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APPENDIX A – OPERATIONS MANAGEMENT PLAN

Envirofert Compost Facility Operations Plan

Prepared by Peter Moon, P.E. and Harold Ruppert 02Compost,

December 2018

Contents 1.0 Introducing Envirofert Compost .................................................................................................................................. 6

1.1 Overview ..................................................................................................................................................................... 6 1.2 Mission ........................................................................................................................................................................ 6 1.3 Purpose ....................................................................................................................................................................... 6

2.0 Composting Methodology ........................................................................................................................................... 6 2.1 Extended Aerated Static Pile Method of Composting ................................................................................................. 6 2.2 The Anatomy of an Aerated Static Pile ........................................................................................................................ 6

2.2.1 On-Grade Aeration ............................................................................................................................................ 6 2.3 Plenum Material .......................................................................................................................................................... 7 2.4 Compost Mix ............................................................................................................................................................... 8 2.5 Biofilter Cover ............................................................................................................................................................. 8

3.0 Envirofert process design and operations ................................................................................................................... 9 3.1 Site Grades and Site Drainage ................................................................................................................................... 10 3.2 Green Waste Receiving and Grinding Area ............................................................................................................... 11 3.3 Aerated Compost Pad ............................................................................................................................................... 11 3.4 Curing Area ................................................................................................................................................................ 11 3.5 Screening and Finished Product Storage ................................................................................................................... 11 3.6 Compost Sales ........................................................................................................................................................... 11

4.0 Facility Operator Training .......................................................................................................................................... 12 4.1 Equipment Description .............................................................................................................................................. 12

5.0 Record keeping .......................................................................................................................................................... 12 5.1 Daily Operating Records ............................................................................................................................................ 12 5.2 Preventative Maintenance Schedule......................................................................................................................... 12 5.3 Forms for Recordkeeping .......................................................................................................................................... 13

6.0 Feedstock Acceptance Criteria .................................................................................................................................. 13 6.1 Acceptable Compost Feedstocks ............................................................................................................................... 13 6.2 Non-Acceptable Compost Feedstocks ....................................................................................................................... 13 6.3 Procedure for Ensuring Acceptable Wastes are Received ......................................................................................... 14 6.4 Procedure for Handling Unacceptable Wastes.......................................................................................................... 14

7.0 Composting Procedures ............................................................................................................................................ 14 7.1 Initial Compost Mix - Mass Balance Procedures........................................................................................................ 14 7.2 Material Flow Plan..................................................................................................................................................... 14 7.3 Mixing Bulking Agents ............................................................................................................................................... 15 7.4 Receiving Feedstocks................................................................................................................................................. 15 7.5 Pre-Processing and Batch Mixing .............................................................................................................................. 16 7.6 Building Aerated Static Piles ...................................................................................................................................... 16 7.7 Active Composting .................................................................................................................................................... 16 7.8 Curing ........................................................................................................................................................................ 17 7.9 Screening ................................................................................................................................................................... 17 7.10 Storage ................................................................................................................................................................. 17

8.0 Process Monitoring Plan............................................................................................................................................ 18

8.1 Compost Monitoring and Control Parameters .......................................................................................................... 18 8.2 Initial Mix Ratios and Characteristics ........................................................................................................................ 18 8.3 Porosity ..................................................................................................................................................................... 18 8.4 Bulk Density ............................................................................................................................................................... 18 8.5 Moisture Content ...................................................................................................................................................... 18 8.6 Available Carbon Content.......................................................................................................................................... 18 8.7 Nutrient Content ....................................................................................................................................................... 19 8.8 pH .............................................................................................................................................................................. 19 8.9 Visual/Qualitative ...................................................................................................................................................... 19 8.10 Decomposition ..................................................................................................................................................... 19 8.11 Temperature......................................................................................................................................................... 20 8.12 Qualitative Parameters ......................................................................................................................................... 20

9.0 Final Product Quality Plan ......................................................................................................................................... 20 9.1 Product Quality Parameters ...................................................................................................................................... 20 9.2 Particle Size Distribution ........................................................................................................................................... 20 9.3 Nutrient Content ....................................................................................................................................................... 21 9.4 Weed Seed Viability .................................................................................................................................................. 21 9.5 Salinity ....................................................................................................................................................................... 21 9.6 Foreign Matter Content ............................................................................................................................................ 21 9.7 pH .............................................................................................................................................................................. 21 9.8 Visual/Qualitative ...................................................................................................................................................... 21

10.0 Pathogen Reduction Plan .......................................................................................................................................... 22 10.1 NZS4454-2005 Criteria ......................................................................................................................................... 22

11.0 On-Site Testing Plan .................................................................................................................................................. 23 11.1 On-Site Measurements ......................................................................................................................................... 23

11.1.1 Pile Temperature ............................................................................................................................................. 23 11.1.2 Oxygen Content ............................................................................................................................................... 24 11.1.3 Moisture Content ............................................................................................................................................ 24 11.1.4 Bulk Density ..................................................................................................................................................... 24 11.1.5 pH .................................................................................................................................................................... 24

11.2 Monitoring Equipment Calibration and Maintenance .......................................................................................... 25 12.0 Final product testing and quality assurance .............................................................................................................. 26

12.1 Introduction .......................................................................................................................................................... 26 12.2 Testing Parameters ............................................................................................................................................... 26 12.3 Testing Frequency ............................................................................................................................................... 26 12.4 Types of Samples .................................................................................................................................................. 27 12.5 Representative Sampling / Collection Points ........................................................................................................ 27 12.6 Sampling Equipment List ...................................................................................................................................... 28 12.7 Sample Collection ................................................................................................................................................. 28 12.8 Proper Packaging and Delivery to Analytical Laboratory ...................................................................................... 28 12.9 Sampling Log Book ............................................................................................................................................... 28 12.10 Sample Chain-of-Custody ..................................................................................................................................... 29

12.11 Preparation of Samples for Analysis ..................................................................................................................... 29 12.12 Analytical Detection Limits ................................................................................................................................... 29 12.13 Analytical Methods and Procedures ..................................................................................................................... 30

12.13.1 Quality Control Procedures in the Field ...................................................................................................... 30 12.13.2 Quality Control Procedures in the Laboratory ............................................................................................ 31 12.13.3 Data Assessment and Reporting ................................................................................................................. 31

12.14 References ............................................................................................................................................................ 31 13.0 Odour Management and Dust Control Plan .............................................................................................................. 32

13.1 Introduction .......................................................................................................................................................... 32 13.2 Composting Method to Reduce Odours ............................................................................................................... 32 13.3 Sitewide mitigation............................................................................................................................................... 32 13.4 Potential odour discharges ................................................................................................................................... 33

13.4.1 The transport of raw materials to and through the site .................................................................................. 33 13.4.2 Raw product dumping and storage ................................................................................................................. 33 13.4.3 Raw product shredding and mixing ................................................................................................................. 34 13.4.4 Formation and operation of aeration windrows ............................................................................................. 35 13.4.5 Transfer of compost from aeration windrows to maturation windrows and maturation phase composting . 36 13.4.6 Transfer of compost from maturation windrow to screening pad, screening, storage, and load out of mature compost 37 13.4.7 Compost leachate collection and transfer to leachate storage pond .............................................................. 37 13.4.8 Leachate storage ............................................................................................................................................. 38 13.4.9 Leachate irrigation to land, discharge to wetland, or sale as liquid fertiliser .................................................. 39

13.5 Potential dust discharges ..................................................................................................................................... 39 13.6 Air Quality Complaint Response ........................................................................................................................... 40

13.6.1 Follow up actions ............................................................................................................................................. 40 14.0 Leachate Management Plan ...................................................................................................................................... 41

