2910_DavidsonComposting_20170920_ApplicationReviewLetter_DIN28492

State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary

MICHAEL SCOTT
Director
September 20, 2017

M. Scott Keller
AES, LLC
PO Box 130
Sanford, NC 27331

Re: Davidson Composting Facility
Cunningham Road
Thomasville, NC 27360
Large Type 4 Facility

Dear Mr. Keller;

On May 5, 2017, the Division of Waste Management, Solid Waste Section (Section) received
AES, LLC permit application entitled;

Proposed Composting Facility, Davidson Mine II, Cunningham Road, Davidson County, NC
prepared by Engineering & Environmental Sciences Company.

The Section has performed an interim review of the application for a determination of
completeness and determined the application is incomplete. The application referenced above
lacks the information required in North Carolina Administrative Code (NCAC) 15A NCAC 13B
.1405 (b) (1) (A). Per the provided deed the land owner is listed as Cunningham Brick Company.
Additional, the permit references “two parcels” of land totaling 128 acres yet only one page of
one deed was provided. A land owner authorization form must be signed and notarized.

Per NCAC 15A NCAC 13B .1405 (b) (2), A letter from the unit of government having zoning
jurisdiction over the site is required.

Details on of the permeability of pads are inconsistent. Page 4 indicates “the shale will also be
used as a protective layer for the soil liner.” Page 5 of the Management Plan indicates a “six inch
protective soil layer will be placed over the liner. The Typical Compost Pad Cross-Section on
Compost Pad Details Sheet No. 3 3 indicates a 2’ impervious Soil Layer, while the Typical
Linear Cross-Section indicates a 0.5’ Clay Shale Protective Layer. To ensure the permeability of
pad, the pad will need to be constructed similar to a landfill liner pad, and should follow
construction and testing rules referenced in the landfill rules. The application should provide a
description of the construction details, testing and construction quality assurance. Refer to 15A
NCAC 13B .1624 (b) (8) for permeability pad construction.

Permeability pads are required in areas consisting of the unloading area, feedstock storage area,
composting area, curing area, areas that will receive runoff from those areas, and the
stormwater/wastewater pond. The area includes ditches or pathways that lead to the
M. Scott Keller
September 20, 2017
Page 2 of 3

stormwater/wastewater pond. A description of the method to control, collect, treat and dispose of
leachate generated is required.

Compost pad details sheet 3 indicated monitoring wells yet a sampling and analysis plan was not
included in the application. For a Type 4 facility that utilizes a constructed soil pad, the Section
will require a water quality monitoring plan to ensure surface water and groundwater protection.
A water quality monitoring plan, including site characterization, should be submitted. An
example water quality monitoring plan can be download from the below location.

http://edocs.deq.nc.gov/WasteManagement/0/edoc/96511/SW_F_2514-Compost_03-26-
2014_SP_AC%20(2).pdf?searchid=248870c1-9650-4b21-bc8b-b86902674dcf

A stormwater permit may be necessary under the National Pollutant Discharge Elimination
System (NPDES). Note composting operations classified as Type 4 are “excluded from coverage
under” General Permit No. NCG240000. Page 4 of the Proposed Composting Facility indicated
“(a) stormwater permit will also be obtained for the composting activities.” A detailed
description of the methods to prevent surface water run-on and run-off the management of and
collection, storage and disposal of process water is necessary.

A description of the active mine operations will be necessary, including how the active mine may
affect the compost operations.

The flow diagram contains insufficient detail. The process flow diagram needs to include each
step of the operation including but not limited to the quantity of material anticipated, process
duration and equipment used for each step.

A detail description of how the temperature control and monitoring equipment is necessary.

“Oakboro soils…have a seasonally high groundwater table of 1 to 2 feet and frequently floods.”
Does the facility potentially contain wetlands? Has a wetland determination been completed for
the facility?

A detail on final usage of the material is required. The flow diagram indicated that the final
material will be disposed of onsite, while the Proposed Petroleum Contaminated Soil
Composting Facility indicated the material would be sold.

A compliance history review is required. NCDEQ will be contacting you requesting the
compliance history information. These comments address several of the major issues, however a
complete and detail review has not been completed. A full and detailed review will be performed
upon receipt of a complete application package. Refer to the Compost Facility Permit
Application Guidance, located at the below location, for the items necessary for a complete
application.

https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Guidance/Compost%20application
%20guidance%20%2010-12-16.pdf

M. Scott Keller
September 20, 2017
Page 3 of 3

For your reference, included below are examples of approved application permits for composting
facilities.

http://edocs.deq.nc.gov/WasteManagement/0/edoc/83787/SW_F_2514-COMPOST-2014_03-23-
2012_SP_AO.pdf?searchid=a7a9d593-229c-40e1-bff3-f6e131e6fb87

http://edocs.deq.nc.gov/WasteManagement/0/edoc/274945/3303_EasternCompost_ApprvdAppli
c_DIN26652_20100304.pdf?searchid=47895220-f133-4984-92d9-d2e5f96d2774

If you should have any question regarding this matter you may contact me at [phone] or
by email at [e-mail].

Sincerely,

Ethan J. Caldwell, P.E., P.G,
Permitting Engineer

cc:
T. Patrick Shillington, P.E., Engineering & Environmental Science Co., Inc
Ed Mussler, P.E, NCDEQ DWM Permitting Branch Supervisor
Donna Wilson, NCDEQ DWM