WQ0018347_Permit_20100108

Iii
North Carolina Department of Environment and Natural Resources
Beverly waves Perdue
Governor
RICHARD J. NEWMASTER - CFO
LEBANON SEABOARD CORPORATION
' 1600 CUMBERLAND STREET
LEBANON, PENNSYLVANIA 17042
Dear Mr. Newmaster:
Division of Water Quality
Coleen H. Sullins
Director
January 8, 2010
Dee Freeman
Secretary
Subject j� PermitT'o YWQ�C20i18347
a`Lebario�i`Seab-�oa'rd C`orpor_ ation
Dry Roots (3-3-3), Endo Roots (3-3-4),
M-roots (3-3-3), and 1-Step (2-2-2)
Distribution Program .
Distribution of Animal Residual Solids
Roanoke County, Virginia
In accordance with your change of, ownership request received November 9, 2009, we are
forwarding herewith Permit No. WQ0018347, dated January 8, 2010, to Lebanon Seaboard Corporation
for the continued operation of the subject animal residuals distribution program +The owner name h-
�be�en changedfrom_Nouozymes B'iologicals;_Inc �to_Lebanon_SeaboardaCo pora one'
Please note that on August 5, 2009, Session Law 2009-406, entitled "An Act to Extend Certain
Government Approvals'Affecting the Development of Real Property Within the State," was enacted by
the General Assembly and signed into law. The Act, known as the Permit Extension Act of 2009, extends
the expiration date of certain government approvals and permits. Non -discharge permit WQ0018347
issued by the Division of Water Quality falls within the scope of this Act and is therefore being extended
until September 30, 2013. Please note per your permit, a renewal application must be submitted six
months in advance of the extended expiration date.
This permit shall- be -effective- from the date of issuance until September 30, 2013, shall void
Permit No. WQ0018347 issued October 12, 2005, and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring requirements in this permit. Failure to
establish an adequate system for collecting and maintaining the required operational information will
result in future compliance problems.
This permit approves the continued operation of the subject program for the distribution of a
composted fertilizer/soil amendment product, containing poultry animal residuals, that meets exceptional
quality standards and is marketed under the product names Dry Roots (3-3-3), Endo Roots (3-3-4), M-
Roots (3-3-3), and 1-Step (2-2-2) throughout the state of North Carolina (i.e., in bulk and bags). Note that
this permit does not concurrently provide a license to distribute a fertilizer, as is required by the Fertilizer
Section of the NC Department of Agriculture and Consumer Services Plant Industry Division. More
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 One
Phone: [phone] FAX 1: 919-715.0588; FAX 2: 919-715-60481 Customer Service:1-877-623-6748 Noi t 1 Cairo ina
Internet: www.ncwaterguality.orq
An Equal Opportunity 1 Affirmative Action Employer � �"

Mr. Richard J. Newmaster
January 8, 2010
Page 2 of 2
information about applying for this license may be found at the following web address:
littT):Hwww.nca--r.sio-,,/i3lantindustrv/fei-tilizer/index.htm.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of
this permit. This request must 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, 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 matter, please contact Lori Montgomery at
[phone] or [e-mail].
Sincerely,
�Coleen H. Sullins
cc: NC Department of Agriculture and Consumer. Services, Plant Industry Division, Fertilizer Section
Asheville Regional Office, Aquifer Protection Section
'Fayetteville.Regional_Office,.Aquifer Prote6 on Sect n
Mooresville Regional Office, Aquifer Protection Section
Raleigh Regional Office, Aquifer Protection Section
Washington Regional Office, Aquifer Protection Section
Wilmington Regional Office, Aquifer Protection Section
Winston-Salem Regional Office, Aquifer Protection Section
Permit File WQ0018347
Notebook File WQ0018347

