1905_BrooksCompost_renewapplic_20190927

P.O. Box 129
Morrisville, NC 27560
919-467-1239
MACCONNELL
& ASSOCIATES, P.C.
A. R. Rubin, Professor Emeritus, NCSU-BAE and
President, A. R. Rubin and Associates
205 Stanton Gable Lane
Hillsborough, NC, 27278
Sherri Stanley
NCDEQ DWM
1646 Mail Service Center
Raleigh, NC, 27699
Dear Ms. Stanley;
Subject: Brooks Compost Facility renewal request
1101 Nowell Road
Suite 118
Raleigh, NC 27607
RECEIVED
SEP 2 f C019
SOLJ'D WASTE SECTION
27 September 2019
Fax [phone]
Mr. Gary Mac Connell and I are pleased to submit this renewal request for the compost operation serving clients throughout
the RTP area and providing an essential service to recycle biodegradable materials in this rapidly growing area on NC. The
Brooks Composters processing facility near Goldston, NC is an essential element of the recycling infrastructure. The initial
permit for the compost operation was approved in March 1025 and the renewal request is due by the end of September 2019.
This request for renewal is hereby submitted.
The compost operation remains as described in the initial application and as approved in the initial permit. Brooks Composters
has added a new screen and moved the old screen to an area on Brooks Property, but outside the permitted site footprint. The
management at Brooks would like to add an area within the permitted compost production area to utilize the aerated static
pile method for compost production.
The facility was initially permitted to accommodate 60,000 tons per year. At no time during this permit cycle has the volume
approached this limit, but forecasts suggest an increase in recyclable biodegradable waste will be available and consequently
the management at Brooks would like to increase the permitted volume to 115,000 tons/year. The compost quality has been
monitored as required and the quality has been excellent. The compost product has been used on a variety of commercial and
residential landscapes, valuable receiver crops and reclaimed area vegetation. The USDA has deemed the material an organic
amendment and the U. S. Compost council recognizes the product as a high quality compost
Please accept the request for the renewal attached. The initial project team consisting of Mac Connell and Associates and me
has reviewed this submittal. We believe the information to be accurate.
Thank you for your review of this material.
Respectfully Submitted:
A. R. Rubin
CC: Donna Wilson, NCDEQ DWM
Gary MacConnell, P.E.

it
SEAL
17069 *;Brooks Contractor Compost Facility
Permit Renewal
Section 1— General Information - Provide a narrative discussion, including the following:
The name of the facility: Brooks Composters
Street address and mailing address for the facility is:
1195 Beal Road, Goldston, NC
Facility type: The Brooks Composters facility is a large Type III facility. The facility was permitted
previously and this is a request for a permit renewal for Permit No.1905 COMPOST.
Developed by: Amy Brooks, Brooks Compost, and
Dr. A. R. Rubin, A. R. Rubin and Associates
General Information: Brooks Contractor Compost, Large Type 3 Compost Facility
Owners: Brooks Family
Location: Goldston, NC
Permit Number: 19 05-COMPOST
Primary Contact - APPLICANT AND LAND OWNER: Amy Brooks
Office: 919 837 5914
Cell: 919 842 6063
E-Mail: [e-mail]
Background:

