310017_Add-Info Response_20220418

April 14, 2022
Christine Lawson
NCDEQ Division of Water Resources
1601 Mail Service Center
Raleigh, NC 27699-1601
Subject: Response to Additional Information Request
Application No. AWS310017/AW1310017
DM Farms Sec 2 Sites 1-4
CAVANAU G H
Stewardship Through Innovation
Modification to Swine Digester Animal Waste Management System
Dear Ms. Lawson,
Cavanaugh & Associates, P.A., on behalf of the permittee, has reviewed your comments dated April 8,
2022 for the permit modification for the subject facility, and has developed responses and additional
supporting information to address each item in your comments. For your convenience, we have
repeated the comments below in bold font, followed by the responses in italicized font.
1. Permit Type Requested — Please clarify if the proposed modification is requested under the
current Individual Permit or General Permit. Are you requesting rescission of the alternate
permit? Do you wish to withdraw the AW1310017 renewal application received September 10,
2021?
Response:
The permittee, and applicant, wishes to proceed with a permit modification under the General
Permit, and upon issuance of the updated Certificate of Coverage under the General Permit,
proceed with recission of the Alternate Permit and withdrawal of the renewal application
received September 10, 2021.
2. Liner design information — Please provide all available design information for the existing earthen
liner for the proposed Digesters A and B (lagoons 2-2 and 2-3, respectively).
Response:
All available liner design information for the existing earthen liner has been included with this
response. The liner design information was provided with the necessary liner certification
documentation upon completion of construction, in or around 1995, and has been accepted as
having been provided as required in each subsequent permit renewal by the Division, de facto.
The applicant is unable to locate copies of the original design document used over twenty-five
years ago, but is confident that the information regarding the liner was found to have been
acceptable by the Division now through numerous permit renewals.
3. Land Application/Irrigation Map — Please provide a land application/irrigation map that aligns
with the Waste Utilization Plan.
Response:
Please see additional map information included with this response.
Page 1 of 3

4. Watershed Classification Map —The Watershed Classification Map submitted shows the location
of a proposed NEW digester that is not indicated anywhere else in the application package. Please
clarify.
Response:
Please see revised Watershed Classification Map included with this response.
5. Design Volumes/Calculations —The design volumes shown for Lagoon 2-2 (Digester A) and Lagoon
2-3 (Digester B) are the same. The (West) Volume Calculations sheet shows Digester A (lagoon "2-
2") in the table heading. The (East) Volume Calculations sheet shows Digester A (;lagoon "2-3") in
the table heading. The data in both tables are identical; however, the site plan clearly shows that
the two lagoons are not identical in construction. Please provide clarification regarding the
discrepancy, particularly for the Digester Volume Calculations which might better be based on the
as -built designs.
Response:
The volume calculations for Lagoon '2-3'should refer to Digester B instead of Digester A; the
typos have been corrected and revised and corrected calculations are submitted with this
response. That being said, the volume calculations correctly use the dimensions given from the
original lagoon designs; Lagoon '2-2' was approved by Neal Tucker on 1994-10-27 and gives
lagoon dimensions of 500'x450'x11 ' and Lagoon '2-3' was approved by Neal Tucker on 1994-10-
27 and gives lagoon dimensions of 500'x450'x11' (the some date and reviewer as Lagoon '2-2') .
6. Tank Digesters — Please describe how existing tank digesters will be used, decommissioned or
officially closed.
Response:
The existing tank digesters will be emptied of their contents and will not continue to receive
manure or be used for the anaerobic digestion of manure upon placing the proposed covered in -
ground digesters into service. The tanks will remain in place and will not be demolished, but will
not be physically connected to the manure piping system (air gap installed). ). The permittee
desires the tanks to remain in the permit for effluent storage that can be used in extreme
weather or emergency situations.
7. Operation & Maintenance —Contact Information —The contact information you have listed for me
is out of date, by some years. My current phone number is 919-707-3664. Please verify that
information for all contacts is accurate and update the O&M Contact List.
Response:
Please see updated Appendix A of the Operation & Maintenance Plan, with updated and current
contact information included, included with this response.
8. Stormwater Outlet —Please provide atypical detail for outlet for stormwater removed from
digester cover. Please also indicate location.
Response:
Please see Stormwater outlet detail included with this response. It should be noted that the
design low point in the lagoon cover will be determined by the cover supplier/installer, and
provided to the permittee as a submittal drawing prior to installation. Therefore, the specific
Page 2 of 3