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NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF ANIMAL RESIDUAL SOLIDS
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
Lebanon Seaboard Corporation
Roanoke County, Virginia
FOR THE
continued operation of a program for the distribution of up to 700 dry tons per year of a composted
fertilizer/soil amendment product containing poultry animal residuals, marketed under the names: Dry
Roots (3-3-3), Endo Roots (3-3-4), M-Roots (3-3-3), and 1-Step (2-2-2); generated by the source-
generating facilities listed in the most recently -certified Attachment A with no discharge of wastes to
surface waters, pursuant to the change of ownership request received on November 9, 2009 and in
conformity with the project plan, specifications, and other supporting data subsequently filed and
approved by the Department of Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until September 30, 2013, shall void Permit No.
WQ0018347 issued October 14, 2005, and shall be subject to the following specified conditions and
limitations:
I. SCHEDULES
1. No later than six months prior to the expiration of this permit, the Penmittee 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.
II. PERFORMANCE STANDARDS
1. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface
waters or groundwater resulting from the operation of this animal residuals distribution program.
2. No residuals other than those generated by the residuals source -generating facilities listed in the most
recently -certified Attachment A of this permit shall be approved for distribution in accordance with
this permit.
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3. The pollutant concentrations in any residuals that are distributed site shall not exceed the following v
Ceiling and Monthly Average Concentrations (i.e., dry weight basis)
Parameter
Monthly Average
Concentration
(mg/kg)
Ceiling Concentration
(mg/kg)
Arsenic
41
75
Cadmium
39
85
Copper
1,500
4,300
Lead
300
840
Mercury
17
57
Molybdenum
n/a
75
Nickel
420
420 ,
Selenium
100
100
Zinc
2,800
7,500
4. When residuals are distributed under the conditions of this permit, one of the Class A pathogen
requirements in 40 CFR 503.32(a) shall be met. Additionally, an evaluation shall be performed that
demonstrates the product's ability to comply with this requirement. Upon request, a copy of this
evaluation, including all test results and calculations, shall be submitted.
5. No product containing animal residuals that is classified as a hazardous or toxic waste under 40 CFR
Part 261 shall be sold or given away for application to the land under the conditions of this permit.
M. OPERATION AND MAINTENANCE REQUIREMENTS
The animal residuals distribution program shall be effectively maintained and operated at all times as
a non -discharge system to prevent the discharge of any wastes resulting from the operation of this
program.
2. In the event that the animal residuals distribution program is not operated satisfactorily, including the
creation of nuisance conditions due to improper operation and maintenance, the Permittee shall
immediately cease distribution of residuals to the sites impacted. In addition, the Permittee shall
contact the Aquifer Protection Section of the appropriate Division regional office, and take any
immediate corrective actions as may be required by the Division.
These action(s) do not prevent the Division from subsequently taking actions in response to any
violations consistent with the condition of this permit, North Carolina Administrative Code rules,
regulations, and the NC General Statutes.
3. This permit shall become voidable and may be rescinded by the Division in the event of failure of the
animal residuals distribution program to adequately meet the conditions of this permit and protect the
assigned water quality standards of the surface waters and groundwater.
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4. A label shall be affixed to the bag or other container in which residuals that are sold or given away, or
r an information sheet shall be provided to the person who receives the residuals sold or given away in
other containers. The label or information sheet shall contain the following information:
a. The name and address of the person who prepared the product containing animal residuals that is
sold or given away in a bag or other container for application to the land.
b. A statement that application of the residuals to the land is prohibited except in accordance with
- the instructions on the label or information sheet.
c. A statement which identifies that this material shall be prevented from entering any public or
private water supply source (including wells) and any stream, lake, or river.
d. A statement that the application of the product containing animal residuals shall not be applied to
any land that is flooded, fiozen, or snow-covered.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue analyses)
in
deemed necessary by the Division to ensure protection of the environment shall be established, and
an acceptable sampling and reporting schedule shall be followed.
2. An analysis shall be conducted on the animal residuals product generated for distribution at the
frequency listed in the most recently certified Attachment A of this permit. The results shall be
maintained on file by the Permittee for a minimum of five years. The analysis shall include, but shall
not necessarily be limited to, the following parameters:
Aluminum
Magnesium
pH
Ammonia -Nitrogen
Mercury
Plant Available Nitrogen (by calculation)
Arsenic
Molybdenum
Selenium
Cadmium
Nickel
Sodium
Calcium
Nitrate -Nitrite Nitrogen
% Total Solids
Copper
Phosphorus
TKN
Lead
Potassium
Zinc
After the residuals generated by a particular residuals source -generating facility have been monitored
for two years at -the frequency specified in the most recently -certified Attachment A of this permit, the
Permittee may submit a request to the Division for a permit modification to reduce the frequency of
this monitoring requirement. In no case, however, shall the frequency of this monitoring be less than
once per year when the product containing animal residuals is sold or given away for application to
the land during that year.
The product containing animal residuals shall be monitored by the Permittee for compliance with
Condition II.4. at the frequency specified in the most recently certified Attachment of this permit.
The results of all analysis as well as data to verify stabilization of the product shall be maintained on
file by the Permittee for a minimum of five (5) years. The required data shall be specific to the
stabilization process utilized, and should be sufficient to clearly demonstrate compliance with the
Class A pathogen requirements in 40 CFR Part 503.32(a). In addition, the EPA certification
statement concerning compliance with -pathogen requirements shall be completed by the proper
authority (either the person who generates the product containing animal residuals or the person who
prepares the product to be sold or given away for application to the land) at the frequency specified in
the most recently certified Attachment A of this permit.
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4. Laboratory analyses of parameters as required by Conditions IV. 2. and IV.3. shall be i
performed/gathered on the product containing animal residuals as it is to be distributed.
5. Laboratory analyses of parameters as required by Conditions IV. 2. and IV.3. shall be in accordance
with 15A NCAC 02B .0505.
6. Proper records shall be maintained by the Permittee to track all distribution activities within the state
of North Carolina. These records shall include, but are not necessarily limited to, the following
information:
a. Source and amount (i.e., volume), and analysis of each product containing animal residuals.
b. Name of the initial recipient of the product containing animal residuals, the amount (i.e., volume)
distributed, and the intended use.
7. All records required as part of this permit shall be retained a minimum of five years.
Three copies of an annual report shall be submitted on or before March V. The annual report shall
meet the requirements described in the Instructions For Residuals Application Annual Reporting
Forms. The most recent instructions for reporting and annual report forms are available on the Land
Application Unit website at http://h2o.enr.state.nc.us/lau/compliance.html, or can be obtained by
contacting the Land Application Unit directly. The annual report shall be submitted to the following
address:
NCDENR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
9. Noncompliance Notification
The Permittee shall report by telephone to the Aquifer Protection Section of the nearest Division of
Water Quality Regional Office (see permit Page 8 for regional office listing and contact information)
as soon as possible, but *in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence with the distribution program which results in the land application of significant
amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to receiving waters.
c. Any time that self -monitoring information indicates that the facility has gone out of compliance
with the conditions and limitations of this permit or the parameters on which the system was
designed.
d. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate residuals treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of residuals.
Any emergency that requires immediate reporting (e.g., discharges to surface waters, imminent
failure of a storage structure, etc.) outside normal business hours must be reported to the Division's
Emergency Response personnel at telephone number [phone], [phone], or (919) 733-
3300. Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) days following fist knowledge of the occurrence. This report must outline the actions
taken or proposed to be taken to ensure that the problem does not recur.
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V. INSPECTIONS
The Pennittee or his designee shall inspect the residuals storage, transport, and application facilities
to prevent malfunctions and deterioration, operator errors, and discharges that may cause or lead to
the release of wastes to the environment, a threat to human health, or a nuisance. The Permittee shall
maintain an inspection log or summary including at least the date and time of inspection; observations
made, and any maintenance, repairs, or corrective actions taken by the Permittee. This log of
inspections shall be maintained by the Permittee for a period of five years from the date of the
inspection and shall be made available to the Division or other pennnitting authority, upon request.
2. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises, or place on or related to the land application
sites or facilities at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records that must be kept under the terms and conditions of this permit; and
may obtain samples of groundwater, surface water, or leachate.
V. GENERAL CONDITIONS
This permit shall become voidable unless the activities of the animal residuals distribution program
are carried out in accordance with the conditions of this permit, the supporting materials, and in the
manner approved by the Division.
2. This permit shall be effective only with respect to the nature and volume of residuals described in the
application and other supporting data.
3. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee
to enforcement action,by the Division in accordance with North Carolina General Statutes §143-
215.6A through § 143-215.6C.
4. The annual administering and compliance fee shall be paid by the Permittee within 30 days of being
billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate action to
revoke this permit, as specified by 15 NCAC 2T .0105 (e).
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 government agencies (local, state,
and federal) that have jurisdiction. 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 NCG010000, and any requirements pertaining to
wetlands under 15A NCAC 02B .0200 and 02H .0500.
6. This permit may be modified, revoked, and/or reissued to incorporate any conditions, limitations and
monitoring requirements the Division deems necessary in order to protect the environment and public
health adequately.
7. This pen -nit shall not be automatically transferable. In the event that there is a desire for the class A
residuals management program to change ownership or to change the name of the Permittee, a formal
permit request shall be submitted to the Division documentation from the parties involved and other
supporting materials as may be appropriate. The approval of this request shall be considered on its
merits and may or may not be approved.
WQ0018347 Version 2.1 Shell Version 090204 'Page 5 of 7