The Brooks Compost Facility is located in Chatham County, North Carolina, at 1193 Beal Road,
approximately 3 miles south of Goldston, NC. This facility is currently permitted by NCDENR-DWM as a
Large Type 3 composting operation. The operation has been very successful in diverting a variety of
materials to beneficial use and this material is submitted as supporting documentation for the permit
renewal. In addition to the renewal, the management at the Brooks Contractor compost operation
wishes to increase the volume of material composted to 110 tons per day from the currently allowed
90,000 tons/day as detailed in Section 3, items 1 and 2 that follows and to add an area for static pile
composting.
Site visits conducted previously by representatives from DEMLR indicate that there is no stormwater
discharged from the property and a separate stormwater permit is not required. The DEMLR staff
determined that stormwater is wholly contained on the site.
Section 2 — Siting Requirements:
The site is currently permitted as a compost facility through NCDWM. A site plan, parcel map and parcel
ID, and vicinity map were provided during the initial permitting process and are available in the DWM
file. The site is located at 1195 Beal Road in Goldston, NC. The NRCS Soil Map shows the compost
operation on the site is located on soil material mapped as the Badin series with shallow water table at
depths over 80 inches.
The total acreage on the site is approximately 100 acres. The portion of the site utilized for active
composting and curing cover 70 acres. This area is well suited to accommodate the additional feedstock
volume requested.
A legal description of the property and the deed as required in section 2(3) were permitted with the
initial application. .
The USGS topographic map of the area as required in section 2(4) was provided in the initial application.
A zoning letter from the Chatham County planning and zoning office was provided previously with the
initial application.
A FEMA map of the area was provided previously with the initial application.
Site assessments conducted previously indicate that there are no jurisdictional wetlands present on the
site. The Soil Survey of Chatham County documents the soil resources on the actual area hosting the
compost operation are not considered hydric soils.
NCDWM establishes buffer requirements associated with compost operations. The site map provided
with the initial application for the permit showed the setback distances are appropriate for the
continued operation of the Brooks Composter compost facility.
The site is NOT located on a closed -out solid waste disposal facility.
The Modern Soil Survey of Chatham County demonstrates the soil material and associated texture on
the site is predominantly Badin soil. In addition, site evaluations conducted previously indicate the soil
texture is finer than loamy sand and the ongoing solid waste compost operation has compacted soil to
render the site permeability very slow. This protects the quality of the underlying groundwater and any

render the site permeability very slow. This protects the quality of the underlying groundwater and any
stormwater generated is diverted to a portion of the site where it infiltrates or is utilized beneficially as
moisture required in the composting operation.
Section 3 — Design Plan: Major elements of the initial design plan remain unchanged. Items
that have changed are addressed below; items that remain unchanged are designated "NA"
(1 and 2) The raw feedstock materials for the composting operation will come from permitted sources.
These include the following materials deemed suitable by the site owner/operator
Grease trap wastes, DAF Skimmings (to include offal) and material from permitted waste
sources such as scrapped manure or litter from local animal operations — collected by licensed
pumpers and dewatered on site prior to mixing and blending with other feedstocks. The
estimated volume is 200,000 GPD or 25 dry tons/day
Sawdust from a local forest products facilities the estimated volume is variable, but estimated as
10 tons/day
Vegetative waste — collected from local municipalities and food service operations in the RT
area. The estimated volume peaks in the fall at 100 Tons wet weight (20 dry tons)/day.
• Agribusiness residues or vegetative agricultural wastes and by-products (such as waste cotton
fiber or gin trash, corn Stover, straw or wet hay, egg processing waste) estimated at 10 tons/day
on a wet weight basis.
• Land clearing debris estimated as 10 wet tons/day or 5 dry tons/day
• Shavings and animal waste from any local livestock trailer wash {DAF skimming) — collected by
licensed pumpers and haulers estimated as 10 tons/day
• Pre and postconsumer food wastes from source controlled operations estimated at 40 wet
tons/day or 20 dry tons
• Untreated, unpainted new construction wallboard or gypsum board estimated as 5 tons/day
(3) TOTAL ESTIMATED: 110 to 115 dry tons/day
The site owner/operator will not accept the following materials:
Municipal sludge or listed hazardous waste
* New Feedstock:
Materials composted must be addressed in the DWM permit and at present the approved feedstocks
are contained in the existing permit; new feedstocks have been and will continue to be tested and
approved by consultants or DWM prior to receipt at the Brooks Composter Compost facility. Procedures
for accepting new feedstock materials include an NCDA Waste Analysis (or equivalent).
(4) Recipes: the recipes utilized consist of proprietary mixes of the feedstocks. The materials are mixed
and blended by volume on the site based on history of successful compost operations. Typical mixes
contain dewatered FOG as the major nitrogen and carbon source and containing constituents and

