100033_Response to Notice_20180829

Dave Elkin
Smithfield,
D'rr of Engin a rng
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Smithfield MPD
2822 Hw, 24 Vest
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Warsaw, NC 28398
[phone] tel
910) 284 1740 mobile
August 29, 2018
David Powell
North Carolina Dept of Environmental Quality
Water Resources
127Cardinal Drive Extension
Wilmington, NC 28405-3845
Re: Farms 10-5 & 10-33
Due to excessive rainfall over previous months, both of the farms 10-5 and 10-33 accumulated water well into the
structure freeboard zone on to August 1, 2018, when I first visited these sites. On August 9th I again visited this site,
observing that greater than 12 inches of freeboard had been achieve at each lagoon. During both visits I walked the
lagoon perimeters to assess any issues with the embankment. Additionally, survey crew members of the engineering
department have made multiple trips to the site to makes observations and measurement on my behalf. With the most
recent trip on August 28, 2018, the staff gages were corrected to reflect an accurate freeboard based of the lowest
elevation of the current dike levels.
A freeboard of greater than 36" has been achieved in all lagoons associated with this facility.
Consistent with the observations made by Mr Young, PE, with the Division of Soil and Water, I concur that the dams
appear to be well constructed with an excellent stand of perennial vegetation covering the top of the dam and the
downstream slope. The dike width ( >=10 feet), slope (approximately 3:1 or flatter), and height (less than 6 feet) allow
for the conclusion that these dikes are appropriately designed and constructed.
With no observed erosion, evidence of piping, boils, or sink holes, it is my professional evaluation that these
embankments demonstrate the appropriate structural integrity. When operated at design freeboard levels between
19" to 48", the observed seepage has ceased to be observable at the soil surface along the embankment toe.
Mr. Ward plans to have the liner areas where seepage was observed repaired before October 1, 2018. The freeboard
�( will be maintained below 24" until this repair is completed. Having been on site, reviewed the Division of Soil and Water
r) evaluation, and had staff at these site multiple times observing the embankments and associated freeboard, it is my
VJ '0 ` professional opinion that these lagoons are safe to resume utilization as designed and permitted.
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•��� The following procedure is proposed to repair the clay liner, so that the observed seepage does not occur in the future
regardless of freeboard level.
1) Pump water out of the lagoon as quickly as conditions will allow. The goal should be to achieve approximately 48
inches of freeboard or more. This may require going slightly below the stop pump level of normal operation to
allow for the repairs.
a. As freeboard level moved to greater than 30 inches the ponded area associated with seepage has been
observed to dry out.
b. The goal is to reach 48 inches of freeboard will be September 10, 2018.
2) Upon reaching the 48-inch level, the upper portion of the liner shall be repaired to eliminate any further potential
seepage.

a. This freeboard will allow the embankment to dry, permitting heavy equipment to work safely and
efficiently while traveling the dike and compacting the liner repair area.
3) The repair will consist of the following steps:
a. The repair area will include approximately 10' of the dike above the seep and extend a distance of 25'
along the dike in each direction (total of 60' long). The depth would be approximately 3.5' (freeboard)
which equals 105' from the inside top of (like toward the water surface.
b. This repair shall be done at the earliest time at which there is adequate freeboard and a projected period
of dry weather to allow for the construction to be performed under good working conditions. This will
help assure quality earthwork can be performed and improve safety while working on the potentially
slick slope above the water surface.
1) Removal of the organic matter (grass, sludge, etc.) from the clay liner surface.
2) Evaluation of the clay liner depth and clay quality by Smithfield soils personnel.
3) If clay quality is adequate, then scarify the existing liner approximately 8" to 10" deep, compact with
sheep's foot roller, and add a minimum of 6" of additional clay and compact to achieve at least 1.5'
total clay depth.
4) If clay quality is inadequate, then remove the liner in the proposed area. fill with suitable clay
material in 6" lifts compact with sheep's foot roller until total liner thickness of 1.5' is achieved.
5) This liner rework and compaction on the inside of the lagoon should eliminate the seepage observed.
Upon completion of the repair under my supervision, I will send a letter to certify that the repair meets the design
criteria required.
Respectfully,
David S. Elkin, P.E.
Director of Engineering
cc Gene Ward
Terry Jones
Kevin Weston
Dave Nordin
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Miguez, Kristin
From: Elkin, Dave <[e-mail]>
Sent: Wednesday, September 5, 2018 12:02 PM
To: Lawson, Christine, Powell, David C
Cc: King, Morella s; Miguez, Kristin; Meilinger, Michael J, Jones, Terry
Subject: RE: [External] RE: 10-5 and 10-33
Lim External ernall: uo: not Click links or onen attachments unless verftleo.52nd all susnicir
Individuals from my team will be on site to address the issues this week
There are 5 areas of interest that have been discussed:
10-33 bell swamp
1) North- west corner of west dike seepage. Described in the previous letter. (repair to cut off seepage)
2) North- east corner correct dike height approximately 4" to repair settlement and regain freeboard close to
original embankment height
3) South dike — evaluate to dike west of irrigation pump. This area was identified while it was extremely wet as an
area of interest. I believe due to rain and ground water. There was no observed waste water or flowing water
here.
10-05 Ward
4) East end of the north dike- evaluate soundness of the lagoon, and certify that the vegetation resisted erosion at
the low spot and the exterior embankment
5) South dike — evaluate the area near the irrigation pump and hydrant.
As these areas are evaluated and addressed if other concerns arise, we will communicate and make those repairs while
on site.
Staff gages:
Both sites staff gages have been re -set as of 8/28 to accurately reflect the current conditions. (each was lowered
slightly)
The 10-33 lagoon with be re -set again when the corrective action 2) is complete and field verified. This will
restore approximately 4" of freeboard, which has been lost.
Site 10-05 is accurate today, this top of dike is very uniform and has excellent vegetation. No modification to
this lagoon are recommended.
These lagoons have been tested by mother nature at nearly the most extreme hydraulic loading possible. When these
lagoons are operated within the designed freeboard levels of approximately 19" to 48", there will be less hydraulic
pressure than what they have already sustained. Once the actions above are completed, it is my professional opinion
that the lagoons will be fully functional as originally designed and permitted.
Should you have and questions or need further clarification please let me know.
Regards,
Dave

