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HomeMy WebLinkAbout3613_EarthFarms_renewalapplic_20211215W1NDU ER ENVIRONMENTAL 11/15/2021 North Carolina Department of Environmental Quality Division of Waste Management Solid Waste Section 1646 Mail Service Center Raleigh, NC 27699-1646 Subject: Permit Amendment (Renewal) To Whom it May Concern, This memorandum serves a request for permit amendment (renewal) for the Solid Waste Composting Permit for Earth Farms LLC in Dallas, NC, permit SWC-36-13. Enclosed, you will find the documentation and required narrative that satisfies the questions outlined in Sections 1, 3, 4, 5, 6, 7, as outlined in the NC Compost Facility Types 2, 3, and 4 Permit Application Guidance. Should you have any questions or additional required information please do not hesitate to contact us, and we will provide you with a swift response. The point of contact for this memorandum is the undersigned at 704-689-9249 or rellis@wrenvironmental.com. The Earth Farm's office number is 704-922-1775. Ryan Ellis Branch Manager WRE Earth Farms Par`�h farms pRGANICS cnrwr a TOVWa PW#*MXra Earth Farms Organics LLC Large Type III - Compost Permit Renewal Date: 15 November 15, 2021 Section 1— General Information - Provide a narrative discussion, including the following: 1. The name of the facility or proposed facility. Street address of the facility. Include the facility type: large or small, and Type 2, 3, or 4. Earth Farms, 351 Colt Thornburg Rd., Dallas, NC 28034. Large Type III. 2. Name, address, telephone number, and email address of the applicant/owner and contact person. Wind River Environmental LLC dba Earth Farms Organics, Contact person Ryan Ellis, Branch Manager, Earth Farms, 351 Colt Thornburg Rd., Dallas, NC 28034, 704- 689-9249 3. Name, address, telephone number, and email address of the landowner, if not the applicant. A landowner authorization form must be signed and notarized if the facility owner/operator is not the landowner (see attached form). Applicant is the landowner/ N/A 4. Name, address, telephone number, and email address of the engineer and/or composting consultant (if applicable). N/A 5. Name, address, telephone number, and email address of person to receive permit fee invoices and annual fee invoices, if applicable Ryan Ellis, Branch Manager, Earth Farms, 351 Colt Thornburg Rd., Dallas, NC 28034, 704-689-9249 Section 3 - Design Plan — Provide a narrative discussion, broken into appropriate sections, that includes the following items: 1. List the types of feedstocks, residuals, bulking materials, and amendments to be accepted (for example, yard waste, land clearing debris, pre -consumer food waste, post -consumer food waste, grease trap waste, agricultural waste, etc.). For each material, provide a description, list the sources, and indicate whether it will be accepted from the general public. Analytical data will be required for materials that could contain metals or other contaminants, such as commercial or industrial by- products. For Type 4 wastewater treatment plant sludge/biosolids, provide analytical analysis of total metals by SW-846 methods, for arsenic, cadmium, copper, lead, mercury, molybdenum, nickel, selenium, and zinc, for each waste source. X earth farms ORGANICS co��.osr a ro.soa.�ooucn 3. Provide design capacity of the facility, best estimate. The site capacity is the incoming volume, or throughput, per year, and is based on the compost method, duration of the process, and the size of the facility. Show calculations for Large Type 3 and 4 facilities. This is for information purposes only, not to be regulated. See below for design and estimate of yearly volume. Product to Ma rket 65KTon s/Year 4. Provide a description and sizing of the storage areas or containers for feedstocks, amendment, recyclables, finished compost, and waste. The Earth Farms, LLC Compost Facility consists of a series of gravel, concrete and compacted soil pads each of varying size. The site contains several distinct areas. There are: • Area or bay 1-Material receiving (1,000 square yards) • Area or bay 2-Material processing and dewatering area (4,000 square yards) • Area or bay 3-Material curing and VAR compliance area (44,316 square yards) • Area of bay 4- PFRP compliance area (3,000 square yards) • Area of bay 5- Outside storage -areas suited for storing finished compost or dry feedstock materials (6,000 square yards) • In addition to these defined areas, the site also contains tanks for storage and treatment of the raw materials to be processed and composted. These consist of above ground tanks ranging from 6,500 to 10,000 gallons capacity, a dewatering box and other infrastructure permitted as a part of the on -going septage and grease trap waste management program. �q V V earth farms ORGANICS "W"Val { to.raa Pwoouen 6. Describe methods used for measuring, shredding, mixing, and proportioning feedstock