specific volumes of pre and post consumer food waste, and solid, bulking materials as needed to
prevent excessive moisture from accumulating in the windrow area.
(5) Materials are mixed and blended based on proprietary recipes generated by Brooks Composters. The
dewatering produces the high carbon/high nitrogen primary feedstocks as the primary feedstock. Wood
waste, vegetative waste, and wallboard is shredded if required either on -site or at the source and added
as supplemental feedstock as required or desired by the site operator.
(6) Process Flow: the process flow has remained as initially permitted.
(7) Process duration: the process duration remains as initially permitted. The curing and storage stage
may extend for up to a total of 6 to 9 months depending upon demand.
(9) Compost method: The method of composting utilized at Brooks Composter is the windrow method.
Windrow temperatures are monitored and turned the required 5 times where temperatures are in
excess of 131 degrees F.
Brooks Composters request addition of an aerated static pile as an additional method for compost
production. The area proposed is contained within the windrow area and the addition of the aerated
static pile compost process will assist Brooks Composters accommodate existing and proposed
feedstock. Brooks staff is working cooperatively with this project team and Mr. Bruce Fulford, NCDEQ
DPP on these aerated windrows.
(10) Surface water management is achieved by diversion of excess surface water into a retention pond
from which water is removed as required to support the compost process.
(11) Excess process water is collected in the basin on the site and mixed and blended with water for
supplying moisture to compost facility. The time -temperature requirements are imposed if any process
water is mixed or blended into existing compost operations. Water not use on the site may be
transported to the local wastewater treatment facility by tank truck for treatment.
(12) Amendments and feedstocks were addressed in the initial application and remain the same. The
most problematic feedstock continues to be egg waste and this material is incorporated into windrows
as received. Brooks Composters wishes to add DAF skimmings to the list of permitted feedstocks. These
materials have been composted at several facilities in NC.
(13a) The respective areas for the various mixing, active composting and curing processes remain as
initially permitted.
(13b) Controls for dust, odor, air emission include processing only when wind direction is appropriate to
protect local or adjacent residents, a windsock has been installed; adding moisture to control dust from
roads and un-vegetated areas on the site, and covering potentially odorous materials with finish
compost immediately after placement in the windrow.
(13c) Large chips and bulking materials are collected from the screen and recycled through the compost
windrows to inoculate newly created windrows with organisms populating the windrows.
Section 4 - Compost Operation Plan:

The composting operation will be conducted in open windrows specifically designed for compost
production; these windrows are located on compacted soil. Feedstock storage and final
composting/curing will occur on compacted pads. The windrows are fed from a concrete mixing pad and
compost is discharged following the windrow process to a second portion of the compacted pad for
curing and storage.
Composting Requirements and General Operations
Compost is defined by the U.S. Composting Council as "the product resulting from the controlled
biological decomposition of organic matter that has been sanitized through the generation of heat and
stabilized to the point that it is beneficial to plant growth." Composting is accomplished by mixing an
energy source (carbonaceous material) with a nutrient source (nitrogenous material, phosphorus
containing materials) in a prescribed manner to meet microbial requirements necessary to support
metabolic processes. Moisture levels, solids levels, and nutrient levels in the compost feedstocks are
controlled to assure the process reaches the required temperatures for the time prescribed by rule (15
days above 131 degrees F with 5 turnings in that 15 days or greater time). The process is carried out
under specific moisture and temperature conditions for a specified period of time. Certain steps and
procedures are necessary to ensure that the composting process proceeds properly with a minimum of
odors, adverse environmental impacts, and other process related problems.
(1) The facility will be divided into Six (6) distinct areas and these were identified in the initial permit
application.
Compost feedstocks continue to be mixed and blended on a mix pad and are then added to the
windrows by dump truck. Feedstock materials will be transported to the windrows and placed carefully
in windrows. Material placed in this manner heats adequately to assure PFRP and VAR compliance.
Windrow temperatures are monitored and recorded daily during PFRP. Windrow areas are designated
on the facility permit and all windrows are marked with date and dates of turning.
Materials have historically been discharged from the windrows after achieving the VAR and PFRP
compliance as determined through monitoring temperature and time. Demonstrated compliance has
been assured with temperatures exceeding 131 degrees F for 15 days or longer, with 5 turnings and
temperatures of 131 degrees F or higher for the 15 day period. These PFRP temperatures have
consistently been exceeded in the VAR area of windrow operations and a PFRP windrow is a "de facto"
VAR. Material is moved to curing after VAR and PFRP compliance.
As the aerated static piles enter into the operation, these will be monitored for time and temperature as
required in NCDWM Rule. The temperatures will be maintained above the required 131 degrees F for a
minimum of 5 days; this does exceed the rule requirements.
(2) Site Security: access to the site in only through a gate that is locked after business house. The site is
posted with signage designating the activity accomplished on the site.
(3) Operation: Responsible operators are on -site during operating hours. Several of the responsible
operators have been trained and have provided training through the NC Compost Council Operators
School.

