7100_WilmCompost_comments_20220816

From: Wilson, Donna J
Sent: Tuesday, August 16, 2022 7:13 PM
To: Shane Lippard ([e-mail]); Riley Alber ([e-mail]); Trey
Alber ([e-mail])
Cc: Stanley, Sherri; Patterson, Elizabeth
Subject: Wilmington Compost Facility in Fender County, permit application review comments
Attachments: example soil treatment permeability comment 5.pdf
Hello Shane, Riley, and Trey,
I've reviewed the response to comments and the revised application for the Wilmington Compost facility and treatment
and processing of the LCID, and I have the following review comments:
1. In the application, provide an update on the LCID clean-up that has been accomplished thus far, and describe
each section A, B, C, D, and E. For section B especially, because it contains the compost area, describe whether
there is any waste present and what the soil cover is currently.
2. Describe the mining process for the LCID units, including surface water management and controls. How will the
compost operation tie in with the recovery of wood waste from the LCID? How and where will the material be
removed, dirt removed, and stored? How is slope and run-off from the excavated areas controlled to minimize
ponding and sediment erosion?
3. For stormwater/surface water flow, DEMLR must be contacted to determine if a permit or approval is
needed. The sedimentation and erosion control plan should be sent to DEMLR. Although the plan is to re -use
water collected in the basin, their office must still review the plans and operations to determine if a permit is
needed. Contacts for DEMLR are Bethany Georgoulias at 919-807-6372 or [e-mail]
and Rick Riddle at 919-807-6375 or [e-mail]. A copy of the application should be sent to them
with a drawing that shows the direction of surface water flow to the basins, as mentioned in the comment
below.
4. On the site drawings, show the ditches or berms around the compost areas, and direction of flow to the onsite
basins. There's a ditch/canal along the west side of the compost/screening/curing area.
5. From the soil maps, the soil type for the composting areas are Murville Muck and Leon Fine. A soil scientist will
need to address the site compost soil base and whether it meets the compost rules. For sandy soil that would
not meet the rule, the site compost areas could be adjusted with mixing in compost fines or another material to
slow down the infiltration of liquids to groundwater, with the goal that the modified soil would have an
equivalent permeability of a material finer than loamy sand. This would apply to the food waste receiving and
mixing area, the initial composting, the curing area, and the screening area.
The intent of the rule is that the soil texture of the base is not sandy soil that would allow leachate or process
water to quickly infiltrate down to groundwater. The soil scientist should provide a report addressing
compliance with the soil texture pad requirements of Rule .1404 (a)(10)(B) through (D). It should include a soil
evaluation down to a depth of four feet, or evidence of a seasonal high water table, to evaluate all chemical and
physical soil properties and depth of the seasonal high water table (required minimum 24 inches for the
compost pad). Include the report in an appendix, and reference the report in the text of the Section.
Attached is part of an application report from a site with similar conditions that may assist you with this.
6. The design plan states that 9800 tons per month of material will be received, including both the compost
feedstocks and extra wood waste for boiler fuel. Provide the expected amount of wood waste for the
composting area only, so that the compost area design capacity may be calculated.
For a rough calculation, if it is assumed that the wood waste would be 3 times the amount of food waste by
volume, or 3.5 times by weight, then 1750 tons of yard waste would be needed. The monthly compost amount
would be 500 + 250 +1750 + 50 = 2550 tons. The application calculation on Drawing C4 shows that the
composting area will hold 5375 cubic yards. Assuming the mixed compost would be 0.55 tons/cy, then 5375 cy

