es ROY COOPER . Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Taerim Director Water Resources” Enviroamental Quality May 21, 2018 CERTIFIED MAIL 7016 2140 0000 0562 4332 RETURN RECEIPT REQUESTED Jason Phillips H&J Nursery #1 -3 279 Johnson Church Rd Warsaw, NC 28398, SUBJECT: Lagoon Sampling - April 13, 2018 HEI Nursery #1 -3 Permit # AWS310294 Duplin County Dear Jason Phillips: ‘Thank you for your cooperation in the Division’s lagoon waste sampling efforts on April 13, 2018. On that day seven teams of Division staff sampled 35 farms and a total of 55 waste lagoons. Multiple teams were necessary to assure that teams followed proper biosecurity protocols to protect your animals. I apologize for the short notice that was provided to you by our staff. It was our intent to do the sampling as efficiently and effectively as possible with as litle disruption to you and other operators. Staff notified you as soon as possible once we were comfortable that weather would cooperate and we had staff prepared to complete the desired sampling on a single day. Complete results of the sampling are available on the NCDA&CS Agronomic Services Division PALS website and can be accessed there at your convenience, http:/www.neagr gov/agronomi/pals/ ‘The Division submitted the samples to the lab on April 13, and the standard waste analysis was performed the following week. The certified results are available to use for loading rate calculations in you waste application records. Our staff followed sampling protocol established by NCDA&CS Agronomic Sampling Folder No. 6, revised April 2014, a copy of which is included with this leter. You may at any time resample ‘your lagoons to establish updated results if you feel more representative sample is desired for future application events. One of the intents of the sampling effort was to look at observed changes in lagoon sampling results in a relatively short period of time, Our records show that a previous sampling event took place on March 17, 2018. Results of the April 13 and March 17 sampling events are shown on the following pages for each lagoon sampled on your farm. ‘The results show a significant difference in the PAN concentrations as well as other macro and micro nutrients for lagoon HIN1 And HN2 that put into questions the validity of the March 17 sampling results. It is unlikely that a lagoon make-up will change significantly in a month without significant operations cevent occurring like a lagoon sludge clean out. Staff also noted a high observed sludge blanket in your lagoon; however, have not yet obtained records of the last sludge survey to verify visual observation. For these reasons the Division has deemed the March 17 sampling results for lagoon HNI and HN2 to be invalid until additional information or explanation can be provided to justify differences in sampling results. ‘More details on the information requested to validate the March 17 sampling data is included below. -2-Nothing Compares= Sof Not Casi Enya Quay Dison of Wer Resouces ‘Water Quay Rein Operation Seton 1636 Mai Service Cen | Raleigh North Carin 276851636 s19.7079129Lagoon Sampling — April 13, 2018 Page 2 Lagoon Name: HNI ‘Sample Results (mg/l, PAN in Ibs./1000 gallons) 3/7 - 4/13 3/17/2018 4/13/2018 Difference | % change | 518, 2026 1508 291% 22 84 63 291% 39 496 458 1182% 423, 947, 524) 124% 107 622, 315, 481% 26 200 174 668% 28 479 451 1586% 2.0 327.2 [| 325.2 15955% 03 15.0 148 5574% 05 316.2 515.7 101108% 02 58.9 58.7 34955% 04 15 10 235% 164.3 663.7 499.4 304% 75 74 OT 1% 05 03 02 40% Lagoon Name: HN2 Sample Results (mg/l, PAN in Ibs./1000 gallons) 3/17 4/13 Parameter 3/17/2018 4/13/2018 Difference | % change 539 1469 930 173% 22 61 39 173% 40 307 267 660% 418) 806 388 93% 109 449) 340 312% 27 108 81 300% 29 331 302 1030% 23 223.7 221.4 95.43% 03 10.9 10.6 3645% 07 365.8 365.1 50773% 02 41s 413 18281% 05 1.0 06 118% 163.0 470.8 307.8 189% 74 76 02 3% 09 02 07 73%Lagoon Sampling ~ April 13, 2018 Page 3 Lagoon Name: __HN3 ‘Sample Results (mg/l, PAN in Ibs/1000 gallons) 3/17 - 4/13 Parameter 3/17/2018 4/13/2018 Difference | % change 556 683, 127 23% 23 28 05 23% 40 39. 2 4% 434 725 291 61% i 109 2 2% 27 13 3 50% 30 19 =I 37% 23 42 19 81% 03 03 0.0 0.6 2.6 2.0 02 05 03 04 0.8 O4 168.2 101.3, 66.9 73 79 04 0.6 jons were sampled at your farm. Concentrations reported for the three lagoons in March 2018, were noticeably more similar to one another than compared to the April sampling results. The variation found in the April 13 sampling analysis is much more consistent with normal variations found in swine lagoon effluent is NC. ‘The following two tables show the differences reported for your lagoons for the March and April Sampling Events.Lagoon Sampling ~ April 13, 2018 Page 4 3/17/2018 Sampling Results 4/13/2018 Sampling Results (mg/l, PAN in Ibs./1000 gallons) (mg/l, PAN in Ibs./1000 gallons) ‘Lagoon ID Lagoon ID Parameter | HN1_| HN2 | HN3 | Range | | Parameter | HN1_| HN2 | HN3 | Range 518 | 539 | 556 | 38 2026 | 1469 | 683 | 1344 22 22 23 | 02 84 61 2.8 56 39. 40 40 2 496 | 307 39. 458 43 | 418 | 434 | 16 947 306 | 725 | 222 107 | 109 | iit 4 622 | 449 | 109 | 514 26 27 27 1 200 108 B 187 28 29 30 1 479) 331 19 460 2.0 23 23 | 03 3272 | 223.7 | 42 | 3230 03 03 03 | 00 150 | 109 | 03 148 05 07 06 | 02 5162 | 3658 | 26 | 5135 02 02 02 | OL sao | 415 | 05 | 584 04 05 04 | 00 15 1.0 08 07 663.7 | 470.8 | 101.3 | 5624 TA 16 19 05 164.3 | 163.0 | 1682 | 5.2 75 74 75 | O01 05 09 o6 | 0s 03 02 Asa result of initial evaluation of the sampling results the Division will be conducting additional evaluation of historic data at your farms and at the other farms that were sampled on April 13, 2018. It is necessary to further investigate the unusual changes in lagoon characteristics between March 17 and April 13, 2018, ‘To assist in the investigation Wide the following to the Wilmington Regional Office no later than June 21, 2018. Results of the last 2 years of shidge survey, including information on who conducted the survey. Records of any sludge removal that occurred between March 17 and April 14, 2018. Any operational changes that may have contributed to the lagoon characteristics between March 17 and April 13, 2017. ‘© Results of any additional lagoon waste analysis for the lagoon in question conducted since March 17, 2018 Please contact the Wilmington Regional Office at (910) 796-7215 or Christine Lawson at (919) 807- 6354 if you have further questions. Sincerely, € Ton. Ce Chief, Water Quality Regional Operations Section Division of Water Resources Enclosure cc: Wilmington WQROS Regional Supervisor WOQROS Central Files