A quality assurance/quality control program has been instituted at Brooks Composters. This process will
help to assure:
A. Compliance with appropriate rules and regulations
B. Product quality consistent with specified or designated end use
C. Trained personnel remain available to manufacture quality compost
The QA/QC effort will involve the compliance testing and monitoring including: routine temperature
monitoring and recording, nutrient and regulated metals testing, foreign material content and
bacteriologic sampling. Private certified laboratories have conducted the compliance testing for
regulated metals and bacteria as required. NCDA Sampling has been conducted every 90 days or 20,000,
whichever occurs first. Annual calibration has been accomplished on temperature probes. An annual
report has been submitted to DWM as required as a part of the QA/QC program and the DWM Permit..
As additional raw material streams become available for the composting operation, the materials have
been submitted for review and approval by the DWM- Solid Waste Section or to this consultant prior to
use as a feedstock. The following procedure is utilized to submit raw materials for approval to the Solid
Waste Section. A sample of the raw material will be taken according to the protocol detailed in Section
5.2 of the operations and maintenance manual. Samples are analyzed for the parameters listed in state
rule. A report of the analysis results and a written request for inclusion of the raw material, including
proposed handling instructions for the raw material, are submitted to the Solid Waste Section. Upon
notification of approval of the raw material by the Solid Waste Section, the raw material may be
incorporated into the process used for compost production. All incoming raw material are inspected
visually to assure unwanted trash is not present, that no material received is prohibited by permit, and
that the material received is authorized under the permit.
(4) Access roads: access roads into the site and exiting the site are well maintained, all weather roads.
Staff from Brooks maintain the roads in good condition.
(5) Operating hours: the facility is open daily except Sunday from 7 AM through 7 PM and Saturday from
7 AM to noon. The gate is opened at the beginning of the day and locked at the end of the day. Prior to
operating the facility and throughout the day, staffs monitor the windsock to assure no adverse
conditions exist that may impact adjacent properties.
(6) Signage: a prominent sign is posted at the entrance to the facility listing the facility name and
emergency contact personnel. The sign states no hazardous materials may be received at the facility.
(7) Boundary Markers: The site is marked appropriately and areas within the site hosting various
operations are marked clearly. The site plan initially approved lists appropriate buffer requirements and
the areas on the site maintain these buffers.
(8) Personnel: A general manager (Dean Brooks) oversees all activities on the site and management
staff includes: weigh -master (Amy Brooks), administrative and accounting personnel (Judy Brooks), and
equipment operators supervised by Alan Brooks and Amy Brooks. The compost operations are
conducted under supervision of Alan and Amy Brooks. Operations personnel attend training and
certification programs conducted by the Compost Council and management staff provides periodic

training to the equipment operators. Personnel files maintained on site document training received by
staff.
(9) Process description: the compost process utilized at Brooks is an open windrow turning process. The
various areas on the site have been identified and the operations within each of these areas have been
described. The process is monitored both visually and through temperature testing. Final product quality
is assured through NCDA and other testing.
(10) Load inspection: materials are inspected at the source and again at the facility. The incoming waste
placed on the receiving pit is visually assessed and the incoming FOG and other liquid is assessed visually
at the source to insure it is acceptable for the operation Unacceptable materials are refused at the
source or returned to the generator if deemed unacceptable at the facility. A roll -off is present on site to
accommodate small volumes of undesirable materials that may accumulate on site. These solid wastes
are handled at the local landfill.
(11) Special handling: special waste is incorporated immediately into tankage or covered on a windrow
to minimize adverse conditions.
(12) Amendment storage: special amendments (ground wallboard) is stored in the bulk storage area and
incorporated into materials as they are transported to the compost area. Topsoil used in the
manufacture of manufactured soil is mixed and blended with finish compost to produce manufactured
soil as requested by landscapers and plant industry personnel.
(13) Pre-processing: grinding is accomplished as coarse materials are received on the site. These ground
materials are stored in feedstock storage areas until used.
(14) Moisture is necessary to compliment the biological processes of the microorganisms responsible for
the degradation of organic matter and stabilization of compost. Composting is a naturally occurring
aerobic process. Based on the proposed ratio of materials, the initial moisture content typically reaches
approximately 50% to 60%. The optimum initial moisture level of 50 to 60 % is achieved by mixing the
wetter feedstocks with dry materials such as wood -chip, poultry litter, sawdust shavings or gin trash,
and cotton waste. These are the targets for this operation and are met using the front -end -loader to mix
and blend feedstocks. All mixing and blending of feedstocks will occur on the pad located at the end of
the initial receiving and processing area.
(15) Temperature
Temperature is monitored closely in windrows that are in the VAR/PFRP stage of composting. Locations
are at 20%, 40%, 60% and 80% of windrow length in all active windrows and these values are recorded.
The optimum temperature range for composting is between 131' F (54.4° C) and 160° F (71.1 ° Q. As
stated in the North Carolina Solid Waste Compost Rules section .1406, the facility has consistently
maintained the compost process at a temperature above 131° F (55° C) for 15 consecutive days or
longer, with 5 turnings, and the average temperature during that time shall be higher than 131° F (55' C)
to ensure the highest level of pathogen reduction. Temperature monitoring is accomplished using a dial
stem thermometer.
(16) Mixing and Process Time - NA
(17) Carbon:Nitrogen Ratio (C:N) —The C:N ratios are monitored to optimize compost production

