310557_Add-Info Response_20240314

March 14, 2024
Christine Lawson, Engineer
NCDEQ Division of Water Resources
Animal Feeding Operations
1636 Mail Service Center
Raleigh, NC 27699-1636
Subject: Response to Additional Information Request
Application No. ADS310557
CDP Farm
Duplin County
Dear Mrs. Lawson,
CAVANAU G H
Stewardship Through Innova,,.
Cavanaugh & Associates, P.A., on behalf of Hilton Agribusiness, LLC has reviewed your Additional
Information Request, dated February 19, 2024, for the subject permit modification application for'CDP
Farm', which is noted to have been received by the Division on November 22, 2023; and has developed
responses and additional supporting information to address each item in your letter. For your
convenience, we have repeated the comments below in bold font, followed by the responses in
italicized font.
1. Nutrient Management Plan (NMP) —The NMP submitted is dated 9-28-2018. The application
form stated the new NMP is pending by the owner. Per our conversation during the January
26, 2024 site visit, the new digester will be located in one of the current land application fields.
The NMP shows that pulls 16-19 are leased; no lease agreement was included.
a. Please provide the updated NMP.
b. Please provide the updated irrigation map.
c. Please provide documentation of the lease agreement for pulls 16-19.
Response: The requested information was emailed to you separately by Smithfield today
Thurs. 2024-3-14.
2. Setbacks — Sheet C.2.4.3 shows that the location of the proposed digester does not meet the
Siting Act requirements for:
a. Distance from any occupied residence, which is 1,500 ft, G.S. §106-803(a)(3). As
shown, the digester top of embankment is approximately 600 feet from the residence
of William and Connie Outlaw, Duplin PIN 24870018760.
Response: The owner is working with the applicable residence owners to obtain necessary
easements and understands that these must be in place at the time of
construction to remain in compliance with G.S. 106-803(o)(1). We appreciate
the Division pointing this item out.
b. Distance from any property boundary which is 500 ft, G.S. §106-803(a)(3). As shown,
the digester top of embankment is approximately 400 feet from the residential
property boundary of William and Connie Outlaw, Duplin PIN 24870018760.

Response: The owner is working with the applicable residence owners to obtain necessary
easements and understands that these must be in place at the time of
construction to remain in compliance with G.S. 106-803(a)(1). We appreciate
the Division pointing this item out.
c. The distance from the digester top of embankment to the property boundary with
Benjimin and Michelle Grady, Duplin PIN 248700124473. is approximately 182 feet,
which is greater than the current setback of 78 feet from the lagoon to the property
boundary.
Response: Correct, the proposed digester will not be located closer to the property than the
existing lagoon, which meets the setback requirements.

Thank you for your assistance and review of the permit application package. Please do not hesitate to
contact our office should you have any questions, comments, or require any additional information.
Regards,
Cavanaugh & Associates, P.A.
44 1117
6 ir
Jeff P. Cappadona, P.E.
Attachments
cc: Hilton Agribusiness, LLC