HISTORICAL BEFORE 2018

Water Resources
ENVIRONMENTAL QUALITY
December 7, 2015
MICKEY LEE — MILL MANAGER
PAT MCCRORY
Govemor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
CASCADES TISSUE GROUP —NORTH CAROLINA, A DIVISION OF CASCADES HOLDING US, INC.
POST OFFICE Box 578
MIDWAY, NORTH CAROLINA 28380
Subject: Permit No. WQ0009477
Rockingham FiberClay
Distribution Program
Distribution of Class A
Industrial Byproduct
Residuals
Richmond County
Dear Mr. Lee:
In accordance with your permit renewal request received July 2, 2015, and subsequent additional
information received December 2, 2015, we are forwarding herewith Permit No. WQ0009477 dated
December 7, 2015, to Cascades Tissue Group - North Carolina, A Division of Cascades Holding US, Inc.
for the continued operation of the subject residuals management program. Please note that this renewed
permit shall become effective on January 1, 2016 (i.e. the day after the expiration date of the existing
permit).
Requests for modifications to the previous permit to be reflected in the current permit were made
and the following decisions have been made:
1. Old Condition I1.7. — There was a request to remove this condition because the C:N ratio is
greater than 100, PAN plays no role in determining the agronomic rate. Hence, the condition
is removed.
2. Old Condition II. 8. — The sodium adsorption rate requirement was removed from this permit
as the concentration of sodium, phosphorus, and magnesium are all very low. Hence, the
condition is removed.
3. Old Condition IIIA. — There was a request to clarify that electronic copy of the permit is
allowed. There is no stipulation whether copy means paper or electronic, so electronic copy is
acceptable. However, the language in Condition II1.4. and II1.5. of this permit continues to
read "copy" only.
4. Old Condition II1.6. — There was a request to remove this condition. However, the wording
matches that in rule 15A NCAC 02T A 109(b)(1) and must remain.
5. Old Condition III.7.d. — There was a request to change the wording to indicate the depth of
snow or the depth of freezing before there would be no application. The wording in the
condition exactly matches the wording in 15A NCAC 02T ,1109(b)(1)(D) and shall remain so.
Direciar
State of North Carolina j Environmental Quality I Water Resources I Water Quality Permitting I Non -Discharge Permitting
1617 Mail Service Center I Raleigh., North Carolina 27699-1617
919 807 6464

Mr. Mickey Lee
December 7, 2015
Page 2 of 5
6. Old Condition III.7.e. — There was a request to remove this condition. However, this is an
explicit requirement of 15A NCAC 02T .1109(b)(1)(E) and for that reason retrains part of
Condition 1111.7. of this permit.
7. Old Condition I11.7.£ — There was a request to remove this because it was impossible to held
measure such small amounts of rain. The wording was changed to exactly match the wording
of rule 15A NCAC 02T .I 109(b)(1)(F).
8. Old Condition 1II.7.g. — There was a request to remove this because the residual is not a liquid.
Although the residual is not a liquid, rain is. If the slope is too great, then the residuals will
still spread which is the purpose of the condition.
9. Old Condition III.7.h. — There was a request to remove this because the residuals have a high
pH. The condition was removed.
10. Old Condition III.7.i. — There was a request to remove this condition stating the condition is
new. The condition is explicitly required in rule 15A NCAC 02T .1109 and must be retained.
11. Old Condition III.7.1. — There was a request to either remove the condition or to redefine
agronomic rate based on lime equivalent. Agronomic rate is based on N, P, and lime
equivalent. The wording has been changed to indicate that for this residual lime equivalent is
controlling because it is applied in excess relative to N and P.
12. Old Condition III.8. -- There was a request to rework the condition because it placed a major
administrative burden on the Permittee. The Utilization Agreement requirements have been
reworked.
13. Old Condition III.9.a. — There was a request to remove this condition based on track record.
While the track record has been good, that is not sufficient reason for removing this condition
in the new permit.
14. Old Condition III.9.b. — There was a request to change the language of this condition. The
language has been changed to indicate that the farmer is not the one applying the residuals.
15. Old Condition II1.9.c. — There was a request to remove this condition since there is no nutrient
value. While the residuals may not have nutrient value, it has lime equivalent value and hence
a recommended application rate. The wording is changed to reflect this, but the condition is
not removed.
16. Old Condition I1I.9.e. — There was a request to state that electronic copy was permissible. As
with Old Condition II1.4., there is no stipulation as to whether the copy is paper or electronic,
and the language remains unchanged.
17. Old Condition 111.9.f. — There was a request to stipulate that the copy of the Utilization
Agreement be in the superintendent's truck. If the superintendent' truck is not on site, the
agreement is not where it needs to be. Furthermore, if the agreement is on site, it need not be
in the superintendent's truck. The language remains unchanged.
18. Old Condition 111.12.d. — There was a request to change the language based on lime equivalent.
Agronomic rates are based on N, P, and lime equivalents rather than just N. Neither N nor P
is of concern for this residual, but the lime equivalent is. The wording is changed to reflect
this.

Mr. Mickey Lee
December 7, 2015
Page 3 of 5
19. Old Condition IV.2. — There was a request to remove this condition. Testing of residuals for
corrosivity, ignitability, reactivity and toxicity is required under rules 15A NCAC 13A
.0102(b), 15A NCAC 02T .1101 and 15A NCAC 02T .1105. For this reason, it is not possible
to halt all testing despite demonstrated low concentrations of the metals and chemicals in the
residuals. Once per permit cycle is as infrequently as testing is permitted.
20. Old Condition IV.3. — There was a request to cease testing for various metals. Al, As, Cd, Ca,
P, Hg, Mo, K, Se, Na and Pb were removed as requested. In addition, the Sodium Adsorption
Ratio (SAR) was removed. Cu- and Ni- testing are as before, however, since there are
mandatory testing procedures. Although there may be very little nitrogen in the residuals, it is
still necessary to test for and report the various species of nitrogen.
21. Old Condition IV A. — There was a request to remove this condition. This remains as is.
However, in Attachment A there is no requirement for either pathogen reduction or vector
attraction reduction since the waste is not biological. The reason for having this is that it is a
standard requirement in residuals permits the Division is issuing and it serves as a flag to signal
consideration has been made for pathogen reduction and vector attraction.
22. Old Condition IV.6.d. — There was a request to change volume to weight. The product is not
liquid, hence weight rather than volume is more appropriate measure.
23. Old Condition IV.6.£ — There was a request to remove this condition. There is a C:N ratio
greater than 100, hence there is no reason to track the nitrogen application rate and the condition
is removed.
24. Old Condition VI.3. — There was a request to change volume to weight since the residual is not
liquid. Volume is changed to weight.
This permit shall be effective from January 1, 2016 until December 31, 2020, shall void Permit No.
WQ0009477 issued January 28, 2011, and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring requirements listed in Attachment A for they may
differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
Please note the following permit conditions have been removed since the last permit issuance
dated January 28, 2011:
1. Old Condition 1.2. — Conditions of meeting pathogen reduction have been fulfilled.
2. Old Condition 1I.7. — The C.N ratio is greater than 100, hence PAN requirement is not
necessary.
3. Old Condition IL8. — Sodium and the sodium adsorption ratio have not been a concern in the
residuals derived from this industrial process.
4. Old Condition I1I.7.h. — The residuals have a high pH, so there is no need for this condition.
5. Old Condition UI.9.b.i. — While this condition no longer exists, its language is incorporated in
New Condition 111.10.a.
6. Old Condition IV.6.f. — Because there is very little nitrogen in residual, there is no reason to
track.

Mr. Mickey Lee
December 7, 2015
Page 4 of 5
Please note the following permit conditions are new since the last permit issuance dated
January 28, 2011:
1. Condition II1.8.1. — Lime equivalent is applied in excess relative to N and P. Therefore, the
wording is changed to indicate that the agronomic rate depends on the lime equivalent.
2. Condition III.9. — While there was a Utilization Agreement requirement in Old Condition III.8,
the terms are very different. It is very important to understand the terms of the requirements
for the new Utilization Agreement. These differences include (1) a duration that is up to the
Permittee, Subcontractor, and those receiving the residuals rather than a limit depending on the
permit termination date; (2) ability of those receiving the residuals to end the agreement at any
time; (3) termination of the agreement if those receiving the residuals sell their land or if the
permit is rescinded; and (4) requirement that those receiving the residuals be notified of any
changes in the permit.
3. Condition III.I0.b.i. —Stockpiling for more than 60 days is allowed under certain conditions.
4. Condition IH.10.c. —There is a wording change to reflect since there is no nutrient value to the
residuals.
5. Condition III,12.d. — Agronomic rates are based on N, P, and lime equivalents rather than just
N. Neither N nor Pis of concern for this residual, but the lime equivalent is. The wording is
changed to reflect this.
6. Condition IV.3. — The list of parameters required is different in this permit than in the Old
Condition IV.3. of the 2011 permit. Aluminum, arsenic, cadmium, calcium, lead, mercury,
molybdenum, phosphorus, potassium, selenium, sodium, and the sodium adsorption ratio
(SAR) are no longer monitored since there are very low concentrations in the residuals derived
from the industrial process.
7. Condition IV.6.d. —Volume of residuals has been changed to weight of residuals since residuals
are not liquid.
8. Condition VI.3. - Volume of residuals has been changed to weight of residuals since residuals
are not liquid.

Mr. Mickey Lee
December 7, 2015
Page 5 of 5
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 troy.dobygncdenr.gov.
Sincerely,
S. Jay Zimmerman, P.G., Directo
Division of Water Resources
cc: Richmond County Health Department (Electronic Copy)
Fayetteville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Ellwood Black [eblack [e-mail]] (Electronic Copy)
Beth Buffington — Protection and Enforcement Branch (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

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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
Cascades Tissue Group — North Carolina, A Division
of Cascades Holding US, Inc.
Richmond County
FOR THE
continued operation of a residuals management program. for Cascades Tissue Group - North Carolina, A
Division of Cascades Holding US, Inc. and consisting of the distribution of Class A Industrial Byproduct
residuals generated by the approved facilities listed in Attachment A with no discharge of wastes to surface
waters, pursuant to the application received July 2, 2015, and subsequent additional information received
by the Division of Water Resources, 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 January 1, 2016 until December 31, 2020, shall void Permit No.
WQ0009477 issued January 28, 2011, and shall be subject to the following specified conditions and
limitations:
L SCHEDULES
1. 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 .0105(d), .0108(b)(2), 02T .01091
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II. PERFORMANCE STANDARDS
1. 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 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. [I SA NCAC 02B .0200,
02L .0100]
3. Only residuals generated by the facilities 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
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
Arsenic
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
2,800
[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]
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6. Setbacks for Class A land applied bulk residuals shall be as follows:
Setback Description
Setback by residual type
(feet)
Liquid
Cake*
Private or public water supply
100
100
Surface waters (streams — intermittent and perennial,
perennial waterbodies, and wetlands)
100
25
Surface water diversions (ephemeral streams,
waterways, ditches
25
0
Groundwater lowering ditches (where the bottom of
the ditch intersects the SITWT
25
0
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 .1108]
OPERATION AND MAINTENANCE REOUIREMENTS
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 Flan (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;
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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 as per Attachment A (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).
[ 15A NCAC 02T .1100]
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 III. 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]. [15A NCAC 02T .0117]
4. When the Permittee or his subcontractor 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 or his subcontractor transports or land applies bulk residuals, the spill control
provisions shall be maintained in all residuals transport and application vehicles. [15A NCAC 02T
.1110]
6. When the Permittee or his subcontractor 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 or his subcontractor 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 by the Division. [15A NCAC 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 if there is a hurricane watch, unless the bulk residuals are
injected or incorporated within a 24-hour period following a residuals land application event;
£ During precipitation events 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;
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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 or common corn -wheat -soybean rotation, cotton -soybean or corn rotation,
and continuous corn, soybean or cotton 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, e.g., based on lime equivalency.
[I5A NCAC 02T .I 109(b)(1)]
9. A Utilization Agreement between the Permittee, his subcontractor distributing and applying the
residuals, and the entity agreeing to accept Class A bulk residuals shall be in place prior to distribution
of the bulk residuals. The agreement shall specify the subcontractors and the agreeing entity's
responsibilities. The Permittee, the subcontractor, and the entity accepting the Class A bulk residuals
shall sign the Utilization Agreement. The Utilization Agreement shall have a clause allowing the
recipient of the residuals to end the Utilization Agreement at any time by notifying the Permittee in
writing. If the recipient of the residuals sells the property, the Utilization Agreement shall automatically
terminate. If the permit is rescinded, the Utilization Agreement shall automatically terminate. The
duration of the Utilization Agreement shall be one to which the Permittee, the subcontractor, and the
recipient of the residuals agree. Any changes in the agreement that are necessitated by changes in the
permit shall be mailed to the subcontractor and the recipient of the residuals by certified mail with
return receipt. The Permittee shall keep these records on file for inspection by the Division for each
Utilization Agreement while that Utilization Agreement is in force. [ 15A NCAC 02T .0108(b)(1), 02T
.1104]
10. At a minimum, the Utilization Agreement shall stipulate the following:
a. By agreeing to accept the bulk Class A residuals, it is recognized that the application of these
residuals is allowed under the conditions of this agreement including the prohibitions contained in
Condition 111.8. Land application of Class A residuals is considered the beneficial reuse of a waste
under 15A NCAC 02T .I100, and has been deemed permitted under 15A NCAC 02T .1103(4)
provided the conditions of this agreement are met. Any action resulting in damages to surface water
or groundwater, caused by failure to follow the conditions of this agreement, is subject to Division
enforcement action;
b. Application of Class A residuals shall meet the following application requirements:
Residuals shall not be stockpiled for more than 60 days (after the delivery of the last load)
unless the permittee notifies the Fayetteville Regional office and receives approval to exceed
the 60 day limit. At a minimum, the information provided shall be the location, the date that
the last load was delivered, the quantity of residuals stockpiled, the percent solids of the
residuals stockpiled, measures taken to prevent stockpile runoff (e.g. placement, perimeter
berms, etc.) and the anticipated date the residuals will be spread.
ii. Application of bulk residuals shall not occur within 100 feet of a public or private water supply
source;
iii. Application of bulk residuals shall not occur within 100 feet of any well, with the exception of
Division approved monitoring wells;
iv. Application of bulk residuals shall not occur within 25 feet of surface waters.
c. The generator of the Class A bulk residuals shall provide information on the proper use of the
residuals, including information on the recommended application rates.
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d. The applicator or party accepting bulk residuals from the Permittee shall supply all third parties
receiving bulk residuals with documentation specifying that application shall occur consistent with
the utilization agreement;
e. Instructions, including contact information for key personnel, shall be provided to the applicator or
party receiving bulk residuals in the event that any requirements specified in the utilization
agreement are not met.
f. A copy of the Utilization Agreement shall be maintained at the land application sites when bulk
residuals are being applied.
[ 15A NCAC 02T .0108(b)(1), 02T .1104]
11. 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 the
residuals recipient. If an alternate storage site is used, approval must be obtained from the Division.
[15A NCAC 02T .0108(b)(1)]
12. An information sheet shall be provided to the person who receives Class A residuals. At a minimum,
the 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 setbacks are to be observed so 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 (e.g., for lime equivalent) and
recommended rates for its intended use.
[15A NCAC 02T. I 109(a)]
13. The Permittee shall not distribute bulk residuals to any person or entity known to be applying residuals
contrary to the condition of the signed Utilization Agreement. [ 15A NCAC 02T .1103(a)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. 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)]
2. 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)l shall be performed at the
frequency specified in Attachment A, and the Permitter 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):
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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)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0.00s)
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)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
[15A NCAC 13A .0102(b), 02T .1101, 02T .1105]
3. An analysis shall be conducted on the Class A residuals 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:
Ammonia -Nitrogen
Nickel
Plant Available Nitrogen
(by calculation)
Copper
Nitrate -Nitrite Nitrogen
TKN
Magnesium
Percent Total Solids
Zinc
PH
[I5A NCAC 02T . i 1011
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 .1107, 02T .1111(c)]
5. Laboratory parameter analyses shall be performed on the residuals as they are disposed, 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 (or latitude and longitude) of recipient of residuals;
d. Weight (tons) of residuals distributed to each recipient;
e. Intended use of residuals.
WQ0009477 Version 3.0 ShelI Version 151201 Page 7 of 9

[I5A NCAC 02T .0109(a)]
7. Three copies of an annual report shall be submitted on or before March l gt. 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
hV.-/_/portal.ncdenr.org/web/wq/qps/lau/reporting, or can be obtained by contacting the Land
Application 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
f 15A NCAC 02T . I I I I (d)]
8. Noncompliance Notification
The Permittee 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 .0108(b)]
2. Prior to each bulk residuals distribution event, the Permittee or his designee shall inspect the residuals
storage, transport and application facilities to prevent malfunctions, facility deterioration and operator
errors resulting in discharges, which may cause the release of wastes to the environment, a threat to
human health or a public nuisance. The Permittee 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 Permittee 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. [I 5A
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 land application 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)]
WQ0009477 Version 3.0 Shell Version 151201 Page 8 of 9

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 land application 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 quantity (tons) 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 NCG010000; 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 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110. [ 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 71h day of December 2015
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Jay Zimmerman, P.G., Director
61 Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0009477
WQ000947 7 Version 3.0 Shell Version 151201 Page 9 of 9

THIS PAGE BLANK

ATTACHMENT A - Approved Residual Sources
Certification Date: December 7, 2015
Cascades Tissue Group - North Carolina, A Division of Cascades Holding US, Inc.
Permit Number: WQ0009477 Version: 3.0
Maximum
Monitoring
Monitoring
Monitoring
Frequency for
Approved
Owner
Facility Name
County
Permit
.Biological
Dry Tons
Frequency for
Frequency for
Pathogen &
Mineralization
Number
Residuals
per 'Year�
Non -hazardous
Metals and
Vector Attraction
t
Rate
Characteristics 2
Nutrients 3, 5
Reductions 6
Cascades Tissue Group —
North Carolina, A Division of
Rockingham Clay
Richmond
WQ0009477
No
50,000
Once per Permit
See Table Below
None
-
Cascades Holding,US, Inc.
Distribution Program
Cycle
Total
50,000
7T
1. Maximum Dry Tons per Year is the amount of residuals approved for distribution from each permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition IV.2.
3. Testing of metals and nutrients as stipulated under permit Condition IV.3.
4. Analyses of pathogen reductions as stipulated under permit. Condition IVA.
5. Monitoring frequencies are based on the actual dry tons distributed per year using the table below, unless specified above.
Dry Tons Distributed
short tons per ear
Monitoring Frequency
Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
1/Year
=>319 - <1,650
1/ Quarter (4 times per ear
=>1,650 - <16,500
1/60 Days 6 times per ear
=>16,500
1/month 12 times per ear)
6. Class A residuals are exempt from meeting vector attraction reduction requirements in Condition IVA., provided they are not mixed with residuals that have been generated during the treatment of
domestic wastewater, the treatment of animal processing wastewater, or the biological treatment of industrial wastewater. The Class A residuals must be treated and processed in a manner as not
to meet the definition of `Biological Residuals" as defined in 15A NCAC 02T .1102(6),
If no land application events occur during a required sampling period (e.g. no land application occur during an entire year when annual monitoring is required), then no
sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data. Those required to submit the annual
report to EPA may be required to make up the missed sampling, contact the EPA for additional information and clarification.
WQ0009477 Version 3.0 Attachment A Page 1 of 1

:Cascades _..
Date: Feb 20, 2015
Cascades Tissue Group — North Carolina
A Division of Cascades Holding US Inc.
805 Midway Road, P.O. Box 578, Rockingham, NC 28380 USA
Phone: [phone] Fax: [phone]
www.cascades.com * [e-mail]
To: State of North Carolina Department of Environment and Natural Resources
Division of Water Quality
Aquifer Protection Section
Land Application Unit
512 N Salisbury St.
Raleigh, North Carolina 27604
1-919-807-6300
From: Karen Bellamy-ORC and Preparer of 2014 Annual Report
Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.
805 Midway Road
Rockingham, NC 28379
1-910-895-4033 EXT 2280
1-910-895-1877 Fax
Karen Bel I amy(a)-Cascades. com
Permit # WQ0009477
Subject: Land Application Annual Report Cover Letter
Forms Included:
Cover Letter
NCDENR Dec 15, 2014 Compliance Evaluation Inspection Letter from Tony Honeycutt
Annual Land Application Certification Form DENR Form ACF
Letters from E. D. Black on Application & SAR Calculation
Excel Spreadsheets on Farmers, Field #, Rain Data, Crops, If K Soil, % Solids, Acres, Wet Tons, Dry Tons,
Dry tons per Acre.
DENR Form DMSDF and Additional Supplemental
DENR Form RSSF
DENR Form RSSF-B
Lab Results & SAR Information
TCLP, Ignitability, Reactivity, & Corrosivity
DENR Form PVRF 503
Letter on Vector Reduction
Page 1 of 2
P _.

Subject: Land Application Annual Report Cover Letter.
Cascades did get inspected in 2014 by Tony Honeycutt. No Violations.
Cascades have 1 ORC and 1 Backup at the present time. Clifton Willard just past Land Application Testing.
Cascades needs to add him to our list of Backup ORC. Mike Kopel who needs to retake the Land
Application Test this year. Once he has passes we will add him to our list as backups.
Field Inspections where conducted, equipment calibration, PM work on equipment and backup ORC
performed required inspections for the year.
Anthony Nessell attended PWC Meeting in 2014 for our Continuing Education Contact Hours. Karen
Bellamy received continuing credits from taking Biological and Physical Chemical Training with NCRWA.
Dr. Elwood Black continues to work closely with our land application Program. _
Only issues for 2014: On July 9,2014 Cascades received a call from Tony Honeycutt. Tony had received a
call from Greg Warnock who wanted to log a complaint in case his trees got damaged from Biosolids from
James Madrey Field. James Madrey land -was farmed by Dave Kunn. This is field 1904 which Cascades
spread in May of 2014. Cascades and Advanced Residual meet with Mr. Warock on July 11, 2014. Mr.
Warock was concerned about the pine trees adjacent to the access road which wasn't his land.. He said
something must be wrong with the material , because we didn't spread close to the pond. We told Mr.
Warock this is standard procedures of all NCDENR Permits. We explained what our material was and
answered any concerns he had. NCDENR Regional Office closed this complaint out. Oct 23,2014
Cascades Notified Tony Honeycutt that an Advanced Residual Employee had taken 2 to 5 gals of Bio solids
and spread it in his yard. Advanced Residuals Cleaned material up once this was discovered and
Employee no longer works for them. Also during the year we had a truck turn on the intersection of 74 and
Long Drive (i nte rsection of Burger King ) In Rockingham. A very very small amount of material fell off the
truck.-1 gal. This was cleaned up right away.
Received Salmonella Test results in Jan 20141ab tested Per 25 G instead of per 4 G. Notified Ed Hardee .
Ed Hardee said this was ok (as this was stricter than what our permit called for, and to make a note of it in
my cover letter with our Annual Report).
Advanced Residuals has worked hard to have a good program. Cascades and Advanced Residuals has
worked hard to make sure we have a good program that is Environmentally Friendly and also benefits the
farmers. We have gotten a lot of positive feedback from farmers. Duke Goodwin is the Project Manager for
Advanced Residuals project at Cascades. Mr. Goodwin has been a farmer for several years and also has
worked at the City of Rockingham WWTP, so he is very familiar with regulations.
Cascades will put in an Application to renew our current permit in 2015

Pat McCrory
Governor
A 'T i� X
NCDENR
North Carolina Department of Environment and Natural Resources
December 15, 2014
Karen V Bellamy
Cascades Tissue Group - North Carolina A Division of Cascades Holding US Inc
PO BOX 578
Rockingham NC 283800578
SUBJECT: 12/11/2014 Compliance Evaluation Inspection
Cascades Tissue Group - North Carolina A Division of Cascades Holding US Inc
Rockingham, NC Division Fiber -Clay Distribution Program
Permit No: WQ0009477
Richmond County
Dear Ms. Bellamy:
John Skvarla
Secretary
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on 12/11/2014.
The Compliance Evaluation Inspection was conducted by Tony W. Honeycutt of the Fayetteville Regional Office. The
facility was found to be in Compliance with permit WQ0009477.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any
questions, please call me at [phone].
Sincerely,
Tony W. oneycutt
Environmental Specialist
NCDENR
Division of Water Resources
Water Quality Regional Operations Section
Fayetteville Regional Office
cc: Karen V Bellamy, ORC
Central Files
Fayetteville Files
Water Quality Program - 225 Green St, Ste, 714
Fayetteville, North Carolina 28301-5095
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
An Equal Opportunity 1 Affirmative Action Employer

Permit: WQ0009477 Owner- Facility: Cascades Tissue Group - North Carolina A Division of Cascades Holding US Inc
Inspection Date: 12/11/2014 Inspection Type. Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Cascades produces a class "A" product.
The residual records were in good shape.
Ms. Bellamy is doing a good job with the management of the Cascades land application program.
Page: 2

Cornpliance Inspection Report
Permit: WQ0009477 Effective: 01/28111 Expiration: 12/31/15 Owner: Cascades Tissue Group - North Carolina A
Division of Cascades Holding US Inc
SOC: Effective: Expiration: Facility: Rockingham, NC Division Fiber -Clay Distribution Pro
County: Richmond 805 Midway Rd
Region: Fayetteville
Rockingham NC 283794101
Contact Person: Karen V Bellamy Title: ORC (2011 designation form) Phone: [phone] Ext.2280
Directions to Facility:
Travel US Hwy. 74 to US Hwy. 1 intersection. Follow US Hwy. 1 interchange. Turn west onto Midway Road. The plant is
approximately two miles from this turn
System Classifications: LA,
Primary ORC: Karen V Bellamy Certification: 19197 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 12/11/2014 Ent Time: 10:OOA Exit Time: 11:45AM
Primary Inspector: Tony W Honeyc Phone: [phone]
P
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
W Miscellaneous Questions Record Keeping
(See attachment summary)
Page: 1

permit WQ0009477 Owner - Facility: Cascades Tissue Group - North Carolina A Division of Cascades Holding US Inc
Inspection Date: 12/11/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
r
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ ® ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ IN ❑
Are there any GW quality violations?
❑ ❑ IN ❑
Is GW-59A certification form completed for facility?
❑ ❑ ® ❑
Is a copy of current permit on -site?
®❑ ❑ ❑
Are current metals and nutrient analysis available?
EN ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
IN El ❑ ❑
a. TCLP analysis?
®❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
®❑ ❑ ❑
Are PAN balances being maintained?
®❑ ❑ ❑
Are PAN balances within permit limits?
®❑ ❑ ❑
Has land application equipment been calibrated?
❑ ❑ ❑ 19
Are there pH records for alkaline stabilization?
❑ ❑ In ❑
Are there pH records for the land application site?
®❑ ❑ ❑
Are nutrient/crop removal practices in place?
NM ❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
W ❑ ❑ ❑
Are hauling records available?
IV El ❑ ❑
Are hauling records, maintained and up-to-date?
Im ❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
❑ ®❑ ❑
Has application occurred during Seasonal Restriction window?
❑ ❑ ® ❑
Comment: A complaint was registered against Cascades in 2014. Ms. Bellamy
resolved the situation with
the compiatant and ICWR considers the matter closed.
` Page: 3

ANNUAL LAND APPLICATION CERTIFICATION FORM
WQ Permit#: WQ0009477 County: Richmond Year: 2014
Cascades Tissue Group -North Carolina, a division of Cascades Holding US
Facility Name (as shown on permit): Inc.
'wand Application Operator: Karen V. Bellamy Phone:
Land pplication of residuals as allowed by the permit occurred during the past calendar year? 70—W5:,Y0 3—�?
Yes ❑ No - If No, skip Part A, and. Part B and proceed to Part C. Also, If residuals were
generated but not land applied, please attach an explanation on how the residuals were handled.
Part A - Residuals Application Summary:
Total number of application fields in thepermit:
Total number of fields utilized for land application during the year:
Total amount of dry tons applied during the year for all application sites:
26028.13955
Total number of acres utilizes for land application during the year:
Part_B - Annual Compiance Statement:
Facility was compliant during calendar year 2014 with all conditions of the land applic ion permit
(including but.not limited to items 1-13 below) issued by the Division of Water Quality. Yes ❑ No
If no please, provide a written description why the facility was not compliant, the dates, and explain, corrective action
taken.
1) Only residuals approved for this permit were applied to the permitted sites.
2) Soil pH was adjusted as specified in the permit and lime was applied (if needed) to achieve a soil pH of at least 6.0 or the
limit specified in the permit.
3) Annual soils analysis were performed on each site receiving residuals during the past calendar year and three (3) copies
of laboratory results are attached.
4) Annual TCLP analysis (if required) was performed and three (3) copies of certified laboratory results are attached.
5) All other monitoring was performed in accordance with the permit and reported during the year as required and three (3)
copies of certified laboratory results are attached.
6) The facility did not exceed any of the Pollutant Concentration Limits in 15A NCAC 02T .I 105(a) or the Pollutant
Loading Rates in 15A NCAC 02T .1105(b) (applicable to 40 CFR Part 503 regulated facilities).
7) All general requirements in as specified in the Land Application Permit were complied with (applicable to 40 CFR Part
503 regulated facilities). .
8) All monitoring and reporting requirements in 15A NCAC O2T .1111 were complied with (applicable to 40 CFR Part 503'
regulated facilities).
9) All operations and maintenance requirements in the permit were complied with or, in the case of a deviation, prior
- authorization was received from the Division of Water Quality.
10) No contravention of Ground Water Quality Standards occurred at a monitoring well or explanations of violations are
attached to include appropriate actions and remediations.
11) Vegetative cover was maintained and proper crop management was performed on each site receing residuals, as specified
in the permit.
12) No runoff of residuals from the application sites onto adjacent property or nearby surface waters has occurred.
13) All buffer requirements as specified on the permit were maintained during each application of residuals.
Part C - Certification:
"I certify, under penalty of law, that the above information is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations."
Karen V. Bellamy Environmental Manager
.''ermittee Name and Title (type or print)
Signature of Permittee Date
Duke odw � Z — Zs- J l r
Signature of Preparer* Date
(if different from Permittee)
* Preparer is defined in 40 CFR Part 503.9 (r) and 15A NCAC 02T
of Land Applier
Date
(if different from Permittee and Preparer)
.1102 (26) DENR FORM ACF (12/2006)

E. D. Black
Land Treatment ® By -Product Utilization ® Soil Remediation ©1 Vetlands ® Biofiltration
February 10, 2015
Cascades Tissue Group
POB 578
Rockingham, NC 28380
Attention: Karen Bellamy - Technical Director
Dear Ms Bellamy:
From January 1, 2014 thru December 31, 2014, FiberClay was directed only to
agricultural land. No farm field received FiberClay in a continuous year-to-year
application as defined by the North Carolina Department of Environment and
Natural Resources respective to permit WQ0009477.
These statements are based on information reported by Advanced Residuals
Management.
Sincerely:
Elwood Black, Ph.D. - Soils
P.O. Box 3244 o Cary, NC 27519-3244 ® 919-859-3805 ® FAX [phone]

February 19, 2015
Cascades Tissue Group
POB 578
Rockingham, NC 28380
Attention: Karen Bellamy - Technical Director
Dear Ms. Bellamy;
The estimated 2014 FiberClay Sodium Adsorption Ratio (SAR) based on the dry
weight calculation, grab sample and respective results is 0.32. The Cascades Tissue
Group has furnished the Na, Ca and Mg laboratory results for the FiberClay sample
SAR calculation.
Sincerely:
Elwood Black, Ph.D. - Soils

Karon Elwood Soil Tons Tons
Month - `"' dTort3 ` "^' Tons FarmeY Field Rain TYPe K '�)ids I Acres I (Wet) (I llse
Jan
Jan
Good
12/17/2014
1.3339255 _ ]Rows
Wilkens ' `
_—
1781.____
RC
NK,YW,N
F YS NP
47.0
43 a
12/17/2014
1. 0 12697 dkanS .:, -: _
-
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_
Rain Q'1IT0114 i{.0"
RC
NK,NF,N
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47.0
43 a
111812013
_ IJRobe7t
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_ t452
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Rain 01128t14 25"_Ram 01l28l14 0 25
Snow 01129/1RC
RC
47.00
44 a
1/18/2013
7/2212013
RC
INK
47.00
47.0_8__Rain
3001723
:' 1758
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1761
9102114055" _
I
RC
RC
47.0
50 a
12/17/2014
NK,YF,N
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12/17/2013
12117/2013
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105 a
_
Rain 01/10114 0,55" Rain 01/111141.05".
RC
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1/6/2014
116/2014;'
1770 _
RC
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1/8/2014
-.: ..
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RC
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12/17/2013
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01/06/14
01/06/14
RC
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1

,
01/06114
'-
1782
Rain 01/14114 0.35"
RC
NK,NF,N
W NS NP
47.0
26 a
1 /6/2014
1783 -
RC
NK,NW,N
F NS NP
47.0
15 a
RC
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2,SD-1,
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57 a
1/6/2014
1784
47.0
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47.0
174 a
12117/2013
5 765-"
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1786 -
RC
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RC
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1/14/2014
789
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1/18/2013
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RC
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Month 3867.39 1817.6733