(18) Compost Recipes
Ongoing analysis has produced several compost recipes with potential for use at the composting facility.
These recipes assume a "Plug Flow" batch of compost. The process time for the compost batch is
normally 120-160 days in a windrow, this includes the initial time to achieve the PFRP and VAR
requirements and limited curing. another 120 days in a curing pile prior to being screened and ready for
market. The recipes are proprietary and Brooks Composters does not share these recipes.
x(19) Operations
The Brooks Composters Compost Facility will be operated daily, from 7:OOam until 6:OOpm Monday
through Friday and from 7 AM to noon Saturday. Additional hours of operation may occur during
periods of high demand for the finished compost material; however, no Sunday operations are planned.
Operations will proceed according to the requirements and procedures detailed in the operations
manual provided for the initial permitting.
(20) Personnel Duties and Requirements
A. Compost Facility Operator - This individual is responsible for overall operation of the Compost facility
and is responsible for loading the proper amount of the selected raw material into the mix to insure a
good quality finished compost. In addition, the facility operator is responsible for scheduling turning
operations, maintaining all the temperature monitoring logs and collecting samples of the finished
compost for analysis.
B. Assistant Facility Operator(s) -This individual will assist the facility operator, as necessary, and
additionally will be responsible for upkeep and clean up around the compost facility. This individual will
perform routine preventative maintenance on the composting equipment
C. Maintenance crew -These personnel are the staff available to Brooks Composters from other
operations as maintenance staff required to perform major maintenance or repairs on the composting
equipment.
D. Equipment crew -These personnel will be responsible for screening and custom blending the
finished compost material, and for loading trucks for delivery.
E. Transport crew - These personnel will operate over -the -road transfer trucks. The compost will either
be trucked to the final destination by over -the -road trucks, or may be removed by vendor trucks as well,
depending on size of the order. Direct sale of bulk material to local contractors is accommodated by
direct loading of the buyer vehicles (private trucks or trailers) by equipment operators and these
transport vehicles are weighed to assess the volume marketed.
(21) Compost Testing Needs
In addition to the routine testing of the compost material every 20,000 tons or every 3 months for the
parameters specified in the operations manual and the monitoring of the composting process for
temperature, it has been advantageous to test compost material for carbon, nitrogen, moisture, and pH
should compost fail to reach desired temperature, if odor problems develop or if a client expresses a
specific need for testing. The finished compost material is monitored every 3 months or 20,000 tons of
compost processed (the smaller of the two) for nutrients and regulated metals tested by the North

