHALL NOT BE REPRODUCED, EXCEPT IN FULL, WITHOUT THE WRITTEN CONSENT OF BCS LABORATORIES

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Environmental. Chemists, Inc.
envirochem 6602 Windmill Way, Wilmington, NC 28405 - 910.392.0223 Lab - 910.392.4424 Fax
710 Bowsertown Road, Manteo, NC 27954 - 252.473.5702 Lab/Fax
sM 255-A Wilmington Highway, Jacksonville, NC 28540 - 910.347.5843 Lab/Fax
ANALYTICAL & CONSULTING CHEMISTS info`t environmentalcllemists.com
Branch Residuals/Bob Branch
1735 Heckle Blvd Suite 103-291
Rock Hill SC 29732
Attention: Bob Branch
Date of Report: Feb 09, 2022
Customer PO #:
Customer ID: 15060009
Report #: 2022-00648
Project ID: Sludge -von Drehle
Lab ID Sample ID:
Collect Date/Time Matrix Sampled by
22-01588 Site: Sludge
1/11/2022
11:30 AM Solid/Sludge Bob Branch
Test
Method
Results Date Analyzed
Chlordane (TCLP)
SW-846 8081 8
<0.02 mg/L
01/26/2022
Endrin (TCLP)
SW-846 8081 B
<0.0005 mg/L
01/26/2022
Heptachlor (TCLP)
SW-646 8051 B
<0.0005 mg/L
01/26/2022
Heptachlor epoxide (TCLP)
SW-846 8081 8
<0.0005 mg/L
01/26/2022
Lindane (TCLP)
SW446 8081 B
<0.0005 mg/L
01/26/2022
Methoxychlor (TCLP)
SW-846 8081 B
<0.0005 mg/L
01/26/2022
Toxaphene (TCLP)
SW-846 8081 B
<0.05 mg/L
01/26/2022
2,4,5-TP (TCLP)
SW-8468151 A
<0.003mg/L
01/27/2022
2,4-D (TCLP)
SW-846 8151 A
<0.003 mg/L
01/27/2022
1,4-Dichlorobenzene (TCLP)
SW-846 8270 E
<0.050 mg/L
01/28/2022
2,4,5-Trichlorophenol (TCLP)
5W-846 8270 E
<0.050 mg/L
01/28/2022
2,4,6-Trichlorophenol(TCLP)
SW8468270E
<0.050mg/L
01/28/2022
2,4-Dinitrotoluene (TCLP)
SW-846 8270 E
<0.050 mg/L
01/28/2022
Cresol (TCLP)
SW-8468270E
<0.050mg/L
01/28/2022
Hexachlorc-1,3-butadiene (TCLP)
SW-848 8270 E
<0.050 mg/L
01/28/2022
Hexachlorobenzene (TCLP)
SW-846 8270 E
<0.050 mg/L
01/28/2022
Hexachloroethane(TCLP)
SW-8468270E
<0.050mg/L
01/28/2022
m + p-Cresol (TCLP)
SW-846 8270 E
<0.050 mg/L
01128/2022
Nitrobenzene (TCLP)
SW-8468270E
<0.050mg/L
01/28/2022
o-Cresol (TCLP)
SW-846 8270 E
<0.050 mg/L
01 /28/2022
Pentachlorophenol(TCLP)
SW-8466270E
<0.050mg/L
01/28/2022
Pyridine (TCLP)
SW-846 8270 E
<0.050 mg/L
01/28/2022
1,1-Dichloroethylene (TCLP)
SW-84B Method 8260D
<0.01 mg/L
01/19/2022
1,2-Dichloroethane (TCLP)
SW-846 Method8250D
<0.01 mg/L
01/19/2022
Benzene (TCLP)
SW-845Method 8260D
<0.01 mg/L
01/19/2022
Carbon Tetrachloride (TCLP)
SW-846 Method8260D
<0.01 mg/L
01/19/2022
Report # 2022-00648 Page 1 of 2

