5800_DirtcraftCompost_Comments_20240628

From: Wilson, Donna J
Sent: Friday, June 28, 2024 9:54 AM
To: Wyatt Edsel
Cc: Dirtcraft Organics; Jorge Montezuma; Justice, Summer H; Stanley, Sherri
Subject: RE: [External] Re: Dirtcraft Compost application, Madison County
Hello,
I have two remaining comments for the application:
1. From the previous response to comments, the response information in comment 9f (how the
blower is sized for the facility) is OK and should be added to the application text.
2. The text about temperatures taken every 20 to 25 feet along the windrow, so at least 2 temperature
points should be taken per bay, with appropriate representative spacing, is for the aerated static
bays, not for the curing piles. What is the access method to reach the temperature points within
each of the piles in the ASP?
If you have any questions let me know.
Donna J. Wilson
Engineering Project Manager
Solid Waste Section - Division of Waste Management
North Carolina Department of Environmental Quality
Office - Raleigh: [phone]
Email - donna.wilson(@deq.nc.gov
Websites - - - Solid Waste Section - - - Composting
ee �e D_!Q::NOR 11I Ceti XX.INA
oeprsrbnem n} Emwffl al Dual
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Wyatt Edsel <[e-mail]>
Sent: Tuesday, June 25, 2024 11:04 AM
To: Wilson, Donna J <[e-mail]>
Cc: Dirtcraft Organics<[e-mail]>; Jorge Montezuma <[e-mail]>;
Justice, Summer H <[e-mail]>; Stanley, Sherri <[e-mail]>
Subject: [External] Re: Dirtcraft Compost application, Madison County
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.

Donna,
Responses to your comments are below in red. The revised operation and management plan is
attached. Please let me know if you need anything else.
Thankyou,
On Fri, Jun 21, 2024 at 4:35 PM Wilson, Donna J <donna.wilsonCa)deq.nc.gov> wrote:
Hello,
I've completed review of the revised application for the Dirtcraft Compost Facility, and I have the following
remaining comments:
1. From the previous response to comments, the response information in comments 8a and 9f are OK
and should be added to the application text. This has been added to the applicaiton text in pages
6-9.
2. Temperatures should be taken every 20 to 25 feet along the windrow, so at least 2 temperature
points should be taken per bay, with appropriate representative spacing. This text has been added
to page 7
3. Page 7—The sentence describing the continuous extended pile should be corrected. The reference
to continuous extended pile has been removed.
4. On the topo map, the location should be identified as shown below:
This site is labeled on the USGS topo map on page 23 as shown below

46 47 46
Please provide a pdf copy of the revised application, and a response to comments. Revisions to the
application should be incorporated into the text of the application.
I've started to prepare the draft permit. A compliance history questionnaire will be sent to you next week,
a standard part of the application process.
If you have any questions let me know.
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

e:! ee �e D_E Q
NUI?1111, W XX. INA ��
oepubeenl o, EmlmnTMIDI p DIA�
Email correspondence to and from this address is subject to the North
Carolina Public Records taw and may be disclosed to third parties.
From: Wyatt Edsel <[e-mail]>
Sent: Thursday, May 16, 2024 9:37 AM
To: Wilson, Donna J <[e-mail]>
Cc: Dirtcraft Organics<[e-mail]>; Jorge Montezuma <[e-mail]>
Subject: [External] Re: Dirtcraft Compost Review Comments
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report
Message button located on your Outlook menu bar on the Home tab.
Donna,
We have addressed all of your comments in the attached response to comments documents.
The requested additional information/documents as well as revised plans and O&M Plans are
attached for your review. Please let me know if you have questions or if you need additional
information.
Do you have an estimate of how long you will need to review and respond to our resubmission?
Thank you for your help.
Have a good day,
On Fri, Apr 12, 2024 at 3:04 PM Wilson, Donna J <donna.wilsonCa)deq.nc.gov> wrote:
Hello Adam and Wyatt,
Again, sorry for the delay in getting the complete review to you. I have many applications I am working
on.

