820556_NOV-2019-DV-0233 Response_20190613

KOOBA DAIRY INC.
June 13, 2019
Hand Delivered
North Carolina Department of Environmental Quality
Division of Water Resources
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, North Carolina 28301
Subject:
RECEIVED
JUN132019
DEQ-FAYETTEVILLE REGIONAL OFFICE
NOTICE OF VIOLATION/NOTICE OF RECOMMENDATION
FOR ENFORCEMENT — RESPONSE
Administrative Code 15A NCAC 2T .1304
NOV-2019-DV-0233
KooBa Dairy Inc. Facility No. 82-556, Permit No. AWC820556
Sampson County
Dear Mr. Trent Allen,
In response to your letter of the Notice of Violation/Notice of Recommendation for
Enforcement, we at KooBa Dairy, acknowledge and take full responsibility for the
discharge of our cows' manure into the drainage ditch while irrigating our fields on May
3, 2019.
This discharge is not something we take lightly as our mission statement and core values
address the importance of protecting our land and respecting our environment. KooBa
Dairy takes pride in the fact that it can recycle it's cows' manure to take part in practicing
sustainable agriculture. We work hard to ensure that the cow manure, which we recycle
and use as fertilizer, ends up on the fields to help our crops grow. KooBa Dairy has
policies in place during irrigation that the hydrants and pumps in use at the active
location sites are checked every 30 minutes. Unfortunately, the spillage occurred on a
field where irrigation was not active at that moment. After an irrigation event on May 1,
the irrigation reel that was used on this portion of our fields was brought back to our shop
for a minor repair, with the intention to be put back on that same section on the morning
of May 3. Therefor the existing cut off valves that we would normally have used to cut
off portions where irrigation is not active, were not closed.
Irrigation on May 3 began at 7:00am at hydrant 7. At 8:00am everything was still in
working order, and at around 9:30am we discovered the broken pipe at hydrant #42.
Upon discovery of the broken pipe we immediately began containing the spillage to the
best of our abilities by damming off the creek using two straw bales, and using a wheel
loader, moved sand from the field to completely block off the flow into the wooded area.
Once the creek was dammed off, we went further into the woods with shovels to create
more man-made dams to block off the stream to prevent it from entering the neighbor's
pond. Curtis Barwick was contacted immediately to assist us in following the proper
emergency procedure for when an event like this happens.

KOOBA DAIRY INC.
The owner of the pond was contacted and informed of the events as well, to ensure that
he was made aware of what had happened, and the actions KooBa Dairy took to
minimize harm to the pond. Once the spill was contained, we began pumping out the
ditch which we had blocked off. Using our diesel irrigation pump and a traveler irrigation
reel we pumped the wastewater back onto our cornfield, as it is part of our waste
utilization plan. Since this ditch is a drainage ditch, it would fill up with more water every
day - diluting what was left over. Because of this we continued to pump out the ditch for
another 4 days and continued monitoring the area for possible environmental damage
and/or adverse environmental effects.
KooBa Dairy took every effort possible to minimize any potential adverse effects of this
event, by removing 5 of our employees from their regular tasks on the farm to focus on
damming the ditch and the area in the woods. Our employees exerted physical, manual
labor, for several hours, by shoveling man-made dams in the wooded area and pumping
out the ditch.
Since the events of May 3, 2019, KooBa Dairy has taken the following steps to prevent
an incident such as this one from happening again:
• Reinforce our current protocols that cut off valves are being utilized at all times.
• Adding an additional cut off valve on the back field (cut off valve #7) and
upgrading two outdated valves (see attached map for location of cut off valves).
We immediately ordered 3 cut off valves, which were delivered on May 24, as
evidenced by copy of the invoice #40693. For a total of $1,813.28 (excludes labor
and installation with a backhoe).
• After consulting with Brock Equipment, a solution has been found to install a
custom-made low pressure cut off switch to our electric irrigation pump. Costs
still unknown.
• The broken PVC tee riser was replaced by a galvanized tee riser. In addition to
this KooBa Dairy will also be replacing two other outdated PVC risers with
galvanized risers, assuring a reliable system that will minimize the potential of
events such as this from occurring in the future. Total costs of materials
$1,692.61, see invoice #40188. (excludes labor and installation with a backhoe)
Based on KooBa Dairy's swift response and measures taken to minimize the potential
adverse effects on the environment both at the time of the incident as well as for the
future, along with our commitment to taking care of the environment, and our 10-year
violation free and clean record, we respectfully ask you not to pursue recommending a
civil penalty assessment to the Director of the Division.
Sincerely,
Wilma Koopman
OIC of KooBa Dairy

BROCK EQUIPMENT
C COMPANY
BROCK EQUIPMENT (BAILEY)
PO BOX 100 BAILEY, NC 27807
252-235-4111 252-235-4112
Invoice
40693
5/24/2019 11:39 AM
Customer - Type Charge
Acct# 116, KOOBA DAIRY INC.
1719 PENNY TEW MILL. RD.
PO# KLAUS
Salesman': Watson, Robbie
ROSEBORO , NC 28382 Tax ID: 704551
Notes _.. _... ,.
City Line Part#
Description
Core
List
Amount Extended Exch Tax
3 MAT 200RTD13
1 FRT FREIGHT
6' IPS SIZE RING-TITE RESILIENT
WEDGE VALVE
FREIGHT
0.00 650.00 560.94 1,682.82 N N
0.00 0.00 130.46 130.46 N N
0.00 650.00
Total Freight 130.46
Signed:
691.40 1,813.28
Non -Taxable 1,813.28
Taxable 0.00
Tax 0.00
Total 1,813.28
PLEASE REMIT ALL PAYMENTS TO: PO BOX 100 BAILEY, NC 27807
111111III 1111111III III
THANK YOU FOR YOUR BUSINESS!
lnv#: 40693 [1 of 1]

KOOBA DAIRY INC.
See attached:
- Copy Invoice # 40693
- Copy Invoice # 40188
- Map location cut off valves
- Copy Press Release presented to The Sampson Independent

NOTICE OF DISCHARGE OF ANIMAL WASTE
KooBa Dairy, 1719 Penny Tew Mill Rd, Roseboro had a discharge of approximately 13,000 gallons of
untreated wastewater from a broken pipe during an irrigation event. The discharge was on May 3, 2019
at approximately 8:00 am until 9:30 am. The wastewater entered a drainage ditch that leads to an
unnamed pond which drains to Coharie Creek which is a part of the Cape Fear river basin. Containment
and remediation efforts began immediately upon discovery. The incident was reported to NCDENR on
May 3, 2019. The wastewater was partially contained on farm property and returned to the farm's
manure management system. No irrigation occurred in this area until conditions were favorable to
prevent further discharges. This notice was required by NC General Statutes Article 21 Chapter
143.215.C. For more information, contact Klaas Koopman at [phone].
Chris Berendt,,
The Sampson Independent
Managing Editor
91➢-249-4619 )Direct Other? Line)
910-379-9547 )Mobile)
cberendt ocivitasmedia corn
ID9lN_ Main St.
Clinton, NC 2832E1
mere clintonnc.com