840001_Response to Notice_20240405

On January 23, 2024, staff of North Carolina Division of Water Resources (DWR), Water
Quality Regional Operations Section (WQROS), received a complaint regarding waste over -
applications of the above referenced Animal Waste Individual Permit AWI840001 (Permit). We
understand that this facility is currently undergoing a lagoon closure and Dennis Daley and
Ronnie G. Kennedy, Jr. of Renewable Transport LLC are contracted to complete the lagoon
closure.
Staff responded to the complaint on January 26, 2024, and conducted follow-up site visits on
January 30, 2024, and February 22, 2024. Accordingly, the following violations of the Permit
were documented during the inspections:
Violations
1. Permit Condition I.1. states "The animal waste management system operated under this
Permit shall be effectively maintained and operated as a non -discharge system to prevent the
discharge of pollutants to surface waters, wetlands, or ditches. " and Permit Condition I.2 states
"No discharge of waste shall result in a violation of the water quality standards established for
receiving waters as per Title 15A, Subchapter 2B, Section .0200 of the North Carolina
Administrative Code (NCAC) and Title 15A, Subchapter 2L of the NCAC." Per 15A NCAC 02B
.0211 (12): "Oils, deleterious substances, or colored or other wastes: only such amounts as shall
not render the waters injurious to public health, secondary recreation, or to aquatic life and
wildlife, or adversely affect the palatability offish, aesthetic quality, or impair the waters for any
designated uses. For the purpose of implementing this Rule, oils, deleterious substances, or
colored or other wastes shall include substances that cause a film or sheen upon or discoloration
of the surface of the water or adjoining shorelines, as described in 40 CFR 110.3(a)-(b),
incorporated by reference including subsequent amendments and editions. " The site visits
found evidence of waste discharged at multiple places to a classified stream tributary to
Long Creek (Class C) from waste over application on Farm 8949 Tract 2365 of the
CAWMP and at an additional location on cropland fields (approximate coordinates
35.277894,-80.248769).
I disagree with this assessment. There should be more evidence than what is presented I see
pictures of clear water running away from my property in a natural drainage pattern. Heavy
rainfall events after land application caused nutrients and mud sediment to migrate into
natural drainage patterns. In addition I am including the precipitation we have had from Jan3
- Mar 23=12.59" of rainfall with heavy events denoted during DEQ investigation periods.
(See attached Rainfall totals)
In order to mitigate the above finding I have incorporated all applied material and a crop in
currently growing. Crop will be terminated in the near future and a corn crop will be planted.
No discharge is or will be occurring.
2. Permit Condition I.3 states "The facility's CAWMP is hereby incorporated by reference into
this Permit. The CAWMP must be consistent with all applicable laws, rules, ordinances, and
standards (federal, state and local) in effect at the time of siting, design, and certification of the
Facility. Any violation of the terms or conditions of the COC or the CAWMP is a violation of this
Permit subject to enforcement action and may result in the Permittee having to take immediate