would be equivalent to 2956 tons that the compost area would hold, or a little over 1 month volume. Because
the compost area duration is 3 to 6 months for a batch, it appears that the current design is not big
enough. Please address this so that the size of the compost area will fit the expected incoming volumes.
7. Discuss compliance with the buffer requirements of the Compost Rules, Section .1404 (a)(2) through (5), and
(8). The original application had more information for this and should be added back in. Buffer requirements
apply to unloading areas, composting and curing areas, mixing/processing areas, and feedstock storage
areas. Final product may be stored within the buffer. Provide distance from the compost boundary to the
nearest offsite residence, and nearest perennial stream or water body.
8. The response to comment letter states that an on -site monitoring well will be located west of the food waste
receiving zone. The operating plan states that there will be deep well water source for operations located
onsite. Show these onsite wells on a map. The water source well cannot be within 100 feet of the compost
operation boundaries.
9. For unloading of food waste and liquid -containing waste in the receiving area,
a. How will liquids be prevented and minimized from flowing off the area or infiltrating in the
ground? Describe mixing of food waste and liquid containing waste with the other waste to prevent
liquid run-off.
b. In the facility components description for the receiving area, what is the monitoring and processing of
waste, and meeting proper levels, before it is mixed with other waste (as described in the
application)? Normally incoming odorous feedstocks should be added to carbon material and mixed
into a windrow as soon as possible.
10. Feedstocks - Provide more descriptions of the hemp bio-waste, mushroom substrate material, and spent
brewery trub/grains. What exactly is in it, what does it look like, is it liquidy, is it odorous? Photos would be
helpful. Also, provide more details for the seafood waste, what it would include.
11. On drawing C2, there is a feedstock list and a facility component description. These lists are also in the text but
there are inconsistencies between the text and the drawings. Please remove the feedstock list from the
drawing, and simplify the components list on the drawing so that it is not inconsistent with the application text.
12. The design plan states that 9800 tons per month of material will be received, including both the compost
feedstocks and extra wood waste for boiler fuel. Provide the expected amount of wood waste for the
composting area only, so that the compost area design capacity may be calculated.
For a rough calculation, if it is assumed that the wood waste would be 3 times the amount of food waste by
volume, or 3.5 times by weight, then 1750 tons of yard waste would be needed. The monthly compost amount
would be 500 + 250 +1750 + 50 = 2550 tons. The application calculation on Drawing C4 shows that the
composting area will hold 5375 cubic yards. Assuming the mixed compost would be 0.55 tons/cy, then 5375 cy
would be equivalent to 2956 tons that the compost area would hold, or a little over 1 month volume. Because
the compost area duration is 3 to 6 months for a batch, it appears that the current design is not big
enough. Please address this so that the size of the compost area will fit the expected incoming volumes.
13. Operations Plan:
a. Describe methods to minimize noise, vectors, and litter. It should be stated that at the end of each
operating day, the unloading area will be clear 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.
b. Describe actions to be taken when a pile has too much moisture, or has ponded liquids around the base
of the pile.
14. Design Plan — VAR and PFRP — The text should state that windrow PFRP method of 15 days at 131 degrees, with
5 turnings during the high temperature phase, also satisfies the VAR requirement.
15. The Odor Control Plan in the original application was more detailed than in the revised application, and this
information should be added back in. Also, information from the response to comment letter about the odor
control plan should be included. The intent of the plan is to have a procedure in place if odors become a
problem. Describe prompt mixing and handling of odorous waste, such as seafood waste, so that offsite odors
are minimized. Describe the timing of windrow turning with wind and weather conditions, and windrow
covering, such as the application of 3 to 6 inches of finished compost cover over piles, if odors become a
problem.
N

16. The following parts of the application have unclear meaning without a reference back to the guidance
document. These should be revised to discuss the subject more clearly:
a. Section 2, #10.
b. Section 4, #17.
c. Section 4, #20.
d. Section 4, #25.
Just to note, the future vegetative processing zone is not considered part of the compost application for now. It can
be added in the future as a permit modification.
Responses to comments should be incorporated into the text of the application. Please provide a digital copy (pdf)
only of the revised application and a cover letter that includes responses to comments.
Do not hesitate to call me to discuss any of these comments. I can help explain or help with options. My phone
number is 919-707-8255.
Donna
Dora J- Wilson
Engineering Project Vfanager, Solid Waste Section
Division oj'11'aste -'l anagoment
North arolma-Department of Environmental Quality,
919.707.8255 (Office)
Donna- ilsonrRRncdenr-Ao
Physical Address: 2.17 West Jones Street, Raleigh NC 27603
_flailing address: 164 Mail er��ice Center, Raleigh NC 27699
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