HomeMy WebLinkAbout820715_NOV-2019-DV-0284 NOV Response_20210611Smithfield.
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August 1, 2019
NCDEQ DWR
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301
Attn.: Trent Allen, Regional Supervisor
Subject:
Dear Mr. Allen,
ENTERED TC)
JUN i i tuL1
DEQ/DWR WOROS
FAYE.Ti E\iILLE REGIONAL OFICE
Additional Considerations in Response to
NOV-2019-DV-0284
Carroll's Farm 2096, Facility No. 82-0715, Permit No. AWS820715
Sampson County
M. Kevin Weston
Sr. Environmental Compliance Technical Specialist
Smithfield Hog Production Division
P.O. Box 856
2822 NC Hwy 24 West
Warsaw, NC 28398
(910) 293-3434 tel
(910) 293-3138 fax
This letter contains additional considerations in response to the NOTICE OF VIOLATION/NOTICE OF
RECOMMENDATION FOR ENFORCEMENT letter dated July 23, 2019.
According to the notice letter, the required corrective action along with the typically requested information has already
been provided to the Fayetteville Regional Office on June 24, 2019. In addition to this information, please consider the
following:
• All irrigation line ditch crossings have been marked with posts and will be maintained so that anyone
performing field maintenance activities will be aware of the irrigation lines crossing the ditches,
• All irrigation line ditch crossings are encased in a second pipe for added protection from maintenance activities,
• Underground gate valves have been installed throughout the system and various valves will be closed to isolate
or shut off sections of the system that are not in use during an irrigation event,
• Prior to starting any irrigation event, the entire irrigation system will be inspected for damages and repairs
made as needed,
• The farm has a good environmental history and responded to the incident in an appropriate, responsible, timely
and effective manner in accordance with our Environmental Management System (EMS) as well as our current
state General Permit,
• This incident occurred while the farm was and still is under contract to be sold. Current and proposed
management personnel have been involved with the corrective actions taken and proposed.
Our Environmental Management System (EMS) proved its effectiveness by providing the structure and protocol that
ensured the incident was discovered quickly and appropriate corrective actions and notifications were done in a timely
and effective manner. Recovery and remediation efforts began within three hours of discovery of the incident. The pipe
repair was completed the following day. Expenditures for recovery, remediation and repair caused by this incident
totaled more than three days of labor and over $3700.
Thanks for the opportunity to present additional information for consideration in response to this notice. If you have
further questions or need additional information regarding this matter, please contact me.
Sincerely,
,fie/ z--�
M. Kevin Weston
kweston@smithfield.com
www.smithfieldfoods.com
Murphy Brown.
Murphy Brown East
June 19, 2019
Bill Dunlap
NCDEQ — Division of Water Resources
Suite 714 225 Green Street
Fayetteville, N.C. 28301
RE: Farm 20963
Facility # 82-715
Accidental Discharge 6/17/19
PO Box 856
Warsaw, NC 28398
REUtlVE
DECyDwR
JUN242019
AYETTFv!'I EREGIO
l.NALOft";C
Dear Mr. Dunlap,
This letter is the follow-up to an accidental discharge on farm 20963 reported to you on June
17, 2019. The sequence of events on Monday 6/17/2019 was as follows:
1) The farm's LNM Tech started the irrigation pump at 10:20am and then checked the
hydrants, air vents and valves for leaks. He retumed to the pump to begin increasing
pressure on the system and immediately noticed that something was wrong. He shut the
pump down at 10:40am.
2) The Tech checked the system again and checked the ditches as well for any problems. At
11:15am he found a broken irrigation line in a ditch on the Western end of the farm.
3) The Tech immediately contacted his supervisor and put in an earthen dam at the pipe
break to contain the effluent that was leaking from the line.
4) The complex manager called to have recovery pumps brought to the site. Once
equipment arrived, pumps were set up and remediation began at 1 pm. The effluent mixed
water was pumped onto the farm's spray fields. In addition, we brought in other
equipment which included an excavator to further contain and recover the effluent.
5) When equipment arrived, a containment dam was constructed at the furthest point
accessible. A pump was placed there, and remediation began at approximately 5 pm.
The effluent mixed water was pumped from this point onto the site's spray field. I called
Bill Dunlap with DEQ at approximately 5 pm to report the spill and give details of the
situation.
6) Hughie White with DEQ arrived Monday 5/20/19 at approximately 6:45pm to inspect the
incident and recovery efforts.
7) Recovery and remediation included pumping the effluent onto the farm's spray fields from
the containment dams. Cleanup efforts were carried on into the night on 6/17/19 and on
6/18/19 until all effluent mixed water was recovered behind the dams.
8) Our LNM crew invested over 47.5-man hours in efforts to recover as much effluent from
the spill as possible at a cost of approximately $2,440.00.
9) Root Cause: A 6" PVC irrigation line that crossed a field ditch was hit and busted by
someone. We do not know by whom or when this occurred.
Estimate of the discharge:
• Page 2 June 20, 2019
A) We estimate approximately 8,000 gallons of effluent was lost through the irrigation line.
Through our efforts we feel that we recovered approximately 4,800 gallons and no more
than approximately 3,200 gallons escaped past our constructed dams. See estimate of
discharge attached
Corrective Actions taken:
1) The busted irrigation line was repaired
2) Further investigation to find out who damaged the pipe and why it was not repaired.
Included with this letter is a copy of the most current waste analysis as required by the permit and a
copy of the estimate of discharge. Also, as required by NC general statutes chapter 143-215.10C (h)(I)
a public notice was released to local media outlets on 6/18/19. (See attached copy of public notice.)
I have outlined all currently available information about this incident. Murphy -Brown LLC staff has
responded in an appropriate and responsible manner in accordance with our Environmental
Management System Emergency Response Plan and in keeping with our responsibilities under the
state permit.
Our Environmental Management System (EMS) proved its effectiveness by providing the structure and
protocol that all parties involved in the response and ensuring, that they did so in a timely and effective
manner.
If I can be of any further assistance, please feel free to contact me.
Sincerely, Q �%41jejil
Michael Norris
Environmental Systems Manager
Murphy -Brown LLC
(910) 293-5575
NOTICE OF DISCHARGE OF UNTREATED WASTE
The 20963 Farm, located at SR 1255, 1148 Hayne Stretch Rd Autryville and owned by Murphy -Brown
LLC, had a discharge of approximately 8,000 gallons of untreated wastewater originating from a
damaged irrigation line on the farm. The discharge occurred on June 17, 2019 and was discovered at
approximately 11 am. The wastewater entered an unnamed tributary of Big Swamp. Containment and
remediation efforts began immediately upon discovery, and the incident was reported to NCDEQon
June 17, 2019. The spilled wastewater was partially contained on farm property and returned to the
farm's manure management system. In addition, the damaged irrigation line was repaired to prevent
further discharges. This notice was required by North Carolina General Statutes 143-215.10C (h)(I). For
more information, please contact Michael Norris.