location depicted in the detail provided may change; and if so, such change will be reflected in
the record drawings upon completion of construction.
9. Gas Utilization — Please provide information for the intended onsite and/or offsite use of the
biogas. The current designated use is electrical generation. If this is not the case, please provide
information regarding the decommissioning of generator and gas conditioning equipment.
Response:
At this time, the applicant has no specified nor contracted on -site nor off -site use of the biogas.
In the interim, the biogas will be vented to atmosphere.
10. Clarification of Flare Model — Please verify that a separate flare will be kept on -site for use for
each digester — a total of two. Where will these flares be stored? Will they be tested periodically?
Response:
A candlestick flare will be kept on site, at a location that is protected and chosen by the farm
owner based on ready accessibility, for use at each digester. There are no plans nor need to test
the flare on any regular basis, as the biogas will be vented to atmosphere should accumulated
biogas be stored for any extended duration.
11. Gas Generation Estimate — Please submit an estimate for the daily volume of biogas to be
generated by the proposed Digester.
Response:
The daily volume of biogas varies based on animal stocking numbers, animal age, and climatic
variations; is considered confidential business information by the applicant, and we are unable to
find reference to the requirements for providing biogas generation estimates when seeking a
modification to the Permit of the subject facility. If our interpretation is in error, please provide
the reference to the applicable rule or statute.
Thank you for your continued efforts to review this permit application and supporting information.
Please do not hesitate to contact our office should you have any questions, comments, or require any
additional information.
Regards,
Cavanaugh & Associates, P.A.
illiam G. Simmons, Jr., P.
Attachments
cc: Ironside Investment Management, LLC, via AJ Linton
Jeff P. Cappadona, P.E., Cavanaugh & Associates, P.A.
Page 3 of 3

1
n
75,
1
.
1 A�
II '
41 6

(#2) UNNAMED
TRIBUTARY TO
MURPHEYS CREEK
EX. 0 (#1) UNNAMED
LAGOON TRIBUTARY TO
O MURPHEYS CREEK
0
EX.
LAGOON
1%7
c:::3
C=:3
O
O
0 EX.
O LAGOON
SEC 2 FARMS \ '
0 EX.
0 LAGOON
O
O
O
r
�I
(� (#3) UNNAMED EXISTING
\ \ TRIBUTARY TO LAGOONS TO
MURPHEYS CREEK BE CONVERTED
TO ANAEROBIC
DIGESTER
NAME OF STREAM
ISTREAM CLASS
STREAM INDEX
1
UT TO MURPHEYS CREEK
C; Sw
18-74-29-0.5
2
UT TO MURPHEYS CREEK
C; Sw
18-74-29-0.5
LATITUDE: 34°52'04.0"N
LONGITUDE: 78°09'06.80"W ��

WATERSHED CLASSIFICATION MAP
BF GRADY BIOGAS COLLECTION
DM FARMS SEC 2—SITES 1-4
OWNER: IRONSIDE INVESTMENT MGMNT, LLC
CAVANAUGH
Stewardship through innovation
LOCATION
NOT TO SCALE
Cavanaugh & Associates, P.A. 1213 Culbreth Dr.
Wilmington, NC 28403
[phone] Fax: [phone] www.cavanaughsolutions.com
PROJECT if: BE19.006
DRAWN BY: LJL
BD 1: SCALE: 1"=600' 1
DATE: 2020-03
REVISION 1.0 -APRIL 14, 2022
CORRECTED NOTATION OF CONVERSION OF EXISTING LAGOONS TO ANAEROBIC DIGESTER; REMOVED
PROPOSED NEW DIGESTER

