710006_DV-2017-0080_20180118

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Water Resources
Environmental Quality
January 18, 2018
TO: Christine Lawson, Program Manager
Animal Feeding Operations Permitting -
FROM: Kristin Miguez, Environmental Specialist
Wilmington Regional Office
V
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
THROUGH: Morella Sanchez -King, Acting Wat&r Quality Regional Operations Section
Supervisor
Wilmington Regional'Office
SUBJECT: Enforcement Report
Greenwood Livestock, LLC
Greenwood Finishing #3 Farm
Facility Number: 71-06
Pender County
Please find attached the subject enforcement report, which concludes that Greenwood Livestock,
LLC violated Condition I.1. of the General Permit AWG100000 for failure to prohibit a
discharge to surface waters of the State and Condition 11.5. of the General Permit AWG100000
for failure to apply animal waste to a land application field which would not result in. excessive
ponding of any runoff during any given application event. -
On August 31, 2017, the Wilmington Regional Office (WIRO) received a complaint regarding
suspected animal waste in a tributary immediately downstream from the Greenwood Finishing
Farm #3. DWR staff inspected the farm on August 31, 2017 and again on September 1, 2017, and
found discharged animal waste and evidence of a fish kill mi surface waters of a tributary to Sills
Creek. Two dead fish were seen in the creek immediately downstream from the farm. Samples
were collected -and pictures taken. of the discharge in surface waters.
A Notice of Violation and Recommendation for Enforcement (NOV-2017-DV-0259) was issued
on October-13, 2017, for above mentioned violations to the General Permit AWG100000.
It is recommended that appropriate civil penalties be assessed in accordance with G.S. 143-
215.6A(a)(2). It is also recommended that all of the enforcement costs incurred in the
��Nothfng Compares7-_:,
State of North Carolina I Environmental Quality
1611 Mail Service Center Raleigh, North Carolina 27699-1611
919-707-9000

investigation be recovered in,the amount of $2431.47 pursuant to G.S. 143-215.3(a)(9) and G.S.
14313-282.1(b)(8).
If you have any questions, please contact me -at 910-796-1387.
cc: Wilmington Regional Office CAFO'files
Enc: Notice of Violation dated October 13, 2017
Incident Synopsis
Finding and Decisions
Civil -Penalty Assessment
G:\WQ\Shared\ANIMALS\PENDER\2017\71-06 NOVREF\2017 Enforcement Package .

INCIDENT SI'NOPSIS — CASE NO: DV-2017-0080
ENFORCEMENT ACTION / CIVIL PENALTIES
FARM NAME: Greenwood Finishing #3
VIOLATOR NAME: Greenwood Livestock, LLC
COUNTY: Pender
CASE BACKGROUND
August 31— Complaint
PERMIT NO: AWS710006
FACILITY NO: 71-06
OFFICE: WIRO
WIRO received information on a complaint:
N WiRO received call from Martin McLawhorn (NCDA) about a reported discharge
of suspected animal waste in a nearby tributary.
N WiRO contacted Sam Edwards with NCDA since Pender is part of the Pilot
Program County.
N WiRO also contacted Curtis Barwick to gain access to the farm.
/1 WiRO arrived at the farm and met with Curtis Barwick (Technical Specialist),
Kevin Weston (Murphy Brown) and David Naylor (farm manager).
August 31, 2017 — Inspection
WiRO arrived at the site at 4:45 p.m. to begin the inspection at the Greenwood Finishing #3
Farm and found:
N Suspected animal waste was observed in a tributary of Sills Creek (at crossing on
Raccoon Road).
N Suspected animal waste was observed ponded, running off land application fields
and into adjacent ditches.
4 Samples (# 1 and #2) were taken from the adjacent ditches with photos of the
incident.
N WIRO left the site at 6:30 pm due to approaching storms and darkness. An
estimated 1" of rain fell at the site on the night of 8/31/2017.
N Sample (0) taken at creek crossing on Raccoon Road.
N All samples were delivered to Environmental Chemists, Inc. in Wilmington, NC
at 8:45 pm on August 31, 2017.
September 1, 2017 — Inspection
WiRO returned to the farm to continue investigating the discharge:
N Inspection started at:
N Sample (#4) taken at the next downstream road crossing on Englishtown Road.
N WiRO received permission to access land adjacent to the Greenwood Finishing 43
farm so that we could follow the tributary from the road crossing up to the farm.
N WiRO followed the tributary to the farm property and took two additional
samples (45 and #6) and associated photos.
Additional sample (47) taken at crossing on Racoon Road (same location at
8/31/2017).
Greenwood Finishing #3
71-06