and/or long-term corrective action(s) as required by the Division. " Per the CAWMP (signed and
dated by Josh Amick 8/16/2023) for Twin J Farms/ J-Caine Inc, the "Required Specifications For
Animal Waste Management" states the following "9. Animal waste shall be applied on actively
growing crops in such a manner that the crop is not covered with waste to a depth that would
inhibit growth ... 22. Waste shall be tested within 60 days of utilization... ". Animal waste/ sludge
was applied to fields and cropland up to eight (8) inches thick submerging the wheat crop.
(Farm 8949 Tract 2365). Sludge sample data results were not included in the Nitrogen
Balances on the SLUR-2 Forms completed by Renewable Transport LLC.
I disagree with this assessment. based off several facts there should be more evidence than
what is presented to assume this statement. First off was this assessment made after a heavy
rainfall event? Could the depth have come from the flow of mud and sludge from atop a hill
and slope and deposited in a valley? In this case what was applied correctly could be displayed
in a negative light after a heavy rainfall event. For example one day before afield
investigation was made on 1126 on 1125 a heavy rainfall event was documented at 7 inches in
a short span. This event would be enough to cause sludge and mud to slide off the hill into a
field valley. No one thought to look at the condition of the field prior to this heavy rainfall
event. This is a piedmont region with steeply rolling hill topography by definition. Sludge
sample data results are included in the records and land application package (included)
In order to mitigate the above finding applied waste has again been evenly distribute throughout the field.
3. Permit Condition I1.2. states `A vegetative cover shall be maintained as specified in the
facility's CAWMP on all land application fields and buffers in accordance with the CAWMP. No
waste shall be applied upon areas not included in the CAWMP or upon areas where the crop is
insufficient for nutrient utilization. " No vegetation was viewed or was sparse with weeds and
limited crop of Farm 8949 Tract 2365 Field #1, Field #2, Field #3, and Field #4. Tract 2357
Field #1 with a Field Size of 15 Wettable Acres and Tract 2702 Field #1 with a Field Size of
76.4 Wettable Acres have completed SLUR-2 Forms by contractor Renewable Transport
LLC showing waste applications. In addition, Farm 8949 Tract 2365 had visual waste land
applications observed during January and February 2024 Site Visits to the following
locations: Field #3, cropland between Field #3 and Field #2, Field #4, cropland located
north of the existing poultry houses and adjacent to Sides Road (approximate coordinates:
35.281725,-80.245677), the eastern cropland adjacent to the existing poultry houses
(approximate coordinates: 35.279608,-80.245413), the southern cropland located south of
the lagoon (approximate coordinates 35.277894,-80.248769). These cropland fields have
evidence of waste applications, are NOT listed fields for waste utilization within the
CAWMP (signed and dated 8/16/2023) and have sparse vegetation.
I disagree with this assessment. It is my understanding that we are allowed to apply land 30
days prior to planting. However, this planting could have been delayed due to the rains and
cold temperatures that are common this time of year. The areas of concern map which I am
including in my full summary at the end of this response are fields that are indeed in my
operational plan that was inherited from the previous permit holder. Farmers, such as myself
that have inactive waste water lagoon structures are required to have lands available in which
they can manage these structures. In this case these lands are my lands that you see in the
"Areas of Concern " map and also in the (enclosed) prior Nutrient Algt Plan that was in place

and passed down tome as the new owner. This plan was pulled from the DEQ files, so to say
these lands were not in a plan is an oversight and this accusation should have been discovered
by the inspector and should be retracted moving forward.
All fields have a crop actively growing. Waste has not been applied to fields no in the plan.
4. Permit Condition IIA. states "Land application rates shall be in accordance with the CAWMP.
In no case shall the total land application rates from all nutrient sources exceed the agronomic
rate of the nutrient of concern for the receiving crop. " Also, 15A NCAC 02T .1304 (b) (3) states
"The waste shall not be applied at greater than agronomic rates. " Farm 8949 Tract 2365 Field
#2, the eastern cropland adjacent to the existing poultry houses
(approximate coordinates: 35.279608,-80.245413), and the southern cropland located south
of the lagoon (approximate coordinates: approximate coordinates 35.277894,-80.248769)
show wet sludge material was applied up to eight inches thick. Additionally, the SLUR-2
form, completed by Renewable Transport LLC, states that Field #2 has an available
Nitrogen Balance of 2.69 lb/acre with the last application date of 10-5-2023. All provided
SLUR-2 forms utilized only lagoon liquid sample data from samples JAS1, JAS2, and SC -
Land application of waste, including sludge, may not exceed the agronomic rate for
nutrient uptake by the receiving crop.
I disagree with this statement for the same reasons explained in the first two permit condition
violation responses. Weather is the primary factor that is overlooked here, yet again.
No sludge has been applied to any fields and waste applications have not exceeded agronomic rates
Waste has been incorporated and crops have been planted.
6. Permit Condition II.13 states that "At the time of sludge removal from a lagoonlstorage pond,
the sludge must be managed in accordance with the CAWMP. When removal of sludge from the
lagoon is necessary, provisions must be taken to prevent damage to the lagoon dikes and liner. "
Sludge applications were not managed in accordance with the CAWMP (e.g.: applications
to cropland not included in the WUP, waste and sludge not applied within agronomic rates,
overapplications). Additionally, the dike wall was damaged in three locations for equipment
access to the lagoon for sludge removal with resulting lower elevation changes to the
original dike wall structure. DWR was not notified of any dike wall breach or damage.
It is common practice in decommissioning waste water lagoons to create access points for
heavy equipment to safely enter the structure when required to agitate the waste in very steep or
deep lagoons and/or to scrape lagoons if required by a Technical Specialist. A Technical
Specialist requested the scraping and a Technical Specialist wanted the equipment to enter the
lagoon for such actions. If you speak to any Technical Specialist or NRCS Engineer Staff
Member that have been involved with lagoon closures they have directed these type operations
in order to insure the liquid slurry and removal part of the standard are followed. In this case
the photo showing the entry point for the equipment is 10' or more above the current waste
water level,
Applied waste has not exceeded agronomic rates and fields were included in the plan. The damaged portion
of the lagoon wall will be repaired and seeded.