materials, to ensure the proper ratios are met. • The compost is manufactured from a mixture of Substrate (the non-putrescible materials) like hardwood and softwood chips and sawdust, ground corn cobs, ground yard waste, etc. with the feedstock (the putrescible materials) like animal bedding, FOG wastes, pre and post -consumer food waste, vegetative/agribusiness wastes. • All the Feedstock (putrescible material) are mixed and blended with a suitable Substrate (the non-putrescible materials) in the concrete mixing pit on the day of arrival to prevent nuisance problems. • The substrate materials (Wood chips, yard waste etc.) for staging purposes are stored in the raw material storage areas for subsequent use as needed. • Feedstocks and Substrates are measured and added into the mixing pit in increments of 5 cubic yards using a front -loader to achieve the required ratio. Feed stocks and substrates are mixed by combining feedstocks and substrates directly on top of each other in the concrete, water sealed mixing pit. And then flips and mixes the compost mixture by rolling and fluffing material with the front loader bucket. • The blended compost materials are then transported and placed on a windrow compost production pad area. • On the pad the windrows continue the composting process that takes approximately 30 days, the windrows are regularly turned (Mixed) using a windrow turner to meet and maintain required time, temperature and turns as required by our permit. At the end of the composting process, once compost has met all time, temperature and turns required the PFRP/VAR compliant compost is moved by a loader and dump truck to the finished compost, storage pad for curing. The finished compost is stored on the curing pad for further curing and stabilization. • A portion of the finished compost is sold in bulk as a soil amendment, but the majority is blended with topsoil or sand etc. and marketed as a finish garden blend or topsoil blend. ., earth =farms � ORGANICS A rubber -tired CAT/VOLVO/John Deere loader is used to mix the wood chips and feed stock on the concrete mixing pad. The primary processing equipment utilized at the site for composting is a Komptech rotating drum compost windrow turner, is a tracked vehicle and powered by it's own CAT motor. The rotating drum rotate and mixes and turns the windrows as it travels down the windrow. The drum is approximately 18 feet in length. The drum turner straddles the windrow which are average 15'ft wide and 6'ft high. A McCloskey 619 and 621 Trommel Screener is used to screen the finished compost. The screener is loaded with the Cat Loader. 8. Provide the anticipated process duration for each stage of the process, including receiving, preparation, composting, curing, and distribution. Receiving. • On day of arrival, the non-putrescible materials are stored in the raw material storage areas for subsequent use as needed for staging purposes. • On day of arrival Feedstocks are offloaded into one of the mixing pits, and then the pit operator using a 5 Cubic Yard front -loader blends the feedstock with the Substrate at the required ratios. • Then mixes the compost blend by rolling and fluffing material with the front loader bucket. • The materials are then transported by loader or dump truck and placed on the windrow pads. • The windrow compost process continues in these open windrows for approximately 30 days for placement to product. • At the end of the composting process, the PFRP/VAR compliant compost is moved by a loader and or dump truck onto the finished compost storage pad for curing. The finished compost is to be stored here for further curing and stabilization until it is ready to be screened, typically less than 180 days. • The cured compost is moved to the screening pad by loader and screened. Typically, only on the screening pad for a day or two. • A portion of the finished compost is sold in bulk as a soil amendment, but the majority is blended with topsoil or sand etc. and marketed as a finish garden blend or topsoil blend. These products are then sold to customers, typically in bulk. If sold in wholesale transactions, compost or compost blends are loaded onto either a 30 Cubic yard Dump Truck or 40 cubic yard tractor and trailer and delivered to customers by Earth Farms tractor operators. If sold in retail transaction, compost is pickup up onsite by Earth Farms customer or delivered to site of use, in no less than 20 Cubic yard quantities. earth Xfarms ORGANIC$ • Content of the collection area or shallow basin are removed as needed and are normally incorporated back into compost batch as a liquid and nitrogen source or are allowed to evaporate. • Any addition of run-off water back to the windrow is carried out in the primary loading of the windrow and results in an additional full processing and heat cycle which results in the Process to Further Reduce Pathogen (PFRP) to be