DIVISION OF WATER QUALITY REGIONAL OFFICES
Asheville Regional Office
Washington Regional Office
Raleigh Regional Office
2090 U.S. Hwy 70
943 Washington Square Mall
3800 Barrett Drive
Swannanoa, NC 28778
Washington, NC 27889
Raleigh, NC 27609
[phone]
[phone]
[phone]
Fax [phone]
Fax [phone]
Fax [phone]
Avery Macon
Beaufort Jones
Chatham Nash
Buncombe Madison
Bertie Lenoir
Durham Northampton
Burke McDowell
Camden Martin
Edgecombe Orange
Caldwell Mitchell
Chowan Pamlico
Franklin Person
Cherokee Polk
Craven Pasquotank
Granville Vance
Clay Rutherford
Currituck Perquimans
Halifax Wake
Graham Swain
Dare Pitt
Johnston Warren
Haywood Transylvania
Gates Tyrell
Lee Wilson
Henderson Yancy
Greene Washington
Jackson
Hertford Wayne
Hyde
Fayetteville Regional Office
Mooresville Regional Office
Wilmington Regional Office
Systel Building, Suite 714
610 East Center Avenue, Suite 301
127 Cardinal Drive Extension
Fayetteville, NC 28301
Mooresville, NC 28115
Wilmington, NC 28405-3845
[phone]
[phone]
[phone]
Fax [phone]
Fax [phone]
Fax [phone]
Anson Alexander
Lincoln Brunswick
New Hanover
Bladen Robeson
Cabarrus Mecklenburg
Carteret Onslow
Cumberland Richmond
Catawba Rowan
Columbus Pender
Harnett Sampson
Cleveland Stanly
Duplin
Hoke Scotland
Gaston Union
Montgomery Moore
Iredell
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
[phone]
Fax [phone]
Alamance Rockingham
Alleghany Randolph
Ashe
Stokes
Caswell
Surry
Davidson
Watauga
Davie
Wilkes
Forsvth
Yadkin
Guilford
WQ0018347 Version 2.1
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vj
ATTACHMENT A - Approved Residual Sources
Permit Number: WQ0013347 Version: 2.1
Lebanon Seaboard Corporation
Certification Date: 01/08/2010
Owner
Facility Name
County
Permit
Number
Is 503?
Maximum Dry
Tons Per Year
Monitoring Frequency for
Condition IV. 2. and
Condition IV. 3. b
Lebanon Seaboard
Corporation
Distribution Program for: Dry Roots (3-3-3),
Endo Roots (3-3-4), M-roots (3-3-3), and
l-Step (2-2-2)
Roanoke, VA
N/A`
No
700
Quarterly
Total
" The composting operations are at Daylay Egg Farms, Inc., 11 177 Road 113, West Mansfield, OH 43358. However, the final product formulations are made at
the Lebanon Seaboard facilities in Salem, VA.
b Monitoring frequencies are based on the actual dry tons applied per year, unless specified. The Monitoring Frequency Requirements Table below shall be used
to determine appropriate sampling frequency. The Permittee is responsible for managing program to assure that adequate sampling is performed.
Monitoring Frequency Requirements
Dry Tons Generated
(short tons per year)
Monitoring Frequency
(Established in 40 CFR 503 and
15A NCAC 02T .111
<319
I/Year
=>319 - <1,650
1/ Quarter (4 times per year)
=>1,650 - <16,500 -
1/60 Days (6 times per year)
=> 16,500
I/month (12 times per year)
WQOO 18347 Version 2.1 ATTACHMENT A Page 1 of I

