820689_Responce Letter_20190404

From: Steeds Farms Inc.
PO Box 448
Mount Olive, NC 28365
May 4, 2019
To: NCDEQ, Division of Water Resources
Fayetteville Regional Office
225Green Street, Suite 714
Fayetteville, NC 28301
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MAY 0 6 2019
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Subject: Response to Notice of Violation/Notice of Intent NOV-2019-PC-0250,
issued for Steeds Farms Inc. Facility No. 82-689, Permit No. AWS820689
Mr. Allen:
Below is the response to your regional office staff findings during his inspection:
1-2. Explanation of how this violation occurred and steps that have and will be taken to prevent future
occurrences:
Respectfully, the statement in your letter that states that DWR understands that Eastern NC received
above average rainfall in 2018, is a gross understatement, when in fact the rainfall broke all records
since they have been documented in the state. Repeated rain events each month in 2018 interfered
with the opportunity to pump as frequently as desired due to the wet field.
The statement that no efforts were made to lower the lagoon level prior to Hurricane Florence is false.
The pumping records clearly show that pumping occurred multiple dates in July and one date in August
prior to the extended period of rain events that occurred in August and September. Due to excessive
water in the field no more pumping was done as to not over apply and cause prohibited runoff.
Immediately prior to the storm the lagoon level was at 25 as noted on the Daily Rainfall/Lagoon Level
Record.
With roads and bridges washed out and trees and power lines down, as soon as I was able to ascertain
the status of all farms, on September 16, multiple attempts to contact the Fayetteville and Wilmington
offices were made, and quite understandably to me, the phone lines were out of order. First thing
Monday morning 9/17 a friend that works in Raleigh personally notified Christine Lawson of all Steeds
Farms lagoon levels and I followed up with an email documenting the same (see Attached email). My
Smithfield representative was also notified and the POA process ensued.

Multiple calls were made to several other facilities in the area during the period after the hurricane and I
was told they had no room at those facilities to accept any water that the state says should have been
pumped/hauled; all farms in southeastern NC had historic lagoon levels. At no time did the lagoon at
this facility overtop or breach; the structural integrity of the lagoon design was approved by the state
many years ago and has been maintained to this date. The lagoon did what it was designed to do, it
held the waste with no spill to surrounding land or creeks.
It should also be noted that with prior staging of a generator before the storm, I was able to maintain
power to feed and water the animals continuously during this trying time, and experienced no more
than normal mortality at the facility. It should also be noted that no pigs were on site from January
through the early April 2019.
I will continue to be a good steward of the land and waterways and abide by the permit requirements of
the state approved designed structural freeboard. To aid in this effort the irrigation system has been
changed from using a reel system to using the Airway system to apply the waste. I plan to only use
Airway irrigation in the future at this farm to assure lagoon levels are sufficient to prevent ever reaching
freeboard again within the 60 days required by the state from the date of receipt of this letter which
was April 27, 2019. No one can prepare for 40-50 inches of rain that we received in a 4-day period, and
although the storm was predicted, no one expected a storm of that magnitude, but as soon as possible, I
plan to reduce the lagoon level as much as is allowed by my permit so this never occurs again in the
future.
3. Weekly Lagoon Level Forms for 2018 until current date (Attached).
4. IRR2 forms for 2018 until current date (Attached).
I have been raising hogs for a very long time and have never experienced the extensive rainfall that we received
in 2018 or the trials that have ensued trying to recover from the effects of Hurricane Florence. I have invested
thousands of dollars repairing wind and water damage to the houses, and contracting the Airway operator for
removal of the waste from the lagoon in efforts to resume normal operations at this facility in as timely a
manner as possible. I respectfully request that DWR not issue any civil penalty for these violations issued.
Sincerely,
J. Frank Steed III
Owner/President
Steeds Farms, Inc.