repeated. • Also, option to lime stabilize and land apply. • In very wet conditions or in an emergency, such as a sustained power outage or equipment breakdown, the collected runoff will be transferred to the nearby wastewater treatment facility in Cramerton, NC. 12. Describe any amendments (lime, wood ash, gypsum, etc.) to be added to the finished compost, if applicable, including the amount. For wood ash, provide analytical data for total metals by methods in SW-846. Describe storage of the amendments, maximum pile size, and methods to prevent surface water run-on and run-off, if applicable. If wood ash is added, it should be stated that samples for required finished compost metals analysis will be taken from the compost after the ash is added. No amendments outside of soil and sand are added to compost. 13. Describe controls to address dust and other air emissions (example, a spray mist for dust). For indoor facilities, describe how particulates are minimized. • A water truck with a fan like sprayer on the rear of the truck will pump and spray roads to reduce dust on roads and pathways. 14. Describe any recycling or other material handling processes used at the facility. Section 4 - Operation Plan — Provide a narrative discussion, broken into appropriate sections, that includes the following items: 1. Name and contact for the person responsible for the operation of the facility • Ryan Ellis, Branch Manager, 704-689-9249, 351 Colt Thornburg Rd, Dallas NC 28304 2. A list and description of the equipment, scales, structures, unloading area, water source, hopper, and any other feedstock or compost management devices. Also describe equipment maintenance. Compost Equipment: Superior Scale Inc. Avery -Weigh Tronix Scale: • Weigh in and out trucks to determine weight of loads. Receiving mix pit: • Two cast in place concrete below grade mixing pits. .,� ear" farms ❑RGANICS c mom a topwR rROWic- a * All equipment maintenance is completed according to manufactures specifications through contracted maintenance personnel. Please see below. Water source Unloading Area Equipment Parking Shop / when not in use Office Mulch Food Waste Compost Pad #2 Vegetable Matter Only Compost �di 0 Water source Treatment Plant McCloskey 619 and �r 621 Screeners R i lu i O a Staging Final d ;�Ashed Goods Curing Pad #3 Septage and Food Waste Compost Potential Sources of Odor Note Pads 1,2, and 3 when turning 3. Site security and access control. Large sites must be secured by gates, chains, berms, fences, or other measures to prevent unauthorized entry. Include whether the site will receive feedstocks or residuals from the general public. Security: • The site is secured by fencing on all boundaries, and at entry and exit points there are gates that are chained and locked when facility is not in operation. Compost Pads are also bermed on their perimeter. Receipt of Feedstocks: • Feedstock receipt is limited to licensed contractors. • Site has cameras installed to monitor operations. • All vehicles entering the property must go over the scales and report to the administration office before they can unload or pick up material. • All incoming feedstock is weighed and inspected. • We do not accept feedstocks or residuals from the general public nor unlicensed operators. Xearth j. farms ORGANICS CGWvpyy a ror"M PROOUCn Please see below demonstrating compliance. Earth Farms Crganks Send Waste compost Facmw WN.nk.n mb—Swtas-]s WE •ccep t: •f+n Ma4T..sYnW. I ear W� s,MLL Wa�c. fv, Wnwl MaU-.W Iwn.�a rh" &" yWi ..I. alb � ar .raw w! DO NOT 4CCIM A.larba. [onwn:I.r %,am MW..kn... Warr Mad .W wrap Non d Opwad.n M-F 7:3GAM-1:WPM M.N.5"KI Cawlart WV— 9101 10448 9249 OrM/ENMr7]I ]06 iW S. Permanent boundary markers may be required, depending on the layout of the site, to maintain the operation's required setbacks to the property line or to other nearby residences, wells, floodplains, etc. If natural or existing benchmarks don't exist, include a description of the boundary markers, installed at intervals to allow for line of sight from one marker to the next. Boundary markers are not required. • But berms are established around the composting pads to define the pad edges. 