6101_PenlandCompost_RequestExemption_20191125

Wilson, Donna J
From:
Casara Logan <[e-mail]>
Sent:
Monday, November 18, 2019 3:12 PM
To:
Wilson, Donna J
Cc:
Dave Sommer
Subject:
[External] Small Compost Facility Exemptions
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L AL
Good Afternoon,
I am writing to follow up on our conversation about whether our Small Type III Compost Facility (Facility
Name: Penland School of Crafts Compost Facility; Permit Number: 6101-COMPOST-2013) may be eligible
for Exemption from Permitting. After reading over the Guidance Document for revised Small Compost Facility
Exemptions (effective as of November 1, 2019), It appears to me that our operation meets all 3 qualifying
conditions.
Feedstocks .1402(g)(2)(A)- The only feedstocks we accept are pre- and post -consumer food waste, occasionally
compostable dinnerware, and yard and garden waste.
Volume of Material Onsite .1402(g)(2)(B)- Annually, as reflected in our submitted reports, our facility never
exceeds 32 tons of material. This includes all feedstock storage, active composting, and curing compost piles.
Size of Operations Area .1402(g)(2)(C)- Our total operations area, including finished compost storage, is less
than .30 acres.
I would like to request an evaluation from the Section to see whether our site qualifies for an exemption. We are
a very small operation, which I believe is demonstrated by this information. I look forward to discussing this
more and thank you in advance for your help!
Best regards,
Casara
Casara Logan
(she/her/hers)
Groundskeeper
Penland School of Craft
P.O. Box 37, Penland, NC 28765
828-765-3087
www.penland.org
Penland School of Craft is an inclusive organization that values diversity and respects the rights of everyone.

Wilson, Donna J
From: Casara Logan <[e-mail]>
Sent: Monday, November 25, 2019 10:22 AM
To: Wilson, Donna J
Subject: Re: [External] Small Compost Facility Exemptions
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ort.s am c nc. ov
Goodmorning Donna,
Afterter thoroughly reviewing the latest version of the document, I do believe that we still qualify for
exemption.
Location and setback requirements- we are not located within a 100-year floodplain, wetland, nor on top of a
closed disposal area. Our <.30 acre compost facility is located in the western meadow of Penland Schools
property and is well over 800ft from our nearest property line, private residence, wells, streams, or ditches and
berms.
Soil pad under the operations area- the soil pad on our site is generally clay, preventing infiltration of liquids to
groundwater
Surface water and liquids management- Soil erosion control measures are practiced to prevent discharge of soil
into surface waters and I do operate the site to minimize surface water run-off /ponding of liquids around
windrows. I put a 10" layer of sawdust between our soil pad and food waste to assist in absorption of any excess
liquids. This, in conjunction with the location of the active compost bin on our site (with a strong
consideration to it being a level site with very little to no change in grade), is effective in preventing any run-
off, etc.
Pathogen reduction- I actively monitor and record the temperature of our compost piles, maintaining a
temperature of 131 degrees or greater for, at minimum, 15 consecutives days. I turn our active piles (windrows)
during the high temperature period more than 5 times in that 15-day period.
Operation requirements- I actively monitor and record the temperature of our compost piles, and upon adding
and food waste I promptly mix brown, carbon bulking material equivalent to or more often greater than the
quantity of "green" material to facilitate the composting process as well as to prevent offsite odors. My active
turning of the piles minimizes odors as well as prevents airbornes particles from leaving the property.
Analytical testing- All of the compost produced at our small facility, which as our records indicate does
not exceed 13 tons annually, is used on our property (not distributed). We do perform analytical testing bi-
annually (using Water Tech Labs in Granite Falls, NC) to test for fecal coliform bacteria, as well as the
NCDA&CS Agronomic Division for a Predictive Waste Report to test the nutrient measurements as well any
heavy metals present. We have records of our test results as well as our temperature monitoring since the
inception of our compost facility.
Thank you so much for your time and consideration. Please let me know if there is any more information I can
provide about our Compost Facility.

I hope you have a lovely holiday and I look forward to hearing from you.
Best regards,
Casara Logan
Casara Logan
C,roundAeeper
Penland Scbuol of Craft
P_O. Box 37, Penland, NC 28765
828-765-3087
www-yenlmd.ory
Penland School of Craft is an mchurve organrzatton that values diversroy and respects the rights of everyone-