14.1 Introduction .......................................................................................................................................................... 41 14.2 Contributing Area ................................................................................................................................................. 41 14.3 Leachate Water Balance Design Basis ................................................................................................................. 41 14.4 Water Balance ...................................................................................................................................................... 41

15.0 Stormwater Management Plan ................................................................................................................................. 43 15.1 Surface and Ground Water Protection ................................................................................................................. 43

16.0 Equipment and Structure Inspection Plan ................................................................................................................. 43 16.1 Site Inspection Log................................................................................................................................................ 43 16.2 Inspection Schedule ............................................................................................................................................. 43 16.3 Leachate Pond Liner Inspection ............................................................................................................................ 43

17.0 Neighbour Relations Plan .......................................................................................................................................... 43 18.0 Safety, Fire and Emergency Plan ............................................................................................................................... 44

18.1 Emergency Response ............................................................................................................................................ 44 18.2 Bodily Injury .......................................................................................................................................................... 44 18.3 Fire ........................................................................................................................................................................ 44 18.4 Hospitals ............................................................................................................................................................... 44

18.5 Personal Hygiene and Safety ................................................................................................................................ 45 18.6 Operator Training ................................................................................................................................................. 45 18.7 Safety Equipment ................................................................................................................................................. 45 18.8 Emergency Evacuation ......................................................................................................................................... 46

19.0 Staff Responsibilities ................................................................................................................................................. 46 20.0 Appendix A: Preventative Maintenance Inspection .................................................................................................. 47 21.0 Appendix B: Load Receivals and Inspection .............................................................................................................. 48 22.0 Appendix C: Complaint Record .................................................................................................................................. 49 23.0 Appendix D: Bulk Density and Free Air Space Determination ................................................................................... 50 24.0 Appendix E: Temperature Monitoring....................................................................................................................... 53 25.0 Appendix F: Moisture Content Monitoring Procedure .............................................................................................. 54 26.0 Appendix G: Sample Tracking Form .......................................................................................................................... 56 27.0 Appendix H: Boundary Odour and Dust Monitoring Procedure ................................................................................ 57 28.0 Appendix I: Water Balance ........................................................................................................................................ 62

1.0 Introducing Envirofert Compost

1.1 Overview Envirofert Compost receives and processes green waste, food waste, wood waste, and agricultural by-products. The feed stocks consist primarily of green waste received from local contract haulers of municipal solid waste and from commercial landscapers. Food waste arrives at the site in several forms: Commercial Food Scraps (including restaurants, supermarkets, event facilities, non-marketable spoils from local greenhouses, etc.) and Auckland City curb-side collections.

1.2 Mission Envirofert Compost's mission is to preserve and enhance the environment by providing cost effective composting of green waste from residential, municipal, and commercial customers. Envirofert Compost serves to provide a recycling service that is beneficial to people of the region by providing an alternative to landfilling. Quality compost / mulch products are produced and sold for use in orchards, landscapes and home gardens.

1.3 Purpose The purpose of this Operations Plan is to provide:

1) specific information about the Aerated Static Pile Method of composting; and

2) prescriptive step by step procedures for site staff to follow.

This Plan also includes a troubleshooting guide for resolution of environmental impacts and operational inefficiencies.

2.0 Composting Methodology

2.1 Extended Aerated Static Pile Method of Composting Envirofert Compost currently utilizes the Extended Aerated Static Pile (EASP) method of composting, also referred to colloquially as the “Wedge Method”. With EASP composting, fresh air (i.e., oxygen) is delivered into the pile under positive pressure to:

1) maintain aerobic conditions throughout the pile and

2) eliminate the need for pile turning.

By maintaining aerobic conditions throughout the pile, the rate of composting is dramatically increased, pathogen reduction criteria are achieved, and the release of volatile organic compounds (VOC’s) is greatly reduced.

2.2 The Anatomy of an Aerated Static Pile An Aerated Static Pile (ASP) consists of the following elements, each of which are discussed below in greater detail.

• Aeration pipes placed directly on the ground (“on-grade aeration”); • Course woody material placed over the perforated pipe (“plenum material”); • The compost mix of feedstock materials (“mix”); and • A biofilter cover layer consisting of unscreened finished compost (“biofilter cover”).

2.2.1 On-Grade Aeration

In general, an on-grade aeration system includes:

1) a portable blower operated by an On/Off cycle timer;

2) a pipe manifold for distribution of the airflow laterally; and

3) a set of parallel aeration pipes (“laterals”) consisting of solid and perforated pipe that distribute airflow along the length of the pile.

An example on-grade aeration system is illustrated in Figure 1 and Figure 2.

Figure 1 Pipes on grade

Figure 2 Plan view of ASP

2.3 Plenum Material The plenum material consists of clean wood chips or recycled course screened compost (“screen overs”). The purpose of the plenum layer is to provide open pathways for airflow for uniform air distribution across the base of the pile (see Figure 3). The plenum layer also provides a pathway for excess water to drain from beneath the pile, facilitating the maintenance of aerobic conditions which in turn helps to mitigate the generation of offensive odours.

Figure 3 Aeration Plenum

The plenum layer does not extend to the edges of the pile to avoid short circuiting of airflow to the atmosphere. Because it is encased on all sides by the compost mix, airflow is forced under pressure to pass upwards through the compost mix.

2.4 Compost Mix Preparation of the initial compost mix requires attention to meeting a set of quantitative and qualitative parameters, including:

• Porosity (as measured by bulk density and free-air space); • Moisture Content; • Nutrient Content (i.e., Carbon to Nitrogen Ratio or C:N); and • pH

Each of these parameters are discussed in detail in following sections of this Operations Plan. Field and laboratory test procedures for measuring these parameters are also presented below.

The key objective in preparing the compost mix is to produce a uniform, homogeneous blend of materials (i.e., no layering) to optimize uniform airflow through the compost pile (see Figure 4).

Figure 4 Compost Mix

2.5 Biofilter Cover The biofilter cover layer is an essential component of an EASP System and serves several purposes:

• Insulating Layer – The biofilter consists of unscreened compost that has already met time-temperature criteria for pathogen destruction. It serves to insulate the underlying compost mix to ensure that it meets or exceeds 55oC for a minimum of 3-days.

• Biofiltration Layer – Unscreened compost is very effective at absorbing / adsorbing volatile organic compounds (VOC’s) and nitrogen based off-gases (principally ammonia). These gases are treated in-situ by the microorganisms that reside in the finished compost. It is important to note that the biofilter

layer must be kept wet for it to work properly. The moisture content of this outer layer should ideally between 50% and 70%.

• Nutrient Retention – A secondary benefit of the biofiltration capability of this layer is the retention of nutrients, principally nitrogen in the finished compost, thereby enhancing the marketability of the compost and its overall value as a soil amendment.

• Vector Barrier – The biofilter layer also serves as a deterrent to vectors. Because of the heat of the underlying compost mix, birds, rodents, and larger wildlife are dissuaded from digging into the pile in search of a food source. Also, flies and other insects are not attracted to this layer as a potential food source and breeding habitat.

• Moisture Retention – During extended periods of dry weather it is often necessary to top-irrigate the EASP biofilter layer so that it performs as intended. By keeping the biofilter layer wet, there is a decreased tendency to lose water from the core of the compost pile, thereby helping to sustain the biologic degradation of the compost mix.

Figure 5 Biofilter cover layer

3.0 Envirofert process design and operations The Envirofert Compost Facility layout and operation is illustrated (in Figure 6) and summarized below:

Figure 6 Site layout

3.1 Site Grades and Site Drainage Site grades are constructed to enhance drainage of compost leachate toward leachate drains and sumps. Site grades are to be 1.5% or greater. The compost pad is constructed from of structural fill consisting of a clay base fill, contoured to correct fall and track compacted with 300mm of GAP 65 metal lime/cement stabilized to 250mm.