envirochem
M
ANALYTICAL 8 CONSULTING CHEMISTS
Environmental Chemists, Inc.
6602 Windmill Way, Wilmington, NC 28405 - 910.392.0223 Lab - 910.392.4424 Fax
710 Bowsertown Road, Manteo, NC 27954 - 252.473.5702 Lab/Fax
255-A Wilmington Highway, Jacksonville, NC 28540 - 910.347.58-13 Lab/Fax
info cc environmentalchemists.com
Branch Residuals/Bob Branch
Date of Report: Feb 09, 2022
1735 Heckle Blvd Suite 103-291
Customer PO #:
Rock Hill SC 29732
Customer ID: 15060009
Attention: Bob Branch
Report #: 2022-00648
Project ID: Sludge -von Drehle
Chlorobenzene (TCLP)
SW-846 Method 8260D
<0.01 mg/L
01/19/2022
Chloroform (TCLP)
SW-846 Method 8260D
<0.01 mg/L
01/19/2022
Methyl ethyl ketone (TCLP)
SW-846 Method 0250D
<0.05 mg/L
01/19/2022
Tetrachloroethylene (TCLP)
SW-B46 Method 8280D
<0.01 mg/L
01/19/2022
Trichloroethylene (TCLP)
SW-846 Method 8250D
<0.01 mg/L
01/19/2022
Vinyl Chloride (TCLP)
SW-846 Method 8260D
<0.01 mg/L
01/19/2022
RCI
Ignitability
EPA 1030
<0.8 mm/sec
01/17/2022
Cyanide
SM 4500 CN D
1.36 mg/kg
01/20/2022
Sulfide
SM 4500 S D
0.56 mg/kg
01121 /2022
pH
SW 846 Method 9045D
7,87 units
01/24/2022
Result estimated. Analyzed out of 15 minutes hold time.
TCLP Metals
Arsenic
EPA 200.7, Rev. 4.4, 1994
<1.Omg/L
01/26/2022
Barium
EPA 200.7, Rev. 4.4, 1994
<1.0 mg/L
01/26/2022
Cadmium
EPA 200.7. Rev. 4.4, 1994
<1.Omg/L
01/26/2022
Chromium
EPA 2007, Rev. 4.4, 1994
<1.0 mg/L
01/26/2022
Lead
EPA 200.7, Rev. 4.4. 1994
<1.0 mg/L
01/26/2022
Selenium
EPA 200.7,Rev. 4.4,1994
<1.Omg/L
01/26/2022
Silver
EPA 200.7, Rev. 4.4, 1094
<1.0 mg/L
01/26/2022
Mercury
EPA 245.1
<0.0002 mg/L
01/28/2022
Comment:
Reviewed by:
Report #:: 2022-00648 Page 2 of 2

Environmental Chemist, Inc., Wilmington, NC Lab #94
6502 Windmill Way
Wilmington, NC 28405
910.392.0223
,,
Sample Receipt Checklist
Client:ELUISA 4 S I DU rI.S Date: 1 Report Number..Qo, — bO �o q s
Receipt of sample:
ECHEM Pickup Cq Client Delivery O
UPS ❑ FedEx ❑ Other ❑
❑ YES
113
NO
Off N/A Il. Were custody seals present on the cooler?
❑ YES
10
NO
W N/A 12. If custody seals were present, were they intact/unbroken?
Original temperature upon receipt °C Corrected temperature upon receipt eC
How temperature taken:
❑ Temperature Blank V Against Bottles
IR Gun ID: Thomas Traceable S/N 192511657 IR Gun Correction Factor'C: 0.0
D YES
❑
NO
3. If temperature of cooler exceeded 6°C, was Project Mgr./QA notified?
Dr YES
❑
NO
4. Were proper custody procedures (relinquished/received) followed?
YES
❑
NO
5. Were sample ID's listed on the COC?
JV YES
❑
NO
6. Were samples ID's listed on sample containers?
$1 YES
❑
NO
7. Were collection date and time listed on the COC?
YES
❑
NO
8. Were tests to be performed listed on the COC?
YES
❑
NO
9. Did samples arrive in proper containers for each test?
YES
❑
NO
10. Did samples arrive in good condition for each test?
YES
❑
NO
11. Was adequate sample volume available?'
YES
❑
NO
12. Were samples received within proper holding time for requested tests?
❑ YES
Ill
NO
13. Were acid preserved samples received at a pH of <2?
❑ YES
❑
NO
14. Were cyanide samples received at a pH >12?
❑ YES
I ❑
NO
15. Were sulfide samples received at a pH >9?
❑ YES
O
NO
16. Were NH3/TKN/Phenol received at a chlorine residual of <0.5 m/L? **
❑ YES
❑
NO 117.
Were Sulfide/Cyanide received at a chlorine residual of <0.5 m/L?
❑ YES
❑
NO 118.
Were orthophosphate samples filtered in the field within 15 minutes?
* TOC/volatiles are pH checked at time of analysis and recorded on the benchsheet.
** Bacteria samples are checked for Chlorine at time of analysis and recorded on the benchsheet.
Sample Preservation: (Must be completed for any sample(s) incorrectly preserved or with headspace)
Sample(s) were received incorrectly preserved and were adjusted accordingly
by adding (circle one): H2SO4 HNO3 HCI NaOH
Time of preservation: If more than one preservative is needed, notate in comments below
Note: Notify customer service immediately for incorrectly preserved samples. Obtain a new sample or
notify the state lab if directed to analyzed by the customer. Who was notified, date and time:
Volatiles Sample(s) were received with headspace
COMMENTS:
DOC. QA.002 Rev 1