DM Farms Sec 2 Sites 1-4 (East) Volume Calculations
Project:
Project No
Date:
DM Farms Sec 2 Sites 1-4 (East) Location: Duplin & Sampson County, NC
BE.19.006 Client: Smithfield
2021-9-23
Freeboard Elevation
Digester Required Volume:
Digester Design Volume (@ freeboard):
% Required:
Di
ester B Volume (Lagoon '2-3'
Elevation ft
Area sf
Incr. Vol cf
Cumul. Vol cf
27.00
166,656
-
-
28.00
171,600
169,128
169,128
29.00
176,616
174,108
343,236
30.00
181,704
179,160
522,396
31.00
186,864
184,284
706,680
32.00
192,096
189,480
896,160
33.00
197,400
194,748
1,090,908
34.00
202,776
200,088
1,290,996
35.00
208,224
205,500
1,496,496
36.00
213,744
210,984
1,707,480
37.00
219,336
216,540
1,924,020
38.00
225,000
222,168
2,146,188
506,160 cu ft.
1,707,480 cu ft.
337%
%.

H
Design By: JPC
Checked By: WGS
Note: The dimensions
and volumes shown are
provided based on the
lagoon design for the '2-
3' lagoon, approved by
Neal Tucker on 1994-10-
27
1 of 2

Overall Farm Volumes: (cu.ft.)
Treatment
Excess Wash Water
Rainfall in excess of evaporation
Storm Storage
Daily Inflow
Total
4
CAVANAU G H
Stewardship Through Innovation
Existing
Configuration
Existing Lagoon '2-3'
Existing Lagoon '2-4'
Vol. Required`
Vol. Provided"
Efficiency
Vol. Required`
Vol. Provided"
Efficiency
1,069,200
1,069,200
100%
1,069,200
1,069,200
100%
171,529
171,529
100%
0
0
N/A
156,737
156,737
100%
149,042
149,042
100%
167,933
167,933
100%
153,301
153,301
100%
261,106
358,561
137%
261,106
436,017
167%
1,826,505
1,923,960
105%
1,632,649
1,807,560
1
111%
Note: The existing volumes shown above
are provided based on the lagoon calculations
for this farm, approved by Neal Tucker on
1994-10-27
Note: The existing volumes shown above are
provided based on the lagoon calculations for this farm,
approved by Neal Tucker on 1994-9-25
Total Required
2,138,400
171,529
305,779
321,234
522,212
3,459,154
Proposed Configuration (Digester + Storage Lagoon)
Volume Required*
Volume Provided*
Digester B
(i.e. '2-3')
Existing Lagoon
'2-4'
otaDigester
Required
B
(i.e. '2-3')
Existing Lagoon
'2-4'
I ota
Provided
Efficiency
Treatment
1,069,200
1,069,200
2,138,400
1,707,480
430,920
2,138,400
100%
Excess Wash Water
171,529
0
171,529
0
171,529
171,529
100%
Rainfall in excess of evaporation
0
149,042
149,042
0
149,042
149,042
100%
Storm Storage
0
153,301
153,301
0
153,301
153,301
100%
Daily Inflow
261,106
1 261,106
1 522,212
1 0
1 902,768
1 902,768
1 173%
Total
1,501,835
1 1,632,649
13,134,4841
1,707,480
1 1,807,560
1 3,515,040
1 112%
Total Required Temporary Storage:
Existing
Proposed
Excess Wash Water
171,529
171,529
Rainfall in excess of evaporation
305,779
149,042
Daily Inflow
522,212
522,212
Total
999,520
842,783
Days of Storage:
Existing Lagoon'2-4' Revised Elevations:
Zone Volume
I Cumulative Vol.
I Elevation
Treatment
430,9201
430,920
83.67
Temporary
1,223,339
1,654,259
90.26
Storm
153,301
1,807,560
91.00
of Dike Elev = 92
Top of Storm Elev = 91 (1807560 cf)
Top of Temp Storage Elev = 90.26 (1654259 cf) (Start Pump)
Top of Treat Elev = 83.67 (430920 cf) (Stop Pump)
Finished Bottom Elev = 81
Note: Elevations and volumes are based on the same datum and sizing information as the lagoon calculations for this farm,
approved by Neal Tucker on 1994-9-25
2 of 2

