8304_NCORCompost_ReviewComments_20221102

From: Wilson, Donna J
Sent: Wednesday, November 2, 2022 9:15 AM
To: Bill Kish
Cc: Powell, David C; Stanley, Sherri
Subject: NCOR Compost Permit - Food depackaging - Scotland County
Attachments: example NCSU Compost applica.pdf
Hello Bill,
I've completed review of the Large Type 2 compost application for NCOR and I have the following comments.
1. Provide the land deed and parcel information. Parcel information (map with outline and parcel ID numbers) can
be obtained from the County GIS website.
2. Application should state that it meets the 500-foot setback to residences, instead of 200 feet.
3. Provide the USGS topo map (high quality copy is OK) with the compost area outlined on the map (not shaded
in). The topo quad for this area, Wakulla, is showing that the ditch crossing from the NE corner down to the SW
corner is a blue line stream, indicating that it is perennial. Unless this is no longer the case, the drawing should
show the 50-foot setback to the stream.
4. Provide the floodplains map, as described in the guidance.
5. The soil pad requirements would apply to areas onsite where runoff would be in contact with the ground, such
as curing piles. Provide the soil report as described in the text. If all areas are impermeable, such as concrete,
and there is no runoff, then the soil report is not required.
6. Volume calculations for the daily compost amounts appear to be low in the application. A typical food waste
density for source separate industrial food waste is 0.44 tons/CY. With 3 times the volume for yard waste, and
for 15 days volume, the total compost volume would be about 15,300 CY, and would require 13 bins, at 740 CY
per bin.
7. Design Plan:
a. Provide a copy of the DEMLR No Exposure Certification, when you have received it. I believe that the
curing piles would be outside the aerated bins, is that correct?
b. If compost is cured outside the aerated bays, show this area on the map, with surface water control
features.
c. How large is the Clear -Span cover to allow for movement of equipment?
d. How is the mixing area designed and operated to contain liquids?
e. How will the operation within the building be designed and managed to prevent waste spillage outside
the building, and to prevent liquids from flowing out of the building or off the pad?
Operating Plan
a. The text describes the waste arriving at the compost area from trucks that enter the site. Yard waste
would enter in this way. But the food waste would be transported directly from the building to the
compost area. Describe how it will be moved from the warehouse building to the compost area to
prevent spillage.
b. Provide a list of the equipment to be used for the compost operation.
c. Describe the narrative process for the duration within the aerated bays (15 days I believe), and then to
the curing area and duration, and to the final product storage.
d. Provide pile sizes of feedstocks and curing piles, as described in the guidance.
e. 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.

f. 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.
g. Describe contingency plans for wind, heavy rain, snow, freezing weather and other extreme weather
events, air pollution, equipment breakdown, spills, unusual traffic patterns, long-term power outages,
cracks in concrete pads, etc.
h. Describe 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.
9. Site Drawing — Show the curing area, roads, and the footprint of the Clear -Span cover.
10. Provide the aerial photo drawing, as described in the guidance.
11. In the odor control plan, define "LO."
12. Closure plan — Clarify the following: Class 1 or Class 4 landfill, City of Fort Smith, and adjacent municipal solid
waste landfill.
Revisions to the application should be incorporated into the text of the application. Please provide an electronic copy
(pdf) of the revised application, including drawings, and a cover letter that includes responses to comments.
Just for information and comparison purposes, a similar application from another site is attached.
If you have any questions, or would like to discuss, please let me know.
Donna
RE
Donna J_ W11san
Engikwering Project Vanager' Solid Paste Section
Division of 9aste Management
North Carolina Departinent ofEn-vironsnental Quality,
919.707.8255 (Office)
Donna _wilson�dear_ goy
Physical Address: 217 West Jones Street, Raleigh SIC 27603
_Mail- z address: 1646 Mail Service Center_ Raleigh NC 27699
cwespoixi re la and f'Crn tias d4dr ;s l try Owd AkAh Gwcsru F'UL,* ; Fw€: wm Law&xj
MW b, ck3� b 1l>+rdpwk."",
From: Bill Kish <[e-mail]>
Sent: Wednesday, October 19, 2022 2:06 PM
To: Wilson, Donna J <[e-mail]>
Subject: [External] NCOR Compost Permit
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Good Afternoon,
I have been in contact with Danny Smith — Head of Storm water Permitting at NCDEQ and Mike Lawyer — Fayetteville
Region storm water permitting.
I have discuss the compost site, compost operation and the process at the Maxton location. It is their conclusion that we
will not need a storm water permit. They have advised that we request a No Exposure Certification. We are required to
notify Mr. Lawyer 60 days prior to the start up date of the facility so that he can perform a site inspection. He will be

specifically looking to confirm that the receiving/blending and the active composting and curing are all confined to inside
of a building, as we have stated.
Therefor, we are requesting that our permit approval proceed so that we can start and complete the construction in a
timely manner. Campbell Soup has been requesting a timeline as to when they can stop taking the vegetables to the
landfill and start compost at our Maxton facility.
Please let me know the status of our application.
Thanks
Bill Kish
Sent from Mail for Windows 10
BILL KISH
DIRECTOR
OPERATIONS AND MARKETING
ACOR
[phone]
Bkish(@ACORUSA.com