3204_DurhamCompost_foodwaste_20200103

Wilson, Donna J
From: Wilson, Donna J
Sent: Friday, January 3, 2020 4:57 PM
To: Jorge Montezuma; Muriel Williman ([e-mail]); gary.nihart
([e-mail])
Cc: Stanley, Sherri; 'Doby, Troy'; Davis Conners ([e-mail]); Rick Trone
([e-mail])
Subject: City of Durham composting, food waste and yard waste grinding, 3204-
COMPOSTING-1991 and WQ0040265
Attachments: Compost (g)(2) exemption guidance 12-10-19.pdf
Hello Jorge,
This email is in response to the City of Durham and Atlas Organics' proposal to operate a food waste and yard waste
grinding operation on the site of the City of Durham's Type 1 compost site. The Type 1 compost site is permitted as
3204-COMPOST- 1991, and is located at 2115 East Club Boulevard in Durham, latitude/longitude 36.037672,-78.852378.
After grinding, the mixed food waste and yard waste would be transported to the City's nearby compost site that is
permitted by NC DEQ Division of Water Resources, as permit WQ0040265, located at latitude/longitude 36.027569, -
78.857498.
The Solid Waste Section agrees that the proposed food waste and yard waste grinding operation appears to be able to
meet the permitting exemption of compost rule .1402 (g)(2). Guidance for the permitting exemption is attached.
The Section may require a permit in the future (combine it with the Type 1 compost permit), if there are observed
operational problems, including leachate and odors.
The following are descriptions you provided for the operation:
1. The plan is to collect post -consumer food waste in the yard waste bins collected in the City of Durham and bring
those bins to the Type 1 facility. We expect between 10-20 pounds of food waste per household per week to be
present in the bins. Once the comingled bins are unloaded at the Type 1 site, the materials will be ground and
transported to the DWR-permitted Type 4 compost facility (down the road) to be composted properly. Based on
our conversation, as long as we don't exceed 100 cubic yard of food waste at any one time and follow the other
provisions on the exemption, the Type 1 would not need a permit modification.
2. Prepare Mulch Bed: Place a layer of mulch (-1 foot) where the trucks will be unloading the comingled yard
waste and food waste loads to absorb any potential liquids.
The Type 1 operation has a compacted pad which drains to a stormwater pond which then flows to the North
Durham wastewater treatment plant. These elements ensure protection to surface water and groundwater.
3. Grinding Enough Yard Waste: We estimate the volume of yard waste will be much larger than that of food
waste in the comingled loads, but to ensure that is the case, we plan to add additional yard waste material to
absorb liquids through the grinding process.
4. Yard Waste Loads Post -Grinding Comingled Loads: after all of the comingled food waste and yard waste is
ground, staff will ensure that there is no visible food waste on the grinder and will add yard waste -only loads
through the grinder and manage this material as if it were comingled with food waste.
5. Move Material: after grinding, the material will be moved from to the Type 4 facility (down the road without
leaving county property) as soon as possible to minimize odors. We expect to move material within 24-48 hours
of grinding.