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural. Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
October 14, 2005 :
MR. JEFFREY J. HOWARD; PROJECT MANAGER _ _
NOVOZYMES BIOLOGICALS, INC. OCT
c/o REGISTRATION BY DESIGN, INC.
118 % E. MAIN ST, SUITE 1 J H
SALEM VA 24153
Subject: Permit No. WQ0018347
Novozymes Biologicals,. Inc.
dry roots (3-3-3), endo roots (3-3-4); M-roots (3-3-3),
and 1-step (2-2-2) Distribution Program
Distribution of Animal Residual Solids
Roanoke County, Virginia
Dear Mr. Howard:
In accordance with your change of ownership request received on March 5, 2005 and a permit
renewal application package received on August 29, 2005 as, well as additional information received
October 4, 2005 and Gctober 6; .2005; we are forwarding herewith Permit No. WQ0018347, dated..
October 14, 2005, to Novozymes Biologicals, Inc. for the subject animal residuals distribution program.
This permit shall be effective from the date of issuance until September 30, 2010; shall void
Permit No. WQ0018347; issued to Roots, Inc. on October 18, 2000;sha11 be subject to the conditions and,
limitations as specified therein. Make note of this permit's expiration date and the fact that a permit
renewal 'application is due to the Division of Water Quality (Division) no later than six months prior to
that date (i.e., see Condition V. 7.), as the Division does not send reminders to apply for permit renewal.
Beaware that payment of `the annual administering and compliance fee, as stipulated in Condition V. 4.
will not automatically renew this permit.
This permit approves the continued operation of program for another five-year cycle for the
distribution of a composted fertilizer/soil amendment product, containing poultry animal residuals, that ,
meets exceptional quality standards and is marketed under the names dry roots (3-3-3), endo roots (3-3-
4), M-roots (3-3-3), and 1-step (2-2-2) throughout the State of North Carolina (i.e., in bulk and in bags).
Note that this permit does not concurrently provide a license to distribute a fertilizer, as is required by the
Fertilizer Section of the NC Department of Agriculture and Consumer Services' Plant Industry Division. More information about applying for this license may be., found at the following web site:
bttp://www.ncajzr.com/plantind/fert/ferlics.htm.
Please take the time to review this permit thoroughly. Pay particular attention to the
monitoring requirements in this permit. Be aware .that failure to establish an adequate system for
collecting, maintaining, and submitting the required operational information will result in future
compliance problems.
ne
No UffiCarolina
aturail
Aquifer Protection Section 11636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Mr. Jeffrey J. Howard -
October 14, 2005
Page 2
If any parts, requirements, and/or limitations contained in this, permit are unacceptable, you have
the right to request an adjudicatory hearing upon written request within 30 days following receipt of this
permit. This request shall be in the from of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes and fled with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such demands are made, this permit shall be final
and binding.
If you need any additional information concerning this matter, please contact Mr. J R Joshi by
telephone at [phone], or via e-mail [e-mail].
Sincerely,
for Alan W. Klimek, P.E.
cc: VA Dept. of Environmental Quality -
NC Department of Agriculture and Consumer Services -Plant Industry Division (Fertilizer Section)
Asheville Regional Office -Aquifer Protection Section
rLFayetteville_Regional-Offce�Aquifer_Protection_S.ection
Mooresville Regional -Office --Aquifer Protection -Section
Raleigh Regional Office -Aquifer Protection Section
Washington Regional Office -Aquifer Protection Section
Wilmington Regional Office -Aquifer Protection Section
Winston-Salem Regional Office -Aquifer Protection Section
APS Central Files
APS Files
LAU Residuals Program Coordinator