Karon Elwood �— 7 Soil,, ToTons
Month Tbns _� To_n_5- �. Farmer Field Rain if.' '.CropAs"w^�.. Type' Acres (Wet) (Dry) Use
Feb lGood -�
1/18/2013 v=c-.: 1462}lain
11/25/2013 1723
--
02101114 0.44"
RC
NK,YW,N
F NS NP
48.70
44 a
I
I
I
RC
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YP-2
48.70
35 a
12/16/2013 1745
11612014 1767
jRain 02119M4 OAS"
I
RC
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NP
48.70
19 a
RC
NK,NP,N
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105 a
— --
j'
1129I2013 1790
Rain 02,106114 0.15" RC
�.
I
Rain. 02/01114 0.44" .. RC
NK,YW-
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48.70
43 a
NK,NW,N
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a —
}"
-- ---._—
Rain 02/01/14 0,44"
RC
NK,YW.N
F,NS,YP,
2D
48.70
48 a
1/18/2013 1799
1131/2014 1800
RC
NK,NW,N
F,NS,NP,
ditch-6
48.70
1 a
.�...__.__�
>
1/11/2014 1802
RC
Nk,NF,Y
W,NS,NP,
ditch-3
48.70
32 a
1/31/2014 1803
RC
NK,YW,N
F,NS,NP
48.70
15 a
1131/2014 v, i fl04
I
RC
NK YW-
3,NF,NS,
NP D
48.70
21 a
I ..._._._
1Rain,021111140.35E&Rain 02l211140.30"_-.
RC
Nk,YW,N
F,YS,YP-
2D4
48.70
95 a
1/11/2014 1805
1lt t/2014 1808
RC
NK,YW,Y
F,NS,Old
P
48.70
25 a
2/4l2014 1610
-
2/4/2014 1811
-
Rain 02l05/14 0.15"
RC
NK,YW,N
F,NS,NP,
ditch
48.70
27 a
RC
NK,YW,N
F,NS,NP,
ditch
48.70
13 a
�f3

e !j

LM
2/17/2014u,1638
RC
NK,YW,N
F,NS,ditc
h-3 NP
48.70
21 a
K,NF,YS,P,Y
atn 02/19/14.0,15" .`_
Grass
NS,Y
W
48.70
45 a
21 B/2014
2/19/2014
2120I2014
in 02121Md tl;3tr" "_ _ ' _'_"
Grass
K,YW-
2,NF,NS,
NP
1 48.70
26 a
Grass
NK,YW,N
F,NS,ditc
h NP
48.70
45 a
2/20/2014 •:,+.; ,y.
Grass
K,YW-
3,NF,NS,
NP
48.70
43 a
2/20/2014 044''':'
Grass
K,YW,NF,
YS P-2
48.70
30 a
a"
Ri�T 211140,30'_
Grass
NK,YW-
2,YF,YS,d
itch YP
48.70
33 a
2/6/2014 '1847_ _ .
_ ___
y ---�-------
2!6l2014 .-848
--
Grass
NK YW-
2,NF,NS,
ditch-
3 NP
48.70
16 a
Grass
NK,YW,N
F,NS,ditc
hNP
48.70
19 a
216/2014 ;N049`
2/6/2014 1850
Rain 02/26/74 0.03'
Grass
K,NW,NF,
NS NP
48.70
10 a
216/2014 1851 _
Grass
Nk,NW,N
F NS NP
48.70
7 a
III
2/2412014 1852.
am 02t26414 0.03'
Grass
NK,YW.N
F,YS,NP,
D-2
48.70
51 a
_
Z/24/2014 1853
Rain 02126 i4 U 03'
Grass
NK,YW,N
F,NS,NP,
D-2
48.70
9 a
4439.661 2162.11442

.Karen,,.:' Elwood
Month __Tons: Tons'___ Farmer -
Field
Soil S
Rain -Cron.,. .,-Type Acres
Tons Tons
(Wet) (Dry) Use
March Good
Estimate
7/22/2013
.2,8987767 -rank HOWie .....
1G16_
Rain 03/08/14 23'7", Rain 0317114 0.85", 03il7114
0.07" _
RC
K,YW,YF,
NS,YP,D-
4
46.80
800
a
3/9/2012
--------._
-
77 '7774 - Lim TOckcr
1 a,9E,
1726
7
1;?so
� R tin D3107114 0.85' , Rain 03112/14 0,02",
RC
NK,YW,N
F,NS,NP,
D4
46.80
229
a
_
�
-
Rain n31 9IM4 0,03"
17I25I2013
.. 2 2'.751331. G 1S
RC
2,NF,NS,
YP-2
46.80
3!
a
11
RC
NK,NP,N
W,NF,NS,
D-6
46.80
105
a
K,NW,NF,
111212014
02l12/14
_
RC & Grass
NS YP
46.80
36
a
1831
RC
K,NW,NF,
YS,NP,D-
3
46.80
37
a
0
-----
I
1 1Q32 ''
1842
_
i
Grass
NK,NW,N
F,NS,YP,
D
46.80
32
a
2/20/2014
Grass
W
K,Y-
3,NF,NS,
NP
46.80
43
a
2/2012014
-
-- --- --- --
Rain031031140_05" _ _j
Grass
K,YW,NF,
NSNP
46.80
15
a
__1843
.__:
j--
2120/2014
M
--
-- -- — --—
Rain 03103/14 0,05"
Grass
K,YW,NF,
YS P-2
46.80
30
a
211212014
'IQ4S
_..._
RC
K,YW,NF,
NS NP
46.80
10
a
2/21/2014
1846
Grass
S P
46.80
25
a
2/2512014
M
1855
-
Rain 03703114 0.05"
Grass
K,YW,NF,
NS NP
46.80
19
a
I
2126/2014
--
1856
pp ----- ---- ---- ----- ----1
I Rain 03103/14 0.05"
Grass
K,YW,NF,
NS NP
46.80
27
a
3/13/2012
t 1857
I
Rain 031D7114 0.85" a
Grass
4,D-3
Stay 200
feet from
state line 1
46.80
35
a
2/1212014
1862_Rain
03112J14 0,02" __
Grass
YS YP
46.80
60
a
3/12/2014
1884 ' �
Grass
K,YW,YF,
YS,YP,
Ditch-2
46.80
63
a
1865
187,:
7/22/2013
Rain 03l29/14 0 17".
RC
YF.YS,D'I
46.80
331
7/22/2013
Grass
K,YP,NW,
NFNSD
46.80
61
,� �8 ., a

01"' ,'
3/21/2014
3/21/2014
2,YF,
14,YF-
2,NF,NS,

%"�'talbnvas .Elwood I I I soilTons Tons
Month Tons Farmer Field Rain T ' K A', ti98st-, Acres Wet D Ilse
April IGood
Grass
K,NW,NF,
NS YP
46.60
82
Estimate
a
8/20/2013
166T
1I71/2013
1861
RC
NK,NF,N
W NS YP
46.60
15
a
3/12/2014
1863
Grass
K,NW,NF,
NS YP D
46.60
70
a
7/22@013
1865
-
Rain 04107114.0,63"
RC
K,NW,YF,
YS YP D
46.60
331
a
6124I2011
1870
<
Rain 04/07/14 0.63'
Grass
K,YW-
2,NF,NS,
YP D-2
46.1
181
a
61
--
`-- --- -i
Rain 04/07/14 0,63"
RC
K YW-
2,NF,NS,
YP ND
46.60
26
a
.,„.1871
Ili
6/24/2011
---
1872
—
_
Rain 04107114 0.63`
_._
Grass
K,YW,NF,
NS NP D
46.60
12
a
1873
_
Grass
K,YP,NW,
NF NS D
46.60
61
I°'4; a
7/22J2013
3121/2014
1875
Grass
K,Yw,YP-
14,YF-
2 NS D-3
46.60
185
a
3/2112014
Grass
K,YW,YP-
2,NF,NS,
ditch-3
46.60
43
a
1876
02/29/12
1877
RC
K,YW,NF,
NS YP D
46.60
25
a
3/21/2014
-----
1880
Grass
K,NW,YP,
NF,NS,D-
3
46.60
107
a
3121/2014
1882
Grass
K,YW,NF,
NS,YP,D-
3
46.60
185
a
3121/2014
1883
Grass
K,YW,NF,
NSYPYD
46.60
20
a
4/14/20t4
--
1884
--
-
Grass
K,YW,NF,
NS NP D
46.60
47
M
1
3127I2014
—
Grass
KYW
2,NF,NS,
YP D
46.60
56
a
iga
`� 1886
1887
3/21I2014
Grass
K,YW,NF,
NS,YP-
2 D
46.60
75
a
a
-
Grass
K,YW,NF,
NS,NP,N
D
46.60
37
4/15/2014
1.552913ar Avpry:Hatglor " 1888
..-_.

N
41151201
1889
Grass
K,YW,YF,
YP,NS, D
46.60
33
a
1891
Grass
NK,YW-
2,NF,NS,
YP-2
46.60
4121I2014
Grass
NK,YW-
3,NF,NS,
YP.D-3
46.60
so
a
a
1 a92
4125/2014
?
wn
RC
NK,YW-
3,NF,NS,
YP-6,D-2
—46.60--
4/2312014
1394
Rain0.02"04130114
RC
,YW,N,NF
'NS,P
46.60
188
an
4/
ti
Grass
NK,YW-
3,NF,NS,
YP3
46.60
59
an
9,
RC
K,YW,NF,
ND,
NS,YP
46.6
74
71.U3
an
iMonth
4868.15 1
2268.55791
1
0

nEKaren Elwood
"Tons --:•1 Tons Soil Tons .Ions
I Month
-� Farmer _Field Rain '- T e KI--Saltds;:j Acres Wet D Use
Ma Good
Estimate
7/22/2013
1865
Rafn A,51R 13 �.Oi32.. ..
RC
K,NW,YF,
YS YP
45.40
331 a
_
— --
4/18/2014
Grass
NK,YW
2,NF,NS,
YP-2
45.40
47 a
1891
- --
412512014
RC
NK YW-
3,NF,NS,
YP-6 D-2
45.40
203 a
_ 1893�
4123/2014
1894
RC
YW,N,NF
NS P
1aB a
4/30l2014
Grass
NK,YW-
3,NF,NS,
YP-3
45.40
59 a
1895_-
_
4/30/2014
96
Rain 05/10/14 0,22"_ _
Grass
NK,NW,N
F NS NP
45.40
15
7122/2013
J 1897_ ..
--�
7898_
Rain 05110/14 0_22 _ _
�—
Rain 051151141.97`
RC
Grass
Grass
Grass
K,NW,YF,
NS NP
EK,,Y
NK,YW,N
F,NS,YP,
D
45.40
45.40
45.40
45.40
166 Fa
29
90 a
173 a
3112/2013
518/2014
1899
5115/2014
1901 ;
1902
5/15/2014
.._....___.
Grass
NK,NF,N
W,NS,YP-
3
45.40
19 a
5/15/2014
'
^' 1903
--- ---
Grass
Nk,NW,N
FNSNP
45.40
16 a
5/15/2014
1904
----
Grass
K,YW,YF,
NS YP
45.40
as a
4/23/2014
RC
NK,NF,N
W,NS,YP-
2
45.40
102 a
`H. 1905 �
K
'"
.,ce,
4123/2014
----
RC
NK,YW-
2,NS,YP,
NF
45.40
36 a
4/2312014
RC
NK,YW,N
SNP YF
45.40
26 s
94J

W,NS,YP,
K,NF,YW,
NS.YP.ND 45.40
45.40
V ` I

I -
Karon Elwood Soil Tons Tons
Month - TonsTons Farmer Field Rain''. "•'iiYp "a T K Salidsa^ Acres Wet D Use
June
Good
Estimate
7122/2013
C ,,� •-
"-"Ise 0
RC
K,NW,YF,
YS YP
47.70
331
51291201 4
>� °.
i2ai�1P0 2, .. nb'x,r 4� ���. �i}'
Grass
3,YW-
3,YW-
18,YF,YS
D-3
47.70
356
a
s • z
'
5129I2014
"N1Hif'
�o a, t'; :
.g91T,.; m-
Grass
K,NW,YP,
NFNSD
47.70
5323.318a
43
75.401
5/29/2014
" ».
82888•
ra € +€+:: ,•
�<''1918�•+�.,. `'.
Grass
NK,NW,Y
P NF YS
47.70
a
3 r
4/1112012
IRS IMINOWNNK,YP,NF
.AB 4"?- `�
Grass
NW NS D
47.70
150
'"`�",''
4111I2012
- ••'
`51 a �`: •::
1915 '
Grass
NK,YP,NF
NW NS
47.70
41
=•
�• 2,$8692
a
41ll/2012
°'0h�' �-
191G__
Grass
NK,NW,N
P NF NS
47.70
61
293.. `
_-.__.
942
a
___--
a
4111/2012
:6 �-
d`;. ,< ,`
191$'
_.._.�.,�.._.T_�,_....._.
Rain 06111/12 0.03" `
Grass
NK,W,NP,
NS NF
47.70
29
i
'
4/11/2012
.: 3 �
A e=,,. X ���
....
1919
Grass
NK,YW,N
P NF NS
47.70
40
,.
411112012
., ,".: ..
1920'
I---
Rain 06111112 0 03"
Grass
NK,NF,Y
W NP NS
47.70
25
a
6/24/2011
y
RC
K,NW,NF,
NS NP
47.70
29
a
I
3I15/2013
1922
Grass
K,NF,YW,
NS YP D
47.70
25
a
612312014
_2:0231$63
Wa1rrto Saunders +
_ 1923 '
._..
Grass
K,YW,Yf,
YP NS D
47.70
245
a
6/2312014
1924
Grass
K,NF,NW,
YSNP
47.70
42
a
—_
_----
Month
4752.92 2267.14284

;.
Elwood
Field
Rain
._.._.._,.....
Cry
Soil
�_
Tons
Tons
Month -, V#Fada, ,,.i;
Tons
Farmer _
{ Typo K
1 Solids
Acres
(Wet)
(Dry) Use
JUN Good
Estimate
3/15/20131922
Grass
NK,YW,NF,
Yr P D
34.60
25
a
6/2312014
z;'
Grass
K,YW,Yf,
yp-
3 NS D
34.60
245
a
6123/2014
r�`ty24C' .-
Grass
K,NF,NW,
YS NP
34.60
42
a
6/30/2014
Grass
K,YW-
2,NF,YP-
5 S D
34.60
52
a
_1925
6/3012014
1926
Grass
K,NF,YW,
YP-2 NS
34.60
45
a
6130/2014
1927__.
Grass
K,NW,NF,
NP NS
34.60
13
a
613012014
1928�
Grass
K,NF,NP,
NW NS
34.60
19
a
_
6/30/2014
...��
1 J29;:_
-
Grass
K,YW,NF,
NS NP
34.60
13
a
6/3012014
—._--
1930_
Grass
K NW,YF
NS YP D
34.60
29
a
_i
6/23/2014
Grass
K,NF,YW-
2, Np ,
NS D-3
34.60
109
a
1432
3/15/2013
--
1933
-
RC
K,NW,YP,
NF NS D
34.60
16
a
1934
Grass
K,YW,NF,
NS YP D
34.60
19
a
6/30/2014
7/BI2014
r: I
07/09/14 0.37" Rain 07110114 0.12"
Grass
K,NW,NF,
NS,YP-
4 D-2
34.60
104
a
1935 —_Rain
..__ _....... .. _�._._.._..._
Grass
K,NW,NF,
NS NP
34.60
14
a
711412014
1937
7:
Rain 07/151141c04' �i
Grass
K,YW,YF,
NS YP D
34.60
70
a
----
711412014
1938__
---- ----- -
Rain _07/16114-0.02''_
Grass
K,NW,NF,
NS NP
34.60
7
a
7/14/2D14
______'__...._._...._........_......._.._......._..._..�._..__
__.._._.__-
-
07115114 1.04" Rain 0706114 0.02"
07/19114 0,08"
Rain 07116114 0.02" �
Grass
Grass
K,YW,NF,
NS,NP,D-
4
K YW,YS,
YF YP
34.60
34.60
50
66
e
wr ., .. :. as ov, ,
f -,� `"'' :.. a
1939 [Rain
" 1940 (Rain
„
1944
1945�
711412014
Grass
Grass
K,NW,NF,
NS YP
K,NW,NF,
NSNP
34.60
34.60
16
a
.. .x
.'���4 .�8.6#i"•=". a
2 a
7114/2014
7/14/2014
13

7/14/2014
6/23/2014
K,YW,NF,
1946
Grass
NS NP
34.60
27
Rain 07/21/14 0,33" Rain 0.722114 6.03", Rain
2,NS,D-
1949:
07/24/14 0.07"
Grass
3 NP
34.60
81
NO
S,YF,NS,
1950
Ra(n 07121N4 0.33" , 07/22114 0.03"
Grass
YP
34.60
96
K,NW,NF,
1951
Rain 071161140.02"
Grass
NSNP
34.60
16
---r
aria
-----_.-----------
I
r..e.
K,NF,NW,
ue n�o
va en
�o
4 0.07"
Grass 12 D,SF N I 34.60 I 103
(�) y

Tons Tona
Month j Field I Rain 7-Typep" Acres D Use
AugGood
Estimate
K,YW,Yf,
YP-
6/2312014
Grass
3 NS D
50.50
245
a
K,NW,YF,
NS,YP-
7/15/2014
Grass
2,13
50.5
73
a
K,YW„NF
,NS,YP,D-
M612014
Grass
3
50.5
84
62312014
Grass
NF,NS
50.50
65
a
K,YW-
-...,.,�
5,NF,NS,
6/2312014
�,
Grass
YP D
50.5
94
a
K,NW,NP,
712812014
1JG0�'
Grass
NS NF
50.5
16
a
K,YW,NF,
712812014
19ri3"'
Grass
NS YP D 1
50.5
57
a
- — -
K,YP,YW-
7/14/2014
1964 _ J
Grass
2 NF YS
50.5
58
a
— Rain 08101114a484
K,NW,YP,
6/23/2014
1905 �003",481tl6114 D 04.' _ _
_
Grass
NF YS
50.50
70
a
K YW-
- Rain.08/02/14 0.05'.',08104M4 0.03", 08/08/14
6,YP,D,N
6/2312014
19G6 0.04" 08/09/14 0.27"
Grass
F NS
50.50
160
a
---
K YW NP
818/2014
`",a.: s ', -`.
Grass
NS NF D
50.50
45
a
K,YW-
2,NF,NS,
81812014
Grass
YP-3 D-2
50.50
152
a
K,YP,NS,
D-
812512014
Grass
3 YW NF
50.50
119
a
K,YW-
4,YP-
2,D,NF,N
8/2612014
Grass
S
50.50
55
a
Month 14390.111
2217.00363 ????

NF S�J Tons Tons _
Month�,T%A Field Rain ;_Crap TypeK Solids-] Acres(Wet)D Use
SeptGood
Estimate
Rain 097041141.15"
Grass
K,YW-
8,NP,NF,
NS D
48.90
47
a
7/14/2014
7/14/2014
1055 ]
Rain_ 0.91041141.15_, Rain 0,02"
Grass
K,YW,NP,
NFNS
48.90
28
a
7/28/2014
1961
I Rain W05114 0,02"
Grass
K,NW,NP,
NFNS
48.90
7
Grass
7/28/2014
1962
Rain 9106114 0.02"
K,NW,NP,
NFNS
48.90
8
a
7/14/2014
---
1964
—
Rain 09104114 t1Fi'
Grass
K,YP.YW-
2NFYS
48.90
58
a
6/23/2014
1974
Rain 09/24414 0,12"
Grass
K,YW,NP,
NF NS
48.90
35
a
6/23/2014
::
',
1975
Grass
K,YW-
2,YP,YNS
NF D-2
48.90
39
a
6/25/2014
_1979
�R n09/0 t740.22
Grass
K,YP,NS,
D-
3YWNF
48.90
119
a
812612014
1980
I
Rain 09/02114 0.22"
Grass
K'YW-
4,YP-
2,D,NF,N
S
48.90
55
a
4/2312014
1981
--------�..
1982
1983
--
�1984
IRain 09108114 0.56
_
Rain 09/02114 0.22'
RC
48.90
45
a
4123I2014
FNK,NW,N
RC
48.90
98
a
Grass
K,YW,NP,
NFNS
48.90
21
_
8/2512014
-.
Rain 09108114 0,56"
RC
NK,NF,N
W NP NS
48.90
75
� r
.�9* 8 ,- , . 6 a
9/6/2014

F)q

-�-Karen
.Elwood '"Soil'
Tons
Tons
_
Month (�':; �Tons ''<.�
Tons. Farmer
Field Rain
JTvpeK
Solids;: Acres
(Wet)
(Drv) Use
Oct Good
Estimate
RC
K.
YW,NF,N
SNP D-3
44.00
19
a
3/15/2013
1868" ,
612312014
�$6$f:.'
Grass
K,NP,NW,
NF,NS
44.00
28
ag
612
Grass
K,NW,NF,
NS,YP
44.00
24
ag
6l2312014
Grass
K,W, YP,
NF NS
1 44.00
11
a
6/23/2014
_iv_jvL
Grass
K,NW,NP,
NF NS D
44.00
40
a
.Rain 10103f14 0,02"
Grass
NK,YW-
2,YP-2,D-
2 NF NS
44.00
187
a
9110l2014
a 1988
9/26/2014
------
_.,1995 _
-- _--.—_
Rain 101031140.02", 9Oil lit 40.02",1Oil 4114 0.04",
Rain 101201140.03' 10MI140.39
Grass
K,YF,YP-
9,D4,YW-
3 YS
44.00
870
a
916/2014
19E96
RC
K,P, NW,
ND NF
44.00
74
a
9N0/2014
1997
Grass
K,W P, D,
NF NS
44.00
63
9/10/2014
--...---
9998
--
Grass
K,NP,NW,
ND NF
44.00
22
a
10/10l2014
---
1999
— --
Grass
K YW YP,
ND, NF,
NS
44.00
36
a
-
------
RC
NK
NP,NW,N
F NS
44.00
37
a
4123/2014
2001
4/23/2014
—
2002 I
---- ---- --
-
RC
NK,NW,N
P NF NS
44.00
44
a
_
10112/2014
2003
f Rain 10/14114 0,04" 10115/14 0.67 :
Grass
K,W,P,F,
NS
44.00
153
a
10l12/2014
004':. T
in 1011 a114 0.6Ti 10/20114 0,03" _
Grass
K,W-
3,NP,
NF NS
44.00
54
07$83i <: a
10/12I2014
" - .i'
Grass
NK,YW-
2,YP,YF,
NS
44.00
230
-.; . _P,,,.. .$ - + 923r a
Grass
K,YW,NP,
NFNS
44.00
32
..-„14279 £L8tt76 255 a
10120/2014
200T
Grass
K,NP,NW,
ND YF NS
44.00
85
1012012014

u/G

?`.K TE'„,`i' ". Elwood (o,.:_I I I Tons 'Tons
Month Mrp
TwfiW,, Tons Farmer Field I Rain - ;t lltls s Acres Wet rr 0 Use
Nov lGood
Estimate
Grass
K,YW-
5,YP,NF,
NS
50.00
25 a
6/23/2014
9/10/2014 1 1989
Grass
K,YW,NF,
NS YP
50.00
52 a
9/26I2014 1995'
RdIO'�1111i'(t'�4b 44
Grass
9 D-4,YW
3, YS
50.00
870 ag
9I6/2014 1996 `
10/12/2014 2003
RC
K,P, W,
ND,
NF NS
50.00
74 a
Grass
K,W,P,F,
NS
50.00
153 a
lonzlzola zo08„,°'
Rain11106114031
Grass
2,YP,YF,
NS
50.00
23o ag
10/24/2014 2009 f
j
_-
Grass
K,YW-
3,D,NF,N
PNS
50.00
71 a
-._.__---- -
Rain 11/01114 0.44"
Grass
K,NP,NW,
ND,NS,NF
50.00
31 ag
9/1ono14 2010
9110/2014 '2011
Grass
K,NW NP,
ND NF
50.00
33 a
-------
9110/2014 2012
Grass
K,NW,NP,
ND NF
50.00
75 a
9/t 012014 2013
Grass
K,NW,YP,
ND NF NS
50.00
38 a
10112/2014 2014 !Rain
10/12/2014 2015 I
11106/140,31"r'
RC
2,D,NS,N
F,NK
50.00
44 ag
Grass
K,YP,YW,
NS NF
60.00
26
10/12/2014 ^' 2016
RC
NK,YW,Y
PNS NF
50.00
24 a
7128/2014 2017
6/23/2014 201R
_
Grass
K,YW,NP,
NS ND NF
50.00
77 a
Grass
K,YW,NS,
NF NS NP
50.00
23 a
i
---
1111012014 2019
-'
RC
NK,YW,N
PNS NF
50.00
13 a
---
RC
Mk,YW,Y
P,NS,YD,
NF
60.00
42 a
11/10I2014 2020.,:. .:",

11I1012014 2021'
_ , _
Grass
K,NW,NS,
NF YP ND
50.00
60
a
11/131ZU14 2022
Rain_11117114 0.86" -.
Grass
8,NP,NS,
D-2,NF
50.00
86
ag
2112/2014 2U23
Rain 11/171140.86'°
RC
D,NS,NF,
NP
50.00
12
ag
2112/2014 ,. 21724
RC
]NS,ND,NF
50.00
34
a
_
10/24/2014 2025 lRain
11117114 086"
Grass
50.00
24
ag
10124/2014 2026
Rain 11119114 0.02"
Grass
K,YW,NP,
Ns,ND,NF
50.00
24
"'-` '- ""' ag
1012412014 2027
1 Ram 11117114 0.86"
i
Grass
K,NW,NP,
NS,ND,NF
50.00
15
ag
10/24/2014 2tl28
;12aift 111191140,02"
Grass
6,YP,ND,
NS,NF
50.00
25
ag
_
-
10124/2014 2029
.__
—`—_—_
Grass
K,YW-
2,YP-
2,D,NS,N
F
50.00
24
a
10124/2014 2030
Grass
K,YW-
2,NP,-
2D YS NF
50.00
1
a
,.
Grass
K,NW,NP,
D-
4 NS NF
50.00
50
a
10I2412014 2031
10124/2014 2032
'—
Rain 11125/140.09"
Grass
K,NW,YP-
3,D,NS,N
F
50.00
57
a
1012412014 2034
Rain 11119114'0.02"
Grass
NYW,NP,
NS,D-2,F
50.00
25
ag
11110l2014 - 2035
Grass
K,YW,YP-
3,YD-
6 NS NF
50.00
62
a
a
11119I2014 2036
_ _ _
in I It25/14 0.09" __
Grass
ND NS NF
50.00
30
-
1012412014 .. .,. 2037
— —
Rain 11/26/140,87"
Grass
K,YW-
6,YP-2,D-
2 NS NF
50.00
47
a
-
10/24/2014 2036-
Grass
K,YW,YP-
2,NS,D-
3 NF
50.00
58
a
Month
4327.96 2,163.980

... .._ Soil 1 Tons Tons
Month ,�.��. ;Y"N uvi�:7oris� Farmer Field Rain ' • T K SnN s� I Acres Wet D ff=Use
Estimate
M,
,•`.
4/11/2012 ':>„ , �:'i
Grass
K,NW,NP,
NSNSNF
46.90
17 a
10/24/2014 193t
_
Grass
K,YW,YP,
ND NS NF
46.90
18 a
�tiain 12t09f14 0.02
Grass
K,YP,Yw
N,D,
NS NF
46.90
53 a
7/14/2014 1943
8/22/2014 1978
(Rain 12105114. 0.02"
Grass
2,ND,NS,
YF
46.90
57 ag
---. ----
Rain 121081140.22
-
Grass
K,NW,YD-
5,YS,NP,
NF
46.90
85 a
9/1012014 ^2000
10/24/2014 '2030
Grass
K,YW-
2,NP,D-
2 YS NF
1 46.90
67 a
11/tOf2014 2035
Grass
K,YW,YP-
3,D-
62 a
6 NS NF
46.90
9/14l2014 2039
Grass
K,NW,NP,
ND NS W
46.90
18 a
Grass
K,YW,NP,
NS,ND,NF
46.90
18 ag
10124l2014 2040
12/5/2014 2041 -
Rain 12/06/14 0,09"
Grass
2,YP,D-
2,NS,NF
46.90
38 a
12/2112014 '•> 2046
Rain 12129/140;73", 121301140.03"
RC
NK,NW,Y
P,ND,NS,
NF
46.30
80 a
d
12/1I2014 ;�054
Ra1n 12109114 n,02",Rain121081140.22"
Grass
K,YW-
4,YP-
3,NS,YD-
2NF
1 46.90
124 a
11119/2014 - 2065
Grass
K,YW,NP,
NS ND NF
46.90
9 a
11/19/2014 2056
Grass
K,YW,YP,
DNS NF
46.90
54 a
11/1912014 2057
K,YW,YP,
YD NS NF
46.90
26 a
---,--Grass
11/19/2014 2059
Grass
K,NW,NP,
NS ND NF
46.90
14 a

WL
12/5/2014 2062
RC
K,NW,NP,
YS YD NF
46.90
B
a
121512014
Grass
D,NS,NF,
NW
46.90
43
a
12/5/2014
Grass
NK,YW-
2,YP„ND,
46.90
26
a
11/10/2014 2068
Grass
PK,YW,NP,
46.90
150
a
6/23/2014 207o
Grass
46,90
24
a
'
Grass
K,YW,NP,
NS ND NF
46.90
20
lag
6/2312014 ' -. 2071���-"'
6/2312014 2072
Grass
K,YW,NP,
NS ND NF
46.90
17
a
RC
K,YW-
3,NP,NS,
ND NF
46.90
20
a
121512014
7/15/2014
Grass
K,YW,NP,
ND,NS,NF
46.90
29
kg
/F
12/11/2014
RC
K,Nf,NW,
NS,NP
46.90
15
ag
12/18/2014 2077
Grass
K,YW,YP,
YD YS NF
46.90
a4
a
12119/20' 2078
Grass
S,ND,NF,
K
46.90
25
�118.94 " ' 64 32896 ... 1 316&` t, ag
... .. _
--
1
7/15I2014 '079
12/18/2014 �,; 2080
12/11/2014 2081
Grass
K,NW,NP,
ND,NS,NF
46.90
28
.....
,, _ 11478 III' ,`3,6 4 2 1915865 �ag
__.._200 21 _.. .33 6 + 0 �8t34051:r,aH a9
.:: 670fi
a
Grass
4,NP,YD-
4,NS,NF
46.90
95
RC
K,YW,NP,
YS,YD,YF
46.90
32
Grass
K,NW,NP,
YS ND NF
46.90
36
711512014 2082
.;
..
12/21/2014 2083
----
Grass
K,YW-
6,YP-
2,YD-
3 NS NF
1 46.90
90
a
12/22/2014 2066
Ruin 12129/14 0.73'
Grass
K,YW,NP,
YD,ND,N
S NF
46,90
38
s
P 'o)N3

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
WQ PERMIT #: WQ0009477 FACILITY NAME: Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.
PHONE: [phone] COUNTY: Richmond OPERATOR: Karen V. Bellamy
FACILITY TYPE (please check one): ❑ Surface Disposal (complete Part A (Source(s) and "Residual In" Volume only) and Part C)
:Ej Distribution and Marketing (complete Parts A, B, and C)
Was the facility in operation during the past calendar year? Yes �3 No ❑ -► If No skip parts A, B, C and certify form below
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/
Bulking Agent
Residual'In
Product Out
Name(s) ,
Volume (dry tons)
Intended use(s)
January
WQ0009477
1817.6733
1817.6733
See Attached
Agricultural
February
WQ0009477
2162.11442
2162.11442
Agricultural
March
WQ0009477
2213.64
2213.64
Agricultural
April
WQ0009477
2268.5579
2268.5579
Agricultural
May
WQ0009477
2260.8746
2260.8746
Agricultural
June
WQ0009477
2267.14284
2267.14284
Agricultural
July
WQ0009477
1668.3255
1668.3255
Agricultural
August
WQ0009417
2217.00353
2217.00353
Agricultural
September
WQ0009477
2508.44286
2508.44286
Agricultural
October
WQ0009477
2196.0532
2196.0532
Agricultural
November
WQ0009477
2163.98
2163.98
Agricultural
December
WQ0009477
2284.3314
2284.3314
Agricultural
Total from FORM DMSDF (sup)
0
26028.13955 26028.13955
26028.13955 `
Totals:
Annual (dry tons):
0
26028.13955
1 26028.13955-
26028:13955
Amendment(s) used: Bulking Agent(s) used:
* If more space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Form DMSDF (Supp)l 10
Part C:
Facility was compliant during the past calendar year with all conditions of the land application permit JR Yes
(including but not limited to items 1-3 below) issued by the Division of Water Quality: ❑ No - 0 If No, Explain in Narritive
1. All monitoring was done in accordance with the permit and reported for the year as'required and three (3) copies of certified laboratory results are attached.
2. All operation and maintenance requirements were compiled with or, in the case of a deviation, prior authorization was received from the Division of Water Quality.
3. No contravention of Ground Water Quality Standards occurred at a monitoring well.
"I certify, under penalty of law, that the above information is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
i
Signature of Permittee Date Signature of Preparer** Date
(if different from Permittee)
**Preparer is defined in 40 CFR Part 503.9(r) and 15A NCAC 2T .1102 (26)
nGniQ Gnann nnncnr: (1919nnn%

CLASS A ANNUAL DISTRIBUTION AND MARKETING[SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
Q Q p g W PERMIT #: W 0009477 FACILITY NAME: Cascades Tissue Grou -North Carolina "a.division of:Cascades.Holdm US Inc:
PHONE: [phone] COUNTY: Richmond OPERATOR: Karen V:'Bellamy
FACILITY TYPE (please check one): ❑ Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
Qr Distribution and Marketing (complete Parts A, and B)
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume'(dry tons)
Recipient Information
Amendment/
Bulking Agent
Residual In
Product Out
Name(s)
Volume (dry
tons)
Intended use(s)
Jan
WQ0009477
14.5949
11.5949
Ricky Blants
11.5949
ag
WQ0009477
124.6346
124.6346
John Bridges
124.6346
ag
WQ0009477
45.9143
45.9143
Guy Bryant
45.9143
ag
WQ0009477
70.3026
70.3026
Frank Howie Jr.
70.3026
ag"
WQ0009477
5:6.3154
56.3154
Lee Grady Lowery
56.3154
ag
WQ0009477
56.4893
56.4893
Rickey Lowery
56.4893
ag
WQ0009477
1:47.862
147.862
Rickey Oxendine
147.862
ag
WQ0009477
238.1349
238.1349
Roger Pierce
- 238.1349
ag
WQ0009477
545.623
545.623
David Snook
545.623
ag
WQ0009477
520.8023
520.8023
Robert Wilkens
520.8023
ag
Totals:
Annuah(dry tons):
0
18:I7.:673'3
1817.6733'`" 1817:6733
'
Amendment(s)used: Bulking Agents) used:
* If more space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Form DMSDF,(Supp) : 10
n=nio CnMfi nnnenr

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
WQ PERMIT #: W00009477 FACILITY NAME: Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.
PHONE: [phone] COUNTY: Richmond OPERATOR: Karen V. Bellamy
FACILITY TYPE (please check one): Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
X Distribution and Marketing (complete Parts A, and B)
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
Name(s)
Volume
(dry tons)
Intended use(s)
Feb
W00009477
11.53216
11.53216
Guy Bryant
11.53216
ag
WQ0009477
80.33552
80.33552
Delton Chavis
80.33552
ag
W00009477
81.11959
81.11959
Harold Chavis
81.11959
ag
WQ0009477
247.14276
247.14276
Lacy Cummings
247.14276
ag
W00009477
82.26404
82.26404
Marion Dial
82.26404
ag
WQ0009477
81,14394
81.14394
Johnny Jordan
81.14394
ag
WQ0009477
11.48833
11.48833
Robert Lemonds
11.48833
ag
WQ0009477
23.31756
23.31756
Daniel Locklear
23.31756
ag
WQ0009477
46,48415
46.48415
Kirme Locklear
46.48415
ag
W00009477
46.5085
46.5085
Marice Locklear
46.5085
ag
W00009477
664.28748
664.28748
Terry Locklear
664.28748
ag
WQ0009477
117.86861
117.86861
Lee Grady Lowery
117.86861
ag
WQ0009477
34.69388
34.69388
Willie Lowery
34.69388
ag
WQ0009477
131.01761
131.01761
Casey McQueen
131.01761
ag
WQ0009477
46.33805
46.33805
John Mullin
46.33805
ag
WQ0009477
116.87026
116.87026
Ricky Oxendine
116.87026
ag
WQ0009477
103.61899
103.61899
Thomas Scott
103.61899
ag
WQ0009477
106.83319
106.83319
Caleb Smith
106.83319
ag
W00009477
58.49357
58.49357
Jerry Snead II
58.49357
ag
WQ0009477
70.75623
70.75623
David Snook
70.75623
ag
Totals:
Annual (dry tons):
0
2162.,11442
16 2'i>`:i:.:<'>:Gz:<'.::;»:3i`.»«
2162.114423:Sz>sr;;:,.:<:>.>#'i6>^>::.>:>!::,'s>::<"> >"., 2162. .
Amendment(s) used:
Bulking Agent(s)
used:
* If more space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Form DMSDF (Supp)l 10 1