N Sample (48) taken at a location upstream of the discharge along the backside of
the lagoon.
N WiRO reviewed the farm's recent pumping records.
N All samples were delivered to Environmental Chemists, Inc. in Wilmington, NC
4:20 pm on September 1, 2017.
PHOTO COMMENTS
PHOTO NO.
COMMENT
1
Tributary at road crossing just downstream from the farm
2
Dead fish at stream crossing just downstream from the farm
3
Sample location 1
4
Sample location 2
5
Sample location 3
6
Sample location 4
7
Sample location 5
8
Sample location 6
9
Sample location 7
MAP 1
Map of farm and sample locations
All of the samples were analyzed for Fecal Coliform, Total Nitrogen, Ammonia Nitrogen and
Total Kjeldahl Nitrogen. The sample results are as follows:
Fecal
Ammonia
Total
Sample ID
Date Date
Coliform
Total Nitrogen
Kjeldahl
Sampled
(colonies/100
(mg/L)
(mom)
Nitrogen
ML)
(mom)
WQ Standard
Class C/Sw
-
< 200
-
-
-
waters *
Sample 1
8/31/2017
310
4.1
6.35
3.9
Sample 2
8/31/2017
48000
47.8
52.0
47.7
Sample 3
8/31/2017
28000
55.5
64.8
55.4
Sample 4
9/l/2017
2000
8.8
0.5
8.8
Sample 5
9/1/2017
3200
3.4
0.6.
2.8
Sample 6
9/1/2017
8000
2.8
0.5
2.8
Sample 7
9/1/2017
13000
2.9
0.5
2.4
Sample 8
9/l/2017
4900
1.8
<0.2
1.6
* NC 15A NCAC 02B Water Quality Standards for Surface Waters
Greenwood Finishing #3
71-06 2

October 13, 2017 — Notice of Violation with Recommendation for Enforcement
An NOV with Recommendation for Enforcement was issued on October 13, 2017 citing two (2)
violations: -
1. Failure in prohibiting a discharge to surface waters of the State in accordance with
Condition I.1. of the Swine Waste System General Permit No. AWG100000.
2. Failure in maintaining land application rates that would not result in excessive ponding or
runoff during any application event in accordance with Condition II. 5. of the Swine Waste
System General Permit No. AWG100000. -
Response to the Notice of Violation
Greenwood Livestock, LLC's response to the NOV was dated October 23, 2017 and received by
the Wilmington Regional Office on October 27, 2017.
PREVIOUS VIOLATIONS AND PENALTIES
It should be noted that the Notices and Penalties issued to this- facility that are listed below
occurred when the farm was under previous ownership. Greenwood Livestock, LLC took
ownership of the farm on March 21,. 2017.
0 February 2016 — A Notice of Violation with Recommendation for Enforcement was
issued to Bandit 3, LLC for failure in prohibiting a discharge to surface water of the State and
failure in maintaining land application rates that shall not result in excessive ponding or runoff.
June 2016 — Civil Penalty assessed
►/ March 2014 — A Notice of Violation with Recommendation for Enforcement was issued
to Bandit 3, LLC failure in maintaining land application rates that shall not result in excessive
ponding or runoff; failure to maintain a vegetative cover as specified; failure to have an Operator
in Charge (OIC) inspect the land site as often as necessary to insure that animal waste is land -
applied in accordance with the CAWMP; and failure to notify the appropriate Division Regional
Office within 24 hours following the first knowledge any discharge.
July,2014 — Civil Penalty assessed
Greenwood Finishing #3
71-06

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December 2017
Photo 5:.Sample 3, taken where the tributary of Sills Creek crosses Raccoon Road (downstream of the farm, same location as Photo 1).

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Violator:
County:
Case Number:
Permit Number:
DIVISION OF WATER RESOURCES
CIVIL PENALTY ASSESSMENT FACTORS
Greenwood Livestock, LLC
Pender
DV-2017-0080
AWS710006
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
Lab results indicate fecal coliform concentrations of 48,000 colonies/100mL in ditches
adjacent to the spray irrigation fields and 28,000 colonies/100mL in the downstream
tributary to Sills Creek. This is indicative of high concentrations of animal waste in the
water. Animal waste is high in BOD, Fecal Coliform, and can cause eutrophication
which can disrupt natural ecosystems. Two dead fish were observed just downstream ,
from the farm in the tributary to Sills Creek.
2) The duration and gravity of the violation;
Staff from the Wilmington Regional Office received a complaint of probable animal
waste in the tributary of Sills Creek on the afternoon of August 31, 2017. Animal waste
was evident in the tributary and the ditches surrounding the spray irrigation field when
we arrived on site later that afternoon (8/31/17) and again the following morning
(9/l/2017). The most recent pumping events prior to the receipt of the complaint had
occurred on the morning of August 30, 2017. Lab results indicate fecal coliform
concentrations of 48,000 colonies/100mL running off from the spray irrigation fields.
3) The effect on ground or surface water quantity or quality or on air quality;
Not evaluated. However, overapplication of animal waste on spray fields can cause
potential groundwater and aquifer contamination, have negative effect on the
environment, and disrupt natural ecosystems. Discharge of animal waste to surface
waters can lead to eutrophication, contributes to algae blooms, nutrient enrichment and
fish kills. Two dead fish were observed in the tributary to Sills Creek immediately
downstream from the farm on the afternoon of August 31, 2017.
4) The cost of rectifying the damage;
Unknown.