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF ANIMAL RESIDUAL SOLIDS 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
Novozymes Biologicals, Inc.
Roanoke County, Virginia
FOR THE
Continued operation of a program for the distribution of up to 360 dry tons per year of a composted
fertilizer/soil amendment product, containing poultry animal residuals, that meets exceptional quality
standards and is marketed under the name dry roots (3-3-3), endo roots_ (3-3-4), M-roots (3-3-3), and 1-
step (2-2-2) throughout the State of North Carolina (i.e., in bulk and in bags). The program shall be
operated such that no discharge of waste to surface waters occurs, pursuant to your change of ownership .
request received on March 5, 2005 and a permit renewal application package received on August 29, 2005
as well as additional information received October 4, 2005 and October 6, 2005; and in conformity with
the project plan, specifications, and other supporting data subsequently filed and approved by the
Department of Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until September 30, 2010 and shall -be
subject to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
1. The distribution program shall be effectively maintained and operated as a non -discharge
system to prevent the discharge of any wastes to waters of the state resulting from the .-
operation of this program.
2. This permit shall become voidable in the -event of failure of the distribution program to
adequately protect the assigned water quality standards of the surface waters and
groundwater.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface water or groundwater resulting from the operation of this distribution program.

H.
4. In the event that the distribution program is not operated satisfactorily, including the creation
of nuisance conditions, the Permittee shall take any immediate corrective actions as may be
required by the Division of Water Quality (Division).
When product containing animal residuals is sold or given away for application to the land
under the conditions of this permit, one of the Class A pathogen requirements in 40 CFR Part
503.32(a) shall be met. Additionally, an evaluation shall be performed which demonstrates
the product's ability to comply with this requirement. Upon request, a copy of this
evaluation, including all test results and calculations, shall be submitted. -
No, product containing animal residuals that tests or is classified as a hazardous or toxic waste
under 40 CFR Part 261 shall be sold or given away for application to the land under the
conditions of this permit.
OPERATION AND MAINTENANCE REQUIREMENTS
The distribution program shall be properly operated and maintained at all times.
2. No product containing animal residuals other than that generated by the following facility
shall be approved for distribution in accordance with this permit:
Permit Volume
Facility County Number (Dry Tons/Year)
Novozymes Biologicals, Inc. Roanoke (VA) N/Aa 700.0
(d/b/a dry roots (3-3-3), endo roots (3-3-4), M-roots (3-3-3),*and 1-step (2-2-2) in NC)
aThe composting operations are at Daylay Egg Farms, Inc: 11177 Road 133, West Mansfield,
OH 43358. However, the final formulations are made at the Novozymes facilities at Salem,
VA.
3. No other product containing animal residuals, other than that from the facility specified in
Condition H. 2. shall be distributed under the conditions of this permit. The Permittee shall
request and obtain a permit amendment from the Division for each additional facility prior to
allowing distribution through this program.
4.. For a product containing animal residuals to be sold or given away in bags or other container
for application to the land under the conditions of this permit, the following shall be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations (Dry Weight Basis) shall be maintained:
Ceiling Monthly Average
Concentrations Concentrations
Parameters , (mZ&O (M&W -
Arsenic
75
Cadmium
85
Copper
4;300
Lead
840
Mercury
57
Nickel
420
Selenium
100.
Zinc
7,500
41
39
1,500
300
17
420
100
2,800
2

When distributed under the conditions of this permit, a label shall be affixed to the bag or
other container in which the product containing animal residuals is sold or given away for
application to -'the land; or an information sheet shall be provided to the person who receives
the product containing animal residuals sold or� given away in another container for
application to the land. The label or information sheet shall contain the following
minimum information:
a. The name and address of the person who prepared the •product containing animal
residuals that is sold or given away in a bag or other container for application to the
land.
b. A statement that application of the product containing animal residuals to the land is -
prohibited except.in accordance with the instructions on the label or information sheet.
c. A statement that adequate procedures shall be provided to prevent surface runoff from
carrying any disposed or stored product containing animal residuals into any surface
waters.
c. A 'statement to help prevent direct application of the product containing animal
residuals to water supply- sources and all other waters of the state. For example, "as
with any fertilizer product, do not apply in or near any water supply source or any body
of water, including wells, streams, rivers, and lakes."
d. A statement that application of he product containing animal residuals shall not be
applied to any land that is flooded, frozen, or "snow-covered.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e., including groundwater, surface. water, residuals, soil, or plant tissue,
analyses) deemed necessary by the Division to ensure protection of the environment shall be
established and an acceptable sampling and reporting schedule shall be followed.
2. Proper records shall be maintained by the Permittee to track all distribution activities within
the State of North Carolina. These records shall include, but are not necessarily limited to,
the following information:
a. Source, amount (i.e., volume), and analysis of each product containing animal residuals.
b. Name of the initial recipient of the product containing animal residuals, the amount (i.e.,
volume) distributed, and the intended use.
3. An analysis shall .be conducted by-the-Permittee on the product containing animal residuals at
least quarterly from the date of permit issuance: . The results of all analyses shall be
maintained on file by the Permittee for a minimum of five years. The analysis shall include
the following parameters:"
Aluminum
Ammonia -Nitrogen
Arsenic
Cadmium
Calcium
Copper
Lead
Magnesium
Mercury
Molybdenum
Nickel
Nitrate -Nitrite Nitrogen
Percent Total Solids
pH
Phosphorus
Potassium
Selenium
Sodium
Total Kjeldahl Nitrogen
Zinc
Plant Available Nitrogen
(by calculation)
W