9. List of personnel required and the responsibilities of each position. Branch Manager Job Description: • -Daily Supervision of Staff • -Inspect Facility Daily • -Responsible for Direction of Operations Supervisor and Compost Tech • -Responsible for all record keeping • -Prepare yearly budget • -Manage all maintenance of equipment and facilities Operations Sul2ervisor- Job Description: • -Daily Direct Supervision of Staff • -Assist with facility inspection; fix or mitigate any deficiencies • -Inspect each piece of equipment on a daily basis • -Review daily work orders and plan delivery routes • -Direct supervision of site safety earm fa rms ORGANICS CON~ a 1000.1ft PRODU Ta 11. A narrative description of the compost process, from beginning to end, to include arrival of materials, unloading, processing, mixing, storage, composting, curing, testing, final product storage, and removal from site. Describe the location that each of the activities takes place, and the estimated time for composting and curing. The composting process at the Earth Farms Compost Facility is depicted on the site plan showing the processing area, the concrete mixing pad, the compost production windrows, the curing area, and the screening/mixing area and may be described as follows: o Dry raw materials such as sawdust, wood chips, bedding material, and ground pallet materials (wooden pallets) are received and stored prior to use in "dry material" storage areas. o These materials are combined with a daily delivery of wet raw materials and the dewatered materials generated on -site. o The dry materials are placed directly onto the pad and the wet or processed septage/grease trap materials are placed over the top of the material, these materials are mixed and blended using a loader at the required ratio's. o These materials are mixed in the mixing pit. o The proper ratio of material introduced onto the mixing pad is determined by the number of "buckets" of material placed by the loader. o The bulk mixing operation thoroughly combines the raw material and "mixed" raw materials are transferred to the compost production area. o After initial treatment in the compost windrows for PFRP and VAR compliance, the compost is removed to the initial storage area, where it is allowed to complete the compost curing process. The critical flow duration in the active windrow is 15 days at required temperature with 5 consecutive turnings as required in rule. Typical time in an active windrow will be 4 to 6 weeks to allow for temperature to rise from ambient to thermophilic. Curing and storage may require between 2 and 4 months depending on the season and the end use Mixing and blending will be accomplished in a 24-to-48-hour duration. 12. Method for screening loads for unacceptable waste. Describe plan for handling incoming loads that contain unacceptable waste. Describe storage of the unacceptable waste, the frequency of removal of the waste (at least weekly), and final disposition. • All incoming loads of waste will be screened by either plant operators, equipment operator, operations supervisor, or branch manager. • Visual inspections will be made by these personnel to ensure that any waste brought to site is acceptable. • If large batches of food waste, both pre and post -consumer, are brought onsite, mechanical inspection may be necessary to determine that the load does not consist of unacceptable waste. • No unacceptable waste will be permitted to be stored on site. -.., earth arms ORGANICS �c"WW i TOPOM PRODUM 17. Describe compliance with the time, temperature, and turning requirements in Rule .1406 (11), (12), and (13) as appropriate for the feedstock and compost method. Describe location of and spacing of monitoring points, probe depth (at least 24 to 36 inches), monitoring frequency, and recordkeeping. Monitoring frequency during the time and temperature requirement period should be every other day, or Monday -Wednesday -Friday if the site is not open on weekends. If the site is operated to meet Rule (13)(a) for PFRP then Rule (12) is automatically met for VAR. Temperature will be monitored closely at 20%, 40%, 60%, and 80% of windrow length in all active windrows and recorded daily. • Metabolic or biological activity increases with increasing temperature. • The optimum temperature range for composting is between 130 degrees Fahrenheit and 160 degrees Fahrenheit once the process has begun. • As stated in the North Carolina Solid Waste Compost Rules section .1406, the facility shall maintain the compost process at a temperature above 131 degrees Fahrenheit for 15 consecutive days or longer, with 5 turnings and the average temperature during that time shall be higher than 131 degrees Fahrenheit to ensure the highest level of pathogen reduction. • If windrow material does not reach operating temperature, investigate windrow for moisture content, porosity, and thoroughness of mixing. • Compost managed at the required temperatures will favor destruction of pathogens. 