7. Permit Condition II.21 states "The Permittee shall maintain buffer strips or other equivalent
practices as specified in the facility's CAWMP near feedlots, manure storage areas and land
application areas. " Within Farm 8949 Tract 2365, the eastern cropland adjacent to the
existing poultry houses (approximate coordinates: 35.279608,-80.245413) and cropland
located north of the existing poultry houses and adjacent to Sides Road (approximate
coordinates: 35.281725,-80.245677) have waste land applications that exceed the edge of
the mapped cropland. Waste was observed coating the foliage/ tree buffer up to four (4)
feet high and extend into the foliage/ tree buffer up to fifteen (15) feet.
I disagree from the picture and reasons provided that what was actually seen was indeed waste
water on foliage and beyond field boundaries feet high especially after the heavy rain events
that occurred just prior to the investigation.
Crop is actively growing and no damage has been done to surrounding trees.
8. Permit Condition III.2.a. states "Highly visible waste -level gauges shall be maintained to
mark the level of waste in each lagoon/storage pond that does not gravityfeed through a free -
flowing transfer pipe into a subsequent structure. The gauge shall have readily visible permanent
markings. " No freeboard marker was observed in the lagoon structure.
Please see pics (attached) of not 1 but 2 Freeboard markers that were overlooked by the
inspector. I request this accusation be retracted from this NOV which is public record.
Markers were present, pictures are included.
9. Permit Condition III.5. states "An analysis of a representative sample of the animal waste to be
applied shall be conducted in accordance with recommended laboratory sampling procedures as
close to the time of application as practical and at least within sixty (60) days (before or after) of
the date of application... " Manure Analysis of Sludge/ Solid waste was not utilized on
SLUR-2 forms which only show liquid analyses not sludge (JAS1, JAS2, SC1). SLUR-2
forms were completed by Renewable Transport LLC.
Please see attached manure samples taken within the time framed required and recorded on the
land application records.
Only agitated material has been applied during the closure process.
10. Permit Condition III.8 a-e. states "If, for any reason, there is a discharge from the waste
collection, treatment, storage and application systems (including the land application sites), to
surface waters or wetlands, the Permittee is required to make notification in accordance with
Condition III.12... " Additionally, Permit Condition III.12.g. states "An application of waste
either in excess of the limits set out in the CAWMP or where runoff enters ditches, surface
waters, or wetlands. " The Permittee did not notify DWR of a discharge to a Stream/ Water
of the State from land overapplication of waste and sludge. The OIC must inspect the
application fields during application events. Permit Condition 2.17 states that "Inspections
shall include but not limited to visual observations of application equipment, land application
area, subsurface drain outlets, ditches, and drainage ways for any discharge of waste." Required
inspections of the application fields at the time of application would have shown waste
runoff from over -application and thus discharge to state waters.