5) The amount of money saved by noncompliance;
The amount of money saved is not known. This event is suspected to have occurred as a
result of both a broken hydrant a couple of days before the application event and then
overapplication on the 8/30/17 pumping events. Items to consider: Irrigate more often in
shorter events to allow proper infiltration at agronomic rates; the time and materials
associated with the cost for the OIC to operate more frequent pumping events or the cost
to pump and haul waste; and the cost to install the preventative measures the owner plans
to implement (slam gates/water control structures in ditches, staff re-education, new
employees) and those they've already implemented since purchasing the farm in early
2017 (aerwaying the irrigation fields, new irrigation reels, repairing broken hydrants,
electrical and roofing work on the houses, etc.).
6) Whether the violation was committed willfully or intentionally;
Unknown. Staff from the Wilmington Regional Office received a complaint of probable
animal waste in the tributary of Sills Creek on the afternoon of August 31, 2017. Animal
waste was evident in the tributary and the ditches surrounding the spray irrigation field
when we arrived on site later that afternoon (8/31/17) and again the following morning
(9/l/2017). The farm owners mention all of the effort they've made to bring this farm
into compliance since taking ownership in March 2017 in a letter sent to DWR as part of
their response the Notice of Violation.
7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
The current owner has no record of previous violations or deficiencies at this farm. All
previous compliance issues were when the farm was under other ownership.
8) The cost to the State of the enforcement procedures.
The State's enforcement costs totaled $2431.47, as follows:
Staff
25.5 hours @ $33.97/hour
$866.24
Staff
15.5 hours @ $28.50/hour
$441.75
Samples
8 Sample Sets @ $125.00/sample
$1000.00
Mileage (3 trips)
252 miles @ $0.49/mile
$123.48
Total
$2431.47'
O l /l to 11b
Date
Supervisor a

;-1
ROY COOPER
Govenzor
MICHAEL S. REGAN
Secretarj,
S. JAY ZIMMERMAN
Director
October 13, 2017
CERTIFIED MAIL 70171450 0000 3937 2649
RETURN RECEIPT REQUESTED
Mr. Dean Hilton
Greenwood Livestock, LLC
PO Box 535
Elizabethtown, NC 28337
Subject: NOTICE OF VIOLATION with RECOMMENDATION FOR ENFORCEMENT
NOV-2017-DV-0259
Administrative Code 15A NCAC 2T . 13 04
Greenwood Livestock, LLC — Greenwood Finishing #3
Permit No. AWS710006
Pender County
Dear Mr. Hilton:
On August 31, 2017 and September 1, 2017, staff from the Wilmington Regional Office (WIRO) of the
Division of Water Resources (D)ATR) visited and inspected the permitted waste management system of the
Greenwood Finishing Farm #3 in response to a nearby reported discharge of suspected animal waste. We
appreciate David Naylor being present and assisting us with the inspection.
As a result of these inspections, you are hereby notified that, having been permitted to have a non -discharge
permit for the subject animal waste management system pursuant to 15A NCAC 2T .1304, you have been
found to be in violation of your Certified Animal Waste Management Plan (CAWMP) and the Swine Waste
System General Permit No. AWG100000 as follows:
Violation 1: ;
Failure in prohibiting a discharge to surface waters of the State in accordance with Condition I.1 of the
Swine Waste System General Permit No. AWG100000. Any discharge of waste that reaches surface waters
or wetlands is prohibited except otherwise provided in this General Permit and associated statutory and
regulatory provisions. Waste shall not reach surface waters or wetlands by runoff, drift, manmade
conveyance, direct application, and direct discharge or through ditches, terraces, or grassed waterways not
otherwise classified as state waters.
On August 31, 2017, the Wilmington Regional Office (WIRO) received -a complaint regarding suspected
a, animal waste in a tributaryjust downstream from the Greenwood Finishing Farm #3. DWR staff inspected
the farm on August 31, 2017 and again on September 1, 2017,. and found discharged animal waste in surface
waters of a tributary to Sills Creek. Samples were collected and pictures taken of the possible discharge in
surface waters.
�Nothtng Compares!: --,-
State of North Carolina I Environmental Quality I Water Resources
127 Cardinal Drive Extension, Wilmington, North Carolma 28405
910-796-7386

