100021_NOV-2020-PC-0495 Response_20220728

RECEIVED/NCDENR/DWR
AUG 012022
Water Quality Regional
Operations Section
Wilmingtonn Regional Office
KAIZEN FARMS
July 28th, 2022
North Carolina Department of Environmental Quality
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources
Attention Morella Sanchez-King:
Subject: In response to NOV
Farm/Permit AWS 100021
Brunswick County
NOV-2020-PC-0495
This letter serves as a response to the re-issue of notice of violations.
Violation #1— Failure to prevent a discharge of waste into wetlands.
Response: We respectfully disagree with this statement as it is not true. There was no runoff into any
wetlands. The water in question was contained in the ditch at the front of the property. The water
never reached any wetlands.
Violation #2— Failure to prevent runoff.
Response: The state requirement in a land application event is to monitor the system every 2 hours
during operation. The amount of water of subject in this NOV would strongly support that we were
monitoring the system we!!within the state requirements and were much more aggressive than the
state requirements in terms of management.
Violation #3 - Failure to notify the Division of a discharge.
Response: The OIC on this site was the person operating the system and caught the issue through normal
observation and limited the waste runoff to the ditch adjacent to the property of Carolina Bay Farm LLC.
It is irrational for one to think that he acted/we acted in negligence or with the intentions of hiding this.

The road front ditch will not allow this from being hidden. We felt it was such a small amount and had
not gotten to a wetland area,creek, etc.that we would simply just clean it up as any responsible producer
would do. The area of concern took a very short amount of time to clean up nor was any risk to state
waters as it was responded to quickly. There was no natural movement of the water in the area that was
cleaned up. The OIC could not of reacted any sooner unless he was sitting there watching pivots every
move. We have changed our system to prevent this from reoccurring in the future and have invested over
$200,000 to do this.
•
Violation #4—Failure to inspect the land application site.
Response — We respectfully disagree with this statement as it is untrue and inaccurate. The state
requirement in a land application event is to monitor the system every 2 hours during operation. The
amount of water of subject in this NOV would strongly support that we were monitoring the system well
within the state requirements and were much more aggressive than the state requirements in terms of
management.
Carolina Bay Farm LLC has invested a great deal of time, money, and other resources to continue to
operate in accordance with the current state guidelines and rules. We feel that we have improved the
site to operate well beyond the expectations of the state requirements and are continuing to proactively
improve the operating systems at Carolina Bay Farm LLC.
Respectfully,
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Director of Operations
910-379-8822 Mobile
[e-mail]