0406_McGillAnson_Comments&Responses_20230901

From: Brokaw, Matt <[e-mail]>
Sent: Thursday, September 28, 2023 3:41 PM
To: Wilson, Donna J; Katherine Sullivan
Cc: Stanley, Sherri; Bradford, Teresa
Subject: [External] RE: McGill Anson Compost, preliminary application comments
Attachments: McGill Response to Comments_ 9-28-23.docx; Pages from Groundwater_SW_F_0403-MSWLF-2000_
2011_ Hest Environmental.pdf, Fig 2-1_ USGS Topo Map_Polkton.pdf; Fig 2-2_ USGS Topo
Map_Russellville.pdf
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Hello Donna,
Apologies on the delay in responses. Please see our initial response below (and attached) to your preliminary
comments. Note that any changes to the permit application itself will be incorporated and re -submitted once your
review is complete, to minimize versions. If that is not acceptable please do not hesitate to let us know and we will
adjust accordingly.
Thank you
Matt Brokaw, PE
SCS Engineers
Raleigh, North Carolina
919.604.4342 (C)
[e-mail]
From: Wilson, Donna J <[e-mail]>
Sent: Friday, September 1, 2023 3:41 PM
To: Brokaw, Matt <[e-mail]>; Katherine Sullivan <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; Bradford, Teresa <[e-mail]>
Subject: McGill Anson Compost, preliminary application comments
This email originated from outside of SCS Engineers. Do not click links or open attachments unless you recognize the sender and
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Hello Kate and Matt,
I'm sorry I missed the call this morning. I'm reviewing the McGill Anson Compost application and I have some
preliminary comments:
For the wood waste feedstock, confirm that the lumber and pallets would be clean, not painted or contaminated
(spills, wood preservatives, fire retardants, etc.).

Response: All lumber and pallets used for bulking agents will be clean, unpainted, not contaminated, and stockpiled
separately. This will be maintained through the screening and inspection process of incoming materials, as described in
Sections 3.1 and 4 of the application.
2. Section 3.4 — I believe the wood waste piles would be more than one pile, 30 feet high and 50 feet wide, as
shown on a drawing. If yes, change text to say piles sizes no larger than 30 x 50. If larger pile sizes are planned
(100 feet wide), address how the pile will be managed to prevent excess heat generation, and how it would
allow reasonable access to firefighting vehicles.
Response: That is correct, there will be at least two wood waste stockpiles, each no more than 50' wide x 30' tall (length
of stockpiles to be no more than 100'), as depicted on the site plan drawing. The text in Section 3.4 is being updated to
more accurately describe this. A minimum distance of 25' will be maintained around the edge of all stockpiles for
firefighting access.
3. For the VAR and PFRP description, include the number of days and temperatures to be met for each.
Response: Per NCAC 13B .1406 regulations, Process to Further Reduce Pathogens (PFRP) will be met by maintaining
temperatures above 131 degrees F for at least 3 days. This is achieved during the primary composting process (typically
7 to 8 days). Vector Attraction Reduction (VAR) will be met by maintaining temperatures above 104 degrees F for at
least 14 days. This is achieved during the curing process (typically 15 days). Section 4.3 of the application is being
corrected to specifically state this. This is also demonstrated in Appendix E of the application, with typical Temperature
Report sample from similar facility.
4. Financial assurance cost estimate — the disposal cost should be to another compost site that can take it, or to a
landfill, and should not be to a facility owned by the permittee.
Response: McGill would like to note that the entity that owns the Merry Oaks compost facility will not be the same entity
that owns the proposed Anson facility. Please see attached McGill Comment Response document for further response.
A better topographic map (portion of a map) is needed to show features such as topo contours, blue line
streams, likely wetlands, etc. One website is ngmdb.usgs.gov. Go to TopoView, then Get Maps, then search for
location. Use the most up-to-date map, unless an earlier version has more detail.
Response: Please see attached Figure 2-1 and 2-2. This will replace Figure 2 in the application.
6. Final product storage — Provide source info for the depth to SHWT, minimum 12 inches.
Response: Final product storage will be graded to a uniform pad at approximately EL. 314 to 310'. The east corner of the
building will be approximately EL. 314 , with the Storage Area graded to drain to the northeast down to EL. 310'. The
adjacent Anon County Landfill has several monitoring wells along the perimeter of the site, the closest being MW-
2S. Based on the attached Potentiometric Surface Map from 2011, SHWT at the edge of the property is approximately
EL. 304' (or approx. 10' bgs). By approximation, there will be at least 6' of separation between the proposed final
storage pad and SHWT. Furthermore, site investigation and survey show the intermittent streams passing through the
proposed McGill site reveal a water table no higher than EL. 270-290'. Therefore, using the Anson County landfill
groundwater elevation of 304. is likely a more conservative value.
Drawings —
a. Show plan and profile of the building. Will it be all enclosed, or will there be partially open walls or
roof? Response: Please see attached McGill Comment document.
b. Show plan and profile of a bay. What is the distance between aerated pipes? Response: Please see
attached McGill Comment document.
c. Provide detail of where the wall and floor meet, to show that liquids cannot flow out of the blending
area or building. Response: Please see attached McGill Comment document.