Appendix A: Contact Information
Project Management and Equipment Service Providers:
Management & Equipment
CompanyProject
Contact/Local Service
Influent Pump Station
Lee Brock
Brock Equipment Company
lee@ brockeguipment.com
[phone]
Anaerobic Digester Cover
Plastic Fusion Fabricators, Inc.
Larry Hice
[e-mail]
[phone]
Mixing Pump Station
Lee Brock
Brock Equipment Company
lee@ brockeguipment.com
[phone]
Transfer Pump
Lee Brock
Brock Equipment Company
[e-mail]
[phone]
Flare
ProPump & Controls Inc.
Jeff McGuire
Work: [phone]
Cell: [phone]
[e-mail]
Mechanical Installation & Controls (Biogas)
ProPump & Controls Inc.
Jeff McGuire
Work: [phone]
Cell: [phone]
[e-mail]
Mechanical Installation & Controls (Manure
Murphy Family Ventures, LLC
collection, Digester, Effluent, & Irrigation)
Dan Best
Self -Performed by Permittee
Cell: 910-271-0362
[e-mail]
Anaerobic Digester System O&M Page 13 of 16

Regulatory and other Agencies:
MOP Location
Christine Blanton
Lawson
DWQ, AFO Permitting Raleigh, NC
and Compliance
[phone]
Anaerobic Digester System O&M Page 14 of 16

���`�-��'✓ 1111 `t e..�✓' � �> > �1 y0r ^�, '1/1�F�7 �t..:'Y.4 "( `Y� iFlJz"�"i�-�y—�����i
t :':k:•a` o. d IP5-2e
INV w.�: .y STORMWATER DRAIN PIPE & OUTLET
M1T t ! 1 1 •� .� (EXISTING) c PROTECTION
Nt1 1 9 1 1. qry}e r^ ...y _ _ �...�1 �(1.el1 •� a rd ,I ii ifs �.'M1 •`1i N.
i r•� i 1.1 �• v IPS-3B
EXISTING LAGOON �2-2' _ �rC PIPE
TO BE CONVERTED TO / q"'a (EXISTING)
ANAEROBIC DIGESTER-_.ro _
tis
•� TOP OF DIKE 137.00'_ IPSING)
INV
(EXIEXISTING FREEBOARD 136.00'
'� ST}.
NEW FREEBOARD 13500' e
JFFE 14000t l o z zz, 0 11iIr� a�Ly J:'n i!
EFE 14000 - �zm� { I111{�-1v cl\ 1 a,, �. a`T•
FE 14000'
'4
�/
r.1., .. _. �i-r%,.�', i ,.,. ,.,. N� �'C 01111 �1�,�_-.,..�-n-%,�••�f .,. r(,
LOCATION MAP 2
SCALE: NOT TO SCALE B jDl
DRAIN PIPE SHALL BE 4" CORR. HDPE OR EQUIVALENT.
STORMWATER DRAIN SHALL HAVE MIN. 0.25% SLOPE.
DRAIN LOCATION SHOWN AS APPROXIMATE. EXACT DRAIN PUMP
LOCATION AND OUTLET TO BE DETERMINED UPON RECEIPT AND
APPROVAL OF COVER SUBMITTALS.
OUTLET SHALL EXTEND MIN 10' BEYOND OUTSIDE TOE OF DIKE.
LACE WASHED
TONE AROUND
IPE AS DIRECTED
Y THE ENGINEER
EQUAL
MAINTENANCE
INSPECT OUTLET STRUCTURES WEEKLY AND AFTER SIGNIFICANT (1" OR
GREATER) RAINFALL EVENTS TO SEE IF ANY EROSION AROUND OR
BELOW THE OUTLET HAS TAKEN PLACE, OR IF STONES HAVE BEEN
DISLODGED. IMMEDIATELY MAKE ALL NEEDED REPAIRS TO PREVENT
FURTHER DAMAGE.
OUTLET PROTECTION 1
SCALE: NOT TO SCALE B D 1
STORMWATER
OUTLET
DETAIL
PROJECT #: BE.19.0G.
DRAWN BY: WGS
ON -FARM
DM FARMS
B I O G A S
SEC 2
SYSTEM
SITES 1- 4;
2-2
CAVANAU G H
Solutions through integrity and partnership
BD1
D U P L I N &
SAMPSON COUNTY,
NC
Cavanaugh & Associates, P.A. PO Box 11197
Winston3alem, N0 gh1 l
1-871-551-8923 wwwca .vanaughsolutions.com
DATE: 4/14/2022