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
WQ PERMIT #: WQ0009477 FACILITY NAME: Cascades. Tissue Group North Carolina;, a, division of Cascades Holding,VS'Inc. ,.
PHONE: [phone] COUNTY: Richmond OPERATOR: '. Karen V'. Bellam
y
FACILITY TYPE (please check one): Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
X Distribution and Marketing (complete Parts A, and B)
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
Name(s)
Volume (dry
tons)
Intended use(s)
Mar
WQ0009477
22.1832
22.1832
Guy Bryant
22.1832
ag
WQ0009477
128.51280
128.51280
Mike Greene
128.51280
ag
WQ0009477
75.80196
75.80196
Danny Griggs
75.80196
ag
WQ0009477
841.39848
841.39848
Frank Howie Jr.
841.39848
ag
WQ0009477
10.99332
10.99332
Johnny Jordan
10.99332
ag
WQ0009477
34.13592
34.13592
Willie Lowery
34.13592
ag
WQ0009477
;
161.16516
161.16516
Caleb Smith
161.16516
ag
WQ0009477
11.84976
11.84976
Jerry Snead II
11.84976
ag
WQ0009477
22.86648
22.86648
David Snook
22.86648
ag
WQ0009477
29.49804
29.49804
Randy Steele
29.49804
ag
WQ0009477
173.19744
173.19744
Jacob Tarlton
173.19744
ag
WQ0009477
319.13388
319.13388
David Traywick
319.13388
ag
WQ0009477
291.69504
291.69504
Jim Tucker
291.69504
ag
WQ0009477
91.20852
91.20852
Don Vaughn
91.20852
ag
tals:
r
Annual (dry tons):
0
2213.E 40
Amendment(s) used: I
Bulking Agent(s) used:
* If more space is required, attach additional information sheets (FORM DMSDF (supp)):
Total Number of Form DMSDF (Supp) 10
fie:,

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
WQ PERMIT #: W00009477 FACILITY NAME: Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.
PHONE: [phone] COUNTY: Richmond OPERATOR: Karen V. Bellamy
FACILITY TYPE (please check one): Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
X Distribution and Marketing (complete Parts A, and B)
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
Name(s)
Volume (dry
tons)
Intended use(s)
April
W00009477
10.48034
10.48034
Lee Berry
10.48034
ag
WQ0009477
293.93882
293.93882
Ricky Carter
293.93882
ag
WQ0009477
33.54268
33.54268
Tommy Deese
33.54268
ag
WQ0009477
217.03018
217.03018
Chris DeWitt
217.03018
ag
W00009477
109.48204
109.48204
Mike Greene
109.48204
ag
WQ0009477
109.31894
109.31894
Vann Godwin
109.31894
1 ag
W00009477
78,37188
78.37188
Carl Gordon
78.37188
ag
WQ0009477
57.4578
57.4578
Avery Haigler
57.4578
ag
WQ0009477
160.48108
160.48108
Frank Howie Jr.
160.49108
ag
`
WQ0009477
388.56012
388.56012
John Maynard
388.56012
ag
WQ0009477
30.06632
30.06632
Cecil Meachum
30.06632
ag
WQ0009477
33.89218
33.89218
Pernay Tom Preslar
33.89218
ag
WQ0009477
77.29076
77.29076
Ellen Shauf er
77.29076
ag
WQ0009477
64.94176
64.94176
1 Jacob Tarlton
64.94176
ag
WQ0009477
550.91918
550.91918
David Traywick
550.91918
ag
WQ0009477
19.38384
19.38384
Tommy Williams
19.38384
ag
WQ0009477
33.09998
33.09998
Duke Goodwin
33.09998
ag
Totals:
Annual d tons):
(dry )
0
26825 9
2 7
68 5
22682579 .:': %:>:::'?>::>:«:;::>:>::>i>>:t: i'sii?i.;<: 22 .2 79
>i ? <>S: !; ia;.y
Amendment(s) used:
Bulking Agent(s)
used:
* If more space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Forni DMSDF (Supp)l 10

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
WQ PERMIT #: W00009477 FACILITY NAME: Cascades Tissue Group -North Carolina a division of Cascades Holding US Inc.
PHONE: [phone] COUNTY: Richmond OPERATOR: Karen V. Bellamy
FACILITY TYPE (please check one): Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
x M%trihntion and Marketing (emmnlete Parts A. and B)
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
Name(s)
Volume (dry
tons)
Intended use(s)
May
WQ0009477
431.69952
431.69952
Ricky Carter
431.69952
ag
W00009477
107.28474
107.28474
Tommy Deese
107.28474
ag
W00009477
94.10966
94.10966
Chris DeWitt
94.10966
ag
W00009477
31.47128
31.47128
Carl Gordon
31.47128
a
W00009477
577.38812
577.38812
Frank Howie Jr.
577.38812
ag
WQ0009477
139.30536
139.30536
Stuart King
139.30536
ag
WQ0009477
657.99582
657.995821
Dave Kunn
657.99582
ag
WQ0009477
31.68012
31.69012
Brian Pucket
31.68012
ag
WQ0009477
90.49582
90.49582
Wilson Thomas
90.49582
ag
WQ0009477
88.11232
88.11232
011ie Greene
88,11232
ag
W00009477
11.33184
11.33184
Myers Wadley
11.33184
ag
June
W00009477
35.78454
35.78454
1 Russell Caudell
35.78454
ag
WQ0009477
11.78667
11.78667
Frank Howie Jr.
11.78667
ag
WQ0009477
844.4331
844.4331
Lem Kern
844.4331
ag
WQ0009477
48.29625
48.29625
John Maynard
48.29625
ag
W00009477
448.48494
448.48494
Wayne Saunders
448.48494
ag
WQ0009477
23.31099
23.31099
Wilson Thomas
23.31099
ag
WQ0009477
76.40109
76.40109
Myers Wadley
76.40109
ag
WQ0009477
778.64526
778.64526
Gary Welch
778.64526
ag
Totals:
Annual d tons
(dry )�
0
8 0
452 . 174
3 4528.01744
4528 0174 '2s::i•: >' '>?':»>`<»>?ir >'.' ;? ..
Amendment(s) used:
Bulking Agent(s)
used:
* If more space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Form DMSDF (Supp)l 10 1

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
WQ PERMIT #: WQ0009477 FACILITY NAME: Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.
PHONE: [phone] COUNTY: Richmond OPERATOR: Karen V. Bellamy
FACILITY TYPE (please check one): Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
Distribution and Marketinu (emmnlete Parts A_ and R1
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
i
Name(s)
Volume
(dry tons)
Intended use(s)
July
W00009477
101.0493
101.0493
Wayne Allred
101.0493
ag
WQ0009477
196.71138
196.711381
Frankie Cagle
196.71138
1 ag
WQ0009477
25.56594
25.56594
Russell Caudill
25.56594
ag
W00009477
102.50942
102.50942
Wayne Cisco
102.50942
ag
W00009477
183.26928
183.26928
Eddie Davis
183.26928
ag
W00009477
93.81098
93.81098
Brandon Hussie
93.81098
ag
WQ0009477
144.26124
144.26124
Roger Little
144.26124
ag
W00009477
279.16318
279.16318
Gary Mabe
279.16318
ag
W00009477
16.80522
16.80522
John Maynard
16.80522
ag
WQ0009477
230.38064
230.38064
Darrel Saunders
230.38064
ag
WQ0009477
294.79892
294.79892
Wayne Saunder
294.79892
ag
AugW00009477
175.70970
175.70970
Maxton Cisco
175.70970
ag
WQ0009477
243.9857
243.9857
Jerry Gillispie
243.9857
ag
W00009477
421.3417
421.3417
Kyle Gillispie
421.3417
ag
W00009477
73.7906
73.7906
Richard Kern
73.7906
ag
W00009477
68.5689 1
68.5689
Danny McNeal
68.5689
ag
WQ0009477
161.0748
161.0748
Tommy Poe
161.0748
ag
W00009477
906.85173
906.85173
Wayne Saunders
906.85173
ag
W00009477
165.68040
165.68040
Bobby Stutts
165.68040
ag
Totals:
Annual (dry tons):
0
3885.3290
3885.3290 :>' ''r:<>: ?i<! >''::?ii:::::> :::>:? is
..: .................... 3885.3290
..
Amendment(s) used:
Bulking Agent(s)
used:
. 1t more space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Form DMSDF (Supp)l 10 1

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
WQ PERMIT #: W00009477 FACILITY NAME: Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.
PHONE: [phone] COUNTY: Richmond OPERATOR: Karen V. Bellamy
FACILITY TYPE (please check one): Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
X Dictrihution and Marketing (ramnlete Pnrtc A_ and Rl
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
Name(s)
Volume (dry
tons)
Intended
use(s)
Set
W00009477
47.64327
47.64327
Maxton Chrisco
47.64327
ag
WQ0009477
229.09161
229.09161
Rickey Carter
229.09161
ag
W00009477
850.86978
850.86978
Eric Clapp
850,86978
ag
WQ0009477
106.46997
106.46997
Wayne Crisco
106.46997
ag
WQ0009477
173.83950
173.83950
Duke Goodwin
173.83950
ag
WQ0009477
47.34987
47.34987
Jerry Gillispie
47.34987
ag
WQ0009477
12.01473
12,01473
Richard Kern
12.01473
ag
W00009477
59.35482
59.35482
Mike Long
59.35482
ag
W00009477
47.58948
47.58948
Danny McNeil
47.58948
ag
WQ0009477
324.28524
324.28524
Eric McInnis
324.28524
ag
W00009477
23.93655
23.93655
Thomas Poe
23.96550
ag
WQ0009477
48.82176
48.82176
Bobby Richardson
48.82176
ag
WQ0009477
153.94209
153.94209
Wayne Saunders
153.94209
ag
WQ0009477
35.59920
35.59920
Sterling Welch
35.59920
ag
W00009477
347.63499
347.63499
Steve Williams
647.63499
ag
Totals:
Annual (dry tons):
0
Amendments) used:
Bulking Agent(s)
used:
* if more space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Form DMSDF (Supp) 10

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
WQ PERMIT #: W00009477 . FACILITY NAME: Cascades Tissue Group -North_, Carolina , a division of Cascades Holding US Inc._
PHONE: [phone] COUNTY: Richmond - OPERATOR: Karen„V. Bellamy
FACILITY TYPE (please check one): Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
X Distribution and Marketing (complete Parts A, and B)
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
Name(s)
Volume
(dry tons)
Intended use(s)
Oct
W00009477
21.30640
21.30040
Russell Caudil
21.30040
ag
WQ0009477
106.11920
106.11920
Ricky Carter
106.11920
ag
W00009477
171.34480
171.34480
Eric Clapp
171.34480
ag
W00009477
42.74160
42.74160
Duke Goodwin
42.74160
ag
W00009477
231.95040
231.95040
Wes Gillispie
231.95040
ag
WQ0009477
83.3404
83.3404
Eric McInnis
83.3404
ag
WQ0009477
360.2588
360.2588
1 Billy Needham
360.2588
ag
W00009477
798.9212
798.9212
Bobby Richardson
798.9212
ag
W00009477
211.4992
211.4992
Wayne Saunders
211.4992
ag
W00009477
50.5384
50.5384
Charles Teeter
50.5384
ag
W00009477
118.03880
118.03880
Terry Freeman
118.03880
ag
Totals:
Annual d tons):
(dry )
0
OS
2196. 320
2196.05320 ''ilia::>i<`ri$i::'?iCizsi ? ;::;<;
....:. 2196.05320
: »:><:: >: i;;i i><:i::<:> ;::>:<<:_';:
Amendment(s) used:
Bulking Agent(s)
used:
* If mare space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Form DMSDF (Supp) 10

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental' Information
WQ PERMIT #: W00009477 FACILITY NAME: Cascades Tissue,Groiu -NOrth Carolina ,a divi•Sion.ofCascades;i�iolding.U&Inc:
PHONE: [phone] COUNTY: Richmond' . ; OPERATOR:,.,.:.. .;KarerilV: Bellamy
FACILITY TYPE (please check one):! Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
X Distribution and Marketing fcomnlete Parts A. and B1
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
Name(s)
Volume
(dry tons)
Intended use(s)
Nov
W00009477
162.74000
'' 162.74000
DeWight Atkins
162.74000
ag
W00009477 !
167.27500
167.27500
Barnard Beck
167.27500
ag
W00009477
677.03500
677.03500
Terry Freeman
677.03500
ag
WQ0009477
48.09500
48.09500
Duke Goodwin.
48,09500
ag
WQ0009477
95.53000
95.53000
Gilbert Key
95.53000
ag
WQ0009477
60.61500
60.61500
Seth Lucas
%61500
ag
WQ0009477
214.95000
214.95000
Eric McInnis
214.95000
ag
WQ0009477
360.01500
360.01500
Billy Needham
360.01500
ag
W00009477
35.39000
35.39000
Thomas Poe
35.39000
ag
W00009477
107.84000
107.84000
Bobby Richardson
107.84000
ag
W00009477
69.72000
69.72000
Wayne Saunders
69.72000
ag
WQ0009477
92.58500
92.58500
Richard Seawell
9158500
ag
W00009477
72.19000
72.19000
Caleb Smith
72.19000
ag
Dee
W00009477
74.08324
74.08324
Michael Phillips
78.08324
ag
WQ0009477
22.40413
22.40413 '
Dewight Atkins
22.40413
ag
W00009477
11.36387
11.36387
Clayton Burrow
11.36387
a
WQ0009477
67.66263
67.66263
David Chrisco
67.66263
ag
WQ0009477
55.22475
55.22475
Donald Chrisco
55.22475
ag
W00009477
169.82959
169.82959
Maxton Chrisco
169.82959
ag
WQ0009477
179.07827
179.07827
Eric Clapp
179.07827
a
of 1
T a s.
Annual (dry tons):
os
0
2743 6 64
. 2 8
� 74 `6 '
3. 2648s»»»is:i>s:;:?»:i'>:��»:'»»;#>:i»>:<s:�
27 6 6.
`•:
Amendment(s) used:
Bulking Agent(s)
used:
" It more space is required, attach additional tntormatton sheets (FORM DMSDF (supp)): I Total Number of Form DMSDF (Supp)1 10 1

CLASS A ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
Supplemental Information
WQ PERMIT #: W00009477 FACILITY NAME: Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.
PHONE: [phone] COUNTY: Richmond OPERATOR: Karen V. Bellamy
FACILITY TYPE (please check one): Surface Disposal (complete Part A - "Month", "Source(s)" and "Residual In" columns only)
X Distribution and Marketing (complete Parts A, and B)
Part A*:
Part B*:
Month
Sources(s) (include NPDES # if
applicable)
Volume (dry tons)
Recipient Information
Amendment/ Bulking Agent
Residual In
Product Out
Name(s)
Volume (dry
tons)
Intended use(s)
Dec
WQ0009477
87.10268
87.10268
Paul Comer
87.10268
ag
W00009477
91.09856
91.09856
JeffDavis
91.09856
ag
WQ0009477
133.68376
133.68376
Terry Freeeman
133.68376
ag
WQ0009477
74.05041
74.05041
Duke Goodwin
74.05041
ag
W00009477
87.77335
87.77335
Tony Helton
87.77335
ag
WQ0009477
84.56539
84.56539
Doug Hudson
84.56539
ag
W00009477
54.32896
54.32896
Ronald Hussey
54.32896
ag
W00009477
93.89849
93.89849
Charles Deaton
93.89849
ag
WQ0009477
98.959
98.959
Seth Lucas
98.959
ag
WQ0009477
243.07332
243.07332
Lywood McFarlin
243.07332
ag
WQ0009477
190.92521
190.92521
Danny Queen
190.92521
ag
WQ0009477
96.28101
96.28101
Wayne Saunders
96.28101
ag
WQ0009477
103.55051
103.55051
David Sherrill
103.55051
ag
W00009477
33.7211
33.7211
Gary Welch
33.7211
ag
WQ0009477
119.63721
119.63721
Johnnie Williams
119.63721
ag
W00009477
34.06816
34.06816
Steve Williams
34.06816
ag
WQ0009477
77.9478
77.9478
Jackie Richardson
77.9478
ag
Totals:
t •
Annual (dry on s .
0
1704:G6492
1704.66492;i>:z>::>'s»<»>:<'>?#>?i::'i::>:>: 1704.66492
<
Amendment(s) used:
Bulking Agent(s) used:
* If more space is required, attach additional information sheets (FORM DMSDF (supp)): Total Number of Form DMSDF (Supp)l 10 1

i
ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Please note that your permit may contain additional parameters to be analyzed. The parameters can be reported in FORM RSSF - B
WQ Permit Number: WQ0009477
Cascades Tissue Group -North Carolina, a
Facility Name: division of Cascades Holdings US Inc.
Residual Source WQ # or WQ0009477
NPDES #:
WWTP Name:
Residual Analvsis Data
Laboratory: 1) Pace Analytical Services Inc.
2) A&L Eastern Agr. Laboratories, Inc.
3)
4)
5)
Summit
aramet)
Parameter
Conc.
Limit
m /k a
Sample or Composite Date
01/06/14
02/10/14
03/10/14
04/07/14
05/12/14
06/02/14
07/07/14
08/4/14
09/08/14
10/07/14
11/10/14
12/08/14
Percent Solids (%)
NA
47
48.7
46.8
46.6
45.4
47.7
34.6
50.5
48.9
44
50
46.9
Arsenic
75
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Cadmium
85
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Copper
4,300
9.7
10.1
19
14.2
15.7
13.4
22.6
5.5
9.9
10.9
21
11.3
Chromium
NA
1.8
2.2
5.2
2.1
2.3
3.2
4.0
2.7
5
2.8
2.9
2.90
Lead
840
0.74
ND
0.77
ND
1.2
1.5
ND
1.1
ND
2.5
3.5
2.9
Mercury
57
0.012
0.006
0.01500
0.0099
0.011
0.022
0.0025
0.0067
0.012
0.020
0.0084
0.031
Molybdenum
75
3.2
3
3.1
2.3
2.3
2.4
4.90
3.30
3.6
1.6
2.9
2.7
Nickel
420
0.73
1.3
1.4
0.96
1.4
2.4
1.9
1.1
2.8
1.4
1.6
1.5
Selenium
100
ND
ND
ND
ND
ND
ND
ND
ND
23.1
ND
ND'
ND
Zinc
7,500
78.5
88.5
196
69
91.4
342
161
86.2
59
139
86:5
177
Total Phosphorus
NA
131
182
131
114
128
133
115
124
148
155
133
131
TKN
NA
1860
1970
1700
1750
1260
1740
1980
1960
1630
2590
1760
1500
Ammonia -Nitrogen
NA
ND
41.3
ND
24
ND
37.5
ND
25.6
20.5.
ND
ND
ND
Nitrate and Nitrite
NA
ND
ND
ND
ND
ND I
ND I
ND
ND
ND
ND
ND
ND
a For surface disposal facilities the ceiling concentration limits listed in this form are not applicable. Reference the individual permit for metals limits.
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
of Pr6parer *
Date
*Preparer is defined in 40 CFR Part 503.9(r) and 15A NCAC 2T .1102 (26)
nGniR f:nRnn Dc(Zr 110i1)nna►

ANNUAL RESIDUAL SAMPLING SUMMARY FORM - B
Report all sampling analysis results for parameters not listed in FORM RSSF that are part of the WQ permit or were analyzed for over the past
calendar year. Use additional forms as needed.
WQ Permit Number: W00009477 Laboratory:
Cascades Tissue Group -North Carolina, a
Facility Name: division of Cascades Holding US Inc.
Residual Source
NPDES # or WQ1h
WWTP Name:
Recidnal Analvcic Data
WQ0009477
1) Pace Analytical Services, Inc
2) A&L Eastern Agr. Laboratories,Inc
3)
4)
5)
Summit
Sample or Com osite Date
Parameter
01/06/14
02/10/14
03/10/14
04/07/14
05/12/14
06/02/14
07/07/14
08/04/14
09/08/14
10/07/14
11/10/14
12/08/14
(mpg)
Pan Cal
558
599
510
530
378
530
594
593
493
777
528
450
Aluminum
1490
1370
1320
1210
1100
1410
1860
1410
1690
1210
1390
1590
Carbon/Nitrogen Ratio
177
172
183
164
132
185
195
117
171
144
170
173
Calcium Carbonate
440000
439000
402000
478000
444000
418000
4400000
456000
405000
271000
443000
411000
Equivalency
PH
8.2
8.5 1
7.4
7.2
8.4
.8.1
7.4
8.4
8.2
7.9
7.7
8.5
Magnesium
1540
1530
1510
1520
1300 1
1520
2080
1610
1610
1030
1770
1630
Sodium
799
729
438
450
310
467
564
380
716
440
ND
ND
Potassium
83.3
71.2
45.1
56.1
31.2
37.9
62.8
38.4
23.1
ND
ND
ND
Calcium
170000
180000
167000
185000
138000
178000
241000
180000
166000
86700
179000
173000
Calcium for SAR A&L
189000
171000
188000
Test
Sodium for SAR A&L
513
576
459
test
Magnesium for SAR
2030
1870
1840
A&L Test
>200
Ignitablilty- Summit
02/06/14
Reactivity Summit
02/06/14
ND
Corrosivity Summit
02/06/14
6.7
Total Nitrogen
1860
1 1970
1700
1750
1260
1740
1980
1 1960
1 1630
1 2590
1 1760
1500
TOC
280000
303000
313000
266000
294000
303000
287000
285000
297000
3980001
286000
290000
Volatile Solids
47800015203001555000145760015063001
520700
476000
484000
496000
689000
481000
491000
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are
significa t penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Signature of Preparer * Date
*Preparer is defined in 40 CFR Part 503.9(r) and 15A NCAC 2T .1102 (26)
MCKID ononn Deer - D i�oronna�

aceAnaljdical
www.pacelabs.com
i
i
ANALYTICAL RESULTS
Project: MONTHLY SLUDGE 116/14
Pace Project No.: 92185479
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE Lab ID: 92185479001 Collected:
Results reported on a "dry -weight" basis
Report
Parameters Results Units Limit
01/06/14 08:00
MDL DF
Received: 01/07/14 15:35 Matrix: Solid
Prepared Analyzed CAS No.
Qua]
6010 MET ICP
Analytical Method: EPA 6010 Preparation Method: EPA 3050
Aluminum
1490 mg/kg 14.6
3.8
1
01/08/14 10:10
01/08/14 21:07 7429-90-5
M1
Arsenic
ND mg/kg 1.5
0.47
1
01/08/14 10:10
01/08/14 21:07 7440-38-2
Cadmium
ND mg/kg 0.15
0.088
1
01/08/14 10:10
01/08/14 21:07 7440-43-9
Calcium
170000 mg/kg 1460
379
100
01/08/14 10:10
01/09/1414:54 7440-70-2
M6
Chromium
1.8 mg/kg 0.73
0.044
1
01/08/14 10:10
01/08/14 21:07 7440-47-3
Copper
9.7 mg/kg 0.73
0.058
1
01/08/14 10:10
01/08/14 21:07 7440-50-8
Lead
0.74 mg/kg 0.73
0.70
1
01/08/14 10:10
01/08/14 21:07 7439-92-1
Magnesium
1540 mg/kg 14.6
0.44
1
01/08/14 10:10
01/08/14 21:07 7439-95-4
Molybdenum
3.2 mg/kg 0.73
0.029
1
01/08/14 10:10
01/08/14 21:07 7439-98-7
Nickel
0.73J mg/kg 0.73
0.26
1
01/08/14 10:10
01/08/14 21:07 7440-02-0
Potassium
83.3J mg/kg 730
0.61
1
01/08/14 10:10
01/08/14 21:07 7440-09-7
M1
Selenium
ND mg/kg 1.5
0.55
1
01/08/14 10:10
01/08/14 21:07 7782-49-2
Sodium
799 mg/kg 730
0.90
1
01/08/14 10:10
01/08/14 21:07 7440-23-5
M1
Zinc
78.5 mg/kg 1.5
0.38
1
01/08/14 10:10
01/08/14 21:07 7440-66-6
7471 Mercury
Analytical Method: EPA 7471 Preparation
Method: EPA
7471
Mercury
0.012 mg/kg 0.0082 0.00016
1
01/08/1415:16
01/08/1420:58 7439-97-6
Percent Moisture
Analytical Method: ASTM D2974-87
Percent Moisture
53.1 % 0.10
0.10
1
01/09/14 08:32
160.4 Total Volatile Solids
Analytical Method: EPA 160.4
Total Volatile Solids
478000 mg/kg 10000
10000
1
01/10/14 12:27
254OG Total Percent Solids
Analytical Method: SM 2540G
Total Solids
47.0 % 0.000010
1
01/08/14 13:07
9045 pH Soil
Analytical Method: EPA 9045
pH at 25 Degrees C
8.2 Std. Units 0.10
1
01/08/14 14:49
Plant Available Nitrogen
Analytical Method:40CFR PART 432.2
Plant Available Nitrogen
558 mg/kg 1.0
1
01/15/14 16:11
N2
Total Nitrogen Calculation
Analytical Method: 40CFR PART 432.2
Nitrogen
1860 mg/kg 40.0
1
01/15/1415:15 7727-37-9
350.1 Ammonia
Analytical Method: EPA350.1
Nitrogen, Ammonia
ND mg/kg 21.3
21.3
1
01/09/14 03:28 7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
1860 mg/kg 71.0
71.0
1
01/14/14 14:33 7727-37-9
M1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 01/16/2014 11:46 AM without the written consent of Pace Analytical Services, Inc.. Page 5 of 20

aceAnalytical
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i
ANAL`1 T ICAL RESULTS
Project: MONTHLY SLUDGE 1/6/14
Pace Project No.: 92185479
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE
Lab ID: 92185479001
Collected:
01/06/14 08:00
Received: 01/07/14 15:35 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters
Results Units
Limit
MDL DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, NO2/NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg
4.1
4.1 1
01/14/14 17:38
Nitrogen, Nitrite
ND mg/kg
2.0
2.0 1
01/14/14 17:38
Nitrogen, NO2 plus NO3
ND mg/kg
4.1
4.1 1
01/14/14 17:38
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 131 mg/kg 7.3 7.3 1 01/1011415:34 7723-14-0
Date: 01/16/2014 11:46 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 20

A
Page: 1 of 1
t
Report Number: 14-008-0202
p AFL. Eastern Laboratorie
Account Number: 05755 s �g a�yry�t�pirieRpad''RfFhlnohd,Vu irifa-2323T ;(80dr74$=901 Tig,(604)271=W61
Submitted B TABITHA DACAL
Y� ,www.�least'�rn.cpm.
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal)
TABITHA M DACAL
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
Lab Number: 97379 .
Sample Id : MONTHLY SLUDGE 116/14
Total Solids
Moisture *
Total Kjeldahl Nitrogen
Calcium Carbonate Equivalent
Total Volatile Solids
C/N RATIO
Carbon (TOC)
Comments:
Project.92185479
NC CERT#257
REPORT OF ANALYSIS Date Sampled: 1/6/2014 08:00:00
Date Received: 01/08/2014 00:00
Date Reported: 01/14/2014
46.76
467600
100.0
JM
01/08/201413:59
SM-2540G
53.24
100.0
JM
01/08/201413:59
SM-2540G
0.16
1580
10.0
JM
01/09/2014 08:35
SM-4500-NH3C-TKN
44.00
440000
100
JM
01/13/2014 13:00
AOAC 955.01
48.21
482100
100.0
JM
01/08/201413:59
SM-2540G
177
1
D H
01/14/201414:45
CALCULATION
28.00
280000
100
D H
01/14/201.4 14:45
CALCULATION
All values are on a dry weight basis except as noted by -asterisk. Detection limit on all N series is on a wet basis
Our- reports and letters are for the exclusive and confidential use or our clients, and may not be reproduced in Whole or part, nor may any reference be made,
to the work, the results, or the company in any advertisinrl, news release, or other public announcements Without obtainirkq our ptior written authorization.
Debbie Holt

Page: 1 of 1
Report Number: 14-009-0219 @P,
Account Number: 05755
Submitted By: TABITHA DACAL wwwaleastern.com
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal)
TABITHA M DACAL
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
Lab Number: 97412
Sample Id: 010814-CASCADES
A&L Eastern Laboratories, Inc.
11111.11
7621 Whitepine Road Richmond, Virginia 2$237 (E04) 743-9401 Fax [phone]
Project : 92185547
NC CERT#257
REPORT OF ANALYSIS Date Sampled: 1/6/2014 08:00:00
Date Received: 01/09/2014 00:00
Date Reported: 01/14/2014
Total Solids *
47.60
476000
100.0
DH
01/10/2014 08:30
SM-2540G
Moisture *
52.40
100.0
DH
01/10/2014 08:30
SM-2540G
Total Calcium
18.90
189000
100
KM
01/10/2014 14:19
SW 6010C
Total Magnesium
0.20
2030
100
KM
01/10/2014 14:19
SW 6010C
Total Sodium
0.05
513
100
KM
01/10/2014 14:19
SW 6010C
Sodium Absorption *
0.10
CALCULATION
Comments:
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis.
Ourlvoorts and letter's are for 0"a, excdusivr, arcs confidential use cif our t"Wen&;, nand nony not be reproduced rn %6ole or'pall , 17or1r.7Y r rz;,•"er�:rr "" be rmade
Y
t0 th' o 4Yorlt, thF.. results, pr the company in ary advertrsfr;p, ne4✓s fvfease' or Other public: announcennprts ovithout cbtairrng our prior wrii0617 authon'xation.
Debbie Holt

�acue Analytical
www.pacelabs.com
f
3
I
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Project: Monthly Sludge 2/10/14
Pace Project No.: 92189489
Sample: 'SLUDGE Lab ID: 92189489001 Collected: 02/10114 10:00 Received: 02/11/14 17:20 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters Results Units Limit MDL DF Prepared Analyzed CAS No. Qua]
6010 MET ICP
Analytical Method: EPA 6010 Preparation Method: EPA 3050
Aluminum
1370 mg/kg 16.8
4.3
1
02/14/14 15:49
02/17/14 22:50 7429-90-5
Arsenic
ND mg/kg 1.7
0.54
1
02/14/14 15:49
02/17/14 22:50 7440-38-2
Cadmium
ND mg/kg 0.17
0.10
1
02/14/14 15:49
02/17/14 22:50 7440-43-9
Calcium
180000 mg/kg 1680
438
100
02/1411415:49
02/1811412:18 7440-70-2
Chromium
2.2 mg/kg 0.84
0.051
1
02/14/14 15:49
02/17/14 22:50 7440-47-3
Copper
10.1 mg/kg 0.84
0.067
1
02/14/14 15:49
02/17/14 22:50 7440-50-8
Lead
ND mg/kg 0.84
0.81
1
02/14/14 15:49
02/17/14 22:50 7439-92-1
Magnesium
1530 mg/kg 16.8
0.51
1
02/14/14 15:49
02/17/14 22:50 7439-95-4
Molybdenum
3.0 mg/kg 0.84
0.034
1
02/14/14 15:49
02/17/14 22:50 7439-98-7
Nickel
1.3 mg/kg 0.84
0.30
1
02/14/14 15:49
02/17/14 22:50 7440-02-0
Potassium
71.2J mg/kg 842
0.71
1
02/14/14 15:49
02/17/14 22:50 7440-09-7
Selenium
ND mg/kg 1.7
0.64
1
02/14/14 15:49
02/17/14 22:50 7782-49-2
Sodium
729J mg/kg 842
1.0
1
02/14/14 15:49
02/17/14 22:50 7440-23-5
Zinc
88.5 mg/kg 1.7
0.44
1
02/14/14 15:49
02/17/14 22:50 7440-66-6
7471 Mercury
Analytical Method: EPA 7471 Preparation Method: EPA 7471
Mercury
0.0060 mg/kg 0.0051 0.00010
1
02/14/1413:50
02/1411415:36 7439-97-6 B
Percent Moisture
Analytical Method: ASTM D2974-87
Percent Moisture
51.3 % 0.10
0.10
1
02/17/14 10:02
160.4 Total Volatile Solids
Analytical Method: EPA 160.4
Total Volatile Solids
506000 mg/kg 10000
10000
1
02/14/14 20:05
2540G Total Percent Solids
Analytical Method: SM 2540G
Total Solids
48.7 % 0.000010
1
02/15/14 11:32
9045 pH Soil
Analytical Method: EPA 9045
pH at 25 Degrees C
8.5 Sid. Units 0.10
1
02/12/14 10:45
Plant Available Nitrogen
Analytical Method: 40CFR PART432.2
Plant Available Nitrogen
599 mg/kg 1.0
1
02/25/14 11:23 N2
Total Nitrogen Calculation
Analytical Method: 40CFR PART 432.2
Nitrogen
1970 mg/kg 40.0
1
02/25/1411:26 7727-37-9
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
41.3 mg/kg 20.5
20.5
1
02/21/14 15:45 7664-41-7 M1
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
1970 mg/kg 64.2
64.2
1
02/21/14 12:24 7727-37-9
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 03/11/2014 12:45 PM without the written consent of Pace Analytical Services, Inc.. Page 5 of 20

aceAnaljd cal
wwWwce(abs,com
f
ANALYTICAL RESULTS
Project: Monthly Sludge 2/10/14
Pace Project No.: 92189489
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: SLUDGE
Lab ID: 92189489001 Collected:
02/10/14 10:00
Received: 02/11/14 17:20 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters
Results Units Limit
MDL DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, NO2/NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg 4.1
4.1 1
02/18/14 23:17 M1
Nitrogen, Nitrite
ND mg/kg 2.1
2.1 1
02/18/14 23:17
Nitrogen, NO2 plus NO3
ND mg/kg 4.1
4.1 1
02/18/14 23:17 M1
365.1 Phosphorus, Total
Analytical Method: EPA 365.1
Phosphorus 182 mg/kg 10.3 10.3 1 02/21/1415:18 7723-14-0 M1
Date: 03/11/2014 12:45 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 20