I disagree with this statement as I did not see any indications of problems only that we were
having chronic rainfall events that were prohibiting the lagoon closure process.
I was not aware of any discharge events
11. Permit Condition V.3. states "Any containment basin, such as a lagoon or a storage pond,
used for waste management shall continue to be subject to the conditions and requirements of
this Permit until properly closed... Closure shall also include a minimum of 24 hours pre-
notification of the Division... " Notification to DWR of closure by NRCS Grayson Sarif email
dated 10/4/2023 stating "the lagoon closure for Joshua Amick in Stanly County is
scheduled to being this coming Monday, October 9th [20231." In addition, the email
contained an attachment of the approved CAWMP, signed by both Lee Holcomb (NRCS)
and Josh Amick (Permittee) dated August 16, 2023. The WUP shows waste is to be applied
on wheat and pasture crops. The SLUR-2 forms completed by Renewable Transport LLC
show waste applications to wheat crop began as early as on September 6, 2023, and thus,
closure began prior to notification on October 4, 2023.
I disagree with this assessment. Per my existing plan dated 311212009 (attached) I am allowed
and required to manage topwater from my lagoon structure. The records indicate my actions
as required and permitted which has been the same operational protocol since my purchase of
the farm.
Permitted Operation Owner Summary
• Improper Name Disclosure
It should be noted that when a legal North Carolina company is contracted verbally or
by contract to do a job the company is an entity of its own by law. Individual names
should not be mentioned as the individuals are separate entity (not contracted
individually to do a job) . Mentioning personal names can be viewed as defamation
especially if there is a difference in opinions between these individuals. We request
that personal names be removed from this official public document.
• Lack of Transparency
I was not properly notified of inspections occurring on my farm. I was not notified of
potential problems and given any instruction or guidance as to how any perceived
problem should be alleviated. It should be common courtesy to provide notice of such
investigations occurring on my land especially when I am participating in a voluntary
state program to eliminate a 10 Acre Waste lagoon Structure.
It should not have taken from 112312024 until 312512024 for this violation to be
produced and sent to the list of individuals. There should have been ample notice
provided indicating there will be violations forthcoming.

• Weather Considerations at around the time of Investigations
At least 5 of the permit condition violations were influenced by chronic rainfall events
at or around the time of investigations. Not once was the weather mentioned or
considered in this six page violation.
• Lack of Experience and Understanding of Waste Lagoon Closures and Inactive
Permitted Operations
The mention of lagoon structure disturbances, liner integrity, during a lagoon closure
process should fall under the expertise of the Certified Technical Specialist which
would include Private Engineer PE, NRCS Engineers with job approval, or Division of
Soil and N ater Engineers. All of the before mentioned are involved currently in my
project, of which none were consulted before the DEQ inspector cited me with this
violation. This is an example of the lack of experience and professionalism when there
is access to other more qualified individuals were not consulted before the NOV was
written.
Inactive operations are required to maintain records and their animal waste mgt
system just as if it were an active operation. These operations use existing nutrient Mgt
plans as a guide to maintain lagoon compliance. In this case, the DEQ inspector is
unaware of existing waste utilization plans for this purpose and cited the owner for
using fields not in his plan. The existing waste mgt plan (attached) was pulled from
DEQ files and did describe the fields that are available for compliance purposes to
receive waste from this permitted structure.
• Lack of Understanding the Importance to Closing Lagoon Structures and the
Cooperation it takes to Administer Government Lagoon Closure Programs
New programs to close lagoons have pushed this practice into heavy scrutiny it should
be noted that the overall number one Environmental Impact here is the lagoon
structure and getting it decommissioned so that a very large amount of waste will no
longer have the potential to harm anyone downstream. In this case of complete
misunderstanding, we have an inspector that spends days after heavy rainfall events,
looking intensely around 9.29 Acres of impact area (see attached map). This area
comprised 1.4 % of 650 acres of land that was land applied with around 23 million
gallons of slurry. N by did this inspector not look at the overall operation and the other
640 acres that received wastes? Why did they go to specific areas and concentrate on
creating this 6 page violation letter? Why did the inspector step over the Technical
Specialists involved in this process to cite me for creating a lane for heavy equipment to
access the lagoon for scraping and pumping. tYhy the trespassing and showing upon
my property and lack of transparency that was evident throughout this entire process?
Why are there only around 20 lagoon closures completed since 2022 which is the the

inception of the program. I personally believe DEQ in cooperation with Division of
Soil and Water was trying to make an example of me for standing up for what is right,
for calling my legislators, and expressing my dissatisfaction with how this closeout
program is moving terribly slow and not on task to close 155 lagoons by 2026. I hope
you have seen here why this program is failing and will continue to fail as long as we
have people that are more concerned with personal validation than cooperating with a
great program that ultimately protects the Environment.