I've completed review of the application and have the following questions and comments:
1. Show on a drawing the outline boundaries of the operations areas —areas used for
feedstock storage, unloading, grinding, mixing, composting, and curing. It may look
something like below:
2. Provide the sedimentation and erosion control approval, permit, or current status.
3. Provide the updated County Parcel number for this property, if known.
4. Draw an outline boundary of the site on wetlands map. It can be an approximate
rectangle shape.
5. Provide an update for the County zoning and special use permit.
6. The drawings indicate that a utility pole will be relocated. Provide more information for
this. Will it be moved prior to compost operation?
7. Page 9 — Provide location of the well that will be drilled onsite. There is a 100-foot
setback requirement between any well and the compost operation boundary.
8. Operation:
a. Provide slope and drainage information for the working pad on the east
side. Where does water and liquids run off from the large pad to surrounding
areas? Does this drainage enter the collection tank? Is there a barrier to prevent
Liquids flowing offsite to the north?

b. For the Receiving & Prep area, page 7, it should state that prior to unloading of
food waste, a layer of wood chips/woody material (6 —12 inches) will cover the
floor of the bay to provide immediate absorption of liquids being unloaded.
c. What methods will be used to prevent liquids from flowing out of the
unloading/mixing bay?
9. Active composting and time/temperature:
a. Pagel 1 —The ASP pile sizes in this section are not consistent with the text in other
sections, with 4 ASP piles, and a pile size of 40' wide and 55` long.
b. Clarify that there will be space between each ASP pile (not one continuous pile) so
that temperatures may be taken along the sides of each pile. What is the spacing
of temperature points along each pile? Provide depth that the temperatures will
be taken (normally 24 to 36 inches), varied in the pile.
c. Describe how the site will meet time and temperature for PFRP and VAR. PFRP for
aerated static piles has been discussed (3 days at 131 0), but meeting VAR has not
been addressed. VAR is 14 days at average 1130 degrees, with a minimum 1040
during that time. PFRP and VAR can overlap; for example, 3 days at minimum
1310, followed by 11 days at minimum 1130.
d. Describe monitoring of the piles to ensure the key process indicators are within
the acceptable range, for moisture and porosity (air pockets). What actions will
be taken if a pile is too dry or too wet?
e. Will air flow be adjustable for a particular pile based on it's age? The amount of
air needed for each pile will vary. Recommended reference-
https://www.biocycLe.net/aeration-fLoor-fundamentaLs.
f. How is the blower sized for this facility? Recommended reference -
https://www.biocycle.net/design-considerations-in-aerated-static-pile-
composting/
https://www.biocycle.net/pipe-and-blower-fan-fundamentals-in-asp-design/
10. Drawings:
a. Cover sheet —the location pin should be accurate to the compost site.
b. Drawing C-4 —Amore clear/less blurry aerial photo is needed as abase for the drawing.
c. Provide drawing illustrating the ASP piles on the 60 x 60 ASP pad.
d. Provide detail drawing of the pipe layout on the pad. Indicate spacing
between pipes, and pipe size. Show location of blowers.
e. Provide plan and profile drawings of the overall ASP pad area, including side
walls and overhead cover.

11. Please add page numbers.
Recommendation, not a comment - Compost overs mixed into new compost piles instead of placed
on top of new piles for odor filter. The overs will contain bacteria inoculant.
Please provide a pdf copy of the revised application, and a cover letter that includes response to
comments. The response to comments should also indicate where the revision is located in the
application. Revisions to the application should be incorporated into the text of the application.
If you have any questions let me know.
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
D_E Q2>
nxx3rri crmxirvn
oepunnem of Enwronmemai quenry
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
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.

Wyatt Edsel, PE
Principal Engineer
Edsel Engineering, PLLC
(C) 828-707-6120
Wyatt Edsel, PE
Principal Engineer
Edsel Engineering, PLLC
C 828-707-6120