Page: 1 of 1
Report Number: 14-049-0215
Account Number: 05755
Y; A.&LL, Eastern Labora0 ies, Inc
7621 WhitePine Road ''Richmond, Virginia 23237' [phone] 'EdX-(6.04) 27M446i
www,aleaste.mxom
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal)
TABITHA M DACAL
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
Lab Number: 97953
Sample Id: SLUDGE
Project : 92189489001
NC CERT#257
REPORT OF ANALYSIS Date Sampled: 2/10/2014 10:00:00
Date Received: 02/18/2014 00:00
Date Reported: 02/21/2014
Total Solids *
49.55
495500
100.0
JM
02/18/2014 14:24
SM-254OG
Moisture *
50.45
100.0
JM
02/18/2014 14:24
SM-254OG
Total Kjeldahl Nitrogen
0.18
1760
10.0
JM
02/19/2014 07:50
SM-4500-NH3C-TKN
Calcium Carbonate Equivalent
43.90
439000
100
JM
02/19/2014 11:19
AOAC 955.01
Total Volatile Solids
52.03
520300
100.0
JM
02/18/2014 14:24
SM-254OG
C/N RATIO *
172
1
D H
02/21/2014 11:00
CALCULATION
Carbon (TOC) *
30.30
303000
100
D H
02/21/2014 11:00
CALCULATION
Comments:
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis.
Our reports and loiters am,. for the exclusive and confidontia; use of our clients, and may not be reproduced in whole or part, normay any roterence be made
to the: wodr, the results, or the contprirny in any advedishiq, news tehmse, or orhor public annotmcetnents without obtaining our prior written authorization.
Debbie Holt

Page: 1 of 1
Report Number: 14-049-0216
Account Number: 05755
99,
A&LEastern- Laboratories, Inc.
7621 Whitepine Road Richmond, Virginia 23237 [phone] Fax [phone]
www.aleastern.com
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal)
TABITHA M DACAL
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
Lab Number: 97954
Sample Id : SLUDGE
Project : 92189491001
NC CERT#257
REPORT OF ANALYSIS Date Sampled: 2/10/2014 10:00:00
Date Received: 02/18/2014 00:00
Date Reported: 02/21/2014
Total Solids *
47.06
470600
100.0
JM
02/18/2014 14:24
SM-2540G
Moisture *
52.94
100.0
JM
02/18/2014 14:24
SM-2540G
Total Calcium
17.10
171000
100
KM
02/19/2014 10:57
SW 6010C
Total Magnesium
0.19
1870
100
KM
02/19/2014 10:57
SW 6010C
Total Sodium
0.06
576
100
KM
02/19/2014 10:57
SW 6010C
Sodium Absorption *
0.12
CALCULATION
Comments:
QUALIFIER: THE MATRIX SPIKE WAS OUT OF LIMITS FOR "Fe" AND "Se". ALL OTHER QC DATA IS ACCEPTABLE.
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis.
Gtit' t"eporis at letters, are riyr the oxchfs W ;arar co:&f hilfItial ur>e> of of11'::G[irfts, anII nu.-ly Rot be rfi`j7tod(iced a v4hoie or I: aft, rx:r tray noy Indetra:ce be rrf adA.+
fa tho avork, the results, or the cot nparfy in any zadvertisi;7y, iivivs release. or olherpahlic atwounc ^tents [vithuftt abiaMing our pnor wrttten atltho.,tatton.
Debbie Holt

-� aeeAralytical
i wwpacelabscom
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Project: MONTHLY SLUDGE 3/10/14
Pace Project No.: 92192828
Sample: MONTHLY'SLUDGE Lab ID: 92192828001 Collected: 03/10/1413:00 Received: 03/11114 16:55 Matrix: Solid
Results reported on a "dry -weight" basis `
Report
Parameters
Results Units Limit
MDL
DF
Prepared
Analyzed CAS No.
6010 MET ICP
Analytical Method: EPA 6010 Preparation
Method: EPA 3050
Aluminum
1320 mg/kg 14.1
3.6
1
03/12/14 11:30
03/14/14 14:18 7429-90-5
Arsenic
ND mg/kg 1.4
0.45
1
03/12/14 11:30
03/14/14 14:18 7440-38-2
Cadmium
ND mg/kg 0.14
0.084
1
03/1211411:30
03/1411414:18 7440-43-9
Calcium
167000 mg/kg 703
183
50
03/12/1411:30
03114/1416:33 7440-70-2
Chromium
5.2 mg/kg 0.70
0.042
1
03/12/14 11:30
03/14/14 14:18 7440-47-3
Copper
19.0 mg/kg 0.70
0.056
1
03/12/14 11:30
03/14/14 14:18 7440-50-8
Lead
0.77 mg/kg 0.70
0.67
1
03/1211411:30
03/14/14 14:18 7439-92-1
Magnesium
1510.mg/kg 14.1
0.42
1
03/12/14 11:30
03/14/14 14:18 7439-95-4
Molybdenum
3.1 , mg/kg 0.70
0.028
1
03/12/14 11:30
03/14/14 14:18 7439-98-7
Nickel
1.4 ,mg/kg 0.70
0.25
1
03/12/14 11:30
03/14/14 14:18 7440-02-0
Potassium
45.1J mg/kg 703
0.59
1
03/12/14 11:30
03/14/14 14:18 7440-09-7
Selenium
ND mg/kg 1.4
0.53
1
03/12/14 11:30
03/14/14 14:18 7782-49-2
Sodium
438J mg/kg 703
0.87
1
03/12/14 11:30
03114/1414:18 7440-23-5
Zinc
196 mg/kg 1.4
0.37
1
0311211411:30
03/14/14 14:18 7440-66-6
7471 Mercury
Analytical Method: EPA 7471 Preparation
Method: EPA 7471
Mercury
0.015 mg/kg 0.0075
0.00015
1
03112/1416:35
03/12/1418:47 7439-97-6
Percent Moisture
Analytical Method: ASTM D2974-87
Percent Moisture
53.2 % 0.10
0.10
1
03/12/14 15:04
160.4 Total Volatile Solids
Analytical Method: EPA 160.4
Total Volatile Solids
555000 mg/kg 10000
10000
1
03/14/14 02:14
254OG Total Percent Solids
Analytical Method: SM 254OG
Total Solids
46.8 % 0.000010
1
03/12/14 10:30
9045 pH Soil
Analytical Method: EPA 9045
pH at 25 Degrees C
7.4 Std. Units 0.10
0.10
1
03/12/14 14:40
Plant Available Nitrogen
Analytical Method: 40CFR PART 432.2
Plant Available Nitrogen
510 mg/kg . 1.0
1
03/25/14 11:10
Total Nitrogen Calculation
Analytical Method: 40CFR PART 432.2
Nitrogen
1700 mg/kg 40.0
1
03/25/1411:02 7727-37-9
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
ND mg/kg 21.4
21.4
1
03/19/14 12:46 7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
1700 mg/kg 71.2
71.2
1
03/14/14 11:20 7727-37-9
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 03/25/2014 11:11 AM without the written consent of Pace Analytical Services, Inc..
Qual
B
N2
M1
Page 5 of 20

Analytical
wmv.pacelabs,com
t
ANALYTICAL RESULTS
Project: MONTHLY SLUDGE 3/10/14
Pace Project No.: 92192828
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE
Lab ID: 92192828001
Collected:
03/10/14 13:00
Received: 03/11/14 16:55 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters
Results Units
Limit
MDL DF
Prepared Analyzed CAS No. Qua]
353.2 Nitrogen, NO2/NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg
4.1
4.1 1
03/21/14 18:44
Nitrogen, Nitrite
ND mg/kg
2.0
2.0 1
03/21/14 18:44
Nitrogen, NO2 plus NO3
ND mg/kg
4.1
4.1 1
03/21/14 18:44
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 131 mg/kg 8.5 8.5 1 03/18/1411:14 7723-14-0
Date: 03/25/2014 11:11 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 20

7
Page: i of i
f r
Report Number: 14-073-02064 c�._aStrn LbQ.tpr>,e, Ji1..
Account Number: 05755 `�.x, r. ti
whlfptnsAad: Rrdhinond, u,r�niaazar ;ia7aa�.aa1 .�ait;teaa 27i
Submitted B TABITHA DACAL�
Y� <wvyw:aleast�ry;cgm`
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal)
TABITHA M DACAL
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
Lab Number: 98389
Sample Id : 9219282001
Total Solids
Moisture "
Total Kjeldahl Nitrogen
Calcium Carbonate Equivalent
Total Volatile Solids
C/N RATIO
Carbon (TOC) "
Comments:
Project : 92192828001
MONTHLY SLUDGE 3/10/14
REPORT OF ANALYSIS Date Sampled: 3/10/2014 13:00:00
Date Received: 03/13/2014 00:00
Date Reported: 03/19/2014
46.30
463000
100.0
BW
03/14/201415:00
SM-254OG
53.70
100.0
BW
03/14/201415:00
SM-2540G
0.17
1710
10.0
JM
03/17/2014 09:15
SM-4500-NH3C-TKN
40.20
402000
100
JM
03/17/2014 13:00
AOAC 955.01
53.85.
538500
100.0
BW
03/14/201415:00
SM-2540G
183
-1
D H
03/18/201416:00
CALCULATION
31.30
313000
100
D H
03/18/2014 16:00
CALCULATION
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis.
Our reports and fetters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or part nor may any reference be made
to the work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written, authorization.
Debbie Holt

4 aceAnalWical
J www.pacelabs.cam
i
ANALYTICAL RESULTS
Project: MONTHLY SLUDGE 4/7/14
Pace Project No.: 92196540
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE TEST Lab ID: 92196540001 Collected: 04/07/14 10:00 Received:' 04/08/14 17:25 Matrix: Solid
Results reported on a -dry-weight" basis
Parameters
6010 MET ICP
Aluminum
Arsenic
Cadmium
Calcium
Chromium
Copper
Lead
Magnesium
Molybdenum
Nickel
Potassium
Selenium
Sodium
Zinc
7471 Mercury
Mercury
Percent Moisture
Percent Moisture
160.4 Total Volatile Solids
Total Volatile Solids
254OG Total Percent Solids
Total Solids
9045 pH Soil
pH at 25 Degrees C
Plant Available Nitrogen
Plant Available Nitrogen
Total Nitrogen Calculation
Nitrogen
350.1 Ammonia
Nitrogen, Ammonia
351.2 Total Kjeldahl Nitrogen
Nitrogen, Kjeldahl, Total
Date: 04/23/2014 11:40 AM
Report
Results Units Limit MDL DF Prepared Analyzed CAS No. Qua]
Analytical Method: EPA 6010 Preparation Method: EPA 3050
1210 mg/kg
17.9
4.6
1
04/10/14 16:15
04/11/14 22:41
7429-90-5
ND mg/kg
1.8
0.57
1
04/10/14 16:15
04/11/14 22:41
7440-38-2
ND mg/kg
0.18
0.11
1
04/10/14 16:15
04/11/14 22:41
7440-43-9
185000 mg/kg
894
232
50
04/10/14 16:15
04/14/1412:39
7440-70-2
2.1 mg/kg
0.89
0.054
1
04/10/14 16:15
04/11/14 22:41
7440-47-3
14.2 mg/kg
0.89
0.072
1
04/10/14: 16:15
04/11/14 22:41
7440-50-8
ND mg/kg
0.89
0.86
1
04/10/14 16:15
04/11/14 22:41
7439-92-1
1520 mg/kg
17.9
0.54
1
04/10/14 16:15
04/11/14 22:41
7439-95-4
2.3 mg/kg
0.89
0.036
1
04/10/14 16:15
04/11/14 22:41
7439-98-7
0.96 mg/kg
0.89
0.32
1
04/10/14 16:15
04/11/14 22:41
7440-02-0
56AJ mgJkg
894
0.75
1
04/10/14 16:15
04/11/14 22:41
7440-09-7
B
ND mg/kg
1.8
0.68
1
04/10/14 16:15
04/11/14 22:41
7782-49-2
450J mg/kg
894
1.1
1
04/10/14 16:15
04/11/14 22:41
7440-23-5
69.0 mg/kg
1.8
0.46
1
04/1011416:15
04/11/14 22:41
7440-66-6
Analytical Method: EPA 7471
Preparation
Method: EPA 7471
0.0099 mg/kg 0.0070 0.00014
1
04/14/1422:25
04115/1416:16
7439-97-6
M1,R1
Analytical Method: ASTM D2974-87
53.4 %
0.10
0.10
1
04/14/14 18:04
Analytical Method: EPA 160.4
439000 mg/kg 10000
10000
1
04117/1413:51
D6,H1
Analytical Method: SM 2540G
46.6 % 0.000010
1
04/14/14 15:00
Analytical Method: EPA 9045
7.2 Std. Units
0.10
0.10
1
04/10/14 15:31
Analytical Method: 40CFR PART
432.2
530 mg/kg
1.0
1
04/17/1418:56
N2
Analytical Method: 40CFR PART
432.2
1750 mglkg
40.0
1
04/17/1418:41
7727-37-9
Analytical Method: EPA 350.1
24.0 mg/kg
21.5
21.5
1
04/15/1417:24
7664-41-7
M1
Analytical Method: EPA 351.2
1750 mg/kg
61.3
61.3
1
04/15/1412:30
7727-37-9
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 5 of 20

/�aceMalytical`
wwwpacelabs.com
f
ANALYTICAL RESULTS
Project: MONTHLY SLUDGE 4/7/14
Pace Project No.: 92196540
Pace Analytical Services, inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE TEST
Lab ID: 92196540001
Collected:
04/07/14 10:00
Received: 04/08/14 17:25 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters
Results Units
Limit
MDL
DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, N021NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg
4.1
4.1
1
04/16/14 17:38
Nitrogen, Nitrite
ND mg/kg
2.1
2.1
1
04/16/14 17:38
Nitrogen, NO2 plus NO3
ND mg/kg
4.1
4.1
1
04/16/14 17:38
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 114 mg/kg 5.2 5.2 1 04/15/14 15:37 7723-14-0
Date: 04/23/2014 11:40 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 20

t
Page: 1 of 1
Report Number: 14-100-0203
Account Number: 05755
Submitted By: TABITHA DACAL
A&L. Eastern Laboratories, Inc.
7621.Whiteoine Road Richmdnd; Virginia 23237 [phone] F.ax,(604j,271.6446
Wwwal®astern.com
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal)
TABITHA M DACAL
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
Lab Number: 98909
Sample Id : MONTHLY SLUDGE TEST
Total Solids
Moisture
Total Kjeldahl Nitrogen
Calcium Carbonate Equivalent
Total Volatile Solids
C/N RATIO *
Carbon (TOC)
Comments:
Project : 92196540001 - SAMPLING 4/7
NC CERT #257
REPORT OF ANALYSIS
Date Sampled: 4/7/2014 10:00:00
Date Received: 04/10/2014 00:00
Date Reported: 04/15/2014
47.67
476700
100.0
JM
04/10/201415:00
SM-2540G
52.33
100.0
JM
04/10/201415:00
SM-2540G
0.16
1620
10.0
JM
04/11/2014 08:44
SM-4500-NH3C-TKN
47.80
478000
100
JM
04/14/2014 11:30
AOAC 955.01
45.76
457600
100.0
JM
04/10/201415:00
SM-2540G
164
1
D H
04/15/2014 11:00
CALCULATION
26.60
266000
100
D H
04/15/2014 11:00
CALCULATION
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis
Our repots and letters ate for the exciuslve sand confidential use of our cfionts, and may not be reproduced in whole or part, nor may any referonce be made
to th„ work. the: results, or the: camptany in any advertising, news refr;a.;e, or other public, announcements without obtairt,•ng our prior writt ;n authorization.
Debbie Holt

Page: 1 of 1
Report Number: 14-100-0204
Account Number: 05755.
Submitted By: TABITHA DACAL Www.aleastern.com
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal)
TABITHA M DACAL
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
Lab Number: 98910
Sample Id: SAR
Total Solids *
46.65
Moisture *
53.35
Total Calcium
18.80
Total Magnesium
0.18
Total Sodium
0.05
Sodium Absorption *
0.09
Comments:
A&L Eastern Laboratories, Inc.
7621 Whitepine Road Richmond; Virginia 23237 (804) 7435401 .Fax(804) 271-MG
Project : 92196572001 - SAR 4/7/14
NC CERT #257
REPORT OF ANALYSIS Date Sampled: 4/7/2014 10:00:00
Date Received: 04/10/2014 00:00
Date Reported: 04/15/2014
466500
100.0
JM
04/10/201415:00
100.0
JM
04/10/201415:00
188000
100
KM
04/11/201415:19
1840
100
KM
04/11/201415:19
459
100
KM
04/11/201415:19
SM-2540G
SM-254OG
SW 60.10C
SW 6010C
SW 6010C
CALCULATION
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series -is on a wet basis.
AILour rK ooris and i'quer:s or(,,, for tRr exciusive, zami conf de rifial use of vor ::hoots, and Inny nor be ropYn:tUL;h�C!
to the tvork, the results, or the Company rn any advertising, news release, or other publip am?arm ernents .,'!thorn obtaining our prior ivrittrrr auttiOriZatren. -
Debbie Holt

Pace Analytical Services,, Inc.
,.f:ac�Ana�ytcal®
�6701,ConferenceDrive
`Raleigh; NC 27607
vnwrpacefatis eom;
[phone] ;.
-ANALYTICAL
RESULTS
Project: MONTHLY 5/12
Pace Project No.: 92201074
Sample: MONTH LYSL:UDGE,TEST
Lab -ID: 92201074001•' Collected:—05/12/14-14:30r•-Received:-=05/13/l416.00• Mat'nz:'Solid''
Results reported on a "dry -weight" basis
Report
Parameters
Results.. Units,. Limit
MDL
DF.,
Prepared
Analyzed °' GAS No. Qual
6010 MET ICP
Analytical Method: EPA 6010 Preparation'Meth6d`.:EPA'3050:��
-=�' .
Aluminum _
1100 mg/kg t }• 14.3
3.7
1
05/14/14'12:45
05/15/14 17:00 7429-W-'5
Arsenic >>; •;
ND mg/kg 1.4
= = 0.46
1
05/14/14,12:45
05/1511417:00 7440-38=2-r
Cadmium :. : -
ND mg/kg 0.14
0.086
1
05/14/14.12:45
05/15/1417:00` 744043'_4 `
Calcium
138000 mg/kg 716
186,
50
05/1411412:45
05116/1414:58 7440-70-2
Chromium
2.3 mg/kg 0.72
0.043-
1
05/14/1412:45
05/15/14 17:00 7440-47-3`
Copper _ =, ,; ,; ,;
15.7 mg/kg 0.72
_ : ;0.057
1
05/14/14 12:45
05/15/14 17:00 7440-50-8
Lead
11.2 mg/kg 0.72
0.69
1
05/14/14 12:45
05/15/14 17:00 7439-92-1
Magnesium
1300 mg/kg 14.3
0.43
1
05/14/14 12:45
05/15/14 17:00 7439-95-4
Molybdenum
2.3 mg/kg 0.72
0.029
1
05/1411412:45
0511511417:00 7439-98-7
Nickel
1.4 mg/kg 0.72
0.26
1
05/14/14 12:45
05/15/14 17:00 7440-02-0
Potassium
31.2J mg/kg 716
0.60
1
05/14/14 12:45
0511511417:00 7440-09-7 B
Selenium
ND mg/kg 1.4
0.54
1
05/14/14 12:45
05/15/14 17:00 7782-49-2
Sodium
310J mg/kg 716
0.89
1
0511411412:45
05/15/14 17:00 7440-23-5
Zinc
91.4 mg/kg 1.4
0.37
1
05/14/14 12:45
05115/1417:00 7440-66-6
7471 Mercury
Analytical Method: EPA 7471 Preparation
Method:
EPA 7471
Mercury
0.011 mg/kg 0.011
0.00021
1
05/14/14 20:30
05/15/14 21:14 7439-97-6 B,M1,
R1
Percent Moisture
Analytical Method: ASTM D2974-87
Percent Moisture
54.6 % 0.10
0.10
1
05/14/14 15:45
160.4 Total Volatile Solids
Analytical Method: EPA 160.4
Total Volatile Solids
503000 mg/kg 10000
10000
1
05/20/14 15:13 H1
254OG Total Percent Solids
Analytical Method: SM 2540G
Total Solids
45.4 % 0.000010
1
05/14/14 09:00
9045 pH Soil
Analytical Method: EPA 9045
pH at 25 Degrees C
8.4 Std. Units 0.10
0.10
1
05/15/14 13:00
Plant Available Nitrogen
Analytical Method: 40CFR PART 432.2
Plant Available Nitrogen
378 mg/kg 1.0
1
05/27/1416:47 N2
Total Nitrogen Calculation
Analytical Method: 40CFR PART 432.2
Nitrogen
1260 mg/kg 40.0
1
05127/1416:43 7727-37-9
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
ND mg/kg 22.4
22.4
1
05/14/14 18:26 7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
1260 mg/kg 88.2
88.2
1
05/27/14 10:23 7727-37-9
Date- 05/28/2014 10:57 AM
- REPORT. OF LABORATORY'ANi4LY.SIS
This report shall not be reproduced, except in'full,
without the written consent of Pace Analytical Services, Inc..
Page 5 of 20

aco.Analyiical
W wrpacelabs.com
{
t
ANALYTIC"
L ON"
Project: MONTHLY 5/12
Pace Project No.: 92201074
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE TEST
Lab ID:. 92201074001
Collected:
05/12/14 14:30
Received: 05/13/14 16:00 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters
Results Units
Limit
MDL DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, NO2/NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg
4.4
4.4 1
05/21/14 18:15
Nitrogen, Nitrite
ND mg/kg
2.2
2.2 1
05/21/14 18:15
Nitrogen, NO2 plus NO3
ND mg/kg
4.4
4.4 1
05/21/14 18:15
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 128 mg/kg 11.6 11.6 1 05/23/14 16:10 7723-14-0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 05/28/2014 10:57 AM without the written consent of Pace Analytical Services, Inc.. Page 6 of 20

Page: 1 of 1
Report Number: 14-134-0205 A.&L Ebste nwL borat ries, rl7C
Account Number: 05755 „a,,.;•y., .�K si.:a,oasr, Ati4;r4.�i
Submitted By: TABITHA DACAL wuNwaleastgrt);co;
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal) Project: 92201074 MONTHLY 5/14
TABITHA M DACAL NC CERT#257
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
REPORT OF ANALYSIS Date Sampled: 5/12/2014 14:30:00
Lab Number: 55348 Date Received: 05/14/2014 00:00
Sample Id : 92201074001 MONTHLY SLUDGE TEST Date Reported: 05/20/2014
Total Solids
Moisture *
Total Kjeldahl Nitrogen
Calcium Carbonate Equivalent
Total Volatile Solids
C/N RATIO *
Carbon (TOC)
Comments:
46.09
460900
100.0
JM
05/14/201413:59
SM-254OG
53.91
100.0
JM
05/14/201413:59
SM-254OG
0.22
2230
10.0
JM-
05/15/2014 08:15
SM-4500-NH3C-TKN
44.40
444000
100
JM
05/16/2014 11:55
AOAC 955.01
50.63
506300
100.0
JM
05114/201413:59
SM-2540G
132
1
D H
05/19/2014 11:00
CALCULATION
29.40
294000
100
D H
05/19/2014 11:00
CALCULATION
All values are on a dry weight.basis except as noted by asterisk. Detection limit on all N series is on a wet basis.
Our reports and letters are for the exclusive and confidential use of our clients, and may not be reproduced in whole or part, nor may any reference be made I d"Ala-, .
to the work, the results, or the company in :any advertising, news release, or other public announcements without obtaining our prior written authorization.
Debbie Holt

Pace Analytical Services, Inc.
0
aCeMalyt'ca1 6701 Conference Drive
G Raleigh, NC 27607
wtwrpacelabs.com
[phone]
1
I
r
ANALYTICAL RESULTS
Project: SAMPLING 612
Pace Project No.: 92203840
Sample: NORMALLY MONTHLY Lab ID: 92203840001 Collected: 06/02/14 07:30` 'Received: 06/03/14 16:00 Matrix: Solid,*,
SLUDGE
Results reported on a "dry -weight" basis
Report
Parameters _ Results' _ Units "' Limit` MDL DFn Prepared Analyzed.•, _CAS_N0. _ Qua]
6010 MET ICP Analytical Method: EPA 6010 Preparation Method: EPk3050
Aluminum 1410 mg/kg 19.4 5.0 1 0610611416:10 06/09/14 17:54 7429-90-5
Arsenic ND mg/kg 1.9 0.62 1 06/06/14 16:10 06/09/14 17:54 7440-38-2 °
Cadmium ND mg/kg 0.19 0.12 1 06/06/14 16:10 06/0911417:54 7440-43-9
Calcium 178000 mg/kg 388 101 20 06/06/14 16:10 06/10/1415:27, 7440-70-2
Chromium 3.2 mg/kg 0.97 0.058 1 06/06/14 16:10 06/09/14 17:54 7440-47-3
Copper 13.4 mg/kg 0.97 0.078 1 06/06/14 16:10 06/09/14 17:54 7440-50-8
Lead 1.5 mg/kg 0.97 0.93 1 06/06/14 16:10 06/09/14'17:54 7439-92-1
Magnesium 1520 mg/kg 19.4 0.58 1 06/06/14 16:10 06/09/14 17:54 7439-95-4
Molybdenum 2.4 mg/kg 0.97 0.039 1 06/06/14 16:10 06/09/14 17:54 7439-98-7
Nickel 2.4 mg/kg 0.97 0.35 1 06/06/14 16:10 06/09/14 17:54 7440-02-0
Potassium 37.9J mglkg 971 0.82 1 06106/1416:10 06109/1417:54 7440-09-7
Selenium ND mg/kg 1.9 0.74 1 06/06/14 16:10 06/09/14 17:54 7782-49-2
Sodium 467J mg/kg 971 1.2 1 06/06/14 16:10 06/09/14 17:54 7440-23-5
Zinc 342 mg/kg 1.9 0.50 1 06/06/14 16:10 06/09/14 17:54 7440-66-6
7471 Mercury Analytical Method: EPA 7471 Preparation Method: EPA 7471
Mercury 0.022 mg/kg 0.0075 0.00015 1 06/04/1413:15 06104/1414:40 7439-97-6
Percent Moisture Analytical Method: ASTM D2974-87
Percent Moisture 52.3 % 0.10 0.10 1 06/09/14 15:48
160.4 Total Volatile Solids Analytical Method: EPA 160.4
Total Volatile Solids 500000 mg/kg 10000 10000 1 06/04/14 02:55
254OG Total Percent Solids Analytical Method: SM 2540G
Total Solids 47.7 % 0.000010 1 06/09/14 11:15
9045 pH Soil Analytical Method: EPA 9045
pH at 25 Degrees C 8.1 Std. Units 0.10, 0.10 1 06/05/14 16:57
Plant Available Nitrogen Analytical Method: 40CFR PART 432.2
PlantAvailable Nitrogen 530 mg/kg 1.0 1 06/11/14 11:28 N2
Total Nitrogen Calculation Analytical Method: 40CFR PART432.2
Nitrogen 1740 mg/kg 40.0 1 06111/1411:29 7727-37-9
350.1 Ammonia Analytical Method: EPA 350.1
Nitrogen, Ammonia 37.5 mg/kg 21.0 21.0 1 06/09/14 16:47 7664-41-7
351.2 Total Kjeldahl Nitrogen Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total 1740 mg/kg 123 123 1 06/09/14 14:41 7727-37-9 M1
Date: 07/01/2014 08:38 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 5 of 20

In
�aceAnalytical'
www.paeelabs.com
a
A NALY 1 I—iAL RESULT S
Project: SAMPLING 6/2
Pace Project No.: 92203840
Pace Analytical Servicres, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: NORMALLY MONTHLY
Lab ID: 92203840001
Collected:
06/02/14 07:30
Received: 06/03/14 16:00 Matrix: Solid
SLUDGE
Results reported on a "dry -weight" basis
Report
Parameters
Results Units
Limit
MDL DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, N021NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg
4.2
4.2 1
06/10/14 23:09
Nitrogen, Nitrite
ND mg/kd
2.1
2.1 1
06/10/14 23:09
Nitrogen, NO2 plus NO3
ND mg/kg
4.2
4.2 1
06/10/14 23:09
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 133 mg/kg 12.3 12.3 1 06/10/14 13:52 7723-14-0 M1
Date: 07/01/2014 08:38 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 20

Page: 1 of 1
Report Number: 14-156-0212 (I
Account Number: 05755 990
Submitted By: TABITHA DACAL www.aleastem.com
Send To: PACE ANALYTICAL CHARLOTTE (for Tabitha Dacal)
TABITHA M DACAL
9800 KINCEY AVE - STE 100
HUNTERSVILLE , NC 28078
Lab Number: 55765
Sample Id : 92203840001
A&L. Eastern Laboratories, Inc.
U21 Whitepine Road Richmond, Virginia 23237 [phone] Fax [phone]
Project : 92203840 SAMPLING 6/2
NC CERT#257
REPORT OF ANALYSIS
Date Sampled: 6/2/2014 07:30:00
Date Received: 06/05/2014 00:00
Date Reported: 06/11/2014
Total Solids *
46.21
462100
100.0
RD
06/06/2014 14:30
SM-2540G
Moisture *
53.79
100.0
RD
06/06/2014 14:30
SM-254OG
Total Kjeldahl Nitrogen
0.16
1640
10.0
JM
06/06/2014 07:59
SM-4500-NH3C-TKN
Calcium Carbonate Equivalent
41.80
418000
100
JM
06/06/2014 13:59
AOAC 955.01
Total Volatile Solids
52.07
520700
100.0
RD
06/06/2014 14:30
SM-2540G
C/N RATIO *
185
1
D H
06/10/2014 16:00
CALCULATION
Carbon (TOC) *
30.30
303000
100
D H
06/10/2014 16:00
CALCULATION
Comments:
TOC, C/N AND CCE NOT FOR COMPLIANCE PURPOSES
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis
Our rclpods and letters are for the exclusive and ronfidontial use of our clients, anti may not he, reproduced in Thole or part, nor inay any roforonc e be made
to Ile :,voric. the, results, or the company ill any adVertislog, rrays rc tr.;ase, or otherpublic arinocrrtcEarnrerr , .vithr.,ut obtaining our Poor writton r,.)utholiz uorr.
Debbie Holt

aeeAnalytical
imv+.pacelabs,-
r
r
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
6701 Conference Drive
'Raleigh, NC 27607
[phone]
Project: July Monthly Sludge
Pace Project No.: 92208296
Sample: SLUDGE NORMAL Lab ID: 92208296001 Collected: 07/07/14 10:30" Received: 07/08/14 11:50 Matrix: Solid
MONTHLY
Results reported on a "dry -weight" basis
Report
Parameters Results Units Limit MDL DF Prepared Analyzed CAS No. Qual
6010 MET ICP
Analytical Method: EPA 6010 Preparation Method: EPA 3050
Aluminum
1860 mg/kg 23.7
6.1
1
07/09/14 16:55
07/10/14 18:12 7429-90-5
M1
Arsenic
ND mg/kg 2.4
0.76
1
07/09/14 16:55
07/10/14 18:12 7440-38-2
Cadmium
ND mg/kg 0.24
0.14
1
07/09/14 16:55
07/10/14 18:12 7440-43-9
Calcium
241000 mg/kg 1180
308
50
07/09/14 16:55
0711111414:29 7440-70-2
M6
Chromium
4.0 mg/kg 1.2
0.071
1
07/09/14 16:55
07/1011418:12 7440-47-3
Copper
22.6 mg/kg 1.2
0.095
1
07/09/14 16:55
0711011418:12 7440-50-8
Lead
ND mg/kg 1.2
1.1
1
07109/1416:55
07/1011418:12 7439-92-1
Magnesium
2080 mg/kg 23.7
0.71
1
07/09/14 16:55
07/10/14 18:12 7439-95-4
Molybdenum
4.9 mg/kg 1.2
0.047
1
07/09/14 16:55
07/10/14 18:12 7439-98-7
Nickel
1.9 mg/kg 1.2
0.43
1
07109/1416:55
07/1011418:12 7440-02-0
Potassium
62.8J mg/kg 1180
0.99
1
0710911416:55
07110/1418:12 7440-09-7
B
Selenium
ND mg/kg 2A
0.90
1
0710911416:55
07/1011418:12 7782-49-2
Sodium
564J mg/kg 1180
1.5
1
07/09/14 16:55
07/10/14 18:12 7440-23-5
Zinc
161 mg/kg 2.4
0.62
1
07109/1416:55
07/1011418:12 7440-66-6
7471 Mercury
Analytical Method: EPA7471 Preparation
Method: EPA7471
Mercury
0.0025J mg/kg 0,012 0.00024
1
07/10/14 13:00
07/14/1415:52 7439-97-6
B
Percent Moisture
Analytical Method: ASTM D2974-87
Percent Moisture
65.4 % 0.10
0.10
1
07/09/14 14:41
160.4 Total Volatile Solids
Analytical Method: EPA 160.4
Total Volatile Solids
476000 mg/kg 10000
10000
1
07/09/14 03:00
254OG Total Percent Solids
Analytical Method: SM 254OG
Total Solids
34.6 % 0.000010
1
07/09/14 10:11
9045 pH Soil
Analytical Method: EPA 9045
pH at 25 Degrees C
7.4 Std. Units 0.10
0.10
1
07/09/14 12:13
Plant Available Nitrogen
Analytical Method: 40CFR PART 432.2
Plant Available Nitrogen
594 mg/kg 1.0
1
07/15/14 17:23
N2
Total Nitrogen Calculation
Analytical Method: 40CFR PART 432.2
Nitrogen
1980 mg/kg 40.0
1
07115/1417:16 7727-37-9
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
ND mg/kg 28.9
28.9
1
07/14/14 17:14 7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
1980 mg/kg 138
138
1
07/14/14 11:42 7727-37-9
M1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 07/18/2014 01:04 PM without the written consent of Pace Analytical Services, Inc.. Page 5 of 20

ace.Analytical
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ANALYTICAL RESULTS
Pace Analytical Services, Inc.
6701 Conference Drive
F�bleigh, NC 27607
[phone]
Project: July Monthly Sludge
Pace Project No.: 92208296
Sample: SLUDGE NORMAL Lab ID: 92208296001 Collected:
07/07/14 10:30
Received: 07/08/14 11:50 Matrix: Solid
MONTHLY
Results reported on a "dry -weight" basis
Report
Parameters Results Units Limit
MDL
DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, NO2/NO3 Analytical Method: EPA 353.2
Nitrogen, Nitrate ND mg/kg 5.6
5.6
1
07/10/14 19:05
Nitrogen, Nitrite ND mg/kg 2.8
2.8
1
07/10/14 19:05
Nitrogen, NO2 plus NO3 ND mg/kg 5.6
5.6
1
07/10/14 19:05
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 115 mg/kg 17.0
17.0
1
07/15/14 15:35 7723-14-0
Date: 07/18/2014 01:04 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 20