Carolina Department of Agriculture. More frequent testing is accomplished as additional feedstock is
added or as process optimization begins, to ensure that the composting process has been successful and
that the NC Solid Waste Section annual reporting requirements have been met.
(22) Storage - Storage of finished compost should be limited to 6 months after completion of the
process. Compost should be utilized within this time period if at all possible. Storage will be provided in
either open areas on the site.
(23) Equipment - In order to optimize the composting process, proper maintenance of the facility and
equipment is recommended. Personnel at Brooks Composters have followed appropriate practices to
assure proper operation of all equipment required for the operation.
(24) Nuisance control - Personnel at Brooks Composters have followed a variety of practices that reduce
the potential of odor emission from the Compost Site. These practices include:
A. Avoidance of overly wet feedstocks and compost. The use of relatively coarse co -
composting materials that allow oxygen diffusion into the pile can help avoid odor problems.
B. Mixing and movement of odorous raw material to minimize the impact of odors.
Accomplishing these activities only early in the work -day to take advantage of rising air currents.
Avoiding accomplishing/performing these activities on hot, still days or holidays and weekends.
Monitoring the wind direction and postpone activities that may release significant odors when the wind
is blowing toward the most sensitive neighbors.
C. Preventing puddles and standing water on the compost pad.
D. Ensure that proper aeration, pH, and temperature control is maintained during the
composting process.
(25) Seasonal and Weather Management
Composting can continue year round, even during cold weather. Seasonal and weather variations may
require operational adjustments that compensate for the change in weather conditions. The insulation
layer covering the windrows should sufficiently buffer the mass of materials in the windrow against
temperature variation, and changes in the operation should not be required.
Cold weather can slow the composting process by increasing the heat transfer rate from the composting
operation into the atmosphere, but the insulation layer should mitigate this transfer. The lower air
temperatures reduce the microbial activity, especially near the surface. This, in turn, decreases the
amount of heat generated.
Warm weather enhances water loss due to evaporation from the windrows. Water or recovered
leachate should be added if materials become too dry (moisture content drops below 40%). Again, the
loss should not be excessive from the windrow, and controls can be implemented by scheduling turning
operations or adding moisture as required.
In event excess liquid accumulates on the site because of wet weather or other adverse condition. That
excess liquid will be collected in a tank truck and transported to an approved wastewater facility for
treatment through the NPDES permit.

(26) Contingency Plans
I. Equipment Breakdown
In the event of a breakdown of the compost equipment (turner, loader, screens, etc.), delivery of raw
materials from the mix area to the windrow is delayed until the equipment is repaired or material is
transported to a new windrow.
2. Fire
In the case of a fire, immediately notify the local fire department. If employee safety is not
compromised, the company pump truck may be utilized to extinguish the fire.
3. Freezing Conditions
Operation in freezing conditions requires more frequent inspection of the leachate collection system to
insure the drains do not freeze and allow leachate liquid to pool on the concrete pads or windrow areas.
Additional caution in operation of the turner and loader is necessary during conditions where ice may
have formed on the sit
4. Extended Power Failure
Operations during an extended power failure may be accomplished by the use of a portable generator.
Temperature monitoring of the composting windrows during a power failure must be continued, and
any compost that does not meet the temperature criteria must be re -processed.
5. Windy Conditions
Windy conditions should have little effect on the composting operation since windrows are in open
areas. However, during windy conditions, special attention must be given to the temperature of the
windrows, and care must be taken during the loading of raw materials (especially light materials such as
sawdust) which could tend to "blow off' the composting area. It is anticipated that the local vegetation
(tree line) will tend to block a great deal of the wind from the facility. However, if windy conditions are
demonstrated to have a detrimental effect on the continued processing of the compost, consideration
will be given to planting additional windbreaks.
6. Disposal or Re -Processing of Poor Quality Products
The compost produced at this facility has consistently met the standards for Class A compost. In the
event that a batch of compost does not meet the requirements for Class A compost, several options
exist. An initial option would be to re -process the batch in an attempt to meet the Class A compost
requirements. This option would be selected if the controlling factor indicating poor quality was
pathogen reduction.
Compost materials that do not meet Class A compost requirements but meet the Class B compost may
be land applied under specific circumstances in accordance with a separate permit. Specifically, these
materials could be applied to agricultural land, provided the land is used for non-food chain related
production, or the material could be used for land reclamation projects. Compost which does not meet
either Class A or Class B criteria, and is deemed undesirable for any attempt at re -processing, will be
disposed of in an appropriate approved, sub -part D landfill site.