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SECTION III
MANAGEMENT PLAN

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

Overview of Process and Residual Solids Handling

Overview of Process and Residual Solids Handling
von Drehle Corporation Cordova facility is located at 126 First Street in Richmond County, North
Carolina. This facility produces, approximately 28,500 dry tons of Fiber Clay annually through
separation and fractionation processes from their feed stock recycled paper. The processes remove all
plastics which are sent to the landfill. The majority of the recycled paper is repulped for von Drehle's
paper making process. The clay and short fibers that are separated out in the various screening and
fractionation processes are run through a belt press and Fiber Clay is made. Fiber Clay is a product
of non -biological processes and has no domestic contribution.
Fiber Clay can be placed in sealed trucks have three potential types of destinations:
• To a landfill for use as daily cover,
• To an offsite blending operation for the inclusion in composts, soil amendments, and potting
soils or
• As a replacement for commercial lime (or most limiting application factor) on nonspecific
agricultural receiver sites.

Distribution Methods for Reuse

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

Transportation and Logistics

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

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

Monitoring and Recordkeeping

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

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

Leachate Collection

Leachate Collection
No provision is made for leachate collection since the residuals are not designed to undergo any
mixing with other productions on -site. The storage pad at the facility is sloped to the back to the
drainage feature. Below the drainage feature is a screen to capture any solids that are washed to the
drain.
Once these residuals have been transported to the potential application sites or for other uses, the fiber
clay can be stockpiled in a covered facility or covered on the ground similar to other Class A products.
Once covered this material will remain covered until the time of application.
No provision is made for leachate collection since the residuals are not designed to undergo any
mixing with other productions on -site. The storage pad at the facility is sloped to the back to the
drainage feature. Below the drainage feature is a screen to capture any solids that are washed to the
drain.
It will be the responsibility of the distribution sites that receive these residuals. These residuals that
are to be land applied, either to permitted or unspecified sites, can be stockpiled in a covered facility
similar to what is provided with chicken litter and not be removed until the time of application.
Below are Solvita tests for von Drehle Fiber Clay for ammonia and carbon dioxide. These tests have
been used in the past for stockpile use and as a measure of product stability. These tests were
performed over a 4-hour period on November 1, 2022.
Solvita Test for CO2 evolution for Fiber Clay — low CO2 (values of 7/8 for all six jars).
Solvita Test for NH4 evolution for Fiber Clay — low NH4 (values of 5, 5, 5, 5, 5, and 5)
Based on Solvita's brochure, Fiber Clay has a Maturity Index of 5, one below the maturity level of 6
that is considered "Mature Compost". Fiber Clay has no ammonia and at a level that is between
Mature compost and compost that has a low carbon to nitrogen ratio. These values were rechecked
after 2 additional days incubation. At that time CO2 evolution for Fiber Clay —after 2 days had values
of 2, 2 2, 3, 3, and 2. The ammonia values of before remained unchanged. In light of the values after

2 days, the Fiber Clay is a characterized by the Solvita tests as a very active compost with a maturity
level of 3. Both of these levels of maturity indicate that high respiration rates will continue to occur
and significant turning made be necessary as respiration occurs. Onsite stockpiling is recommended
to remain at no more than 60 days for these non -biological residuals.