Cover in Case of Equipment Breakdown: in case material cannot be ground right away, the comingled yard
waste and food waste loads will be covered to minimize odors. And if the material has been ground but is not
able to be moved, it will be covered prior to odors forming.
If you have any questions, please let me know.
Donna
DBE
Donna J. Wilson
Engineering Project it anager, Solid WasteSection
Division of 1J'asre _ & aagement
North Carol=Department ofEnvironmental Quality
919.707.8255 (Office)
Donna. Wi lsonr nc dery _ g o
Physical Address: 217 West Jones Street, Raleigh NC 27 03
_Mailing address: 1646 Dail Service Center, Raleigh ICI 27 99
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North Carolina Department of Environmental Quality
Division of Waste Management
Solid Waste Section
NORTH CAROLINA
Environmental Quality
12-10-2019
COMPOST FACILITY
PERMIT EXEMPTION GUIDANCE
RULE .1402 (g)(2)
The North Carolina Compost Rules, readopted effective November 1, 2019, include a new
permitting exemption for small compost facilities accepting certain Type 1, 2, and 3 feedstocks,
provided that specific conditions are met. The permitting exemption will primarily apply to
small food waste compost facilities, and is described in the Compost Rules in 15A NCAC 13B
.1402 (g)(2).
Compost facility operators that meet the conditions of the exemption are not required by the
Solid Waste Section (Section) to obtain a permit, and are not required to notify the Section or
obtain any approval from the Section for the compost operation. If a compost site meets the
conditions and operates according the conditions of the exemption, then the site is in
compliance with the Section rules.
Compost facility owner/operators that currently hold a compost permit or compost demo with
the Section, and believe that their site qualifies for the exemption, should contact the Section
at phone [phone].
Other compost permit exemptions, including backyard composting and farming operation, have
not changed from the previous rules, and are not included in this guidance. Some current small
Type 1 notified sites may qualify for the new exemption, based on size. See Rules .1402 (f) and
(g) (1) for reference.
Conditions of the Exemption
Feedstocks that can be received are limited to food waste, compostable dinnerware,
manure, vegetative agricultural waste, yard and garden waste, land -clearing debris,
untreated and unpainted wood waste, and/or source separated paper.
2. Volume of material onsite, not including finished compost, cannot exceed 100 cubic
yards at any given time. This amount includes feedstock storage, active composting and
curing composting. The volume onsite does not include finished compost. As a rough
estimate:
• The size of 100 cubic yards of compost, in the shape of one long windrow, would be
approximately 8 feet wide, 5 feet high, and 100 feet long (windrow shape can vary).
• The weight of 100 cubic yards of compost would be approximately 55 tons.
3. Size of the operations area must be less than one acre. The operations area is the sum
of the areas for feedstock storage, unloading, grinding, mixing, composting and curing.
The operations area does not include finished compost storage, roads, or buffer areas.
This guidance is not a substitute for the applicant reviewing and understanding the applicable North Carolina Statutes
and Administrative Code.

4. Location and setback requirements:
• Cannot be located within the 100-year floodplain (see Rule .1404 (a)(1)).
• Cannot be located in a wetland.
• Cannot be located on top of a closed disposal area, without approval of the Section.
• Minimum setbacks are required between the compost operations areas and the
following:
o Property line, 50 feet
o Residences not owned by the owner/operator, 200 feet
o Wells, except monitoring wells, 100 feet
o Streams and water bodies, 50 feet
o Ditches and berms, 25 feet
5. Other local, state, and federal rules and requirements continue to apply to the compost
operation, including local zoning.
6. Soil pad under the operations area:
• The operations areas must have either a soil pad with a soil texture finer than loamy
sand or an impermeable pad, such as concrete or asphalt. A soil pad finer than
loamy sand generally means that the soil pad contains enough clays and silt size
particles to prevent quick infiltration of liquids to groundwater. Natural soil
conditions in some areas in the coastal regions are highly permeable sands with little
to no fines.
• The depth to groundwater for the operations area must be at least 24 inches.
7. Surface water and liquids management:
• Liquids, compost process water, and contaminants cannot enter surface water in
violation of the Clean Water Act and water quality standards 15A NCAC 02B.
• The site must be operated to minimize surface water run-on to the site, run-off of
liquids from the site, and ponding of liquids around the compost windrows.
• Soil erosion control measures must be practiced to prevent discharge of soil and
feedstocks into surface waters or wetlands.
8. Pathogen reduction and vector attraction reduction is required, and is documented by
time and temperature measurements. Written records of temperature monitoring must
be kept for each batch during the time and temperature requirement period.
Windrow Method
• Aerobic conditions must be maintained during the composting process.
• A temperature of 131 degrees F or greater must be maintained for at least 15
consecutive days.
• During the high temperature period, the windrow must be turned at least 5
times.
Aerated Static Pile Method
• Aerobic conditions must be maintained during the composting process.
• The temperature of the compost must be maintained at 131 degrees F or
higher for at least 3 consecutive days, to meet PFRP (Process to Further Reduce
Pathogens).

