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According to the NC Cooperative Extension in its pamphlet titled “Soil Facts: Nutrient Removal by Crops

in North Carolina,” [see Appendix C] Coastal Bermudagrass has a minimum removal rate of 400 lbs. of

nitrogen/acre/year. Thus, the wastewater applied to the fields is expected to contain less nitrogen –

approximately 42% less nitrogen – than the cover crop is able to remove.

Furthermore, the NC Cooperative Extension in its pamphlet “Soil Facts: Nitrogen Management and Water

Quality” [see Appendix C] notes that many crops have inefficient nitrogen utilization rates. In other

words, many crops can typically use only about 50% of the nitrogen applied to the field. In contrast the

pamphlet continues, “Research in North Carolina has shown that 90 percent or more of the nitrogen

applied to sod crops (such as bluegrass or Coastal Bermudagrass) is commonly recovered.” Thus the

proposed cover crop is more efficient in nitrogen removal than typical crops.

In addition to its high rate of nitrogen uptake, according to the County Extension director [See Appendix

C], a managed Bermudagrass hay field requires fewer insecticides and herbicides than other crops

typically grown in Nash County.

Once the land application system is in service, it is expected that the DWQ permit will require on-going

groundwater and surface water monitoring to prevent the over-application of treated effluent and to

ensure treatment is sufficient to protect ground and surface water quality. [See Appendix C for WWTP

data at Sanderson’s Moultrie, GA and Kinston, NC facilities and for Groundwater Data at its Moultrie,

GA facility. It also includes 15A NCAC 02T Section .0500 – Wastewater Irrigation Systems, the state

code that regulates sprayfield permitting.] Groundwater nitrate must meet drinking water regulations in

the monitoring wells.

In addition, poultry litter generated by the growing houses will be required to be managed in accordance

with the policies of the state and those of the company. According to North Carolina General Statute

§143-215.10C (see “Dry Litter Poultry Requirements” published by the Division of Water Quality in

Appendix D), dry litter poultry operations are deemed permitted. This means these operations do not

have to apply for permits, but must meet a list of state requirements.

The Division of Water Quality’s requirements are intended to ensure that nutrient release from dry litter

to ground or surface waters or the atmosphere is minimized. These requirements include setbacks from

perennial streams and wells for stockpiles and application of litter, and mandatory covering of litter for

periods over 15 days in length to prevent the loss of nutrients to the air and to water through runoff during

storage. For land application of the litter, DWQ requires that application rates of nutrients shall not

exceed the agronomic rates of the receiving crop. Therefore, over-application of litter in excess of NRCS

standards would be a violation of NCGS §143-215.10C.

Manure hauling will be required to be done in accordance with 15A NCAC 02T.1400. [See Appendix D.]

These activities are deemed permitted by the state and require similar setback and application restrictions

as those for dry litter. Under both litter and hauling operations, the state and DWQ require additional

reporting to DWQ and Waste Utilization Plans when a threshold quantity is reached by any single farm or

hauler. In this manner, large operations are regulated by the state and can be monitored to the extent

required by the Division.

As an additional measure to ensure environmental regulations are followed by its contract growers,

Sanderson Farms includes the following language in its standard grower contract:

“Dead Bird and Litter Disposal. The Grower, at his or her expense, will dispose of all dead

birds and used litter in a timely manner in compliance with all federal, state and local laws and

regulations and the Broiler Growing Program. Failure to do so (regardless of whether or not

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The same study references the joint 1999 USDA-USEPA report titled Unified National Strategy

for Animal Feeding Operations which states that “land application is the most common, and

usually most desirable method of utilizing manure because of the nutrients and organic matter.”

Reference is also made to the comments about poultry litter presented by the Nash County

Extension Director in Section D.8 Solid Waste Management.

In summary, the over-application of manure can have negative impacts on water quality as cited

in the commenter’s text. It is with proper management – in accordance with the laws,

requirements, and permits established by North Carolina – that the facilities will be required to

operate. It is therefore expected that the impacts to water quality in the basin as a result of this

facility, even in combination with the new facility in Kinston, will be minimal.

3. Groundwater Pollution – The comment references a study in Wilkes County, North Carolina in

which the effects of long-term poultry litter application on groundwater quality was studied. The

study investigated a total of three (3) sites.

It is not initially known if the litter application studied was managed properly and in accordance

with DWQ requirements. What is noted in the study’s abstract found at

http://ngwa.confex.com/ngwa/expo07/techprogram/P4597.HTM is that, “The concentration of P

(phosphorus) in the top/shallow soil was detected above the North Carolina Department of

Agriculture Agronomic Division’s soil test P index (P-I) level of 100. When P-I is greater than

100, plants will not respond to additional P.” Though it is not stated, it is clear that the soil

described in this study had endured an over-application of nutrients – to the extent that additional

phosphorus addition would have no impact on plant growth.

Reviewing the soil test criteria information provided by the North Carolina Department of

Agriculture and Consumer Services (http://www.ncagr.gov/agronomi/obpart1.htm), the following

description of the soil test scale for elements such as phosphorus states:

“The index rating system: P, K, Mn, S, Zn & Cu: As explained on the soil test report, the

Agronomic Division reports phosphorus (P), potassium (K), manganese (Mn), sulfur (S), zinc

(Zn) and copper (Cu) levels as indices. The index scale used for fertilizer recommendation ranges

from 0 to 100. The relationship between soil test index and fertilizer requirement is shown in

figure below.

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The critical quantitative value for each nutrient is assigned an index of 25. Values of 25 or below

indicate low soil fertility, a high fertilizer requirement and potentially dramatic yield increases in

response to fertilization. Values from 26 to 50 indicate medium fertility; those above 50, high

fertility. Values above 100 are considered excessive and show no response to fertilizer

application. Certain micronutrient levels above a 250 index can be detrimental to crops.”

It is clear from the information provided that phosphorus level in excess of 100 means that the

level is “in excess of plant requirements.” Therefore, it is concluded that the negative effects to

groundwater cited in the commenter’s study were more likely from the mis-management of

poultry litter rather than a proper management.

The proper application of poultry litter is a valuable and common fertilizer method. As stated by

the Virginia Cooperative Extension Service in its on-line article Land Application of Broiler and

Turkey Litter for Farming Operations Without a DEQ Permit (http://pubs.ext.vt.edu/442/442-

052/442-052.html), “Poultry litter (poultry manure and a bedding material such as sawdust, pine

bark, or peanut hulls) is a good source of nutrients and organic matter for growing crops. Land

application of poultry litter on farms has been the mainstay of effective and safe usage for years.

Unfortunately, improper management of litter applications may cause nutrient enrichment and/or

contamination of surface and ground water resources. The key to proper management is an

understanding of the nutrients available in the litter, the nutrient requirements of the crops to be

produced, and the potential for the litter and/or nutrients to reach surface or ground waters.”

In addition to managing the amount of nutrients that should be applied, the DWQ requirements

also require setbacks for litter application from wells and surface waters.

The contract farms associated with the project will be required to comply with NC DWQ

requirements, county requirements, and company policies for the proper management of poultry

litter and its application. In this manner, deleterious effects to ground and surface waters can be

avoided.