18. Describe the probe thermometer to be used. Describe calibration of the thermometer at least once per year, to include written documentation of the calibration. Onsite calibration using ice water is an acceptable method. Monitor temperature of the compost windrow daily -except for weekends. • The compost tech should monitor temperatures at specified monitoring locations along the windrow. • Temperature monitoring locations are 20%, 40%, 60% and 80% of the total length of the windrow. • The temperature monitoring probes consist of 36- to 48-inch-long dial stem thermometers. Temperature monitoring shall be accomplished at the 24-to-30-inch depth at each monitoring location. • A probe type dial stem thermometer (as manufactured by REOTEMP) with a 36" stainless steel stem will be needed to monitor the temperature of the compost. o Ice Calibration Method ■ Fill a tall glass to the top with ice cubes. Add pre -chilled water to just below the top of the ice. Stir for about 15 seconds. ■ Insert the thermometer stem or probe 2" into the center of the ice bath and stir gently for another 15 seconds, keeping the stem surrounded by the ice cubes and moving constantly An accurate thermometer will read 32°F. Don't let the thermometer rest against the ice or you'll get a low reading. Don't let the thermometer rest against the earth f a rm ORGANICS overnighted to A&L Great Lakes laboratory for examination and is tested within 24 hours of receipt. • Additionally, Solvita testing is conducted on a monthly basis onsite to determine ammonia and carbon levels indicating maturity and stability. • Regular daily on site hand squeeze tests are done to estimate moisture content. • The sample should be processed within the hold time required by the lab testing procedure, and this is usually 24 hours. • The sample that is collected for metals analysis is to be collected and composited over a six- month period (or every 20,000 tons produced) from each batch of compost. See Rule .1407(b)(4) for procedure. 22. Describe distribution and ultimate use of the finished compost. If agriculture nutrient claims are to be made for the compost, for fertilizer or soil additive, the owner is required to meet the requirements of the NC Department of Agriculture and Consumer Services, Plant Industry Division. Finished compost will be utilized as a component of bioretention mix in stormwater systems, as a medium for plant growth, as a landscape material and for agricultural, horticultural, or silvicultural substrate. Sold to Landscaping companies as Compost, or as Topsoil, or ad a Garden blend. All compost materials will be certified as PFRP and representative samples of the material will be tested as accomplished by NCDA for organic matter, nutrient, regulated metal, and salt levels. 23. Describe method for removal from the site, and a contingency plan for disposal or alternative usage of residues or finished compost that cannot be used in the expected manner due to poor quality or change in market conditions. In the event that product is deemed to be of "poor" quality, the compost will be added back to new production of compost and undergo the composting process over again. • This includes PFRP, temperature, oxygen, and moisture monitoring and screening. • If any material was determined to be undesirable and not suitable to be reprocessed, it would be taken to landfill for disposal. • High quality and compliant product that meets all requirements is removed from site and taken to market by either truck and trailer or by dump truck. • It is in a stable and mature state when removed from the property. • Compost or compost products are loaded onto truck by front wheel loaders. • The material is tarped in the bed of the truck and hauled off 24. Describe recordkeeping and annual reporting in accordance with Rule .1406 (1)(b), Rule .1406 (19)(c), and Rule .1408 provide a copy of the temperature log forms and other recordkeeping forms. Per Rule .1406 (1)(b), Rule .1406 (19)(c), and Rule .1408, a copy of the permit, plans, and operational reports are maintained at Earth Farms at all times. Annual training documents for facility staff, including a review of the operations plan and permit documents are maintained on site. earth . arms U MSANICC8 �ayso�r a lepl :s. P=W-1:vr, 27. Plan for fire prevention and actions to be taken in the event of an accidental fire. Describe equipment provided to control accidental fires. It should be stated that any fire will be reported to the Solid Waste Section within 24 hours, followed by a written notification of the details of the fire within 15 days of the incident. • Temperature, moisture, and pile size will be monitored and remediated, if necessary, in order to prevent fires. • Site monitors windrows for hot spots and if any are identified they are addressed before they can develop into a fire. • In the event of an accidental fire, the local fire emergency services will be immediately contacted for assistance. • If employee safety is not compromised, water truck and excavation equipment will be utilized to assist in putting out the fire. • Any fire will be reported to the Solid Waste Section within 24 hours, followed by a written notification of the details of the fire within 15 days of the incident. 