• The temperature of the compost must also be maintained at 104 degrees F or
higher for 14 consecutive days or and the average temperature for that time
must be 113 degrees F or higher, to meet VAR (Vector Attraction Reduction).
• The two temperature requirements can be combined or overlap. The following
are examples:
0 14 consecutive days at minimum 131 degrees F.
0 3 consecutive days at minimum 131 degrees F, followed by 11
consecutive days at minimum 113 degrees F.
In -Vessel Method
• The temperature of the compost must be maintained at 131 degrees F or
higher for at least 3 consecutive days, to meet PFRP (Process to Further Reduce
Pathogens).
• The temperature of the compost must also be maintained at 104 degrees F or
higher for 14 consecutive days or and the average temperature for that time
must be 113 degrees F or higher, to meet VAR (Vector Attraction Reduction).
• The two temperature requirements can be combined or overlap. The following
are examples:
0 14 consecutive days at minimum 131 degrees F.
0 3 consecutive days at minimum 131 degrees F, followed by 11
consecutive days at minimum 113 degrees F.
9. Operation requirements:
• The temperature of the compost must be monitored with a compost thermometer,
which should be calibrated annually. Calibration can be achieved using ice water.
• Odorous waste arriving at the site must be promptly mixed into the compost process
with carbon bulking material to prevent offsite odors.
• The site must be operated to minimize odors at the property boundary. Methods
include covering the windrows with finished compost and turning windrows during
favorable weather conditions.
• Adequate design process indicator parameters, such as C:N ratios, moisture content,
porosity, oxygen, etc., must be maintained to prevent odors and to meet pathogen
reduction.
• The site must be operated in a manner to prevent dust or other airborne particles
from leaving the property, and to prevent the attraction of insects and rodents.
10. Analytical testing
• If the finished compost will be distributed to the public or used in public places (such
as the entrance to an office building), then analytical testing is required. A sample of
the compost is required to be sent to a lab every 6 months for analysis of pathogens
(either fecal coliform or salmonella), in accordance with Rule .1407(b). Records of
testing must be kept for 5 years. A list of labs is linked on the Section's website.
• If only Type 1 waste is composted (yard and garden waste, tree clearing waste, and
untreated/ unpainted wood waste), analytical testing is not required.

If a compost operation cannot meet all the requirements of the exemption, then a compost
permit will likely be required. The operator may contact the Section or refer to the compost
application guidance on the Section's website.
Enforcement and Compliance
If the Section receives a complaint about a compost facility subject to this exemption, an
inspection will be made to determine compliance with State Rules.
If a compost site subject to this exemption fails to meet the requirements, then the Section
may initiate enforcement action. A permit will be required for a site that cannot maintain the
requirements of the exemption, such as failure to minimize odors, failure to maintain size
requirements, inadequate buffers, liquids entering surface water, or presence of unacceptable
feedstocks.
Compost Rules
The N.C. Compost Rules, 1SA NCAC 13B .1400 et seq., can be viewed on our compost webpage:
http://deg.nc.gov/about/divisions/waste-management/solid-waste-section/composting.
Contact the Solid Waste Section
If you have questions, please contact the Solid Waste Section at phone [phone].