Page: 1 of 1
Report Number: 14-190-0215
Account Number: 06534
Submitted By: JON BRADLEY
f
A&L EasternLaboratories, Inc.
' 7W •Whiteo ne Road Ri6hm6nd; Vir&ia 2323,7' (Ba4)"743=940i' Fax,(9Q4) 271-'W, 6�
www,iloasfem.com
Send To: PACE ANALYTICAL CHARLOTTE LAB (JON BRADLEY)
JON BRADLEY
9800 KINCEY AVE SUITE, 100
HUNTERSVILLE , NC 28078
Lab Number: 56374
Sample Id : 92208296001 SLUDGE NORMAL MONTHLY
Total Solids
Moisture *
Total Kjeldahl Nitrogen
Calcium Carbonate Equivalent
Total Volatile Solids
C/N RATIO *
Carbon (TOC)
Comments:
TOC, C/N, CCE NOT FOR COMPLIANCE TESTING
Project : 92208296 SLUDGE 7/7
NC CERT#257
REPORT OF ANALYSIS
Date Sampled: 7/7/2014 10:30:00
Date Received: 07/09/2014 00:00
Date Reported: 07/17/2014
46.22
462200
100.0
JM
07/09/201415:29
SM-2540G
53.78
100.0
JM
07/091201415:29
SM-2540G
0.15
1470
10.0
JM
07/10/2014 08:50
SM-4500-NH3C-TKN
44.00
440000 .
100
JM
07/10/2014 00:00
AOAC 955.01
49.36
493600
100.0
JM
07/141201415:00
SM-254OG
195
1
D H
07/17/2014 11:32
CALCULATION
28.70
287000
100
D H
07/17/2014 11:32
CALCULATION
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis
Our rc ports and !otters are for the exclusive and confidential use of our ctionts, and may not.be reproduced in whole or part, normay any reference be made
to the wort. the results, of. the comprarty in ,any advertising, news relef se, or other public announcements without obtaining out' prior written c+uthorix at!on.
Debbie Holt -

®
aceMaOcal
wxvrpacelabs.com
ANALYTICAL RESULTS
Project: August Monthly Sludge Test
Pace Project No.: 92212084
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: Monthly Sludge Test
Lab ID: 92212084001 Collected:
08/04/14
14:00
Received: 08/05/14 17:35 Matrix: Solid
Results reported on a "dry -weight"
basis
Report
Parameters
Results Units Limit
MDL
DF
Prepared
Analyzed CAS No. Qua]
6010 MET ICP
Analytical Method: EPA 6010 Preparation Method: EPA 3050
Aluminum
1410 mg/kg 18.7
4.8
1
08106/1416:20
08108/1414:47 7429-90-5
Arsenic
ND mg/kg 1.9
0.60
1
08/06/14 16:20
08/07/14 20:14 7440-38-2
Cadmium
ND mg/kg 0.19
0.11
1
08/06/14 16:20
08/07/14 20:14 7440-43-9
Calcium
180000 mg/kg 373
97.1
20
08/06/14 16:20
0810811414:50 7440-70-2
Chromium
2.7 mg/kg 0.93
0.056
1
08/06/14 16:20
08/07/14 20:14 7440-47-3
Copper
5.5 mg/kg 0.93
0.075
1
08/06/14 16:20
08/07/14 20:14 7440-50-8
Lead
1.1 mg/kg 0.93
0.90
1
08/06/14 16:20
08/07/14 20:14 7439-92-1
Magnesium
1610 mg/kg 18.7
0.56
1
08/06/14 16:20
08/07/14 20:14 7439-95-4
Molybdenum
3.3 mg/kg 0.93
0.037
1
08/06/14 16:20
08/07/14 20:14 7439-98-7
Nickel
1.1 mg/kg 0.93
0.34
1
08/06/14 16:20
08/07/14 20:14 7440-02-0
Potassium
38.4J mg/kg 934
0.78
1
08/06/14 16:20
08/07/14 20:14 7440-09-7 B
Selenium
ND mg/kg 1.9
0.71
1
08/06/14 16:20
08/07/14 20:14 7782-49-2
Sodium
380J mg/kg 934
1.2
1
08/06/14 16:20
08/07/14 20:14 7440-23-5 B
Zinc
86.2 mg/kg 1.9
0.49
1
08/06/14 16:20
08/07/14 20:14 7440-66-6
7471 Mercury
Analytical Method: EPA 7471 Preparation
Method:
EPA 7471
Mercury
0.0067J mg/kg 0.0076
0.00015
1
08/06/14 16:20
08/07/14 12:07 7439-97-6
Percent Moisture
Analytical Method: ASTM D2974-87
Percent Moisture
49.5 % 0.10
0.10
1
08/06/14 15:51
160.4 Total Volatile Solids
Analytical Method: EPA 160.4
Total Volatile Solids
484000 mg/kg 10000
10000
1
08/07/14 11:15
254OG Total Percent Solids
Analytical Method: SM 254OG
Total Solids
50.5 % 0.000010
1
08/06/14 11:46
9045 pH Soil
Analytical Method: EPA 9045
pH at 25 Degrees C
8.4 Std. Units 0.10
0.10
1
08/06/14 11:32
Plant Available Nitrogen
Analytical Method: SM 2710B
Plant Available Nitrogen
593 mg/kg 1.0
1
08/18/14 11:30 N2
Total Nitrogen Calculation
Analytical Method: TKN+NO3+NO2 Calculation
Nitrogen
1960 mg/kg 40.0
1
08/1311416:47 7727-37-9
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
25.6 mg/kg 20.6
20.6
1
08/07/14 17:13 7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
1960 mg/kg 187
93.4
5
08/13/14 15:34 7727-37-9 M1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 09/03/2014 02:16 PM without the written consent of Pace Analytical Services, Inc.. Page 5 of 20

aceAnalytical
w%wp-elabs.c.&n
f
t
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Project: August Monthly Sludge Test
Pace Project No.: 92212084
Sample: Monthly Sludge Test Lab ID: 92212084001 Collected:
08/04/14 14:00
Received: 08/05/14 17:35 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters Results Units Limit
MDL
DF
Prepared Analyzed CAS No. Qua]
353.2 Nitrogen, N021NO3 Analytical Method: EPA 353.2
Nitrogen, Nitrate ND mg/kg 3.8
3.8
1
08/12/14 16:08
Nitrogen, Nitrite ND mg/kg 1.9
1.9
1
08/12/14 16:08
Nitrogen, NO2 plus NO3 ND mg/kg 3.8
3.8
1
08/12/14 16:08
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 124 mg/kg 5.3
2.7
1
08/14/14 16:14 7723-14-0 M1
Date: 09/03/2014 02:16 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 20

f
„ _ l
Page: 1 of 1
Report Number: 14-219-02099
Il
Account Number: 06534'
�.
Submitted By: JON BRADLEY wWwaleast`ern.com
Send To: PACE ANALYTICAL CHARLOTTE LAB (JON BRADLEY)
JON BRADLEY
9800 KINCEY AVE SUITE 100
HUNTERSVILLE , NC 28078
Lab Number: 56922
Sample Id : 92212084001
Total Solids "
49.24
Moisture "
50.76
Total Kjeldahl Nitrogen
0.24
Calcium Carbonate Equivalent
45.60
Total Volatile Solids
49.02
C/N RATIO *
117
Carbon (TOC) *
28.50
Comments:
CCE, C/N, TOC NOT FOR COMPLIANCE PURPOSES
6AL, Eastern LOorra:tories, lnc:
1W Whiteploe ROW R1cho16hd", Vir­0iaia`23237-(8.04) 743.940 F.4X,[phone]
Project: 92212084 AUG MONTHLY SLUDGE TEST
NC CERT#257
REPORT OF ANALYSIS
Date Sampled: 8/4/2014 14:00:00
Date Received: 08/07/2014 00:00
Date Reported: 08/13/2014
492400
100.0
RD
08/07/201414:30
SM-254OG
100.0
RD
08/07/201414:30
SM-2540G
2440
10.0
JM
05/11/2014 09:45
SM-4500-NH3C-TKN
456000
100
JM
08/11/2014 15:20
AOAC 955.01
490200
100.0
RD
08/07/201414:30
SM-2540G
1
D H
CALCULATION
285000
100
D H
CALCULATION
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis
Our repods and letters -am for the exclusive, and confidential use of our clients, and may not be reproducedin whole: or part, not, may any reference be made
to the t-voh<. the results, or the comp airy in rmy actveriis6xl, news releiIse, or other public announcernents without obtaining our prior written authorizetion.
Debbie Holt
, 63 L (�� -,

aceAnalXical
ww-wpacelabs:co n
r
ANALYTICAL -RESULTS
Project: Monthly Sludge September
Pace Project No.: 92216704
Pace Analytical Services, Inc.
6701 Conference Drive
',kaleigFi,-NC 27607
- (919)8344984
Sampler Monthly Sludge Lab ID: 92216704001 Collected:-09/08/14 13:30 Received: 09/09/14 16:30 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters Results Units Limit MDL DF Prepared Analyzed -, CAS No. Qual
6010 MET ICP Analytical Method: EPA 6010 Preparation Method: EPA 3050
Aluminum
1690 mg/kg
13.1
3.4
1
09/10/14 16:45
09/12/14 20:31
7429-90-5
Arsenic
ND mg/kg
1.3
0.42
1
09/10/14 16:45
09/12/14 20:31
7440-38-2
Cadmium
ND mg/kg
0.13
0.079
1
09/10/14 16:45
09/12/14 20:31
7440-43-9
Calcium
166000 mg/kg
1310
341
100
09110/1416:45
09/15/14 16:10
7440-70-2
Chromium
5.0 mg/kg
0.66
0.039
1
09/10/14 16:45
09/12/14 20:31
7440-47-3
Copper
9.9 mg/kg
0.66
0.052
1
09/10/14 16:45
09/12/14 20:31
7440-50-8
Lead :
ND mg/kg
0.66
0.63
1
09/10/14 16:45
09/12/14 20:31
7439-92-1
Magnesium
1610 mg/kg
13.1
0.39
1
09/10/14 16:45
09/12/14 20:31
7439-95-4
Molybdenum
3.6 mg/kg
0.66
0.026
1
09/10/14 16:45
09/12/14 20:31
7439-98-7
Nickel '
2.8 mg/kg
0.66
0.24
1
09/10/14 16:45
09/12/14 20:31
7440-02-0
Potassium
. ND mg/kg
656
0.55
1
09/10/14 16:45
09/12/14 20:31
7440-09-7
Selenium
23.1 mg/kg
1.3
0.50
1
09/10/14 16:45
09/12/14 20:31
7782-49-2
Sodium
716 mg/kg
656
0.81
1
09/10/14 16:45
09/12/14 20:31
7440-23-5
Zinc
59.0 mg/kg
1.3
0.34
1
09/10/14'16:45
09/12/14 20:31
7440-66-6
7471 Mercury
Mercury
Percent Moisture
Percent Moisture
160.4 Total Volatile Solids
Total Volatile Solids
254OG Total Percent Solids
Total Solids
9045 pH Soil
pH at 25 Degrees C
Plant Available Nitrogen
Plant Available Nitrogen
Total Nitrogen Calculation
Nitrogen
350.1 Ammonia
Nitrogen, Ammonia
351.2 Total Kjeldahl Nitrogen
Nitrogen, Kjeldahl, Total
Date: 10/03/2014 01:02 PM
Analytical Method: EPA 7471 Preparation Method: EPA 7471
0.012 mg/kg 0.0083
0.00017
1
09/1111417:05 09/12/1416:06 7439-97-6
Analytical Method: ASTM D2974-87
51.1 % 0.10
0.10
1
09/2411412:59
Analytical Method: EPA 160.4
496000 mg/kg 10000
10000
1
09/13/14 08:00
Analytical Method: SM 2540G
48.9 % 0.000010
1
09/11/14 09:24
Analytical Method: EPA 9045
8.2 Std. Units 0.10
0.10
1
09/11/14 11:55
Analytical Method: SM 2710B
493 mg/kg 0.12
0.12
1
09/17/1411:15 N2
Analytical Method: TKN+NO3+NO2 Calculation
1630 mg/kg 40.0
1
09/17/14 11:12 7727-37-9
Analytical Method: EPA 350.1
20.5 mg/kg 20.1
20.1
1
09/16/1416:09 7664-41-7
Analytical Method: EPA 351.2
1630 mg/kg 102
51.2
1
09/16/14 11:03 7727-37-9 M1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 25

��acmnalytical"
mmpace/absmro
t
SAMPLE ANALYTE COUNT
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Project:
Pace Project No.:
Monthly Sludge September
92216704
Analytes
Lab ID
Sample ID
Method
Analysts
Reported
Laboratory
92216704001
Monthly Sludge
EPA 6010
JMW
14
PASI-A
EPA 7471
HVK
1
PAS [-A
ASTM D2974-87
ACS
1
PASI-C
EPA 160.4
TEP
1
PASI-A
SM 2540G
ACS
1
PASI-A
EPA 9045
MAB
1
PASI-A
SM 2710B
EWS
1
PASI-A
TKN+NO3+NO2 Calculation
EWS
1
PASI-A
EPA 35V. 1
AES2
l
PASI-A
EPA 351.2
JDA
1
PASI-A
EPA 353.2
DMN
3
PASI-A
EPA 365.1
JDA
1
PASI-A
92216704002
Monthly Sludge 92216704001 RR
ASTM D2974-87
ACS
1
PASI-C
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 5 of 25

1�5a'neAnalOcal"
wwvl.parelabs,com
t
t
t
ANALYTICAL RESULTS
Project: Monthly Sludge September
Pace Project No.: 92216704
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh; NC 27607
[phone]
Sample: Monthly Sludge
Lab ID: 92216704001 Collected:
09/08/14 13:30
Received: 09/09/14 16:30 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters
Results Units Limit
MDL
DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, NO2/NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg 3.6
3.6
1
09/16/14 20:52
Nitrogen, Nitrite
ND mg/kg 1.8
1.8
1
09/16/14 20:52
Nitrogen, NO2 plus NO3
ND mg/kg 3.6
3.6
1
09/16/14 20:52
365.1 Phosphorus, Total
Analytical Method: EPA 365.1
Phosphorus
148 mg/kg 12.0
6.0
1
0911611415:28 7723-14-0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 10/03/2014 01:02 PM without the written consent of Pace Analytical Services, Inc.. Page 7 of 25

�11
..acce.AnalXical'
t mvwpaselabs.com
i
t
ANALYTICAL -RESULTS
Project: Monthly Sludge September
Pace Project No.: 92216704
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: Monthly Sludge Lab ID: 92216704002 Collected: 09/08/14 13:30 Received: 09/16/14 16:30 Matrix: Solid
92216704001 RR
Results reported on a "dry -weight" basis
Report
Parameters Results Units Limit MDL DF Prepared Analyzed CAS No. Qual
Percent Moisture Analytical Method: ASTM D2974-87
Percent Moisture 51.1 % 0.10 0.10 1 09/24/14 17:00
Date: 10/03/2014 01:02 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 8 of 25

r �
t
Page: 1 of 1
Report Number: 14-254-0207
Account Number: 06534
Submitted By: JON BRADLEY
A&L. Eastern •Laboratories, Inc.
7011.whltepine Road Richmond; Virginia MZ (W) 743*61 Fax [phone]
wwwalAaifgm.com
Send To: PACE ANALYTICAL CHARLOTTE LAB (JON BRADLEY)
JON BRADLEY
9800 KINCEY AVE SUITE 100
HUNTERSVILLE , NC 28078
Lab Number: 57530
Sample Id : 92216704001
Total Solids *
48.37
Moisture *
51.63
Total Kjeldahl Nitrogen
0.17
Calcium Carbonate Equivalent
40.50
Total Volatile Solids
51.07
C/N RATIO *
171
Carbon (TOC) *
29.70
Comments:
TOC, C/N AND CCE NOT FOR COMPLIANCE PURPOSES.
Project: 92216704001/NC CERT#257
REPORT OF ANALYSIS
Date Sampled: 9/8/2014 13:30:00
Date Received: 09/11/2014 00:00
Date Reported: 09/16/2014
483700
100.0
RD
09111/201414:50
SM-254OG
100.0
RD
09/11/201414:50
SM-254OG
1740
10.0
JM
09/12/2014 09:49
SM-4500-NH3C-TKN
405000
100
MW
09/15/2014 12:24
AOAC 955.01
510700
100.0
RD
09/11/201414:50
SM-254OG
1
D H
09/16/2014 14:00
CALCULATION
297000
100
D H
09/16/2014 14:00
CALCULATION
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis.
Our reports and letters are for the exclusive and confidential use of our aients, and may not be reproduced in 4vhole or part, nor may any reference be mado
to the work• the results, or tlx: cornpeany in :any advertising. news release, cr other public: announcements wilhout obtairdng our prior evriften ;,authoriz,ation,
Debbie Holt

laceAnalyficale
j www.pacelabs:com
i
ANALYTICAL RESULTS
Project: OCTOBER MONTHLY SLUDGE TEST
Pace Project No.: 92220457
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE TEST Lab ID: 92220457001 Collected: 10/07/14 08:00 Received: 10107/14 16:05 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters Results Units Limit MDL DF Prepared Analyzed CAS No. Qua]
6010 MET ICP
Analytical Method: EPA 6010 Preparation Method: EPA 3050
Aluminum
1210 mg/kg 12.0
6.0
1
10/09/14 11:25
10/09/14 14:48
7429-90-5
Arsenic
ND mg/kg 1.2
0.60
1
10/0911411:25
10/09/14 14:48
7440-38-2
Cadmium
ND mg/kg 0.12
0.060
1
1010911411:25
10/09/14 14:48
7440-43-9
Calcium
86700 mg/kg 120
59.8
10
10/09/14 11:25
10/09/1415:06
7440-70-2
Chromium
2.8 mg/kg 0.60
0.30
1
10/09/14 11:25
10/09/14 14:48
7440-47-3
Copper
10.9 mg/kg 0.60
0.30
1
10/09/14 11:25
10/09/14 14:48
7440-50-8
Lead
2.5 mg/kg 0.60
0.30
1
10/09/14 11:25
10/09/14 14:48
7439-92-1
Magnesium
1030 mg/kg 12.0
0.30
1
10/09/14 11:25
10/09/14 14:48
7439-95-4
Molybdenum
1.6 mg/kg 0.60
0.30
1
10109/1411:25
10/09/14 14:48
7439-98-7
Nickel
1.4 mg/kg 0.60
0.30
1
10/09/14 11:25
10/09/14 14:48
7440-02-0
Potassium
ND mg/kg 598
598
1
10/09/14 11:25
10109/1414:48
7440-09-7
Selenium
ND mg/kg 1.2
0.60
1
10/0911411:25
10/09/14 14:48
7782-49-2
Sodium
440J mg/kg 598
299
1
10/09/14 11:25
10/0911414:48
7440-23-5
Zinc
139 mg/kg 1.2
0.60
1
10/09/14 11:25
10/09/14 14:48
7440-66-6
7471 Mercury
Analytical Method: EPA 7471 Preparation
Method:
EPA 7471
Mercury
0.020 mg/kg 0.0092
0.00018
1
10/09/1412:00
10/0911413:23
7439-97-6
254OG Total Percent Solids
Analytical Method: SM 2540G
Total Solids
44.0 % 0.000010
1
10/10/14 09:48
Percent Moisture
Analytical Method: ASTM D2974-87
Percent Moisture
56.0 % 0.10
0.10
1
10/10/14 13:50
160.4 Total Volatile Solids
Analytical Method: EPA 160.4
Total Volatile Solids
689000 mg/kg 10000
10000
1
10/09/14 18:31
9045 pH Soil
Analytical Method: EPA 9045
pH at 25 Degrees C
7.9 Std. Units 0.10
0.10
1
10/09/14 14:15
Plant Available Nitrogen
Analytical Method: SM 2710B
Plant Available Nitrogen
777 mg/kg 0.12
0.12
1
10/23/14 08:35
N2
Total Nitrogen Calculation
Analytical Method: TKN+NO3+NO2 Calculation
Nitrogen
2590 mg/kg 40.0
1
10/16/1417:16
7727-37-9
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
ND mg/kg 22.7
22.7
1
10/13/14 22:12
7664-41-7
351.2 Total Kjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
2590 mg/kg 142
71.1
1
10/14/14 12:29
7727-37-9 M1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 10/23/2014 08:36 AM without the written consent of Pace Analytical Services, Inc.. Page 5 of 20

aceAnalytical
WKW pacerabs.com
i
f
t
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Project: OCTOBER MONTHLY SLUDGE TEST
Pace Project No.: 92220457
Sample: MONTHLY SLUDGE TEST Lab ID: 92220457001
Collected:
10/07/14 08:00
Received: 10/07/14 16:05 Matrix: Solid
Results reported on a "dry -weight" basis
Report
Parameters Results Units
Limit
MDL DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, N021NO3 Analytical Method: EPA 353.2
Nitrogen, Nitrate ND mg/kg
4.5
4.5 1
10/16/14 02:48
Nitrogen, Nitrite ND mg/kg
2.3
2.3 1
10/16/14 02:48
Nitrogen, NO2 plus NO3 ND mg/kg
4.5
4.5 1
10/16/14 02:48
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 155 mg/kg 11./ 11.4 1 10/14/14 09:55 7723-14-0 R1
Date: 10/23/2014 08:36 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 20

Page: 1 of 1
Report Number: 14-282-0202
Account Number: 07135
Submitted By: LIAMM CARRUBBA
Send To: PACE ANALYTICAL LABS
LIAMM CARRUBBA
9800 KINCEY AVE SUITE 100
HUNTERSVILLE , NC 28078
Lab Number: 58026
Sample Id : 92220457001 MONTHLY SLUDGE TEST
Total Solids *
43.08
Moisture *
56.92
Total Kjeldahl Nitrogen
0.28
Calcium Carbonate Equivalent
27.10
Total Volatile Solids
68.48
C/N RATIO *
144
Carbon (TOC) *
39.80
Comments:
TOC, C/N AND CCE NOT FOR COMPLIANCE PURPOSES.
A&L. Eastern Laboratories, Inc.
762l Whitep(he Road: ki6hni6dd; Virginia 23237 (6o4) 743.946i. T.ax (BQ4) 27t-,6,446
,www.aleastern.com
Project: 92220457 OCT MONTHLY SLUDGE TEST
NC CERT#257
REPORT OF ANALYSIS Date Sampled: 10/7/2014 08:00:00
Date Received: 10/09/2014 00:00
Date Reported: 10/13/2014
430800
100.0
JM
10/09/201415:00
SM-254OG
100.0
JM
10/09/201415:00
SM-254OG
2760
10.0
JM
10/10/2014 08:50
SM-4500-NH3C-TKN
271000
100
JM
10/13/2014 09:35
AOAC 955.01
684800
100.0
JM
10/09/201415:00
SM-2540G
1
D H
10/13/2014 15:00
CALCULATION
398000
100
JM
10/13/201415:00
CALCULATION
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis
Our reports and !oilers are for the exclusive and confidential use of our clients, rind ,may not be reproduced in whole or part, nor may any reference be made
to the work, the results, or the: company in aoy;advtutisi fy, news release, crother public ,announcements without obtaining our prior written authorization.
Debbie Holt

aceAnalytical
-pacelabs.com
i
i
ANALYTICAL RESULTS
Project: NOVEMBER SLUDGE TESTING
Pace Project No.: 92225079
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE Lab ID: 92225079001 Collected: 11/10/1413:10 Received:' 11/11/1414:40 Matrix: Solid
TESTING
Results reported on a "dry -weight" basis -
Report
Parameters Results Units Limit MDL- DF Prepared Analyzed CAS No. Qual
6010 MET ICP
Analytical Method: EPA 6010 Preparation Method: EPA 3050
Aluminum
1390 mg/kg 19.2
9.6
1
11/12/14 16:40
11/13/14 00:32
7429-90-5
Arsenic
ND mg/kg 1.9
0.96
1
11112?1416:40
11/13/14 00:32
7440-38-2
Cadmium
ND mg/kg 0.19
0.096
1
11/12/14 16:40
11/13/14 00:32
7440-43-9
Calcium
179000 mg/kg 384
192
20
11/1211416:40
11/13/1414:50
7440-70-2
Chromium
2.9 mg/kg 0.96
0.48
1
11/12/14 16:40
11/13/14 00:32
7440-47-3
Copper
21.0 mg/kg 0.96
0.48
1
11/12/14 16:40
11/13/14 00:32
7440-50-8
Lead
3.5 mg/kg 0.96
0.48
1
11/12/14 16:40
11/13/14 00:32
7439-92-1
Magnesium
1770 mg/kg 19.2
0.48
1
11/12/14 16:40
11/13/14 00:32
7439-95-4
Molybdenum
2.9 mg/kg 0.96
0.48
1
11/12/14 16:40
11/13/14 00:32
7439-98-7
Nickel
1.6 mg/kg 0.96
0.48
1
11/12/14 16:40
11/13/14 00:32
7440-02-0
Potassium
ND mg/kg 961
961
1
11/12/14 16:40
11/13/14 00:32
7440-09-7
Selenium
ND mg/kg 1.9
0.96
1
11/12/14 16:40
11/13/14 00:32
7782-49-2
Sodium
ND mg/kg 961
480
1
11/12/14 16:40
11/13/14 00:32
7440-23-5
Zinc
86.5 mg/kg 1.9
0.96
1
11/12/14 16:40
11/13/14 00:32
7440-66-6
7471 Mercury
Analytical Method: EPA 7471 Preparation Method: EPA 7471
Mercury
0.0084 mg/kg 0.0081
0.00016
1
11/12/1412:20
11113/1417:09
7439-97-6
254OG Total Percent Solids
Analytical Method: SM 2540G
Total Solids
50.0 % 0.000010
1
11/17/14 08:55
Percent Moisture
Analytical Method: ASTM D2974-87
Percent Moisture
50.0 % 0.10
0.10
1
11/17/14 13:08
160.4 Total Volatile Solids
Analytical Method: EPA 160.4
Total Volatile Solids
481000 mg/kg 10000
10000
1
11/14/14 17:36
9045 pH Soil
Analytical Method: EPA 9045
pH at 25 Degrees C
7.7 Std. Units 0.10
0.10
1
11/18/14 14:41
Plant Available Nitrogen
Analytical Method: SM 2710B
Plant Available Nitrogen
528 mg/kg 0.12
0.12
1
11/19/14 15:16
N2
Total Nitrogen Calculation
Analytical Method: TKN+NO3+NO2 Calculation
Nitrogen
1760 mg/kg 40.0
1
11/19/14 15:30
7727-37-9
350.1 Ammonia
Analytical Method: EPA 350.1
Nitrogen, Ammonia
- ND mg/kg 18.5
18.5
1
11/12/14 03:01
7664-41-7
351.2 Total Rjeldahl Nitrogen
Analytical Method: EPA 351.2
Nitrogen, Kjeldahl, Total
1760 mg/kg 62.5
31.2
1
11/18/14 14:43
7727-37-9
-REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 11/19/2014 03:33 PM without the written consent of Pace Analytical Services, Inc.. Page 5 of 21

aceAnalytical
vnwipacelabs.cora
ANALYTICAL RESULTS
Project: NOVEMBER SLUDGE TESTING
Pace Project No.: 92225079
Pace Analytical Services,, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE
Lab ID: 92225079001
Collected:
11/10/14 13:10
Received: 11/11/1414:40 Matrix: Solid
TESTING
Results reported on a "dry -weight" basis
Report
Parameters
Results Units
Limit
MDL DF
Prepared Analyzed CAS No. Qua[
353.2 Nitrogen, N021NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg
3.6
3.6 1
11/18/14 22:29
Nitrogen, Nitrite
ND mg/kg
1.8
1.8 1
11/18/14 22:29
Nitrogen, NO2 plus NO3
ND mg/kg
3.6
3.6 1
11/18/14 22:29
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 133 mg/kg 10 5.0 1 11/17/1413:29 7723-14-0
Date: 11119/2014 03:33 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 21

Page: 1 of 1
Report Number: 14-316-0201
Account Number: 07135`
Submitted By: LIAMM CARRUBBA ,wyuwalga;texnc9m
Send To: PACE ANALYTICAL LABS (for Liamm Carrubba)
LIAMM CARRUBBA
9800 KINCEYAVE SUITE 100
HUNTERSVILLE , NC 28078
A &L Easaern La:b.oraaories'I :Inc..
7821 gJhiteplrie Road Risfimond, (304)'743.9401 Fak,(804) 271, WG?
Project: 92225079 NOV SLUDGE TESTING
NC CERT # 0257
REPORT OF ANALYSIS Date Sampled: 11/10/2014 13:10:00
Lab Number: 58619 Date Received: 11/12/2014 00:00
Sample Id : 92225079001 Date Reported: 11/14/2014
Total Solids *
49.28
492800
100.0
JM
11/12/2014 15:00
SM-2540G
Moisture *
50.72
100.0
JM
11/12/2014 15:00
SM-254OG
Total Kjeldahl Nitrogen
0.17
1680
10.0
JM
11/13/2014 08:24
SM-4500-NH3C-TKN
Calcium Carbonate Equivalent
44.30
443000
100
JM
11/13/2014 13:00
AOAC 955.01
Total Volatile Solids
49.19
491900
100.0
JM
11/12/2014 15:00
SM-254OG
C/N RATIO *
170
1
D H
11/14/2014 11:00
CALCULATION
Carbon (TOC) *
28.60
286000
100
D H
11/14/2014 11:00
CALCULATION
Comments:
TOC, C/N AND CCE NOT FOR COMPLIANCE TESTING
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis
CD
r❑
C ux,weports and leiiors are for thu oxclusive, and confidential use of our clients, and may not be reproduced in whole or part, nor may any reference be made
to Re work, the results, or the company in any advertising, news release, or other public announcements without obtaining our prior written authorization.
N
Debbie Holt

aceAhaljd cal
vnwrpacelabsxorn
(
i
-ANALYTICAL RESULT8
Project: MONTHLY SLUDGE
Pace Project No.: 92228839
Pace Analytical Services; Inc.
6701 Conference Drive
t* Raleigh, NC 27607
(919)8344984
Sample: MONTHLY SLUDGE Lab ID: 92228839001 • Collected:' 12/08/14 15:00 • Received: 12/09/14 16:10 Matnx_Solid
TESTING
Results reported on a "dry -weight" basis
Parameters
6010 MET ICP
Aluminum
Arsenic
Cadmium
Calcium
Chromium
Copper
Lead
Magnesium
Molybdenum
Nickel
Potassium
Selenium
Sodium
Zinc
7471 Mercury
Mercury
254OG Total Percent Solids
Total Solids
Percent Moisture
Percent Moisture
160.4 Total Volatile Solids
Total Volatile Solids
9045 pH Soil
pH at 25 Degrees C
Plant Available Nitrogen
Plant Available Nitrogen
Total Nitrogen Calculation
Nitrogen
350.1 Ammonia
Nitrogen, Ammonia
351.2 Total Kjeldahl Nitrogen
Nitrogen, Kjeldahl, Total
Date:12/30/2014 12:00 PM
Report
Results Units', Limit MDL DF Prepared Analyzed CAS No. Qual
A I I M o, dEPA 6010 P ra foMeo th d' EPA 3050
na ytica e o repain
.
1590 mg/kg
17.8
8.9
1
12/11/14 17:10
12/12/14 02:13 7429-90-5
ND mg/kg
1.8
0.89
1
12/11/14 17:10
12/12/14 02:13 7440-38-2' '
ND mg/kg
0.18
0.089
1
12/11/14 17:10
12/12/14 02:13 7440-43-9
173000 mg/kg
888
444
50
12/11/14 17:10
12/12/1413:17 7440-70-2
3.0 mg/kg
0.89
0.44
1
12/11/14 17:10
12/12/14 02:13 7440-47-3'
11.3 mg/kg -
0.89
0.44
1
12/11/14 17:10
12/12/14 02:13 7440-50-8
2.9 mg/kg
0.89
0.44
1
12/11/14 17:10
12/12/14 02:13 7439-92-1
1630 mg/kg
17.8
0.44
1
12/11/14 17:10
12/12/14 02:13 7439-95-4
2.7 mg/kg
0.89
0.44
1
12/11/14 17:10
12/12/14 02:13 7439-98-7
1.5 mg/kg
0.89
0.44
1
12/11/14 17:10
12/12/14 02:13 7440-02-0
ND mg/kg
888
888
1
12/11/14 17:10
12/12/14 02:13 7440-09-7
ND mg/kg
1.8
0.89
1
12/11/14 17:10
12/12/14 02:13 7782-49-2
ND mg/kg
888
444
1
1211111417:10
12/12/14 02:13 7440-23-5
177 mg/kg
1.8
0.89
1
12/11/14 17:10
12/12/14 13:13 7440-66-6
Analytical Method: EPA 7471
Preparation
Method:
EPA 7471
0.031 mg/kg 0.0094
0.00019
1
12/10/1412:55
1211011415:59 7439-97-6
Analytical Method: SM 2540G
46.9 % 0.000010
1
12111/1410:37
Analytical Method: ASTM D2974-87
53.1 %
0.10
0.10
1
11/12/1414:52
Analytical Method: EPA 160.4
491000 mg/kg 10000
10000
1
12/11/1417:15
Analytical Method: EPA 9045
8.5 Std. Units
0.10
0.10
1
12/14/14 16:15
Analytical Method: SM 2710B
450 mg/kg
0.12
0.12
1
12/19/14 15:56
Analytical Method: TKN+NO3+NO2
Calculation
1500 mg/kg
40.0
1
12/19/1415:59 7727-37-9
Analytical Method: EPA 350.1
ND mg/kg
21.3
21.3
1
12/11/1414:25 7664-41-7
Analytical Method: EPA 351.2
1500 mg/kg
107
53.3
1
12/12/14 14:53 7727-37-9
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
N2
Page 5 of 21

ace Analytical
ww ipacelabs.com
i
i
ANALYTICAL RESULTS
Project: MONTHLY SLUDGE
Pace Project No.: 92228839
Pace Analytical Services, Inc.
6701 Conference Drive
Raleigh, NC 27607
[phone]
Sample: MONTHLY SLUDGE
Lab ID: 92228839001
Collected:
12/08114 16:00
Received: 12/09/14 16:10 Matrix: Solid
TESTING
Results reported on a "dry -weight" basis
Report
Parameters
Results Units
Limit
MDL DF
Prepared Analyzed CAS No. Qual
353.2 Nitrogen, NO2/NO3
Analytical Method: EPA 353.2
Nitrogen, Nitrate
ND mg/kg
4.1
4.1 1
12/16/14 20:50
Nitrogen, Nitrite
ND mg/kg
2.0
2.0 1
12/16/14 20:50
Nitrogen, NO2 plus NO3
ND mg/kg
4.1
4.1 1
12/16/14 20:50
365.1 Phosphorus, Total Analytical Method: EPA 365.1
Phosphorus 131 mg/kg 4.1 2.0 1 12/13/1414:20 7723-14-0
Date: 12/30/2014 12:00 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 21