(27) Equipment Specifications
The equipment required to operate the Brooks Composters Composting Site can be characterized as
either processing or monitoring equipment.
A. Processing Equipment
The primary processing equipment currently utilized at the site for composting include: front-end
loaders, dump -bed transport vehicles, a Scarab Compost Turner, Roto Mix Mixer, power screens and a
manual bagger. The windrow turner is powered by a diesel engine that rotates the flails in a backward
rotation, which turns the bottom center of the windrow outward. Both turners straddle the windrows,
which are 16 ft wide and 6 ft high when in the beginning stages. Equipment may change with time, but
basic functions associated with each will remain as critical to the process. Equipment may be replaced
with like equipment. Current equipment inventory of direct support equipment located within the
permitted area and essential equipment located outside the permitted site, but on Brooks property
includes :
• Scarab BD-600-RTBA windrow turner
• Rice Lake Survivor Scales
• Deere 644K rubber -tired loader
• Volvo 110E rubber -tired loader
• Volvo 120D rubber -tired loader
• One (1) finished product loader bucket
• Two (2) buckets for mixing/ screening of finished product
• Two (2) raw material loader buckets
• One (1) Allu grinder bucket for coarse wood materials
• Custom Manufactured Screen (BMC, Siler City, NC)) and Powerscreen Warrior 1800 screen with
stacking conveyors (as a backup)

• Airlift Separator (screen attachment)
• Deere 450CLC Excavator
• Volvo 240C Excavator
• Bell large capacity off -road truck
• Spray truck for windrows
• Kuhn 8132 Spreader
• Kubota RTV
• Green Mountain Technologies (or equivalent) software and thermometers for recordkeeping.
• Roto Mix Mixer is used to mix the feedstocks and mulch to get a homogenous mix before going
to the windrows
B Monitoring Equipment
A probe -type dial stem thermometer (as manufactured by Green Mountain Technologies) with a 36"
stainless steel stem is used to monitor the temperature of the compost in the active windrows The
thermometer probe has a temperature range of 0-200 degrees Fahrenheit and is calibrated.
C. Scales
The scales are used to weigh all feedstock in and weigh finished product out before delivery. The scales
are calibrated by a State approved facility. Incoming feedstocks and outgoing product is weighed.
(28) Nutrient Management Plan
The majority of the compost produced by the Brooks Composting Facility is sold as a soil amendment.
Additional or excess compost will be sold in bulk to local greenhouses and landscape contractors for use
as a soil amendment or to the NCDOT for use in highway landscape projects. A compost guide is
supplied to users as requested and the nutrient management criteria are addressed.
(29) Compost Record Keeping, Analysis and Reporting Requirements
The compost produced at the Brooks Composters facility is routinely analyzed to insure quality control is
maintained. Analysis shall be conducted by the North Carolina Department of Agriculture (NCDA), Soil
Test Laboratory on Blue Ridge Road in Raleigh, or by a certified analytical laboratory (A and L, Prism
Laboratories, Southern Testing, etc.). The compost is monitored for temperature daily to insure vector
and pathogen reduction compliance (see record keeping forms in Appendix 1). An annual report has
been submitted to the NC Solid Waste Section by August I" of each year, in compliance with NCAC 13B
Section .1408 (c).
(30) Daily Record Keeping

The compost facility maintains daily (except Sunday) temperature, compost processing length and daily
volume of compost processed records for the composting operation. In addition, the volumes of the
various feedstocks are recorded to ascertain the optimum mix and blend ratios for the continued
operation at this facility.
(31) Routine Compost Sampling Procedure
The compost is sampled once per every 20,000 tons of compost produced or every three (3) months
whichever comes first. The samples are obtained in a sterile manner according to the following
procedure. The samples are obtained from the finished compost piles and represent the material
marketed to the public. Samples are collected Immediately prior to the screening and bagging
equipment. These sample locations are randomly selected from within the finished pile, and should
represent a "cross section" of the pile, not just the "surface". The sampling is conducted wearing latex or
nitrile gloves, and the composite samples are well mixed to insure a representative sample is tested.
Samples are immediately refrigerated or placed in sealed containers in a cooler for transport to the
laboratory. Collected composite samples are placed in sterile bags provided by the laboratory if
pathogen samples are to be run on the material. Samples are delivered to the laboratory within 24
hours if pathogen testing is to be performed. Brooks staff coordinates with the laboratory ahead of
sampling to insure that the proper "hold times" for the various parameters to be tested are not
exceeded. When necessary, Brooks staff run intermediate nutrient and metal content samples at a more
frequent interval than the once every 20,000 cubic Yards specified by regulation.
(32) Routine Compost Analysis
The analyses include the parameters listed in the permit with measurements less than the regulatory
limits based on dry weight (mg/kg) or percentage. Testing is conducted by private certified laboratories
for regulated metals and bacteria. NCDA testing is adequate for nutrients, and trained personnel at
Brooks Composters can test foreign matter levels.
Foreign matter testing is determined as follows. The compost material will be dried (EPA Method 160.3),
weighed and passed through a one quarter inch (1/4") screen. All materials remaining on the screen will
be visually inspected and all foreign material (glass, plastic, metal, etc.) will be removed and weighed.
The weight of the removed foreign material divided by the weight of the total dried sample is multiplied
by 100. This percentage will be recorded and reported as the percentage foreign material observed in
the sample.
(33) Annual Report
An annual report is submitted to the NC Solid Waste Section by August I" of each year, in compliance
with NCAC 13B Section .1408 (c). The annual report contains the facility name, address, permit number,
a summary of the total quantities of raw material received at the facility, the total quantity of compost
produced by the facility, and the total quantity of compost removed from the facility (marketed or
disposed of off -site). The annual report has also include temperature monitoring records and the results
of the required analysis for metals, pathogen reduction analysis (fecal coliform), and for the percentage
of foreign matter in the finished compost.

