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Home My WebLink About090173_NOV 4-2-2020 Response_20200422Bull Creek Farms LLC 304 Fox Lake Drive Clinton, North Carolina 28328 bullcreekfarmsllcggrnail.com (910) 385-6229 April 7, 2020 Mr. Trent Allen Regional Supervisor Water Quality Regional Operations Section Division of Water Resources 225 Green Street, Suite 714 Fayetteville, North Carolina 28301 Dear Mr. Trent Allen, w h�I;EIUtD DEQIDWR APR Z Z 2020 This letter is in response to the Notice of Deficiency delivered via mail on April 2, 2020. My family and I are owner operators of Bull Creek Farms LLC No. 09-0173, Permit No. AWS090173 and are deeply regret the issues that generated the Notice of Deficiency. We are heavily involved in the North Carolina pork industry and would never intentionally do anything to harm people, animals, the environment or the industry. In the paragraphs below, I will attempt to provide information and details outlining the events surrounding the alleged offense, documents requested, and actions taken. Deficiency 1: Failure to maintain the collection, treatment, and storage facilities and the land application equipment and fields shall be properly operated and maintained at all times, %1 SA NCAC 02T.1304(b)l in accordance with Condition H 1. of Swine Waste System General Permit No. AWGI00000. February 15, 2020, I started transferring water from F3 lagoon (see attached diagram) to lagoon F 1. After building pressure at the pump, I went to lagoon F 1 to make certain water was flowing. Once this was confirmed, I traveled around to all risers, to confirm that there were no other leaks or issues. Approximately 30 minutes had lapsed from the time I started the pump until I found the broken line in the back field (see the "X" in the diagram). I immediately shut off the pump and call my sons to help contain the runoff. We gathered shovels and the tractor and began placing earthen dams in the ditch near the broken line (see the " 0 " in the diagram), to stop the flow of the runoff. Once contained and we were certain no water left our property, we placed a trash pump in the ditch and began pumping the water back to the nearest lagoon. With everything in place to contain the runoff, I called Mr. Guyton (Senior Environmental Specialist — North Carolina Division of Water Resources), to inform him of the incident. Mr. Guyton told me that he would be at the farm the next morning to review the incident. After speaking with Mr. Guyton, I was uncomfortable that our trash pump would clean up the runoff in a timely manner, so I contacted Johnny and Eric Smith (Triple S Farms & Cleaning Inc.) to assist. From that time forward, my sons and I stayed at the site with the trash pump the entire time (all night long) to ensure the dams did not break, the trash pump was still functioning and that no water would leave our site. Approximately, 8:30 am the next day (February 16, 2020) Triple S arrived to help and Mr. Guyton arrived to inspect. Triple S completed their work by early that afternoon (See attached invoice as proof of work by Triple S). After the site and ditches were completely cleaned, I contacted Ingold Irrigation to fix the broken pipes and install a gate valve (see " + " in the diagram) in the existing line. The valve was installed to isolate and close all irrigation lines on the back side of the of the farm. After Ingold completed the repair and installation of the valve, we pressure tested all the underground irrigation lines and confirmed there were no other leaks (see attached invoice as proof of work completed by Ingold Irrigation. While it is hard to estimate because of the ground water that was already in the ditch, based on the run time and the amount of water that was entering F1 lagoon, we estimate the runoff into the ditch to be less than 1,000 gallons, and at no time did the runoff leave our property. Going forward we have put the following steps in place to prevent future violations: • Broken pipe was repaired by Ingold Irrigation and lines were pressure tested to ensure no other leaks exist. • Ingold irrigation installed a gate value that would isolate the back line from the rest of the operation. This valve will always be closed during irrigation, except for times we are transferring water from the old nursery lagoons. • During any irrigation event we will inspect all risers, fields and equipment routinely to ensure all systems are operating correctly. Again, we deeply regret the recent event and will do everything in our power to ensure that our farm complies with all regulations. ly, JohnNe en'� Presi �/ Bull k Farms LLC 2 !ngoldIrrigation LLC _ _~.__'-_-'-_~__'_-___-'-.___- 1657 2/2B/2D2O Invoice 13249 - Line repair and install line valve Bull Creek Farms LLC Invoice 13249 - Line repair and install line valve 1,554.00 1,554.00 �rf goW Drrigation LLC 1030 Usbon Bridge Road Bill To Bull Creek Farms LLC John Sargent 304 Fox Lake Drive Clinton NC 28328 7t)f➢..._.._ �__A__ _AA w Wayne Lamb Q nva d, C, C Date Invoice # 2/20/2020 13249 Wayne 910-3 85-6318 Office 910-590-6157 Fax 910-529-1119 ingoldirrigation@centurylink.net x awnuv v.. YYY Y4 YA.W 6YYY W.Y8Y 6. H6y payable to. -- - P.O. number Terms Due Date Ingold Irrigation LLC Net 15 3/6/2020 Quantity Item Code Description Price Each Amount Called in by John Bull Creek 2 Parts 4" Repair Couplings 44.00 88.00 10 Pipe 4" PVC 2.00 20.00 2 Parts 6" Repair Coupling 80.00 160.00 2 Parts 6" Saddle Tees 75.00 150.00 1 Parts 6" Red Gate Valve 520.00 520.00 2 Parts Y of 2" Galy Nipples 35.00 70.00 2 Parts 2" Airvent 35.00 70.00 6 Pipe 6" PVC 4.00 24.00 4 Labor Repaired 4" trunk line in back field and put new gate valve in 6" 45.00 180.00 trunk line between farms. 4 Helper 20.00 80.00 2 Back -hoe 75.00 150.00 42 Mileage 1.00 42.00 Thank you for your business. Ta se, $1,554.00 BULL CREEK FARPOS LLC r---5�Tiple S Farms & Cleaning Inc. Invoice 2867 - Spill cleanup Bull Creek Farms LLC Invoice 2867 - Spill cleanup 2/29/2020 16%1 2,600.00 "S•" � (fy. � n a3 P� �;� �,� � G� �r � `�� %� �`N .y Z �� dy� �Y� ��s � �s ii.3;y�,aF�ri� yin;;,/�. �a• .,� � � .LtY«2eN�81 t �^,y�}�� , R '� �' Prt=`5- (s0)g8399 oC- 1J.�ING.rfa ki �31 ��a �r' J � tip �� f•'..��. ��'�j t/�/ '�" F/y_d ff 1 'Cr_.. i G' " ��.l 'y� (•.� A tress v'� n