From: Lawson, Christine <[e-mail]>
Sent: Wednesday, September 05, 2018 9:39 AM
To: Powell, David C <[e-mail]>; Elkin, Dave <[e-mail]>; Jones, Terry
<tjones@sm ithfield.com>
Cc: King, Morella s <morelIa. [e-mail]>; Miguez, Kristin <[e-mail]>; Meilinger,
Michael J <[e-mail]>
Subject: RE: [External] RE: 10-5 and 10-33
Based upon the letter send by Dave Elkin, I am satisfied in having the farms repopulated so long as the permittee
adheres to the conditions described until repairs are completed.
As David Powell stated, my questions were more of the what if variety related to the repair work. I do not foresee that
holding up the operation of the facility at this time. As a licensed Professional Engineer that has evaluated the lagoons
and developed a plan for continued operation and repairs, Mr. Elkin has satisfied the permit requirements related to the
scope of work for the repairs at this point. See permit condition 11.25 of the 2014 Swine General Permit.
We will need an engineer's certification upon completion of the repairs. Since the extent of the repairs cannot be
known until efforts begin, the documentation provided to the division along with the certification shall include a full
description of the repair —extent, location, design.
Please contact me if you have any additional questions.
Christine B. Lawson
Program Manager
Animal Feeding Operations Program
Department of Environmental Quality
919 707 3664 office F NEW NUMBER
984 232 1223 mobile
Christine. LawsonC@ncdenr gov
Email correspondence to and hom this address is subject to the
North Carolina Public Records Law and may be disclosed to Owd p wfes
From: Powell, David C
Sent: Tuesday, September 04, 2018 11:03 AM
To: Elkin; Dave <[e-mail]>; Jones, Terry <[e-mail]>
Cc: Lawson, Christine <[e-mail]>; King, Morella s<morella.sanchez-I<[e-mail]>; Miguez,
Kristin <[e-mail]>; Mellinger, Michael J <[e-mail]>
Subject: RE: [External] RE: 10-5 and 10-33
Ok thanks. We would like some clarification and Christine voiced a concern as well but was satisfied. Can you confirm
that the dike wall repair work will be done, as stated in part 3, on both lagoons? That's how we understand it. Also,
Christine questioned if during the repair they find the clay material to be unsuitable in the area to be repaired, what do
you propose to further evaluate the rest of the liner? She didn't think you needed to modify the letter but have an
understanding on this "what if?"
Thanks
David Powell, Environmental Specialist
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Regional Operations Section
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405-3845

Tel. [phone]
fax [phone]
For any emergency, which requires immediate reporting after normal business hours, contact must be made with the
Division of Emergency Management at 1-800-858-0368.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Elkin, Dave [mailto:[e-mail]]
Sent: Wednesday, August 29, 2018 5:19 PM
To: Powell, David C <[e-mail]>; Jones, Terry <[e-mail]>
Cc: Lawson, Christine <[e-mail]>; King, Morelia s [e-mail]>; Miguez,
Kristin <[e-mail]>; Meilinger, Michael J <[e-mail]>
Subject: [External] RE: 10-5 and 10-33
David,
Please find the attached letter regarding the assessment of the dikes, measures taken and planned at Mr. Wards farms.
At this time I feel that adequate freeboard has been achieved to safely resume operation of these facilities, which is
outlined in the letter. Also in the letter are the steps which are proposed to permanently address the observed
seepage. Please respond letting me know if you have additional concerns, need further information, or concur with the
proposed next steps.
Regards,
Dave
From: Powell, David C <[e-mail]>
Sent: Wednesday, August 22, 2018 4:40 PM
To: Elkin, Dave <[e-mail]>
Cc: Christine Lawson <[e-mail]>; King, Morelia s <morella.sanchez-king@ncdenr.�ov>; Miguez,
Kristin <[e-mail]>; Meilinger, Michael J <[e-mail]>
Subject: 10-5 and 10-33
Mr. Elkin, per our conversation today, I believe these are the problems that need addressing with these farms. An
engineer will need to either sign off on the structural integrity of these lagoon structures on these farms or a repair plan
submitted to DWR for approval and then documentation of the structural integrity after the repair is
complete. Obviously 10-5 waste level gauge was off and needs to be reset to read the correct level and 10-33 needs to
be checked as well and documentation/engineer stamped, provided stating this has been satisfied. I am unsure if

Christine or my supervisor Morella will have anything to add but I think those are the issues that need addressing
currently. Thanks for you kind words and if we can be of assistance in the future please let us know.
Thanks
David Powell, Environmental Specialist
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Regional Operations Section
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405-3845
`�,
Tel. [phone]
Fax [phone]
For any emergency, which requires immediate reporting after normal business hours, contact must be made with the
Division of Emergency Management at 1-800-858-0368.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.