After the product containing animal residuals has been monitored for two years at the above -
listed frequency, the Permittee may submit a request to the Division for a permit modification
to reduce the frequency of this monitoring requirement. In no . case, however,. shall the
frequency of this monitoring be less .than once per year when the product containing animal
residuals is sold or given away, for application to the land during that year.
4. The product containing animal residuals shall be monitored by the Permittee at quarterly for
compliance with Condition I. 5. of this permit. The monitoring frequency cycle shall start on
the date of permit issuance, and the results of all analyses shall be maintained on file by the
Permittee for a minimum of five years. Data to verify stabilization of the product shall be
maintained by the Permittee. The required data shall be specific to the stabilization process
utilized, but should be sufficient to demonstrate compliance with the Class A pathogen
requirements in 40 CFR Part 503.32(a) clearly. In addition, the EPA certification statement
concerning compliance with pathogen requirements, shall be completed at the above
frequency by the proper authority - or authorities if more than one is involved, either the
person who generates the product containing animal residuals or the person who prepares the
product to be sold or given away for application to the land.
5. Laboratory analyses and/or operational data, as required by Condition III. 3., and Condition
III. 4. shall be performed/gathered on the product containing animal residuals as it is to be
distributed. Furthermore, analytical determinations made pursuant to the monitoring and
reporting requirements of this permit shall be made by a laboratory certified by the Division
for the required parameter(s) under 15A NCAC 211.0800 or 15A NCAC 2H .1100. P
6. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition III. 2., Condition III. 3., Condition III. 4., and Condition III. 5. shall be
submitted annually on or before March 1" of the. year following the distribution event to the
following address:
NCDENR-DWQ
.Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
7. Noncompliance Notification:
The Permittee shall report by telephone to the Aquifer Protection Section of the appropriate
Division regional office (i.e., see Attachment A) as soon as possible, but in no case more than
24 hours or on the next working day following the occurrence or first knowledge of the
occurrence of any of the following:
a. Any occurrence with the distribution program that•results in the distribution of significant
amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to receiving.
waters.
c. Any time that self -monitoring information indicates that the distribution program has
gone -out' of compliance with the conditions and limitations of this permit or the
parameters on which the facility was designed.
d. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate treatment.
4

e. Any spillage or discharge from a vehicle or piping system during transportation of
residuals or product containing animal residuals.
Persons reporting such occurrences by telephone shall also file a written report in letterform
within five days following first knowledge of the occurrence. This report shall outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
IV. INSPECTIONS
1. The Permittee or his designee shall inspect the storage, transport, and treatment facilities
related to the distribution program to prevent malfunctions and deterioration, operator errors
and discharges which may cause or lead to the release of wastes to the environment, a threat
Jo human health, or, a nuisance. The Permittee shall maintain an inspection log or summary
including at least the date and time of inspection, observations made, and any maintenance;
repairs, or ' corrective actions taken by the Permittee. This log of inspections shall be
maintained by' the Permittee for a period of five years from the date of the inspection and
shall be made.available to the Division or other permitting authority, upon request.
2. Any duly authorized officer, employee,_ or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises or place on or related to
the distribution program at any reasonable time for the purpose of determining compliance
with this permit; may inspect or copy any records that must be kept under the terms and
conditions of this permit; and may obtain samples of groundwater, surface water, or leachate.
V. GENERAL CONDITIONS
This permit shall become voidable unless the distribution program is operated in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by
the Division.
2. This permit - shall be effective only. with respect to the nature and volume of product
containing animal residuals described in the application and other supporting data.
3. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement ' action by the Division in accordance with North Carolina
General Statutes § 143-215.6A through § 143-215.6C.
4. The annual administering and compliance fee shall be paid by the Permittee within 30 days
after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit, as specified by 15 NCAC 2H .0205 (c)(4).
5. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances that may be imposed by other government agencies
(i.e., local, state, and federal) which have jurisdiction, including, but not limited to, applicable
river buffer rules in 15A NCAC 2B .0200, soil erosion and sedimentation control
requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCGO10000,
and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC
.0500.

6. This permit may' be modified, revoked, and/or reissued to incorporate any conditions,
limitations and monitoring requirements the Division deems necessary in order to -protect the
environment and public health adequately.
7. The Permittee,. at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the
distribution program described therein, and if warranted, shall extend the permit for such
period of time and under such conditions and limitations as it may deem appropriate.
8. This permit shall not be automatically transferable. In the event that there is a desire for the
distribution program to change ownership or to change the name of the Permittee, a formal
permit request shall be submitted to the Division documentation from the parties involved
-and other supporting materials as may be appropriate. The approval of this request shall be
considered on its merits and may or may not be approved.
Permit issued this the fourteenth day of October, 2005.
NORTH CAROLINA ENV NMENTAL, MANAGEMENT COMMISSION
1
for A n W. Klimek, P.E., Director ri
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0018347.
0