Page: 1 of 1
Report Number: 14-345-0215
Account Number: 07135 @P-'
Submitted By: LIAMM CARRUBBA wwwaleastern.com
Send To: PACE ANALYTICAL LABS (for Liamm Carrubba)
LIAMM CARRUBBA
9800 KINCEY AVE SUITE 100
HUNTERSVILLE , NC 28078
Lab Number: 59203
Sample Id : 92228839001
A&L .Eastern Laboratories,, Inc,..
7621.White01ne Road Richmond, Virgihifi'23237' (804)743.940t F05 804) 271 G448.
Project : 92228839
NC CERT#257
REPORT OF ANALYSIS
Date Sampled: 12/8/2014 15:00:00
Date Received: 12/11/2014 00:00
Date Reported: 12/19/2014
Total Solids *
46.98
469800
100.0
DH
12/12/2014 13:59
SM-2540G
Moisture *
53.02
100.0
DH
12/12/2014 13:59
SM-254OG
Total Kjeldahl Nitrogen
0.17
1680
10.0
JM
12/17/2014 08:10
SM-4500-NH3C-TKN
Calcium Carbonate Equivalent
41.10
411000
100
JM
12/16/2014 13:50
AOAC 955.01
Total Volatile Solids
49.90
499000
100.0
DH
12/12/2014 13:59
SM-2540G
C/N RATIO *
173
1
D H
12/18/2014 13:00
CALCULATION .
Carbon (TOC) *
29.00
290000
100
JM
12/18/2014 13:00
CALCULATION
Comments:
TOC, C/N AND CCE NOT FOR COMPLIANCE TESTING
All values are on a dry weight basis except as noted by asterisk. Detection limit on all N series is on a wet basis
d
m
N,
Liz: veports and tctiers are for the exclusive and confidential use of our clierds, and may not be reproduced in whoto or pail, nor may aar7y reference be rnade
ro work. the results, or the cotaapatay in airy ,advertising, news role ase.. or ottaar pt;blic annoutrcetraents t-vitlarut oiatainin;7 oar pricer wtitiwn authorzatinn.
N
Debbie Holt

PNVIRONMEi�TAt-TE i785itiE.AJtAiEw7, iNl..
Analytical Laboratories
Client
Cascades Tissue Group - North Carolina Inc
805 Midway Road
.Rockingham, NC 28379
Order Number
1400314
Project Number
N/A
Issued
Monday, February 17, 2014
Total Number of Pages
5 (excluding C.O.C. and cooler receipt form)
Approved By :
e
QA Manager v.
Certifications: A2LA/DOD 0724.01, Alabama 41600, Arkansas 88-0735, California 07256CA, Colorado, Connecticut PH-0105,
Delaware, Florida NELAC E87688, Georgia E87688 and 943, Idaho OH00923, Illinois 200061 and Reg.5, Indiana
C-OH-13, Kansas E-10347, Kentucky (underground Storage Tank) 3, Kentucky 90146, Louisiana 04061 and
LA12004, Maine 2012015, Maryland 339, Massachusetts M-OPH923, Michigan (Reg.5), Minnesota 409711,
Montana CERT0099, New Hampshire 2996, New Jersey OH006, New York 11777, North Carolina 39705 and
631, Ohio 4170, Ohio VAP CL0052, Oklahoma 9940, Oregon OH2O0001, Pennsylvania 68-01335, Rhode Island
LA000317, South Carolina 92016001, Tennessee TN04018, Texas T104704466-11-5, Region 5 WG-15J, Region
8 8TMS-L, USDA/APHIS P330-11-00244, Utah OH009232011-1. Vermont VT-87688, Virginia 00440 and 1581,
Washington C891, West Virginia 248 and 9957C and E87688, Wisconsin 399013010
"Analytical Integrity" - EPA Certified • NELAP Certified3310 Wits street • Cuyahoga Faits, Ohio 44223 a `Phone: [phone] • Fax: [phone]
Web Site: wmv. settek. coat

ZNVIRONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
Sample Summary
Client: Cascades Tissue Group - North Carolina Inc
Order Number: 1400314
Laboratory ID Client ID
1400314-01
Matrix
2
Sampling Date
Sludge TCLP Sludge 2/6/2014
"Analytical Integrity" - EPA Certified - NELAP Certified
3310 Win Street - Cuyahoga Falls, Ohio 44223 ® Phone: [phone] - Fax. [phone]
Web Site: www.settek.com

AM
,. .
rr
AN
ENVIRONMENTALTECHNOLOGIES; fNC.
Analytical Laborat6ries
K
Report Narrative
Client: Cascades Tissue Group - North Carolina Inc
Order Number: 1400314
No problems were encountered during analysis of this order number, except as:noted.
Method numbers, unless specified as SM or ASTM, are EPA methods.
Method of analysis for TCLP Volatiles is 1311 /8260B
Method of analysis for TCLP Metals is 1311 /6010B and 1311 /7471 A
Method of analysis for TCLP BNA is 1311 /8270C
Data Qualifiers:
B = Analyte found in the method blank
J = Estimated concentration of analyte between MDL (LOD) and Reporting Limit (LOQ)
C = Analyte has been confirmed by another instrument or method
E = Analyte exceeds the upper limit of the calibration curve.
D = Sample or extract was analyzed at a higher dilution
X = User defined data qualifier.
S = Surrogate out of control limits
U = Undetected
a = Not Accredited by NELAC
ND = Non Detected at LOQ
DF = Dilution Factor
Limit Of Quantitation (LOQ) = Laboratory Reporting Limit (not adjusted for dilution factor)
Limit Of Detection (LOD) = Method Detection Limit
Practical Quantitation Limit (PQL) = (same as LOQ)
Method Detection Limit (MDL) = (same as LOD)
Reporting Detection Limit (RDL) = (same as LOD)
Estimated uncertainty values are available upon request.
Matrices:
A = Air
C = Cream
DW = Drinking Water
L = Liquid
0=Oil
SL = Sludge
SO = Soil
S = Solid
T = Tablet
TC =TCLP Extract
WW = Waste Water
W = Wipe
The test results meet the requirements of the NELAC standard, except where noted. The information contained in
this analytical report is the sole property of Summit Environmental Technologies, Inc. and that of the client. It cannot
be reproduced in any form without the consent of Summit Environmental Technologies, Inc. or the client for which this
report was issued. The results contained in this report are only representative of the samples received. Conditions
can vary at different times and at different sampling conditions. Summit Environmental Technologies, Inc. is not
responsible for use or interpretation of the data included herein.
`Analytical Integrity" - EPA Certified • NELA€� Certified
Wi
n in Str4et • Cuyahoga Falls; Ohio 44223 : a'' Phone: [phone] • Fax: [phone]
;' eb Site: wwvi.settek.co

am
ENVIRONMENTAL TAL TECHNOLOGIES, INC.
Analytical Laboratories
February 17, 2014
Client: Cascades Tissue Group - North Carolin
Address: 805 Midway Road
Rockingham, NC 28379
Received: 21812014
Project #: N/A
TCLP Volatiles
Client II?#
lab ID#
Collected Analyt_e
Rep Lm
Result
Units
Matrix
Method
DF
R 4Lvl
--
Run, 'Ana st
1
Sludge TCLP
1400314-01
06-Feb-14 Chlorobenzene
0.1
ND
mg/L
SL
1311
1
100
11-Feb-1: h7S
Sludge TCLP
1400314-01
06-Feb-14 Vinyl Chloride
0.2
ND
mg/L
SL
1311
1
0.2
11-Feb-14.M9'
Sludge TCLP
1400314-01
06-Feb-14 2-Butanone (MEK)
2
ND
mg/L
SL
1311
1
200
11-Feb;14,;MS.
Sludge TCLP
1400314-01
K 06-Feb-14 Tetrachloroethene
0.1
'ND
mg/L
SL
1311
1
0.7
11-Feb``-14 MS
Sludge TCLP
1400314-01
06-Feb-14 1,1-Dichloroethene
0.1
ND
mg/L
SL
1311
1
0.7
11-Feb-14 MS
Sludge TCLP
1400314-01
06-Feb-14 Trichloroethene
0.1
ND
mg/L
SL
1311
1
0.5
11-Feb 14. MS
Sludge TCLP
1400314-01
06-Feb-14 Carbon tetrachloride
0.1
ND
mg/L
SL
1311
1
0.5
11-Feb-14 MS
Sludge TCLP
1400314-01
06-Feb-14 Benzene
0.1
ND
mg/L
SL
1311
1
0.5
11-Feb-14 MS
Sludge TCLP
1400314-01
06-Feb-14 1,2-Dichloroethane
0.1
ND
mg/L
SL
1311
1
0.5
11-Feb-14.MS
Sludge TCLP
1400314-01
06-Feb-14 Chloroform
0.1
ND
mg/L
„SL
1311
1
6
11-Feb-14 MS
TCLP BNA
Client ID#
Lab ID#
Collected Analvte
Rep Lmt
Result
Units
Matrix
Method
DF
RegLvl
Run, Analyst
Sludge TCLP
1400314-01
06-Feb-14 Hexachloroethane
0.1
ND
mg/L
SL
1311
1
3
12-Feb-14 AE
Sludge TCLP
1400314-01
06-Feb-14 2,4-Dinitrotoluene
0.1
ND
mg/L
SL
1311
1
0.13
12-Feb-14 AE
Sludge TCLP
1400314.01
06=Feb-14 Hexachlorobenzene
0.1
ND
mg/L
SL
1311
1
0.13
12-Feb-14 AE
Sludge TCLP
1400314-01
06-Feb-14 Hexachloro-1,3-butadiene
0.1
ND
mg/L
SL
1311
1
0.5
12-Feb-14 AE
Sludge TCLP
1400314-01
06-Feb-14 Pentachlorophenol
0.25
ND
mg/L
SL
1311
1
100
12-Feb-14 AE
Sludge TCLP
1400314-01
06-Feb-14 2,4,6--Trichloropheriol.
0.25
ND
mg/L
SL
1311
1
2- ..
12-Feb-1,AE _.
Sludge TCLP
1400314-01
06-Feb-14 Nitrobenzene
0.1
ND
mg/L
SL
1311
1
2
12-Feb-14 AE
Sludge TCLP
1400314-01
06-Feb-14 2,4,5-Trichlorophenol
0.25
ND'
mg/L
SL
1311
1
400
12-Feb-14 AE,
Sludge TCLP
1400314-01
06-Feb-14 Pyridine
0.25
ND
mg/L
SL
1311
1
5
12-Feb-14 AE
Sludge TCLP
1400314--01
06-F6-14 1,4-Dichlorobenzene
6.1
ND
mg/L
SL
1311
1
7.5
12-Feb-14 AE
Sludge TCLP
1400314-01
06-Feb-14 Cresols
5
ND
mg/L
SL
1311
1
200
12-Feb44 AE .
TCLP Arsenic
Client D)# -
Lab ID#
Collected Analyte
Rep Lmt
Result
Units
Matrix
Method
DF
Re gLyl
Run Analyst
Sludge TCLP
1400314-01
06-Feb-14 TCLP Arsenic
0.5
ND
mg/L
SL
1311
1
5
11-Feb-14 VVK
TCLP
Barium
Client ID#
Lab ID#
Collected Analyte
Rep Lmt
Result
Units
Matrix
Method
DF
Re Lvl
Run Analyst
Sludge TCLP
1400314-01
06-Feb-14 TCLP Barium
5
ND
mg/L
SL
1311
1
100
11-Feb-14 VVK
TCLP Cadmium
Client M#
Lab ID#
Collected Analvte
Rep Lmt
Result
Units
Matrix
Method
DF
RegLvl
Run Analyst
Sludge TCLP
1400314-01
06-Feb-14 TCLP Cadmium
0.1
ND
mg/L
SL
1311
1
1
11-Feb-14 VVK
TCLP Chromium
Client ID# :
Lab ID#
Collected Anal t
Rep Lmt
Result
Units
Matrix
Method
DF
Re_qLvl
Run Analyst
Sludge TCLP
-
1400314-01
06-Feb-14 TCLP Chromium
0.2
ND
mg/L
SL
1311
1
5
11-Feb-14 VVK
TCLP Lead
_-
Client ID#
Lab ID#
Collected Analyte
Rep Lmt
. Result
Units
Matrix
Method,
DF
RegLvl
Run Analyst
Sludge TCLP
1400314-01
06-Feb-14 TCLP Lead
0.5
ND
mg/L
SL
1311
1
5
11-Feb-14 VVK
"Analytical Integrity" • EPA Certified • NELAP Certified Page 4
3310 Win Street • Cuyahoga Palls, Ohio 44223 Phone: [phone] . Pax: 330-25 -4489
Web Site: t ww. settek. com

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ENVIkONMENTAL TECHNOLOGIES, INC.
Analytical Laboratories
TCLP Mercury
February 17, 2014
Client: Cascades Tissue Group - North Carolin
Address: 805 Midway Road
Rockingham, NC 28379
Received: =12014
Project #: N/A
Client ID#
Lab 1D#
Collected Anal to
Rep Lmt Result
Units
Matrix Method
DF
ReqLvl
Run Aha]3§
Sludge TCLP
1400314-01
06-Feb.-14.Mercury
0.002 ND
mg/L
SL 1311
1
0.2
11-.FebL 14 ALI
TCLP Selenlum
Client IN
Lab 1D#
Collected Anabq
Rev Lmt Result
Units
—Matrix Method
DF
ReqLvi
Run Analyst.
Sludge TCLP
1400314-01
06-Feb-14 TCLP Selenium
0.5 ND
mg/L
SL 1311
1
1
11-FebL14VVK
TCLP Silver
Pigmlrw Lab ED# -Collected APWZ Rep Lm Result
Sludge TCLP 1400314-01 06-Feb-14 TCLP Silver 0.5 ND
Client, ID# Lab 1D# Collected Analyte Result
Sludge TCLP 1400314-01 06-Feb-14 Flash Point >200
—Client ID# Lab IJD4 Collected Anal +te Result
Sludge TCLP 1400314-01 06-Feb-14 pH 6.70
Units Matrix Method DF ReqLvi Run 'Analyst
mg/L SL 1311 1 5 11-Feb-14 VVK
!Lnk Matrix Method DF LQQ Run Analyst
OF SL 1010 1 13-Feb-14 TG
Units Matrix Method DF LOQ Run Analyst
S.U. SL 9046 1 0.01 10-Feb-14 AYS
Client ID#
Lab FD#
sollected Ana
J71-
Units Matrix Method
DF
LOB(.
Run Analyst
Sludge TCLP
1400314-01
06-Feb-14 Reactive Cyanide
ND
mg/kg SL 7.3.3.2
1
0.5
10-Feb44.-1111
. . .. . .....
Client DDA
Lab 1D#
Collected Analyte
Result
Units Matrix Method
DF
LQQ
Run. Analyst
SludgeTCLP
1400314-01
06-Feb-14 Reactive Sulfide
ND
mg/kg SL 7.3.4.2
1
25
'
10-Feb-14TIR
Page 5
"Analytical Integrity" - EPA Certifi*ed - NELAP Certified
3310 Win Street - Cuyahoga Falls, Ohio 44223 d Phone: [phone] - Fax: [phone]
Web Site: www.settek.com

ANNUAL PATHOGEN AND VECTOR ATTRACTION REDUCTION FORM (503 Rules)
Cascades Tissue Group -North Carolina a division of
Facility Name: Cascades Holding US Inc. WQ Permit Number: WQ0009477
WWTP Name:
NPDES Number:
Monitoring Period: From 1/1/2014 To 12/31/2014
Pathogen Reduction (40 CFR 503.32) - Please indicate level achieved and alternative performed:
Class A:
Alternative 1 ❑
Alterative 2 ❑
Alternative 3 ❑
Alternative 4 ❑ .
Alternative 5 ❑
Alternative 6 ❑
If applicable to alternative
performed (Class A only) indicate "Process to Further
Reduce Pathogens":
Compost ❑
Heat Drying ❑
Heat Treatment ❑
Thermophilic ❑
Beta Ray ❑
Gamma Ray ❑
Pasteurization ❑
Class B:
Alterative 1 ❑
Alternative 2 ❑
...................... _
If applicable to alternative
performed (Class B only) indicate "Process to Significantly Reduce Pathogens":
Lime Stabilization ❑
Air Drying❑
Composting ❑
Aerobic Digestion ❑
Anaerobic Digestion
If applicable to alternative performed (Class A or Class B) complete the following
monitoring data:
Parameter
Allowable Level
in Sludge
Pathogen Density
Number o
Excee-
deuces
Frequency
of Analysis
Sample
Type
Analytical
Tech -
maue
Minimum
Geo. Mean
Maximum
Units
Fecal Coliform
2 x 10 to the
6th power
per gram of
total solids
MPN
CFU
10.00 mpn per gram
of total solid (dry
weight)
Salmonella bacteria
(in lieu of fecal
coliform)
3 MPN per 4 grams
total solid (dry
weight)
<25
See Cover
Letter
grams
0
Annually
Vector Attraction Reduction (40 CFR 503.33) - Please indicate option performed:
Alt.1 (VS reduction)'
❑
Alt. 2 (40-day bench)
❑
Alt. 3 (30-day bench) ❑
Alt. 4 (Spec. Oz uptake)
❑
Alt. 5 (14-Day Aerobic)
❑
Alt. 6 (Alk. Stabilization
❑
Alt 7 (Drying - Stable) ❑
Alt. 8 (Drying - Unstable)
❑
Alt. 9 (Injection)
❑'
Alt. 10 (Incorporation)
❑
No vector attraction reduction alternatives were performed
❑
CERTIFICATION STATEMENT (please check the appropriate statement)
"I certify, under penalty of law, that the pathogen requirements in 40 CFR 503.32 and the vector
attraction reduction requirement in 40 CFR 503.33 have been met."
❑ "I certify, under penalty of law, that the pathogen requirements in 40 CFR 503.32 and the vector
110P attraction reduction requirement in 40 CFR 503.33 have not been met." (Please note if you check
this statement attach an explanation why you have not met one or both of the requirements.)
"This determination has been made under my direction and supervision in accordance with the system
designed to ensure that qualified personnel properly gather and evaluate the information used to determine
that the pathogen and vector attraction reduction requirements have been met. I am aware that there are
significant penalties for false certification including fine and imprisonment."
Preparer Name and Titlg'(type or print)
Signature of
Land Ap ier Name and Title (if applicable)(type or print)
Date Signature of Land Applier (if applicable) ate
*Preparer is defined in 40 CFR Part 503.9(r)'and 15A NCAC 2T .1102 (26)
DENR FORM PVRF 503 (12/2006)

177-51ONCRwy-902 P Bear-Cmek, NC,27207
Phone, 91M737­7 Fay::
LL
SAMPLE NO.-,:34'12.65
SAMPLE,017'. SLUDGE
SAMPLE IJD; 11912<00:GRAB
CAMERON T88TIN'
AT,TNf t',HRI8,CArvlERON
219SOUTH STEELE STREET
SANF6Rb -'C---
TEST,
-SALMONELLA
REPORT DATE: 0_1'11:3114
RECEIVED bATE:'0,11,09/14
CERTIFICATE DF ANALYSIS
RESULTS IJKIT8
NEGATIVE f260_
kEs''OL 8.,,ARE,rOR.',,THE.8U[3rvllTTEb SAMPLE"ONLY YREPORT; IF RI Pf R."6 _i b . THIS'R E . RU ED,
MUST'BE,REPRODU.CED IN ITS ENTIRETY.
RESPECTFULUY-SUBMITTED,
C;kROLINAANALYT_lCAL SERVICES-, LLC,
JENNIE STEWART
A'OCS CHEMIST

t
,.Cascades
Date: Feb 20, 2015
Cascades Tissue Group - North Carolina
A Division of Cascades Holding US Inc.
805 Midway Road, Post Office Box 578
Rockingham, NC 28380 USA
Phone: [phone] Fax: [phone]
From: Karen Bellamy
Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.
Po Box 578 805 Midway Rd.
Rockingham, NC 28380
Phone [phone]-Ext 2280
"Fax [phone]
.Email: Karen BellamynCascades.com
Permit: WQ0009477
Subject: Fecal Testing
Cascades Material is a lime material, so we don't perform vector reduction.
Should your office have any question please contact me at the above numbers or email.
Karen V. Bellamy
Environmental Manager
Cascades Tissue Group -North Carolina, a division of Cascades Holding US Inc.

CDEN
Norte Caroline Department of Environment and Natural Resources
' uivision c Water Quality°
Beverly Eaves Perdue uoleen K. Sulbs Ne ;�reemar
governor Director Se�retar
March 25, 2011
Mr. Eric Taylor — MilI Manager
Cascades Tissue Group — North Carolina,
a division of Cascades Holding US Inc.
P.O. Box 578
Midway, North Carolina 28380
Dear Mr. Taylor:
Subject: Permit No. WQ0009477
Cascades Tissue Group —
North Carolina, a division of
Cascades Holding US Inc.
Rockingham, NC Division Fiber-Ciay
Distribution Program
Distribution of Class A Residuals
(503 Exempt)
Permit Correction
Richmond County
In accordance with your requests submitted in a meeting with DWQ representatives on February
14, 2011, and subsequent emails and telephone conversations, we are forwarding herewith corrected
Permit WQ0009477, issued on January 28, 2011.
The following corrections have been made to the permit:
• Cover letter — The designation "503 Exempt" has been added to the cover letter and to the
permit title.
• Condition I.1. has been revised to require an updated "facility" map rather than a "site" snap.
• Previous Condition I.2. has been deleted.
• Item H.3. has been revised to clarify that a permit modification would be required for any
additional residual generated by Cascades,
• A footnote has been added to Condition II.4. to clarify that the monthly average
concentrations refers to the residuals content.
• Previous Condition H.5 has been deleted.
• Condition 11.6. (previous Condition II.7.) has been revised to clarify that the agronomic rates
for this product shall be calculated based upon the lime content of the residual.
• Condition 11.7. (previous Condition 11.8) has been modified to require that residuals not be
applied if the calculated ESP value is 10°�0 or greater or if the SAR value is 10 or higher
(either measurement may be used).
e-: f-JIC': vF'I21. K-,m-, ••'��i i,P` ?L:JG "IUG.,
91 P r FA- "
�^• _- -° � sv E F
64

Mr. Eric Taylor
March 25, 2011
Page 2 of 2
• Item 11.8. has been added to specify the actual pathogen reduction requirements that will be
met. Item U.8. has also been revised to allow reporting of fecal coliform samples in units of
either MPN/gram. or CFU/gram.
• Conditions 111.4. and 111.6. have been revised as requested to be consistent with the
Permittee's operational procedures.
• Previous Conditions 111.71. and 111.71 have been deleted because they were not applicable
to this operation.
• Condition ilI.7.£ has been revised to remove the arbitrary reference to .01 in/hr rainfall
intensity.
• Condition III.7.j. (previous Condition 111.7.1.) has been revised to clarify that the agronomic
rate is based upon the lime content of the residual.
• Condition M.8. has been revised to replace the term "entity" with the term "farmer", and to
clarify that the utilization agreements will be updated at least every three years,
• Condition 111.9.b.ii. has been revised to allow the residuals to be staged for two cropping
cycles, not to exceed 180 calendar days.
• Previous condition II1.9.c. has been deleted because it was not applicable to this operation.
• Item 111.9.e. (previous Condition 111.91) has been revised to allow the utilization agreement
to be kept in the field superintendent's truck.
• Condition Ill.10. has been revised to replace the term "buyer" with "farmer".
• Condition III.I 1.c. has been revised to require that reasonable measures be taken to prevent
residuals from entering any water supply source or surface water.
+ Condition iV.3. has been revised to be consistent with previous permit versions.
Specifically, monitoring for Ammonia, Nitrate, TKN, PAN, and SAR has been removed.
Monitoring for CEC and Carbon/Nitrogen Ratio has been added.
+ Item IVA. has been revised -to remove erroneous language about a stabilization process.
• Item N.S. has been revised as requested to better reflect the Permittee's current record
beeping procedures.
• - Item IV.Ke. has been revised to be consistent with the Permittee's operational procedures.
• Attachment A has been revised to allow for annual monitoring for pathogen reduction
compliance.
Please replace the previous permit you received dated January 28, 2011 with this corrected permit
version. If you need additional information concerning this matter, please contact Lori Montgomery at
[phone] or [e-mail].
Sincerely,
Coleen H. Sullins
cc: Richmond County Health Department
Fayetteville Regional Office, Aquifer Protection Section
Technical Assistance and Certification Unit
Permit File WQ0009477
Notebook File WQ0009477

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF CLASS A RESIDUAL SOLIDS PERMIT (503 EXEMPT)
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
Cascades Tissue Group — North Carolina, a division of
Cascades Holding US Inc.
Richmond County
FOR THE
continued operation of a residuals management program for Cascades Tissue Group — North Carolina, a
division of Cascades Holding US Inc. and consisting of the distribution of Class .A. non -biological
industrial residuals (hereafter referred to as "residuals") generated by the approved facilities listed in
Attachment A and marketed under the product name Fiber Clay with no discharge of wastes to surface
waters, pursuant to the application received January 4, 2011, and in conformity with other supporting data
subsequently filed and approved by the Department of Environment and Natural Resources 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 (January 28, 2011) until December 31, 2015, shall
void Permit No. WQ0009477 issued January 19, 2007, and shall be subject to the following specified
conditions and limitations:
1. SCHEDULES
l . No later than six months prior to the expiration of this permit, the Perinittee 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 facility map to be submitted with the permit renewal
application.
WQ000947Versioii -'. ] Shell Version 101116 - Page 1 of 9

II. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all tunes
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 nuisance
conditions due to improper operation and maintenance, the Permittee shall immediately cease
distribution of Class A residuals, contact the Fayetteville regional office's Aquifer Protection Section
supervisor, and take any immediate corrective actions.
2. This permit shall not relieve the Permittce of their responsibility for damages to groundwater or
surface water resulting from the operation of this residuals management program.
3. Only residuals generated by the facilities listed in Attachment A are approved for land application /
distribution in accordance with this permit. A modification to this permit will be required for any
additional residual generated by Cascades.
4. Pollutant concentrations in residuals distributed or applied to any land application site shall not
exceed the following Ceiling Concentrations and Monthly Average Concentrations (i.e., dry
weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
n/a
Nickel
420
420
Selenium
1.00
100
Zinc
7,500
2,800
I . Monthly average concentration refers to the polkutant concentration in the residuals.
5. Setbacks for land applied bulk residuals shall be as follows:
Setback Description
Setback by residual type
(feet)
Liquid
Cake*
Private or public water supply
100
100
Surface waters (streams — intermittent and perennial,
perennial waterbodies, and wetlands)
100
25
Wells with exception to monitoring wells
100
100
* Unless otherwise noted in Attachment A, "cake" residuals are those that have greater than 151 o
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, slinger spreader, broadcast spreader or
other equipment designed for handling solid materials) without leaving any significant liquid
fraction behind.
WQ0009477Version 2.1 Shell Version 10 111h Paae 2 of 9

6. Bulk residuals shall not be applied in exceedance of agronomic rates. An appropriate agronomic rate
shall be calculated based on the lime content of the residual.
The Permittee shall report results for either sodium adsorption ratio (SAR) of the residuals or
calculated exchangeable sodium percentage (ESP) of the application ,fields annually. If SAR is
reported, then the Permittee shall not distribute Class A residuals when the SAR is 10 or higher
without Division approval. If ESP is reported, then the Permittee shall not distribute Class A
residuals when the ESP is 10% or higher without Division approval. The Permittee may seek
approval by demonstrating that the farmer accepting the residuals is: aware of the effects of a high
SAR/ESP value; has agreed on proper residual application rates; and has agreed to operational
considerations to ensure that the high SAR/ESP value will not adversely impact the receiving sites.
S. - The residual will demonstrate the following: -
a) The density of fecal coliform is less than 1,000 Most Probable Number (MPN) per gram of total
dry solids or 1,000 Colony Forming Units (CFU) per gram of total dry solids; or
b) The density of Salmonella sp. Bacterial is less than three Most Probable Number per four grams
of total dry solids.
)fII. OPERATION AND MAINTENANCE REQUIREMENTS
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.
2. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) pursuant to .
15A NCAC 02T .1110. Modifications to the 0&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 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 locations) 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 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.
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.
WQ0009477Version 2. i
Shell V ersioT� 101 1 1 h
Pk,-,e 3 of 9

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 their 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 III.
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 Quality's
Technical Assistance & Certification Unit at [phone].
4. A copy of this permit, a signed copy of the applicable utilization agreement, and a copy of O&M Plan
shall be maintained in the field superintendent's truck during land application activities. The spill
prevention and control plan shall be maintained in all residuals transport and application vehicles.
5. When land applying 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.
A vegetative cover plan shall be developed and maintained for all farm fields that will receive the
residuals. The plan will pertain to either row crops rotation (RC) or grass (pasture or hay) systems.
7. 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 latid 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, 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 vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
i. If the vertical separation of bedrock and the depth of residuals application is less than one foot.
j, Application exceeds agronomic rates. An as onomic rate shall be determined based on the lime
content of the residual.
A Utilization Agreement between the Permittee and the farmer agreeing to accept and distribute
Class A bulk residuals shall be in place prior to distribution of the bulk residuals. The agreement
shall specify the agreeing farmer's responsibilities. The Utilization Agreement(s) shall be updated as
necessary at least every three (3) years.
WQ0009477Version 2.1 Smell Version 10 111h Page 4 of 9

9. At a minimum, the Utilization Agreement shall stipulate the following:
a. By agreeing to accept the bulk Class A residuals, it is recognized that the application of these
residuals is allowed under the conditions of this agreement. Land application of Class A residuals
is considered the beneficial reuse of a waste under 15A NCAC 02T .I 100, and has been deemed
permitted under 15A NCAC 02T .1103(.4) provided the conditions of this agreement are met. Any
action resulting in damages to surface water or groundwater, caused by failure to follow the
conditions of this agreement, is subject to Division enforcement action;
b. The person or entity accepting the bulk Class A residuals shall to the best of their knowledge
meet the following application requirements:
i. List all prohibitions under Condition IH.7 with a statement that bulk residuals shall not be
laud applied under these conditions.
ii. The residuals shall be distributed/iand applied within two cropping cycles, not to exceed 180
calendar days of the date that the last load was hauled to the farm field.
iii. Application of bulk residuals shall not occur within 100 feet of a public or private water
supply source;
iv. Application of bulk residuals shall not occur within 100 feet of any well, with the exception
of Division approved monitoring wells;
v. Application of bulk residuals shall not occur within 25 feet of surface waters.
c. The applicator or party accepting bulk residuals from the Permittee shall supply all third parties
receiving bulk residuals with documentation specifying that application shall occur consistent
with the utilization agreement;
d. Instructions, including contact information for key personnel, shall be provided to the applicator
or party receiving bulk residuals in the event that any requirements specified in the utilization
agreement are not met.
e. A copy of the Utilization Agreement shall be maintained in the field superintendent's truck when
bulk residuals are being applied.
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
the farmer. If an alternate storage site is used, approval must be obtained from the Division.
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 that reasonable measures shall be taken to ensure that this material is 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.
12. The Permittee shall not distribute bulk residuals to any person or entity known to be applying
residuals contrary to the condition of the signed Utilization Agreement.
WQ0009477Version 2.1 Shell Version 101116 , Page 5 of 9

IV. MONITORING AND REPORTING REQUIREMENTS
1. 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.
2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). The analyses Jcorrosivity, ignitability, reactivity, and toxicity
characteristic leaching procedure (TCLP)] 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-Di chloroethylene (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)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0.008)
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 (0A)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200,0)
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.
3. An analysis shall be conducted on the Class A residuals at the frequency specified in Attachment A,
and the Permittee shall maintain the results for a minimum of five ycars. The analysis shall include
the following parameters:
Aluminum
Mercury
Potassium
Carbon/Nitrogen Ratio
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Calcium Carbonate
Equivalency
Zinc
Calcium
Percent Total Solids
Magnesium
Copper
pH
Lead
Phosphorus
WQ0009477Version 2.1 Smell Version 101116 Page 6 of 9

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.
5. Laboratory parameter analyses shalt be performed on the residuals as they are distributed, and shall
be in accordance with the monitoring requirements in 15A NCAC 02B .0505.
6. The Permittee shall maintain records tracking all bulk residual land application events. At a
minimum, these records shall include the following:
a. Source of residuals;
b. Month of distribution/land application;
c. Name of recipient of residuals;
d. Weight (dry tons) of residuals distributed to each recipient;
e. Intended use of residuals;
f. Application rate based on the lime content of the residuals.
7. Three copies of an annual report shall be submitted on or before March I". The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Re ortinn
Forms. Instructions for reporting and annual report forms are available at
httt�;/ part�tl.nccleilr.org rebivtic!aps/law reporting, or can be obtained by contacting the land
Application Unit directly. The annual report shall be submitted to the following address:
Division of Water Quality
liiformation Processing Unit
1617 Mail Service Center
Raleigh,,North Carolina 276994617
8, Noncompliance Notification
The Permittee 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. Any occurrence with the distribution program resulting in the land application of significant
amounts of wastes that are 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 during residuals transportation to the receiving farm.
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
be taken to ensure that the problem does not recur.
WQ0009477Version �.I Shell Version 101116 Page 7 of 9

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.
2. Prior to each bulk residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport and application facilities to prevent malfunctions, facility deterioration
and operator errors resulting in discharges, which may cause the release of wastes to the
environment, a threat to human health or a public nuisance. The Permittee 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 Permittee 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. '
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the land application 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.
VI, GENERAL CONDITIONS
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.
2. This permit shall become voidable if the residuals land application' events are not carried out in
accordance with the conditions of this permit.
This permit is effective only with respect to the nature and volume of residuals .described in the
permit application and other supporting documentation.
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.
5. In the event the residuals program changes ownership or the Permittee changes their 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.
6. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 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).
WQ0009477Version '-.1 Shell Version 101116 Page 8 of 9

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 pursuant to 15A
NCAC 02T .0105(c)(3).
Permit issued this the 28"' day of January, 2011
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
1
��✓ oleen Vfsullins, Director
Division of Water Qualit\:
By Authority of the Enviroiunental Management Commission
Permit Number WQ00009477
W00009477 ersion 2.1 She][ Version 101116 face 4 of 0

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ATTACHMENT A - Approved Residual Sources
Cascades Tissue Group -- North Carolina, a division of Cascades Holding US ine.
Certification Date: January 28, 201.1
Permit Number- WQ0009477 Version: 2,1
MaximumMonitoring
Monitoring
Monitoring
A1 ip roved
Owner
Facility Name
CountyPermit
N!!ml3e!'
Biological
Residuals
Dry lofts
Frequency for
1VOn-IaaZflrdUU$
Frequency for
Metals and
Frequency for
Pathogen
Mineralization
Per Year
1 !
Characteristics 2
Nutrielits 3*5
Reduction '€'s
Rate
Cascades I issue Group -
division
Rockingham. NC Division
fiber Distribution
Richmond
WQ0009177
No
50.000
Once per perniit
See T tblc Below
Annually
OM-
Forth Carolina. a of
-Clay
cycle
Cascades Holding US Inc.
Program
Total
5t).Ol)tl
1. Maximum Dry Tons per Year is the amount of residuals product approved for distribution from the permitter{ facility.
2. MalvISes to demonstrate that residuals are non -hazardous (i.e..'I'C'L1', ignitability, reactivity. and corrosiyity) as stipulated under permit Condition IV.2.
3. Testing of metals and nutrients as stipulated under permit Condition IV.3.
4. Analyses of pathogen reduction as stipulated under permit Condition 11.8.
5. Monitoring frequencies are based on the actual dry tons applied per year using the table below. unless specified above.
Dry Tons Generated
(short torts per year)
Monitoring Frequency
(Established in 40 CFR 503 and 15A NCAC 027'.1111
'319
I/Year
=--319 --:1,650
1/(quarter (4 tinies er 'ear)
—1,650 - -16.500
1/60 lla -s (6 tinies per year)
=: .16.500
Ilmonth (12 tinies per year)
ii no land application events occur during a required sampling period (e.g. no land application occur during an entire year when annual monitoring is
required), then no sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data.
Those required to submit the annual report to EPA may be required to make up the missed sampling, contact the EPA for additional information and
clarificatiola.
WQ0009I77Version 2.1 Attachment A Page I of I

MCDENR
North Carolina DePaftrnent of Environment and Nalurat Resources
Division of k4'ater Quality
Beverh, paves Perdue Coieen H. Guifins Dee .Freeman
Governor Direvtc„ Secretar.
January 28, 2011
Mr. Eric Taylor — Mill Manager
Cascades Tissue Group — North Carolina,
a division of Cascades Holding US Inc.
P.O. Box 578
Midway, North Carolina 28380
Subject: Permit No. WQ0009477
Cascades Tissue Group —
North Carolina, a division of
Cascades Holding US Inc.
Rockingham, NC Division Fiber -Clay
Distribution Program
Distribution of Class A Residuals
Richmond County
Dear Mr. Taylor:
In accordance with your permit name change request received January 4, 2011, we are forwarding
herewith Permit No. WQ0009477, dated January 28, 2011, to Cascades Tissue Group -- North Carolina, a
division of Cascades Holding US Inc. for the continued operation of the subject residuals management
program.
Please note the Permittee name has been changed from Cascades Tissue Group — North Carolina,
Inc. to Cascades Tissue Group --- North Carolina, a division of Cascades Holding US Inc.
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, WQ0009477, issued
by the Division of Water Quality falls within the scope of this Act and is therefore being extended until
December 31, 2015. Please note per your permit, a renewal application must still be submitted six
months in advance of the extended expiration date.
This permit shall be effective from the date of issuance until December 31, 2015, shall void
Permit No. WQ0009477 issued January 19, 2007, and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring requirements listed in Attachment A,
for they may differ from the previous permit issuance. Failure to establish an adequate system for
collecting and maintaining the required operational information shall result in future compliance
problems.
,' PPO"r-uTlON SEA TIC,'
15.,. _' Service Center, RaieVg Mort., Car.:
! o i - 2 Cac al c ti ar Ra N. `1 C , n r ? f �} y,
F, 07 33-32� FA a a1c 1J A'/ 91� 71 6 Gus%r. ar Sete,_:: 1 " � 3-6'4f ! V i �'�t.i�....::�."i��a�i�
I arr� F,.

