ROY COOPER Governor MICHAEL 8. REGAN Seeretary Water Resources LINDA CULPEPPER nviroamental Quality “interim Director May 21, 2018 CERTIFIED MAIL 7016 2140 0000 0562 4387 RETURN RECEIPT REQUESTED Terry Miller Terry Miller Farm sites 182 1816 Pasture Branch Rd Beulaville, NC 28518 SUBJECT: Lagoon Sampling - April 13, 2018 ‘Terry Miller Farm sites 182 Permit # AWS310445 Duplin County Dear Terry Miller: ‘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 little 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. Ittp:/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 letter. 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 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 event 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 TMI and TM2 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. ->-Nothing Compares=- Sate of North Carolina Eavironmentl Quality | Division of Water Resources ‘Water Quality Regional Operations Seton 1636 Mail Service Cee | Raleigh, Nort Cron 27688-1636 919-707-9129Lagoon Sampling ~ April 13, 2018 Page 2 Lagoon Name: __ TMI ‘Sample Results (mg/l, PAN in Ibs./1000 gallons) 3/17 4/13, Parameter 3/17/2018 4/13/2018 Difference | % change Tay 522 1403 881 169% a 22 59 37 169% 40 266 226 560% 502 1230 728 145% 107 315) 208 194% 26 109 3 318% 28 184 156 354% 23 105.4 103.1 168% 03 62 59 1942% 05 178.1 177.6 34751% 02 23.5 23.2 9634% 05 16 12 251% 155.9 322.1 166.2 107% 72 76 04 6% 0.6 O1 04 15% ‘Sample Results (mg/l, PAN in Ibs/1000 gallons) 3/17 - 4/13 3/17/2018 4/13/2018 Difference | % change 525 1038 513 98% 22 43 21 98% 40 cy 28 70% 481 1234 734 157% 107 117 10 9% 26 16 10 3% 27 36 8 31% 24 86 62 255% 03 06 03 96% 05 1s 11.0 2030% 02 19 17 820% 05 1S ie 225% 150.4 170.8 [| 204 14% 74 19 0s T% 07 0.0 07 -99%Lagoon Sampling — April 13, 2018 Page3 ‘Two lagoons were sampled at your farm. Concentrations reported for the two 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. 3/17/2018 Sampling Results 4/13/2018 Sampling Results (mg/l, PAN in Ibs./1000 gallons) (mg/ PAN in Ibs./1000 gallons) ‘Lagoon ID ‘Lagoon ID Parameter | TM1_| TM2 Range Parameter | TM1_| TM2 Range 522 | 525 3 1403 | 1038 365 22 | 22 0.0 39 43 13 40 40. 0 266 68 198 302 | 481 21 1230) 1234 4 107 | 107 0 315 |_i117 198 26 26 0 109 16 93 28 27 1 184 36 148 23 | 24 on 105.4 | 86 96.7 03 | 03 0.0 62 06 56 05 05 00 178.1 | 115 1663 02 | 02 0.0 235 | 19 21.6 05 05 00 16 15 on 1559 | 1504 35 322.1 | 1708 1513 72 | 74 02 76 79 03 06 | 07 Ol On 0.0 On ‘As a 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 please provide the following to the Wilmin gion Regional Office no later than June 21, 2018. ‘© Results of the last 2 years of sludge 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‘Lagoon Sampling ~ April 13, 2018 Page 4 Please contact the Wilmington Regional Office at (910) 796-7215 or Christine Lawson at (919) 807- 6354 if you have further questions. Sincerely, co (eA nigdd Chief, Water Quality Regional Operations Section Division of Water Resources Enclosure ce: Wilmington WQROS Regional Supervisor WQROS Central Files