9700_WilkesAbattoir_ReviewComments_20230518

From: Wilson, Donna J
Sent: Thursday, May 18, 2023 4:05 PM
To: Adam Gaines; Chandler Cummins ([e-mail]); [e-mail]
Cc: Gerstell, Charles
Subject: Wilkes Abattoir Compost facility, Wilkes County
Attachments: Compost 2 3 4 applic guidance 2-23-2021.pdf, NC Compost Rules (November 1, 2019).pdf
Hello,
I've completed review of the application for the Wilkes Abattoir Compost facility, a small Type 3 compost
facility. Review comments and questions are below. Attached are the application guidance and a copy of the Compost
Rules.
1. General Information and Siting:
a. Provide the legal name for the applicant in the application, as it is registered with the NC Sec. of
State. This will be on the permit cover.
b. On the first page of the application, the lat/long location of the site appears to be wrong. I believe it
would be approximately 36.248099,-81.124943, based on the maps.
c. The property information listed in the application appears to be the wrong parcel for the compost
facility. Provide the parcel number and PIN number, and a copy of the map showing the property
parcel, which can be obtained from the County GIS website.
d. Provide a copy of the land deed, this can be obtained from the County Reg. of Deeds website.
e. Provide an image copy of the floodplain map with the site location marked.
Operating and Design:
a. The carbon to nitrogen ratio, and porosity, will be hard to meet with only using finished compost for the
bulking material. It's OK to use some finished compost and chicken litter for initial mixing, but there will
need to be other woody type material to provide carbon, absorption, and air pockets. Provide volume
or weight of carbon material to be received and composted per week.
b. Add in text how the waste will be transported, unloaded, and moved within the building, prior to
compost mixing, to minimize spillage of liquids and waste.
c. For active composting on the aerated floor, please add pile size - height, width, length. Also add the
maximum pile size for curing compost.
d. Describe how the piles will be labeled or managed to keep track of the age of each pile.
Related to the pile size/shape, how and where along the piles will temperatures be taken? Depth 24 to
36 inches. How many temperature points per pile, or volume, or feet along the pile, or other method?
Provide an estimate for the site capacity throughput amount per year, based on the incoming un-
composted volume, including both the nitrogenous and carbon volume. The site capacity is determined
from the amounts received, but may be limited by the duration of the process, and the size of the
facility.
Provide a process flow diagram of the entire operation, including the type, size, and location of all major
equipment, and feedstock flow streams. Provide a list and description of the equipment to be used.
Describe the design and operation of aeration, and how it is monitored.
The design and operating plans in general — many of the words "should be" should be changed to "will
be." For example, the temperature of the piles will be measured daily during the required 14 day
temperature rule requirement; and incoming animal waste will be mixed with carbon within 24 hours
(12 hours/4 hours?) of arrival at the site.
For static aerated floor composting, PFRP requires maintaining 3 consecutive days of at least 131
degrees F. VAR requires an average of 113 degrees F or higher for 14 consecutive days, with a minimum
temperature of 104 degrees during this time. The two temperature requirements can be combined or

overlap. The following are 2 possible ways, but there are other ways: (1) 14 consecutive days at
minimum 131 degrees F, or (2) 3 consecutive days at minimum 131 degrees F, followed by 11
consecutive days at minimum 113 degrees F. Describe or address this in text.
k. Please clarify that the outdoor tractor shed area is not used for any waste handling.
I. Describe normal operating hours and days of operation. It can be stated that this could vary.
m. Describe compliance with the personnel training requirements described in Rule .1406 (19). Operators
of new sites are required to meet the rule within 18 months of permit issuance.
n. 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.
o. Describe site safety procedures concerning onsite equipment (especially grinders).
Odor control plan:
This section should address the items listed in the application guidance, Section 5.
b. List actions to be taken in the event of odor complaints. For example, storage time of animal waste,
prior to mixing with carbon, would be minimized, and placing a layer of finished compost over newly
formed piles, as needed.
4. Appendix D — the testing requirement provided is not the most current rules. A copy of the rules are attached.
5. Drawings and text — Show the location of the grinder, is it one grinder or two (pre-processor)? Is the grinder in
the pre-processor bin, and the compost mixture being conveyed out in the Dump Bin? I believe the Raw
Material Storage area should be changed to curing and/or finished compost.
Please provide an electronic copy (pdf) of the revised application, including drawings, and a cover letter that includes
responses to comments. Revisions to the application should be incorporated into the application text and drawings.
If you have any questions, do not hesitate to let me know.
Thanks, Donna
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Donna J_ Wilson
Ena ineering Project Vffmager, Solid Paste Section
Division ofK'aste _'Management
North Carolina Department of Environmental Quality.
919.707.8255 (Office)
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Physical Address: 217 West Jones Street, Raleigh NC 27603
Mailing address: 1646 Mail Service Center, Raleigh SIC 27699
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