On Drawing 2, for the Clay Base with Binder ground cover, is that for the entire area inside of the
stormwater diversion ditches? Will everything in the area be drivable, around/between the storage
piles, biofilter, etc.?
Response: Per the legend on the site plan drawing, everything hatched with the clay base with binder will be driveable.
This includes the area within the stormwater diversion ditches, around/between the storage piles, and biofilter.
A complete technical review will be forthcoming.
If you have any questions, let me know.
Thanks, Donna
Donna J. Wilson
Engineering Project Manager
Solid Waste Section - Division of Waste Management
North Carolina Department of Environmental Quality
Office: [phone]
Email - [e-mail]
Websites - - - Solid Waste Section - - - Composting
Jane,? correspondence fo and from INs address is subject io [ire f ilh
Cararma Pub4c Rec+oxos taw and may be discfosed to Mrrd parries.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

4. Financial assurance cost estimate —the disposal cost should be to another compost site that can
take it, or to a landfill, and should not be to a facility owned by the permittee.
We have reached out to multiple entities and are awaiting quotes. The Merry Oaks Composting
Facility initially referenced is owned and operated by a different entity than the proposed Anson
facility. McGill Environmental Systems of NC, Inc. owns McGill Merry Oaks and McGill
Environmental Facilities, LLC will own and operate the McGill Anson Composting Facility. We
respectfully request that the department considers allowing the Merry Oaks Composting Facility
as a suitable option for the financial assurance cost estimate.
7. Drawings —
a. Show plan and profile of the building. Will it be all enclosed, or will there be partially
open walls or roof?
Please see attached artist rendering of the proposed facility. All off-loading and
processing areas will be enclosed. Final screening will be covered will have either partial
walls or block walls on three sides. For items 7a — 7c, please note that McGill is still
working to finalize construction documents for the facility.
b. Show plan and profile of a bay. What is the distance between aerated pipes?
Please see attached photo of a bay. McGill's technology is patented and does not wish
to publicly disclose the distance between aerated pipes. If there is a way to keep that
information confidential, then McGill will disclose.
c. Provide detail of where the wall and floor meet, to show that liquids cannot flow out of
the blending area or building.
Please see attached photos of McGill Fairless Hills LLC, a facility that is currently under
construction in Pennsylvania. McGill's Anson facility will be extremely similar in nature, with a
few layout modifications that are being finalized.

RE: [External] RE: McGill Anson Compost, preliminary application comments
Wilson, Donna J <[e-mail]>
Wed 11/1/2023 7:15 PM
To:Brokaw, Matt <[e-mail]>
Cc:Katherine Sullivan <[e-mail]>;Stanley, Sherri <[e-mail]>
0 1 attachments (522 KB)
example topo usgs map for applic.pdf,
Hello Matt and Kate,
I've completed review of the Anson McGill compost facility application. Please address the questions and
comments below:
1. The size and boundary of the compost operations area should be clarified, on the map and in the text. The
drawing currently identifies the operations area as the area inside the property line setback, but the
compost/waste management area should be included within the ditches and surface water/sediment
control areas. The operations area is the total area used for mixing, grinding, processing, composting,
curing, and wood waste and feedstock unloading and storage. It can be one continuous area for simplicity,
but it could be separate identified areas. The compost operations area is the area used for compost or
waste management, and does not have to include roads, stormwater ditches or basins, the biofilter,
buffers, or finished product storage. It may look something like below. The storage area on the east side
should be labeled. If it is just finished product, it would not need to be included in the compost operations
area, but it could be.