Figure 7 New site layout and water drainage

3.2 Green Waste Receiving and Grinding Area The green waste receiving and grinding area is located in the centre of the site to accommodate these operations for both the Phase I area to the southwest and the Phase II area to the northeast.

3.3 Aerated Compost Pad The aerated compost pad includes a series of blowers and on-grade aeration pipe networks, as illustrated in two cross sections in Figure 8. The aeration pipes consist of 100 mm diameter, thick-wall high density polyethylene (HDPE – SDR 11). This pipe is corrosion resistant and very durable and as such it is commonly used for landfill leachate and gas management. In this application, it can be removed from beneath the compost pile without concern of damage, and it can be reused repeatedly without it deforming and becoming brittle (as is common with PVC Pipe).

Figure 8 EASP cross section profiles

3.4 Curing Area Following 30 to 45 days of aerated composting, the EASP will be deconstructed and the compost will be transferred into a non-aerated static pile located in the adjoining operations area. During the deconstruction and transfer process the compost will be remixed thereby providing an opportunity to rewet the compost to a minimum 50% moisture content if needed. Compost will reside in the curing area for a period of 60- to 90-days.

3.5 Screening and Finished Product Storage Cured compost will be screened on an on-going basis in the area that immediately adjoins the curing area. The screened product (i.e., fine fraction) will be transferred into the covered structure (shed site in Figure 7) to keep the product dry. The screened compost will ultimately be loaded out in trucks and delivered to the end users.

The screen “overs” (i.e., course fraction) will be transferred to a uncovered temporary storage area and reused in the composting process, both as an inoculant for the newly shredded green waste and as the aeration plenum material, covering the on-grade aeration pipes.

3.6 Compost Sales Envirofert supplies Compost in Bulk form only. The markets have traditionally been Kiwi Fruit orchards from the Far North to the Bay of Plenty which still makes up a large proportion of sales. The local market is growing with a number of crop and vegetable growers, particularly in the Franklin and North Waikato areas now using compost to re-introduce organic matter into otherwise spent soils.

Bagged compost has not been a focus for Envirofert in the past and the possibility to enter this market is being discussed.

4.0 Facility Operator Training Staff on-site will be trained in all phases of the operations from Green waste and Food Scraps acceptance, through the Compost process and final screening and load out for delivery in accordance with the guidelines set out in this Operations Management Plan and the staff training register.

Training will include:

1) Health and Safety;

2) machinery operations, maintenance and safety procedures;

3) balance of green waste, food scraps and timber/sawdust to gain the correct carbon to nitrogen ratio;

4) construction of the aeration and maturation piles;

5) monitoring of temperature, oxygen and density;

6) routine site inspections and record keeping;

7) maintenance of the leachate drains, pumps and ponds; and irrigation; and

8) storage requirements and all other on-site actions that may be required for the operation.

4.1 Equipment Description The following equipment is used on-site, site staff will be trained to be proficient operators of this equipment and understand the required maintenance procedures, such that this equipment is maintained in good working order and does not result in reportable Health and Safety incidents.

• Front-end Loaders: 2015 Caterpillar 924K 2015 Caterpillar 962H 2012 Hyundai 760

• Excavator: 2015 Caterpillar 320DL • Shredder: 2005 Komptech Crambo • Screen(s):

2014 Komptech L3 2008 Komptech M3 1998 McCloskey Trommel

5.0 Record keeping

5.1 Daily Operating Records Envirofert Compost keeps daily records of temperatures, pile numbers, inspections, and all check sheets required by the resource consents. These are kept in a clearly labelled file, in the operations office and available for inspection by the Waikato Regional Council (WRC) and the Waikato District Council (WDC). Copies of the resource consents, Engineering Report, the Operations Plan and any additional regulatory documents associated with this site will be kept on-site in this same file location.

5.2 Preventative Maintenance Schedule Proper facility operation must ensure that all equipment and facilities are maintained and in good operating condition. This equipment includes the items listed below:

• Electric blowers and cycle timers • Front-end loader • Grinder • Screen and stacking conveyors • Stormwater conveyance structures and retention pond • Source of water

Because the maintenance for each of these operating systems is different, a check sheet has been developed, to be completed monthly by on-site personnel. This sheet assures that each piece of critical equipment will be checked for

maintenance performed and will be inspected for signs of long-term wear and potential failure. This sheet is in the Appendix A titled Preventative Maintenance Inspection.

5.3 Forms for Recordkeeping Green waste materials will typically be brought to the recycling facility by covered trucks. Upon entering the site, the volume of material received will be estimated.

All loads that are delivered to the facility cross a weighbridge located at the entrance. The weights are recorded on the basis of weight instead of volume. The average bulk density (weight per unit volume) and moisture content of the in-bound waste will be measured seasonally. This information will be used to confirm that initial mix parameters are met during the shredding and pile construction stages.

A record of incoming load quantities and material type are kept at the Envirofert Compost site and be available for inspection. A record of loads rejected will also be kept on-site. This record will include quantity, time of rejection, date of rejection, source and type of material, and license plate number.

The site completed inspection records will be kept on-site for inspector review. The record will include the following information:

• Date and time of inspection. • Names and signatures of person(s) conducting the inspection. • Notations of observations made during the inspection. • Dates and nature of any corrective actions taken.

The form for recording this information is included as Appendix B.

The log will be kept at the facility for at least five years from the date of inspection, and copies of these records will be available to WRC or WDC upon request.

Complaints received will be recorded on a form (Appendix C) and a response, according to the plan, will be made. All records of complaints will be kept on-site and available for the inspector.

An annual report will be submitted to WRC as stipulated in the resource consents, including the name and address of the facility, the calendar year covered, and annual quantity and type of material accepted, in estimated tonnes or cubic metres. WRC/WDC will specify the form of the annual report.

6.0 Feedstock Acceptance Criteria A specific list of materials that will and will not be accepted at Envirofert Compost will be provided to all participating municipalities; waste hauling companies and their respective truck drivers; and others who visit the compost facility to drop off their waste materials. This list will also be posted on signs at the facility entrance.

6.1 Acceptable Compost Feedstocks Types of materials acceptable include the following:

• Green waste • Food scraps • Wood waste

6.2 Non-Acceptable Compost Feedstocks Types of materials deemed not acceptable, include the following:

• Liquids of any type • Painted and/or treated wood products • Chemically contaminated soils • Municipal Solid Waste • Sheetrock or paper/cardboard recycled from sheetrock • Building demolition debris • Insulation • Roofing materials including wood shingles • Biosolids • Non-compostable plastic bags

• Rocks • Plastic containers such as pots • Broken tools • Sod • Hydrocarbon contaminated materials • Animal manure

6.3 Procedure for Ensuring Acceptable Wastes are Received A load will be considered unacceptable if the physical contamination exceeds 5% by volume. Physical contamination will be considered anything that is not acceptable feedstock according to this Operations Plan. If the contamination is removable the hauler may remove the material and dispose properly to achieve the acceptable percentage. If this is not possible, the hauler is to leave the site with the entire load.

6.4 Procedure for Handling Unacceptable Wastes All incoming loads will be directed to a specified unloading area. As the truck bed gates are opened, and as the load is being dumped, on-site personnel will inspect the waste material. In the event that the site operator is temporarily occupied with other activities and direct inspection is not possible, the daily records will be compared to loads received and any hauler responsible for delivering unacceptable loads will be notified to return to the site to retrieve the unacceptable materials.

These haulers will bear the cost of reloading these materials, and they will receive a warning not to deliver unacceptable materials in the future. Repeat offenses will not be tolerated, and Envirofert reserves the right to ban these haulers from the site.