(34) Safety & Health
Staff at Brooks follows accepted health and safety practices. Safety practice compliance at composting
facilities can prevent most occupational risks. The safety concerns in composting relate primarily to the
use of equipment. Normal safety precautions, such as those provided with the equipment, should be
followed. In addition, The Farm Safety Association has developed a fact sheet (No. F-017- Agricultural
Machinery Hazards and this fact sheet is available on -site and is reviewed by all personnel operating or
working near machinery.
Fires are rarely a problem in outdoor composting, Properly moistened composting material does not
readily bum. However, if material does dry out or if storage piles are too large, spontaneous
combustion becomes a possibility. An accessible water supply is a valuable safety precaution and the
leachate pond at Brooks Composters serves as a resource is needed. In addition, the local fire
department is a short distance away.
Human health concerns relating to compost depend both on the individual and on the material being
composted. While few pathogenic organisms found in farm animal manures orvegetative wastes affect
humans, normal sanitary measures are important (such as washing hands before touching food, eyes,
etc.). Some individuals may be hyper -sensitive to some of the organisms in compost. The high
population of many of the species of mold and fungi in an active compost process can cause allergic
reactions in sensitive individuals. Simple precautions, such as wearing dust masks or even half -mask
respirators with disposable cartridges, can help limit human exposure to organisms that may cause
allergic reaction. Conditions that may predispose individuals to an infection or allergic response include
allergies, asthma, such medication conditions such as antibiotics, punctured eardrum, weakened
immune, etc. Workers with any of these conditions should not be assigned to a composting operation.
If a worker does• develop an allergic reaction to compost, it is important to recognize the problem
promptly so that it does not develop into a chronic condition. To prevent health concerns during
particularly dry and dusty conditions, a dust mask or half mask respirators should be worn. Blood borne
pathogen testing may be accomplished on employees of the compost operation as a part of the annual
physical.

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NOTES
1. SEE C-101 FOR ALL GENERAL NOTES.
Pxcfiw ®
SEP 2 7 2019
BOLA) WASTE S$(Tj(jN
GRAPHIC SCALE: 1 " = 150'
0 75 150 300 450
REVISIONS
NO. DATE I DESCRIPTION
PROJECT MANAGER: PROJECT ENGINEER:
GSM AVF
DRAWN BY: CHECKED BY:
JDH GSM
DATE:
SEPTEMBER 27, 2019
SEAT.
C 17069 P :,-JZZ
A V •F/vG IN��
MacCONNELL
& Associates, P. C.
1101 NOWELL ROAD, SUITE 118
RALEIGH, NORTH CAROLINA 27607
P.O. BOX 129
LICENSE MORRISVILLE, NORTH CAROLINA 27560
No. C-1039 TEL: [phone] FAX: [phone]
BROOKS COMPOST
FACILITY
SITE PLAN
CHATHAM COUNTY, NC
EXISTING CONDITIONS
PROJECT NUMBER DRAWING NUMBER
A70901.00 C-101
r
0901.00 - BROOKS COMPOST FACILITY - SITE PLAN