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. Cak~ll be transported in specially design boxes on rail cars to the Patton Island rail facility and unloaded. The non-PSRP biosolids will be transported from the

rail facility to our lime stabilization site and treated to meet class B. After confirmation of treatment the biosolids will then be transported to agricultural land application sites. Synagro will land apply biosolids on approved sites in accordance with operational procedures and rates established. Application sites will be rotated so as not to adversely impact the local community transportation system. Highway regulations, weight limits and other ordinances are known and will be observed.

Based on EPA, ADEM and Agronomic guidelines the annual rate of application has been found to be governed by the nitrogen content of the biosolids. The lifetime application rate is limited by metals, based on recommended nutrients and metals additions to agricultural land set forth in EPA Process Design Manual, Land Application of Municipal Biosolids, Technology Transfer (EPA 625/1-83-016 October, 1983)

Biosolids will be transported from the treatment site to approved land application sites. The transport units will be inspected, licensed and appropriately marked, as required, for the purpose of transporting biosolids. The transport trucks will deliver the biosolids to high floatation; land application equipment stationed in the field.

Synagro will utilize road tractors with trailers equip to handle the boxes. Biosolids will be delivered and applied between the hours of 6a.m and 6p.m.

Biosolids distribution on the land application sites will be uniform throughout the approved area. To ensure adequate of the application rate for each site, the equipment used for spreading will be calibrated by measuring the amount of out put on a known square footage. While the rate of discharge from the application equipment is fixed the speed of the equipment can be adjusted to maintain the flow rate needed to achieve a specific rate.

Application operations will be discontinued during periods of inclement weather and will not resume until sufficient drying of the fields is complete. This allows equipment access without causing excessive soil compaction or rutting and prevents run off.

Site Operations

1) The principal method of application will be surface.

2) The amount ofbiosolids applied will be limited to field crops, forages and timber.

3) The buffer zone distances as follows will be observed.

a) From traveled surfaces of public roadway: 50 feet

b) From on - site residences of land owner receiving biosolids: 50 feet (if a buffer waiver is signed)

cj.From any residences or place of public assembly under separate ownership or which is to be sold: 300 feet

d) From property line: 50 feet

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e) From residential well: 300 feet

f) From livestock well: 100 feet

g) From Karsts feature: 300 feet

h) From municipal well: 1000 feet

i) From streams, wet lands, ponds: 50 feet

j) From ditches: 33.5 feet k) From springs: 300 feet

Buffer zones will be flagged, and no biosolids will be applied within the buffer zone. The most restrictive buffer will apply in combined situations.

4) Operational provisions will be taken to prevent soil loss through erosion.

Provisions will include contour application and avoidance of areas where surface drainage patterns result in concentrated flow of runoff from rainfall.

5) In accordance with good agronomic practice, areas which are unseasonably wet, therefore producing rutting or damage to the field will not be utilized for application during these periods.

6) The amount of biosolids will not exceed the physical dry ton capacity of the field at the time of each application.

Currently EPIC a Division of Synagro is providing rail transportation for New York City Class B biosolids. These biosolids are being railed to Virginia and to Colorado for land application. EPIC also provides rail transportation ofbiosolids that do not meet EPA's requirements for Class B biosolids, these residuals are treated to Class B requirements before being land applied.

Synagro is proposing two professional services through EPIC to the City of New York. One is the lime stabilization of non Class B biosolids to meet Class B, and second is the land application of the biosolids. The residuals will be received by rail at our Patton Island Facility in Lauderdale County Alabama. The non Class B residuals will go to our treatment facility in Colbert County Alabama where they will be lime stabilized and certified as Class B material. The lime stabilized residuals will then be land applied.

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Synagro is proposing that up to 73,000 wt of residuals from New York City be railed to Alabama for lime stabilization and land application. The rail siding for receiving biosolids and the operation center is located at Florence, AL located in the extreme NW

., comer of Alabama. The lime stabilization site will be located in Colbert County, AL.

Colbert County is located in North West Alabama. The treatment facility will be in a rural area of Colbert County. The dominant agricultural land use for north west Alabama is row crops and cattle. The planed area of land application operations will cover Lauderdale, Franklin, Limestone Lawrence and Colbert counties. These counties cover several land resource areas; they are the Tennessee Valley, Sand Mountain and Coastal Plain. The Tennessee Valley is characterized by broad, gently sloping areas with semikarst topography. The Sand Mountain is characterized by steep mountain sides and broad plateaus while the Coastal Plains are characterized by long narrow ridge tops, steep side slopes and a dendritic. drainage pattern. These three land resource areas support timber, cattle farms and row crop farms.

These counties have humid and temperate summers while winters are cool but include frequent short periods that are cold or moderately warm. Precipitation is distributed fairly through out the year with late winter and early spring having the greatest rainfall.

Synagro will lease the property for lime stabilization from Mr. Mark Hamilton of Hamilton Farms in Colbert County. Improvement to this property will be made to accommodate our lime stabilization process. Such improvements will include a concrete slab for unloading biosolids as well as a slab and roofed area to house the Bio*Fix processing unit

Synagro will use a proprietary alkaline stabilization process called Bio*Fix. This process uses quicklime (CaO) to treat biosolids prior to beneficial use. The Bio*Fix Class B process is characterized by an increase in pH and temperature that meets environmental standards established by the u.S. EPA 40 CFR Part 503 Regulations and state, local requirements associated with the end product use. The process effectively controls odors, inactivates pathogenic microorganisms and prevents vector attraction.