These practices will be continually reviewed and improved if a more rigorous inspection procedure is required.

7.0 Composting Procedures

7.1 Initial Compost Mix - Mass Balance Procedures Mass balance estimates are used for planning purposes, and are not intended to be prescriptive. Because conditions and material properties vary seasonally, the site operator must develop a talent for making adjustments to the mix composition and ratio of bulking agents in order to prepare an initial mix that can be effectively and efficiently composted without adverse impact to surface water, ground water or air quality.

During the spring and early summer months, the wet, nitrogen rich green waste will be blended with a higher proportion of ground woody residuals or screen overs. As the season progresses, the ratio of bulking materials will be adjusted to allow more green waste to account for the changes in moisture and nitrogen content. During the winter months, the bulking agent will be comprised almost entirely of ground wood waste and screen overs.

The parameters for an initial compost include:

• Target-bulk density of 400 to 600 kilograms / cubic meter • Initial moisture content of 60 to 65 percent • Carbon to nitrogen ratio between 25:1 and 35:1

The green waste fraction of the mass balance will change significantly during the course of a year. In addition, the composition and nutrient character of the waste material changes significantly as well. During the spring and early summer months, it is comprised primarily of wet, nitrogen rich lawn clippings and trimmings. As the summer and early fall seasons advance, the materials become progressively drier and more carbonaceous. By late autumn the materials consist predominantly of leaves. The small amount of green waste available during the winter months consists primarily of tree and shrub pruning waste.

7.2 Material Flow Plan A generic process material flow diagram is provided in Figure 9. Each operations step depicted in the flow diagram is discussed in the following sections.

Figure 9 Process flow diagram

7.3 Mixing Bulking Agents Bulking agents typically consist of woody materials that have sufficient size to provide structural support and maintain air spaces within the composting matrix. Bulking agents form a three-dimensional matrix of solid particles capable of self-support by particle-to-particle contacts. Grass clippings and similar "wet" feed stocks can be viewed as being supported within the voids between the bulking agent particles.

The bulking agents to be used for this process include: shredded wood waste and compost screen overs (i.e., coarse fraction). In the case of shredded green waste, the available nutrients are a source of energy for the compost material and thereby provide a secondary benefit. The screen overs serve to inoculate the initial mix of compost materials with microorganisms and to provide structure and porosity in the pile. These materials will be processed to a 50 mm minus size using the shredder that is dedicated to the site.

7.4 Receiving Feedstocks Feedstocks will be of three general types. One type will be woody or low nitrogen feed stocks. Generally, these will be land clearing debris, orchard pruning’s or solid wood materials that have little potential for odour generation. This material will be ground and used as a carbon source and for bulking. This material will be ground and moved as needed to prepare the appropriate mix for composting.

The second type of feedstock will be green waste (i.e. curb side green bin collections) that is high in nitrogen. In all cases the delivery will be to a tipping area identified at the site. Green waste will comprise the majority of materials received and processed by Envirofert.

A third type of feedstock will be food scraps, including commercial collections (restaurants, supermarkets, event centres) and Auckland City kerb-side collections. Delivery will take place on the receiving area but then moved by loader to the mix being prepared for compost feedstock. The runoff from the receiving slab will have leachate retention. If this method causes nuisance odours Envirofert will prioritize pre-processing to place them within and EASP within 24-hours. Food scraps have historically comprised a small percentage of materials received and processed at the site.

All feed stock material will be tipped on the dedicated receivals area (see Figure 7).

7.5 Pre-Processing and Batch Mixing Size reduction of the green waste materials will be accomplished with a front-end loader and a shredder that are both dedicated to the site. Incoming materials will be reduced to a 50 mm minus size and blended with bulking materials (shredded wood waste and horticulture residuals) as needed to provide an initial mix that has a carbon to nitrogen ratio (C:N) of between 25 : 1 and 35 : 1 and a moisture content of 60 to 65 percent.

The initial mixing will be accomplished promptly to produce a homogeneous blend of materials (as the first step to mitigate potentially offensive odours). Mixing will be accomplished partially using the front-end loader then completed during the shredding process. To obtain the proper mix the front-end loader scoop volume will be used as the unit of measure the operator will simply count bucket loads of the various mix components. Mixing will be performed by dumping on the pad the appropriate proportions and lifting and combining the feedstock on a clean flat surface.

Samples of the initial mix may be taken as necessary to be and tested by a certified laboratory. Suitable methods of sampling and testing are discussed in detail in the "On-site testing" section (Section 11) of this Operations Plan. Test results will:

1) confirm that desired mix parameters are attained and

2) provide baseline data to compare with typical lab results for finished compost.

Seasonal adjustments of the initial mix will be necessary. As discussed above the feedstocks will vary over the course of the year. Records of the mix ratios will be retained on-site such as to provide guidance to other site staff and future operators.

7.6 Building Aerated Static Piles Envirofert Compost utilizes the Extended Aerated Static Pile (EASP) method of composting for feed stocks. The EASP method uses perforated pipes placed on-grade prior to construction of the compost pile. The air pipe is connected to electric blowers, which forces air into the compost pile (positive aeration). Contiguous compost cells are constructed directly on the flank (side slope) of the previous cell thereby producing a flat-topped extended pile.

As each cell is being constructed, a 300 mm layer (minimum thickness) of finished compost is placed over the top of the raw feed stocks. This cover layer serves four main purposes:

1) acting as an insulating blanket to ensure that all of the materials reach desired temperatures for pathogen and weed seed destruction,

2) serving as a biofilter to digest odour-causing compounds before being emitted to the open air, and;

3) helping to maintain the desired moisture content within the pile; and

4) control vectors from breeding or burrowing in the pile.

Each EASP cell (up to 8 cells per windrow) will contain approximately 840 m3 of feedstock materials, and each completed pile/windrow will contain a total of 6,750 m3. During peak operating conditions, there will generally be one fully constructed EASP and one partially constructed EASP at any given point in time. The entire composting process will take place without moving the pile. This step will take 21 to 30 days and completion will be based on the temperature cycle and the need to create space for subsequent piles.

By maintaining an oxygen level of at least 8 to 10 percent within the pile, aerobic conditions will be met, thereby mitigating offensive odours.

The extended piles will be constructed on a lime stabilised slab that slopes to drain by gravity to a leachate collection drain. The 2 piles will each measure approximately 25 m wide by up to 90 m long (the two maturation piles will have the same approximate dimensions). The initial height of the pile will be on the order of 3 m. Over time, shrinkage will occur as a result of material consolidation and decomposition, reducing overall pile height to 2.5 m by the end of the active phase of composting.

7.7 Active Composting The active phase of composting (the period during which most of the process heat and potentially offensive odours are generated) generally lasts between 21 and 30 days and will take place in extended aerated static piles, as discussed previously.

During the active phase of composting the primary objective is to reach temperatures throughout the pile of at least 55°C for a minimum of 72 hours. This standard is referred to as the minimum pasteurisation time in NZS4454-2005 Composts, Soil Conditioner and Mulches. These criteria will be used to produce a safe finished product, available to the public for unrestricted use.

7.8 Curing The subsequent curing phase of composting (the period during which the product becomes stable and marketable) lasts an additional 30 to 60 days. The curing phase may be accomplished either in the original compost pile, with adjusted airflow, or in a separate stockpile. Given that the finished product is screened, the screening process can take place either before or following product curing. The product curing area is shown on the site plans (see Figure 7).

7.9 Screening Following curing the product will be screened to produce as many as three products.

1) Fine screened product,

2) Medium screened product and

3) Screen overs.

The size of the fine and medium products will depend upon the size of the mesh used. Screen overs may be used as they are, or reground for size reduction. Often the screen overs are used as plenum, or fed back into the pile for further composting.