1
NOV-2017-DV-0259 i
October 13, 2017
Violation 2:
Failure in maintaining land application rates that shall not result in excessive ponding or runoff during any
given application event in accordance with Condition 11.5 of the Swine Waste System General Permit No.
AWG100000.
On August 31, 2017, staff inspected the land application field and observed animal waste ponding in several
ditches that are adjacent to the land application fields. On September 1, 2017, staff returned and walked the
ditches and channels between the farm property and the tributary to Sills Creek. Staff observed suspected
animal waste in those channels. Samples were collected and pictures taken of the discharge.
Required Corrective Action for Violations:
Please provide to our office, a description of the corrective action(s) you will take or have taken to resolve
this issue.
You may wish to contact your County Soil & Water Conservation District Office, County Extension office,
a qualified technical'specialist, and/or a professional engineer for any assistance they may be able to provide
you in order to prevent violations from occurring.
Be advised that this office is considering recommending assessment of civil penalties to the Director
of the Division of Water Quality for the above noted violations. These violations may result in civil
penalties of up to $25,000 per violation in accordance with North Carolina General Statute 143-
215.6A(a)(2). You may also be assessed for reasonable costs of the investigation in accordance with
North Carolina General Statute 143-215.3(a)(9). Your response will be forwarded to the Director
along with the enforcement package for his consideration. Be advised that the Division of Water
Quality may take further action in this matter including injunctive relief and permit revocation.
If you wish to provide additional information regarding the noted violation, request technical assistance,
or discuss overall compliance please respond in writing within ten (10) business days after receipt of this
Notice. A review of your response will be considered and you will then be notified of any civil penalties
that may be assessed regarding the violations. If no response is received in this Office within the 10-
day period, a civil penalty assessment may be prepared. Please include in your response all corrective
actions already taken and a schedule for completion of any corrective actions not addressed.
If you have any questions concerning this Notice, please contact me at (910) 796-73 86.
S mcerely,
IIJ�r
Jim gson, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ

{
0
NOV-2017-DV-0259
October 13, 2017
cc: WQROS CAFO Unit
Jason Turner, Pender County Soil and Water Conservation District
Kraig Westerbeek, Murphy Brown LLC
Curtis Barwick (via email)
Martin McLawhorn, NCDA
DWR Wilmington Animal Files 71-06
i
G:\WQ\Shared\ANEYIALS\PENDER\2017\71-06
i"
.r

GEENWOOD LIVESTOCK, LLC
PO BOX 535
ELIZABETHTOWN, NC 28337
September 2, 2017
Mr. David C. Powell
North Carolina Division of Water Resources
Water Quality Regional Operations Section
127 Cardinal Dr. Extension
Wilmington, NC 28405
Dear Mr. Powell,
In response to your visit to Greenwood Finishing #3 (71-6) on August 31 and September 1,
2017, 1 submit the following explanation of the incident, to the best of our knowledge.
On Wednesday, August 30,.2017 at 5:00 am, my farm manager conducted an irrigation event to
apply swine wastewater onto pulls 813 & 9B. This irrigation event lasted until 8:30 am. A second
event on the same two pulls was conducted from 9:30 am to 11:30 am. The field was dry
enough for the manager to pull the reels back out for a second, fast application. Our manager
observed no issues with these irrigation events on August 30th. My Operations Manager, David
Naylor, received a call on August 31st around 3:20 pm -stating that a discharge of wastewater
had occurred in the creek near our farm. Our Technical Specialist, Curtis Barwick, received a
call at 3:28 from Martin McLawhorn, NCDS&WC stating the same information. Both of these
men went to the farm and began walking ditches along with staff from Smithfield Foods to
determine if any waste had been released from our farm. It was determined that some
wastewater had entered a lateral ditch adjacent to pull 9B. This ditch empties into a main ditch
and it appeared that some wastewater may have had entered this main ditch which drains to
Sills Creek. By this time, you and Kristin Miguez had arrived and observed the ditches in
question along with Curtis, David and Kevin Weston from Smithfield. Also during your visit, farm
staff began pumping the pooled wastewater from the lateral ditch back into the waste storage
lagoon.
It appears that _the second application on August 30th of approximately 22,000 gallons of
wastewater brought the 9B pull to field capacity and a portion of that wastewater ran into the
ditch. An exact amount cannot be determined but after much discussion, you determined that
approximately 15,000 gallons of wastewater was_ discharged.
To prevent future discharges of wastewater, irrigation operators will visually observe all lateral
ditches around all fields in which irrigation is being conducted so that any release can be
avoided or immediately found so that application can be ceased upon discovery. We are also
considering adding water control structu res/fl ash board risers at the ditch outlets to contain any
water in the ditches.
I am enclosing a site sketch showing the path of the wastewater and a copy of the last waste
analysis performed from the lagoon. We engaged Environmental Chemists on September 1st to
sample and analyze the lagoon wastewater and await their results. A press release and public
notices have been distributed as per the permit requirements contained in Section III, 15 and
16.