28. Plan for maintaining facility property in a sanitary condition and actions to be taken to minimize noise, vectors, litter, dust, and other airborne particulates. It should be stated that at the end of each operating day, the unloading area will be cleared, and all feedstocks will be processed/mixed or properly stored. Describe procedures to prevent blowing litter and dust from leaving the compost area and from leaving the property. Vector and nuisance conditions will be addressed by maintaining proper cover over windrows to prevent vector attraction. • Facility is located in rural, agricultural area, and due to the size of the property any noise nuisance is greatly limited. • Dust control, if needed, will be achieved by wetting roadways and other surfaces generating dust. • At the end of each operating day, the unloading area will be cleared, and all feedstocks will be processed/mixed or properly stored. • Listed below are some maintenance practices that will be implemented to ensure the maintenance and cleanliness of the facility. • Do not allow any equipment that exceeds design load limits on or within twenty feet of the pads. • Maintain all electrical and mechanical equipment in good operating condition by following electrical codes and manufacturers recommendations. Inspect and repair grounding rods, switches, wiring, and all vehicles and equipment involved in the process. • Fences, railings, roofing, and/or warning signs must be maintained to provide warning and prevent unauthorized entry. • Keep the area around the composting facility mowed and free of tall weeds and brush. • Repair any vehicular, vandalism or animal damage. • Inspect and maintain runoff control structures. XLW4earth farms ORGANICS coww 46 TOPOM rwooucrs Equipment Breakdown: In the event of a breakdown of the compost equipment, delivery of raw materials from the onsite treatment facilities should be suspended until the equipment is repaired or replaced and material passes all VAR and PFRP requirements. 30. Site safety procedures concerning onsite equipment (especially grinders), safety during unloading and loading of materials, and safety to address other possible site hazards to workers or the public. • Upon entering the site, the speed limit is 15mph. • Heavy Equipment has the right of way. • All vehicles and equipment when not in motion or in use must be placed in the "park" position and parking brake applied. • All personnel, employees, patrons, and guests must wear reflective gear at all times while on the Earth Farms property. • When operating in conjunction with vehicles, loaders will sound horn upon approach and exit. • When passing at pinch points, all vehicles will sound with a horn blast and the opposite vehicle will sound horn in response. • Spill kits and hazardous disposal kits will remain in place and ready around site at any potential safety hazards. • First aid kits and Eye wash stations are located in the water treatment facility and in the Farm shop. • Trommel screeners operate with automatic shut off features for safety of personnel operating the equipment. • All staff participate in monthly LMS safety training, and regular tail gate safety meetings are held to discuss relevant topics. • EH&S Director from Wind River Environmental does routine site visits and inspections. • Site manager does monthly site inspection including EMS topics and areas. 31. Describe closure procedures for the site when the site ceases operation, in accordance with Rule .1410. Per Rule .1410, if the compost facility ceases operations, Earth Farms shall meet the following conditions: • 1. all feedstock and unfinished compost materials shall be removed from the site and taken to a permitted solid waste or composting facility within 180 days. • 2. Finished compost materials left onsite shall comply with G.S. 130A-309.05. 0 3. Earth Farms shall notify the Division in writing upon completion of the requirements. earth farms ORGANICS • Facility is located in mostly agricultural area with significant buffer and distance from nearest residential homes. • Composting can continue year-round, even during cold weather. Seasonal and weather variation may require operational adjustments that compensate for the change in weather conditions. • Cold weather can slow the compositing process by increasing the heat loss transfer rate form the composting operation into the atmosphere, but the insulation layer should mitigate most of this transfer. The lower temperature reduces the microbial activity, especially near the surface. This, in turn, decrease the amount of heat generated. • Warm weather enhances water loss due to evaporation from the windrows. Water should be added if material become too dry (moisture content drops below 40%). Again, the loss should not be excessive from the windrow, and controls can be implemented by scheduling turning operation or adding moisture as required. • In event excess liquid accumulates on the site because of rain and wet weather. That excess liquid will be collected in a tank truck and processed on site through the SDTF or transported to an approved liquid handling facility such as city of Crameton POTW. 3. Plan to monitor onsite