7.10 Storage As part of the maturation process, the finished compost product will typically be stored for some period of time (typically not exceeding 360 days).

Storage of product following maturation will take place off the lime stabilised pad and off the area of leachate collection. Before product can be stored off the pad it must be confirmed that the metals concentration, pathogen destruction, pH, physical contaminants, sharps, and stability meet the levels specified in NZS4454-2005. Storage piles will be stored in weatherproof sheds (located at each end of the lime stabilised pad (as marked on Figure 7).

Storage piles must also be kept at a moisture content below 60% water. This can be accomplished by confirming with the squeeze test that the stored compost’s moisture is initially below 55%. The covered storage sheds will help maintain a dry stable final product.

Porosity in the storage piles will be achieved and maintained by keeping the height of the piles at or below 3 m. This will minimize consolidation and compaction. When the storage piles are constructed the operator will break up any existing dense areas from prior storage by handling with the loader (pouring and fluffing the material when building pile). The loader operator will avoid driving on the pile to prevent compaction.

In addition, performance standards specified in NZS4454-2005 must be achieved.

8.0 Process Monitoring Plan

8.1 Compost Monitoring and Control Parameters Composting is a controlled biological process designed to rapidly convert waste organic material into a humus-like, rich material that is useful for a variety of purposes associated with landscaping, growing plants and erosion control. Controlling the compost process allows composting to be completed efficiently and mitigates adverse impacts to the environment.

The compost monitoring and control parameters are discussed in the following sections.

8.2 Initial Mix Ratios and Characteristics Mix ratio development and characteristics are critical to successful composting. Mix ratio refers to the portions of each feedstock in the initial mix. The initial mix impacts a number of processing parameters including: processing time, aeration requirements, odour generation, leachate production and final product quality. The following parameters are significant in the initial mix:

• Porosity • Moisture Content • Available Carbon Content • Nutrient Content (i.e., C:N Ratio)

8.3 Porosity Porosity is of primary importance for initial mixing. A mix with insufficient porosity will limit aeration. Porosity is provided by large particle size materials such as chipped brush and wood chips. The moisture content of the mix also influences porosity. If the moisture content is excessive, pore spaces are filled with water instead of air. In general, the porosity is considered optimal if the moisture content is between 65 and 60 percent and the bulk density is between 400 and 600 kg/m3).

The optimum porosity/moisture is dependent on the moisture holding capacity of the initial mix. Experience working with the various feed stocks at a specific site will dictate what the optimum bulk density and moisture content of an initial mix should be.

8.4 Bulk Density Bulk density is a simple means of assessing porosity. The denser the material is, the lower the porosity. This field test procedure is described in the Appendix D. The bulk density of composting material should remain less than 700 kg/m3, with an initial target value between 400 to 600 kg/m3.

8.5 Moisture Content Maintaining the moisture content of a compost pile within the optimum range is critical. Excessive moisture content reduces the pore spaces and the availability of oxygen. This causes anaerobic conditions and slows the decomposition process. Excessive moisture also acts as a heat sink, reducing pile temperatures. Insufficient moisture, below 45%, is a poor environment for the bacteria and the composting process will stop. The optimum moisture content for composting is around 60 percent with the range being 50 – 65%. Field test procedures for assessing moisture content are included in Appendix E.

8.6 Available Carbon Content Heat is generated during the composting process as a by-product of the rapid decomposition of organic compounds that are readily available as a substrate for microbial growth. Carbon rich substrates such as sugars, starches, fats and proteins are considered readily available, whereas hemicelluloses, cellulose and lignin decompose much more slowly and are therefore not considered readily available. The composting process requires a certain fraction of readily available compounds to be present. For example, a pile of sawdust will not generate much heat compared to a similar sized pile of sawdust and grass or manure. If the amount of readily available sugars, starches, and fats are too high, rapid oxygen depletion occurs (i.e. anaerobic conditions) and odour generation can result. Available carbon should be 30 times the available nitrogen for an ideal mix. This is customarily referred to as a Carbon to Nitrogen ratio (C:N) of 30:1.

In general, the older the plant tissue, the less energy or readily available substrate is present. Small particle sized materials are more readily available for microbial consumption. Food Scraps have a high content of readily available substrates, whereas wood chip substrates are less available. A continuum of relative carbon availability is presented below:

Raw wastewater solids = grass clippings > Green Leafy Vegetation > Brown Leafy Vegetation > Chipped Brush and Twigs= New Sawdust> Old Sawdust> Wood Chips (Hog Fuel).

8.7 Nutrient Content Inorganic nutrients such as nitrogen, potassium and phosphorous are required for microbial growth. In some mixes, nitrogen can be limiting. Green waste collection during the winter months, for example, can have low nitrogen content. All other nutrients are typically present in sufficient quantity. As a general rule of thumb, the ratio of carbon to nitrogen (C:N ratio) should be between 25:1 and 35:1. A lower C:N ratio can result in the production of odourous nitrogen containing compounds such as amines and ammonia, during composting. At higher C:N ratios, nitrogen may not be sufficient for active, thermophilic composting. However, initial mixes with C:N ratios as high as 60:1 have been noted to compost quite well.

8.8 pH The initial pH of a compost mix should range between 6.0 and 7.5.

Either excessively acidic or basic conditions can inhibit biological activity. Initial pH outside of the desired range of 6 to 7.5 should be adjusted unless demonstrated to perform adequately in pilot testing operations. A mix that is slightly acidic will reduce off-gassing of ammonia thereby reducing the potential for odour impacts.

8.9 Visual/Qualitative Trained and experienced compost facility operators can utilize simple qualitative tests as aids to operations. The visual appearance of the material at all phases of the mixing and composting process provides valuable insights into the status of the process. Colour, moisture, particle size and void spaces, absence of mix "balls" and odour are useful visual/ qualitative indicators. Of primary use during the initial mix operation is:

1) the squeeze test for free moisture (Appendix E),

2) the bucket test to determine mix bulk density and free-air space (Appendix D) and adequacy of void spaces in the mix and

3) the observed thoroughness of mixing.

8.10 Decomposition Maintaining optimum decomposition rates will reduce processing time and improve product quality. Optimum decomposition rates are obtained by providing an initial mix with sufficient carbon and nutrients and maintaining adequate temperature, moisture and oxygen levels. In general, decomposition occurs over two phases.

The first phase, described as the thermophilic phase (or active phase) is evident by temperatures greater than 40 °C (105 °F). This phase is when the majority of the energy source is used (simple sugars, carbohydrates, and fats). As the energy is used, heat is produced as a by-product.

The elevated temperatures increase the kinetics of the system. The higher temperatures along with adequate moisture and oxygen levels also encourage the growth of aerobic microorganisms. This is significant, as aerobic decomposition occurs at a faster rate than anaerobic decomposition and has far lower odour potential.

If all other environmental conditions are optimal, temperatures dropping into the mesophilic range (less than 40°C ( 1050F)) indicate microbial respiration or decomposition rates have been reduced and the composting process has entered the second phase of decomposition, called the curing phase. The first (active) phase of composting may last for a few weeks to a few months, depending on the substrates composted and the conditions provided. The second (curing) phase can take upwards of a few months before a mature final product is produced. Decomposition is assessed by evaluating several parameters throughout the process and measuring the stability of the final products. The following parameters are used to assess decomposition during processing:

Volume Reduction - As the material degrades, the volume of the pile decreases. With the aerated static pile process, this volume reduction is easily determined by monitoring pile height. For a consistent long-term program, the volume reduction could be correlated with other degradation parameters for use as an indicator of pile status.

Volatile Solids Reduction - A reduction from initial to final volatile solids of 50 to 60 percent is indicative of a stable compost product.