Wilson, Donna J
From: Jorge Montezuma <[e-mail]>
Sent: Thursday, December 19, 2019 4:25 PM
To: Wilson, Donna J
Subject: RE: [External] Re: Durham Type 1 - Exemption Clarification
EExternal
email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
@nc.gov
Hi Donna,
Sorry for the delay in response, I was working on other projects. When we begin grinding comingled yard waste and
food waste at the Type 1 we plan to follow these BMPs:
1. Prepare Mulch Bed: Place a layer of mulch (-1 foot) where the trucks will be unloading the comingled yard
waste and food waste loads to absorb any potential liquids.
a. The Type 1 operation has a compacted pad which drains to a stormwater pond which then flows to the
North Durham wastewater treatment plant. These elements ensure protection to surface water and
groundwater.
2. Grinding Enough Yard Waste: We estimate the volume of yard waste will be much larger than that of food
waste in the comingled loads, but to ensure that is the case, we plan to add additional yard waste material to
absorb liquids through the grinding process.
3. Yard Waste Loads Post -Grinding Comingled Loads: after all of the comingled food waste and yard waste is
ground, staff will ensure that there is no visible food waste on the grinder and will add yard waste -only loads
through the grinder and manage this material as if it were comingled with food waste.
4. Move Material: after grinding, the material will be moved from to the Type 4 facility (down the road without
leaving county property) as soon as possible to minimize odors. We expect to move material within 24-48 hours
of grinding.
5. Cover in Case of Equipment Breakdown: in case material cannot be ground right away, the comingled yard
waste and food waste loads will be covered to minimize odors. And if the material has been ground but is not
able to be moved, it will be covered prior to odors forming.
Please let me know if these BMPs address your questions. I would be happy to discuss and modify as needed.
Thank you,
Jorge
Jorge L. Montezuma, PE
Atlas Organics, Inc.
864-345-0190
www.atlasorganics.net
From: Wilson, Donna J <[e-mail]>
Sent: Friday, December 6, 2019 10:03 AM
To: Jorge Montezuma<[e-mail]>
Subject: Re: [External] Re: Durham Type 1- Exemption Clarification

Sorry Jorge. I've been out of the office some and Sherri has been too, but I have talked with her about it.
If you could address a couple of things about it, we would appreciate it. The main points for us are protection
of human health and the environment, and for this it would be liquids potentially entering surface water or
infiltrating to groundwater, through both the grinding and any storage, and potential offsite odors. Could you
tell us how this would be handled at the grinder site?
Thanks, Donna
Do= J. Wilson
Engineering Project Vanager, .Solid Waste .Section
D1viEion of Maste Management
North Carolma.Department ofEnviromnental Quality
919.707.8255 (Office)
Don rta _Wilsonra�ncdeny_
Physical Address: 217 West Jones Street, Raleigh NC 27603
_flailing address: 1646 Mail Service Center, Raleigh NC 27699
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From: Jorge Montezuma <[e-mail]>
Sent: Thursday, December 5, 2019 10:16 AM
To: Wilson, Donna J <[e-mail]>
Subject: [External] Re: Durham Type 1 - Exemption Clarification
I email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
nc. ov
Good morning Donna,
Just following up on this. Please let me know if you have any questions. Thanks.
Jorge
Jorge L. Montezuma, PE
Engineering Division Manager
Atlas Organics, Inc
On Dec 2, 2019, at 10:50 PM, wrote:
Hi Donna,
I hope you had a good Thanksgiving weekend. I'm writing to follow up on our conversation from Friday,
November 22 regarding accepting comingled food waste and yard waste at the Durham Large Type 1
compost facility (3204-COMPOST-1991) and the .1402(g)(2) exemption. The plan is to collect post -
consumer food waste in the yard waste bins collected in the City of Durham and bring those bins to the

Type 1 facility. We expect between 10-20 pounds of food waste per household per week to be present
in the bins. Once the comingled bins are unloaded at the Type 1 site, the materials will be ground and
transported to the DWR-permitted Type 4 compost facility (down the road) to be composted properly.
Based on our conversation, as long as we don't exceed 100 cubic yard of food waste at any one time
and follow the other provisions on the exemption, the Type 1 would not need a permit modification.
Please let me know if this is correct.
Thank you,
Jorge
Jorge L. Montezuma, PE
Atlas Organics, Inc.
864-345-0190
www.atlasorganics.net