6030_DavidsonCompost_emailexemption_20200521

From: Wilson, Donna J
Sent: Thursday, May 21, 2020 5:22 PM
To: 'Jolly, Charles'
Cc: '[e-mail]'; 'Smith, Ryan P.'; Teresa Bradford
([e-mail]); Stanley, Sherri; Deb Aja ([e-mail])
Subject: Davidson College Compost Facility, 6030-COMPOST, possible permit exemption
Attachments: Compost (g)(2) exemption guidance 12-10-19.pdf
Hello Charles,
As we were discussing by phone today, the NC Solid Waste compost rules were revised November 1, 2019. One of the
changes is a new permit exclusion that it appears the Davidson College compost site would qualify for. If the site
qualifies, then a permit would no longer be required, but the site would still have to meet state compost rules.
A guidance document for the new permit exemption is attached. The new rules can be viewed here.
Two conditions in particular that you would need to check are the size limitation (one acre) and maximum amount
onsite at any given time (100 cubic yards).
The size exemption of maximum one acre is for the combined mixing, feedstock storage, active composting, and curing
areas; but not finished compost.
Please look at the attached guidance and let me know if you believe that your qualifies for the exemption. If it does, we
will close out the permit. You can choose to stay permitted, however. If the permit is closed out now, it can be re-
opened in the future.
We also discussed a separate compost operation on the college property that would be associated with farming
operations. Farming compost operations are exempt from the state compost rules if the compost is produced from
materials grown on the owner's land and re -used on the owner's land or associated farming operations and not offered
to the public. See page 2 of the rules, at the link above, 15A NCAC 13B .1402 (f) (2).
If you have any questions please let me know.
Thanks, Donna
Donna J. Wilson
Engineering Project Vfanager, Solid Paste Section
Division of Maste Management
North Carolina Department of Environmental Quality
919"707"8255 (Office)
Donnas-Wilson,L41 deer"g
Physical Address: 217 West Jones Street, Raleigh NC 27603
Mailing address: 1646 Mail Service Center, Raleigh NC 27699
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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].