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

The von Drehle Corporation Cordova
Fiber Clay Label
Produced By Preparer
von Drehle Corporation Mitchell Luckie [phone]
Wastewater Treatment Plant 126 First Street
Cordova, North Carolina 28330 Cordova, North Carolina 28330
For information on this product contact von Drehle Corporation
Cordova, NC facility at [phone]
Fiber Clay from the von Drehle Corporation Cordova NC are the clay and short fibers excluded from the repulping
process of recycled paper production. The generated residuals have no domestic source percentage and are an exceptional
quality residual solid that is permitted for bulk distribution.
Approved used for von Drehle Fiber Clay:
• Amendment for creation of soil mixture to be further distributed to the public,
• Amendment for compost to be further distributed to the public,
• Use as a daily landfill cover,
• Application to potential receiver sites for use as a soil amendment or replacement for agricultural lime.
Provisions for application are listed below.
Provisions for Application
Application of von Drehle Fiber Clay are prohibited except in accordance with the provisions specified in the Application
Information Sheet. Application must conform to standards identified in Permit No. WQ0039924 and include but are not
limited to:
Maximum slope for the land application of these residuals is 10 % for surface applications and 18% for subsurface
applications
Distance
Buffer Items (feet)
Public or private water supply source, waters classified as SA or SB, and any Class 1 or Class 11 impounded
reservoir used as a source of drinking water for both surface and subsurface methods 100
Surface waters (intermittent streams, perennial streams, perennial surface water bodies and wetlands) 100
Surface water diversions (ephemeral streams, ditches, groundwater lowering ditches, or waterways) 0
Application can not occur to:
• adversely affect a threatened or endangered species or it's critical habitat,
• within the 100-year flood plain unless solids are incorporated within a 24-hour period,
• cause prolonged nuisance conditions,
• create conditions where runoff will occur,
• within the 100-year flood plain unless solids are incorporated within a 24-hour period, or
• during a measurable rainfall event or 24-hours following a 0.5 inch cumulative rainfall event (over 24-hours).

Application Information Sheet von Drehle Fiber Clay
1. von Drehle Fiber Clay shall not be applied to flooded, frozen, or snow-covered areas.
2. Application and storage of von Drehle Fiber Clay must be conducted in such a way as to prevent runoff or
erosion from the application or storage site to any surface water.
3. Applications of von Drehle Fiber Clay must not be applied so thick as to cover existing vegetation. Application
that is made to sites with less than 50 percent ground cover should be incorporated unless incorporation will result
in violation of other federal program.
4. Applications of von Drehle Fiber Clay shall be applied uniformly at a rate equal to amount that can be
adequately assimilated into the soil through incorporation, will not smother any current living crop on the surface
of the soil if material will not be incorporated, or the agronomic rate of the crop as specified by the permit and
the most recent residual analysis, or the lime requirement of the soil and most recent residuals analysis; whichever
is most limiting.
5. An acceptable soil pH (greater than 6.0) see appropriate state extension service for crop specific optimal soil pH
on individual receiver sites. The soil pH should be verified annually with a soil sample with recommendations.
These recommendations should be followed as they relate to optimal crop growth, monitoring and adjustment of
the exchangeable sodium percentage, potential for calcium and magnesium deficiency, as well as other relevant
agronomic information. Additional fertilizer, lime, or other nutrients may need to be added as directed by the soil
sample results.
6. Applications and loading rates of von Drehle Fiber Clay shall be applied at rates that comply with realistic yield
expectations based on the soil series and crops found at: http://nutrients.soil.nesu.edu/yields:'
von Drehle Corporation Cordova Fiber Clay
Approximately Contain:
32.10
Percent Solids
2.34
Plant Available Nitrogen surface land applied) pounds per dry ton
2.67
Plant Available Nitrogen (incorporated or injected pounds per dry ton
0..6
Phosphate 205pounds per dry ton
0.16
Potash K2Opounds per dry ton
180
Lining agent pounds per dry ton
7.8
pH of Fiber Clay
See von Drehle Corporation Cordova WWTP for a copy of the most recent residuals analysis
and loading rates.

SECTION V
VON DREHLE FIBER CLAY RECEIPT FORM

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

SECTION VI
SPILL CONTROL PLAN

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

SECTION VII
APPLICATION RATES

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

below outline the lime -added values from the following applications. At this point application rates
should be limited to lime needs of the soil.
Wet Tons/
Acre
Dry Tons/
Acre
PAN
#/Acre
Lime
Tons/Acre
1
0.32
0.75
0.09
2
0.64
1.50
0.18
3
0.96
2.25
0.27
4
1.28
3.00
0.36
5
1.61
3.75
0.45
6
1.93
4.50
0.54
7
2.25
5.25
0.63
8
2.57
6.00
0.72
9
2.89
6.75
0.81
10
3.21
7.50
0.90
11
3.53
8.25
0.99
12
3.85
9.00
1.08
13
4.17
9.75
1.17
14
4.49
10.50
1.26
15
4.82
11.25
1.35
16
5.14
12.00
1.44
17
5.46
12.75
1.53
18
5.78
13.50
1.62
19
6.10
14.25
1.71
20
6.42
15.00
1.80