We regret this incident took place and will make certain we more closely monitor all events and
notify DWR of any future discharges.
Thank you for your attention to this matter.
Sincerely,
Dean Hilton

GREENWOOD LIVESTOCK, LLC
POST OFFICE BOX 535
ELIZABETHTOWN, NC 28337
October 23, 2017
RECEIVED/NCDENR/M
Mr. Jim Gregson, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office DWR,NCDEQ OCT 2 7 2017
127 Cardinal Dr. Extension
Wilmington, NC 28405 Water Quality Regional
Operations Section
Dear Mr. Gregson,
Wilmington Regional Office
In response to your Notice of Violation (NOV-2017-DV-0259) of October 13, 2017 for
Greenwood Livestock, LLC Greenwood Finishing #3.farm (71-6), I submit the following:
Violation 1: Failure in prohibiting a discharge to surface waters of the State.
On Wednesday, August 30,, 2017 at 5:00 am, my farm manager conducted an irrigation event to
apply swine wastewater onto pulls 813 & 913. This irrigation event lasted until 8:30 am. A second
event on the same two pulls was conducted from 9:30 am to 11:30 am. The field was dry
enough for the manager to pull the reels back out for a second, short application. Our manager
observed no issues with these irrigation events on August 30th.
Our Operations Manager, David Naylor, received a call on August 31st around 3:20 pm stating
that a discharge of wastewater had occurred in the creek near our farm. He and Curtis Barwick
went to the farm and began walking ditches along with staff from Smithfield Foods to determine
if any waste had been released from our farm. It was determined that some wastewater had
entered a lateral ditch adjacent to pull 913. This ditch empties into a main ditch and it appeared
that some wastewater, may have had entered this main ditch which drains to Sills Creek.
Irrigation operators are now required to observe all ditches around the fields they 'are irrigating
to check for any run-off.
Furthermore, we are reviewing quotes from several metal fabricators to build water control
structures to be placed in farm ditches to contain any wastewater should an unfortunate incident
as this occur in the future. This approximate cost is $6,000. Although such structures are not
required by law, we believe they will go a long way towards protecting the environment, as I
explain below.
Violation 2: Failure in maintaining land application rates that shall not -result in excessive
ponding or runoff.
During the aforementioned irrigation events there was ponding in pull 9B and evidently some of
this ponded wastewater ran into the adjacent field ditch and made its way to Sills Creek. We
have re-educated staff regarding field Conditions, soil moisture and wind during irrigation so that
we do not have ponded wastewater in the future. This will minimize the chance of runoff. Also,
we have hired irrigation technician Marc Parispau to manage all irrigation activities on the
Pender County farms. Marc will re-train all personnel involved with irrigation also all will be
required to attend an Animal Waste Operator class. -

We would like for you to consider and know the history of this farm from the previous operators,
because through the efforts of Greenwood Livestock, our management has lessened the
environmental imprint this farm is making. Greenwood began discussions to purchase this farm
in the winter of 2016. DWR & DS&WC inspection reports will show the state of the farm before
we purchased it. Freeboards in the three waste lagoons were into the structural zone for a long
period of time. We assisted in applying waste before we bought the farm so as to minimize the
risk of overtopping or failure of the lagoons. Greenwood Livestock, LLC purchased this farm on
March 21, 2017. Greenwood operates four other hog farms and is managing these facilities with
a high level of attention to detail. We know that it is important to be good neighbors, good
operators and good stewards of our natural resources.
Some of our recent efforts in this regard are: Since purchasing the farm we spent $36,000 to
hire an airway contractor to apply waste and bring the lagoon levels to greater than 24 inches.
We subsequently bought two new irrigation reels and a new pumping unit at a cost of $69,000.
The farm, in general, and the irrigation system, in particular, was in disrepair and we spent over
$3,000 repairing all broken hydrants. Also, we have re -wired all the buildings and have replaced
roofs at an additional cost of over $35,000. In the spring we will plant cedars or Leland cypress
trees to provide a site and odor break for our neighbors.
Greenwood is a good neighbor at its other farms and plans to be at this farm as well. We are
committed to making things right at this farm and would appreciate you taking into account the
money and time we have spent to improve this farm. The spillover into the creek is an
aberration from the usual care and attention our employees and contracted help provides to us.
We believe in these circumstances that NCDEQ should abate the penalty and assess
Greenwood Livestock LLC for the enforcements costs.
Greenwood is remorseful about the runoff that occurred from our irrigation system and will do all
things possible to keep a spill from occurring in the future. If you need further information
regarding this please call me at 910-862-1718. Thank you for your attention to this matter.
Sincerel
Dean Hilton

