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Sanderson Farms project in Nash County, N.C. environmental impact statement. Part 1 of 2.
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Environmental Impact Statement – Draft Project Baseball – Wastewater Improvements, Nash County, North Carolina 28 of 377
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
Environmental Impact Statement – Draft Project Baseball – Wastewater Improvements, Nash County, North Carolina 163 of 377
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.
Environmental Impact Statement – Draft Project Baseball – Wastewater Improvements, Nash County, North Carolina 164 of 377
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.