Rainfall
Date
Rainfall
Year-to-date
1 /3/2024
0.00"
0.00"
1 /5/2024
0.31 "
0.31 "
1 /6/2024
0.98"
1.29"
1 /8/2024
0.19"
1.48"
1 /9/2024
2.35"
3.83"
1/12/2024
1.09"
4.93"
1/15/2024
0.04"
4.96"
1 /16/2024
0.24"
5.20"
1 /23/2024
0.04"
5.25"
1 /24/2024
0.27"
5.52"
1 /25/2024
0.70"
6.22"
1 /26/2024
0.02"
6.23"
1 /27/2024
1.12"
7.35"
1 /30/2024
0.09"
7.44"
1 /31 /2024
0.04"
7.48"
2/9/2024
0.01 "
7.48"
2/10/2024
0.03"
7.51 "
2/11 /2024
0.19"
7.71 "
2/12/2024
0.37"
8.08'
2/22/2024
0.03"
8.11 "
2/23/2024
0.20"
8.31"
2/27/2024
0.14"
8.45"
2/28/2024
0.02"
8.47"
3/1 /2024
1.38"
9.85"
3/2/2024
0.01"
9.86"
3/5/2024
0.11"
9.97"
3/6/2024
0.31 "
10.29"
3/8/2024
0.25"
10.54"
3/9/2024
0.80"
11.34"
3/15/2024
0.34"
11.68"
3/22/2024
0.88"
12.56"
3/23/2024
0.03"
12.59"

Nutrient Management Plan For Animal Waste Utilization
03-12-2009
This plan has been prepared for:
Twin J Farms
Larry Faulkner
Albemarle, AIC 28001
This plan has been developed by:
R Pigg
NRCS
3230 Presson Rd
Monroe, A'C 28112
704-233-1621
Developer Signature
Type of Plan: Nutrient Management with Manure Only
Owner/Manager/Producer Agreement
I (we) understand and agree to the specifications and the operation and maintenance procedures
established in this nutrient management plan which includes an animal waste utilization plan for
the farm named above. I have read and understand the Required Specifications concerning animal
waste management that are included with this plan.
ignature (owner) Date
/64w IV- 3 -12 ^01
4gnature (manager or producer) Date
This plan meets the minimum standards and specifications of the U.S. Department of Agriculture -
Natural Resources Conservation Service or the standard of practices adopted by the Soil and Water
Conservation Commission.
Plan Approved B%�: ��Za AA;42k
Technical Specialist Signature Date
......................................................................... .... ...... ............................................
930123 Database Version 3.1 Date Printed: 03-12-2009 Cover Page I
RECEIVED IOENR/DWO
AQUIFFR PRnTFr.Tn.v CF_CTION
MAR 18 2009

Narrative
THIS NUTRIENT MANAGEMENT PLAN IS WRITTEN FOR THE RAINFALL EVENTS OF THIS
LAGOON ONLY. THE LAGOON IS ABANDONED AND NO ADDITIONAL WASTES ARE
ACCUMILATED. IT IS PLANNED USING AN ANNUAL RAINFALL MINUS EVAPORATION
RATE OF 3 INCHES AND THE I YEAR124 HR. STORM EVENT OF 3 INCHES FOR A TOTAL OF
6 INCHES PER YEAR RAINFALL INPUT. ONCE THE RAWPALL HAS BEEN COLLECTED AND
CONTAIMINANTED WITH TI IE WASTE EXISTING IN THE LAGOON, IT WILL THEN BE
APPLIED ON THE FIELDS LISTED IN THE PLAN AT THE RATES CONTAINED WITHIN THE
PLAN. ALL MANAGEMENT OF THE LAGOON WILL BE THE SAME AS PREVIOUSLY
PREFORMED AND MUST MEET ALL FREEBOARD, RUNOFF, ETC. GUIDELINES. IT WILL BE
THE OPERATORS RESPONSIBILITY TO MAINTAIN ALL RAINFALL AND PUMP RECORDS IN
ACCORDANCE WITH NC STATE AND FEDERAL LAWS AS APPLICIPLE.
.................................................................................................................................................. .........
Preview Database Version 3.1 Daic Primed:' 03-12-2009 Narrative Page Page I of I