t{- tSCY".a �`; :%•2e..a�l4',F.^^}Y t�:.':/si;
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Environmental Chemists, Inc.
6602 Windmill Way, Wilmington, NC 28405 C 910.392.0223 Lab a 910.392.4424 Fax
710 Bowsertotvn Road, Manteo, NC 27954 e 252.473.5702 Lab/Fax
255-A Wilmington Highway, Jacksonville, NC 28540 a 910.347.5843 Lab/Fax
ANALYTICAL & CONSULTING CHEMISTS , - [e-mail]
NCDENR-DWR Date of Report: Sep 15, 2017
127 N. Cardinal Drive Ext. Customer PO #:
Wilmington NC 28405 Customer ID: 09010049
Attention: David Powell Report #: 2017-13256
Project ID: 71-6
Lab ID Sample ID: Collect Date/Time Matrix Sampled by
17-31774 Site: sample 4 9/1/2017 10:13 AM Water D.Powell/K.Miguez
Test Method Results Date Analyzed
Ammonia Nitrogen EPA350.1 0.5 mg/L 09/06/2017
Fecal Coliform SM 9222D MF 2000 Colonies/100ml- 09/01/2017
Total Nitrogen (Ca1c)
Total Kjeldahl Nitrogen (TKN) EPA351.2 8.8mg/L 09/11/2017
Nitrate+Nitrite-Nitrogen EPA 353.2 < 0.02 mg/L 09/05/2017
Total Nitrogen Total Nitrogen 8.8 mg/L 09/14/2017
Lab ID Sample ID: Collect Date/Time Matrix Sampled by
17-31775 Site: sample 5 9/1/2017 10:50 AM Water D.Powell/K.Miguez
Test Method Results Date Analyzed
Ammonia Nitrogen EPA 350.1 0.6 mg/L 09/06/2017
Fecal Coliform SM 92220 MF 3200 Colonies/100mL 09/01/2017
Total Nitrogen (Calc)
Total Kjeldahl Nitrogen (TKN) EPA 351.2 2.8 mg/L 09/11/2017
Nitrate+ N itrite-Nitrogen EPA 353.2 0.59 mg/L 09/05/2017
Total Nitrogen Total Nitrogen 3.4 mg/L 09/14/2017
Lab ID Sample ID: Collect Date/Time Matrix Sampled by
17-31776 Site: sample 6 9/1/2017 11:20 AM Water D.Powell/K.Miguez
Test Method Results Date Analyzed
Ammonia Nitrogen EPA350.1
0.5 mg/L
09/06/2017
Fecal Coliform SM 9222D MF
8000 Colonies/100mL
09/01/2017
Total Nitrogen (Ca1c)
Total Kjeldahl Nitrogen (TKN) EPA351.2
2.8 mg/L
09/11/2017
Nitrate+Nitrite-Nitrogen EPA 353.2
< 0.02 mg/L
09/05/2017
Total Nitrogen Total Nitrogen
2.8 mg/L
09/14/2017
Report #-: 2017-13256 Page 1 of 2

Environmental Chemists, Inc.
° 6602 Windmill Way, Wilmington, NC 28405 a 910.392.0223 Lab ° 910.392.4424 Fax
710 Sowsertown Road, Manteo, NC 27954 m 252.473.5702 Lab/Fax
sM 255-A Wimington Highway, Jacksonville, NC 28540 • 910.347.5843 Lab/Fax
ANALYTICAL & CONSULTING CHEMISTS
[e-mail]
NCDENR-DWR
Date of Report: Sep 15, 2017
127 N. Cardinal Drive Ext.
Customer PO #:
Wilmington NC 28405
Customer ID: 09010049
Attention: David Powell
Report #: 2017-13256
Project ID: 71-6
Lab ID Sample ID:
Collect Date/Time Matrix Sampled by
17-31777 Site: sample 7
9/1/2017 12:25 PM Water D.Poweli/K.Miguez
Test
Method
Results Date Analyzed
Ammonia Nitrogen
EPA 350.1
0.5 mg/L 09/06/2017
Fecal Coliform
SM 9222D MF
13000 Colonies/100mL 09/01/2017
Total Nitrogen (Cale)
Total Kjeldahl Nitrogen (TKN)
EPA351.2
2.4 mg/L 09/11/2017
Nitrate+Nitrite-Nitrogen
EPA 353.2
0.49 mg/L 09/05/2017
Total Nitrogen
Total Nitrogen
2.9 mg/L 09/14/2017
Lab ID Sample ID:
Collect Date/Time Matrix Sampled by
17-31778 Site: sample 8
9/1/2017 12:45 PM Water D.Powell/K.Miguez
Test
Method
Results Date Analyzed
Ammonia Nitrogen
EPA 350.1
< 0.2 mg/L 09/06/2017
Fecal Coliform
SM 9222D MF
4900 Colonies/100mL 09/01/2017
Total Nitrogen (Cale)
Total Kjeldahl Nitrogen (TKN)
EPA 351.2
1.6 mg/L 09/11/2017
Nitrate+Nitrite-Nitrogen
EPA 353.2
0.21 mg/L 09/05/2017
Total Nitrogen
Total Nitrogen
1.8 mg/L 09/14/2017
Comment:
Reviewed by:
ti
Reoort#:: 2017-13256 Paae 2 of 2