Respiration Rate - Respiration rate can be used as an indicator of biological activity throughout the composting process. This testing method is discussed in a later section.

8.11 Temperature The use of temperature as a method of monitoring the composting process is the most common and most convenient. Temperature measurements can indicate several composting performance goals and may be used to do the following:

Determine the suitability of the initial mix- if the initial mix has the appropriate physical and chemical characteristics, then thermophilic temperature should be achieved within three to five days and maintained for three to six weeks thereafter. Monitoring temperatures enable the operator to:

• Document the achievement of pathogen reduction requirements. • Document the achievement of vector attraction reduction. • Document temperatures required for weed seed destruction. • Indicate oxygen-limiting conditions- a drop in temperatures during the active process, indicates oxygen

is limiting or excessive aeration is being provided. • Determine compost stability- a 15 m3 pile of cured product should not reheat more than 20 °C above

ambient temperatures.

Temperature monitoring is done manually and records maintained on-site (Appendix E)

8.12 Qualitative Parameters Assessing the compost visually and by smell and feel can provide valuable insight to the process. It is generally recommended that the sample being assessed be taken from the pile interior (deeper than 900 mm) with a front-end loader. The senses can be used to assess the following parameters:

• Moisture content - composting material should feel moist but not excessively wet. When squeezed in a fist, free water should not drip from the material.

• Odour - a sour or pungent odour is an indication that the pile is anaerobic and that the blower-operating period (i.e., frequency and duration) should be increased.

• Porosity- the compost should have a granular, chunky appearance. A fine texture is an indication the material may not be sufficiently bulked.

9.0 Final Product Quality Plan

9.1 Product Quality Parameters The following parameters should be evaluated to determine final product quality:

• Particle Size Distribution • Nutrient Content • Weed Seed Viability • Salinity • Foreign Matter Content • pH • Visual/ Qualitative • Pathogen Destruction

9.2 Particle Size Distribution The particle size distribution of the compost product is important for most uses of the material. The particle size of the product is determined primarily by the screen size used in post-processing the material. However, the visual effect and distribution below the screens' threshold size is greatly influenced by the bulking material used. For example, all of the sawdust used for bulking normally ends up in the product, whereas hog fuel will largely be screened out of the product. Green waste, when used as a bulking material contributes a significant fraction to the product and has a strong impact on the product appearance and character. Branchy green waste may result in twigs "spearing" through the screen opening, resulting in a coarser finished product.

9.3 Nutrient Content Compost is considered a soil conditioner and is used primarily to improve the organic matter content of soil. However, depending on the feed stocks and process used, compost can have an appreciable nutrient content. Compost with a "high" nutrient content is considered better in quality and potentially has a higher market value. The nitrogen content of compost is especially significant as it is the plant nutrient required in greatest quantity.

More important, the addition of immature compost to soil may result in the microbial "tying- up" or immobilization of inorganic nitrogen. The carbon to nitrogen ratio (C:N) is one means of assessing the fate of inorganic nitrogen when compost is used. In general, a C:N ratio in compost feedstock above 30 may result in the immobilization of inorganic nitrogen. Conversely, a C:N ratio below 30 typically results in the mineralization or "release" of inorganic nitrogen, which is desirable.

Additional nutrients required for plant growth include: K, P, Ca, Mg, plus a variety of nutrients needed in trace amounts. Trace nutrients include: AI, B, Cu, Co, Fe, Mn, Mo and Zn. A balanced supply of these nutrients is required for good plant growth. If the supply of these essential nutrients is inadequate or excessive, the growth of plants is abnormal or stunted. Compost has been shown to be an excellent source of trace nutrients, within the desired range.

9.4 Weed Seed Viability For most uses of compost, it is very important that viable weed seeds not be present. Weed seed viability is determined by placing a sample of compost in an enclosed container and maintaining the moisture content between 45 and 55 percent, and temperature between 18 and 24 °C. The containers should be examined several times a week for the presence of germinating seeds. No viable weed seeds should be found.

9.5 Salinity Organic material such as compost varies greatly in salinity (soluble salt content). The two deleterious effects most often encountered are excess total salts and high sodium levels. Excess total salts can inhibit the germination and growth of plants. High sodium levels and, to a lesser degree, potassium levels cause dispersion of soil particles, poor soil structure, and reduced infiltration rates.

A simple method of evaluating salinity is to measure the electrical conductivity (EC) of the material. Estimating soluble salt content by measuring EC generally is accurate enough to evaluate the effects of organic material application on land. Salinity tolerance can range from 2 mmhos per em for plants that are salt sensitive, to 18 mmhos per em for salt tolerant plants. A desirable product range is from 2 to 6 mmhos. Studies have shown that salts do tend to leach out of the soil/ compost mix, thereby reducing the potential adverse impacts. However, the salts can accumulate within the root zone with multiple and excessive applications over time.

9.6 Foreign Matter Content The presence of significant visible foreign matter such as plastic, glass and metal that relate the product to its source of origin can greatly reduce the marketability of the product. The final product must be tested to assure that the amount of foreign matter present is equal to or less than 1.0 percent total by weight and not to exceed 0.25 percent film plastic by weight. However, visual examination of the product will generally suffice.

9.7 pH Most plants have a range of tolerable pH. The product pH should be provided to users to assure proper usage. Product pH outside of normal ranges may indicate the need for initial mix or process adjustments. In most cases, the pH of a finished compost material (regardless of its initial pH as an initial mix) is 6 to 7.5.

9.8 Visual/Qualitative Assessing the compost visually and by smell and feel can provide valuable insight to the product quality. The "market" generally perceives the best quality finished compost materials to be dark brown to black in colour, to have a forest duff odour, and to be uniformly fine in texture.

10.0 Pathogen Reduction Plan The United States EPA established the minimum criteria used for meeting human health objectives. These criteria are stated in the body of regulation entitled 40 CFR Part 503.32, (also referred to as the "503 Regulations"). The technical term for the minimum criteria to produce a Class A compost is "Process to Further Reduce Pathogens" or PFRP.

The PFRP criteria for the aerated static pile and in methods of composting biosolids are stated as follows:

• Pile temperatures shall be maintained at 55°C (131°F) or higher for a minimum of 3 days (i.e., piles must be covered to ensure minimum temperatures throughout the pile); and

• Fecal Coliform must be less than 1,000 most probable numbers (MPN) per gram total solids (dry-weight-basis); or

• Salmonella sp. Bacteria must be less than 3 MPN per 4 grams of total solids (dry-weight-basis).

Note: While the Envirofert Compost Facility does not process biosolids these criteria are still used as a measure to ensure product quality and end user safety.

Because the Envirofert Compost facility does not receive or process biosolids, the term “PFRP” has been replaced throughout this Operations Plan with the expression “Time-Temperature Criteria”.

10.1 NZS4454-2005 Criteria Envirofert is also seeking to produce products that meet the NZS4454-2005 criteria listed in Table 3.1 of this standard. Due to copywrite laws these parameters cannot be reproduced in this Operations Plan, however a hard copy of this standard will be retained on-site for the purposes of reference.

11.0 On-Site Testing Plan

11.1 On-Site Measurements The lead operator will conduct specific on-site tests to monitor the composting process and maintain desired conditions within the compost pile. The on-site measurements include:

• Pile Temperature • Oxygen Content • Moisture Content • Bulk Density • pH

In addition, certain tests might be made on the curing pile and finished compost to minimize laboratory costs. These tests include:

• Moisture Content • Bulk Density • pH • Compost Stability- Respiration rate (Solvita™)

11.1.1 Pile Temperature

Pile temperatures will be taken daily in each EASP cell until such time as that particular cell satisfies PFRP and NZ4454-2005 conditions.

