960119_NOV issued on 2-10-2021 Response_20210303

March 3, 2021
To NC DWR Washington Regional Office Staff:
This letter is in response to the "Notice of Violation" issued Feb 10, 2021 to Craig #3,
AWS960119 in Wayne County. The NOV mentioned two violations and this letter is to address
both of those.
Violation #1: Overapplication of PAN on small grain crop
All of the waste plans for our other farms have 100 lb overseed PAN rates, this
plan did not. It was not realized until after application that the overseed was only listed for 501bs
on this specific plan, which had not been updated. This correction has been made to our new
waste plan, attached, and you will see that it has the 100 lb overseed in the plan as needed.
It is now in our current waste plan to allow the 100 lb PAN overseed on our winter small grain
crop.
The 25 lb PAN rule in January, was not put into effect until 2017, via a change by
DWR/DEQ. As such, again on this plan that had not been updated since, the operator was
unaware of the 25 lb rule. It is put into place on our new, current waste plan, as you will see
in the attachment. During this extremely wet winter, we received excessive rainfall amounts,
with over 5" falling in January alone, the choice to apply in good weather or risk a discharge,
was in effect. That, along with the ignorance of the new rule, resulted in application of more than
25 lbs in January 2021. Now that the operator has been made aware of the changes, and the
regulations, that will not happen again and the waste plan will be followed.
Violation #2; Hydraulic Overloading Rates
Application of more than 27, 154 gallons per acre on fields 7, 8, and 12 on the
2020 Bermuda hay was a simple oversight on the part of the operator. The system ran too long,
and although it was checked every 120 minutes, it did not match up with the waste plan
requirements. The plan has been updated, the operator informed, and the issue will not happen
again.
Corrective Actions:
• Waste plan has been updated to include the 100 lb PAN overseed amount, the memo
stating this is in effect, and the 25 lb PAN rule for January applications (put into effect in
2017)
• The operator has been made aware of all the changes and thoroughly understands the
waste plan
• Any questions or concerns will be addressed prior to applications, with Wayne County
Soil and Water Conservation District Office as well as the Wayne County Cooperative
Extension Livestock Agent to make sure everything is done properly

March 3, 2021
Please contact us with any other questions or concerns regarding this NOV. The problems fisted
above have been addressed, understood, and rectified. They will not happen again.
Debra Craig, Owner
Craig #3, AWS 960119
3/Ez.t,
Shane Craig, Operator in Charge
Craig #3, AWS 960119