Attachment A
DIVISION OF WATER QUALITY REGIONAL OFFICES
Asheville Regional Office
Fayetteville Regional Office
Mooresville Regional Office
APS Supervisor
APS Supervisor,
APS'Supervisor
2090 U.S. Highway 70
Wachovia Building, Suite 714
610 E. Center Aved Suite 301
Swannanoa, NC 28778
Fayetteville, NC 28301
Mooresville, NC 28115
Phone: [phone]
Phone: [phone]
Phone: [phone]
Fax: [phone]
Fax: [phone]
Fax: [phone]
Avery Macon
Anson. Moore
Alexander Lincoln
Buncombe Madison
Bladen Robeson
Cabarrus Mecklenburg
Burke McDowell
Cumberland Richmond
Catawba Rowan
Caldwell Mitchell
Harnett Sampson
Cleveland Stanly
Cherokee Polk
Hoke - Scotland
Gaston - Union
Clay Rutherford
Montgomery
Iredell
Graham Swain
Haywood Transylvania
Henderson .. Yancey
Jackson
Raleigh Regional Office
Washington Regional Office
Wilmington Regional Office
APS Supervisor
APS Supervisor
APS Supervisor
3800 Barrett Drive
943 Washington Square Mall
127 CardinalaDrive Extension
Raleigh, NC 27609
Washington, NC 27889
Wilmington, NC 28405-3845
Phone: [phone]
Phone: [phone]
Phone: [phone]
Fax: [phone]
Fax: [phone]
Fax: [phone]
Chatham Nash
Beaufort . Jones
Brunswick New Hanover
Durham Northampton
Bertie Lenoir
Carteret Onslow
Edgecombe Orange
Camden Martin -
Columbus Pender
Franklin Person
Chowan Pamlico
Duplin
Granville- Vance
Craven Pasquotank
Halifax Wake
Currituck Perquimans
Johnston Warren
Dare Pitt
Lee Wilson
Gates Tyrell
Greene Washington
Hertford Wayne
Hyde
Winston-Salem Regional Office
APS Supervisor
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
Fax: [phone]
Alamance Rockingham
Alleghany Randolph
Ashe Stokes
Caswell. Surry
Davidson Watauga
Davie Wilkes
Forsyth Yadkin
Guilford

State of North Carolina
.Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
Mike Davison, President
Roots, Inc.
3120 Weatherford Rd
Independence, MO 64055
Dear Mr. Walraven:
NCDENR
ORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
October 18, 2000 REC�®
idOV 0 0 2000,
'EtrEVILLE
PEG. 0FFIGE
Subject: Permit NoaW10013834
LRoU0ts; Inc
Distnbution�.: 'nimal-Waste_Prodbas
-G:
Ct�mmri.g;. Georg a.
In.,accordance with your application received on March 14, 2000, we are forwarding herewith Permit
No. WQ0018347, dated October 18, 2000; to Roots, Inc. for the distribution and marketing of a fertilizer
containing animal waste products.
This permit shall be effective from the date of issuance until September' 31, 2005, and: shall be subject
to the. conditions: -and limitations as specified therein. Please pay particular attention to .the monitoring and
reporting requirements contained in this permit. Failure to establish an adequate system for collecting and
maintaining the required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this .permit are unacceptable, you have the right
to request an adjudicatory, hearing upon written request within thirty (30) days following receipt of this permit.
This request must be in the form of a written petition, conforming to ,Chapter 150B_of North Carolina General
Statutes, and filed with the Office of Administrative Hearings, 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 matter, please ntact Sue Homewood at (919)
733-5083 extension 502.
' Sinc e
lam/ v
�Kerr.T. Stevens
cc: NCDWQ Regional Offices, Water Quality Section
Susan Baker, Fertilizer Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer - 50% recycled/10%o post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF RESIDUALS OF EXCEPTIONAL QUALITY
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
Roots, Inc.
FOR THE
distribution and marketing of 750 dry tons per year of a fertilizer containing animal waste products,
throughout the State of North Carolina, with no discharge of wastes to the surface waters, pursuant to the
application received on March 14, 2000, and in conformity with the project plan, specifications, and other
supporting data subsequently filed and approved by the Department of Environment and Natural Resources
and considered a part of this permit.
This permit shall be effective from the date of issuance until September 31, 2005, and shall be subject
to the following specified conditions and Iimitations:
I. PERFORMANCE STANDARDS
The program for the distribution and marketing of a fertilizer containing animal waste products
shall be effectively maintained and operated as a non -discharge system to prevent the discharge
of any wastes resulting from the operation of this program.
2. This permit shall become voidable in the event of failure of the distribution and marketing
program to adequately protect the assigned water quality standards of the surface waters and
groundwaters.
The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwaters resulting from the operation of this program.
4. In the event that the distribution and marketing program is not operated satisfactorily, including
the creation of nuisance conditions, the Permittee shall take any immediate corrective actions as
may be required by the Division of Water Quality (Division).
5. When waste residuals are sold or given away, one of the pathogen requirements in 40 CFR Part
503.32(a) must be met. Additionally, an evaluation must be performed which demonstrates the
residuals ability to comply with this requirement. Upon request, a copy of this evaluation must be
submitted including all test results and calculations.