odor and record odor data for the odor sources with the potential to migrate offsite. Data shall include date, time, site specific conditions, weather conditions, wind direction, and characteristics and intensity of odor. Composting plant management and Supervisor routinely conduct site inspections to monitor and address the many routine site management and maintenance requirements. This includes monitoring for any change or increase in odor. • In the event of odor complaints, an Earth Farms representative will immediately investigate the matter and take every available measure to rectify the issue. • The manager and supervisor will investigate odors onsite and will travel to location of odor complaint. • The manager and supervisor will contact complaint making individuals investigate odor include date, time, site specific conditions, weather conditions, wind direction, and characteristics and intensity of odor, and the location the odor was reported. • Manager and supervisor will notify individuals of steps and procedures to fix the described odor and prevent it in the future. • All complaints and actions taken will be login the facility operations logbook. 4. Description of the facility's odor complaint protocol, including forms used, odor verification by operator both onsite and offsite, what the response will be, and who will be contacted. In the event of odor complaints, an Earth Farms representative will immediately investigate the matter and take every available measure to rectify the issue. • The manager and supervisor will investigate odors onsite and will travel to location of odor complaint. • The manager and supervisor will contact complaint making individuals investigate odor time/date, odor smell, odor location, and severity of odor. .. earth farms ORGANICS f. Compost piles are monitored daily for moisture content. When needed, water can be added via water truck to rows. g. Aeration is done through our windrow turner. The windrows will be turned at least 5 times within a period of 15 days while the rows are above 131 F°. h. Any standing water is collected via pump truck. No standing water is permitted on site as per permit requirements. i. The weather is recorded every day in a daily logbook. j. Minimize dust, which can transport odors. k. As and when needed covering the upper third of the windrow with either 3 to 6 inches of finished compost, 3 to 6 inches of a stable compost, or a carbon rich material such as woodchips. • Odor control o Capping piles with fresh carbon source and/or finished compost o All the putrescible material is mixed and blended with a suitable substrate in the concrete pit on the day of arrival to reduce nuisance vectors. o Sufficiently turning piles on a regular schedule and ensuring that they are properly aerated. o Turning is done during low prevailing wind speeds. o Turning is refrained during morning and evening hours as to accommodate for high volume of domestic traveling. o All standing rainwater will be collected and managed as they arise. o Moisture levels, temperature, and pH levels will be monitored daily. • The standing SOP (standard operating procedure) for our site consist of a multifaceted list of checks. This check list takes many factors into consideration when receiving feedstocks (especially new ones), turning windrows, and mixing materials. The list consists of: o Wind direction o Rain falls o Moisture content o Time of day o Overall pungency of feedstock 7. For indoor facilities, describe the design and operation of biofilters, if applicable, and procedures for equipment breakdown. N/A we compost our windrows outdoors. Section 6 — Financial Assurance Financial assurance is required for certain facilities, effective July 1, 2020. It is not required for- earth fare ORGANICS c'a w4w a rorsow PROMM" 2. If the landowner of the property is not the applicant, the attached certification form by the landowner is required. Applicant company is the landowner. Signature page of applicant Name of facility: Wind River Environmental LLC dba Earth Farms Organics I certify under penalty of law that this document and all attachments were prepared under my direction or supervision and that the information provided in this application is true, accurate, and complete to the best of my knowledge. I understand that North Carolina General Statute 130A-22 provides for administrative penalties of up to fifteen thousand dollars ($15,000.00) per day per each violation of the Solid Waste Management Rules. I further understand that the Solid Waste Management Rules may be revised or amended in the future and that the facility siting and operations of this solid waste management facility will be required to comply with all such revisions or amendments. Nab, Signature - Branch Manager Title _ Ellis Print Name Wind River Environmental LLC dba Earth Farms Organics Business or organization name - // A//Zoz-/ Date