710006_Response to Notice_20171027

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GREENWOOD LIVESTOCK, LLC
POST OFFICE BOX 535
ELIZABETHTOWN, NC 28337
October 23, 2017
Mr. Jim Gregson, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office DWR,NCDEQ
127 Cardinal Dr. Extension
Wilmington, NC 28405
Dear Mr. Gregson,
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) 1 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 8B & 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 fortheto pull the reels back out fora 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 31 st 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 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.
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 96-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.'

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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 $86,000 to
hire an aerway 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 ad, 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 out -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. -
Sincerely,
Dean Hilton