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USDA United States
��- Department of Agriculture Stanly County, North Carolina
-
Farm 8949
Tract 2365
2024 Program Year
Page Cropland Total 49 21 acres
Map Created November 21 2023
Base Image Layer flown in 2022
Common Land Unit
Cropland
Non -Cropland
[Tract Boundary
Wetland Determination Identifiers
0 Restricted Use
❑ Limited Restrictions
Exempt from Conservation
f Compliance Provisions
iducer and:or the NAIP imagery The producer
accepts the del 'as Wand assumes all risks associated with its use. The USDA Farm Service Agency assumes no responsibility for actual or consequential damage incurred as a resua of any use es reliance on this data outside FSA Programs
Wetland identifiers do not represent the size, shape, or specific determination of the area Refer to your orig mal determination (CPA-026 and attached maps) for exact boundaries and detem inations or contact NRCS

Nutrients applied in accordance kith this plan will be supplied from the following
source(s):
Commercial Fertilizer is not included in this plan.
U5
(Cleanout)
Layer Lagoon Rainfall is an animal waste treatment lagoon that4equircs removal of
accumulated sludge in order to maintain adequate treatment volume. It is estimat d
that 1,629,313 gallons gloggM lagoon liquid must be removed. ,fal kll
Estimated Pounds of Plant Available Nitrogen Generated
Broadcast
Z e
Incorporated
Injected
Irrigated
r -
C!F
Max. A%,ail.
PAN (lbs) +
Actual PAN
Applied (lbs)
PAN Surplus/
Deficit (lbs)
Actual Volume
Applied (Gallons)
Volume Surplus/
Deficit (Gallons)
w
•
•moon
Note: In source I D. S wwr.% standard sot.Mc, L. inwns user defined source
" Atax. Available PAN is calculated on the basis of the actual application inethod(s) identified to the plan for this sot.rce.
930123 Database Version 3.1 Date Printed. 03-12-2009 Source Page Page I of 1

The table shown below provides a summary of the crops or rotations included in this plan for each field. Realistic Yield estimates are
also provided for each crop, as well as the crop's P205 Removal Rate. The Leaching Index (LI) and the Phosphorous Loss Assessment
Toot (PLAT) Rating are also provided for each field, where available.
If a field's PLAT Rating is High, any planned manure application is limited to the phosphorous removal rate of the harvested plant
biomass for the crop rotation or multiple years in the crop sequence. Fields with a Vcry High PLAT Rating should receive no
additional applications of manure. Regardless of the PLAT rating, starter fertilizers may be recommended in accordance with North
Carolina State University guidelines or recommendations. The quantity of P205 applied to each crop is shown in the following table if
the field's PLAT rating is High or Very High.
Planned Crops Summary
Tract
Field
Total
Acres
useable
Acres
Plat
Rating
LI
Soil Series
Crop Sequence
RYE
P205
Rcmo%al
(tbstacrc)
I Applicd
(Ibstacrc)
PLAN TOTALS:
Ll
Potential Leaching
Technical Guidance
Low potential to contribute to soluble
None
< 2
nutrient leaching below the root zone.
Moderate potential to contribute to soluble
Nutrient Managctnciu (590) should he planned.
>— Z &
nutrient leaching below the root zone.
<= 10
High potential to contribute to soluble
Nutrient Management (590) should be planned. Other conservation practices that improve the soils
nutrient leaching below the root lone.
available water holding capacity and improve nutrient use efficiency should be considered. Examples
arc Cover Crops 1340) to scavenge nutrients, Sod -Based Rotations (328). Long -Tenn No -Till (778),
> 10
and edge -of -field practices such as Filter Strips (393) and Riparian Forest Buffers (391).
PLAT Index
Rating
P Management Recommendation
0 - 25
Low
No adjustment needed; N based application
25 - 50
Medium
No adjustment needed; N based application
51 - 100
High
Application limited to crop P removal
> 100
prep• High
Starter P application only
Date Printed 112n009
NOTE: Symbol ' means user entered data.
PCS Page Page 1 of I