ENVIRONMENTAL CHEMISTS, INC F�9;"' Way &2-0�3FAX9910-M 28405
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Environmental Chemists, Inc.
1 11 6602 Windmill Way, Wilmington, NC 28405 • 910.392.0223 Lab ' ° 910.392.4424 Fax
710 Bowsertown Road, Manteo, NC 27954 a 252.473.5702 Lab/Fax
255-A Wilmington Highway, Jacksonville, NC 28540 ° 910.347.5843 Lab/Fax
ANALYTICAL & CONSULTING CHEMISTS infoQenvironmentalchemists.com
NCDENR-DWR Date of Report: Sep 19, 2017
127 N. Cardinal Drive Ext. Customer PO #:
Wilmington NC 28405 Customer ID: 09010049
Attention: David Powell Report #: 2017-13135
Project ID: 71-6
Lab ID Sample ID: Collect Date/Time Matrix Sampled by
17-31465 Site: Sample 1 8/31/2017 5:45 PM Water D.Powell/K.Miguez
Test Method Results Date Analyzed
Ammonia Nitrogen
SM4500 NH3 C
6.35 mg/L 0911512017
Fecal Coliform
Incubation time < 22 hr.
SM 9222D MF
310 Colonies/100mL 08/31 /2017
Total Nitrogen (Cale)
Total Kjeldahl Nitrogen (TKN)
EPA351.2
3.9 mg/L 09107/2017
Nitrate+Nitrite-Nitrogen
EPA 3532
0.18mg/L 09/05/2017
Total Nitrogen
Total Nitrogen
4.1 mg/L 09/11/2017
Lab ID Sample ID:
Collect Date/Time
Matrix Sampled by
17-31466 Site: Sample 2
8/31/2017 5:55 PM
Water D.Powell/K.Miguez
Test
Method
Results Date Analyzed
Ammonia Nitrogen
SM 4500 NH3 C
52.0 mg/L 09/15/2017
Fecal Coliform
SM 9222D MF
48000 Colon ies/100mL 08/31/2017
Incubation time < 22 hr.
Total Nitrogen (Cale)
Total Kjeldahl Nitrogen (TKN)
EPA351.2
47.7 mg/L 09/07/2017
Nitrate+Nitrite-Nitrogen
EPA 353.2
0.13 mg/L 09/05/2017
Total Nitrogen
Total Nitrogen
47.8 mg/L 09/11/2017
Report #.. 2017-13135
Pone 1 'f 7

"r
Environmental Chemists, Inc. ` -
Q Q 9 6602 lkrindmill Way, Wilmington, NC 28405 ° 910.392.0223 Lab • 910.392.4424 Fax
C� 710 Bowsertown Road, Manteo, NC 27954 • 252.473.5702 Lab/Fax
255-A Wilmington Highway, Jacksonville, NC 28540 m 910.347.5943 Lab/Fax
ANALYTICAL & CONSULTING CHEMISTS [e-mail]
r
NCDENR-DWR Date of Report: Sep 19, 2017
127 N. Cardinal Drive Ext. Customer PO #:
Wilmington NC 28405 Customer ID: 09010049
Attention: David Powell Report #: 2017-13135
Project ID: 71-6
Lab ID Sample ID: Collect Date/Time Matrix Sampled by
17-31467 Site: Sample 3 8/31/2017 6:39 PM Water D.Powell/K.Miguez
Test Method Results Date Analyzed
Ammonia Nitrogen SM4500 NH3 C
64.8 mg/L
09/15/2017
Fecal Coliform SM 9222D MF
Incubation time < 22 hr.
28000 Colonies/100mL 08/31/2017
Total Nitrogen (Calc)
Total Kjeldahl Nitrogen (TKN) EPA351.2
55.4 mg/L
09107/2017
Nitrate+Nitrite-Nitrogen EPA353.2
0.14mg/L
09/05/2017
Total Nitrogen Total Nitrogen
55.5 mg/L
09/11/2017
Comment:
-
Reviewed by: Cam- �Cj-
Report #.. 2017-13135 p-- 1