Synagro has in place a detailed record keeping and analytical process for lime stabilization to document the treatment and insure compliance of the end product.

The Class B Bio*Fix process achieves pathogen and vector attraction reduction requirements by elevating the pH to at least 12 and maintaining pH ~12 for two (2) hours and holding pH ~11.5 for 22 more hours.

Process Description

A typical BIO*FIX process flow diagram is provided below. Dewatered biosolids are transported into a receiving hopper by conveyors or front-end loaders. At the bottom of the hopper a variable speed screw feeder delivers biosolids to a screw conveyor which in turn feeds a process mixer.

The process mixer employed to provide the level of mixing required by the BIO*FIX . process is a dual shaft, plow-type mixer. Quicklime is delivered by trucks and stored onsite in silos. These materials are fed to the mixer via a variable speed airlock valve and screw conveyor.

The end product discharged from the mixer is conveyed via screw conveyors directly into tractor trailers for transportation to sites for land application. The end product(s) can also be diverted into an on-site storage area before being moved if weather dictates.

The state of Alabama falls under the jurisdiction of EPA Region IV in Atlanta, GA. The Alabama regulating authority is the Alabama Department of Environmental "Management (ADEM) located in Montgomery with field offices in major cities throughout the state. ADEM has no home rule governing the use ofbiosolids they defer to EPA Region IV. However Synagro has worked closely with ADEM since the first project began in Alabama in 1987. ADEM is kept informed of all the operations that are currently on going in the state. At this time these are projects we have under contract for land application of residuals;

Albertville Decatur Foley

Gulf Shores Guntersville Jasper Madison Muscle Shoals

Stevenson (Smurfit Stone)

We also have anywhere from one to five clean out projects per year where land application is performed.

Synagro has presented this project verbally to Mike Hom at EPA Region IV. This discussion with EPA provided Synagro with regulatory guidance for this project. For this project; Synagro completed a Treatment Works Treating Domestic Sewage Application (TWTDS) and sent it to Region IV EPA. In addition to the TWTDS Application an ouotof-state notification regarding biosolids from another state being land applied in Alabama, who sent to EPA Region IV. Region IV EPA also request copies of the Annual Biosolids Report due by February 19th of the following year of application. Synagro will provide this data to EPA each year.

The Alabama Department of Environmental Management has also been notified of biosolids coming to Alabama from out of State. In our conversations with Jim Grassiano (Section Chief of Permits & Compliance, Municipal Branch Water Division) the state has no objections to this project. Written confirmation of our intent to move forward with the project has also been sent to ADEM. The state of Alabama will require no permits; however they will be sent a Land Base Book containing all land application sites and specifics to those sites. They will also be sent a Treatment Facility Book containing specifics to the lime stabilization of non PSRP biosolids. Synagro will provide this project information to ADEM.

The land base requirement for the New York City biosolids expected in Alabama is at this time based on 73,000 wt per year, and the average Plant Available Nitrogen estimated at 38 lb/dt. The land base requirements for the project have also been determined from other programs that Synagro manages. In the event volumes for the project increase there is additional land and interested farmers to support this.

The amount of land base needed was determined by converting 73,000 wt into dry tons based on an average %solids from 12 analyses provided by EPIC.

73,000 wt x 21.84% solids = 15,943.2 dry tons

We will be able to land apply 6.26 dry tons per acre based on a Plant Available Nitrogen of 111.36 lbs of PAN per loaded spreader equaling 16cy, a 10% safety factor was used to assure compliance with loading rates. The PAN was calculated by using the average of TKN, NH3, Organic Nand % solids from 12 analyses provided by EPIC. The data was inputted into the following formula; PAN = [fl (ppm Organic N) + VI (ppm Ammonia N) + ppm Nitrate NJ x .002. The main forage grass in the area is Bermuda which requires 300 lbs/ac of nitrogen per year. Based on these figures we will need at a minimum 1744.4 acres to support the project.

15,943.2 dt -i- (2Ids/ac x 3. l Jdt/ld) = 2,546.83 acres

A land base management safety factor of 3 is used as a multiplier to account for land unavailable because of management issues such as weather, grazing, harvesting. 2,546.83 acres x 3 = 7640.49 acres

Land application rates will be based on the PAN of the biosolids and the nitrogen requirement of the crop, forage, hay or timber and there respective means of agronomic management. The current land base proposed is made up of the following.

Crop

Tall Fescue Rye Grass Small Grain Bermuda Grass Corn

Cotton Soybeans

Pines

N lbs/ac 250 160 160 300 200 110 250 120

The biosolids analyses will be forwarded by EPIC to the Synagro Technical Service Manager for the project. Upon receipt of the analyses the results will be reviewed for compliance with 503 regulatory limits. At this time data will be entered into a computer program to evaluate the nitrogen, metals, phosphorus, potassium, and micro nutrients content. The same analyses will also be forwarded to our monitoring department for input to Synagro's Residual Management System (RMS). Application rates will be based on field acres, analyses, 'ORE (Dose Rate Evaluation), Nitrogen requirements and nitrogen already applied, and also metals applied.