Mr. Eric Taylor
January 28, 2011
Page 2 of 2
Please note that on September 1, 2006, North Carolina Administrative Code Title 15A
Subehapter 02T — Waste not Discharged to Surface Waters was adopted. Accordingly, this permit
incorporates the requirements of these rules, therefore, please take the time to review this permit
thoroughly. The following conditions have been added, modified or deleted from those in the last permit
issuance:
y Condition 1.2. — No later than September 1, 2011 the Permittee shall be able to demonstrate
compliance and meet the monitoring and reporting requirements for pathogen reduction.
Condition 11.5. -- Residuals that are distributed / land applied shall meet Class A pathogen
reduction requirements in 15A NCAC 02T .1106 (a) and (b)(2).
r Condition 111.2. - The Permittee shall maintain, an approved Operation and Maintenance Plan
(O&M Plan) pursuant to 15A NCAC 02T .1110. Modifications to the O&M Plan shall be
approved by the Division prior to utilization of the new plan. The O&M Plan shall include
the minimum requirements listed in Condition 111.2.
w Condition IV.4. - Residuals shall be monitored for compliance with pathogen reduction
requirements at the frequency specified in Attachment A.
v Attachment A — contains sampling requirements and frequency for TCLP, nutrients, metals,
and pathogen reduction.
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 matter, please contact Lori Montgomery at
[phone] or Lori.Montgomery ,ncdenr.gov.
Sincerely,
Cole k Sullins
cc: Richmond County Health Department
Fayetteville Regional Office, Aquifer Protection Section
Technical Assistance and Certification Unit
Permit File WQ0009477
Notebook File WQ0009477

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF CLASS A RESIDUAL SOLIDS PERMIT
hi 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
Cascades Tissue Group — North Carolina, a divtslun of
Cascades Holding US Inc.
Richmond County
FOR THE
continued operation of a residuals management program for Cascades Tissue Group — North Carolina. a
division of Cascades Holding US Inc. and consisting of the distribution of Class A residuals generated by
the approved facilities listed in Attachment A and marketed under the product name Fiber Clay with no
discharge of wastes to surface waters, pursuant to the application received January 4, 2011 _ and in
conformity with other supporting data subsequently filed and approved by the Department of
Environment and Natural Resources and considered a part of this permit. The use and disposal of
residuals are regulated under Title 40 Code of Federal Regulations fart 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 December 31, 2015, shall void Permit No.
WQ0009477 issued January 19, 2007, 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.
2. No later than September 1, 2011 the Permittee shall be able to demonstrate compliance and meet the
monitoring and reporting requirements of pathogen reduction.
WQ0009477Versiou 11 Shelf Version 101116 Page 1 of 10

II. PERFORMANCE STANDARDS
i. 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 nuisance
conditions due to improper operations and maintenance, the Permittee shall immediately cease
distribution of Class A residuals, contact the Fayetteville regional office's Aquifer Protection Section
supervisor, and take any immediate corrective actions.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this residuals management program.
3. Only residuals generated by the facilities listed in Attachment A are approved for land application f
distribution in accordance with this permit.
4. Pollutant concentrations in residuals distributed or applied to any land application site shall not
exceed the following Ceiling Concentrations and Monthly Average Concentrations (i.e., dry
weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
nia
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
5. Residuals that are distributed / land applied 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.
WQ0009477Version 2.1 Shell Version'101116 Page 2 of 10

6. Setbacks for land applied bulk residuals shall be as follows:
Setback ]Description
Setback by residual type
(feet)
Liquid
Cake'
Private or public water supply
100
100
Surface waters (streams — intermittent and perennial,
perennial waterbodies, and wetlands)
100
25
Wells with exception to monitoring wells
� 100
100
' 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, Slinger spreader, broadcast spreader or
other equipment designed for handling solid materials) without leaving any significant liquid
fraction behind.
7. 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(httD:,'twwA,.soil.ncsu.edurt7roaranisixunx wields'). A
copy shall be kept on file and reprinted every five years in accordance with Condition IVA
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 Ott :/iwu,-%7,-.enr.state.ne.tisIDSWCi aLesiE!uidance docs.%tml .
iii. Certified Nutrient Management Plan as outlined by the Natural Resources Conservation
Services (MRCS). These plans must meet the USDA-NRCS 590 Nutrient Management
Standards(ftp://ftp-fc.sc.e2ov.usda.aov/NHQ/practiez-standards%standards`590.odt).
d. If the RYE and appropriate nutrient application rates cannot be determined, the Permittee shall
contact the Division to determine necessary action.
The Permittee shall not distribute Class A 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.
WQ0009477Version 2.1 Shell Version 101116 Pacge 3 of 10

III. OPERATION AND MAINTENANCE REQUIREMENTS
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.
2. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) pursuant to
15A NCAC 02T .l 110. Modifications to the 0&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 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 titles of personnel responsible for conducting the sampling and monitoring;
I 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 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).
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 their 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 III.
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 Quality's
Technical Assistance & Certification Unit at [phone].
4. A copy of this permit, a signed copy of the applicable utilization agreement, and a copy of O&M Plan
shall be maintained in all manned equipment at the land application sites during land application
activities. The spill prevention and control plan shall be maintained in all residuals transport and
application vehicles.
When land applying 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.
WQ0009477Version2:1 Shell Version 101116 Fate 4 of 10

6. A suitable vegetative cover shall be maintained on land application sites onto which residuals are
applied 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 by the Division.
7. 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 soil pH is not maintained at 6.0 or greater, unless sufficient amounts of lime are applied to
achieve a final soil pH of at least 6.0, or if an agronomist provides information indicating that the
pH of the soil, residuals and lime mixture is suitable for the specified crop. Any approved
variations to the acceptable soil pH (6.0) will be noted in Attachment B;
i. 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:
j. If the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
k. If the vertical separation of bedrock and the depth of residuals application is less than one foot.
1. Application exceeds agronomic rates.
A Utilization Agreement between the Permittee and the entity agreeing to accept and distribute Class
A bulk residuals shall be in place prior to distribution of the bulk residuals. The agreement shall
specify the agreeing entity's responsibilities. The Permittee or his designee and the person
responsible for application of the residuals compost shall sign the Utilization Agreement, which shall
be considered expired concurrent with the permit expiration date, and shall be renewed during the
permit renewal process.
9. At a minimum, the Utilization Agreement shall stipulate the following:
a. By agreeing to accept the bulk Class A residuals, it is recognized that the application of these
residuals is allowed under the conditions of this agreement. Land application. of Class A residuals
is considered the beneficial reuse of a waste under 15A NCAC 02T .1100. and has been deemed
permitted under 15A NCAC 02T .1103(4) provided the conditions of this agreement are met. Any
action resulting in damages to surface water or groundwater, caused by failure to follow the
cl
conditions of this agreement, is subject to Division enforcement action;
b. The person or entity accepting the bulb Class A residuals shall to the best of their knowledge
meet the following application requirements:
i. List all prohibitions under Condition 111.7 with a statement that bulk residuals shall not be
land applied under these conditions.
WQ0009477Version 2.1 Shell Version I01116 Page 5 of 10

ii. Residuals stockpiled for more than 14 days shall be covered;
iii. Application of bulk residuals shall not occur within 100 feet of a public or private water
supply source;
iv. Application of bulk residuals shall not occur within 100 feet of any well, with the exception
of Division approved monitoring wells;
v. Application of bulk residuals shall not occur within 25 feet of surface waters.
c. The generator of the Class A bulk residuals shall provide information on the proper use of the
residuals, including information on the nutrient quantities within the residuals and recommended
application rates. A copy of the label or information sheet attached to bags or other containers, as
specified in the labeling requirements under Condition III.11. is sufficient;
d. The applicator or party accepting bulk residuals from the Permittee shall supply all third parties
receiving bulk residuals with documentation specifying that application shall occur consistent
with the utilization agreement;
e. Instructions, including contact information for key personnel, shall be provided to the applicator
or party receiving bulk residuals in the event that any requirements specified in the utilization
agreement are not met.
f. A copy of the Utilization Agreement shall be maintained at the land application sites when bulk
residuals are being applied.
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
the buyer. If an alternate storage site is used, approval must be obtained from the Division.
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.
12. The Permittee shall not distribute bulk residuals to any person or entity known to be applying
residuals contrary to the condition of the signed Utilization Agreement.
IV. MONITORING AND REPORTING REQUIREMENTS
1. 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.
WQ0009477Version 2.1 Shell Version 101116 Page 6 of 10

2. ervation Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Cons
and Recovery Act (RCRA). The analyses jcorrosivi"�, ignitability, reactivity, and toxicity
characteristic leaching procedure (TCLP)] 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)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0.00s)
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)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxvchlor (10.0)
'
2.4-D (10.0)
Methyl ethyl ketone (200.0)
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.
An analysis shall be conducted on the Class A residuals 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
Ammonia -Nitrogen
Molybdenum
Selenium
Arsenic
Nickel i Sodium
Cadmium
i Nitrate -Nitrite Nitrogen
Sodium. Adsorption Ratio
SAR
Calcium
Percent Total Solids
TKN
Copper
pH
Zinc
Lead
Phosphorus
Magnesium
i
Plant Available Nitrogen
(by calculation)
WQ0009477Version 2.3 Shell Versioi3 101116 Page 7 of 10

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.
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.
6. The Permittee shall maintain records tracking all bulk residual land application events. 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. 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).
7. Three copies of an annual report shall be submitted on or before March I". 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
htt :// ortal.nedenr.or(r/wel-)/wy /a s/lauh: iortinET, or can be obtained by contacting the Land
Application Unit directly. The annual report shall be submitted to the following address:
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
S. Noncompliance Notification
The Permittec 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. Any occurrence with the distribution program resulting in the land application of significant
amounts of wastes that are 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.
WQ0009477Version 2.1 Shell Version 101116 Page 8 of 10

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
be taken to ensure that the problem does not recur.
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.
2. Prior to each bulk residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport and application facilities to prevent malfunctions, facility deterioration
and operator errors resulting in discharges, which may cause the release of wastes to the
environment, a threat to human health or a public nuisance. The Permittee 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 Permittee 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.
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the land application 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.
NI. GENERAL CONDITIONS
I. 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.
2. This permit shall become voidable if the residuals land application events are not carried out in
accordance with the conditions of this permit.
3. This permit is effective only with respect to the nature and volume of residuals described in the
permit application and other supporting documentation.
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 NCG010000; 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,
5. In the event the residuals program changes ownership or the Permittee changes their 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.
WQ0009477Version 2.1 Shell Version 101116 -Page 9 of 10

6. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 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).
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 pursuant to 15A
NCAC 02T .0105(e)(3).
Permit issued this the 28" day of January, 2011
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
7
Cole . Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ00009477
WQ0009477Version 2.1 Shell Version 101116 Paine 10 of 10

ATTACHMENT A - Approved Residual Sources Certification Date: -January 28, 2011
Cascades Tissue Group —.North Carolina, a division of Cascades Holding 118 Inc. Permit Number: WQ0009477 Version: 2.1
-
Maximum
Monitoring
Monitoring
Monitoring
Approved
Owner
Facility Name
County
Permit
Biological
1Dr • Tons
3
Frequency for
Frequency For
Frequency for
Mineralization
Number
Residuals
Per Year r
Non -hazardous
Metals and
Pathogen
Characteristics Z
Nutrients 4
Reduction 'q a
Rate
Cascades Tissue Group -
Rockingham, NC Division
—
North C'arolirra, a division of
Fiber -Clan Distribution
Richmond
IY'Q0009477
No
50-000
Once per permit
See Table Below
See Table Below
0.40
Cascades I loldiug t1S ]rte.
ProgramTot
evele
al
50,000
I. illaxitnumr Dry "Tans per Year is the aniount of residuals product approved for distribution from the permitted facility.
2. Analyses to demonstrate that residuals are non-lun7ardous (i.e., TCLP, ignitabitity, reactivity. and corrosivity) as stipulated under permit Condition IV.2,
3_ Testing of metals and nutrients as stipulated under perinit Condition I"V.3.
4. Analyses ol-pathngen reduction as stipulated under permit Condition IVA.
5. Monitoring frequencies are based on the actual dry torts applied per year using the table below. unless specified abo%e.
Dry Ton,; Generated
short tun�eear�
Monitoring Frequency
Established in 40 CFR 503 and ISA NCAC oZT.0 111
:319
1/Year
->319 - <1,650
11 Quarter (4 tunes per year
_- 1,650 --16.500
1/60 Da Xs (6 times peryear)
T> 16,500
Umonth (12 times per year)
6. Class A residuals are exempt G-orn meeting [he vector attraction reduction requirements, therefore, shall not be mixed with residuals that have been generated during the treatment of domestic
wastewater, (lie treatment ofanintal processing wastewater, or the biological treatment of industrial wastewater. The Class A residuals must be treated and processed in a manner ms to not meet
the definition of" Biological Residuals" as defined in 15A NCAC 02 1'.1 102(6).
If no land application events occur during a required sampling period (e.g. no land application occur during an entire year when annual monitoring is
required), then €ro sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data.
Those required to submit the annual report to EPA may be required to make up the naisse€1 sampling, contact the EPA for additional information and
clarification.
Page 1 of

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
,severly Eaves Perdue Coleen H. Sullins
Governor Director
March 9, 2010
Mr. Eric Taylor, Mill Manager
Cascades Tissue Group — North Carolina, Inc.
P.O. Box 578
Rockingham, North Carolina 2 83 80
Dee Freeman
Secretary
RECEN ED t DEN RI 0tt0Q
pqu►f�. .
MAR 16 2414.
Subject: Permit Extension
Permit No. WQ0009477
Cascades Tissue Group
Rockingham NC Division
Distribution of Residuals Solids
Program (503 exempt)
Richmond County
Dear Mr. Taylor:
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. For additional information, the following
website ( http:/portal.ncdenr.org/web/wqlaps/lau#extension ) can be viewed to address this statute and
affected DWQ permits.
Nan -discharge permit, WQ0009477, issued by the Division of Water Quality falls within the
scope of this Act and is therefore being extended until 31 December 2014, Please note per your permit, a
renewal application must still be submitted six months in advance of the extended expiration date. If
Cascades Tissue Group — North Carolina, Incorporated needs to modify, upgrade, retrofit infrastructure at
this facility which would require modification of the permit; a permit application can be submitted for
review and the necessary modified permit issued.
If you have any questions regarding this letter, please contact Division staff in the Fayetteville
Regional Office at [phone] or Central Office at [phone]. Thank you in advance for your
cooperation.
Sincerel
ItAB-arl er 2
Aquifer Protection Section
cc: Fayetteville Regional Office, Aquifer Protection Section
WQ0009477 Permit File
WQ0009477 Notebook File
Richmond County Health Department
Technical Assistance and Certification Unit
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$23-6748 NorthCarolina
Internet: www.ncwaterpuaiity.arg �aturall�
An Equal OppoAunily 1.Affrrmalive Action Ernpbyer ` `/

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of EDvironment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
January 19, 2007
MR. MIKE KITNER, GENERAL MANAGER
CASCADES TISSUE GROUT? — NORTH CAROLINA, INC.
POST OFFICE BOX 578
ROCKINGHAM, NORTH CAROLINA 28380
Subject: Permit No. WQ0009477
Cascades Tissue Group- North Carolina, Inc.
Rockingham, NC Division Fiber -Clay
Distribution Program.
Distribution of Residual Solids (503Exempt)
Richmond County
Dear Mr. Kitner:
In accordance with your permit renewal and modification application package received on
October 29, 2003 as well as the additional information received on February 8, 2006; March 10, 2006;
May 5, 2006; and September 8, 2006 we are forwarding herewith a renewed and modified Permit No.
WQ0009477, dated January 19, 2007, to the Cascades Tissue Group —North Carolina, Inc. for the
continued operation of the subject residuals distribution/land application program.
This permit shall be effective from the date of issuance until December 31, 2011; shall void
Permit No. WQ0009477, issued on September 18, 2002; and shall 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 VI.7.), as the Division does not send reminders to apply for permit renewal.
This permit is being issued to approve the continued operation of the Fiber -Clay
distribution/land application program from the Permittee's Rockingham, NC Division for another five-
year cycle. As always, remember to take the time to review this permit thoroughly, as some of the
conditions contained therein may have been added, changed, or deleted since the last issuance. 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.
Aquifer Protection Section 1636 Mail Service Center
Internet: www.ncwatMualitv.ora Location: 2728 Capital Boulevard
An Equal OpportunitylAffirmative Action Employer- 50% Recycled110% Post Consumer Paper
North Carolina
�71�aturally
Raleigh, NC 27699-1636 Telephone: [phone]
Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

If any parts, requirements, and/or limitations contained in this permit are unacceptable, you have
the right to request an ad}udicatory 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 filed 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. Ed Hardee by
telephone at [phone] or via e-mail at [e-mail].
Sincerely,
i
Lor
Alan W. Klimek, P.E.
cc: Ms. Karen V. Bellamy, Cascades Tissue Group -North Carolina, Inc.
Mr. Monty R. Crump, City of Rockingham
Mr. Danny Turner, NCDACS —Plant Industry Division (Fertilizer Section)
Richmond County Health Department
Fayetteville Regional Office -Aquifer Protection Section
Technical Assistance and Certification Unit
APS Central Files
LAU Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF RESIDUAL SOLIDS (503 EXEMPT) 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
Cascades Tissue Group — North Carolina, Inc,
Richmond County
FOR THE
continued operation of a residuals distribution/land application program for the Rockingham, NC
Division of the Cascades Tissue Group — North Carolina, Inc., consisting of the distribution/land
application of residuals generated by the residuals source -generating facilities listed in the most recently -
certified Attachment A and marketed under the product name Fiber -Clay to unspecified land application
sites with no discharge of wastes to surface waters, pursuant to the permit renewal and modification
application package received on October 29, 2003 as well as the additional information received on
February 8, 2006; March 10, 2006; April 5, 2006; and September 8, 2006; 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 October 31, 2011; shall void Permit
No. WQ0009477, issued on September 18, 2002; and shall be subject to the following specified
conditions and limitations:
I. PERFORMANCE STANDARDS
The residuals distribution/land application program 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 residuals distribution/land
application program to adequately protect the assigned water quality standards of the surface
waters and groundwaters.
3. 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 residuals distribution/land
application program.

4. In the event that the residuals program is not operated satisfactorily, including the creation of
nuisance conditions, 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. For any reason that causes a violation of the permit, the Permittee
shall cease operations until the operational conditions that cause the violation have been
corrected.
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/land application in accordance with this permit. The Permittee shall request and
obtain a permit modification from the Division for each additional residuals source -
generating facility or each additional product generated by a currently -certified residuals
source -generating facility prior to acceptance into the residuals distribution/land application
program.
6. Only residuals that are non -hazardous under the Resource Conservation and Recovery Act
(RCRA) shall be approved for distribution/land application in accordance with this permit.
In order to be distributed/land applied under the conditions of this permit, the pollutant
concentrations in any residuals shall not exceed the following Ceiling Concentrations (i.e.,
dry weight basis) or the following Monthly Average Concentrations (i.e., dry weight
basis).
Parameter
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
Arsenic
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
2,800
In order to be distributed/land applied under the conditions of this permit, the residuals shall
be essentially pathogen -free, as evidenced by the testing of seven separate and representative
samples of the residuals for the presence of fecal coliform in accordance with Condition III.
4. of this permit. Distribution/land application of the residuals shall be strictly forbidden in
any sample results in a fecal coliform density of 1,000 most probable number (MPN) or
coliform forming units (CFq per gram of total dry solids. Note that utilization of the
geometric mean shall not be allowed to meet this condition. Only residuals that are generated
by the residuals source -generating facilities that are identified as being exempt from this
condition in the most recently -certified Attachment A shall not be required to comply with
this requirement.
2

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 a residuals distribution/land
application event of residuals generated by the residuals source -generating facility occurs
during that year.
11. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities and residuals distribution/land application program shall be properly
maintained and operated at all times.
2. Upon classification of the residuals distribution/land application program by the Water
Pollution Control System Operators Certification Commission (WPCSOCC), the Permittee
shall employ a certified operator to be in responsible charge (ORC) of the program. The
operator shall hold a certificate of the type classification assigned to the program by the
WPCSOCC. The Permittee shall also employ a certified back-up operator of the appropriate
type to comply with the conditions of 15A NCAC 8G .0202.
Diversion or bypassing of untreated residuals, decant water, or leachate from the residuals
source -generating facilities shall be prohibited. All decant water and leachate shall be
disposed through a Division -approved method.
4. A copy of this permit as well as a spill prevention and control plan shall be maintained in all
residuals transport vehicles.
5. All residuals shall be adequately stored prior to distribution/land application.
No residuals shall be stored at any location other than at the residuals source -generating
facilities listed in the most recently -certified Attachment A at any time, unless written,
approval has first been requested and obtained from the Division.
Staging/stockpiling/temporary storage of residuals at a land application site without prior
Division approval shall be allowed only if the Permittee adheres to the following criteria.
a. Only solid residuals shall be staged.
b. Staging areas shall meet the same buffers as for residuals distribution/land application as
stipulated in Condition 11.6.
c. Staging areas shall be selected such that the location is unlikely to create nuisance
conditions.
d. Guidance shall be provided to the recipient of the residuals regarding how to take
appropriate measures to prevent the direct contact of stormwater with staged residuals,
runoff of staged residuals from the staging area, or wind erosion of staged residuals.

e. Guidance shall be provided to the recipient of the residuals that the staged residuals shall
be distributed/land applied within one cropping cycle, not to exceed 180 calendar days of
being hauled to the site. The guidance shall further recommend that the recipient of the
residuals inspect the staging areas at least weekly during this staging period to ensure
that the measures taken to prevent the direct contact of stormwater with staged residuals,
runoff of staged residuals from the staging areas, or wind erosion of staged residuals are
operating properly and repaired as necessary.
f. Guidance shall be provided to the recipient of the residuals that the staged residuals shall
be removed from the staging area as well as appropriately distributed/land applied under
the conditions of this permit and that the staging area shall be restored to its precious
condition.
Guidance shall be provided to the recipient of the residuals that the following buffer zones
shall be maintained at all times when distributing/land applying residuals under the
conditions of this permit:
a. 100 feet from any private or public water supply sources;
b. 100 feet from any surface waters (i.e., intermittent and perennial streams, perennial
waterbodies, and wetlands; and
c. 100 feet from any well with the exception of groundwater monitoring wells.
7. Guidance shall be provided to the recipient of the residuals that the residuals shall be
distributed/land applied to all land application sites at agronomic rates. Such rates shall be
determined in conjunction with the Permittce's residuals management firm/technical
consultant and shall take factors such as the nutrient concentration/needs, liming
potential/needs, and solids content/crop status into account. Guidance shall be provided to the
recipient of the residuals that the residuals shall not be land applied at rates greater than
agronomic rates, unless authorized by the Division.
Guidance shall be provided to the recipient of the residuals that a suitable vegetative cover
shall be maintained or established on land application sites onto which residuals are
distributed/land applied.
9. Guidance shall be provided to the recipient of the residuals that residuals shall not be
distributed/land applied to any land application site that is flooded, frozen, or snow-covered,
10. Guidance shall be. provided to the recipient of the residuals that the residuals shall be
distributed/land applied only during periods of dry weather for land application sites that are
prone to flooding or historically wet
11. Guidance shall be provided to the recipient of the residuals that the residuals shall not be
distributed/land applied during inclement weather or until 24 hours following a rainfall event
to fields that are dominated with soils that have a USDA Soil Survey reported surface sat K
of less than. 2 inches/hr.
12. Guidance shall be provided to the recipient of the residuals that the residuals shall not be
distributed/land applied if the vertical separation of the seasonal high water table and the
depth of residuals application is less than one foot.
F.

13. Guidance shall be provided to the recipient of the residuals that the residuals shall not be
distributed/land applied if the vertical separation of the depth to bedrock and the depth of
residuals application is less than one foot.
14. All recipients of the distributed/land applied residuals shall be provided with an
information/data sheet that contains the following minimum information:
a. The name, address, and telephone number of the person who prepared the residuals.
b. The name, address, and telephone number of the person hauling the residuals to the land
application site.
c. A description of the source of or the process by which the residuals were generated.
d. Either a summary of the results from the most -recent round of residuals
sampling/monitoring or the NCDA-Agronomic web site address and access information.
e. A summary of the tons of residuals hauled to the land application site.
£ A statement that distribution/land application of the residuals shall be prohibited except
in strict accordance with the instructions/guidance on the information/data sheet.
g. A statement that the application rates of the residuals shall be Iimited to those that can be
agronomically justified (i.e., limited to that needed to meet the liming requirements of
the crops being grown on the land).
h. Specific guidance regarding how to comply with the requirements in Condition Il. 5.
through Condition. H. 13.
i. A list of recommendations to the recipient of the residuals regarding site use, soil testing,
pH monitoring and adjustment, as well as other relevant agronomic information.
III. MONITORING AND REPORTING REQUIREMENTS
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. Residuals generated by each residuals source -generating facility listed in the most -recently -
certified Attachment A of this permit shall be analyzed to demonstrate that they are non-
hazardous under the Resource Conservation and Recovery Act (RCRA). A corrosivity,
ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching Procedure
(TCLP) analysis shall be conducted on residuals generated by each residuals source -
generating facility listed in the most recently -certified Attachment A of this permit. The
analyses shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit, and the results shall be maintained on file by the Permittee for a
minimum of five years. If residuals generated by a particular residuals source -generating
facility are distributed/land applied at a frequency less than that which is specified in the
most recently -certified Attachment A of this permit, the analyses shall be required for each
residuals distribution/land application event. Only residuals that are generated by the
residuals source -generating facilities that are identified as being exempt from this condition
in the most recently -certified Attachment A of this permit shall not be required to comply
with this monitoring requirement.
5

The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter 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) Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide) (0,008) Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5) Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0) 2,4,5-Thchlorophenol(400.0)
m-Cresol (NU)
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) Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
After the residuals have been monitored as specified above 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 request a reduction of this
monitoring requirement. In
no case, however, shall the frequency of monitoring be less than
once per permit cycle.
3. A representative analysis shall be conducted on residuals generated by each residuals source -
generating facility listed in the most recently -certified Attachment A of this permit. The
analysis shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit, and the results shall be maintained on file by the Permittee for a
minimum of five years. if residuals generated by a particular residuals source -generating
facility are distributed/land applied at a frequency less than that which is specified in the
most recently -certified Attachment A of this permit, an analysis shall be required for each
residuals distribution/land application event. The analysis shall include, but shall not
necessarily be limited to, the foRowing parameters:
Aluminum
Lead
H
Carbon/Nitrogen Ratio
Magnesium
Phosphorus
Arsenic
Mercury
Zinc
Cadmium
Molybdenum
Potassium
Calcium
Nickel
Selenium
Calcium Carbonate
Equivalency
Copper
Sodium
Percent Total Solids
C

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 a residuals distribution/land
application event of residuals generated by the residuals source -generating facility occurs
during that year.
4. Residuals generated by each residuals source -generating facility listed in the most recently -
certified Attachment A of this permit shall be monitored for compliance with Condition I. 8.
The monitoring shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit, and the results of all analyses shall be maintained on file by the
Permittee for a minimum of five years. Only residuals that are generated by the residuals
source -generating facilities that are identified as being exempt from Condition I, 8. in the
most recently -certified Attachment A of this permit shall not be required to comply with this
monitoring requirement.
5. Laboratory analyses as required by Condition M. 2., Condition 111. 3., and Condition M. 4.
shall be performed/gathered on the residuals as they are to be distributed/land applied.
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 2H .0800 or 15A NCAC 2H .1100.
6, Proper records shall be maintained by the Permittee tracking all residuals distribution/land
application activities. These records shall include, but are not necessarily limited to, the
following information:
a. Source of residuals distributed/land applied.
b. Date that residuals hauled to the land application site.
c. Name of the initial recipient of the residuals, dry tons hauled, and the intended use.
7. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition 111. 2., Condition III. 3., Condition III. 4., Condition 111. 5., and Condition
III. 6. shall be submitted annually on or before March 1 st of the year following the residuals
distribution/land application event to the following address:
NCDENR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Noncompliance Notification:
The Permittee shall report by telephone to the Aquifer Protection Section of the Division's
Fayetteville Regional Office at telephone number [phone], 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 residuals distribution/land application program which results in
the distribution/land application of significant amounts of residuals which are abnormal.
in quantity or characteristic.
b. Any failure of the residuals distribution/land application program resulting in a release of
material to receiving waters.
7

c. Any time that self -monitoring information indicates that the residuals distribution/land
application program has gone out of compliance with the conditions and limitations of
this permit or the parameters on which the program was designed.
d. Any process unit failure, due to known or unknown reasons, that render the residuals
distribution/land application program incapable of adequate residuals treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of
residuals.
Occurrences outside of normal business hours (i.e., from. 8:00 a.m. until 5:00 p.m. on
Mondays through Fridays, except State Holidays) may also be reported to the Division's
Emergency Response personnel at one of the following telephone numbers [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 be taken to ensure that the problem does not recur.
IV. GROUNDWATER REQUIREMENTS
Other Reouirements:
Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
I. The Per ittee or his designee shall inspect all facilities related to the residuals
distribution/land application 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 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 residuals distribution/land application 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.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the residuals distribution/land application 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 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 15A NCAC 2T.0I05(e).
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 1 SA NCAC Chapter 4 and under the Division's General Permit NCG010000,
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
residuals distribution/land application 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.
This permit shall not be automatically transferable. In the event that there is a desire for the
residuals distribution/land application program to change ownership or to change the name of
the Permittee, a formal permit request shall be .submitted to the Division along with
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 190' days of January, 2006.
NORTH
MANAGEMENT COMMISSION
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0009477
2

ATTACIDIENT A - Approved Residual Sourees-Generatin Facilities
Permit Number: WQ0009477
Cascades Tissue Group - North Carolina Inc
Rocidngliam, NC Division Fiber -Clay Distribution Program
Maximum
Monitoring
Monitoring Frequency
Approved
Dry Tons Per
Frequency for
for Condition III. 3. and
Mineralization
Owner
Facility -Product Name
County
Permit Number
Issued By
Is 503?
Year
Condition III. 2.
Condition III.4.
Rate
Cascades Tissue Group-
Rockingham, NC Division WWTP -
City of
North Carolina, Inc_
FiberCl
Richmond
IiJP NO. 0004
Rockingham
non 503
50,000.
Once per permit cycle
Quarterly
40
Total
50,000.
a Only residuals derived from the treatment of industrial wastewater shall be approved for distrihution/Iand application in accordance with this permit It is the Division's understanding that
domestic wastewater generated from Cascade Tissue's Rockingham, NC Facility is discharge to the municipal wastewater collection system. Under no circumstance shall domestic wastewater be
introduced to this wastewater treatment planL A modification to this pennit shall be requested and approved by the Division if there is a desire to combine the domestic and industrial wastewater sources.
Pennit No, WQ0009477 Page 1 of 1 Certification Date January 19, 2007

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
December 10, 2001
PIERRE LEBEAU, PLANT MANAGER
C/O KAREN BELLAMY, ENVIRONMENTAL DIRECTOR
PERKINS PAPERS (USA) LTD.
P O BOX 578
ROCKINGHAM, NC 28379
Dear Mr_ Lebeau:
4 •
Ad
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No, WQ0009477
Perkins Papers (USA) LTD.
Distribution of Waste Products
of Exceptional Quality: Fiber -Clay TM
Richmond County
In accordance with your modification request, received on September 14, 200I, and subsequent
responses to additional information requests, received from November 8, 2001 through November 19, 2001;
we are forwarding herewith Permit No. WQ0009477, dated December 10, 2001, to Perkins Papers (USA)
LTD., for the distribution and marketing of "Fiber-C1ayTM," consisting of up to 50,000.00 dry tons of paper -
processing wastewater residual by-products which meet exceptional quality standards.
This permit shall be effective from the date of issuance until January 31, 2004, shall void Pernut No.
WQ0009477, issued February 21, 2000, 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.
Please take time to review this permit thoroughly. Of special interest are the following items:
• Please note that the facility and residuals product description has been detailed within the first
paragraph of the permit on page 1.
• Please note that Condition I. 6., of the previously issued February 21, 2000 permit has been
removed, the distribution and marketing label incorporates land application buffer guidelines
within its current text. The Permittee is responsible for providing this label to all recipients of the
Fiber-ClayTM residuals product.
• Condition I.5.: Regarding the prohibited activity of diversion or bypassing of untreated residuals
or leachate from the residual treatment facility.
• Condition II.2.: Regarding the approval of an increased distribution volume of up to 50,000 dry
tons per year of the Fiber-C1ayTM residuals product.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

• Condition 11.5.: Due to the 100 percent industrial content of the Fiber -Clay'" residuals product,
only the parameters listed in this Condition, will need to be maintained for Ceiling Concentrations,
and Pollutant Monthly Average Concentrations.
• Condition H. 6.: Regarding the changed document reference from 15A NCAC 08A .0202
(previous permit issuance) to 15A NCAC 08G .0202, describing the Permittee's requirements for
employment of an Operator in Responsible Charge (ORC).
• Condition 11. 8.: Regarding the necessary marketing label information that must be provided to
the residuals customer, upon receipt of the distributed product. The actual label is found on page 8
of the permit. This marketing label will need to be given to each customer prior to distribution of
your residuals product.
• Please note that Condition 11. 9., of the previously issued February 21, 2000 permit has been
removed, and is a part of the Fiber ClayTm marketing label.
• Condition 111. 3. a. through IH. 3. d.: Regarding Permittee record -keeping responsibilities,
when Fiber C1ayT" is distributed and marketed to the same customer on a consistent basis. Please
note that Condition HL 3. d. contains information regarding soil sampling guidance and frequency,
and analysis parameters.
• Condition 111. 4.: Regarding increased monitoring of residuals analysis to MONTHLY, and the
inclusion of the following parameters, based on pastAiscussion (November 7, 2001 site visit) with
Permittee's representative Dr. Elwood Black: Total Nitrogen: Total Carbon ratio; and Calcium
Carbonate Equivalency. Also, due to the 100 percent industrial nature of the residuals product, the
following parameters have been removed: Arsenic, Chromium, Molybdenum, and Selenium, in
synchrony with their removal in Condition H. 5. Also note that statement regarding reduction in
residuals monitoring.
• Condition HI.5.: Regarding reduction in TCLP monitoring.
• Conditions W.1. : Please note the changed document references for the Compliance and Review
boundaries, as required by the Division, in regards to,the residuals facility system.
• Condition V. 1.: Regarding Permittee responsibility to maintain an inspection log or summary of
the residuals facility system.
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 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 contact Theresa Nartea at (919) 733-
5083 extension 375.
Sincerely, 1
/ r /
Gregory J. Thorpe, Ph.D. `

cc: Richmond County Health Department
Fayetteville Regional Office, Water Quality Section
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
Dr. Elwood Black-P O Box 3244, Cary, NC 27519
Perkins Paper (USA) Ltd. -Karen Bellamy, P O Box 578, Rockingham, NC 28379
Advanced Residuals Management, LLC-P O Box 10159, Southport, NC 28461
NDPU files

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
Perkins Papers (USA) LTD.
Richmond County
FOR THE
continued operation of a recycled paper processing and production residuals facility, comprised of : two -Black
Clawson Double Nip Thickeners; one-Poseiden 1200"de-inking clarifier, one-17,500 gallon sludge tank; one -
horizontal trommel screen; one -sludge belt press; one-400 cubic yard covered storage shed; and all associated
valves, piping, and appurtenances, for the distribution and marketing of up to 50,000 dry tons per year Fiber -
Clay TM residuals (a by-product of recycled paper processing, with no domestic wastewater contribution),
which meets the exceptional quality standards throughout the State of North Carolina, from the source listed in
Condition II.2., with no discharge of wastes to the surface waters, pursuant to the modification request
received on September 14, 2001, and subsequent responses to additional information requests, received from
November S, 2001 through November 19, 2001; 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 January 31, 2004, shall void Permit No.
WQ0009477 issued February 21, 2000, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
1. The distribution and marketing residuals program 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 residuals
program to adequately protect the assigned water quality standards of surface waters and
groundwater.
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 program.