Pile temperatures will be taken at a minimum of three locations in each row (cell):

• 3 m (10 ft) from one end; • The mid-point; • 3 m (10 ft) from the opposite end.

At each of the three locations the temperatures will be taken at two depths: 300 mm (1-foot) and 1 m (3- feet) deep. Locations are illustrated on Figure 10, below.

Temperature readings will be recorded for each cell by the lead operator, and kept at the compost facility. Temperature readings should include the day’s date, ambient air temperature, and comment on weather conditions. The forms for recording these temperatures are included as Appendix E.

Figure 10 Pile Temperature Reading Locations

11.1.2 Oxygen Content

As the primary means of mitigating the generation of objectionable odours, it is critical to the operation of the EASP compost process to maintain aerobic conditions throughout the pile (i.e., oxygen levels of 10% or greater). The oxygen level of free-air is slightly greater than 20% at sea level.

The oxygen level within the core of the compost pile will be measured weekly within each of the 16 aeration zones, using an “Oxytemp Probe”, manufactured by the US based company, ReoTemp. Staff will be train in accordance with the suppliers Operation Manual.

Measurements will include oxygen levels with the blower running, followed by oxygen levels with the blower turned off for a period of at least 30-minutes. The rate at which the oxygen level:

1) decreases during the blower’s off interval and

2) recovers after the blower has been turned on again will also be monitored.

This “depletion/recovery rate” will be used to adjust the blower’s On/Off cycle times to ensure that aerobic conditions are maintained throughout the active phase of composting (the first 21-30 days). The proceedure for adjusting the blower’s on/off cycle is detailed in Appendix X. Generally an increase of xx minutes aeration per hour will increase the oxygen content XX%.

11.1.3 Moisture Content

The moisture content determination will be performed during construction of a pile. During the curing phase of composting, the moisture content will be taken as needed and at least weekly to assure the pile is neither too moist nor too dry (i.e., greater than 65% nor less than 45%).

The moisture content of the compost will be determined quantitatively on a weekly basis using the oven drying method and qualitatively using the “Squeeze Test” as described in the Appendix F. The procedure for adjusting the moisture content is also included in Appendix F.

11.1.4 Bulk Density

The bulk density of the initial compost mix will be determined and recorded on xxx logbook/field sheet as needed on EASP pile startup. During the curing phase of composting, the bulk density of the finished compost will only be taken as needed. Bulk density is a simple means of assessing porosity. The denser the material is, the lower the porosity. This field test procedure is described in the Appendix D.

11.1.5 pH

During the active phase of composting, the pH can be measured as needed. If a delivery is made that consists of high oxygen demand material and apparently anaerobic, pH would be a method to indicate condition of the material. If the pH is 6 or lower it is recommended to place the material on air constantly for two days to initiate an aerobic process. The pH test is easily performed using a slurry of the compost with de-ionized water and using litmus paper or pH paper. This pH measurement will seldom be necessary as food waste is mixed with sawdust of similar at the mixing/shredding phase.

11.2 Monitoring Equipment Calibration and Maintenance Equipment for on-site testing and the appropriate calibration/standardization is listed in Table 1 below:

Table 1 On-Site Monitoring Equipment and Calibration Formation

Measurement Equipment Calibration

Pile Temperature Compost thermometer 1-1.5 m (3 or 4 foot) length

Monthly or according to manufacturer’s instructions

Moisture Content Oven that can be set to 105° C or microwave oven

Check temperature during each measurement with oven thermometer. For microwave method, compare results with lab moisture content results at least monthly.

Bulk Density Calibrated bucket (known volume – usually 20 litre) and scale weighing at least up to 32 Kg – depending upon volume of container.

Check scale with calibrated weight (can be known volume of water) at least monthly. Accuracy need only be ± 0.5 kg for 20-litre container.

pH Litmus paper or pH probe may be used on-site.

Follow manufacturer’s instructions for calibrating a pH probe. Check expiration date on litmus paper at each use.

Stability Solvita ™ CO2 generation

Solvita ™ test kits must be used prior to expiration date.

12.0 Final product testing and quality assurance

12.1 Introduction This Testing Procedures and Quality Assurance Project Plan (QA Plan) serves two important functions:

• First, the plan establishes the requirements and procedures for the monitoring program. Monitoring the composting process is needed to verify that the finished compost meets or exceeds criteria established for an exceptional quality compost product and to ensure that product quality is consistent and predictable over time.

• Second, the completed plan facilitates communication between Envirofert Compost's management, the operations personnel who collect and ship the samples, the analytical laboratory, and the regulator. This plan will also be useful for training new staff who will be working on compost monitoring, with an emphasis on assuring continuity between sampling, testing events and results.

This plan is subject to change to keep the facility in compliance with current regulations. For this reason, this plan should be reviewed annually and amended as needed, with concurrence from the relevant regulatory agency.

NZS4454-2005 requires testing 7 days prior to distribution. It also states that the testing frequency shall be established by the manufacturer such that it is; suited to the scale of manufacture, local conditions and operating environment, to ensure that the quality of the products are consistently in compliance with the Standard.

Individual client requirements may vary from this standard.

12.2 Testing Parameters In accordance with Table 2 below, Envirofert Compost will test composite samples of the finished (i.e., screened) compost product for the following constituents:

• Metals o Arsenic o Cadmium o Copper o Lead o Mercury o Molybdenum o Nickel o Selenium o Zinc

• Biological Stability • Physical Contaminants • Sharps • pH • Fecal Coliform or Salmonella

12.3 Testing Frequency Table 2 Compost Parameter Testing Schedule for the EASP Compost Process

Test Parameters Lab or On-Site Frequency

Active Phase (EASP piles)

Pile Temperature On-Site Daily until PFRP

Moisture Content On-Site or Lab As needed

Bulk Density / Porosity On-Site As needed

pH On-Site As needed

Curing Phase (after PFRP has been achieved) – Maturation piles

Pile Temperature On-Site As needed

Respiration Rate (Solvita) On-Site As needed or requested by clients, or regulatory bodies

Screened Product

Metals (As, Cd, Cu, Pb, Hq, Mo, Ni, Se, Zn)1 Lab See Testing Frequency Below

Physical Contaminants1,A Lab See Testing Frequency Below

Sharps1 Lab See Testing Frequency Below

pH1 On-Site or Lab See Testing Frequency Below

Salmonella or Fecal Coliform1 Lab See Testing Frequency Below

Biological Stability1,B On-Site or Lab See Testing Frequency Below

Testing Frequency: Every 5,000 cubic yards (product) or every 365 days, whichever is more frequent.1

1Required by WAC 173-350-220 (4)(a)(x) Tables 220-B

A) A label or information sheet must be provided with compost that exceeds .1% by weight of film plastic. See WAC 173-350-220 (4)(f)(iii)(D)(I) and (II)

B) Tests for biological stability must be done as outlined in the United States Composting Council Test Methods for the Examination of Composting and Compost unless otherwise approved by the jurisdictional health department.

C) Note: Biosolids composters regulated under this chapter must communicate with the jurisdictional health department to determine if different testing parameters and testing frequencies are required.

12.4 Types of Samples There are two basic types of sample collection, point-sampling and composite sampling. Point sampling consists of site-specific sample collection from within the general mass to identify and quantify points of extreme variability, hot spots or problem zones. Point-sampling alone should not be used unless special conditions warrant.

Composite sampling consists of a single sample that is derived from multiple samples taken from various locations within the compost pile. A composite sample represents an average value of the properties for the general mass. Properly implemented composite sampling is desirable for most sampling plans because it provides a reliable estimate of the average conditions.

