540062_signed letter_20200121

January 21, 2020
Rodney Smith
Southpork Farm
367 Jonestown Rd
Pink Hill NC 28572
David May
Division of Water Resources
Washington Area Regional Office
943 Washington Square Mall
Washington, NC 27889
Mr. May -
I received your Notice of Recommendation of Intent for the Southpork Farm on January 21, 2020. I
would like to provide some additional documentation that you have requested, along with my future plans
to fix each violation that was found. I have been working with my technical specialist and we have
worked on a plan for the farm.
Southpork Farm
AWS540062
NOV-2020-PC-0017
Violation #1
Failure to provide a sludge clean out plan and other records associated with it in accordance with the
facility's CAWMR
MJ' BLsP_w :
I have been in contact with my private consultant, who was onsite during the inspection, and he did not
provide you with the records that I had for the sludge application. You will find attached to this document
the sludge management plan, application records, soil samples, waste analysis, maps of fields, and copy
of the power of attorney that I have for the farms on which sludge was applied. I received cost share
appropriation from the Division of Soil and Water Conservation for the sludge cleanout on this farm in
this lagoon.
Please review the attached documents regarding my sludge application. I apologize for not having it
available during the inspection.
Violation #2
Failure to update the waste management plan to reflect changes in accordance with the facility's CAWMP.
y Response:
I consulted with my technical specialist, Extension Agent Eve Honeycutt, when she was onsite in May of
2018. She advised me that my waste plan should be re -written to reflect the grazing that was occurring.
She updated my waste plan in May of 2018 and I have attached it to this document. Once again, I
apologize that my consultant, who was on -site for the inspection, did not provide this information.
Please review this document and let me know if you find any lacking information.
Violation #3
Failure to maintain a compliant level of sludge in the old lagoon in accordance with the facility's
CAWMP.
My Res o
This violation was the result of some miscommunication, which was my fault. My consultant provided
sludge surveys on my lagoons which indicated that the #1 (old) lagoon was out of compliance and needed
to have sludge removed. I contacted my local soil and water conservation staff to fill out an application
for cost -share in 2016. I began planning for sludge removal but those years were extremely wet. The
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order to receive the cost share allocation, I had to complete the cleanout within their time restrictions. So
in May of 2018, we finally were able to complete our plans for clean out.
I was told by my consultant that the # 1 (old) lagoon needed the clean out. Based on the layout of my
farm, I incorrectly assumed that the old lagoon was the one nearest the wood line. So that is what I told
the cleanout company. As soon as they finished, my consultant stopped by and told me that was not the
correct lagoon. The #1 (old) lagoon is actually closest to the road, and the newer lagoon is by the wood
line. So it was actually the newer lagoon from which sludge was removed.
Because this mistake was a result of my misunderstanding, I have taken some proactive steps to manage
the sludge levels in both lagoons. On January 24, 2020, I asked Eve Honeycutt to come out and do
another sludge survey on the old lagoon. The results of that survey are attached to this letter. The sludge
ratio is 0.61. I will apply for cost share to finally complete the sludge cleanout on the old lagoon. If the
cost share application is not approved, then I will pay for the sludge removal to bring the level back into
compliance. This should resolve the sludge issues on the farm.
Summary
I hope you have all you need to address these violations. Violations 1 & 2 would not have occurred if my
consultant had provided the sludge removal documents and the corrected waste plan. Violation #3 was
my fault and a result of a misunderstanding. Communication is key to having a good inspection and I
will be communicating more with my consultant to make sure these types of oversights do not happen
again. Please let me know if you need anything else from me to correct these violations.
Sincerely, n
,vim �
Rodney Smith, Owner
Southpork Farm