ENVIRONMENTAL CHEMISTS, INC CE. "'� F,1�2 28405
Analytical & Cons"g Chemists NCDENR: DWO CERTIFICATION # 94 NCOHHS: DLS CERTIFICATION # 37729 Into0anvironmentelchemists.com
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STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF
ENVIRONMENTAL QUALITY
COUNTY OF DUPLIN '
File No. DV-2017-0080
IN THE MATTER OF
)
GREENWOOD LIVESTOCK, LLC
)
FINDINGS AND DECISION
FOR VIOLATIONS OF SWINE WASTE
) AND ASSESSMENTS OF
GENERAE PERMIT AWG100000
) CIVIL PENALTIES
PURSUANT TO NORTH CAROLINA
)
GENERAL STATUE 143-215.1
) -
Acting pursuant to delegation provided by the Secretary of the Department of
Environmental Quality and the Director of the Division of Water Resources (DWR), I, Linda
Culpepper, Interim Director of the Division of Water Resources, make the following:
I. FINDINGS OF FACT:
A. Greenwood Livestock, LLC owns and operates Greenwood Finishing #3 Farm, a
swine animal operation located Northwest of Penderlea, North Carolina on the west side
of SR 1328 (Raccoon Road) approximately 0.5 miles North of Highway 11 in Pender
County.
B. Greenwood Livestock, LLC was issued Certificate of Coverage AWS710006 under
Swine Waste Management System General Permit AWG100000 for Greenwood
Finishing #3 Farm on April 13, 2017, with an expiration date of September 30,
2019 for the operation of a swine waste collection, treatment, storage, and
application system.
C. On August 31, 2017, the Wilmington Regional Office (WIRO) received a
complaint regarding suspected animal waste in a tributary downstream from the
Greenwood Finishing Farm 43.
D. DWR staff inspected the farm on August 31, 2017 and again on September 1,
2017, and found discharged animal waste in surface waters of a tributary to Sills
Creek. 11
E. Condition 1. 1 of the Swine Waste System General Permit No. AWG100000
states in part that, "Any discharge of waste that reaches surface waters or
wetlands is prohibited."
F. On August 31, 2017, staff inspected the land application field and observed animal
waste ponding in several ditches that are adjacent to the land application fields. On
September 1, 2017, staff returned and walked the ditches and channels between the

'r`,} t
f
farm property and the tributary to Sills Creek. Staff observed animal waste in those t `
channels.
G. Condition H. 5 of the General Permit AWG100000 states in part that, "In no case
shall land application rates result in excessive ponding or any runoff during any
given application event."
H. A Notice of Violation was issued to Greenwood Livestock, LLC on October 13,
2017.
I. A response to the Notice of Violation was received by WiRO on October 27,
2017.
J. The costs to the State of the enforcement procedures in this matter totaled
$2431.47.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Greenwood Livestock, LLC is a "person" within the meaning of G.S. 143-215.6A
pursuant to G.S. 143-212(4).
B. A permit for an animal waste management system is required by G.S. 143-215.1.
C. The above -cited discharge to surface waters violated Condition I. 1.
of the Swine Waste System General Permit No. AWG100000.
D. The above -cited hydraulic overload caused animal waste to pond and runoff
which violated Condition II. 5. of the Swine Waste System General Permit No.
AWG100000.
E. Greenwood Livestock, LLC may be assessed civil penalties pursuant to G.S. 143-
215.6A(a)(2) which provides that a civil penalty of not more than twenty-five
thousand dollars ($25,000.00) per violation may be assessed against a person who
violates or fails to act in accordance with the terms, conditions, or requirements of
a permit required by G.S. 143-215.1.
F. The State's enforcement costs in this matter may be assessed against Greenwood
Livestock, LLC pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
G. The Section Chief of the Water Quality Regional Operation Section, pursuant to
delegation provided by the Secretary of the Department of Environment Quality
and the Director of the Division of Water Resources, has the authority to assess
civil penalties in this matter.
Based upon the above Findings of Facts and Conclusions of Law, I make the following:

III. DECISION:
Accordingly, Greenwood Livestock, LLC, owner of Greenwood Finishing #3 Farm, is
hereby assessed a civil penalty of-
$ 35�6�Op
$ $2431.47
$ 5q3 141
for violating Condition. I. 1. Of the Swine Waste System
GeneralPermit No. AWG100000 by failing to prevent any
discharge of waste that reaches surface waters or wetlands.
for violating Condition II. 5. Of the Swine Waste System
General Permit No. AWG100000 by not irrigating at land
application rates which would not result in ponding or any
runoff.
TOTAL CIVIL PENALTY
Enforcement costs
TOTAL AMOUNT DUE
As required by G. S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G. S. 14313-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface quantity or quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
•(6) Whether the violation was committed willfully or intentional;
(7) The prior record of the violator in complying or failing. to comply with programs over
which the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
(Date)
Linda Culpepper, Interim Director
Division of Water Resources