5. Clarify whether there will be any amendments added to the finished compost for sale or distribution, such
as wood ash (but not clean soil). If yes, address storage of the amendment and testing as described in the
guidance.
6. Section 3.4 — For the wheel loaders used to transport and mix waste, how will bacteria cross -contamination
be prevented?
7. Please provide an update for the stormwater & sediment and erosion control permits.
8. From the previous response to comments,
a. Include the drawings and details of the building design in the revised application.
b. For the distance between aeration pipes in the bay, please provide a distance that it is no larger
than, for example 2 or 3 feet?
c. Address in a drawing or in the text, how the wall and floor design prevents liquids from flowing out
of the building.
d. Section 3.4 is to be updated about the pile size width for the wood waste stockpiles. Text is to be
added to Section 1.3 about the PFRP and VAR requirements.
e. Include information regarding the depth to SHWT.
For the compliance history review, a complete review was completed in 2020. As an update, please
provide the current organizational chart. Provide explanatory text that identifies all business entities that
are direct or indirect parents, subsidiaries or other affiliates of Applicant and depicts the relationships
among all entities shown on each chart; as well as any partnerships and joint ventures in which any of the
entities are engaged or which have a financial interest in any of the entities. For all business entities
identified in the organizational charts, please identify those business entities which operated under a
previous business name and identify the prior business name. Also — clarify if there have been any
compliance concerns in the last three years with any US facility.
Responses to comments should be incorporated into the text of the application.
If you have any questions or comments, or would like to discuss, please let me know.
Thanks, Donna
Donna J. Wilson
Engineering Project Manager
Solid Waste Section - Division of Waste Management
North Carolina Department of Environmental Quality
Office - Raleigh: [phone]
Email - [e-mail]
Websites - - - Solid Waste Section - - - Composting
Dope 1m 1 W Eno.nmawal Dual
Email correspondence to and from this address is subject to the North
Carolina Public Records taw and may be disclosed to third parties.
From: Brokaw, Matt <[e-mail]>
Sent: Wednesday, October 25, 2023 2:41 PM

Environmental Consultants & Contractors
November 21, 2023
File No. 02222205.00
Ms. Donna Wilson
Engineering Project Manager
North Carolina Department of Environmental Quality
Solid Waste Section - Division of Waste Management
217 West Jones Street
Raleigh, North Carolina 27603
Subject: McGill Environmental Facilities, LLC
Anson Composting Facility
New Permit Application
Response to Comments dated November 1, 2023
Dear Ms. Wilson:
On behalf of McGill Environmental Facilities, LLC (McGill), SCS Engineers, PC (SCS) is pleased to
submit responses to comments for the McGill Anson Composting Facility, New Permit Application.
Technical review comments were received via email dated November 1, 2023. Review comments,
and responses, are provided as follows:
1. Comment: 1. The size and boundary of the compost operations area should be clarified, on
the map and in the text. The drawing currently identifies the operations area as the area
inside the property line setback, but the compost/waste management area should be
included within the ditches and surface water/sediment control areas. The operations area
is the total area used for mixing, grinding, processing, composting, curing, and wood waste
and feedstock unloading and storage. It can be one continuous area for simplicity, but it
could be separate identified areas. The compost operations area is the area used for
compost or waste management, and does not have to include roads, stormwater ditches or
basins, the biofilter, buffers, or finished product storage. It may look something like below.
The storage area on the east side should be labeled. If it is just finished product, it would
not need to be included in the compost operations area, but it could be.
Response: The compost operations area has been amended in the Revised Permit
Application. See revised Proposed Site Plan in Appendix B. The updated compost operations
area is 11.0 acres.
2. Comment: 2. The compost operations area is subject to the siting and location criteria, and
this looks to be OK. However, the distance to ditches applies to the outside storage areas.
Response: Compost operations area complies with all siting and location requirements,
including the 25'-minimum setback from ditches/swales as shown in the updated Proposed
Site Plan in Appendix B of the Permit Application.
3801 Lake Boone Trail, Ste. 410, Raleigh, NC 27607 1 919-662-3015