VOLUME TO BE REMOVED
Length (Top)
950.00
Width (Top)
466.00
Total Depth
0.50
Side Slopes
a Enter horizotal`#'f'sid aslopes
Liquid Depth (it►
0.50
a e:)Fo`ra3s-1,xsiiisbente`r 3
Sludge Depth (1t)
0.00
Freeboa►d (ft)
1.00
Length
Width
Lagoon Dims. @ Liquid Level
94600
46200
Lagoon Dims- @ Sludge Level
944.00
460.00
Lagoon Dims. @ Bottom
94400
460.00
Cubic Feet
Galion
Liquid Depth
217822 67
1629313 55
Sludge Depth
0.00
0.00
Total
217822.67
1629313.56

WASTE ANALYSIS DATA
Date of Analysis &25/2008
Nitrogen Concentration (Broadcast & Irrigation)
(Ibs11000 Gallons) Volume (Gallons) lbs. of PAN
Liquid 0.48 1629313.55 782.07
Sludge 0.00 000
Total 1629313.55 782.07
0.48 lbs_ PAN Mixed Volume Concentration/1,000 gal
13.03 lbs. per acre -inch
Copper Concentration
(ppm) Volume (Gallons)
Dom Cu -gallons
Liquid 0 1629313.55
0.00
Sludge 0.00
0.00
Total 1629313.55
0.00
0.00 ppm Copper Mixed Volume Concentration
Zinc Concentration
(ppm) Volume (Gallons)
aam Cu - gallons
Liquid 0 1629313.55
0.00
Sludge 0.00
0.00
Total 1629313.55
0.00
0.00 ppm Zinc Mixed Volume Concentration

INMroaeZCo"n-Mlon Co-W '!j3 oadcast t ''R : -•
Nitronen laaml Conversion Factor
Liquid 120 02266
Sludge 0.2266
INltroa n Co"`�vrelo„ Facto poi s3nlrnco aorated
Nitronen loam► Conversion Factor
Liquid 120 0.2266
Sludge 0 0.2266
Availability
Ibs. N/Ac4n.
Coeff.
PANIAc-In
PAN11.000 Gal
27.19
0.50
1360
0.50
0.00
0.46
0.00
000
Availability
Ibs. N1Ac-In.
Coeff.
PANIAc-In
PAN11.000 Gal
27.19
078
21.21
0.78
0.00
0.60
0.00
0.00

LAND_APPLIC_ATION OF�F(WAS_TE (NITRO_G_EN_BROADCAST_ & IRRIGATION)__
Tract • I d p 1 �Cjgg Sotl Tvoe $yam { NiAc (max.l I N/Ae lolanne0l J—A,P — —iedI c•1 Ins Aoolled
2365 1 Bermuda Badin 4 200 200 10 2000 _ _13 03 _ _ 153.45 _
2365 2 Bermuda Goldston 4 200 200 14 _ _ 280� —_ _ 13.03 21462
2365 3 Bermuda Goldston 4 200 200 2.5 _ 1_ SOC_ 3 03 _ _ 38 36
2365 4 Bermuda Badin 4 200 200 2.6 500 13 03 —I _ 38 36 _
I—
Mn. Amount (in.11_ Caution
_ 15.34
1" _r_
__ 1534, 0 _
15.74__—
}
Tool
Pan AppliW
�•5017.03