IT.
4. In the event that the distribution and marketing residuals 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. Diversion or bypassing of the untreated residuals or leachate from the residual treatment facilities is
prohibited_
6. All leachate must be reused as a wetting agent for the processing of residuals or routed to the head of
the treatment plant.
OPERATION AND MAINTENANCE REQUIREMENTS
The residuals treatment facilities shall be properly maintained and operated at all times.
2. No residuals other than the following are hereby approved for distribution in accordance
with this permit:
Permit Volume
Source Coqgty Number (DEy Tons/Year
Perkins Papers (USA) Ltd. Richmond IUP #0004 50,000.00
All residuals shall be adequately stored to prevent leachate runoff until treated. The finished
product may be placed on a concrete pad, placed under shelter or covered until such time as it is
distributed to the buyer. If an alternate storage site is to be used, approval must be obtained from
the Division.
4. No other residuals other than those specified under Condition II. 2., shall be distributed. The
Permittee shall request and obtain a permit amendment from the Division for each additional
residual source prior to acceptance of that residual.
5_ For a residual 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/kg
mg/kg
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Nickel
420
420
Zinc
7,500
2,800
6" Upon classification of the facility by the Water Pollution Control System Operators Certification
Commission (WPCSOCC), the Permittee shall employ a certified residuals operator to be in
responsible charge (ORC) of the residuals program. The operator must hold a certificate of the
type classification assigned to the residuals program by the WPCSOCC. The Permittee must also
employ a certified back-up operator of the appropriate type to comply with the conditions of 15A
NCAC 08G .0202.
7. Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying
pollutants from the residuals treatment area onto the adjacent property or into any surface waters.

8. 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 an other container for application to the land. The Iabel or
information sheet shall contain, at a minimum, the following information (Label is attached to the
back of permit, on page 8):
a. The name and address of the person who prepared the 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 Iabel 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. Residuals shall not be applied to any site that is flooded, frozen or snow-covered.
e. Adequate procedures shall be provided to prevent surface runoff from carrying any disposed
or stored residuals into any surface waters.
III. MONITORING AND REPORTING REQUIREMENTS
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 distribution activities.
These records shall include, but are not necessarily limited to the following information:
a. Source, volume and analysis of each residuals;
b. Name of residuals'recipient, volume received, and intended use
3. If the Permittee becomes aware of a distribution and marketing situation, wherein the Fiber-
Clay r"' residuals will be marketed to the same customer on a consistent basis (i.e., the residuals
product will be applied to the same acreage for greater than two sequential cropping years); then
the following records shall be maintained, and kept on file by the Permittee for a minimum of five
years:
a. Location of residual application (site, field, or zone number);
b. Volume of residuals applied in dry tons/acre;
c. Type of crop, or crops to be grown on the field; and
d. An ANNUAL representative soil analysis shall be conducted, in the same calendar year that
the distribution event occurred. The analysis shall be conducted on each of the given
customer's site(s), which have a history (see Condition III.3.) of Fiber-C1ayrm residuals
application. Soil shall be sampled at the effective rooting depth of crop grown, or at the 0-6
inch sample depth, whichever is most applicable for the given field situation.
Calcium Magnesium Sodium
Manganese Potassium Copper
Zinc pH Phosphorus
Exchangeable Acidity Base Saturation Lime Recommendation
Ammonia -Nitrogen Nitrate -Nitrogen Total Nitrogen: Total Carbon
Cation Exchange Capacity

4. A residual analysis shall be conducted MONTHLY, 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 residuals analysis shall include the following parameters:
Cadmium Copper Lead
Nickel Zinc Aluminum
Sodium Calcium Magnesium
Total Nitrogen: Total Carbon Total Kjeldahl Nitrogen Nitrate -Nitrite Nitrogen
Ammonia -Nitrogen Total Solids Percentage (%} pH
Phosphorus Potassium
Plant Available Nitrogen (by calculation)
Calcium Carbonate Equivalency
After the residuals have been monitored for two years at the above frequency, the Permittee may
submit a request to the Division for a permit modification to reduce the frequency of monitoring
for pollutant concentrations. In no case, however, shall the frequency of monitoring be less than
once per year when residuals are sold or given away.
5. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted ANNUALLY
by the Permittee. The TCLP analysis shall include the following parameters (please note the
regulatory level in mg/L in parentheses):
Arsenic (5.0)
Cadmium (1.0)
Chlorobenzene (100.0)
o-Cresol (200.0)
Cresol (200.0)
1,2-Dichloroethane (0.5)
Endrin (0.02)
Hexachlorobenzene (0.13)
Lead (5.0)
Methoxychlor (10.0)
Pentachlorophenol (100.0)
Silver (5.0)
Trichloroethylene (0.5)
2,4,5-TP (Silvex) (1.0)
Barium (100.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chloroform (6.0)
Chromium (5.0)
m-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,4-Dichlorobenzene (7.5)
1,1-Dichloroethylene (0.7)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Hexachloroethane (3.0)
Lindane (0.4)
Mercury (02)
Methyl ethyl ketone (200.0)
Pyridine (5.0)
Tetrachioroethylene (0.7)
2,4,5-Trichlorophenol (400.0)
Vinyl chloride (0.2)
Nitrobenzene (2.0)
Selenium (1.0)
Toxaphene (0.5)
2,4,6-Trichlorophenol (2.0)
After the residuals have been monitored annually for two years, the Permittee may submit a
request to the Division for a permit modification to reduce the frequency of the TCLP analysis. in
no case, however, shall the frequency of TCLP monitoring be less than once per permit cycle
when residuals are sold or given away.
6. Three copies of all required monitoring and reporting requirements as specified in Conditions I11.
1., III. 2., III. 3., I11.4., and 111. 5., shall be submitted ANNUALLY, on or before March 1st of the
year following the initial distribution event, 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
4

Noncompliance Notification:
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone number
[phone], 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 residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of residuals.
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 must outline the actions
taken or proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REOUIREMENTS
1. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC
2L, Groundwater Classifications and Standards. The Compliance Boundary for the disposal system
individually permitted after December 31, 1983, and is established at either (1) 250 feet from the
waste disposal area, or (2) 50 feet within the property boundary, whichever is closest to the waste
disposal area. An exceedance of Groundwater Quality Standards at or beyond the Compliance
Boundary is subject to immediate remediation action according to 15A NCAC 2L .0106 (d)(2).
The REVIEW BOUNDARY is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of standards at
the Review Boundary shall require action, in accordance with 15A NCAC 2L.0106 (d)(1).
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
V. INSPECTIONS
1, 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 Penmittee.
This Iog 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. `
5

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'che 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.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the distribution and marketing 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 subrnitted
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 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 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.
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.
6

Permit issued this the tenth day of December, 2001.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
t
l ` Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0009477

Fiber CIayTM
Provided by
Perkins Papers (USA) LTD.
805 Midway Road
Rockingham, NC 28380
I. The application of Fiber Clay'rm residuals, must be in accordance with the instructions on this information
sheet.
2. Fiber C1ayT"' residuals, shall not be applied to flooded, frozen, or snow-covered fields.
3. Fiber CiayTm residuals, shall not be spread within the following buffers:
a. 100 feet from any public or private water supply source, waters classified as SA or SB; or any Class I,
or Class II impounded reservoir which is used as a drinking water source;
b. 100 feet from any streams classified as WS or B, any stream, canal, or marsh; and
c. 50 feet from a property line.
4. Adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored
residuals, into any surface waters.
5. Fiber ClayTM residuals shall be applied in a manner such that an adequate cover crop can be grown
successfully.
8

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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
.lames B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
February 21, 2000
KAREN V. BELLAMY, TECHNICAL DIRECTOR
PERKINS PAPERS USA LTD.
ROCKINGHAM DIVISION
POST OFFICE BOX 578
ROCKINGHAM, NC 28380
Dear Mr. Ashley:
NCDENR
NORTH CAROLWA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No. WQ0009477
Perkins Papers USA Ltd.
Rockingham Division
Distribution of Waste Products
of Exceptional Quality
Richmond County
In accordance with your request received on February 9, 2000, we are forwarding herewith
Permit No. WQ0009477, dated February 21, 2000, to Perkins Papers USA Ltd. Rockingham Division.
for distribution and marketing of waste products which meet exceptional quality standards. This permit
is being issued to reflect the request to change the Permittee from Cascades Industries, Inc. to
Perkins Papers USA Ltd. No other parts or conditions of the permit have changed as a result of
the request. The subject residuals do not contain any domestic sewage and has pollutant concentrations
below the exceptional quality criteria. Please be advised this program must be operated in a manner that
will allow a cover crop to be grown on all application sites. This permit shall be effective from the date
of issuance until January 31, 2004, shall void Permit No. WQ0009477 issued February 26, 1999, and
shall be subject to the conditions and limitations as specified therein.
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 contact Kristin Miguez at (919)
733-5083 extension 524.
Sin r y, f
Derr T. Stevens
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Sincerely,
Kerr T. Stevens t
cc: Richmond County Health Department
Fayetteville Regional Office, Water Quality Section
Technical Assistance and Certification Unit (no revised rating)
Non -Discharge Compliance/Enforcement Unit

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF EXCEPTIONAL QUALITY RESIDUALS
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
Perkins Papers USA Ltd., Rockingham Division
Richmond County
FOR THE
distribution and marketing of waste products which meet exceptional quality standards throughout the
State of North Carolina, consisting of the distribution of 16,000 dry tons per year of residuals from the
sources listed in Condition II 2, with no discharge of wastes to the surface waters, pursuant to the
amendment request received on September 17, 1997, 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 January 31, 2004, shall void Permit
No. WQ0009477 issued February 26, 1999, and shall be subject to the following specified conditions
and limitations:
I. PERFORMANCE STANDARDS
1. The program for the distribution and marketing of waste products which meet exceptional
quality standards 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.
3. 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).
1

5. All leachate must be reused as a wetting agent for the processing of residuals or routed to
the head of the treatment plant.
6. The following buffers shall be maintained:
_ R
a) 100 feet from any public or private water supply source, waters classified as SA or
SB, and any Class I or Class II impounded reservoir used as a source of drinking
water for both methods,
b) 100 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment, and
c) 50 feet from property lines.
IT. OPERATION AND MAINTENANCE REQUIREMENTS
1. The residuals treatment facilities shall be properly maintained and operated at all times.
2. No residuals other than the following are hereby approved for distribution in accordance
with this permit:
Permit Volume
Source County Number (Dry Tons/Year)
Perkins Papers USA Ltd. Richmond NIA 16,000
3. All residuals shall be adequately stored to prevent leachate runoff until treated. The
finished product may be placed on a concrete pad, placed under shelter or covered until
such time as it is distributed to the buyer. If an alternate storage site is to be used,
approval must be obtained from the Division.
4. No other residuals other than those specified under Condition 11 2 above may be
distributed. The Permittee shall request and obtain a permit amendment from the
Division for each additional residual source prior to acceptance of that residual.
5. For these 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/kg
mglkg
Arsenic
_
75
41
Cadmium
85
39
Chromium
3000
1200
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
--
Nickel
420
420
Selenium
100
36
Zinc
7,500
2,800
2

6. Upon classification of the facility by the Water Pollution Control System Operators
Certification Commission (WPCSOCC), the Permittee shall employ a certified residuals
operator to be in responsible charge (ORC) of the residuals program. The operator must
hold a certificate of the type classification assigned to the residuals program by the
WPCSOCC. The Permittee must also employ a certified back-up operator of the
appropriate type to comply with the conditions of 15A NCAC 8A .0202.
7. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residuals treatment area onto the adjacent property or into
any surface waters.
8. 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 an 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 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 indicates that this material must comply with the buffers listed
Condition 16.
d. Residuals shall not be applied to any site that is flooded, frozen or snow-covered.
e Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored residuals into any surface waters.
9. These residuals shall be applied in a manner such that a cover crop can be grown on the
application site. The rate at which these residuals are to be applied will be determined
through the test plots outlined in the application package. The proposed application rates
for the test plots will be 25, 100, 175, 250, and 325 tons per acres. Once a conservative
application rate has been determined, this rate will be utilized in all applications.
III. MONITORING AND REPORTING REQUIREMENTS
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, volume and analysis of each residuals
b. name of residuals'recipient, volume received, and intended use
3

if the distribution and marketing of the subject residuals are applied in a manner
consistent with other land application permits (i.e. on the same acreage year after year),
then the following records shall be maintained:
a. location of residual application (site, field, or zone #)
b. volume of residuals applied in gallons/acre, dry tons/acre or kilograms/netare
c. type of crop or crops to be grown on field
d. soils analysis as outlined below:
A representative annual soils analysis (Standard Soil Fertility Analysis) shall be
conducted on each site receiving residuals in the respective calendar year and the
results maintained on file by the Permittee for a minimum of five years. The
Standard Soil Fertility Analysis shall include, but is not necessarily limited to, the
following parameters:
Acidity
Calcium
Copper
Magnesium
Base Saturation (by calculation.)
Cation Exchange Capacity
Manganese Potassium.
Percent Humic Matter Sodium
PH Zinc
Phosphorus
3. A residual analysis shall be conducted quarterly 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 residuals analysis shall include the following parameters:
Arsenic Cadmium Chromium
Molybdenum Nickel
Aluminum
Ammonia -Nitrogen
Calcium
Magnesium
Nitrate -Nitrite Nitrogen
% TotaI Solids
Selenium
Copper Lead
Zinc
pH
Phosphorus
Plant Available Nitrogen (by calculation)
Potassium
Sodium
TKN
11

4. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by
the Permittee annually. The TCLP analysis shall include the following parameters
(please note the regulatory level in mg[L in parentheses), -
Arsenic (5.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlorobenzene (100.0)
Chromium (5.0)
m-Cresol (200.0)
Cresol (200.0)
1,4-Dichlorobenzene (7.5)
1,1-Dichloroethylene (0.7)
Endrin (0.02)
Hexachlorobenzene (0.13)
Hexachloroethane (3.0)
Lindane (0.4)
Methoxychlor (10.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Silver (5.0)
Toxaphene (0.5)
2,4,5-Trichlorophenol (400.0)
2,4,5-TP (Silvex) (1.0)
Barium (100.0)
Cadmium (1.0)
Chlordane (0.03)
Chloroform (6.0)
o-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,2-Dichloroethane (0.5)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Lead (5.0)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Pentachlorophenol (100.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Trichloroethylene (0.5)
2,4,6-Trichlorophenol (2.0)
Vinyl chloride (0.2)
5. Three copies of all required monitoring and reporting requirements as specified in
conditions III 1, 1112,1113, 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. Noncompliance Notification:
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone
number [phone], 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.
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.
5

d. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate residual treatment.
Any spillage or discharge from a vehicle or piping system during transportation of
residuals.
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. GROUNDWATER REQUIREMENTS
1. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
1.5A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary
is for the disposal system constructed after December 31, 1983 is established at either (1)
250 feet from the waste disposal area, or (2) 50 feet within the property boundary,
whichever is closest to the waste disposal area. An exceedance of Groundwater Quality
Standards at or beyond the Compliance Boundary is subject to immediate remediation
action in addition to the penalty provisions applicable under General Statute 143-
215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the
waste disposal area. Any exceedance of standards at the Review Boundary shall require
remediation action on the part of the permittee.
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. 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.

VI. GENERAL CONDITIONS
1. 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.
7. 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.
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 thowenty-first day of February, 2000
NORTH AROLINA NMENTAL MANAGEMENT COMMISSION
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0009477
7

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 26, 1999
Richard Ashley
Cascades Industries, Inc.
Post Office Box 578
Rockingham, North Carolina 28379
LTI.KMAI
A&7
Am
D E N R
Subject: Permit No. WQ0009477
Cascades Industries, Inc.
Distribution of Waste Products of
Exceptional Quality
Richmond County
Dear Mr. Ashley.
In accordance with renewal request received on November 5, 1998, we are forwarding herewith
Permit No. WQ0009477, dated February 26, 1999, to Cascades Industries, Inc. for distribution and
marketing of waste products which meet exceptional quality standards. The subject residuals do not
contain any domestic sewage and has pollutant concentrations below the exceptional quality criteria.
Please be advised this program must be operated in a manner that will allow a cover crop to be grown on
all application sites. This permit shall be effective from the date of issuance until January 31, 2004,
shall void Permit No. WQ0009477 issued November 26, 1997, and shall be subject to the conditions and
limitations as specified therein. Please note several additional pollutants limits have been added to
§II.5., and additional pollutant residuals analysis requirements have been added to §111.3.
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, P.O. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
During our review of the 1997 Annual Report for the permit, the Annual Soils Analysis
reports could not be located. In all future reports, this analysis must be included or the Division will
consider enforcement actions and permit rescission. If you need additi al information concerning this
matter, please contact Joe Pearce at [phone] extension 544.
r
Size i
✓�. Preston Howard, Jr., P.E.
J�
cc: Richmond County Health Department
Fayetteville Regional Office, Water Quality Section
Technical Assistance and Certification Unit (no revised rating)
Non -Discharge Compliance/Enforcement Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF EXCEPTIONAL QUALITY RESIDUALS
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
Cascades Industries, Inc.
Richmond County
FOR THE
distribution and marketing of waste products which meet exceptional quality standards throughout the
State of North Carolina, consisting of the distribution of 16,000 dry tons per year of residuals from the
sources listed in Condition II 2, with no discharge of wastes to the surface waters, pursuant to the
amendment request received on September 17, 1997, 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 July 31, 1999, shall void Permit No.
WQ0009477 issued November 26, 1997, and shall be subject to the following specified conditions and
Iimitations:
I. PERFORMANCE STANDARDS
1. The program for the distribution and marketing of waste products which meet exceptional
quality standards 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.
3. 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).
S. All leachate must be reused as a wetting agent for the processing of residuals or routed to
the head of the treatment plant.

6. The following buffers shall be maintained.
a) 100 feet from any public or private water supply source, waters classified as SA or
SB, and any Class I or Class II impounded reservoir used as a source of drinking
water for both methods,
b) 100 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment, and
c) 50 feet from property lines.
II. OPERATION AND MAINTENANCE REQUIREMENTS
The residuals treatment facilities shall be properly maintained and operated at all times.
2. No residuals other than the following are hereby approved for distribution in accordance
with this permit:
Permit Volume
Source County Number (Dry Tons/Year
Cascades Industries, Inc. Richmond N/A 16,000
3. All residuals shall be adequately stored to prevent leachate runoff until treated. The
finished product may be placed on a concrete pad, placed under shelter or covered until
such time as it is distributed to the buyer. If an alternate storage site is to be used,
approval must be obtained from the Division.
4. No other residuals other than those specified under Condition II 2 above may be
distributed. The Permittee shall request and obtain a permit amendment from the
Division for each additional residual source prior to acceptance of that residual.
5. For these 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/kg
mg/kg
Arsenic
75
41
Cadmium
85
39
Chromium
3000
1200
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
--
Nickel
420
420
Selenium
100
36
Zinc
7,500
2,800
6. Upon classification of the facility by the Water Pollution Control System Operators
Certification Commission (WPCSOCC), the Permittee shall employ a certified residuals
operator to be in responsible charge (ORC) of the residuals program. The operator must
hold a certificate of the type classification assigned to the residuals program .by the
WPCSOCC. The Permittee must also employ a certified back-up operator of the
appropriate type to comply with the conditions of 15A NCAC 8A .0202.
K

7. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residuals treatment area onto the adjacent property or into
any surface waters.
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 an 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 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.
A statement which indicates that this material must comply with the buffers listed
Condition 16.
d. Residuals shall not be applied to any site that is flooded, frozen or snow-covered.
Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored residuals into any surface waters.
9. These residuals shall be applied in a manner such that a cover crop can be grown on the
application site. The rate at which these residuals are to be applied will be determined
through the test plots outlined in the application package. The proposed application rates
for the test plots will be 25, 100, 175, 250, and 325 tons per acres. Once a conservative
application rate has been determined, this rate will be utilized in all applications.
III. MONITORING AND REPORTING REQUIREMENTS
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, volume and analysis of each residuals
b. name of residuals' recipient, volume received, and intended use
If the distribution and marketing of the subject residuals are applied in a manner
consistent with other land application permits (i.e. on the same acreage year after year),
then the following records shall be maintained:
a. location of residual application (site, field, or zone #)
b. volume of residuals applied in gallons/acre, dry tons/acre or kilograms/hectare
c. type of crop or crops to be grown on field
d. soils analysis as outlined below:

A representative annual soils analysis (Standard Soil Fertility Analysis) shall be
conducted on each site receiving residuals in the respective calendar year and the
results maintained on file by the Permittee for a minimum of five years. The
Standard Soil Fertility Analysis shall include, but is not necessarily limited to, the
following parameters:
Acidity
Calcium
Copper
Magnesium
Base Saturation (by calculation)
Cation Exchange Capacity
Manganese
Percent Humic Matter
PH
Phosphorus
Potassium
Sodium
Zinc
3. A residual analysis shall be conducted quarterly 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 residuals analysis shall include the following parameters:
Arsenic Cadmium Chromium Copper Lead
Molybdenum Nickel Selenium Zinc
Aluminum
pH
Ammonia -Nitrogen
Phosphorus
Calcium
Plant Available Nitrogen (by calculation)
Magnesium
Potassium
Nitrate -Nitrite Nitrogen
Sodium
% Total Solids
TKN
4. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by
the Permittee annually. The TCLP analysis shall include the following parameters
(please note the regulatory level in mg/L in parentheses):
Arsenic (5.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlorobenzene (100.0)
Chromium (5.0)
m-Cresol (200.0)
Cresol (200.0)
1,4-Dichlorobenzene (7.5)
I ,1-Dichloroethylene (0.7)
Endrin (0.02)
Hexachlorobenzene (0.13)
Hexachloroethane (3.0)
Lindane (0.4)
Methoxychlor (10.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Silver (5.0)
Toxaphene (0.5)
2,4,5-Trichlorophenol (400,0)
2,4,5-TP (Silvex) (1.0)
4
Barium (100.0)
Cadmium (1.0)
Chlordane (0.03)
Chloroform (6.0)
o-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,2-Dichloroethane (0.5)
2,4-Dinitrotoluene (0A3)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Lead (5.0)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Pentachlorophenol (100.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Trichloro ethylene (0.5)
2,4,6-Trichlorophenol (2.0)
Vinyl chloride (0.2)

Three copies of all required monitoring and reporting requirements as specified in
conditions 111 1, 1112, II1 3, and 111 4 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
Post Office Box 29535
Raleigh, North Carolina 27626-0535
6. Noncompliance Notification:
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone
number [phone], 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 residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of
residuals.
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. GROUNDWATER REQUIREMENTS
1 _ The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary
is for the disposal system constructed after December 31, 1983 is established at either (1)
250 feet from the waste disposal area, or (2) 50 feet within the property boundary,
whichever is closest to the waste disposal area. An exceedance of Groundwater Quality
Standards at or beyond the Compliance Boundary is subject to immediate remediation
action in addition to the penalty provisions applicable under General Statute 143-
215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the
waste disposal area. Any exceedance of standards at the Review Boundary shall require
remediation action on the part of the permittee.
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.

V. 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.
VI. 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.
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.
7. 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.
No

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 TwAty-sixth day of February, 1999
NORTH CA"LINA EJIVIRNWNTA,Z/MANAGEMENT COMMISSION
.��. I'xeston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0009477
7

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Richard Ashley
Cascades Industries, Inc.
Post Office Box 578
Rockingham, North Carolina 28379
Dear Mr. Ashley:
LTI.K;TA
IT
A&4
An
BEN Fi
November 26, 1997
Subject: Permit No. WQ0009477
Cascades Industries, Inc.
Distribution of Waste Products of
Exceptional Quality
Richmond County
In accordance with amendment request received on September 17, 1997, we are forwarding
herewith Permit No. WQ0009477 as amended, dated November 26, 1997, to Cascades Industries, Inc.
for distribution and marketing of waste products which meet exceptional quality standards. This permit is
being amended to changed the previous Iand application permit into a distribution and marketing permit.
The subject residuals do not contain any domestic sewage and has pollutant concentrations below the
exceptional quality criteria. Please be advised, this program must be operated in a manner that will allow a
cover crop to be grown on all application sites.
This permit shall be effective from the date of issuance until July 31, 1999, shall void Permit No.
WQ0009477 issued August 31, 1995, 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 Iimitations 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, P.O. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
If you need additional information concerning this matter, please contact Mr. Michael D. Allen at
[phone] extension 547.
Sincerel
_,_4A. Preston Howard, Jr., P.E.
cc: Richmond County Health Department
S&ME, Inc.
Fayetteville Regional Office, Water Quality Section
Technical Assistance and Certification Unit (no revised rating)
Non -Discharge Compliance/Enforcement Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% 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
Cascades Industries, Inc.
Richmond County
FOR THE
distribution and marketing of waste products which meet exceptional quality standards throughout the
State of North Carolina, consisting of the distribution of 16,000 dry tons per year of residuals from the
sources listed in Condition IT 2, with no discharge of wastes to the surface waters, pursuant to the
amendment request received on September 17, 1997, 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 July 31, 1999, shall void Permit No.
WQ0009477 issued August 31, 1995, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
1. The program for the distribution and marketing of waste products which meet exceptional
quality standards 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.
3. 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. All leachate must be reused as a wetting agent for the processing of residuals or routed to
the head of the treatment plant.

6. The following buffers shall be maintained:
a) 100 feet from any public or private water supply source, waters classified as SA or SB,
and any Class I or Class IT impounded reservoir used as a source of drinking water for
both methods,
b) 100 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment, and
c) 50 feet from property lines.
II. OPERATION AND MAINTENANCE RE UIREMENTS
1. The residuals treatment facilities shall be properly maintained and operated at all times.
2. No residuals other than the following are hereby approved for distribution in accordance
with this permit:
Permit Volume
Source County Number (Dry Tons/Year�
Cascades Industries, Inc. Richmond N/A 16,000
All residuals shall be adequately stored to prevent leachate runoff until treated. The
finished product may be placed on a concrete pad, placed under shelter or covered until
such time as it is distributed to the buyer. If an alternate storage site is -to be used, approval
must be obtained from the Division.
4. No other residuals other than those specified under Condition II 2 above may be
distributed. The Permittee shall request and obtain a permit amendment from the Division
for each additional residual source prior to acceptance of that residual.
5. For these 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 m /k 2 mg/kg
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Nickel
420
420
Zinc
7,500_
2,800
6. Upon classification of the facility by the Water Pollution Control System Operators
Certification Commission (WPCSOCC), the Permittee shall employ a certified residuals
operator to be in responsible charge (ORC) of the residuals program. The operator must
hold a certificate of the type classification assigned to the residuals program by the
WPCSOCC. The Permittee must also employ a certified back-up operator of the
appropriate type to comply with the conditions of 15A NCAC 8A .0202.
7. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residuals treatment area onto the adjacent property or into
any surface waters.
2

8. 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 an 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 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 indicates that this material must comply with the buffers listed
Condition 16.
d. Residuals shall not be applied to any site that is flooded, frozen or snow-covered.
e Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored residuals into any surface waters.
9. These residuals shall be applied in a manner such that a cover crop can be grown on the
application site. The rate at which these residuals are to be applied will be determined
through the test plots outlined in the application package. The proposed application rates
for the test plots will be 25, 100, 175, 250, and 325 tons per acres. Once a conservative
application rate has been determined, this rate will be utilized in all applications.
MONITORING AND REPORTING REQUIREMENTS
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, volume and analysis of each residuals
b. name of residuals' recipient, volume received, and intended use
If the distribution and marketing of the subject residuals are applied in a manner consistent
with other land application permits (i.e. on the same acreage year after year), then the
following records shall be maintained:
a. location of residual application (site, field, or zone #)
b . volume of residuals applied in gallons/acre, dry tons/acre or kilograms/hectare
c. type of crop or crops to be grown on field
d. soils analysis as outlined below:
A representative annual soils analysis (Standard Soil Fertility Analysis) shall be
conducted on each site receiving residuals in the respective calendar year and the results
maintained on file by the Permittee for a minimum of five years. The Standard Soil
Fertility Analysis shall include, but is not necessarily limited to, the following
parameters:
Acidity Manganese Potassium
Calcium Percent Humic Matter Sodium
Copper pH Zinc
Magnesium Phosphorus
Base Saturation (by calculation)
Cation Exchange Capacity
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m
3. A residual analysis shall be conducted quarterly 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 residuals analysis shall 'include the following parameters:
Cadmium Nickel
Copper Zinc
Lead
Aluminum
pH
Ammonia -Nitrogen
Phosphorus
Calcium
Plant Available Nitrogen (by calculation)
Magnesium
Potassium
Nitrate -Nitrite Nitrogen
Sodium
% Total Solids
TKN
4. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by the
Permittee annually. The TCLP analysis shall include the following parameters (please note
the regulatory level in mg/L in parentheses):
Arsenic (5.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlorobenzene (100.0)
Chromium (5.0)
m-Cresol (200.0)
Cresol (200.0)
1,4-Dichlorobenzene (7.5)
1, 1 -Dichloroethylene (0.7)
Endrin (0.02)
Hexachlorobenzene (0.13)
Hexachloroethane (3.0)
Lindane (0.4)
Methoxychlor (10.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Silver (5.0)
Toxaphene (0.5)
2,4,5-Trichlorophenol (400,0)
2,4,5-TP (Silvex) (1.0)
Barium (100,0)
Cadmium (1.0)
Chlordane (0.03)
Chloroform (6.0)
o-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,2-Dichloroethane (0.5)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Lead (5.0)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Pentachlorophenol (100.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Trichloroethylene (0.5)
2,4,6-Trichlorophenol (2.0)
Vinyl chloride (0.2)
5. Three copies of all required monitoring and reporting requirements as specified in
conditions III 1, 1112, III 3, and III 4 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
Post Office Box 29535
Raleigh, North Carolina 27626-0535
6. Noncompliance Notification:
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone
number [phone], 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.
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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.
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. GROUNDWATER REQUIREMENTS
I . The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary is
for the disposal system constructed after December 31, 1983 is established at either (1) 250
feet from the waste disposal area, or (2) 50 feet within the property boundary, whichever is
closest to the waste disposal area. An exceedance of Groundwater Quality Standards at or
beyond the Compliance Boundary is subject to immediate remediation action in addition to
the penalty provisions applicable under General Statute 143-215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the
waste disposal area. Any exceedance of standards at the Review Boundary shall require
remediation action on the part of the permittee.
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V . INSPECTIONS
1. 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.
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VI. 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.
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.
7. The Permittee, at Ieast 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.
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 twenty-sixth day of November, 1997
NORTH C LINA ENVIRO NTAL MANAGEMENT COMMISSION
./-A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0009477
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