.. a
II. OPERATION AND MAINTENANCE REOUIREMENTS
1. ` For a treated residuals to be. sold or given away in bags or other container for application to the
land, the following must be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations (Dry Weight.Basis) must be maintained:
Ceiling Monthly Average
Concentrations Concentrations
Parameters mg/k-g mg/kg
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Nickel
420
420
Zinc
7,500
2,800
2. A label shall be affixed to the bag or other container in which residuals that are sold or given
away for application to the land, or an information sheet shall be provided to the person who
receives the residuals sold or given away in any other container for application to the land. The
label or information sheet shall contain the following information:
a. The name and address of the person who prepared the residual that is sold or given away in a
bag or other container for application to the land. ,
b. A statement that application of the residual to the land is prohibited except in accordance with
the instructions on the label or information sheet.
c. A statement that the residuals shall not be applied to any site that is flooded, frozen or -snow-
covered.
d A statement that adequate procedures shall be provided to prevent surface runoff from
carrying any disposed or stored residuals into any surface waters.
e. A statement which identifies that this material shall be prevented from entering any public or
private water supply source (including wells) and any stream, lake, or river.
III. MONITORE\G AND REPORTING REOUIREMENTS
1. Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue analyses)
deemed necessary by the Division to insure protection of the environment will be established and
an acceptable sampling and reporting schedule shall be followed.
2. Proper records shall be maintained by the,Permittee tracking all residual activities. These records
shall include, but are not necessarily limited to the following information:
a. . Source and volume of animal waste residuals, .
b. Name of recipient of product, volume received, and intended use.

3. A product analysis shall be conducted every 60 days from the date of permit issuance by the
Permittee. The results of all analysis shall be maintained on file by the Permittee for a minimum
of five years. The product analysis shall include the following parameters:
Cadmium Nickel
Copper Zinc
Lead
Aluminum ,
pH
Ammonia -Nitrogen
Phosphorus
Calcium
PIant Available Nitrogen (by calculation)
Magnesium
Potassium
Nitrate -Nitrite Nitrogen
Sodium
% Total Solids
TKN
4. All residuals included in this permit must be monitored 60 days from the date of permit issuance,
for compliance with condition 15 of this permit. Data to verify stabilization of the residuals must
be maintained by the Permittee. The required data is specific to the stabilization process utilized,
but should be sufficient to clearly demonstrate compliance with the pathogen requirements in 40
CFR Part 503.32(a). In addition, the EPA certification statements concerning compliance with
pathogen requirements and management practices must be completed every 60 days by the proper
authority or authorities if more than one is involved, either the person who generates the residuals.
or the person who prepares the residuals to be sold or given away.
5. Three copies of all required monitoring and reporting requirements as specified in conditions 1112
III 3, and 1114 shall be submitted annually on or before March 1 of the following year to the
following address:
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
6. NoncompIiance Notification:
The Permittee shall report by telephone to the appropriate DWQ Regional Office (as outlined in
attachment 1) as soon as possible, but in no case more than 24 hours or on the next working day
following the occurrence or first knowledge of the'occurrence of any of the following:
a. Any occurrence with the residual distribution program which results in the application of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to receiving waters.
c. Any time that self -monitoring information indicates that the facility has gone out of
compliance with the conditions and limitations of this permit or the parameters on which the
system was designed.
d. Any process unit failure, due to known or unknown reasons, that render the facility incapable
of adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of residuals.
3

Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) days following first knowledge of the occurrence. This report must outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
IV. INSPECTIONS
The Permittee or his designee shall inspect the residuals storage, transport, and treatment facilities
to prevent malfunctions and deterioration, operator errors and discharges which may cause or lead
to the release of wastes to the environment, a threat to human health, or a nuisance. The
Permittee shall maintain an inspection log or summary including at least the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken by the
Permittee. This log of inspections. shall be maintained by the Permittee for a period of five years
from the date of the inspection and shall be made available to the Division or other permitting
authority, upon request.
2. Any duly authorized officer, employee, or representative of the Division may, upon presentation
of credentials, enter and inspect any property, premises or place on or related to the treatment site
or facility at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records that must be kept under the terms and conditions of this permit;
and may obtain samples of groundwater, surface water, or leachate.
V. GENERAL CONDITIONS
This permit shall become voidable unless the distribution activities are carried out in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by this
Division.
2. This permit, is effective only with respect to the. nature and volume of residuals described in the
application and other supporting data.
3. This permit is not automatically transferable. In the event that there is a desire for the facilities to
change ownership or a name change of the Permittee, a formal permit request must be submitted
to the Division accompanied by an application fee, documentation from the parties involved, and
other supporting materials as may be appropriate. The approval of this request will be considered
on its merits and may or may not be approved.
4. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina General
Statute 143-215.6A to 143-215.6C.
5. The annual administering and compliance fee must be paid by the Permittee within thirty (30)
days after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit as specified by 15 NCAC 2H .0205 (c)(4).
6. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances which may be imposed by other government agencies
(local, state, and federal) which have jurisdiction.
The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the facilities
described therein, and if warranted, will extend the permit for such period of time and under. such
conditions and limitations as it may deem appropriate.
4

8. This permit may be modified, or revoked and reissued to incorporate any conditions, limitations
and monitoring requirements the' Division deems necessary in order to adequately protect the
environment and public health.
Permit issued this the 18t' day of October, 2000.
EMENT COMMISSION
Ken: T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0018347
5