12.5 Representative Sampling / Collection Points For samples to be tested for compliance with Solid Waste Regulations collect composted material samples for analysis that are representative of the pile. Use a sampling method such as described in the U.S. Composting Council 2002 Test Methods for the Examination of Composting and Compost, Method 02.01-A through E.

This Operation Plan relies on composite sampling of representative sub-samples from the compost pile. The term "sample" will be used henceforth to mean a composite representative sample.

Sample collection points will be selected to represent the mass condition, and will generally be taken a minimum of 300 to 450 mm beneath the exposed pile surface. A total of six to eight sub-samples will be taken from each compost pile, with two taken from each of three or four vertical positions in the pile. For example, a pile that measures 2.5 m in height may have two samples taken from the side of the pile at each of the following heights: 0.45 m, 1.2 m, and 1.8 m above the compost pad. Two additional samples may be taken 300 to 450 mm down from the top of the pile, along the mid-line.

The goal of selecting suitable sub-sample collection points is to produce a single, representative composite sample.

12.6 Sampling Equipment List The following equipment and materials should be used for collecting, preparing, packaging and transporting compost samples.

• Sampling container- 20-L (5-gal) plastic, stainless steel, plastic, glass or Teflon • Sampling device- stainless steel, plastic, glass or Teflon spatula, tiling spade, etc. • Trowel - high-density polypropylene (HDPE) • Plastic shipping container -minimum 20-L size cooler • Plastic disposable gloves • Tarp- clean, plastic, canvas, etc. • Plastic bags – 4 L (1-gal) "Ziploc" plastic freezer bags • Cold packs- chemical ice packs • Adhesive tape- duct tape, packing tape, etc.

12.7 Sample Collection Identify and collect an appropriate number of sub-samples needed to ensure a reliable analytical result, as described above. Each sub-sample should be approximately the same volume. Ensure the size of the sub-samples is adequate to produce at least the total sample volume needed by the laboratory for the analyses required. This should be determined by conferring with the laboratory representative prior to sampling. Place each sub-sample onto (into) the mixing surface (container) and proceed to the next selected sample point.

Thoroughly mix the sub-samples using the trowel, moving the materials from the outside to the centre, repeatedly.

Split (i.e., subdivide) the sample into quarters, remove three quarters of the sample and remix as before. Again, split the sample, and remix, and repeat to produce three samples approximately 4-L (1-gal) in volume.

If multiple samples are needed for confirmation testing, remix and split the reserved portion to produce additional samples, each should be at least the volume required for the tests specified. Confer with the laboratory representative to determine required sample volume.

Place each sample in a 4-L (1-gal) Ziploc freezer bag, and remove most of the air prior to sealing. Label the bag as described below, and place the sample in a second, sealed Ziploc plastic bag.

At the conclusion of each sampling event, the equipment should be thoroughly washed and three-times rinsed before initiating subsequent sampling efforts.

12.8 Proper Packaging and Delivery to Analytical Laboratory Each sample must be labelled to include the following information:

• Sample number • Sampling date and time • Cell/Pile number • Age of compost sampled (time since pile formation) • Person who obtained and processed the sample

Place the plastic Ziploc freezer bags containing the samples in the cooler and inter- weave with cold packs for shipping. Seal the cooler and secure the lid with adhesive tape. Place custody seals on at least 2 sides of the lid so that the cooler cannot be opened without breaking the custody seals. Label and send the cooler containing samples by next-day delivery service to the selected laboratory for analysis. Include a completed chain of custody form along with detailed laboratory instructions (i.e., testing program).

Do not use Ice to ship samples unless the water from ice melting can be completely contained.

12.9 Sampling Log Book Record all sampling events in a Sampling Log Book. Each sampling event must include a brief discussion regarding the objectives of the sampling event along with the following information for each sample:

• Sample number • Sampling date and time • Cell/Pile number

• Blower number • Date on which the cell was constructed and date it achieved PFRP conditions • Mix of materials (proportions green waste / other bulking agents) • Person who obtained and processed the sample • General observations and comments

A Sample Tracking Form is provided in the Appendix G section of this Plan of Operations as a starting point for managing the sample documentation required.

12.10 Sample Chain-of-Custody Chain-of-custody (COC) forms and procedures should be used with all environmental or regulatory samples. A chain-of-custody form is used to track sample handling from the time of collection through laboratory analysis, and data reporting. Suggested information for the chain-of-custody record includes, at a minimum:

• Collector’s name • Signature of collector • Date and time of collection • Place and address of collection site • Requested pre-processing • Requested analyses • Sample code number for each sample (if used) • Signature of the persons involved in the chain of possession

Chain of Custody (COC) forms should be maintained along with the Sample Tracking Form, Sampling Log Book, Shipping paperwork, and Laboratory Reports. The laboratory performing the analysis will provide the COC forms.

12.11 Preparation of Samples for Analysis Some laboratory tests require that the sample be prepared prior to testing. This may include further sub-sampling, composting, particle size reduction, etc. The person requesting the test procedure should specify this. Biological analysis requires overnight delivery.

12.12 Analytical Detection Limits The laboratory that provides the analytical services will also provide the detection limits and regulatory limits as part of their analytical reports. The regulatory limits are provided in Table 3.

Pesticide and herbicide scans and bioassays will also be conducted during the first year of start-up. Periodic testing may also be conducted during standard operations, at the request of the regulator. For stability testing, the Solvita™ test method will be used on a regular basis (as described in Section XX and Appendix XX). Testing will be performed by a certified laboratory.

Table 3 Compost Regulatory Limits

Metals and Other Testing Parameters Limit (mg/kg dry weight), unless otherwise specified

Arsenic ≤ 20 ppm

Cadmium ≤ 10 ppm

Copper ≤ 750 ppm

Lead ≤ 150 ppm

Mercury ≤ 8 ppm

Molybdenum ≤ 9 ppm

Nickel ≤ 210 ppm

Selenium ≤ 18 ppm

Zinc ≤ 1400 ppm

Physical Contaminants1 ≤ 1 percent by weight total, not to exceed .25 percent film plastic by weight

Sharps 0

pH 5-10 (range)

Biological Stability2 Moderately unstable to very stable

Fecal Coliform3 < 1,000 Most Probable Number per gram of total solids (dry weight)

OR

Salmonella < 3 Most Probable Number per 4 grams of total solids (dry weight)

1 A label or information sheet must be provided with compost that exceeds 0.1% by weight of film plastic.

2Tests for biological stability must be done as outlined in the United States Composting Council Test Methods for the Examination of Composting and Compost unless otherwise approved by the jurisdictional health department.

3Test for either faecal coliform or salmonella.

12.13 Analytical Methods and Procedures The analytical methods used by the laboratories to evaluate the required parameters shall be in accordance with EPA and Ecology recommendations or NZS4454-2005 requirements.

12.13.1 Quality Control Procedures in the Field

• Make sure all sampling equipment and containers are clean prior to use. Clean any equipment used between each sample: o Partially fill a 20 L bucket with a 10% solution of household bleach or tri-sodium phosphate (TSP) and

Dl water. o Lightly scrub with the bleach/TSP water. Double rinse by pouring Dl water over item thoroughly

directly from Dl water container or use clean squirt bottle of Dl water. o Commence sampling the next pile and repeat the decontamination procedure after sampling has

been conducted. o The bleach/TSP water should be discarded and remade after 5 samples.

• Properly label all samples and keep accurate records. • Store grab samples in a refrigerator before analysis when delays in shipment to the laboratory are

anticipated. If delays exceed sample holding times given by the analytical laboratory, new samples should be collected and shipped to the laboratory in accordance with all described procedures.

• Ship samples in accordance with the analytical laboratory's sample handling criteria. • Always use chain of custody forms and procedures with environmental samples.

12.13.2 Quality Control Procedures in