�v = 1
ill/gllriil \ti/ s�
ltJd!/f Jllr`\\\, 1�`',. �'vRQ�\--"'� �'� STORMWATER DRAIN PIPE&OUTLET
i 7fll�l����v'—�—� _— l� �L�� i6'• z'��: PROTECTION
���1VA r�i V 1 VA��A I "si rrV111s 1�
l FEE 130.00'
Yt` \ 111lII(11 1S lIlY r
� Tull.,✓' \ Yt lr),rlr ,,�\I/
FFE 130.00,1;./•� \ \ 1 (EXISTING LAGOON '2-3'
' _ l\\ \\ II IVIVr/f TO BE CONVERTED TO
/ )ANAEROBIC DIGESTER
TOP OF DIKE 119.00•
FEE 130. "', it l \\ III I I EXISTING FREEBOARD 118.00'
NEW FREEBOARD 117.00'
ll FEE 130.00'
tl\ 'FFE 130_DD' Y/ III"IIUI�lI�
'IPs-4D
J r` r/I PIPE
r / o1j (EXISTING)
f//!)/// /1 !/
r lv /{ / ! J! g� IPS-2D +
I(l/ //j fl f IPS-1C .J SI{ ! (EXISTING) l . i•�y�l S\.
/! Y (EXISTING .. .�
j/ilf/1)!!I ! t t I'WET WELL
+1 !
rrl//f1)/%l1/j 1f/ I) I��\ r. \ 1t /1
_ l�//ii/lil +f / J'' � 1 > l 1 rr / � /r' � � �•.. t` � .
b{lrf .i ]
LOCATION MAP r2
SCALE: NOT TO SCALE B D 1
NOTES:
1. DRAIN PIPE SHALL BE 4" CORR. HDPE OR EQUIVALENT.
2. STORMWATER DRAIN SHALL HAVE MIN. 0.25% SLOPE.
3. DRAIN LOCATION SHOWN AS APPROXIMATE. EXACT DRAIN PUMP
LOCATION AND OUTLET TO BE DETERMINED UPON RECEIPT AND
APPROVAL OF COVER SUBMITTALS.
4. OUTLET SHALL EXTEND MIN 10' BEYOND OUTSIDE TOE OF DIKE.
LACE WASHED
TONE AROUND
IPE AS DIRECTED
Y THE ENGINEER
#57 WASHED STONE,
2" THICK
MAINTENANCE
INSPECT OUTLET STRUCTURES WEEKLY AND AFTER SIGNIFICANT (1" OR
GREATER) RAINFALL EVENTS TO SEE IF ANY EROSION AROUND OR
BELOW THE OUTLET HAS TAKEN PLACE, OR IF STONES HAVE BEEN
DISLODGED. IMMEDIATELY MAKE ALL NEEDED REPAIRS TO PREVENT
FURTHER DAMAGE.
OUTLET PROTECTION1
SCALE: NOT TO SCALE B D 1
2:1 SLOPE
MIRAFI 50OX FILTER
FABRIC OR APPROVED
EQUAL
STORMWATER
OUTLET
DETAIL
PROJECT# BE19.002
DRAWN BY: WGS
ON —FARM
DM FARMS
B I O G A S
SEC 2
SYSTEM
SITES 1-4;
2-3
CAVANAU G H
Solutions through integrity and partnership �`
BD1
D U P L I N &
SAMPSON COUNTY 7
NC
Cavanaugcia h & Assotes, P.A. PO Box 11197
Winston-Salem• N0gh1 1
1-877-551-8923 www._anaughsolutions.com
DATE: 4/14/2022