HomeMy WebLinkAbout820708_NOV-2021-PC-0463_20211106Ken Spell
484 Horse Pasture Rd
Salemburg, NC 28385
11/06/2021
Mr. Trent Allen
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
225 Green St, Suite 714
Fayetteville, NC 28301
Dear Mr. Allen,
In response to your Notice Of Violation NOV-2021-PC-0463 for Whitewoods Farm (82-0708)
dated September 30, 2021 and received by me on 11/05/2021, (my son signed for letter on
October 2 and failed to give letter to me), I submit the following:
1. Violation 1: Failure to calibrate all waster application equipment.
Extension agent Max Knowles performed the calibration of the waste application equipment on
September 17, 2021 and has been emailed to DWR staff Diane Harrison. In the future technical
specialist Nathan Bridgers will be assisting with all aspects of the waste application protocols
and record keeping. I will be working closely with Nathan Bridgers in conducting timely
calibrations of my waste application equipment in the future.
2. Violation 2: Failure to collect an analysis of a representative sample of the animal
waste to be applied in accordance with the time of application.
In the future technical specialist Nathan Bridgers will be assisting with all aspects of the waste
application protocols and record keeping. Nathan Bridgers has performed a waste analysis and
will be emailed to DWR staff Diane Harrison. Another waste analysis will be performed within a
week from today and a copy will be emailed to DWR staff Diane Harrison. I will be working
closely with technical specialist Nathan Bridgers in the future in collecting on time waste
analysis.
3. Violation 3: Failure to conduct a sludge survey accumulation in all lagoons every year.
Extension agent Max Knowles performed a sludge survey for both lagoons on September 17,
2021 and report has been emailed to DWR staff Diane Harrison. In the future technical
specialist Nathan Bridgers will be assisting with all aspects of the waste application protocols
and record keeping and I will be working closely with him in conducting timely sludge surveys in
the future.
4. Failure to record all irrigation and land application events(s) including hydraulic
loading rates, nutrient loading rates and cropping information.
In the future technical specialist Nathan Bridgers will be assisting with all aspects of the waste
application protocols and record keeping. I will be working closely with Nathan Bridgers on
completing the IRRI & IRR2 forms for the pumping events using the calibration and nitrogen
concentration. I am working with Nathan Bridgers on getting records up to date and will be
working/talking/emailing records to DWR staff Diane Harrison.
5. Failure to have a representative Standard Soil Fertility Analysis conducted.
In the future technical specialist Nathan Bridgers will be assisting with all aspects of the waste
application protocols and record keeping. I will be working closely with Nathan Bridgers on
conducting soil fertility analysis every year. A current Soil Analysis will be performed this week
and emailed to DWR staff Diane Harrison.
6. Failure to have a protective vegetation cover on all earthen lagoon/storage pond
embankments, berms, pipe runs and storm water diversions with the goal of preventing
erosion.
I am working closely with engineers at Smithfield Hog Production to correct the eroded areas
around discharge pipes and reseeding grass on the lagoon tops. I will be working closely with
technical specialist Nathan Bridgers in these areas as well. Removal of trees of lagoon has
been completed.
7. Failure to keep collection, treatment and storage facilities, and the land application
equipment and fields properly operated and maintained at all times.
Fields are being bush hogged now and will be completing this process this week and fields will
be sprayed and documentation will be sent to DWR staff Diane Harrison. I will be working with
technical specialist Nathan Bridgers and extension agent Max Knowles closely in the future
spraying spray fields for weeds in a more timely manner. The spray fields (Coastal Bermuda
Hay Fields) have been leased out to local cattle farmer and were sprayed once at the beginning
of the summer with Cimarron herbicide. However, the herbicide worked in some areas and did
not work as well in other areas. I cancelled the cattle farmer's lease this year and I will be
managing the weed control and crop harvesting for the spray fields in the future, with Nathan
Bridgers and Max Knowles assistance.
I hope that my answers to the violations and planned changes will be sufficient so as to avoid a
fine. I will be managing all aspects of waste disposal system to the highest level in the future. To
manage at a higher level, I will be working closely with technical specialist Nathan Bridgers and
extension agent Max Knowles. Thank you for your attention to this matter.
Sincerely,
Ken Spell