_ _ILAND
APPLICATION OF
WASTE
E(COPPER)
Oete & Last
Tract #
Field # Waste Cu
Application
Conversion
I Cu Index Soll Test Cu
Sol Test
I AnDliedimml
Amount in.
Factor
I Ad'ustment
Index
6/25/2008
2365
0.00
15.34
6.297
0.00
93
6/25/2008
_
= 2365
_t _
2
0.00
_ _
15.34
_ _ _
6.297
_
; 0.00
93
6/25/2008
_ -
_ _
- 3
0.00
_
15.3_4 _
6.297
_
; 0.00
93
6/2512008
_2365
u 2365
_
4
_ _
0.00
_
15.34
_
6.297
_ _
j 0.00 -
93
New Soil Cu I
_93.00 93.00 _
93.00

WA R8 C RAL
0 IE N_q.
Mant.ire Analysis
Waters Agricultural Laboratories, Inc
364 W. Park Drive I Warsaw, NC 28398- 1 Phone [phone]
.,��rovin�GYawth:.
RENEWABLE TRANSPORT
GENO KENNEDY
Grower: RENEWABLE TRANSPORT
Sample Number: 2
PO BOX 1096
Lab Number: 10539MS Received: 2/16/2024
BEULAVILLE, NC 28518-
Processed: 2/1912024
Type: Lagoon Sludge Anaerobic -Swine Application Method: Broadcast
Liquid Manure/Sludge Analysis
Analyte .."loqw,
Nitrogen -Total 16-
Result
..
1830.00
Result
Ire ,.
15.2622
Estimate of Nutrients Available First Yea],
lip gallons)
7.6311
P2O5-Total
3268.00
27.2551
27.2551
K2O-Total
644.00
5.3710
5.371
Calcium
611.00
5.0957
5.0957
Magnesium
1037.00
8.6486
8.6486
Sulfur
301.00
2.5103
2.5103
Boron
1.10
0.0092
0.0092
Zinc
62.60
0.5221
0.5221
Manganese
18.20
0.1518
0.1518
Iron
179.00
1.4929
1.4929
Copper
62.50
0.5213
0.5212
Sodium
199.00
1.6597
1.6597
Aluminum
53.00
0.4420
0.442
Results Reported On: Liquid Basis
Comments:
This document may be reproduced only in its entirety Waters Agncultural Laboratories has no conlrol over the manner in which samp;es are taken therefore. analysis is based solely on the
sample as received Laboratory liability is hm.ted to the fee assessed on the referenced sample

Z, ►,, S �JS11--
WA RH q1EC'
AL
O
Vlanure Analysis
Waters Agricultural Laboratories, Inc
364 W. Park Drive I Warsaw, NC 28398- I Phone [phone]
„I M�) r0 V i rt.0, C� rawth< .
WUi vSCW4'ta'
RENEWABLE TRANSPORT Grower: RENEWABLE TRANSPORT
GENO KENNEDY Sample Number: 1
PO BOX 1096 Lab Number: 10538MS Received: 2/1612024
BEULAVILLE, NC 28518- Processed: 2/19/2024
Type: Lagoon Sludge Anaerobic -Swine Application Method: Broadcast
Liquid Manure/Sludge Analysis
Nitrogen -Total
4770.00
39,7818
19.8909
P205-Total
12003.00
100.1050
100.105
K20-Total
1458.00
12.1597
12.1597
Calcium
3597.00
29.9990
29.999
Magnesium
3398.00
28.3393
28.3393
Sulfur
1469.00
12.2515
12.2515
Boron
4.21
0.0351
0.0351
Zinc
42.50
0.3545
0.3544
Manganese
92.40
0.7706
0.7706
Iron
912.00
7.6061
7.6061
Copper
32.60
0.2719
02719
Sodium
453.00
3.7780
3.778
Aluminum
189.00
1.5763
1.5763
Results Reported On: Liquid Basis
Comments:
This document maybe reproduced only ;nits entirety Waters Agricultural Laboratories has no control over the manner in wh ch samples are taken therefore, analysis is based solely on the
sample as received. Laboratory liability is limited to the fee assessed on the referenced sample

vA
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