Ms. Donna Wilson
November 21, 2023
Page 2
3. Comment: 3. The drawings should include existing and proposed contours. For example,
the ditches shown in the areas of the wood material feedstock storage.
Response: Existing grades are shown in Drawings 1 & 2 of Appendix B. Proposed grading
has been added to the Revised Permit Application with Drawing 3 - Proposed Grading Plan
now included in Appendix B.
4. Comment: 4. The topo map in the application should show details such as contours, blue
line streams, approximate wetland areas, etc., at a scale where the features are readable.
For this site, portions of the two topo maps should be pieced together to provide a view of
the site and at least the surrounding 1/2-mile area. The property boundary and the compost
area boundary lines should be drawn on the map (not shaded). Below is a reduced size
example, using the 2022 versions from ngmdb.usgs.gov, it should be larger in the
application.
Response: The USGS Topo map figure has been revised as requested and is provided in the
Revised Permit Application in Appendix A - Figures.
5. Comment: 5. Clarify whether there will be any amendments added to the finished compost
for sale or distribution, such as wood ash (but not clean soil). If yes, address storage of the
amendment and testing as described in the guidance.
Response: Depending on the need for finished product and availability of acceptable
materials, some `amendments' may be added to the finished compost. This may include leaf
compost, topsoil, sand, biochar, and wood ash. If any amendments are being utilized they will
be stockpiled, in relatively small amount, neatly on -site in the amendment storage area
(within the footprint of the woody waste stockpiles shown on site plan), near the final screen,
or in the finished product storage area - all within the compost operations limits.
Further description of finished product amendments, means of storage, and testing methods
has been added to Section 3.3 of the Revised Permit Application.
6. Comment: 6. Section 3.4 - For the wheel loaders used to transport and mix waste, how
will bacteria cross -contamination be prevented?
Response: Loaders will be designated for use in either processing or finished product
handling to eliminate contamination. In the event a loader used for processing needs to be
utilized for finished product handling, the loader will be cleaned in accordance with SOPs. In
addition, loaders are washed down at the end of each shift.
7. Comment: 7. Please provide an update for the stormwater & sediment and erosion control
permits.
Response: Update on State Stormwater and Erosion & Sediment Control (E&SC) permitting
remains the same as described in Section 7 of the Permit Application. McGill will seek
approval for an Erosion & Sediment Control Permit from DEMLR prior to any construction
activities. A draft of the E&SC is in progress, however that will not be finalized and submitted

Ms. Donna Wilson
November 21, 2023
Page 3
until plans and design are `construction -ready', which McGill does not intend to complete
until at least a draft Solid Waste Permit for the compost facility is issued.
Per the discussions with the Stormwater Department, applications for coverage under
NCG24 (General Industrial Stormwater Permit for composting facilities), which McGill intends
to apply for, will not be reviewed/approved until the project is ready for construction either.
8. Comment: 8. From the previous response to comments,
a. Include the drawings and details of the building design in the revised application.
Response: Typical Building Design Drawings are provided in Attachment 1, labeled
`CONFIDENTIAL', and will be equivalent to the Anson facility. McGill requests that these
drawings be accepted as a separate document from the Permit Application as they
contain proprietary information.
b. For the distance between aeration pipes in the bay, please provide a distance that it is
no larger than, for example 2 or 3 feet?
Response: Distance between aeration pipes in the bay will be no larger than 5 feet.
c. Address in a drawing or in the text, how the wall and floor design prevents liquids from
flowing out of the building.
Response: The building is constructed of concrete and steel. The concrete floor meets
concrete walls to enclose the facility. The processing bays are all sloped away from the
external walls so that any liquid material will flow into the concrete aisle, where it will be
managed by an operator. No liquid will flow out of the building.
Below is a photo of a McGill facility currently being constructed in Pennsylvania. The
interior ground will all be concrete once finished. See also Building Drawings as
previously noted in Attachment 1.

Ms. Donna Wilson
November 21, 2023
Page 4
d. Section 3.4 is to be updated about the pile size width for the wood waste
stockpiles. Text is to be added to Section 1.3 about the PFRP and VAR requirements.
Response: Section 3.4 has been revised to clarify the woody waste/amendment
stockpiles. Section 4.3 (not 1.3) has been revised to update and clarify the PFRP and
VAR procedures, and ensure minimum requirements are met. Please see Revised Permit
Application for updates.
e. Include information regarding the depth to SHWT.
Response: Information regarding seasonal high water table (SHWT) has been added to
the end of Section 2.3 of the Revised Permit Application.
9. Comment: 9. For the compliance history review, a complete review was completed in
2020. As an update, please provide the current organizational chart. Provide explanatory
text that identifies all business entities that are direct or indirect parents, subsidiaries or
other affiliates of Applicant and depicts the relationships among all entities shown on each
chart, as well as any partnerships and joint ventures in which any of the entities are engaged
or which have a financial interest in any of the entities. For all business entities identified in
the organizational charts, please identify those business entities which operated under a
previous business name and identify the prior business name. Also - clarify if there have
been any compliance concerns in the last three years with any US facility.
Response: Please find attached, HIGHLY CONFIDENTIAL, Attachment 2 Business
Organizational Chart. This attachment provides a current business org chart that identifies
all of the entities that are parents, subsidiaries, or other affiliates of the Applicant (McGill
Environmental Facilities, LLC). The chart shows the relationship structure as well as the type
of each entity by Tax Classification.
The only compliance concern of note in the last three years (at any US facility under any of
the affiliates listed in the chart) is an NOV received at RER Supply, LLC on October 13th,
2023. The NOV was regarding the storage of grass at the Riverdale, NJ location. McGill
disputed the NOV and has been working towards a resolution. It is our understanding that
the NOV is a result of grass clippings being stored on -site that was not contained in the grass
building or containers at the time.
Please do not hesitate to contact me at [phone] if you have any questions.
Sincerely,
Matt Brokaw, PE
Senior Project Professional
SCS Engineers, PC
46__�
Carlisle Carroll, El
Staff Professional
SCS Engineers, PC

From: Brokaw, Matt <[e-mail]>
Sent: Friday, December 15, 2023 10:55 AM
To: Wilson, Donna J
Cc: Katherine Sullivan; Stanley, Sherri
Subject: [External] RE: McGill Anson Compost, REVISED Permit application, comments
Attachments: McGill Anson_ New Compost Facility Permit Application_ REVISED 2_ Dec23_ sealed.pdf
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Hi Donna,
Please find attached revised New Permit Application for the McGill Anson compost site, SCS Engineers is
submitting on behalf of McGill Environmental Facilities, LLC. The requested items have now been added to the
application itself, along with Response to Comments. Please also see below, outlining the changes made.
Per the voicemail I left, we would also like to request any more information on the draft permit timeframe you
might be able to provide, for planning purposes.
Thank you,
Matt Brokaw, PE
Sr. Project Professional
SCS Engineers
3801 Lake Boone Trail, Suite 410
Raleigh, NC 27607
919.604.4342 (C)
[e-mail]
Driven by Client Success
www.scsengineers.com
From: Wilson, Donna J <[e-mail]>
Sent: Friday, December 8, 2023 4:14 PM
To: Brokaw, Matt <[e-mail]>
Cc: Katherine Sullivan <[e-mail]>; Stanley, Sherri <[e-mail]>
Subject: RE: [External] RE: McGill Anson Compost, Permit application comments
This email originated from outside of SCS Engineers. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Hello Matt,

I've reviewed the last application revision and have a few comments below:
1. The following previous responses to comments are OK (emails 9-28-23 and 11-22-23), but need to be
incorporated into the text of the application:
a. Methods to prevent bacteria cross contamination with equipment. 11-22-23. Added to end of
Section 4.1
b. The building rendering drawings and bay photos and info, 9-28-23. Either added to the text
section or included and referenced in an appendix. It is OK to say the offloading area will be
either roofed or enclosed (or describe other). Finished product area is OK. Added to Appendix
B
c. The text description of how the wall and floor design prevents liquids from flowing out of the
building, 11-22-23. Added to beginning of Section 3.2
d. Distance between pipes in the bays is less than 5 feet. 11-22-23. Added to Section 3.2 under
Primary Processing & Curing Bays description
2. The VAR description in Section 4.1 should be temperatures above 104 degrees for at least 14 days, with
an average temperature of at least 113 degrees. Revised VAR description on page 18 (new pg. 19)
3. Page 19 — For thermometer calibration, I believe it is meant to say ice water. Revised on page 19 under
Monitoring/Recordkeeping (new pg. 20)
Responses to comments should be incorporated into the text of the application. Added Response to Comments
document as Appendix G
We are close to finishing and I will be working on the draft permit.
If you have any questions or comments, or would like to discuss, please let me know.
Thanks, Donna
Donna J. Wilson
Engineering Project Manager
Solid Waste Section - Division of Waste Management
North Carolina Department of Environmental Quality
Office - Raleigh: [phone]
Email - [e-mail]
Websites - - - Solid Waste Section - - - Composting
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From: Brokaw, Matt <[e-mail]>
Sent: Wednesday, November 22, 2023 9:56 AM
To: Wilson, Donna J <[e-mail]>
Cc: Katherine Sullivan <[e-mail]>; Stanley, Sherri <[e-mail]>
Subject: [External] RE: McGill Anson Compost, Permit application comments